PB95-964010
EPA/ROD/R04-95/217
March 1995
EPA Superfund
Record of Decision:
Green River Disposal, Inc,
(O.U. 1), Maceo, KY
12/14/1994
-------
GREEN RIVER DISPOSAL LANDFILL
SUPERFUND SITE
RECORD OF DECISION
U.S. Environmental Protection Agency
Region IV
DECEMBER 14, 1994
-------
GREEN RIVER DISPOSAL LANDFILL SUPERFUND SITE
RECORD OF DECISION
TABLE OF CONTENTS
SECTION PAGE
DECLARATION FOR THE RECORD OF DECISION iii
DECISION SUMMARY I
»•
1.0 BACKGROUND 1
1.1 Site Location 1
1.2 Site Description 1
1.3 Site History 3
2.0 COMMUNITY PARTICIPATION 5
3.0 SCOPE AND ROLE OF THIS RESPONSE ACTION 6
4.0 SUMMARY OF SITE CHARACTERISTICS 7
4.1 Hydrogeology 7
4.2 Surface Water and Sediment 8
4.3 Soil 8
4.4 Leachate Seep, Sediment and Pond Characterization 10
4.5 Landfill Waste Characterization 11
Exploratory Trenching and Waste Sampling 11
4.6 Characterization of Surface Water, Sediment
and Soil in the East and West Ravines 12
4.7 Air Quality Characterization 13
5.0 SUMMARY OF SITE RISKS 14
5.1 Summary of Human Health Risks 15
5.1.1 Constituents of Concern 15
5.1.2 Exposure Assessment 15
5.1.3 Toxicity Assessment 16
5.1.4 Carcinogenic and Noncarcinogenic Risks
for the Green River Disposal Landfill 17
5.1.5 Carcinogenic and Noncarcinogenic Risks
for Kelly Cemetery Road Site 19
5.1.6 Comparison to Regulatory Guidance and Criteria 19
5.2 Summary of the Ecological Assessment 20
6.0 DESCRIPTION OF REMEDIAL ALTERNATIVES 22
6.1 Landfill Remedial Alternatives 23
6.1.1 Landfill Alternative 1 25
-------
GREEN RIVER DISPOSAL LANDFILL SUPERFUND SITE
RECORD OF DECISION
TABLE OF CONTENTS
(continued)
6.1.2 Landfill Alternative 2 25
6.1.3 Landfill Alternative 3 26
6.1.4 Landfill Alternative 4 26
6.1.5 Comparative Analysis of Landfill Alternatives «27
6.2 Leachate Remedial Alternatives 29
6.2.1 Leachate Alternative 1 29
6.2.2 Leachate Alternative 2 . . . . 30
6.2.3 Leachate Alternative 3 30
6.2.4 Comparative Analysis of Leachate Alternatives 32
6.3 Sediment Remedial Alternatives 33
6.3.1 Sediment Alternative 1 34
6.3.2 Sediment Alternative 2 34
6.3.3 Sediment Alternative 3 34
6.3.4 Comparative Analysis of Sediment Alternatives 34
7.0 THE SELECTED REMEDY 36
7.1 Performance Standards 37
7.2 Modifying Criteria 38
7.2.1 State Acceptance 38
7.2.2 Community Acceptance 38
8.0 STATUTORY DETERMINATIONS 40
8.1 Overall Protection of Human Health and
the Environment 40
8.2 Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs) 40
RESPONSIVENESS SUMMARY 44
1.0 OVERVIEW 44
2.0 BACKGROUND ON COMMUNITY INVOLVEMENT 44
3.0 SUMMARY OF MAJOR PUBLIC COMMENTS RECEIVED
DURING THE PUBLIC COMMENT PERIOD, AND EPA
RESPONSES 45
-------
GREEN RIVER DISPOSAL LANDFILL SUPERFUND SITE
RECORD OF DECISION
TABLE OF CONTENTS
(continued)
TABLES
Table 1 Industrial Wastes Contained in the Landfill (Page 4)
Table 2 Constituents Detected in Leachate Sediment Samples, August 1990 •
Table 3 Constituents Detected in Leachate Seep Water Samples, August 1990
Table 4 Constituents Detected in Leachate Water Samples, January 1993
Table 5 Constituents Detected in Ambient Air
Table 6 Constituents Detected in Surface Water
Table 7 Chemicals Detected in Surface Water Sediments
Table 8 Constituents Detected in Leachate Water
Table 9 Constituents Detected in Soil from Kelly Cemetery
Table 10 Exposure Routes Considered
Table 11 Toxicity Values for Potential Carcinogenic and Noncarcinogenic Effects
Table 12 Summary of Site Human Health Risks for the Landfill
Table 13 Summary of Site Human Health Risks for the Kelly Cemetery Road Site
Table 14 Comparison of Surface Water Ecological COG Concentrations to Ambient
Water Quality Criteria
Table 15 Ecological Risk Summary for Surface Water
Table 16 Ecological Risk Summary for Leachate Water
Table 17 Ecological Risk Summary for Surface Water Sediments
Table 18 Risk Assessment and Remedial Action Conclusions for Each Media
111
-------
GREEN RIVER DISPOSAL LANDFILL SUPERFUND SITE
RECORD OF DECISION
TABLE OF CONTENTS
(continued)
FIGURES
Figure la&b Site Location Map
Figure 2 Site Plan . ;
Figure 3 Site Watershed Map
Figure 4 Hydrogeologic Cross-Section, SE to NW Across the Landfill
Figure 5 Potentiometric Surface Map, Groundwater Elevations, January 13,1993
Figure 6 Sediment and Surface Water Sample Locations
Figure 7 Soil Sampling Locations Along the Landfill Perimeter
Figure 8 Grid for Statistical Sampling and Background Locations at the Kelly
Cemetery Road Site
Figure 9 Leachate Seep and Pond Samples, January 1993
Figure 10 Areas of High Apparent Conductivity and In-Phase Disturbance
Encountered During the Geophysical Surveys
Figure lla Isopach Map of the Fill Material Within the Landfill
Figure lib Cross-Section A-A' and B-B' Through the Landfill, Showing Pre-Landfill
and Present Landfill Surfaces
Figure 12 Exploratory Trench Location Map
Figure 13 Estimated Grade and Area! Extent of the Landfill Cap
Figure 14 Generalized Cross-Sections of the Capping Options Evaluated
Figure 15 Cross-Section of a Typical Leachate Interceptor Drain
Figure 16 Conceptual Process Flow Diagram for Leachate Treatment
Figure 17 Areas of Concern
IV
-------
GREEN RIVER DISPOSAL LANDFILL SUPERFUND SITE
RECORD OF DECISION
TABLE OF CONTENTS
(continued)
APPENDICES
APPENDDC A Commonwealth of Kentucky Concurrence Letter for the Record of
Decision
v
APPENDK B Proposed Plan Public Meeting Transcripts
-------
DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Green River Disposal Landfill
Kelly Cemetery Road
Maceo, Daviess County, Kentucky
Statement of Basis and Purpose
i-
This Record of Decision presents the selected remedial action for the Green River
Disposal Landfill site, located in Maceo, Daviess County, Kentucky. The remedial
action selected conforms with the requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP). This decision document is based on the information contained in the
Green River Disposal Landfill Administrative Record.
The Commonwealth of Kentucky Department for Environmental Protection
concurs with the selected remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in this Record of
, Decision, may. present an imminent and substantial endangerment to public
health, welfare, or the environment.
Description of the Selected Remedy
Based on the findings of the Remedial Investigation and Risk Assessment, three
problem areas of the site requiring a cleanup remedy are: the landfill waste;
leachate; and contaminated sediment in the sedimentation pond and unnamed
intermittent stream.
The objectives for the remedy selected are:
• Prevent direct exposure of the landfill waste by humans and fauna
• Prevent infiltration of water into the landfill waste and limit the potential
migration of hazardous substances to the groundwater and nearby stream
• Prevent direct exposure of leachate by fauna
• Prevent direct exposure of contaminated sediment by fauna
-------
Based on the Remedial Investigation, the Baseline Risk Assessment, and the
Feasibility Study, the selected remedy consists of following components:
1. Capping the landfill (waste disposal) area with a composite barrier cover
(the exact configuration and cover system components will be determined
during the design process).
2. Collection of the leachate with subsurface drains, and treatment by
chemical and/or physical methods. Treated water will be discharged to the
unnamed stream.
»•
3. Excavation of contaminated stream and pond sediment and consolidation
with the landfill waste.
4. Removal of surface debris and/or buried wastes located in the east and
west ravines, and dispose these wastes within the landfill cap.
This Record of Decision does not provide a final determination on groundwater
quality at the site or provide a basis for selecting a groundwater remedy. The
data collected during the remedial investigation did not conclusively provide a
direct relationship between the landfill waste and groundwater quality at the site.
Therefore, EPA will require additional groundwater monitoring to sufficiently
determine groundwater quality at the site and conclusively establish the landfill's
impact to the groundwater.
Declaration
The selected remedy is protective of human health and the environment, attains
Federal and State requirements that are legally applicable or relevant and
appropriate to the remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternate treatment technologies/methods to the
maximum extent practicable. 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 remaining on-site above
health-based levels, a review will be conducted within five years after
commencement of remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
Richard D. Green Date
Associate Director
Office of Superfund and Emergency Response
TT
-------
DECISION SUMMARY
1.0 BACKGROUND
1.1 Site Location
The site is located in Daviess County approximately 12 miles northeast of Owensboro,
Kentucky, in the community of Maceo (Figure 1). The site is located within the
Lewisport, Kentucky - Indiana USGS 7.5 Minute Topographic Quadrangle; its
approximate coordinates are 37° 53' 30" latitude and 86° 58' 30" longitude.
v
1.2 Site Description
The Green River Disposal Landfill Site (site) is comprised of two separate areas: the
Green River Disposal Landfill (landfill) and the Kelly Cemetery Road (KCR) Site.
The landfill is a 14-acre tract of land formerly permitted by the state of Kentucky for
disposal of industrial solid waste. The Kentucky Department of Environmental
Protection (KDEP) initially denned the KCR Site as a 4-acre tract of undeveloped
land adjacent to the eastern property boundary of the landfill where drummed waste
had been placed. From a review of the KDEP files, the location of the 4-acre tract
was not apparent. State file maps indicated that three distinct locations within a 25-
acre area north of Kelly Cemetery Road contained drums. When the drums were
removed in 1985, the former locations were not well documented by the KDEP. As
a result, the area (25 acres) between the Kelly Cemetery Road and the bottom of the
ravine located north of Kelly Cemetery Road was investigated (Figure 2). Based on
information collected during the RI, only 4 of the 25 acres which were investigated
likely define the KCR Site.
The topography of the area surrounding the site is characterized by knobs connected
by long, narrow ridges and steep hillsides and ridge tops. The ridges and knobs are
dissected by intermittent stream channels and small streams. Ground-surface
elevations vary from about 550 feet (above the North American Geodetic Vertical
Datum (NGVD) on ridgetops to about 400 feet along the major valleys. The ridge and
valley topography is bordered by the Ohio River floodplain, which is at an average
elevation of about 390 feet NGVD. Figure 3 is a portion of the USGS 7.5 minute
Lewisport KY-IND quadrangle map showing the site location and tile surrounding
topographic features.
Kelly Cemetery Road, located along a narrow ridge line, marks the southern border
of the site. The topography slopes downward from Kelly Cemetery Road to the north
where a narrow valley occupied by an unnamed intermittent tributary is located at
the base of the landfill. Elevations range from about 520 feet NGVD along the road
to between 380 and 415 feet NGVD at the tributary. Chestnut Grove Road is located
on a ridge north of the unnamed tributary.
-------
Record of Decision
Green River Disposal Landfill Site
The unnamed tributary flows to the west into a sedimentation pond located
topographically downgradient of the landfill outside of the Green River Disposal, Inc.,
property boundary but within the site boundaries as shown on Figure 2. The
sedimentation pond is within the Browning Ferries Industries (BFI) property and was
designed and built as part of the landfill closure activities. The sedimentation pond
also receives drainage from other intermittent tributaries in the valley. The pond
outfall continues west approximately 2000 feet where it meets Little Blackford Creek.
Little Blackford Creek flows into Blackford Creek and then into the Ohio River. Tlie
travel distance of surface water flow from the site to the Ohio River is approximately
3 miles.
The study area watershed occupies approximately 187 acres. Chestnut Grove Road
follows the northern boundary of the watershed, and Kelly Cemetery Road marks the
major portion of the southern boundary. Immediately west of the site, the watershed
border diverges from Kelly Cemetery Road and follows a northwest ridge to Little
Blackford Creek. The area of the watershed topographically upgradient of the
sedimentation pond is approximately 114 acres. Figure 3 illustrates these features.
The western side of the landfill is comprised of a steep ravine with a northwest
downward sloping axis. Although landfilling activities have not occurred in this area,
isolated areas containing deteriorated empty drums and drum debris have been
observed on the land surface. The typical slope of the sides of the ravine range from
35 to 45 percent (%). The intermittent stream in the ravine flows off site to the
northwest at a gradient of 7%.
The landfill topography slopes north and has variable gradients: near Kelly Cemetery
Road, the slope ranges from nearly flat to approximately 15%; in the center of the
landfill, the slope ranges from 20% to 30%, and at the base, near the unnamed
tributary to Little Blackford Creek, the slope ranges from 13% to 17%.
The western portion of the KCR Site includes grids Kl through K4, K6, K7 and K8.
A steep ravine separates the landfill from the KCR Site. Landfilled materials
consisting of tile and construction debris were encountered in grid Kl during
exploratory trenching activities. Empty drums and drum debris were observed on the
land surface in the ravine below Kl, and empty drums and drum debris were
observed in grids K4, K6 and K7. Irregular topography was observed at the western
boundary of K8 (common to K7) and may indicate the presence of drum debris. The
remainder of K8 is heavily wooded and no evidence of drums or landfilling has been
detected in this area. Slopes in this area range from 20 to 22 % to the north.
-------
Record of Decision
Green River Disposal Landfill Site
The eastern section of the area investigated as part of the KCR Site is composed of
grids K5 and K9 through K25. This area is the eastern head of the valley formed by
the unnamed tributary. The topography slopes to the west at 10% to 30%. The area
is wooded and does not contain buried waste material or drums.
The site is located in a sparsely populated area of Daviess County, near the town of
Maceo. Land use in the site area ranges from undeveloped deciduous forests, to
farmland, to scattered residential development. Thirty-seven occupied residences are
located within a one-mile radius of the site. The typical crops of the area include corn,
livestock, soybeans, and tobacco.
Recreational activities in the area around the site include hunting, fishing, and dirt
bike riding. The landfill area, portions of the unnamed tributary, and sedimentation
pond are currently fenced, discouraging access for potential recreational activities in
on the site. Hunting may occur at the KCR Site since it is not fenced.
A door-to-door well survey was conducted at dwellings located within a one-mile
radius of the Green River Disposal Site in order to assess the usage of groundwater
in the area. There are ten occupied dwellings, possessing at least one well for
drinking, bathing, cooking and other domestic uses. Other dwellings in proximity to
the site are serviced by a public water supply system.
1.3 Site History and Enforcement Activities
The Green River Disposal, Inc., Landfill was operated from 1970 to 1983. Initially the
site contained two landfills, Reliable Sanitation Company, Inc., (also known as the
W. D. Coleman landfill) and the Dyer Salvage Company, which were merged to form
the landfill. An approximate 14-acre tract of land was authorized by the State to
receive specific industrial wastes from numerous local companies. Table 1, on page
4, is partial list of the industrial wastes believed to be disposed of in the landfill.
Because of the topography of the site, the waste was pushed into the ravine and
covered with soil.
The landfill was closed in 1983. During and after its operations, the landfill was
investigated by the Kentucky Division of Waste Management (KDWM). In January
1983, the facility entered into an Agreed Order with the KDWM and a formal
Closure Plan was submitted.
-------
Record of Decision
Green River Disposal Landfill Site
A construction permit was issued on
March 30, 1983 by the KDWM for a
sedimentation basin. The construction
date of the sedimentation basin/pond is
unknown.
The landfill was reviewed on June 8,
1987, by the KDWM and rated at 31.24
on the HRS scoring package. In response
to comments received by the USEPA
regarding the HRS scoring package, the
final score was reduced to 29.12. The site
was placed on the NPL in August 1990.
In 1985, following an investigation by
KDEP, 776 drums were staged and
removed from the KCR Site located
adjacent to the eastern property line of
the landfill. The drums were staged and
removed under supervision and approval
of KDEP.
Industrial Wastes Contained
in the Landfill
* Spray Booth Paint Sluefere
* 2Znc Phosphate Tank Bottorn
Sludge 1 v
* Cured Epoxy Resin *
• &fecf Paint fitter Waste
* Phenotic Resins
•* Coagulated latex
* CresyiicAdd
* Fainfjine Wastewater Treatment
Sludge
• Aluminum Dross Sattcake
• Waste Rolling OK
* Steef Dtsf
* Asbestos Containing Waste
• Pulverized Aluminum
TABLE 1
In 1990, through an Administrative Order
(AO) issued by EPA, Immediate Response activities were initiated. These activities
included: residential well survey and sampling, construction of a security fence,
sampling to characterize the leachate, geophysical surveys of the landfill, construction
of a temporary leachate control and collection system for the landfill, and installation
of a temporary cover over the landfill.
An Administrative Order on Consent (AOC) between EPA and four Potentially
Responsible Parties (PRPs) to conduct a Remedial Investigation (RI) and Feasibility
Study (FS) was signed in May 1990. The RI field activities were initiated in October
1991, and the combined RI/FS was completed in June 1994.
-------
Record of Decision
Green River Disposal Landfill Site
2.0 COMMUNITY PARTICIPATION
A Community Relations Plan (CKP) was developed to establish a framework for
community relations activities at the Green River Disposal Landfill Site. The Plan
outlines the community relations program, which was designed to provide the public
with: an opportunity to participate in the decision-making process; information to
remain informed on planned and current site activities; and access to EPA staff to
efficiently communicate the community's concerns. The CRP, dated November 6,
1990, was implemented throughout the Remedial Investigation and Feasibility Study
(RI/FS), and is consistent with the requirements of CERCLA §113(kX2XB) and §117.
Prior to the start of the remedial investigation, in November 1990, EPA issued a Fact
Sheet describing the Super-fund process and the planned RI/FS activities. The fact
sheet was sent to the local community, and to local, State, and Federal officials. It
invited the public to participate in the Superfund process by attending an EPA
sponsored public meeting held in tile community. The public meeting was held on
November 15,1990, in the Maceo community to announce the beginning of the RI/FS
and was well attended.
The fact sheet also provided an opportunity for community groups to receive
Technical Assistance Grants (TAG) for closely monitoring the technical progress of
the investigation through their own environmental consultant. However, no
applications for grants were received by EPA.
EPA also established and maintained an information repository and Administrative
Record (AR) at the Owensboro Public Library, located in Owensboro Kentucky. The
information repository included general information about EPA, the Superfund
Program and site specific documents. The AR was established as an official record
of all documents and information EPA used as a basis for developing the proposed
final action.
EPA issued another fact sheet in March 1993 to inform the public about the results
of trenching activities conducted at the site. The fact sheet also announced a public
meeting EPA hosted on March 18, 1993. The meeting was held to discuss the
trenching activities and answer any questions concerning the site. Approximately
forty concerned citizens attended.
In 1992 a members of a local community organization called the Maceo Concerned
Citizens Group formed a subgroup called the Green River Toxic Waste Cleanup
Association. This association is very active in participating in the Superfund process
-------
Record of Decision
Green River Disposal Landfill Site
at the Green River Site. EPA provided the association with the opportunity to review
and comment on draft remedial investigation and feasibility study reports and other
related documents. Additionally, EPA participated in several meetings with the
Cleanup Association to answer questions about the investigation and discuss their
concerns about the site.
On July 15 1994, EPA issued a Proposed Plan Fact Sheet presenting the results of
the remedial investigation, feasibility study and Baseline Risk Assessment. The fact
sheet also described EPA's proposed final remedy for the site and announced the
public comment period. The Fact Sheet was sent to the local community, and to local,
State, and Federal officials. The public comment period began on July 19,1994 and
ended on August 17, 1994.
EPA conducted a public meeting on August 4, 1994 to discuss the findings of the
investigation, to describe the proposed cleanup remedy, and answer questions
concerning the site. Those in attendance at the meeting included concerned citizens,
the Green River Toxic Waste Cleanup Association, a reporter from the Owensboro
Messenger-Inquirer newspaper; a reporter from a local television station;
representatives from Green River (Potentially Responsible Party) Coordinating Group;
and representatives from the Commonwealth of Kentucky, Division of Waste
Management. A transcript of the meeting is included in Appendix B.
3.0 SCOPE AND ROLE OF THIS RESPONSE ACTION
This Record of Decision (ROD) presents the selected remedial action for the Green
River Disposal Landfill Superfund Site. This decision document and response action
are issued for the landfill portion of the site and other contaminated media except on-
site groundwater. For reasons described in section 4.1, EPA will issue a future ROD
for groundwater. Therefore, this ROD will not address a potential remedial action
for groundwater.
The selected remedial action for the landfill and other on-site contaminated media
was chosen based on the results of Remedial Investigation, Baseline Risk Assessment,
Feasibility Study and all other documents and information contained in the
Administrative Record. EPA makes this determination pursuant to the requirements
of CERCLA, as amended by the Superfund Amendments and Reauthorization Act of
1986, and to the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP).
The selected remedy described in this ROD is intended to address conditions at the
site that have been determined to present current and potential ecological threats.
-------
Record of Decision
Green River Disposal Landfill Site
4.0 SUMMARY OF SITE CHARACTERISTICS
4.1 Hydrogeology
Hydrogeologic studies conducted at the site included: rock coring; soil test borings;
drilling and monitoring well installation; downhole geophysical logging; hydraulic
conductivity testing. Subsurface geologic information indicates that the lithologies
present at the site were deposited in a fluvial depositional environment forming
laterally discontinuous interlensing beds of siltstone, shale, and sandstone,
interbedded with discontinuous beds and lenses of coal and limestone. A
hydrogeological cross-section traversing the site from east to west is provided in
Figure 4.
At the site, water within the vadose zone percolates through the soil horizon to the
ground-water surface within the surficial aquifer. It appears that the ground water
then flows to the north to discharge to the intermittent stream along the northern
boundary of the landfill. Data from coring, air rotary drilling, and geophysical
logging indicated that vertical flow of ground water is restricted. The core logs
describe shale layers which likely act as an aquiclude or aquitard; the air rotary
drilling within the bedrock penetrated distinct water bearing zones followed by dry
zones; and the geophysical logging of the borings also detected potential distinct
isolated moist zones within the bedrock indicating that the surficial aquifer is isolated
from the lower aquifer. Additionally, in-situ slug testing within the monitoring wells
revealed that hydraulic conductivity values decrease with depth. The logarithmic
average of the hydraulic conductivities was 6.6 x 10"3 ft/min in the residual soil and
weathered bedrock zone, 1.9 x 10"4 ft/min in the shallow bedrock zone, and 1.2 x 10"6
ft/min in the intermediate bedrock zone. Horizontal ground-water flow mimics the
topography and is the dominant ground-water flow path. A potentiometric surface
map of the ground-water elevations on January 13, 1993 is shown in Figure 5.
Samples collected from monitoring wells installed around the perimeter of the landfill
indicate that no significant contamination problem exists. The results show that
groundwater may have been impacted since some maximum contaminant levels were
exceeded in a few monitoring wells. However, these results are not conclusive in
determining the landfill's impact on groundwater. Therefore, EPA has decided to
continue monitoring for a period not to exceed two years to collect enough data to
conclusively establish the landfill's relationship with the groundwater. EPA will
make a final determination on groundwater quality at the site after the data has
been collected and evaluated. EPA's decision concerning a groundwater remedy will
be established in a future Record of Decision document.
-------
Record of Decision
Green River Disposal Landfill Site
4.2 Surface Water and Sediment
The main surface water features on the site are an unnamed tributary, the
sedimentation pond north of the landfill, and smaller intermittent tributaries located
in ravines east and west of the landfill. Sixteen stream sediment sample locations
(SD-1 through SD-16) and eleven surface water sample locations (SW-1, SW-2, SW-3,
SW-10 through SW-16 and SW-121) were sampled as shown in Figure 6. Three
background stream sediment samples (SD-17, 18, and 19) were also collected. The
surface water and sediment samples were analyzed for TCL/TAL constituents. Five
surface water samples (SW-120 through SW-123 and SW-3) were sampled in January
1993 and analyzed for ammonia
The sedimentation pond was investigated in November 1991. The thickness of the
sediment was measured at 57 locations and the sediment was sampled at ten
locations. The samples were analyzed for TCL/TAL constituents.
A former catchment basin existed at the toe of the landfill when the landfill was
operational; it was backfilled during closure. Sediment from the former catchment
basin was collected from four borings, sampled and analyzed for the TCL/TAL
constituents.
4.3 Soil
Landfill Surface and Subsurface Soil Characterization
The soils investigation was divided into two areas: the landfill and the KCR Site.
The purpose of the soil sampling in the landfill area was to characterize the
undisturbed soils at the perimeter of the landfill. As shown on Figure 7, a total
of 11 locations were sampled from the landfill perimeter (SS-01 through SS-11)
and one background sample (SS-12) was collected. Each sample was analyzed for
TCL/TAL constituents by CLP Methods.
A risk-based statistical sampling plan with a grid sampling system was used to
systematically sample the soil at the KCR Site (Figure 8). Twenty-five grids cover
the areas where drums may have been present, hi December 1992, surface soil
samples from grids K5, K9, K21, and K22 were collected and analyzed for the
TCL/TAL constituents.
The analytical results from the four initial grid samples were used to determine
the Constituents of Concern (COCs). In March and April 1993, the remainder of
8
-------
Record of Decision
Green River Disposal Landfill Site
the grids were sampled. The samples were analyzed for the COCs (chromium,
lead, and arsenic) by CLP methods. Because of the detection of drum debris in
grids K6 and K7, soil samples from these grids and others that may have been
impacted (K4, K6, K7, and K8) were analyzed for the full TCL/TAL. Five
background surface soil samples (BSS-1 through BSS-5) were collected along
Chestnut Grove Road. The background surface soil samples were analyzed for
TCL/TAL compounds.
»•
Both surface and subsurface soil samples were collected and analyzed around the
perimeter of the landfill. The analytical results from the surface soil samples
indicated that most constituents detected were equivalent to background
concentrations. Two times the mean concentration was calculated, and a
constituent greater than two times tile mean was considered a outlier. This
process was repeated until the outliers were removed and the remaining
constituents considered background were below two times tile mean concentration.
The only exception occurred with manganese which was detected at the maximum
concentration in the designated background sample. Outliers not associated with
blank contamination from the surface soil landfill perimeter samples are aldrin,
endosulfan I, PCB 1248, aluminum, calcium, cadmium, chromium, copper,
magnesium, lead, sodium, and zinc. Most of the outliers occurred at locations
along the western landfill boundary.
Beryllium, calcium, cobalt, magnesium, manganese, and 2-butanone were detected
in the subsurface soil samples around the landfill perimeter at concentrations
greater than two times the mean of background. Semi-volatile organics and
pesticides/PCBs were not detected above the Contract Required Quantitation
Limit (CRQL).
Since the perimeter soil locations will be incorporated in the design of the landfill
cover, a risk assessment evaluating exposure scenarios for this soil was not
performed.
KCR Surface Soil Characterization
A risk-based, statistical-sampling approach with a grid sampling system was used
to systematically sample the soil at the KCR Site. A statistical analysis was
performed to determine which of the COCs in the 25 Exposure Units (EUs) were
not consistent with background levels. A Student's t-test with a false negative
rate of 20 percent and a false positive rate of 0.2 percent indicated that chromium
in EUs K2 and K6 (66.3 to 82.4 mg/kg) and lead in EUs Kl and K22 (243 to 307
-------
Record of Decision
Green River Disposal Landfill Site
mg/kg) exceeded the statistical test for a background comparison. The statistical
test was conducted in accordance with the procedures presented in the FSP
(September 1993).
No volatile or semi-volatile organic compounds were detected above the CRQL in
the surface soils. PCB 1248 was detected in EUs K6 and K7 at 0.31 mg/kg and
2.1 mg/kg, respectively. PCB 1260 was detected in EUS K6 and K4 at 0.091
mg/kg and 0.16 mg/kg, respectively. Cyanide was detected in EUs K4 and K6, at
6.6 mg/kg and 62.9 mg/kg, respectively. Based on the sampling data and visual
observation, it appears that the original KCR Site may be limited to that area
occupying EUs K6 and K7 where deteriorated drums and drum debris were
encountered.
4.4 Leachate Seep, Sediment and Pond Characterization
In August 1990, as part of the Immediate Response Action, six leachate water and
leachate sediment samples were collected and analyzed for TCL/TAL constituents by
CLP Methods. A leachate containment and collection system consisting of two
leachate collection ponds, an infiltration trench, and a pump station was also
constructed as part of the Immediate Response Action, in November of 1990.
Leachate is collected in the two collection ponds located at the toe of the landfill and
pumped to an infiltration trench at the to of the landfill where it is recirculated
through the waste. As a result of the operation of the leachate collection system, the
original configuration of the seeps has been modified. The frequency and range of
concentrations of constituents detected in the 1990 leachate seep sediment and water
samples are listed in Tables 2 and 3.
In January 1993, water samples were collected from Leachate Collection Pond A,
Leachate Pond B, and from two active leachate seeps (at the time of sampling) LW-
01E and LW-02E, located near Leachate Collection Pond B (Figure 9). The frequency
and range of constituents detected in the 1993 samples of the leachate seeps and
leachate pond samples are listed in Table 4. The leachate seep samples, LW-01E and
LW-02E were composited for non-volatile TCL/TAL analyses and were analyzed
separately for volatile organic TCL analyses.
A comparison of the maximum concentrations of constituents detected in the aqueous
leachate samples in 1990 and 1993 indicates that dilution has occurred from the
accumulation of precipitation infiltrating through the landfill waste. Constituents
detected in both the 1990 and 1993 samples were reduced by 2 to 96 percent with the
exception of cadmium which remained the same and 2-methylphenol which increased.
10
-------
Record of Decision
Green River Disposal Landfill Site
Because the configuration of the seeps has changed over time and the sediment
collected at the seep locations in 1990 are covered by the lined leachate collection
ponds, there are no current exposure pathways for the 1990 seeps and sediment.
Analysis of the leachate data indicate that the concentrations of ammonia nitrogen,
sodium, chromium, cyanide, and zinc may contribute to an increased risk to human
health and/or the environment. Risks associated with these constituents are
discussed in Section 5. These constituents and the corresponding concentrations are
depicted on Figure 10. The maximum concentrations of ammonia nitrogen (530 mgTl),
sodium (8,050 mg/1), chromium (0.024 mg/1), and cyanide (0.0271 mg/1) were detected
in the seeps and Leachate Collection Pond B samples. The 1993 leachate water
samples were also analyzed for hexavalent chromium; all results were non-detects.
Therefore, the 0.024 mg/1 concentration hi the composite sample consists of trivalent
chromium. The highest concentration of zinc (1.18 mg/1) was detected in the leachate
pond sample from Leachate Pond B.
4.5 Landfill Waste Characterization
Geophysical surveys were performed to collect subsurface data in a non-intrusive
manner. The geophysical surveys at the landfill included electromagnetic, seismic
refraction, and electrical resistivity surveys. The surveys aided in the assessment of
the area! extent of the landfilled material and in the identification of conductive zones
within the landfill (Figure 11).
The vertical extent of the landfill was determined from a comparison of topographic
maps which show the landfill site prior to disposal activities and post disposal
activities. The deepest portion of the landfill is approximately 35 feet (+/- 10 feet)
below the existing topography. Figures 12 and 13 shoe the area! extent of the
landfill, which is approximately 14 acres.
Exploratory Trenching and Waste Sampling
Exploratory trenching and waste sampling at the landfill was conducted to assess
if hot spots (areas with intact drums) were present within the landfill. A total of
eight trenches were excavated and sampled at the landfill in January and
February of 1993 (Figure 14). At the request of the USEPA RPM, two additional
trenches were excavated in areas outside the known limits of the landfill. Trench
9 contained landfilled material; however, no waste material was detected in T10.
No intact or partially intact drums were encountered in any of the trenches.
11
-------
Record of Decision
Green River Disposal Landfill Site
Unconsolidated waste samples were collected from Trenches Tl through T7. The
samples collected from each trench were analyzed for the Target Compound
List/Target Analyte List (TCL/TAL) constituents by the SW-846 methods except
for pesticides/PCBs which were analyzed by the CLP methods. Additionally, one
composite sample of the aluminum dross salt cake exposed at the landfill surface
was collected and analyzed for TAL constituents and ammonia.
Unconsolidated waste samples were collected and analyzed from eight trenches
at the landfill to evaluate the potential presence of hot spots within the landfill.
No intact drums were encountered, but between three to five crushed empty
drums were observed in each of four trenches during the excavation. To assess
the potential presence of hot spots, a statistical test was performed on the waste
sample results for the Toxitity Characteristics (TC) metals (arsenic, barium,
cadmium, chromium, lead, mercury, selenium, and silver). If the concentration
of TC metals from any trench exceeded the sum of two times the average
concentration from all waste samples analyzed from the eight trenches plus an
upper confidence bound of 80 percent, then the remaining trench samples were
submitted for the Toxicity Characteristic Leaching Procedure (TCLP) and the
extract was analyzed for those TC metals which failed the statistical criteria. The
statistical criteria was exceeded in five of the eight trenches sampled and the
samples from these trenches were extracted by the TCLP and analyzed. All TC
metal analytical results were below TCLP regulatory levels. As a result, the
landfill does not contain hot spots that are highly toxic and/or mobile per the
statistical analysis and TCLP results for the TC metals.
An assessment of risk associated with the buried landfill waste was not performed
because no hot spots were identified and a presumptive remedy approach for the
landfill will be used. A landfill cover system, leachate collection/treatment
system, and gas collection system have been evaluated in the FS. Since the
USEPA recognizes that containment is the appropriate response action for
landfills, a decision to evaluate and implement remedial action for the landfill
waste material has already been made.
4.6 Characterization of Surface Water, Sediment and Soil in the East and
West Ravines
Based on the observation of deteriorated drums and drum debris, additional sampling
outside the original scope of work in the FSP was conducted in three areas. One
surface water, sediment, and surface soil sample each were collected in the east and
west ravines. Two surface soil samples were also collected near EUs K6 and K7.
These samples were collected immediately adjacent to empty drums or drum debris.
12
-------
Record of Decision
Green River Disposal Landfill Site
Pesticides and PCBs were detected in the sediment and soil samples; none were
detected in the surface water samples. Sediment and surface soil from the west
ravine contained endrin (tentatively identified at 0.05T mg/kg), PCB-1016 at 0.099
nag/kg in the sediment to 8.4 mg/kg in the soil, and PCB-1248 at 0.16 mg/kg in the
sediment to 14 mg/kg in the soil. Surface soil samples from the KCR Site EUs
contained isophorone at 1.3 mg/kg, PCB 1248 at 3.3 mg/kg, and PCB 1260 at 0.56
mg/kg. The PCB levels were below remedial action levels.
»•
Inorganic constituents greater than two times the mean of background include:
• Chromium was detected in the surface soil and sediment in the west ravines
at concentrations ranging from 42.3 to 144 mg/kg and in surface soil sample
SS-13 and SS-14 from 43.7 to 444 mg/kg.
• Lead was detected at concentrations ranging from 69.9 to 211 mg/kg in
sediment and soil samples from the west ravines and from 23 to 659 mg/kg in
sediment and soil samples in the east ravine.
0 Cyanide was detected at 10 mg/kg in the surface soil sample collected in the
west ravines and at 75.9 mg/kg in SS-14 located at the KCR Site.
4.7 Air Quality Characterization
The air study consisted of (1) canister and high-volume air sampling, (2) an air
emissions study, and (3) air monitoring during the landfill trenching activities. Each
component of the study is discussed below.
The air emission study was a qualitative study performed to assess gas emissions
from the landfill for consideration in remedial design. Air emission measurements
were planned to be performed for six gases at 61 locations located on 100 by 100 foot
grid centers over the surface of the landfill. A spectrophotometer was utilized to
sample for the presence of acetylene, ammonia, hydrogen cyanide, methane, and total
hydrocarbons. Hydrogen sulfide was measured with a hydrogen sulfide monitor.
The air monitoring data collected during the exploratory trenching were used to
assess emissions if the landfill surface is disturbed during remedial action. The total
hydrocarbon monitoring results may also be used to fill spectrophotometer
hydrocarbon data gaps.
13
-------
Record of Decision
Green River Disposal Landfill Site
In general, air emissions from the landfill contain relatively low concentrations of
VOCs, ammonia (where aluminum dross salt cake or leachate are present), methane,
and hydrocarbons. Hydrogen cyanide and hydrogen sulfide are compounds unlikely
to be present at the landfill. Although the methods used to collect the air monitoring
and air emission data were very different, they correlated well. Where data was
rejected because of instrumentation problems with one method, the data from another
sampling method was used to fill the data gap. Acetylene is the only analyte for
which no data is available. . ;
The human health COCs for the air pathway were established from the canister and
high-volume air sampling. They are acetone, benzene, cumene, ethylbenzene, hexane,
toluene, trichloroethene, xylenes, and manganese. Several of these constituents are
included although they were also detected in the upwind sample location because an
off-site, upwind sample location was unavailable. Therefore, it cannot be assumed
that these constituents were emitted from an off-site source such as vehicular traffic
on Kelly Cemetery Road. The exposure pathways include inhalation of ambient air
by current and future trespassers and hunters and near-site and off-site residents.
Based on the annual average concentration, the risk characterization indicates a 3
x 10~6 and 7 x 10"8 cancer risk for future residential and current/future trespassers,
respectively. The HQ for future adult and child residential receptors and trespassers
is less than one. An ecological risk assessment for air was not performed.
5.0 SUMMARY OF SITE RISKS
A Baseline Risk Assessment (BRA) was performed to estimate the potential human
health and environmental impacts if contaminated media at the site were not
remediated. The BRA, presented in Section 6.0 of the Remedial Investigation Report,
includes the Human Health Evaluation, the Ecological Baseline Risk Assessment and
Remediation Goal Options. The Baseline Risk Assessment for Human Health and the
Ecological Baseline Risk Assessment present estimates of potential health and
environmental risks based on information acquired during the RI.
The BRA for human health includes an assessment for exposure to groundwater.
However, since the groundwater analytical data collected during the remedial
investigation could not establish a conclusive relationship between the landfill and
groundwater, the human health risks estimated for groundwater exposure is
considered to be a preliminary estimate. Additional groundwater samples will be
collected and analyzed to determine the influence of naturally occurring constituents
on groundwater quality. Upon completion of the additional groundwater sampling
and analysis, the risk assessment associated with human health and/or
14
-------
Record of Decision
Green River Disposal Landfill Site
environmental groundwater exposure will be completed. A future decision document
will establish the need for groundwater remediation based on an evaluation of the
analytical results and on the conclusions of the risk assessment completed for
groundwater exposure. The summary of the site's risks presented in this section will
include the preliminary groundwater risks estimated. These risks are presented only
as a preliminary estimate and not to support a decision for a groundwater remedial
action.
»-
5.1 Summary of Human Health Risks
5.1.1 Constituents of Concern
Media associated with the landfill investigation include air, groundwater, leachate,
surface water, and sediments. The majority of the samples collected relative to the
investigation of the landfill were located on or adjacent to the landfill and are not
reflective of site conditions for the KCR site. The eastern most surface water and
sediment sample locations collected during the RI may be indicative of KCR site
conditions, but also cannot be completely dissociated from the landfill as a source
area for detected constituents.
Tables 5 through 9 summarizes the results of the RI sampling and identifies the
Constituents of Concern (COG) for each media evaluated in the BRA.
5.1.2 Exposure Assessment
The purpose of an exposure assessment is to provide an evaluation of the potential
for human or environmental exposure to constituents at a site in the absence of
remedial action. The exposure assessment incorporates data that identify the COCs
and their potential transport through the environment. The assessment identifies
potential exposure pathways and receptors associated with a site in order to identify
potential Human or environmental risks associated with the site. Table 10
summarizes the exposure routes considered in the BRA.
Seventeen potential exposure pathways were quantified in this assessment, including
11 current exposure pathways and 17 future pathways. The pathways quantified
include the following:
15
-------
Record of Decision
Green River Disposal Landfill Site
Current and Future Land Uses - Trespassers
1. Dermal contact with surface water while wading
2. Dermal contact with stream sediments while wading
3. Dermal contact with leachate water while wading
4. Inhalation of fugitive dust
5. Incidental ingestion of surface soils
6. Dermal contact with surface soils
7. Inhalation of ambient air
Future Land Uses - Near-Site and Off-Site Residents
8. Ingestion of ground water used for drinking water
9. Dermal contact with ground water while showering and household use
10. Dermal contact with surface soils (KCR Site)
11. Inhalation of fugitive dust (KCR Site)
12. Incidental ingestion of surface soils (KCR Site)
13. Inhalation of ambient air
Current and Future Land Uses - Hunters
14. Inhalation of fugitive dust (KCR Site)
15. Incidental ingestion of surface soils (KCR Site)
16. Dermal contact with surface soils (KCR Site)
17. Inhalation of ambient air
Exposure point concentrations for each of these pathways were determined based on
the results of current monitoring data from sampling locations on-site. The exposure
point concentrations are multiplied by pathway-specific intake assumptions to yield
quantitative estimates of chemical intakes for each pathway.
5.1.3 Toxicity Assessment
Several constituents that have the potential for causing adverse human health effects
have been identified in the environmental media at the site. This section presents
the available toxicity values which were used for the COCs at the site. Toxicity
values are not available for all the constituents detected. Lack of toxicity data may
cause risks to be underestimated. In accordance with EPA guidance, constituent
which lack toxicity values are evaluated qualitatively and the absence of toxicity
values is identified as an uncertainty. Uncertainties also arise because toxicity
values are often based on data extrapolated from other species.
16
-------
Record of Decision
Green River Disposal Landfill Site
The Reference Dose (RfD) and Inhalation Exposure Reference Concentration (RfC) for
noncarcinogenic constituents, and the weight-of-evidence classification and Slope
Factors for carcinogenic constituents used in the BRA are listed in Table 11.
5.1.4 Carcinogenic and Noncarcinogenic Risks for the Green River
Disposal Landfill
Ambient Air '•
The cancer risk for residential exposure is within the acceptable risk range at 3
x 10"6. Estimated risks for trespassers are slightly lower at 7 x 10"8. The
estimated risk is due primarily to the presence of benzene in the sample.
Hazard indices of 0.04 and 0.2 were calculated for future residential adults and
children. Hazard indices for trespassers were also below one. Cumene, hexane,
and toluene present most of the noncarcinogenic risk for ambient air exposures.
A highly conservative approach was used to quantify air exposures. It was
assumed that downwind residents would be exposed to concentrations equal to
those actually present at the site. No dispersion or dilution was included; under
realistic atmospheric conditions, dispersion can create an order of magnitude or
more of concentration reduction over source to receptor distances of approximately
100 feet.
Ground Water
The groundwater risk assessment presented in the RI is considered preliminary.
The groundwater portion of the risk assessment will become final after additional
groundwater analytical data is collected and evaluated. The preliminary risk
assessment for groundwater is presented in this ROD for information purposes
only, and also to aid the reader in developing a conceptual model of the site.
The excess cancer risk estimated for residents via ingestion, was 9 x 10"4 and was
primarily attributed to the presence of beryllium in turbid samples collected from
four on-site ground-water monitoring wells. Estimated risk for the dermal contact
route was 2 x 10"6. Beryllium was detected in site background soil samples and
is commonly present in shale within Kentucky. Its presence in the turbid samples
may be the result of naturally occurring beryllium.
17
-------
Record of Decision
Green River Disposal Landfill Site
Hazard indices for the ingestion route exceeded the departure point of one. The
hazard indices for future residential adults and children were 30 and 200,
respectively. The majority of the risks are associated with one constituent,
manganese, in turbid on-site ground-water monitoring wells.
It was assumed that residents would be drinking water with constituents at levels
equal to those currently found on the site. The highest concentrations were
associated with wells near the eastern leachate collection pond. Due to its steep
slopes and nearby low-lying wetland areas, the landfill is an unlikely location for
residential development and not a suitable source of drinking water.
Concentrations measured in off-site residential wells were considered acceptable
for drinking Fate and transport conditions at the site are not well defined, but
appear to reduce ground water concentrations to acceptable levels before reaching
off-site residential receptors. In addition, levels measured at the landfill may be
influenced by turbidity in the samples since turbidity is an indication of
suspended solids. Only one sampling point was available for the determination
of background ground water levels for metals.
Surface Water and Sediments
Trespassing youth may be potentially exposed to constituents present in surface
water and sediments during wading. Estimated cancer risks for surface water
and sediments were 1 x 10"7 and 3 x 10'6, respectively. Hazard indices for
trespassing youth exposed to surface water and sediment were below one. All
dermal contact scenarios for wading assumed a 2.6 hour duration for 45 events
a year, i.e., recreational swimming Therefore, the exposure assumptions were
conservative for a remote site with intermittent stream flow.
Leachate Water
Trespassing youth may be potentially exposed to constituents present in leachate
water during wading. Estimated excess cancer risk was 2 x 10"7 for dermal
exposures. The related hazard index was less than one. The wading exposure
assumptions were conservative as mentioned above. In addition, the leachate
collection ponds do not represent an attractive site for recreational wading on a
regular basis.
18
-------
Record of Decision
Green River Disposal Landfill Site
Cumulative Risk Estimates
The residential cumulative cancer risk for exposures related to air and ground
water at the landfill, was 9 x 10"4. The cumulative hazard indices for adults and
children were 30 and 200, respectively. The majority of the risk is associated with
the ingestion of ground water. As mentioned previously, the landfill is an
unlikely source of potable water, how or in the future.
»•
The cumulative cancer risk for trespassers was 3 x 10'6. Most of the risk was
associated with sediment exposures. The hazard indices for hunters and
trespassing youth did not exceed one.
Table 19 presents a summary of the site human health risks estimated for the
landfill in the BRA.
5.1.5 Carcinogenic and Noncarcinogenic Risks for Kelly Cemetery Road
Site
Excess cancer risks associated with surface soil exposures at the KCR Site were
within the acceptable range of 1 x 10"4 to 1 x 10"6. The risks for residents and
trespassers were 5 x 10"6 and 1 x 10"7, respectively. Cancer risks were associated with
the presence of chromium which was assumed to be hexavalent chromium. As some
percentage of the total chromium, and possibly the great majority, would be expected
to be trivalent (and thus not classified as a potential carcinogen), the excess cancer
risks are overstated. The hazard indices for soil exposures were all below one. In
addition, the lead soil levels and ground water levels were input in the Lead
Uptake/Biokinetic Model and shown not to present an unacceptable level of risk to
young children potentially residing on or near the site. Surface soils were the only
media of concern at the KCR Site. While this site is upgradient of surface drainage
features addressed during the RI/FS, no apparent impacts on the surface and stream
sediments quality were identified which could be associated distinctly with the KCR
Site, and or with the landfill.
Table 13 presents a summary of the site human health risks estimated for the KCR
area in the BRA.
5.1.6 Comparison to Regulatory Guidance and Criteria
Three compounds in ground water exceeded State and/or Federal primary MCLs for
drinking water. The constituents were barium, beryllium, and cadmium. Manganese
19
-------
Record of Decision
Green River Disposal Landfill Site
exceeded the Kentucky secondary MCL level. The maximum constituent levels for
these four compounds were measured in shallow monitoring wells near the northern
"toe*1 of the landfill. These wells, which are installed adjacent to the landfill wastes,
are not representative of ground water sampled off-site in residential wells.
Several compounds sampled in surface water exceeded State and Federal surface
water quality regulations protective of human health. The regulations assume the
ingestion of 2 liters of water and/or 6.5 grams of fish. Because of the intermittent
flow of site surface features, the surface water streams do not support fish Hfe and
are not a suitable source of drinking water. However, the surface water regulations
were considered in discerning potential impacts on downstream water resources such
as the Ohio River.
The constituent levels detected in stream sediments were compared to NOAA
sediment criteria. Five metals, above estimated concentrations, exceeded NOAA
criteria which indicates that sediment quality may be adversely impacted by
constituents leaching from the landfill. These included cadmium, chromium, lead,
nickel and zinc.
5.2 Summary of the Ecological Assessment
The ecological baseline risk assessment, presented in Section 6.0 of the Remedial
Investigation Report, was conducted in accordance with USEPA's "Risk Assessment
Guidance for Superfund, Volume II: Environmental Evaluation Manual" and MITRE
Corporation's "General Guidance for Ecological Risk Assessment at Air Force
Installations". The objectives of the ecological baseline risk assessment for the site
were:
1. Identify and evaluate the current and future uses of natural resources
(land, air, water, biota) at and adjacent to site;
2. Identify potential environmental impacts associated with the site;
3. Quantitatively and qualitatively assess the significance of any potential
environmental impacts.
Potential receptors present in the vicinity of the site and the potential pathways by
which these receptors may be exposed to constituents of concern present in surface
soils, surface water, stream sediments, and leachate water were evaluated. Potential
risks to environmental receptors arising from exposure to site constituents were
quantitatively characterized for surface water, stream sediments, and leachate water.
Potential risks associated with surface soil exposures at the KCR Site were
qualitatively characterized.
20
-------
Record of Decision
Green River Disposal Landfill Site
Sediments associated with the drainage of the site tributary have constituents which
show the potential for impacting indicator species. Zinc, chromium, and lead have
ecological quotients of greater than 1000 which indicates significant impacts may
occur if species come into contact with site sediments. To a lesser but no less
important extent, cadmium, manganese, nickel, sodium, bis(2-ethylhexyl)phthalate,
and PCB-1248 (EQ of 160 or below) have the potential to have moderate impact to
flora and fauna coming into contact with sediments on the site. It should be noted
that PCB 1248 concentrations at the site were well below any regulatory standards
and below the NOAA sediment criteria. These conservative ecological quotients
suggest the lower life forms (water fleas, fathead minnow) may be impacted by
sediments which can impact food chain mechanisms for predator species which prey
upon them. The impact may be direct by ingesting lower forms contaminated by the
sediment or, more likely, by the absence of lower forms due to the toxicity of the
sediment.
Surface water associated with the intermittent site tributary has constituents which
show the potential for impacting indicator species. Ammonia nitrogen has ecological
quotients of 42 to 94 which indicates a moderate impact may occur if species come
into contact with site surface water. Ammonia nitrogen is the main concern for
impact as toxicity tests performed indicated a severe impact to organisms in surface
water was related to the concentration of ammonia nitrogen. To a lesser extent,
sodium (EQ of 120 or below) has the potential to have an impact to flora and fauna
coming into contact with sediments on the site. These ecological quotients suggest
the lower life forms (water fleas, Fathead Minnow) may be impacted by surface water
which can impact food chain mechanisms for predator species which prey upon them.
The impact may be direct by ingesting lower forms contaminated by the sediment or,
more likely, the absence of lower forms due to the toxicity of the surface water. Table
14 presents a comparison of surface water ecological COG concentrations to ambient
water quality criteria.
Leachate water also has the same potential to impact species present on site.
Ammonia nitrogen with an ecological quotient ranging from 124 to 277 indicates the
potential for moderate impact to site species utilizing the leachate water as a
drinking water source, foraging area, or as habitat. Zinc, sodium, and chromium may
also have an impact but to a much lesser degree.
Surface soils at the KCR Site are not expected to have a significant impact to the
environment. Metals and PCBs bind to soils and the soils are covered by shrubs,
grasses, and humus. Burrowing animals have the greatest potential for impact but
the burrowing species likely to inhabit the area are limited to squirrels and snakes.
Fox species have a more suitable habitat in which to burrow at the landfill.
21
-------
Record of Decision
Green River Disposal Landfill Site
Fauna species can come into contact with leachate water and surface water during
drinking, hunting, or swimming activities. Ingestion of surface water is the most
readily available route of uptake while dermal contact is also expected. Fauna
species may also come into contact with site sediments during these same activities
but dermal contact is the route of exposure which is most likely for contact with
sediments. Fauna species also can be exposed to site constituents by preying upon
lower life forms or plants which may bioaccumulate or bioconcentrate constituents
through their own uptake mechanisms. These same species may be impacted if the
lower life forms are not present due to the inability to survive constituents in the
surface water, leachate water, or sediments.
Flora species inhabiting the riparian of the surface water have the potential for
exposure through the uptake of surface water by the roots or coming into contact with
surface water sediments. Two areas of stressed vegetation were observed along the
sedimentation pond and the periphery of the landfill, but were related to an
accumulation of sediment and heavy equipment damage.
Five federally endangered or threatened species were identified as inhabiting Daviess
County, but none have been observed on the site. Certain trees with shaggy bark are
present at the site which could possibly be used by the Indiana bat as a maternity
habitat.
Overall, impacts to the lower life forms are expected to have occurred given the high
ecological quotients, predominantly for the zinc, chromium, and lead in the
sediments; but also for ammonia nitrogen in surface waters and leachate water.
Impacts to the higher life forms cannot be quantitated due to lack of available LC50s
or EC50s for those species and limited data on population estimates of species on-site
before and after exposure to COCs. Tables 15 through 17 summarize the results of
the ecological risk assessment for surface water, surface water sediment, and
leachate.
6.0 DESCRIPTION OF REMEDIAL ALTERNATIVES
The Feasibility Study (FS) utilized the presumptive remedy approach for municipal
landfills. Title 40 C.F.R. Section 300.430(a)(iii)(B) of the NCP contains the
expectation that engineering controls, such as containment, will be used where
treatment is impracticable. The preamble to the NCP identifies municipal landfills
as a type of Site where treatment of the waste may be impracticable because of the
size and heterogeneity of the contents (55 Federal Register 8704, 1990). Because
treatment is usually impracticable for a landfill, EPA considers containment to be the
22
-------
Record of Decision
Green River Disposal Landfill Site
appropriate response action, or the "Presumptive Remedy". The presumptive remedy
for CERCLA municipal landfill sites relates primarily to containment of the landfill
mass and collection and/or treatment of landfill gas. Other measures to control
leachate, affected groundwater, and/or upgradient groundwater that are causing
saturation of the landfill mass may also be implemented as part of the presumptive
remedy. The presence of concentrated waste areas, or "Hot Spots" would require
additional characterization; however, no hot spots were present at this Site. Use of
the presumptive remedy also eliminates the need for the initial identification and
screening of alternatives during the feasibility study.
Table 18 summarizes the Baseline Risk Assessment Results and remedial action
conclusions for each media. Based on the remedial investigation and on unacceptable
ecological risks associated with site contaminants, three site media will require
implementation of a remedial action. These media are: the landfill waste, leachate,
and sediment in the unnamed tributary and sedimentation pond.
A description of the alternatives evaluated hi the Feasibility Study and a summary
of the comparative analysis of EPA's primary balancing criteria is presented in the
following sections.
6.1 Landfill Remedial Alternatives
Four capping options related to the layered components of the cap system are
described and evaluated in the following sections. These capping alternatives include:
• a native soil cover
• single barrier provided by a compacted clay layer
• single barrier provided by a geomembrane
• composite barrier cover
Each option was considered feasible for application to the containment of the landfill
waste at the site. Table 19 provides a summary of the detailed analysis of capping
alternatives for the landfill waste. A No Action Alternative was not evaluated
because of the presumptive remedy approach of the Feasibility Study.
The area of past landfilling activities was estimated from geophysical surveys and
topographic maps. Additional soil sampling or investigative methods would be
required on the periphery of the estimated area of landfill activity to confirm the
actual extent of the area to be capped. This should be performed during the remedial
design phase.
23
-------
Record of Decision
Green River Disposal Landfill Site
Implementation of each capping alternative requires excavation, hauling and
placement of soil and some landfill waste material as sub-grade fill. Clean soil fill
is available locally. In order to reduce the slope of the capped area, the excavation
of certain areas of landfill waste may be required. The amount of cut and fill
material needed to prepare the cap's subgrade would depend on the final grade design
of the cap.
Figure 14 presents an estimated extent and preliminary grading plan for the cap.
This plan was prepared primarily for cost estimating purposes. According to the
figure, the estimated area that would be capped is 14 acres. Currently, the steepest
slopes in the landfill area range from 25 to 30 percent. The grades on Figure 14
range from approximately ten percent on the upper (southern) end of the landfill to
17 percent over the steepest slopes. An estimated 18,600 cubic yards of borrow
material would be handled from various on-site and off-site sources for construction
of the cap's sub-grade. This volume estimate is based on the preliminary grading
plan. It is expected that some excavation and re-grading of landfill waste would be
required for subgrade preparation. The actual volumes of cut and fill at the landfill
area would be determined during Remedial Design.
Excavating and grading soil and the landfill's waste material would increase the
potential for soil erosion and COG migration to the Unnamed Tributary. However,
these would only be short-term effects during construction. To minimize erosion,
temporary erosion control measures such as silt fences, ditches and sediment basins
would be implemented.
Natural drainage conditions in the vicinity of the landfill would be slightly altered
during cap construction. Run-off would be channeled around the capped area and
run-off would be routed across the slope of the capped area and allowed to dissipate
naturally according to the existing contour of the surrounding areas. With completion
of the cap, surface drainage controls such as ditches, berms and "breaking" slopes
with terraces would be implemented to decrease sedimentation and erosion and
facilitate drainage management.
A passive gas venting system may be required beneath the cap regardless of the
capping option chosen. At a minimum, the system would consist of a continuous
granular layer placed above the landfill waste or a series of sand-filled trenches.
Vertical gas vent pipes extending above the surface of the cap would be installed
within the granular layer or trenches at regular intervals along the perimeter of the
cap.
24
-------
Record of Decision
Green River Disposal Landfill Site
6.1.1 Landfill Alternative 1: Capping With a Soil Cover
This alternative involves the design and construction of a native soil cover over
the area of suspected landfilling activity (i.e. approximately 14 acres). After the
sub-grade is completed, an approximately two-foot thick compacted soil layer
would be constructed. The soil would be obtained from on-site borrow sources,
most likely excavated from the side slopes which consist primarily of loess (silt)
deposits. *:
A lateral drainage layer consisting of a geosynthetic mesh (geonet) would be
placed on top of the compacted soil layer. Geotextile filter fabric would be placed
on both sides of the geonet to prevent clogging of the geonet from the compacted
soil below and the vegetative soil above.
A layer of native soil sufficient to sustain vegetative growth for erosion control
and prevent root penetration of the underlying compacted layer would be placed
over the compacted soil layer. For cost estimation, a three foot thick layer is
assumed. This layer would also provide surface drying and freeze-thaw protection
to the compacted layer. A layer of geogrid reinforcement may be required within
the vegetative soil layer on the steeper slopes of the cap. Figure 15 includes a
generalized cross-section of the soil cap layers.
The estimated present worth cost for this alternative is $5,914,000. The
construction cost is estimated to be $4,948,000 and the estimated present worth
cost of maintenance for years 1 through 30 is $476,000 (1993 dollars). The
present worth cost ($490,250) of the institutional actions is also included this
alternative.
6.1.2 Landfill Alternative 2: Capping With a Clay Barrier
This alternative involves the design and construction of a compacted clay cover over
the area shown on Figure 14. The term "clay" refers to soil classified as CL or CH
according to the United Soil Classification System. After the sub-grade is completed,
an approximately eighteen inch thick compacted clay layer would be constructed.
This thickness is a requirement for clay layers used in Kentucky Solid Waste landfill
caps. The clay would be obtained from an off-site borrow source since site soils have
been identified as loess (silt). A lateral drainage layer consisting of a synthetic
geonet would be placed on top of the clay layer. Geotextile filter fabric would be
placed on both sides of the geonet to prevent clogging of the drainage layer from the
clay soil below and the vegetative soil above. A vegetative layer of native soil
25
-------
Record of Decision
Green River Disposal Landfill Site
approximately three feet thick would be placed over the drainage layer. This layer
would support vegetation for erosion control and would provide freeze-thaw and
surface drying protection to the compacted clay layer. A layer of geogrid
reinforcement may be required within the vegetative soil layer on the steeper slopes
of the cap. Figure 15 includes a generalized cross-section of the layered components
of the clay barrier cap. Long-term periodic maintenance of the clay barrier cap is
required. ;
i-
The estimated present worth cost for this alternative is $6,320,000. The construction
cost is estimated to be $5,354,000 and the estimated present worth cost of
maintenance for years 1 through 30 is $476,000 (1993 dollars). The present worth
cost ($490,250) of the institutional actions is also included in this alternative.
6.1.3 Landfill Alternative 3: Capping With a Single Barrier Geomembrane
The design of this alternative is similar to that of alternative 2 except that a flexible
geomembrane replaces the compacted clay as the barrier layer. A geomembrane (for
cost estimation, 40-mil HDPE was assumed) would be installed over the sub-grade
surface. The sub-grade would be prepared with a smooth surface to reduce the
potential of tearing the geomembrane. A lateral drainage layer consisting of a geonet
mesh would be placed on top of the geomembrane layer. Geotextile filter fabric would
be installed over the geonet to prevent clogging of the drainage layer from the above
vegetative soil. A vegetative layer of native soil approximately three feet thick would
be placed over the drainage layer. This layer would support vegetation for erosion
control and ultraviolet radiation protection to the geonet and geomembrane
components. A layer of geogrid reinforcement may be required within the vegetative
soil layer on the steeper slopes of the cap. Figure 15 includes a generalized cross-
section of the layered components of the single barrier geomembrane cap. Long-term
periodic maintenance of the this cap is required.
The estimated present worth cost for tins alternative is $5,793,000. The construction
cost is estimated to be $4,827,000 and the estimated present worth cost of
maintenance for years 1 through 30 is $476,000 (1993 dollars). The present worth
cost ($490,250) of the institutional actions described in Section 3.1.2.2 is also included
in this alternative.
6.1.4 Landfill Alternative 4: Capping With a Composite Barrier Cover
Sub-grade preparation is similar to alternatives 1, 2 and 3. This particular capping
option includes two barrier layers which consist of an eighteen inch thick compacted
clay layer covered by a geomembrane (40-mil HDPE is assumed for cost estimation).
A geonet drainage layer would be placed over the geomembrane to provide lateral
drainage. Filter fabric would be placed over this drainage layer to prevent overlying
26
-------
Record of Decision
Green River Disposal Landfill Site
vegetative soil from clogging the drainage net. A vegetative layer of native soil about
three feet thick would be placed over the drainage layer. This layer would support
vegetation for erosion control. This soil layer would also provide freeze-thaw and
surface drying protection to the clay layer and ultraviolet radiation protection to the
geonet and geomembrane components. A layer of geogrid reinforcement may be
required within the vegetative soil layer on the steeper slopes of the cap. Figure 3-4
includes a generalized cross-section of this composite barrier cap option.
»-
The estimated present worth cost for this alternative is $8,782,000. The construction
cost is estimated to be $7,722,000 and the estimated present worth cost of
maintenance for years 1 through 30 is $570,000 (1993 dollars). The present worth
cost ($490,250) of the institutional actions is also included in this alternative.
6.1.5 Comparative Analysis of Landfill Alternatives
Overall Protectiveness
In terms of preventing direct contact with landfill waste, all four alternatives would
provide equivalent protection. The main factor related to the degree of protectiveness
that differentiates the capping alternatives is the relative reduction in surface water
infiltration and leachate generation. All the alternatives appear to reduce leachate
percolation by at least 90 percent. Alternative 4 would typically provide the best
overall protection due to its redundancy of barrier layers. Capping alternatives that
include the installation of a geomembrane may result in reduced integrity due to
subsidence of landfill waste. This is especially the case with alternative 3 in which
the geomembrane is not underlain by an additional barrier layer.
Compliance with ARARs
All the capping alternatives can comply with the location and action-specific ARARs
outlined in Section 8.2. Landfill capping in itself may not provide compliance with
the chemical-specific ARARs related to water quality. However, leachate
collection/treatment should provide compliance with these ARARs.
Alternatives 2 and 3 comply directly with Kentucky Solid Waste Rules for final cap
systems components. Alternative 4 also complies with the Kentucky Rules for final
cap components with an additional barrier layer incorporated.
The performance of alternative 1 would be demonstrated according to Kentucky Solid
Waste Rules for alternative specifications of a final cap system. Physical tests
27
-------
Record of Decision
Green River Disposal Landfill Site
performed on site soils indicate that on-site borrow soils can be engineered to achieve
a hydraulic conductivity of 10~7 cm/sec which is a requirement of the Kentucky Solid
Waste Rules.
Long-term Effectiveness and Permanence
In general, alternative 4 would have the highest long-term effectiveness with respect
to infiltration reduction. All the capping alternatives would have equivalent long-
term effectiveness in preventing direct contact with waste and minimizing erosion.
Routine maintenance of the vegetative soil cover is the same for all the'alternatives.
Reduction of Toxicity. Mobility, or Volume
The mobility and volume but not the toxicity of leachate would be significantly
reduced by implementing any of the capping alternatives. Because surface water
infiltration is considered the only mechanism by which leachate is generated, the
HELP model provides a good indication of leachate generation rate via surface water
percolation. The model indicates that alternative 4 would essentially eliminate future
leachate generation. However, the model also indicates that the other alternatives
would reduce leachate generation by 90 percent or more. The toxicity and volume of
landfill waste would not be reduced with any of the capping alternatives.
Short-Term Effectiveness
Alternative 1 would have a significantly better short-term effectiveness than the
other capping alternatives. Because borrow sources for construction of the cap layers
are located on site, there would be fewer haul trucks transporting materials to the
site. This reduction in traffic would decrease associated hazards to the local citizens
especially those on Kelly Cemetery Road and/or Chestnut Grove Road.
Implementability
Alternative 1 would be the simplest cap to construct due to the availability of the
earthen materials. Alternative 2 is relatively simple to construct. However, there
would be a significant effort to transport and handle clay material from off-site. This
effort would also apply to alternative 4. Alternatives 3 and 4 would require more
extensive quality assurance and quality control procedures than alternatives 1 and
2 since 3 and 4 both involve placement and seaming of a geomembrane.
28
-------
Record of Decision
Green River Disposal Landfill Site
Cost
Alternative 3 has the lowest construction (capital) cost estimate ($4,827,000) of the
capping alternatives. Alternative 1 is slightly more expensive with a construction
cost estimate of $4,948,000. The construction cost estimate for alternative 2
($5,354,000) is approximately eleven percent higher than that of alternative 3.
Alternative 4 is the most expensive capping alternative. The construction cost
estimate for Alternative 4 ($6,194,000) is more than $1,300,000, or about 28 percent,
higher than the least expensive capping alternative (alternative 3).
Only cap construction costs are compared because operation and maintenance costs
and institutional control costs are considered approximately the same for each
alternative.
6.2 Leachate Remedial Alternatives
The following discussion and evaluation of alternatives for leachate considers the
areas near the base of the landfill where leachate seeps have been observed. It is
assumed that leachate would continue to seep from these areas if no action is taken
to reduce or eliminate leachate generation. It is believed that a landfill cap may
virtually cease leachate production within 2 to 4 years after construction.
Three remedial alternatives were evaluated for leachate:
• No Action
• Limited Institutional Action
• Collection with Subsurface Drains: Chemical/Physical Treatment for
Removal of Heavy Metals and Organic Compounds; Discharge of Treated
Water into the Unnamed Tributary
6.2.1 Leachate Alternative 1: No Action
The no-action alternative includes no on-site remediation or institutional controls to
address leachate. The leachate seeps would essentially remain in their current state.
However, the placement of a landfill cap would significantly reduce the production
of leachate through decreased subsurface infiltration presented in the detailed
analysis of landfill waste alternatives.
29
-------
Record of Decision
Green River Disposal Landfill Site
6.22 Leachate Alternative 2: Limited Institutional Action
This action involves maintenance of the perimeter fence and long-term security and
inspections. A long-term monitoring program of sediment, surface and ground water
sampling and analysis would be implemented. It is anticipated that sampling would
be performed annually. However, this schedule is subject to alteration depending
upon fluctuations, if any, in sediment and/or water quality results. It can be expected
that the sampling frequency would vary throughout the life of the program. Deed
restrictions would also be instituted to the extent possible to restrict future land use.
Long-term site monitoring was assumed to include sampling in the eleven ground-
water monitoring wells currently on-site. Monitoring at three surface water and
three sediment sample locations is also proposed for this alternative.
The current state of the leachate outbreaks remains relatively unchanged with the
implementation of the limited institutional action alternative.
6.2.3 Leachate Alternative 3: Collection with Subsurface Drains;
Chemical/Physical Treatment for Removal of Heavy Metals and
Organic Compounds; Discharge of Treated Water into the Unnamed
Tributary
In this alternative, leachate would be collected through subsurface interceptor drains.
The collected leachate would be pumped into a equalization tank to begin the
treatment process. The metals would be removed by hydroxide precipitation.
Ammonia and VOCs would be removed by air stripping. The treated leachate would
be discharged through a National Pollutant Discharge Elimination System (NPDES)
discharge point. This alternative includes the Institutional Controls of Alternative
2.
Unit operations proposed for this alternative are common. For cost estimation
purposes some process detail assumptions, such as sodium hydroxide as the reagents
or plate and frame niters as the dewatering equipment, have been made. Actual
process details such as amounts and types of reagents, clarification and dewatering
methods, and filtration equipment will be specified as a result of bench and/or pilot
scale testing which will be performed during the Remedial Design phase.
The major components of this alternative are as follows:
Leachate Collection
The location of interceptor drains will depend upon the landfill cap
configuration. In general, the drains would be located along the northern edge
30
-------
Record of Decision
Green River Disposal Landfill Site
of the cap topographically downgradient of the observed leachate outbreaks.
The total length of drain would be approximately 1,100 feet.
The collection drains would consist of perforated pipe placed in a gravel filled
trench. The trench would be excavated to the depth of the soil-bedrock
interface. The trench depth would range from approximately 10 to 15 feet
below ground surface. If significant fractures are encountered within the
bedrock, they will be sealed with grout prior to completion of the drain
installation. A geotextile niter fabric would be placed around the gravel
envelope in the trench to prevent soil or landfill material from entering the
drain. The bottom of the trench and the downgradient wall would be lined
with a synthetic membrane to contain the leachate. The drains would be
sloped to convey the leachate to one or more sump/pump stations. The leachate
will then be pumped to the equalization tank to begin treatment. A conceptual
typical cross-section of a leachate interceptor drain is shown in Figure 16.
Leachate flow monitored from April 1991 to March 1993 during operation of Hie
temporary leachate control and collection system (discussed in Section 1.2.4 of
the RI report) indicated the following average flow rates from the landfill due
to leachate recirculation:
• Approximately 7 gallons per minute (gpm) for the first six months of
operation
• Approximately 12 gpm for the second six month period of operation
• Approximately 13 gpm for the third six month period of operation
• Approximately 14 gpm for the last six months of operation
These flow data indicate that the recirculation flow rate of leachate through the
landfill had reached a maximum approximately 14 gpm. Natural leachate
discharge from the landfill, (i.e. without recirculation), would likely be
considerably lower than 14 gpm. However, an average flow rate of 5 gpm is
considered reasonable for the life of the landfill closure especially since capping
would significantly reduce the leachate generation rate. Therefore, cost
estimations and conceptual design for treatment are based upon a flow rate of
5 gpm.
Leachate Treatment
Figure 17 is a conceptual process flow diagram of the treatment process.
Leachate would be stored in an equalization tank to equalize flow. From there,
the leachate would be pumped into a metals-removal process where the metals
would be precipitated using sodium hydroxide. The precipitate would be
removed by clarification. Polymer would be added to enhance clarification.
31
-------
Record of Decision
Green River Disposal Landfill Site
Metal precipitate sludge would be dewatered in a plate and frame filter press
or an equivalent process. The sludge can then be tested and disposed of in an
approved landfill.
Clarified liquid from the metals-removal process, would be filtered to remove
suspended solids and passed through an air stripper to remove ammonia and
any trace VOCs. The air stripper is comprised of a column filled with specially
designed packing with large surface areas and low fouling characteristics. Air
would be passed counter current to the leachate to strip the ammonia.out of the
liquid. Some of the volatile organic compounds would also be removed in the
air stripper. It is not anticipated that the vapor discharge would need
treatment. However, this would be verified during remedial design.
After air stripping, the pH of the leachate would be lowered to discharge limits,
usually between 6.0 and 9.0. The treated leachate would then be discharged
to an KYPDES approved discharge outfall.
6.2.4 Comparative Analysis of Leachate Alternatives
Overall Protectiveness
Alternative 3 would provide the best overall protection since leachate would be
collected and treated. Alternative 1 and 2 will provide little or no protection to
ecological receptors.
Compliance with ARARs
Only Alternative 3 is expected to be in compliance with ARARs outlined in Section
8.2. Alternatives 1 and 2 may result in a failure to meet Ambient Water Quality
Criteria (AWQC) downstream of the site.
Long-term Effectiveness and Permanence
Alternative 3 would provide the best long-term effectiveness since the leachate is
controlled and hazardous constituents removed. Alternatives 1 and 2 will not provide
any protection to the environment since uncontrolled leachate discharge would
continue.
32
-------
Record of Decision
Green River Disposal Landfill Site
Reduction of Toxicitv. Mobility, or Volume
Alternative 3 is the only alternative that provides direct reduction in toxicity,
mobility and volume of this liquid waste. Landfill capping should considerably reduce
the volume of leachate generated with time since surface water infiltration into the
waste is the only mechanism for generating leachate.
Short-Term Effectiveness ';
Alternative 1 poses the lowest short-term risk since no remedial activities are
performed. Typical construction hazards associated with trench excavations would
be present with alternative 3. Health risks to site workers who come in contact with
leachate constituents during implementation of alternatives 2 or 3 are considered
minimal and controllable.
Implementability
Alternative 2 is considered highly implementable since its components (fencing,
monitoring wells) have already been completed. Implementation of Alternative 3 is
expected to present only routine construction and planning problems.
Cost
No costs are associated with Alternative 1. The present worth total for Alternative
2 is $490,250. Most of this cost is for long-term monitoring and is representative of
the institutional actions for the whole site. The present worth total for Alternative
3 is approximately $3,312,179. Approximately seventy-five percent of this total is for
operation and maintenance of the treatment system and institutional controls.
6.3 Sediment Remedial Alternatives
The remedial alternatives considered address contaminated sediment located along
the unnamed tributary and in the sedimentation pond, shown on Figure 18.
Three remedial alternative were evaluated for sediment:
• No Action
• Limited Institutional Action
• Excavation and consolidation in the landfill
33
-------
Record of Decision
Green River Disposal Landfill Site
6.3.1 Sediment Alternative 1: No Action
This no-action alternative requires no remediation or institutional constraints to
address sediments in the unnamed tributary and sedimentation pond. Sediments
would remain in their current state.
6.3.2 Sediment Alternative 2: Limited Institutional Action
••
The activities for his alternative as applied to sediments are the same as those
described in Section 5.2.2 except that leachate and ground-water quality monitoring
would not be applicable to sediments.
6.3.3 Sediment Alternative 3: Excavation and Consolidation in the Landfill
This alternative involves excavation of stream and impoundment sediments,
dewatering and consolidation of the sediments with landfill waste, both of which
would be capped. Executing this alternative during dry periods may preclude the
need for surface water diversion.
Continued use of the sedimentation pond can be achieved by removal of the
impoundment sediments. A compacted clay lining would be placed within the
sedimentation pond after sediment removal is completed to eliminate possible
exposure by ecological receptors to any remaining sediment residues.
The Unnamed Tributary would return to a more natural state after removal of the
stream sediments. Sediments would be removed from the tributary to the extent that
native soil is visually exposed.
Excavation and removal of the sediments must precede the capping of the landfill.
Placement in the landfill would necessitate regrading of the placement areas. Placing
the sediments under the landfill cap would significantly reduce the potential for
migration of constituents.
6.3.4 Comparative Analysis of Sediment Alternatives
Overall Protectiveness
Overall protection provided by Alternative 3 is considered better than the other
sediment alternatives primarily because the sediments would be contained beneath
the landfill cap preventing both contact with ecological receptors and migration of
34
-------
Record of Decision
Green River Disposal Landfill Site
sediment constituents off-site. Alternative 1 and 2 would not be protective of
ecological receptors as indicated by the Baseline Risk Assessment and downstream
migration of impacted sediments is expected.
Compliance with ARARs
Alternative 3 appears to be the sediment alternative mostly likely to comply with the
ARARs outlined in Section 8.2. Alternatives 1 and 2 are unlikely to satisfy the
location-specific ARARs related to wildlife protection.
Long-term Effectiveness and Permanence
Long-term effectiveness is achieved best with Alternative 3 since the sediments would
be removed from pathways of continued surface water flow which may promote long-
term leaching. Ecological risks posed by the existing sediment quality are expected
to remain with Alternatives 1 and 2.
Reduction of Toxicitv. Mobility, or Volume
Alternative 3 would be effective in reducing the mobility of sediment constituents
since alternative 3 involves landfill containment. No reduction of toxicity or volume
of sediment constituents would be anticipated with implementation of alternative 3.
No reduction of toxicity, mobility or volume of sediment constituents can be
anticipated with alternative 1 and 2.
Short-Term Effectiveness
Short-term effectiveness is achieved best with alternatives 1 and 2 since no remedial
actions (i.e. disturbance of the sediments) would take place. Alternative 3 would have
the lowest short-term effectiveness. However, short-term risk resulting from
sediment excavation and transport can be easily mitigated with engineering controls.
Implementability
Alternative 3 is considered implementable since consolidation of sediments with
landfill waste would allow re-use of the existing sedimentation pond for surface water
run-off control of the capped landfill. Implementation of alternative 3 would also
provide needed subgrade backfill for landfill cap placement.
35
-------
Record of Decision
Green River Disposal Landfill Site
Cost
No costs are associated with alternative 1. The estimated cost for alternative 3 is
approximately $244,000. The present worth cost of 2 is about $490,000. This total
is not directly comparable to the other sediment alternatives since it is applicable to
the site as a whole as previously discussed.
7.0 THE SELECTED REMEDY '
Based on the Remedial Investigation, Baseline Risk Assessment, Feasibility Study
and on consideration of the requirements of CERCLA and the NCP, EPA has
determined that the most appropriate remedy to mitigate the current and potential
ecological risks associated with the Green River Disposal Landfill will consist of the
following:
1. Landfill Alternative 4: Capping With a Composite Barrier Cover
2. Leachate Alternative 3: Collection with Subsurface Drains; Chemical/Physical
Treatment for Removal of Heavy Metals and Organic Compounds; Discharge
of Treated Water into the Unnamed Tributary
3. Sediment Alternative 3: Excavation and Consolidation in the Landfill
4. Removal of surface debris and/or buried wastes located in the east and west
ravines, and dispose these wastes within the landfill cap.
The total present worth cost of implementing these remedies is estimated at
$11,000,000. The objectives for the remedial action are:
Landfill:
Prevent direct exposure with the landfill contents
Minimize storm water infiltration and production of leachate
Prevent migration of contaminants by leachate collection and treatment
Control surface water runoff and erosion
Control fugitive gas emissions
36
-------
Record of Decision
Green River Disposal Landfill Site
Leachate:
• Prevent direct exposure or ingestion of leachate by environmental receptors
• Prevent migration of contaminants from the landfill wastes to the groundwater
and unnamed tributary
Sediment:
™"^~™ ^^^» ^ ^ t.
• Prevent direct exposure to ecological receptors.
7.1 Performance Standards
Landfill Cap
The landfill cap shall, at minimum, be designed and constructed to meet State
performance requirements outlined in 401 KAR 48:080. The components of the cap
shall include: a vegetation/soil top layer (graded to maximize storm water run-off);
a filter and drainage layer; and a combination of a clay layer and a geomembrane
layer to minimize infiltration. The design of the cap shall consider long-term
permanence and minimal long-term maintenance as principal design elements. EPA
in consultation with KDEP and the local community will review and approve the final
cap design.
The cap shall be designed to accommodate for possible settlement, and requirements
for gas venting will be evaluated during the design phase. Applicable or Relevant
and Appropriate Requirements (ARARs) identified for this component are listed in
Section 8.2.
Leachate
The leachate collection system shall be designed and constructed to collect leachate
from the landfill waste at the perimeter of the waste disposal area and from below
the landfill cap. Leachate shall not be permitted to seep through the landfill cap or
migrate off site by any means.
The leachate treatment system shall be designed and constructed to remove or
substantially reduce the concentrations of any hazardous or toxic constituents
present. The treatment system effluent shall meet all applicable, or relevant and
appropriate requirements for discharge on-site to the unnamed tributary. The
effluent discharge shall comply with effluent standards and monitoring requirements
37
-------
Record of Decision
Green River Disposal Landfill Site
pursuant to the Kentucky Pollutant Discharge Elimination System (KPDES)
program. The leachate collection and treatment system shall be maintained
functional and operational for up to 30 years to meet the objectives outlined in the
previous section.
The system shall be designed and constructed based on the conceptual model
presented in Figure 17. ARARs identified for this component of the remedy are listed
in Section 8.2.
Sediment
Contaminated sediment from the unnamed tributary identified in Figure 18, shall be
excavated and consolidated within the landfill, under the landfill cap. Excavation of
the sediment shall be conducted in a manner that will minimize destruction of the
surrounding environment (i.e. trees, wildlife habitats, etc.). The contaminated
sediment in the stream and sedimentation pond identified in the Remedial
Investigation Report shall be removed to the extent that all of the sediment at these
locations will be excavated. EPA will verify by visual inspection that all sediments
in the areas of concern are removed in accordance with this ROD. The stream shall
then be restored to its natural state by regrading and replacement of sediment where
necessary. ARARs identified for this component are listed in Section 8.2.
7.2 Modifying Criteria
7.2.1 State Acceptance
The Kentucky Department for Environmental Protection (KDEP) assisted EPA in
reviewing all technical reports produced during the RI and FS. Upon review of this
ROD, KDEP raised a concern regarding the proposed landfill cap. KDEP believes
that a more appropriate landfill cap would be a cap that meets the requirements of
Kentucky Hazardous Waste Regulations (i.e. a RCRA Subtitle C Hazardous Waste
Landfill Cap). This concern is based on the belief that Kentucky Hazardous Waste
Regulations are ARARs because hazardous wastes may have been disposed at the
site.
EPA does not agree with this assessment for the following reasons. EPA has
determined that Kentucky Hazardous Waste Regulations (i.e. RCRA landfill cap
closure requirements) are not applicable to the Green River Disposal site. Site
records indicate that industrial wastes, that may have been characterized as a
hazardous wastes (under the current RCRA definition), were accepted at the site
38
-------
Record of Decision
Green River Disposal Landfill Site
prior to 1980, when hazardous waste restrictions became effective. The records also
indicate that wastes disposed of at the site after 1980 were primarily miscellaneous
trash, with a few specifically approved exceptions. Therefore, since no RCRA-defined
hazardous wastes were disposed at the site after 1980, RCRA landfill closure
requirements or Kentucky Hazardous Waste Regulations do not apply.
With respect to the design of the landfill cap, EPA has determined that a RCRA
Subtitle C cap may be relevant based on the types of wastes disposed at the site, but
it is not appropriate because of the low-level threats posed by the site and the high
level of protectiveness achieved by a comparable cap. Analytical results of samples
collected from the buried wastes show that the wastes do not exhibit hazardous waste
toxicity characteristics (40 CFR §261.24). The landfill cap selected in this ROD is the
best alternative to the RCRA Subtitle C cap and provides the greatest degree of
protection in comparison to other cap alternatives evaluated.
EPA recognizes that RCRA Closure and Post Closure Care groundwater monitoring
requirements may be relevant and appropriate; however, groundwater monitoring to
further evaluate the extent of contamination at this site will be completed as
discussed in Section .4.1, and the need for a groundwater cleanup action will be
addressed in a subsequent ROD.
Upon consideration of EPA's response to the landfill cap issue, KDEP concurs with
the selected remedy for the landfill. However, KDEP does not fully agree with the
remedial investigation conducted at the KCR site, and therefore, does not concur with
EPA's decision to take no action at the KCR site. A copy of the Kentucky's letter is
included in Appendix A.
7.2.2 Community Acceptance
The local Maceo community organized a group of concerned citizens to monitor the
progress of EPA's investigation and cleanup of the site. This group, called the Green
River Toxic Waste Cleanup Association, is very involved at the site and has actively
participated in the remedy selection process.
Based on the comments provided by the group at the Proposed Plan Public Meeting,
EPA believes that the community accepts and supports the proposed remedy outlined
in this ROD.
39
-------
Record of Decision
Green River Disposal Landfill Site
8.0 STATUTORY DETERMINATIONS
8.1 Overall Protection of Human Health and the Environment
The selected remedy will provide the best overall protection to human health and the
environment by:
• Containing the landfilled mass by capping and immobilizing hazardous
constituents, minimi^ng leachate generation
• Preventing direct exposure of leachate by ecological receptors and minimi zing
off-site leachate migration through collection and treatment
• Preventing/eUminating direct exposure to the landfill wastes and contaminated
sediments by human and ecological receptors.
Implementation of the selected remedy will reduce ecological risks below the
acceptable threshold of one Ecological Quotient (EQ). The selected remedy meets the
NCPs required threshold criteria for protection of human health and the
environment.
8.2 Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
The selected remedy, consisting of the four components identified in Section 7.0, will
meet all Federal and State ARARs identified below. The ARARs are presented as
Chemical-Specific, Location-Specific, and Action-Specific requirements, and are
identified as follows:
Action-Specific ARARs:
1. The landfill cap will, at minimum, meet the requirements established in the
following Kentucky Solid Waste Rules:
• Cap Design Requirements for Contained Landfills (401 KAR 48:080)
• Operating Requirements for Contained Landfills (401 KAR 48:090)
These regulations establish requirements for landfill cap design and site closure,
and are considered relevant and appropriate since the Green River Landfill was
constructed before the effective date of these rules.
40
-------
Record of Decision
Green River Disposal Landfill Site
2. Groundwater monitoring associated with operation and maintenance of the
landfill after construction of the cap shall meet the substantive requirements
outlined in Kentucky Solid Waste Rules, Surface and Groundwater Monitoring
and Corrective Action (401 KAR 48:300). Because the site is an existing closed
facility, these requirements are considered to be relevant and appropriate.
Additionally, EPA recognizes that RCRA Closure and Post Closure Care
groundwater monitoring requirements may be relevant and appropriate; however,
groundwater monitoring to further evaluate the extent of contamination at this
site will be completed as discussed in Section 4.1, and tile need for a groundwater
cleanup action will be addressed in a subsequent ROD.
3. Air quality at the site during construction shall meet the National Ambient Air
Quality Standards (CAA, 40 CFR Part 50) and the Kentucky Ambient Air Quality
Standards (401 KAR 53:010). These standards are considered applicable.
4. The effluent discharge from the leachate treatment system shall meet the
substantive requirements of the Kentucky Pollutant Discharge Elimination
System program (401 KAR 5:055, Section 6). These requirements are applicable
for regulating effluent discharges from the leachate treatment system into the
unnamed tributary.
5. If hazardous wastes are generated by implementation of the selected remedy,
then these wastes shall be managed in accordance with the requirements of the
Resource, Conservation and Recovery Act (RCRA, 40 CFR Parts 260 to 270).
. These requirements, considered applicable to the selected remedy, regulate the
treatment, storage, and disposal of hazardous waste.
Location-Specific ARARs:
1. Fish and Wildlife Protection (16 USC 661-666c, 6 USC 2901 et seq 33 CFR 320-
330; 40 CFR 6.302) requires adequate protection offish and wildlife if any stream
or body of water is modified. These regulations are applicable to remedial
activities associated with the unnamed tributary.
2. Protection of Wetlands (Executive Order 11009 40 CFR 6.302, Appendix A)
regulates actions involving construction of facilities or management of property
in wetlands to avoid adverse effects, minimize potential harm, and preserve and
enhance wetlands to the extent possible. This requirement is considered relevant
and appropriate because remedial actions on-site may affect wetlands and surface
water bodies off-site through effluent discharges in the unnamed tributary.
41
-------
Record of Decision
Green River Disposal Landfill Site
3. Endangered Species Act of 1973 (16 USC 1531-1544) provides protection of
endangered or threatened species. Although no endangered and threaten species
were observed at the site, this requirement is relevant and appropriate to
preserving protected wildlife and their habitats at or near the site during
construction of the remedy.
Chemical-Specific ARARs:
»•
1. Kentucky Water Quality Standards (401 KAR 5:031) establishes surface water
standards protective of aquatic life. These standards are applicable to the
remedy selected to protect surface water bodies from the leachate treatment
effluent discharge.
To Be Considered (TBC) Criteria or Guidance
CERCLA guidance provides for the identification of criteria that may be relevant and
appropriate to the circumstances of the release at a site, but which do not meet the
statutory definition of an ARAR. To be defined as an ARAR, a standard or criterion
must be a requirement or regulation promulgated under federal or state authority,
and must be of general applicability. Other standards or criteria, known as criteria
"to be considered", or TBCs, may be necessary in order for the remedy to be fully
protective of human health and the environment.
EPA has identified the following TBCs which may be used to establish cleanup levels
and other performance standards for the selected remedy:
1. NOAA Technical Memorandum NOS-OMA52 "Potential for Biological Effects of
Sediment-Sorbed Contaminants Tested in the National Status and Trend
Program"
2. Interim Guidance on Establishing Soil Lead Clean-up Levels at Superfund Sites,
OSWER 9355.4-02, September 7, 1989
3. Handbook to Support the Installation Restoration Program (IRP) Statements of
Work, Volume 1, Section 3, "Ecological Risk Assessment", May 1991
4. Conducting Remedial Investigations/Feasibility Studies for CERCLA Municipal
Landfill Sites EPA/540/P-91/001, February 1991, Guidance Document
42
-------
Record of Decision
Green River Disposal Landfill Site
5. Covers for Uncontrolled Hazardous Waste Sites, EPA/540/2-85/002, September
1985 Guidance Document
6. Overview of RCRA Land Disposal Restrictions (LDRs)USEPA Directive: 9347.3-
01FS, July 1989
7. Super-fund Accelerated Cleanup Bulletin, Presumptive Remedies for Municipal
Landfill Sites, Publication 9203.1-021, February 1993 ;
8. Technical Guidance Document: Quality Assurance and Quality Control for Waste
Containment Facilities, USEPA Office of Research and Development, EPA/600/R-
93/182, September 1993
9. Technical Guidance Document: Construction Quality Management for Remedial
Action and Remedial Design Waste Containment Systems, USEPA Office of
Research and Development, EPA/540/R-92/073, October 1992
10. Technical Guidance Document: Final Covers on Hazardous Waste Landfills and
Surface Impoundments, USEPA Office of Solid Waste and Emergency Response,
EPA/530-SW-89-047, July 1989
11. Seminar Publication: Design and Construction of RCRA/CERCLA Final Covers,
USEPA Office of Research and Development, EPA/625/4-91/025, May 1991.
43
-------
RESPONSIVENESS SUMMARY
1.0 OVERVIEW
A 30 day public comment period for the Green River Disposal Site was established
from July 19,1994 through August 17,1994. The purpose of the comment period was
to request public input concerning EPA's recommended cleanup remedy for the site.
The public comment period was initiated through the Proposed Plan Fact Sheet (sent
to concerned citizens and local officials on EPA's mailing list) and through a notice
placed in the local newspaper. A public meeting was held on August 4, 1994 to
discuss the remedial investigation with concerned citizens and formally present EPA's
recommended remedy for the site. The meeting was held at the Maceo Elementary
School in Maceo, Kentucky. EPA representatives responded to comments and
questions from the local community at the meeting. A transcript of the meeting is
included with this document in Appendix B.
Based on the comments provided by the Green River Toxic Waste Cleanup
Association (Cleanup Association), EPA believes that the Maceo community supports
EPA's selected remedy. EPA worked closely with the Cleanup Association to
determine and address the community's concerns throughout the Superfund process.
2.0 BACKGROUND ON COMMUNITY INVOLVEMENT
The local community has had concerns about the site since the landfill began
operating in the early 1970s. The site file retained by the Kentucky Department for
Environmental Protection, Division of Waste Management, documents many nuisance
complaints about the site from neighbors. There were also concerns from adjacent
property owners about leachate and contaminated groundwater.
When the EPA became involved at the site in 1988, the community organized into a
loosely cohesive group. In 1992 a local community group, called the Maceo Concerned
Citizens Group, adopted the Green River Site as one of their projects. By 1993,
members of this group primarily concerned about the Green River Site established
themselves as the Green River Toxic Waste Cleanup Association (Cleanup
Association) to monitor progress at the site. The Cleanup Association remains very
involved in activities related to the site. This group has provided valuable
information about the site and provided assistance to EPA in coordinating meetings
with local officials and with the community at large.
Throughout the remedial investigation and feasibility study, EPA worked closely with
the Cleanup Association. Draft reports and documents were provided for the Cleanup
Association's comments and input. Formal and informal meetings were held in the
community to keep citizens informed about the site and to discuss issues of concern.
44
-------
Record of Decision
Green River Disposal Landfill Site
3.0 SUMMARY OF MAJOR PUBLIC COMMENTS RECEIVED DURING THE
PUBLIC COMMENT PERIOD, AND EPA RESPONSES
EPA issued a Proposed Plan Fact Sheet summarizing the results of the remedial
investigation, feasibility study and baseline risk assessment on July 15 1994. The
fact sheet also described EPA's proposed final remedy for the site and announced a
public comment period. The Fact Sheet was sent to the local community, and to local,
State, and Federal officials. . ;
The 30-day public comment period began on July 19,1994 and ended on August 17,
1994. Two sets of written comments were received by EPA. One set of comments
was submitted by the Kentucky Resources Council, a nonprofit environmental
organization, and the other set of comments was submitted by the Green River
Coordinating Group, who are the Potentially Responsible Parties that have completed
the RI/FS.
The following is a summary of the major comments EPA received during the comment
period and EPA's response:
Kentucky Resources Council (KRC) comments:
It appears that all of the comments provided by KRC were based on a cursory review
of the Proposed Plan Fact Sheet. One of the purposes of the Proposed Plan Fact
Sheet is to provide the public with a brief summary of the remedial investigation
results. Conclusions about how the investigation was conducted, cannot be made
from the information presented in the fact sheet. Many of KRC's concerns can be
specifically addressed by a review of the RI and FS Report, located in the Green River
Disposal Landfill Site Administrative Record.
1. COMMENT: The KRC is concerned that the investigation and characterization
of the Kelly Cemetery Road Site (Road Site) was not adequate to support a
remedial decision. The following two points were presented:
1) Not enough samples were collected at the Road Site to perform an adequate
risk assessment in accordance with Kentucky Regulations (KRS 224.01-400).
2) No sediment samples were collected in the drainage ways or intermittent
stream located in the ravine between the Road Site and the landfill
45
-------
Record of Decision
Green River Disposed Landfill Site
EPA RESPONSE: The Kelly Cemetery Road Site was included as part of the
Green Riyer Disposal Landfill Superfund Site because of concerns that residual soil
contamination was not addressed during the drum removal conducted by the
Commonwealth. Kentucky Division of Waste Management files do not clearly
indicate the extent in which soil in the drum disposal area was investigated or
remediated. Additionally, the files do not clearly define or locate the area where
the drum removal occurred. Subsequently, twenty-five acres were investigated
alongside Kelly Cemetery Road to locate the drum disposal area and determine if
a remedial response was necessary.
The Potentially Responsible Parties prepared a risk-based statistical sampling plan
with assistance from EPA's Office of Research and Development, Quality
Assurance Management Staff. The sampling plan for the Road Site was prepared
and implemented in accordance with the Data Quality Objectives Process for
Superfund (EPA 540-R-93-071). The number, types and location of soil samples
were meticulously determined. It was shown statistically that a sample composed
of nine aliquots adequately characterizes the presence of contaminants in an acre
area. Composite soil samples were collected from each acre in the 25 acre study
area. The samples were analyzed for specific contaminants associated with the
wastes disposed at the site. Additionally, soil samples collected from the areas
suspected to be the drum disposal area were analyzed for a complete list of
compounds (Target Compound List and Target Analyte List compounds). The
highest concentrations detected in the samples were then used to estimate human
health risks associated with exposure to the surface soil. The results of the risk
assessment were within EPA's acceptable limits.
A sediment and surface water sample was collected from the ravine between the
Road Site and the landfill, and numerous sediment and surface water samples
were collected topographically upgradient of the landfill and downgradient from
the Road Site. The sample results did not show the presence of contaminants
associated with the Road Site.
The amount and types of soil samples collected from the Kelly Cemetery Road site
fully satisfies the remedial investigation/feasibility study (RI/FS) requirements of
the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40
CFR §300.430). The State statute KRS 224.01-400 is substantially equivalent to
the NCP requirements for performance of an RI/FS and selection of a remedy.
EPA believes that the quantity and quality of the data collected from the Kelly
Cemetery Road Site is sufficient to adequately support a no-action decision.
2. COMMENT: KRC believes that Resource Conservation and Recovery Act (RCRA)
closure requirements is an action-specific Applicable or Relevant and Appropriate
Requirement (ARAR) because of the nature of the ferrocyanide wastes disposed at
46
-------
Record of Decision
Green River Disposal Landfill Site
the site. Additionally, since RCRA should be an ARAR and the area may be
considered a land disposal unit, KRC suggests that groundwater monitoring would
also be considered an action-specific ARAR.
EPA RESPONSE: The premise of this comment is that soil contamination exists
at the Kelly Cemetery Road Site. However, based on the results of the remedial
investigation (indicating that no significant residual surficial soil contamination
exists), EPA has determined that no further action is necessary. Therefore, since
no remedial action is proposed, RCRA closure requirements are not appropriate for
consideration;
3. COMMENT: It appears from the fact sheet that soil sampling around the landfill
perimeter showed significant levels of contamination. It is not clear whether
sufficient sampling was performed to determine the full extent of such
contamination, or if such sampling is planned as part of the remedy to ensure that
all the contamination is brought under the cap.
EPA RESPONSE: No supplemental surface soil sampling will be necessary for
soil around the landfill since the proposed landfill cap will encompass all of the
areas where surficial soil samples were collected. Additionally, surface soils
adjacent to the landfill in areas outside the cap will be consolidated within the cap.
Those areas will be regraded and covered with a vegetative layer.
4. COMMENT: Based on the nature of the identified industrial wastes disposed of
at the landfill, and the hazardous constituents detected at the site, a RCRA cap
over the landfill would appear to be an action-specific ARAR.
EPA RESPONSE: EPA has determined that RCRA closure requirements are not
applicable to the Green River Disposal site. Site records indicate that industrial
wastes, that may have been characterized as a hazardous wastes (under the
current definition), were accepted at the site prior to 1980, when RCRA restrictions
became effective. The records also indicate that wastes disposed of at the site after
1980 were primarily miscellaneous trash, with a few specifically approved
exceptions. Therefore, since no RCRA-defined hazardous wastes were disposed at
the site after 1980, RCRA landfill closure requirements are not applicable.
With respect to the design of the landfill cap, EPA has determined that a RCRA
Subtitle C cap may be relevant based on the circumstances at the site, but it is not
appropriate because of the low-level threats posed by the site and the high level
of protectiveness achieved by a comparable cap. Analytical results of samples
47
-------
Record of Decision
Green River Disposal Landfill Site
collected from the buried wastes show that the wastes do not exhibit hazardous
waste toxitity characteristics (40 CFR §261.24). The landfill cap selected in this
ROD is the best alternative to the RCRA Subtitle C cap and provides the greatest
degree of protection in comparison to the other cap alternatives evaluated.
EPA recognizes that RCRA Closure and Post Closure Care groundwater monitoring
requirements may be relevant and appropriate; however, groundwater monitoring
at this site will be addressed in a subsequent ROD. ;.
5. COMMENT: The KRC is concerned that the Presumptive Remedy Approach
implemented at this site has limited the types of possible remedial alternatives
evaluated in the feasibility study.
EPA RESPONSE: The presumptive remedy approach for municipal landfills was
developed by EPA based on an analysis of feasibility studies conducted for similar
types of sites. The EPA analysis concluded that containment is the most
appropriate type of remedy for municipal landfills, except under unusual or site-
specific circumstances. EPA decided to use this approach at the Green River site
since the remedial investigation confirmed that there were no unusual
circumstances to consider. This approach was utilized to streamline the evaluation
of the containment remedies for the landfill only, and was not applied to the
remedy evaluation for leachate or sediment treatment alternatives. The feasibility
study conducted for this site complies with the requirements of the NCP and
included all reasonable remedial technologies appropriate for this site.
6. COMMENT: The KRC is concerned that selecting a landfill remedy prior to
reaching a conclusion regarding groundwater may result in a final overall site
remedy that would be a less effective source control remedy.
EPA RESPONSE: At this site, selection of a landfill cap, leachate collection and
treatment, and sediment treatment, is based on factors independent of
groundwater remedy considerations. As stated in the Proposed Plan Fact Sheet,
EPA will conduct additional groundwater sampling and analysis to better
determine the relationship between the landfill and groundwater. Selection of a
landfill cap and leachate collection system will have no relevancy on selecting a
groundwater remedy, or have no impact on the effectiveness of a groundwater
pump-and-treat system.
Upon evaluation of the additional groundwater analyses, EPA will issue a separate
Record of Decision to document a final decision concerning groundwater at the site.
48
-------
Record of Decision
Green River Disposal Landfill Site
Green River Coordinating Group (Coordinating Group) Comments:
1. COMMENT: The Coordinating Group supports EPA's decision to conduct
additional groundwater analyses, but recommends shortening the planned two year
groundwater monitoring period. The Coordinating Group feels that based on the
age of the landfill, a two year period may not be required.
EPA RESPONSE: EPA is not opposed to shortening the monitoring period, and
encourages any efforts to collect the data necessary as quickly as possible.
However, EPA will not approve a sampling plan that does not provide the
necessary data upon which to base a remedy decision, or accept any data that may
be suspect.
2. COMMENT: The Coordinating Group agrees that containment is the most
appropriate type of remedy for this site. However, they do not agree with the
landfill cap remedy alternative selected by EPA. The Coordinating Group believes
that the low risks associated with the site does not justify the use of a composite
barrier throughout the site. They recommend selecting a combination of
Alternatives 2 (capping with a clay barrier) and 3 (capping with a single barrier
geomembrane), with the flexibility of formally deciding upon the final configuration
during the design process.
EPA RESPONSE: EPA selected the composite barrier cap as the preferred
alternative because this design, in comparison to the other alternatives evaluated,
provides the optimum balance of the nine evaluation criteria required by the NCP.
EPA recognizes'the need for design flexibility, and believes that the composite
barrier cap selected can provide the flexibility needed for this site. EPA also
acknowledges that the composite cap may be difficult to construct over certain
areas of the site because of slope considerations. Therefore, to allow for the
difficult constraints imposed by site (slope, site access, etc.), and according to the
NCP (40 CFR 300.430(e)(5)), EPA may consider alternate innovative cap design
modifications if those design modifications provide comparable or superior
performance or implementability; provide for fewer or lessor adverse impacts to the
surrounding community than the original approach; and lowers costs. EPA in
consultation with KDEP and the local community will review and approve the final
cap design.
49
-------
TABLES INCLUDED IN THIS
RECORD OF DECISION
HAVE BEEN REPRODUCED FROM
THE GREEN RIVER DISPOSAL SITE
REMEDIAL INVESTIGATION REPORT AND
FEASIBILITY STUDY, JULY 1994
PREPARED BY LAW ENVIRONMENTAL, INC.
-------
TABLE 1
IS LOCATED ON PAGE 4
-------
CONSTITUENTS DETECTED IN LEACHATE SEDIMENT SAMPLES
GREEN RIVER DISPOSAL SITE
DAVIESS COUNTY, KENTUCKY
AUGUST 1990
Page 1 of 2
Constituents
Frequency of Detection
Range of Detected
Concentrations
Location of Maximum Concentration
Detected
VOLATILES (mg/kgl
2-Butanone
4-Methyl-2-pentanone
Acetone
1 of 10
1 of 10
7 of 10
NA
NA
0.007J
0.065
0.017
0.24
LS-09
LS-08D
LS-09
SEMI-VOLATILE (mg/kgl
2-Chlorophenol
4-Methylphenol (p-Cresol)
Anthracene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzyl Alcohc!
Di-n-butyl phthalate
Isophorone
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
1 of 11
2 of 11
1 of 11
1 of 11
1 of 11
3 of 11
3 of 11
1 of 11
3 of 11
3 of 11
1 of 11
4 of 11
NA
1.6
NA
NA
NA
0.077J
0.12
NA
NA
0.1 7J
NA
0.042J
0.85
2.4
0.8
0.66
0.79
2.4
1.1
1
1.9
0.71
0.36
1.0
LS-C05
LS-06
LS-C05
LS-C05
LS-COS(RE)
LS-06
LS-C03
LS-C05
LS-C05
LS-C05
LS-06
LS-COS
TOTAL METALS (mg/kg)
Aluminum
Antimony
Arsenic
Barium
Beryllium
10 of 10
4 of 10
10 of 10
9 of 10
9 of 10
874
11. 6B
1.2B
28.6B
2
10900
44.2
24.3
1350
9.6
LS-02
LS-14
LS-14
LS-14
LS-14
-------
Table 2 (continued)
CONSTITUENTS DETECTED IN LEACHATE SEDIMENTS
GREEN RIVER DISPOSAL SITE
DAVIESS COUNTY. KENTUCKY
AUGUST 1990
Page 2 of 2
Constituents
Cadmium
Calcium
Chromium
Frequency of Detection
6 of 10
10 of 10
9 of 10
Range of Detected
Concentrations
1.2B
1478
16.3
36.3
26900
200
Location of Maximum Concentration
Detected
LS-06
LS-06
LS-06
TOTAL METALS (Continued)
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
9 of 10
8 of 10
10 of 10
10 of 10
9 of 10
10 of 10
1 of 10
9 of 10
9 of 10
1 of 10
9 of 10
10 of 10
10 of 10
9B
14.3
334
1
1480
5.8
NA
24.3
1760
NA
3340
1.9B
9.4
22.8
124
175000
2340
4570
4450
0.56
133
6950
8.8
8810
25.1
16400
LS-C02
LS-06
LS-14
LS-06
LS-06
LS-06
LS-06
LS-06
LS-08
LS-09
LS-06
LS-02
LS-06
J - Indicates an estimated value. Concentration detected was below the Contract Required Quantitation Limit (CRQL).
B • The reported value was obtained from a reading less than the Contract Required Detection Limit (CRDL).
RE - Sample results from reanalysis.
NA - Not applicable.
For sample locations, see Figure 2-6.
Prepared by:
Checked by:'
Approved by:
-------
Table 3
CONSTITUENTS DETECTED IN LEACHATE SEEP WATER SAMPLES
GREEN RIVER DISPOSAL SITE
DAVIESS COUNTY. KENTUCKY
AUGUST 1990
Page 1 of 2
Constituents
VOLATILES lug/LI
4-Methyl-2-pentanona
Chlorobanzena
Ethylbenzene
Toluene
Xylenes
Frequency of Detection
Range of Detected Concentrations
3 of 7
3 of 7
3 of 7
3 of 7
2 of 7
U
U
5
0.3J
18J
13
44
26
14
32
location of Maximum Concentration Detected
LW-8
LW-6
LW-6
LW-8
LW-8
6EMI-VOLATILES lug/L)
2-Methylphenol (o-Cresoll
4-Methylphenol (p-Crosoll
Naphthalene
bla(2-Ethylhaxyl|phth8late
Dimethyl phthalate
1 of 7
1 of 7
5 of 7
5 of 7
3 of 7
NA
NA
3J
3J
7J
19
17
21
30
13
LW-8 D
LW-8 D
LW-8D
LW-2
LW-8
INORGANICS tmrj/L)
Aluminum
Anenlc
Barium
Cadmium
Calcium
Chromium
Copper
Cyanide
7 of 7
1 of 7
7 of 7
2 of 7
7 of 7
5 of 7
6 of 7
4 of 7
0. 1 34 BEN
NA
0.370
0.004 B
65.8
0.009 B .
0.011 B
0.0191 N
3.70
0.01 6 BW +
2.46
O.OOB
925
0.017
0.412
0.137
LW-2
LW-8
LW-14
LW-2
LW-2
LW-2S (A)
LW-8
LW-2
-------
Table 3 (continued)
CONSTITUENTS DETECTED IN LEACHATE SEEP WATER SAMPLES
GREEN RIVER DISPOSAL SITE
DAVIESS COUNTY, KENTUCKY
AUGUST 1990
Page 2 of 2
Constituents
Iron
Lead
Magnesium
Manganese
Mercury
Nlckal
Potassium
Illvi-r
Sodium
Zinc
Frequency of Detection
7 of 7
4 of 7
7 of 7
7 of 7
1 of 7
7 of 7
7 of 7
.1 of 7
7 of 7
7 of 7
Range of Detected Concentrations
5.55
0.003 BWN
169
0.130
NA
O.O26 B
443
OO11
4370
0.0128
69.2
0.457
710
12.4
0.00023
0.065
6010
OO74
9850
2.05
Location of Maximum Concentration Detected
LW-14
LW-C01
LW-16
LW-2
LW-6
LW-6
IW.R
LW-? A 1 Wlfi
LW-8
LW-C01
NOTE: Samples analyzed Included LW-O2. LW-06, LW-08, LW-09. LW-14, LW-16. and LW-CO1.
B - The reported value was obtained from a reading less than the Contract Required Detection Limit (CROL).
E • The reported value is estimated because of the presence of interference.
N - Spiked aample recovery was not within control limits.
W • Post-digestive spike for Furnace AA analysis is out of control limits, while sample absorbance Is less than 50% of spike absorbance,
J • Indicates an estimated value.
+ - Correlation coefficient for the MSA is less than 0.995.
(A) • Duplicate of LW-OG.
NA • Not applicable.
For sample locations, see Figure 2-6.
Prepared by: 7ZW Date;
Checked by: tyA Date:
Approved by: //TJ Date:
-------
CONSTITUENTS DETECTED IN LEACHATE WATER SAMPLES
GREEN RIVER DISPOSAL SITE
DAVIESS COUNTY, KENTUCKY
JANUARY 1993
r t't t
Freauencv of Detection
Ranaa of Detected Concentrations
VOLATILES luo/l)'
4 M th I 2 t
Ar^tnnn
R
Phi h
Ethvlbenzene
Xvlenes. Total
SEMI-VOIATILES lug/I):
2 4-DimethvlDhenol
2-Mathylphenol (o-Cresol)
TOTAL METALS Img/L):
/\|umlnum
Barium
Cadmium
Calcium
Chromium
Cvanlfia
Iron
Maanefilum
Manoani-KB
Nickel
Potjinslum
Sodium
Zinc
2 of 4
1 of 4
? nf 4
9 of 4
2 of 4
3 of 4
2 of 3
1 of 3
3 of 3
3 of 3
1 of 3
3 of 3
1 of 3
3 of 3
2 of 3
3 of 3
3 of 3
2 of 3
3 of a
3 of 3
3 of 3
9 J
1 J
1 J
5 J
0.9 J
7 J
NA
1.44
0:0676 B
NA
33.B
NA
0.0061 B
3.24 N
24.7
0.16
0.034 B
?fl n
204
0.0224
10
69
a
13
14
29
76
60
2.48
2.42
0.008
141
OO24
00271
35. B N
31 B
1 21
OO97
v;p,n
8050
1.18
Location of Maytmum Concentration Detected
LW01E
IW01FO
IW01F
IW01E
LW01E
LW01E
LW010E
LW01DE
LW01DE
LW01DE
SWLCPB
L WO IDE
LW01DE
SWLCPB
LW01DE
1 WO1 DF
IW01DE
1 WO1 OF
I WO1CF
LW01 CE
SWLCPB
Ammonia Nitrogen Img/l)
3 of 3
2.1
530
LW01CE
NOTES: SWCPA and SWCPB are leachata pond samples. LW-O1CE It a non-volatile seep composite and LW-O1E and LW-02E are grab-seep samples for volatile organic*.
B - The reported value was obtained from a reading lets than the Contract Required Detection Limit (CRDL).
N • The value !• estimated because spike sample recovery was not within control limits.
J • Indicates an estimated value. Concentration detected was below the Contract Required Quantltatlon Limit (CRQL).
NA • Not applicable.
The «ampto locations are shown on Figure 2*7.
Prepared by:
Checked by:
Approved by:
-------
Table 5
CONSTITUENTS DETECTED IN AMBIENT AIR
Green River Disposal Site
Daviess County, Kentucky
PARAMETER
VOLATILE COMPOUNDS fag/m3):
2— Butanone
* Acetone
* Benzene
* Cumene
• Etbylbenzene
Heptane
* Hexane
* Toluene
* Trichloroethene
* Xylenes, Total
TOTAL METALS (fiftim3):
Copper
Iron
* Manganese
FREQUENCY
OF
DETECTION
1
2
6
1
"'• 6
3
6
6
1
6
2
5
5
/
/
/
/
/
/
/
/
/
/
/
/
/
6
6
6
6
6
6
6
6
6
6
6
6
6
DETECTION
LIMITS
10
10
5
5
5
5
5
5
5
5
0.0036
0.011
0.0018
RANGE OF
DETECTED SELECTION
CONCENTRATION CRITERIA
5 J -
3.6 J -
5.5
6
5.4
27
17
0.023
0.142
0.009
15
30
28 '
7.1
100
43
52
110
6.8
107
0.034
0.284
0.0296
1 a
• a
a
a
a
a
a
a
a
* = Constituents of concern
a = Selected as constituent of concern based on the toxicity screen
-------
Table 6
CONSTITUENTS DETECTED IN SURFACE WATER
Green River Disposal Site
Daviess County, Kentucky
PARAMETER
DISSOLVED METALS Cme/LY
Aluminum, Dissolved
Barium, Dissolved
Calcium, Dissolved
Copper, Dissolved
Iron, Dissolved
Magnesium, Dissolved
Manganese, Dissolved
Potassium, Dissolved
Sodium, Dissolved
Zinc, Dissolved
TOTAL METALS (me/LV
Aluminum, Total
* Arsenic, Total
* Barium, Total
* Beryllium, Total
Cadmium, Total
Calcium, Total
Chromium, Total
Cobalt, Total
• Copper, Total
* Cyanide, Total
* Iron, Total
•Lead, Total
Magnesium, Total
• Manganese, Total
• Mercury, Total
•Nickel, Total
Potassium, Total
Selenium, Total
• Sodium, Total
Thallium, Total
Vanadium, Total
* Zinc, Total
VOLATILES fu.g/LV
1,1,1 -Trichloroethane
Acetone
Carbon disulfide
Dichloromethane - Methylene Chloride
Xylenes, Total
SEMI -VOLATILES Cug/L):
4-Methyl-2— pentanone
Acenaphthene
Benzole Acid
bis(2-Ethylhexyl) phthalate
Diethyl phthalate
• Ammonia Nitrogen (mg/L)
FREQUENCY
OF
DETECTION
2
3
3 ,
3
3
3 ,
3
2
3
3
19
2
21
4
1
21
2
2
14
12
21
11
21
21
4
5
17
3
21
1
1
20
1
7
3
10
5
1
1
4
2
3
4
/ 3
/ 3
/ 3
/ 3
/ 3
L 3
/ 3
/ 3
/ 3
/ 3
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 21
/ 20
/ 21
/ 21
/ 21
/ 21
/ 18
/ 16
/ 18
/ 18
/ 5
RANGE OF
DETECTION
LIMITS
0.0115 -
1.985 -
0.023 -
0.001 -
0.002 -
0.0005 -
0.0025 -
0.02 -
0.0035 -
0.0035 -
0.0025 -
0.004 -
0.005 -
0.001 -
0.1 -
0.003 -
0.011 -
0.001 -
0.0015 -
0.0025 -
0.001 -
2.5 -
5 -
2.5 -
2.5 -
2.5 -
5 -
5 -
25 -
5 -
5 -
0.023
0.002
0.02
0.005
0.005
0.144
0.004
3.97
0.254
0.002
0.2
0.01
0.2
0.005
0.0249
5
0.01
0.05
0.025
0.01
0.1
0.003
5
0.015
0.02
0.04
5
0.01
5
0.01
0.05
0.02
5
10
5
70
5
10
12
50
12
12
0.03
RANGE OF
DETECTED SELECTION
CONCENTRATIONS CRITERIA
0.0252 B
0.0357 B
30.5
0.0059 B
0.0216 B
10.7
0.419
181
4.97 B
0.037 E
0.1 B
0.0037 BW -
0.0367 B
0.0016 B
29.6 E -
0.0072 B
0.0092 B
0.0051 B
0.0043 B
0.175
0.0013 BN -
11
0.294 E
0.0002
0.0198 B
1.06 B
0.0013 B
4.71 B
0.004 B
4 J
0.7 J
1 J
0.4 J
2 J
0.6 J
0.6 J
17
0.0332 B
0.157 B
70.9
0.0097 B
0.12
42.4
0.763
237
515
0.163 E
2.29
0.006 B
1.43
0.0036 B
0.0249 N
335 E
0.0099 B
0.0195 B
0.0256
0.0683
29.1
0.019 B
190
9.67 E
0.0004
0.0835
779
0.0019 BN
2920 E
0.001 B
0.0057 B
0.803
0.4 J
20
3 J
6
0.8 J
4 BJ
0.7 J
4 J
2 J
6 J
180
;.
c
b,c
b,c
a
c
c
c
c
b,c
c
c
c
a
a
c
c
• = Constituents of concern
a = Eliminated because of low frequency of detection
b = Selected because of toxicity screening (Appendix H)
c = Selected because constituent maximum concentration exceeded AWQC (human health or aquatic life)
-------
Table 7
CHEMICALS DETECTED IN SURFACE WATER SEDIMENTS
Green River Disposal Site
Daviess County, Kentucky
FREQUENCY
OF
PARAMETER DETECTION
TOTAL METALS (mg/kgl:
Aluminum
Antimony
• Arsenic
•Barium
• Beryllium
* Cadmium
Calcium
* Chromium
Cobalt
Copper
Iron
•Lead
Magnesium
* Manganese
Mercury
• Nickel
Potassium
Selenium
Silver
Sodium
•Thallium
* Vanadium
• Zinc
VOLATILES (mg/kgV
1,1,1 -Trichloroethane
2— Butanone
Acetone
Carbon disulCde
Dichloromethane - Methylene Chloride
Ethylbenzene
Toluene
Trichloroethene
Xylenes, Total
SEMI -VOLATILES (rug/kg):
2— Methylnapthalene
4-Methylphenol (p-Cresol)
Acenaphthene
Anthracene
Benzoic Acid
Benzo(a) anthracene
Benzo(a) pyrene
Benzo(b) fluoranthenc
Benzo(g,h,i) perylene
Benzo(k) Duoranthene
bis(2-Ethylhexyl) phthalate
Butyl benzyl phthalate
Chrysene
Dibenzofuran
Dibenzo(a,h) anthracene
Diethyl phthalate
30 ,
1
30 ,
30 ,
•19 ,
18
30
30
30
30 ,
30
30
30
30
3
29
28
3
4
25
3
30
30
2
12
24
1
17
1
14
1
2
1
I
2
8
10
15
12
15
8
10
24
7
16
1
1
6
f 30
f 30
f 30
f 30
f 30
f 30
/ 30
/ 30
/ 30
f 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 34
/ 34
/ 34
/ 34
/ 34
/ 34
/ 34
/ 34
/ 34
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
/ 30
RANGE OF
DETECTION
LIMITS
0.005 /
0.01 /
0.01 /
0.005 /
0.005 /
0.005 /
0.005 /
0.005 /
0.005 /
035 /
035 /
035 /
035 /
1.8 /
0.35 /
0.35 /
035 /
035 /
035 /
035 /
035 /
035 /
035 /
035 /
035 /
NA
18.1
NA
NA
058
23
NA
NA
NA
NA
NA
NA
NA
NA
0.18
3.2
1840
2.8
1.9
118
1.4
NA
NA
0.012
0.017
0.024
0.012
0.012
0.012
0.012
. 0.012
0.012
2.3
2.3
2.3
2.3
12
23
2.3
2.3
2.3
2.3
2.3
23
23
2.3
23
23
RANGE OF
DETECTED SELECTION
CONCENTRATIONS CRITERIA
1710 /
1.1 BS /
17 B /
031 B /
1.2 N /
533 B 1
5.2 /
3.8 B /
1.7 B /
10400 /
3.4 /
379 B /
183 • /
0.21 N /
3.4 B /
123 B 1
0.2 B 1
IB /
743 B 1
0.19 B /
5.2 B /
22.9 • /
0.004 J /
0.004 J 1
0.003 J 1
0.0004 J 1
0.0009 J /
0.024 J J
0.018 J J
0.11 J /
0.01 U J
0.026 J /
0.013 J /
0.026 J /
0.013 J 1
0.038 J 1
0.01 J /
0.009 J >
0.01 J ;
27000 •
165 N*
283 N
159
1.2
95
23100
88.8 N'
14.1
116 N*
53800
580 E*
8670
2580
039 N
57.7
4730
0.46 B
1.4 B
4920
0.4 B
385
4300'
0.0005 J
0.025
0.19 B
0.001 J
0.088 B
0.0009 J
0.004 BJ
0.01
0.001 BJ
0.019 J
032 J
0.03 J
0.081 J
1.1 J
0.18 J
0.17 J
0.24 J
0.1U
0.073 J
14
036 J
0.17 J
0.011 J
0.064 J
' 0.025 J
a
a
*i a,b
a,b
a,b
a,b,c
a,b
a,b
a
a
a,c
a
a,b
a,b,c
a
a
a
a,b
a,b
a,b,c
-------
Table 7 (continued)
CHEMICALS DETECTED IN SURFACE WATER SEDIMENTS
Green River Disposal Site
Daviess County, Kentucky
PARAMETER
FREQUENCY
OF
DETECTION
RANGE OF
DETECTION
LIMITS
RANGEOF
DETECTED
CONCENTRATIONS
SELECTION
CRITERIA
Di-n-butyl phthalate
Di—n-octyl phthalate
Fluoranthene
Fluorene
Indeno(l,23—cd) pyrene
Naphthalene
Phenanthrene
Pyrene
1
4
19
4
8
19
18
30
27
30
30
30
30
30
30
035
035
035
035
035
035
035
035
23
23
23
23
23
23
23
23
0.008 J
0.006 J
0.014 J
0.023 J
0.009 J
0.005 J
0.14 BJ
0.026 J
038 J
0.029 J-
0.11 J
0.014 J
0.27 J
0.42 J
PESTICIDES/PCBs fmg/kgV.
4,4-DDD
4,4 -DDT
Aldrin
Dieldrin
gamma— BHC
Methoxychlor
•PCB-1248
1
1
1
1
1
1
23
/ 26
/ 26
/ 29
/ 29
/ 29
/ 29
/ 29
0.007 /
0.007 /
0.003 /
0.007 /
0.003 /
0.035 /
0.07 /
0.016
0.016
0.018
0.036
0.018
0.18
0.18
0.22
0.0096 J
0.0021 J
0.0052 J
0.0022 J
0.046 J
0.0059 J / 031
b,c
NA = Not Available Inorganic detection limits were not furnished with the data package.
* = Constituents of concern
a = Constituents above two times the mean background concentration
b = Constituents selected by toxicity screen which are above estimated concentrations
c = Constituents exceeding NOAA criteria which are above estimated concentrations
-------
Table 8
CONSTITUENTS DETECTED IN LEACHATE WATER
Green River Disposal Site
Daviess County, Kentucky
PARAMETER
TOTAL METALS fmg/U):
Aluminum, Total
* Arsenic, Total
* Barium, Total
* Beryllium, Total
* Cadmium, Total
Calcium, Total
* Chromium, Total
Copper, Total
* Cyanide, Total
Iron, Total
* Lead, Total
Magnesium, Total
Manganese, Total
•Nickel, Total
Potassium, Total
Selenium, Total
* Silver, Total
Sodium, Total
Vanadium, Total
• Zinc, Total
VOLATILES ftig/L):
4-Methyl— 2-pentanone
Acetone
* Benzene
Chlorobenzene
Ethyl benzene
Toluene
Xylenes, Total
SEMI-VOLATILES Otg/L):
1,2— Dichlorobenzene
* 2,4-Dirnethylphenol
2 — Methyln aphthalene
2-Methylphenol (o-Cresol)
bis(2-Ethylhexyl) phthalate
Dibenzofuran
Isophorone
Naphthalene
* Ammonia Nitrogen (mg/L)
FREQUENCY
OF
DETECTION
3 /
3 /
3 /
3 /
1 /
3 /
1 /
3 /
3 /
2 /
3 /
3 /
3 /
2 /
3 /
1 /
1 /
3 /
1 /
3 /
2 /
1 /
2 /
2 /
2 /
2 /
3 /
1 /
2 /
1 /
1 /
3 /
1 /
2 /
1 /
3 1
3
3
3
3
'3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
3
3
3
3
3
3
3
3
3
RANGE OF
DETECTION
LIMITS
0.1
0.002
0.016
0.001
0.006
0.1
0.01
0.004
0.004
0.05
0.003
0.1
0.003
0.011
0.1
0.01
0.003
0.24
0.005
0.004
10
10
5
5
5
5
5
10 - 12
10 - 20
10 - 20
10
10 - 20
10 - 20
10 - 20
10 - 20
0.03
RANGE OF
DETECTED SELECTION
CONCENTRATIONS CRITERIA
1.44
0.0017 BN -
0.0676 B
0.001 B
33.8
0.0074 B
0.0061 B
3.24 N
0.0034 B
24.7
0.16
0.034 B
28.8
204
0.0224
9 J
1 J
1 J
5 J
4 J
0.9 J
7 J
1 J
3 J
2.1
2.48
0.033 BN
2.42
0.002 B
0.008
141
0.024
0.01 B
0.0271
35.8 N
0.017 B
316
1.21
0.097
3590
0.0028 B
0.003 B
8050
0.008 B
1.18
10
69
8
13
14
5 J
29
1 J
76
3 J
50
4 J
0.9 J
6 J
9 J
530
;.a,b
a,b
a,b
a,b
a,b
b
b
a,b
b
a,b
a.b
a
b
* = Constituent of concern
a = Constituent selected based on toxicity screen (Appendix H) and is above background concentration (inorganic)
b = Constituent selected based on exceedance of AWQC (human health or aquatic life) and is above estimated concentration
-------
Table 9
CONSTITUENTS DETECTED IN SOIL FROM KELLY CEMETERY
Green River Disposal Site
Daviess County, Kentucky
FREQUENCY
OF
PARAMETER .DETECTION
METALS frog/kg):
Aluminum
Arsenic
Barium
Beryllium
Calcium
* Chromium
Cobalt
Copper
* Cyanide
Iron
•Lead
Magnesium
Manganese
• Mercury
Nickel
Potassium
Selenium
Silver
Sodium
• Thallium
Vanadium
•Zinc
SEMI-VOLATILES (mg/kg):
1,2,4— Trichlorobenzene
4-Chloro-3-methyl Phenol
Acenaphthene
Benzq(a) anthracene
Benzo(b) fluoranthene
bis(2-Ethylhexyl) phthalate
Chrysene
Di-n-butyl phthalate
Fluoranthene
N— Nitrosodi— n-propylamine
Phenanthrene
Pyrene
PESTICIDES/PCBs (mg/kg):
Endrin ketone
PCB-1248
PCB-1260
8 ,
25 ,
8 ,
8 ,
8 ,
25 ,
8 ,
8 ,
2 ,
8 ,
25 ,
8
8 ,
2 ,
8 ,
8 ,
6 ,
.1 ,
4
2
8
8
1
1
1
1
1
1
1
4
3
1
2
5
1
2
2
1 8
1 25 ,
/ 8
/ 8
( :8
f 25
f 8
/ 8
f 8
/ 8
/ 25
/ 8
/ 8
1 8
f 8
f 8
/ 8
/ 8
/ 8
/ 8
/ 8
/ 8
/ 8
/ 8
/ 8
/ 8
/ 8
/ 8
/ 8
/ 8
/ 8
/ 8
/' 8
/ 8
/ 8
/ 8
/ 8
RANGE OF
DETECTION
LIMITS
NA -
NA -
NA -
NA -
NA -
NA -
0.42 -
0.42 -
0.42 -
0.42 -
0.42 -
0.02 -
0.42 -
0.02 -
0.42 -
0.42 -
0.42 -
0.42 -
0.0006 -
0.042 -
0.042 -
NA
NA
NA
NA
NA
NA
NA
NA
0.55
NA
NA
NA
NA
0.13
NA
NA
0.19
1.5
49.9
2
NA
NA
0.45
0.45
0.45
0.45
0.45
0.12
0.45
0.45
0.45
0.45
0.45
0.45
0.009
0.09
0.09
RANGE OF
DETECTED SELECTION
CONCENTRATIONS CRITERIA
7260
4.1 N -
67.9
0.3 B
1560
9
8.2 B
10.8
6.6
17900
14.4
1430
418
0.12
17.5
675 B
0.27 B
78.3 B
0.19 BN -
17.4
52.6
0.009 J
0.014 J
0.008 J
0.013 J
0.31
0.091
14800
17.8 S
112
0.55 BN
4770
82.4
12.3 N
29.2
62.9
32500
307
2840
732
0.15
30 N
1160 E
0.53 B
0.7 BN
89.6 B
0.23 BN
31 N
212 N
0.053 J
0.14 J
0.089 J
0.037 J
0.061 J
0.019 JV*
0.046 J
0.03 J
0.096 J
0.051 J
0.018 J
0.13 J
0.0031 J
2.1
0.16
*\
a
a,b,c
a,b
a
a,c
a
a,b
a
a
a
a
a,b
a.b
NA = Not Available Inorganic detection limits were not furnished with laboratory package.
(The detection limits have been requested from the laboratoiy.)
* = Constituents of concern
a = Exceeds two times the background mean
b = Selected because of toxicity screen (Appendix H)
c = Selected because the constituent was above background and was a "historic CoC (Field Sampling Plan, 1992)
-------
Table 10
EXPOSURE ROUTES CONSIDERED
Green River Disposal Site
Daviess County, Kentucky
ME FRAME
ant and Future
int and Future
int and Future
<•
MEDIUM
Ground Water
Surface Water
Surface Soils
(Kelly Cemetery
Road Site)
LOCATION
Off-Site and
On-Site
On-Site and
Off-Site
Surface
Water Bodies
On-Site
EXPOSURE ROUTE
Ingestion (drinking water),
Dermal Contact, and
Inhalation
(shower/household use)
Dermal Contact (wading)
Ingestion
Incidental Ingestion
Dermal Contact
Inhalation of Fugitive Dust
POPULATION
Residential Adult
Residential Child
Trespassing Youth
Residential
Trespassing Youth
Residential Adult
Residential Child
Trespassing Adult
Trespassing Youth
Residential Adult
Residential Child
Trespassing Adult
Trespassing Youth
Residential Adult
Residential Child
Trespassing Adult
Trespassing Youth
COMPLETE
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes.
Yes
Yes
EXPLANATION
Existing residential wells potentially
used for irrigation and potable water
uses
Potential for future installation of
additional wells for these uses
Use of Little Blackford Creek,
Blackford Creek and its tributaries by
locals for wading and playing
No residential development of landfill
Periodic sipping while visiting site
Hand-to-mouth contact while eating,
drinking, smoking after visiting the site
Absorption of contaminants on exposed
body parts while visiting the site
Exposure to dust from surface soils
disturbed while visiting the site
1 of 2
-------
Table 10 (continued)
EXPOSURE ROUTES CONSIDERED
Green River Disposal Site
Daviess County, Kentucky
TIME FRAME
rrent and Future
rrent and Future
rrent and Future
rrent and Future
MEDIUM
Stream
Sediments
Leachate Waters
Animal and Plant
Life
Ambient Air
LOCATION
On-Site and
Off-Site
Surface Water
Bodies
On-Site
On-Site and
Off-Site
On-Site and
Off-Site
EXPOSURE ROUTE
Dermal Contact
Incidental Ingestion
Inhalation of Fugitive Dust
Dermal Contact
Ingestion
i
Inhalation
i
POPULATION
Trespassing Youth
Residential
Trespassing Youth
Trespassing Youth
Trespassing Youth
Residential
Hunters/Farmers
Trespassers
Residential
COMPLETE
Yes
No
Yes/No
Yes/No
Yes
No
Yes
Yes
Yes
EXPLANATION
During wading and exploration
No residential development of Landfill
Only when sediments are parched and
physically disturbed
Only when sediments are parched and
physically disturbed
Contact of exposed body parts with
leachate while wading
No residential development of Landfill
Animal/Plant species drinking SW and
ingesting or growing in site soils -
Bioaccumulation
Intermittent Exposure
Exposed to dispersed and diluted
concentrations
2 of 2
-------
Table 11
TOXICITY VALUES FOR POTENTIAL CARCINOGENIC AND NONCARCINOGENIC EFFECTS
GREEN RIVER DISPOSAL SITE
Daviess County, Kentucky
'arameter
)ral Route:
\cetone
\mmonia Nitrogen
\rsenic
iarium
lenzene
ieryllium
Cadmium (food)
Cadmium (water)
Chromium VI
Chromium III
Copper
/umene
Cyanide
1.4 - Dimethylphenol
ithylbenzene
iis (2-Ethylhexyl)phthalate
texane
ron
.ead
Manganese (food)
/tanganese (water)
Mercury
Jickel
'olychlorinated biphcnyls (PCBs)
Jllver
iodium
hallium
oluene
richloroethene
lylenes, Total
line
Slope Factor ^
(kg-day/mg)
no data
no data
1.8E+00
no data
2.9E-02
4.3E+00
no data
no data
no data
no data
no data
no data
no data
no data
no data
1.4E-02
no data
no data
no data
no data
no data
no data
no data
7.7E+00
no data
no data
no data
no data
1.1E-02
no data
no data
Weight of Evidence
Classification ^ Type of Cancer
D
NA
A
NA
A Inc. incidence of nonlymphocytic leukemia,
in occupational exposure: neoplasia in
rats/mice by inhalation & gavage ,
B2 Lung cancer in rats/monkeys via inhalation
B1
B1
A
NA
D
NA
D
NA
D
B2 Liver tumors in rats/mice orally
NA
NA
B2
D
D
D
A
B2 Heptacellular carcinomas In rats
D
NA
NA
D
C-B2 Elevated incidences of pleuritis and pericarditis
D ...
D
Source
IRIS
IRIS
EPA
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
HEAST
IRIS
IRIS
IRIS
IRIS
HEAST
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
Page 1 of 5
-------
Table 11 (continued)
TOXICITY VALUES FOR POTENTIAL CARCINOGENIC AND NONCARCINOGENIC EFFECTS
GREEN RIVER DISPOSAL SITE
Daviess County, Kentucky
'arameter
ihalation Route:
vcetone
\mmonia Nitrogen
asenic
tarium
ienzene
leryllium
Jadmium
Chromium VI
Chromium III
tapper
Jumene
iyanide
:,4 - Dimethylphenol
ithylbenzene
iis (2-Ethylhexyl)phthalate
lexane
on
ead
Manganese
Mercury
Jickel fa
'olychlorinated biphenyls (PCBs)
silver
sodium
hallium
oluene
rlcWoroethene
[ylenes, Total
:inc
Slope Factor
(kg-day/mg)
no data
no data
1.5E+01
no data
2.9E-02
8.4E+00
6.3E+00
4.2E+01
no data
no data
no data
no data
no data
no data
no data
no data
no data
no data
no data
no data
8.4E-01
no data
no data
no data
no data
no data
6.0E-03
no data
no data
Weight of Evidence
Classification ^
D
NA
A
NA
A
B2
B1
A
NA
D
NA
D
NA
D
B2
NA
NA
B2
D
D
A
B2
D
NA
NA
D
C-B2
D
D
Type of Cancer
Lung cancer
Inc. incidence of nonlymphocytic leukemia,
in occupational exposure: neoplasia in
rats/mice by inhalation & gavage :•
Lung cancer in rats/monkeys (inh)
Carcinogenic in mice by various routes
Lung cancer
Carcinomas in rats
Elevated incidences of pleuritis and pericarditis
Source
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
HEAST
IRIS
IRIS
IRIS
HEAST
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
8
S-
Page 2 of 5
-------
Table 11 (continued)
TOXICITY VALUES FOR POTENTIAL CARCINOGENIC AND NONCARCINOGENIC EFFECTS
GREEN RIVER DISPOSAL SITE
Daviess County, Kentucky
3arameter
Oral Route:
<\cetone
<\mmonia Nitrogen
Arsenic
Barium
Benzene
Beryllium
Cadmium (food)
Cadmium (water)
Chromium VI
Chromium III
Copper
Cumene
Cyanide
2,4 - Dimethylphenol
Ethylbenzene
3is(2-Ethylhexyl)phthalate
Hexane
ron
_ead
Manganese (food)
Manganese (water)
Mercury
Mickel
3olychlorinated biphenyls (PCBs)
Silver
Sodium
Thallium (a)
Toluene
Trichloroethene
-------
Table 11 (continued)
TOXICITY VALUES FOR POTENTIAL CARCINOGENIC AND NONCARCINOGENIC EFFECTS
GREEN RIVER DISPOSAL SITE
Daviess County, Kentucky
Parameter
Inhalation Route:
Acetone
Ammonia Nitrogen
Arsenic
Barium
Benzene
Beryllium
Cadmium
Chromium VI
Chromium III
Copper
Cumene
Cyanide
2,4 - Dimethylphenol
Ethylbenzene
b!s(2-Ethylhexyl)phthalate
Hexane
Iron
Lead
Manganese
Mercury
Nickel
Polychlorinated biphenyls (PCBs)
Silver
Sodium
Thallium
Toluene
Trichloroethene
Xylenes, Total
Zinc
Chronic RfD
-------
Table 11 (continued)
TOXICITY VALUES FOR POTENTIAL CARCINOGENIC AND NONCARCINOGENIC EFFECTS
GREEN RIVER DISPOSAL SITE
Daviess County, Kentucky
No Data - No value listed in reference
Withdrawn - Withdrawn (from IRIS) as a result of further review
Pending - Under review by an EPA work group
(a) Slope factors provided in terms of unit risk are converted prior to input on this table as follows:
for oral route: UNIT RISK (L/ug) * 1,000 ug/mg * day/2 L * 70 kg = CSF (kg-day/mg)
for inhalation route: UNIT RISK (m3/ug) * 1,000 t/g/mg * day/20 m3 * 70 kg = CSF (kg-day/mg)
(b) Weight of Evidence Classification:
A - Human Carcinogen C - Possible human carcinogen
B1 - Probable human carcinogen; limited human data available D - Not classifiable as to human carcinogenicity
B2 - Probable human carcinogen; inadequate or no evidence in humans
(c) Value is for nickel refinery dust.
(d) Inhalation RfCs are converted to RfDs using the following equation:
RfC (mg/m3) * 20 m3/day * 1/70 kg = RfD (mg/kg-day)
(e) Confidence Level (i.e., high, medium, or low) as reported in IRIS
(f) Uncertainty Factors (UF) are assigned by USEPA in multiples of 10 based on the following limitations in the database used to develop
the RfC/RfD:
A - Animal to human extrapolation (UF of 10) S - Extrapolation from a subchronic NOAEL instead of a chronic NOAEL (UF of 10)
H - Variations in human sensitivity (UF of 10) L - Extrapolation from a LOAEL to a NOAEL (UF of 10)
(g) Value is for Thallium Sulfate.
Source: IRIS = Integrated Risk Information System (6/93)
HEAST = Health Effects Assessment Summary Tables (FY-1992 Annual)
EPA = Memorandum to Assistant Administrators. Recommended Agency Policy on the Carcinogenicity Risk Associated with the
Ingestion of Inorganic Arsenic. USEPA, Office of the Administrator, Washington, D.C. June 21,1988.
Page 5 of 5
-------
Table 12
SUMMARY OF SITE HUMAN HEALTH RISKS
GREEN RIVER LANDFILL
GREEN RIVER DISPOSAL SITE
Dzvieu County. Kentucky
Future Residential Receptors
Pathway
Ground Water*
Ingestion
Dennal Contact
Ambient Air
Inhalation
Surface Water
Dennal Contact
Leachale Water
Dennal Contact
Sediments:
Dennal Contact
Summary for
Five Media
Adult Child
HQ HQ
30- 200-
0.1 0.1
0.07 03
NA NA
NA NA
NA NA
30 200
Lifetime Envy;
Cancer Risk
9E-04*
2E-06
•: 3E-06
NA
NA
NA
9E-04
Current and Future Trespassing Receptors
Hunter
Adult
HQ
NA
NA
0.001
NA
NA
NA
0.001
Trespasser
Youth Lifetime Excess
HQ f*wfr Risk
NA NA
NA NA
V
0.002 7E-08
0*1 2E-07
0.4 4E-07
0.001 3E-06
0.4 4E-06
HQ Hazard Quotient
NA Not Applicable
* The risks associated with ground water are preliminary only. The ground —water preliminary risk
assessment will be re—evaluated after additional ground—water samples have been collected and analyzed.
-------
Table 13
SUMMARY OF SITE HUMAN HEALTH RISKS
KELLY CEMETERY ROAD
GREEN RIVER DISPOSAL SITE
Dmvieu Couty, Kentucky
Pathway
Surface Soils:
Dermal Contact
Incidental Ingestion
Inhalation of
Fugitive Dust
Summary of
Soil Exposures
Future Residential Receptors
Adult Child Lifetime Exrr.»
HQ HQ Cancer Risk
0.001 0.004 NA
0.05 0.16 NA
0.00002 . 0.00008 5E-06
0.051 0.16 5E-06
Current and Future Trespassing Receptors
Adult
HQ
0.0001
0.001
0.0000004
0.001
Youth
HQ
0.0001
0.005
0.000001
0.005
Lifetime Excess
Cancer Risk
NA
NA;.
1E-07
1E-07
HQ Hazard Quotient
NA Not applicable
-------
Table 14
COMPARISON OF SURFACE WATER ECOLOGICAL COC CONCENTRATIONS
TO AMBIENT WATER QUALITY CRITERIA
Greco River Disposal Site
Davicss County, Kentucky
Parameter
Frequency of
Detection
Maximum Detected
Concentration
AMBIENT WATER QUALITY CRITERIA.
for the protection of:
AQUATIC LIFE:
Federal"
(mg/L)
Slate of Kentucky*1
acute
chronic
acute
chronic
DISSOLVED METALS:
Aluminum
Barium
Calcium
Magnesium
Manganese
Potassium
Sodium
IZinc
(me/U
2/3
3/3
3/3
3/3
3/3
2/3
3/3
Z] 3/3
TOTAL METALS: ( me/L)
Aluminum
Barium
Cadmium
Calcium
Cobalt
Copper
Cyanide
Iron
Lead
Magnesium
Manganese
Mercury
Potassium
Sodium
Vanadium
Zinc
19/21
21/21
1/21
21/21
2/21
14/21
12/21
21/21
21/21
21/21
21/21
4/21
17/21
21/21
1/21
20/21
VOLAT1LES: (ma/Li
Acetone 7/20
Dichloromethane 6/21
INORGANICS: fmg/L)
I Ammonia Nitrogen I 4/5
0.0332 B
0.157 B
70.9
42.4
0.763
237
515
0.163E
2.29
1.43
0.0249 N
334 E
0.0195 B
0.0256
0.0683
29.1
0.019 B
190
9.67 E
0.0004
779
2920 E
0.0057 B
0.803
0.02
0.006
180
0.12
0.11
0.117 '
0.0039
0.0011
0.106 '
J I 0.0039 ' | 0.0011
0.018
0.022
0.082
0.012 1
0.0052 !
i !
0.0177 •
0.022
4
0.0032 ! 0.0816 •
0.0118 *
0.005
1
0.0032 •
0.0024
0.000012
0.0024
0.000012
0.12
0.11 ' : 0.117 '
0.106 '
0.083-4.6 (c)
0.53-22.8 fel
0.0017-0.612JC)! 1
0.05 (d)
0.05 fd)
0.304-1.2(e) !
| 1 Indicates a stale or federal chemical specific standard that was exceeded by the maximum
concentration detected on site.
* - Calculated from a chemical specific hardness dependent equation. A default value of 100 mg/L was used.
a - Values from Quality Criteria for Water, EPA 440/5-86-001. 1987.
b - Values from Kentucky Water Quality Standards. The Bureau of National Affairs. Inc.. 786:1001 S-209, January, 1992.
c - Value is for fish species.
d — Value is for un—ionized Ammonia. Un-ionized Ammonia concentration can be calculated using total Ammonia by the
following calculation: Un = 1.2(Total ammonia-(N))/(l + 10pKa"~pH)
e — Value is for invertebrate species.
B - (inorganic)Estimated value
E - Value is associated with matrix interference.
N - Value is associated with a spiked sample outside of control limits.
-------
Table 15
GREEN RIVER ECOLOGICAL RISK SUMMARY FOR SURFACE WATER
Green River Landfill. Green River Dispoul Site
Davieu County, Kentucky
Pare lot 2
Parameter
Maximum Concentration
Sample Location
Indicator Specie*
Ecological
Quotient*
Risk Number
Effect Type/
Length of Study
DISSOLVED METALS:
Aluminum
Barium
Calcium
Magnesium
Manganese
Potassium
Sodium
Zinc
SW-01
SW-03
SW-02
SW-02
SW-02
SW-02
SW-02
SW-02
No Data
Daphnia magna*
No Data
No Data
Daphnia magoab
No Data
Daphnia magna*
Ceriodaphnia reticulata*
Daphnia magna*
Daphnia pulex*
Daphnia lumholzr*
0.157/410
0.763/1020
515/1640
0.163/0.076
0.163/0.068
0.163/0.107
0.163/0.4375
0.0004
0.75
0.31
2.14
2.40
1.52
0.37
LC50/48hour
EC50/21 day
. ••
EC50V2lday
LC50/4Shour
LC50/4S hour
LC50/48 hour
LC50/96 hour
TOTAL METALS:
Aluminum
Barium
Cadmium
Calcium
Cobah
Copper
Cyanide
Iron
Lead
Magnesium
Manganese
Mercury
Potassium
Sodium
Vanadium
Zinc
SW-16
SW-11
SW-03D
SW-15
SW-03D
SW-03D
SW-03
SW-12
SW-12
SW-ll
SW-ll
SW-03
SW-02
SW-10
SW-03D
SW-10
No Data
Daphnia magna *
Ceriodaphnia dubiab
Daphnia magna*
Daphnia pulicariab
Daphnia Iumholzib
Pimephales promelas*
No Data
No Data
Ceriodaphnia dubia*
Daphnia pulicariab
Pimephales promelasb
No Data
No Data
Ceriodaphnia reticulata*
Daphnia magna*
No Data
Daphnia magna*
Rana hexadactyla *
Daphnia pulex '
No Data
Daphnia magna'
No Data
Ceriodaphnia reticulata*
Daphnia magna'
Daphnia pulex*
Daphnia tumholzi*
1.43/410
0.0249/0.038
0.0249/0.054
0.0249/0.184
0.0249/6.704
0.0249/9.7
0.0256/0.051
0.0256/0.053
0.0256 /0.55
0.019/0.53
0.019/4.4
9.67/1020
0.0004/0.051
0.0004/0.107
2920/1250
0.803/0.076
0.803/0.068
0.803/0.107
0.803/0.4375
0.003
0.66
0.46
0.14
0.004
0.003
OJO
0.48
0.05
0.04
0.004
0.01
0.008
0.004
2.34
10.6
11.8
7.5
1.8
LC50/48 hour
LC50/48hour
LC50/48 hour
LC50/4S hour
LC50/24 hour
LC50/96 hour
avg LC50/4S hour
LC50/48 hour
LCSO/K hour
LC50/48 hour
LC50/48 hour
EC50/21 day
LC50/96 hour
LC50/48 hour
avg EC50/21 day
LC50/48 hour
LC50/48 hour
LC50/48 hour
LC50/96 hour
-------
Table 15 (continued)
GREEN RIVER ECOLOGICAL RISK SUMMARY FOR SURFACE WATER
Green River Landfill. Green River Disposal Site
Daviess County. Kentucky
Pace 2 of 2
Parameter
VOLATTLES:
Acetone
Dichloromelbane
SEMI-VOLATILES:
Ammonia Nitrogen
Maximum Concentration
Sample Location Indicator Species
SW-03/121 Pimephales promelas"
SW-14/16 Daphnia magna*
Pimephales promelas
Rafinesque'
_] SW-122 Amphipoo"
Ceriodaphnia reticulata*
Pimephales promelasb
Ecological Effect Type/
Quotient* Risk Number Length of Study
0.020/8120 0.000002 LCSO/96hour
0.006/224 0.00003 LC50/48 hour
0.006/193 0.00003 LCSO/96 hour
180/1.91
180 /Z71
180/4.25
94.2 LC50/96hour
66.4 LCSO/48 hour
42.4 avg LC50/96hour
I Departure point of 1 for the risk number is exceeded.
a - Is the Maximum Contaminant Concentration in mg/L/ Effective Concentration in mg/L(i.e,
b - LCK for this constituent is from the AQUIRE database.
c — iCx for this constituent is from Environmental Toxicology and Chemistry, vol 12,1993.
d - LCX for thb constituent is from HSDB.
avg — iCx for thb constituent is an average of all bioassays for the same species and test duration.
-------
^-r^-VV^^— •
Table 16
GREEN RIVER ECOLOGICAL RISK SUMMARY FOR LEACHATE WATER
Green River Landfill. Green River Disposal Site
David* County. Krotady
Pa eel of 1
Parameter
TOTAL METALS:
Aluminum
Barium
fSdmitim
Calcium
| Chromium
Cyanide
Iron
Lead
Magnesium
Manganese
Potassium
Silver
1- j-
1 Sodium
Vanadium
jzinc
Maximum Concentration
Sample Location
LW-01CE
LW-01CE
SWCPB
LW-01CEV
LW-01CE
SWCPB
LW-01CE
LW-01CE
LW-01CE
LW-01CE
LW-01CE
LW-01CE
LW-01CE
LW-01CE
SWCPB
VOLATILES:
Acetone LW-01CE
4-Methyl-2-pentanone LW-01E
Xyleoe LW-01E
SEMI-VOLATILES:
1 Ammonia Nitrogen
2 — Methylphenol
LW-01CE
LW-01CE
Indicator Species
No Data
Daphoia magnak
Ceriodaphnia duoiak
Daphnia magna*
Daphnia puUcaria*
Daphnia Iumhol2ib
Fimepbales promelas*
NoDau
Ceriodaphnia reticulata'
Daphnia magna'
Daphnia pulex*
Fimephales promelas'
No Data
Mb Data
Ceriodaphnia redculau'
Daphnia magna'
No Data
Daphnia magna'
No Data
Ceriodaphnia rett'culau*
Daphnia pulex'
Daphnia magna'
No Data
Ceriodaphnia reticulatav
Daphnia magna'
Daphnia pulex'
Daphnia lumholak
Pimephales promelas'
Pimephales promelas'
Pimephales promelas'
Amphipotf
Ceriodaphnia rericulau'
Pimephales promdas*
Daphnia cucullatah
Daphnia magna b
Daphnia puleck
Ecological
Quotient*
Z42/410
osxK/ojcae,
OJXS/OJS4
0008/0.184
OJ10S/6.704
aoos/9.7
0.024/0.045
0.024/0.022
0.024/0.046
0.024/44.5
0.017 /OS3
0^)17/4.4
L21/1020
OM3/ 0.011
0.003/0.014
8050/1250
1.18/0.076
1.18/0.063
1.18/0.107
1.18/0.4375
0.069/8120
0.01/505
0.029 / 42
530/1.91
530/2.71
530/4.25
0.025 / 15 J
0.025 / 8.6
0.025 / 8 -5
Risk Number
OJD06
0.211
0.148
0.043
0.001
0.001
0.53
L09
0.50
0.00
0.03
0.004
0.001
03
0.2
6.4
15.5
17.4
11.0
2.1
0.00001
0.00002
0.001
277
196
125
0.002
0.003
0.003
Effect Type/
Length of Study
LC50/48hour
LC50/48hour
LC5O/48hour
LC50/48hour
LC50/24hour
LCSO/96 hour';
LCSO/48 hour
LCSO/48 hour.
LCSO/48 hour
avg LCSO/96 hour
LC50/4S hour
LCSO/48 hour
ECSOmday
LCSO/48 hour
LC50/48 hour
avg ECSO/21day
LCSO/48 hour
LC50/48 hour
LCSO/48 hour
LCSO/96 hour
LCSO/96 hour
LCSO/96 hour
LC50/24-96hour
LCSO/96 hour
LCSO/48 hour
avg LCSO/96 hour
LC50/48 hour
LC50/48 hour
LCSO/48 hour
I I Departure point of 1 for the risk number is exceeded.
a - Is the Maximum Contaminant Concentration in mg/L/ Effective Concentration in mg/L (U. LC,,)
b — LCB for this constituent is from the AQUIRE database.
c— LCK for this coasdtuent is from Environmental Toxicology and Chemistry, vol. 12.1993.
d - LCM for this constituent u from HSDB.
avg — LC,, for this constituent is an average of all bioasssays for the same species and test duration.
-------
Table 17
GREEN RIVER ECOLOGICAL RISK SUMMARY FOR SURFACE WATER SEDIMENTS
Green River Landfill. Green River Disposal Site
Davien County, Kentucky
Pi re 1 of 1
Parameter
TOTAL METALS:
Aluminum
Barium
Beryllium
Cadmium
Chromium
Iron
Lead
Magnesium
Manganese
Nickel
Selenium
1 Sodium
Thallium
Vanadium
Zinc
VOLATILES:
2-Butanone
SEMI -VOLATILES:
| bis(2-Elhylhexyl)phlhaIate
PESnCIDES/PCBs:
PCB-1248
Maximum Concentration
Sample Location
SD-10
SD-01
SD-05
SD-06
SD-10 :
SD^-06
SD-10
SDH -061525
SD-01
SDD-0265
SDD-0265
SD-07
SDD-066
SDD-0265
SD-10
SD-16
SDD-04
SD-14
| Departure point of 1 for the ris
Indicator Species
No Data
Daphnia magna'
No Data
Ceriodaphnia dubia'
Daphnia magna*
Daphnia pulicaria*
Daphnia lumhola'
Pimephales promelas*
Ceriodaphnia reb'culatak
Daphnia magna'
Daphnia pulet'
Pimepbales promelas'
No Data
Ceriodaphnia dubia*
Daphnia magna'
No Data
Daphnia magna'
Daphnia pulicaria'
Pimephales promelas'
Daphnia magna'
Pimephales promelas'
Daphnia magna'
No Data
No Date
Ceriodaphnia reticulata'
Daphnia magna'
Daphnia pulex'
Daphnia lumhola'
Daphnia magna'
Daphnia pulicaria'
Pimephales promelas'
Daphnia magna'
Pimephales prorodas'
Daphnia magna*
knum her is exceeded.
Ecological Effect Type/
Quotient* Risk Number Length of Study
159/410
9.5/0.058
9S/OJK5
9210212
9J/6.704
9J/12J5
88^/0.045
8&A10J022
8ZA/O.M&
8S.S/44.5
580 /OJ3
580/4.4
25SO/1020
57.7 123
57.7/5^09
0.46/0323
0.46/1
4920/1250
4300/0.076
4300/0^)68
4300/0.107
4300/0.4375
OO25/U
0.025/1.034
0.025/55
14/8
031/0.125
031 / 0.067
039 LCSO/48hour
164 avg LCSO/48hour
112 avg LC50/48hour
45 avg LC50/48hour
1.4 LC50/24 hour
0.74 avg LC50/96hour'-
1970 LCSO/48 hour
4040 LC50/48hour
1850 LC50/48hour
ZOO avg LC50/96 hour
1090 LC50/48 hour
132 LCSO/48 hour
'
2J EC50/21day
25.1 avg LC50/48hour
11.1 LCSO/96 hour
0.9 avg LCSO/96 hour
0.5 LCSO/96 hour
3.9 avg ECSO/21 day
56600 LCSO/48 hour
63200 LCSO/48 hour
40200 LC5(y48 hour
9830 LCSO/96 hour
0.0023 LC50/48 hour
0.02 LC50/48 hour
0.0005 LCSO/96 hour
1.75 avg LCSO/48 hour
2.48 avg LC50/96 hour
4.63 LCSO/21 day
a — Is the Maximum Contaminant Concentration in mg/l(g/ Effecdve Concentration in log/kg (i.e. LCn)
b - LCa for this constituent is from the AQUIRE Database.
c - LCg, for this constituent it from the HSDB.
avg — LC,, for this constituent is an average of all bioassays for the same species and test dura don.
-------
FIGURES INCLUDED IN THIS
RECORD OF DECISION
HAVE BEEN REPRODUCED FROM
THE GREEN RIVER DISPOSAL SITE
REMEDIAL INVESTIGATION REPORT AND
FEASIBILITY STUDY, JULY 1994
PREPARED BY LAW ENVIRONMENTAL, INC.
-------
OWENSBORO ;:;;?;; ;:p:-:
KENTUCKY
Green River Disposal Landfill
Maceo, Daviess County, Kentucky
Figure 1a: Site Location Map
U.S. EPA, Region IV
-------
NQBTH
KENTUCKY
OWENSBQRCJ
Green River Disposal Landfill
Macao. Daviess County, Kentucky
Figure 1 b: Site Location Map
& U.S. EPA, Region IV
-------
CONTINUATION
OF STREAM
OFFSITE
POND
SEDIMENTATION
POND
A '
KELLY CEMETARY
ROAD SITE
INTERPRETED UMITS OF LANDFILL ACTIVITY
BASED ON GEOPHYSICAL SURVEYS
AND TRENCHING ACTIVITIES
LEGEND
XI
200' x 200' GRID BLOCK
AND GRID NUMBER OF
KCR SITE
:LLY CEMETERY ROAD
1
1200
_ . — . _ PROPERTY LINE
POND
• BACKGROUND
BSS-1 SURFACE SOIL
SAMPLE LOCATION
Green River Disposal Landfill
Maceo, Davless County, Kentucky
Figure 2: Site Plan
3& U.S. EPA, Region IV
-------
/ A
SEDIMENTATION
GREEN RIVER
DISPOSAL
SITE
:'
SOURCE: U.S.C.S. 7.5-HINUTE TOPOGRAPHIC QUADRANGLE MAP OF
LEW I SPORT, KENTUCKY-INDIANA 1967.
Green River Disposal Landfill
Maceo, Daviess County, Kentucky
Figure 3: Site Watershed Map
U.S. EPA, Region IV
-------
525-,
500-
475-
450-
425-
400-
375-
350-
325-
300-
275-
250 J
NORTHWEST
D
SOUTHEAST
D1
STB-1
(MW-2)
PRE-LANDFILL
SURFACE
STB-2 ,
MW-n/
LEGEND
OUTER
CASING
OUTER
CASING
SCREEN _
INTERVAL
D
FILL/TRASH
SILT
SIUSTONE
SHALE
LIMESTONE
SANDSTONE
COAL
SEE FIGURE 3-9 FOR
CROSS-SECTION LOCATION
.BORING
TERMINATED
PRE-LANDflLL SURFACE
(DETERMINED FROM TOPOGRAPHIC MAPS)
GROUND WATER LEVEL
MEASURED ON W92
r 525
- 500
- 475
- 450
- 425
- 400
- 375
- 350
- 325
- 300
- 275
L 250
SCM£
M
FtET
VERTICAL EXAGGERATION
8 TO 1
Green River Disposal Landfill
MUM. DtAMt Ceuity. Kentucky
U.S. EPA, Region IV
-------
PROPERTY LINE
INTERMITTENT TRIBUTARIES
INTERPRETED LIMITS OF LA*DTltbsACTIVITY
BASED ON GEOPHYSICAL SURVEYS
SCALE IN rEET
0 150 JOO
450
MONITORING WELL LOCATION
WATER ELEVATION IN FEET, (TYPE II fc TYPE III MONITORING WELL)
POTENTIOMETRIC CONTOUR OF GROUNDWATER
Green River Disposal Landfill
Maoeo, Dorian County, Kentucky
c. Potenflometrte Surface Map
O. GroundvwrtwBevalkinB
January 13,1993
U.S. EPA, Region IV
-------
OFFSITE
POND
SW-121
INTERPRETED LIMITS OF
LANDFILL ACTIVITY BASED
ON GEOPHYSICAL
SURVEYS AND TRENCHING
ACTIVITIES
I
Xu-'m fEET
LEGEND
SEDIMENT SAMPLE LOCATION: SURFACE
WATER WAS NOT PRESENT
SW/SO-OI SURFACE WATER AND
• SEDIMENT SAMPLE LOCATION
^ •—.. — . ^ PROPERTY LINE
. INTERMITTENT TRIBUTARIES
Green River Disposal Landfill
Muw>. OivUu County, K.ntucky
Figures: 8«HnNntiiid3utfK>w>tM
8«mpl« Loeatton*
m U.S. EPA, Region IV
-------
BORROW AREA
INTERPRETED LIMITS OF LANDFILL ACTIVITY
BASED ON GEOPHYSICAL SURVEYS
SS-0«
SCALE IN FEET
400
LEOEMQ
> PROPERTY UNC
MTERUmtNT TRBUTARICJ
SOn. SAMPLt LOCUTION
utosnjRBEO son. SAMPU LOCATION •
800
Green River Disposal Landfill
Macao, Davfem County, Kentucky
7* 5°" Sampling Locations
Along tht Landrill Pertmetof
U.S. EPA, Region IV
-------
400
800
LEGEND. '
APPROXTUATt BACKGROUND
soa SAMPUNO locAncN
—• PROPtHTT IWC
— INITRUintNt TOIBUTARY
JOO'XJOO1 CRlD BIOCX
Green River Disposal Landfill
Macao, Davlam County, Kentucky
8: Grid tor Statistical Sampling
and Background Locations at
tfia Kelly Cemetary Road Stto
U.S. EPA, Region IV
-------
MMOHA NIIROO.N 9X1 mj/1
SOOUM 1050 ng/l
CIK OJJO n,/l
CHKMUV 0.014 mg/l
CYAMDC O.OO81
AMMONIA MIKgdN IW
SCOWU 1,410 mo/t
t.ll
CHIOUUU ND
CVAMDC 0.0)71
AHHONIA MIWKIN 11
SOOnW 104 n«X
IMC O.OJJ4 mg/l
CVAMM oniM
tummro uin cr UMTU. ACIMTT
•AID m oxanmcia smm
SCALE IN FEET
UMHAR COUICKCN KM)
Green River Disposal Landfill
Mnceo, Davless County, Kentucky
9: LaachatoSMpandPond
Somplm, January 1903
U.S. EPA, Region IV
S;
-------
V
LIMITS OF LANDFILL
(DASHED WHERE INFERRED)
ZONE or exnttuciY MICH
APPARENT CONDUCTIVITY (>300m«/m)
lOHtJ Of IN-PHASE BSTURBANK
(POS9BU eURItt) MtlAl)
INTERPRETED LIMITS OF
LANDFILL ACTIVITY BASED .
ON GEOPHYSICAL SURVEYS \
AND TRENCHING ACTIVITIES
Green River Disposal Landfill
Maceo, Oawlan County, Kentucky
10: AIM* of Ugh Apparent
Conductivity and In-PhaM DIsturbanM
Dicountered During the Geophysical Surveys
U.S. EPA, Region IV
-------
\
UMITS OF LANOna BASED ON GEOPHYSICAL SURVEY
AND TRENCHING ACTIVITIES (DASHED WHERE INFERRED)
I
v"/
PROPERTY UNt
INTERMITTENT WOUMRItS
A'
CROSS-SECTION
ISOPACH THICKNtSS IN Ftp .„„.
. n (BASED ON TOPOCRAPWC COMWJISOKS
— 10 — krwttN pRE-iwmna AND POST-
OPERATION)
400
U1BTS Of TMt UNOnil FROM
sunvrr
Green River Disposal Landfill
Maceo, Dovtess County. Kentucky
' Rgure 1 1a: bopadi Mapofth* FID
MatarialwHhlnth* Landfill
U.S. EPA, Region IV
-------
... .-.»-.*.v.v-
A
SOUTH
500—
450-
i
ci
400 —
350-
B
SOUTH
550-i
500-
450-
400-
50
A'
NORTH
PRESENT LANDFILL
SURFACE
PRE-LANDFILL
SURFACE
PRESENT LANDFILL
SURFACE
PRE-LANDFILL
SURFACE
SCALE
IN
FEET
200
^500
— 450
— 400
— 350
B'
NORTH
r-550
-500
— 450
•400
Green River Disposal Landfill
MOMO, DavteM County. Kentucky
Rgure 11 b: CroM^cHon* A-A' and B-B1
Through th« Landfill. Showing PnvLandfill and
Pr«Mirt Landfill Surtao**
U.S. EPA, Region IV
-------
\ ^ -I
v \ *^ V*^
INTERPRETED LIMITS OF LANDFILL ACJMTY
-- - — -- — - - - — ,^"— ^\ t -- • v * V^J
'HYSICAL SURVEYS V— X*— "^ / *"
x — ' 7 • \ c '»" ...'
-.-.-^ ---------------- ^ ----- J.^C..
LECEMi
EXPLORATORY TRENCH LOCATION
LIMITS OF LANDFILL BASED ON GEOPHYSICAL
INVESTIGATION AND TOENCHINC ACTIVITIES
ZONE OF EXTREMELY HIGH
APPARENT CONDUCTIVITY
LEACHATE COLLECTION POND
ZONES Of IN-PHASE DISTURBANCE
(POSSIBLE BURIED METAL)
Green River Disposal Landfill
Macao, Davless County, Kentucky
Figure 12: Exploratory Trench
Location Map
U.S. EPA, Region IV
-------
C 2*9000 C 249250 C.249500 E, 249750 C,230000 E ,250250 C .250500 [,250750 C 251000 C 251250 C.251500 E25I7
INTtRPRETCO LIMITS OF LANDFILL ACTIVITY
BASED ON GEOPHYSICAL SURVEYS
250250 E'250500 E'250750 C '251000
Green River Disposal Landfill
MACM. Dnltu County. Kentucky
Figure 13: E«tim>t«ia»d«indAn>i
Ert.nl ol th« UndlU Cap
s& U.S. EPA, Region IV
-------
-GCONCT DRAINAGE LAYER
-GEOTEXTILE FILTER
-GEOTEXTTLE FILTER
ESTIMATED MAXIMUM
SLOPE OF 17X
COMPACT CLAY
SUB-GRADE SOIL
LANDFILL WASTE
GEOCRID REINFORCEMENT
(ON STEEPER SLOPES)
CLAY BARRIER COVER
-CCONET DRAINAGE LATER
-GEOTEXTILE FILTER
-GEOMEMBRANE
ESTIMATED MAXIMUM
SLOPE OF I7X
COMPACT CLAT
SUB-GRADE SOIL
LANDFILL WASTE
GEOGRID REINFORCEMENT
(ON STEEPER SLOPES)
COMPOSITE BARRIER COVER
-GEOCRIO REINFORCEMENT
(ON STEEPER SLOPES)
ESTIMATED MAXIMUM
SLOPE OF I7X
CEONET DRAINAGE LATER
GEOTEXTILE FILTER
CEOTEXTILE FILTER
COMPACT NATIVE SOIL
SUB-GRADE SOIL
LANDFILL WASTE
SOIL COVER
-GEOGRIO REINFORCEMENT
(ON STEEPER SLOPES)
ESTIMATED MAXIMUM
SLOPE OF 175!
CEOMEMBRANE
SUB-GRADE SOIL
LANDFILL WASTE-
GEOMEMBRANE BARRIER COVER
Green River Disposal Landfill
Mtno, Dntiu County, Kentucky
Figure 14: o
-------
LANDFILL CAP SURFACE.
DRAINAGE
DITCH
GRAVEL ENVELOPE
. ."' '.o.-- •'.•()•• •.'•; a'.
..BACKFILL
o'. '.'•" 6-. '.:: 6'. v-'o';.'.
SYNTHETIC
MEMBRANE
FILTER FABRIC
PERFORATED
DRAIN PIPE
NOT TO SCALE
Green River Disposal Landfill
Maceo, DavlMS County, Kentucky
Figure 15: Cro»s-Sectionofa
Typical Laachata Interceptor Drain
U.S. EPA, Region IV
-------
o
1
1 NoOH
1 POLYMER
_ METAL _
^ PtRCIPITATION ^"
1 FILTER
T
SLUDGE
EQUALIZATION
COLLECTION
TRENCH
AIR STRIPPER
AIR
—Q
r
H2S04
NEUTRALIZATION
NPOES
DISCHARGE
Green River Disposal Landfill
Macao, Dnvtess County, Kentucky
Figure 16: Conceptual Process Row
ui&Qrant for Lo&cn&to TreBtmont
U.S. EPA, Region IV
-------
INTERPRETED LIMITS OF LANDFILL
ACTIVITY BASED ON GEOPHYSICAL
SURVEYS
LECE1JQ
AREA OF LEACHATE OUTBREAKS
(LEACHA IE COLLECTION POND
LOCATION)
LOCATION OF LEACHATE OUTBREAK
SEDIMENT
LANDFILL WASTE
• CHAIN-LINK FENCE
Green River Disposal Landfill
MacM. Divliu County, KinUcky
Figure 17: Areas of Concern
S$Z U.S. EPA, Region IV
-------
GREEN RIVER DISPOSAL LANDFILL
SUPERFUND SITE
RECORD OF DECISION
APPENDIX A
COMMONWEALTH OF KENTUCKY
CONCURRENCE LETTER
for the
RECORD OF DECISION
-------
PHILLIP J. SHEPHERD /SrM^^V BRERETON C. JONES
SECRETARY Iff J»? \el GOVERNOR
COMMONWEALTH OF KENTUCKY
NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION CABINET
DEPARTMENT FOR ENVIRONMENTAL PROTECTION
FRANKFORT OFFICE PARK
14 REILLY ROAD
FRANKFORT. KENTUCKY 40601
December 14, 1994
«
Mr. Nestor Young, Remedial Project Manager
North Remedial Superfund Branch
United States Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Re: Record of Decision
Green River Disposal Superfund Site, Daviess Co., Kentucky
Dear Mr. Young:
The Kentucky Division of Waste Management (KDWM) has reviewed
the Record of Decision(ROD) for the Green River Disposal site,
which incorporates the Remedial Investigation/Feasibility Study,
the Proposed Plan, and all supporting documents. We concur with the
remedial action plan for the landfill portion of the site, which
consists of burial of contaminated stream sediments within the
landfill, a multi-media cap, and leachate collection and treatment.
Please note however that, despite our concurrence, we do not agree
with your analysis that Kentucky Hazardous Waste Regulations are
neither applicable nor relevant and appropriate as they apply to
landfill cover requirements. We also object to the exclusion of
Kentucky Revised Statute 224.01-400 and Kentucky Groundwater
Regulation 401 KAR 5:037 as applicable or relevant and appropriate.
The Division of Waste Management also concurs with the
proposed course of action regarding groundwater, which calls for
the collection of a minimum of two years of additional data which
will be used to determine whether there is statistically
significant evidence of groundwater contamination attributable to
the site, while a final decision concerning a groundwater remedy
will be established in a future record of decision.
No action is proposed for the adjacent Kelly Cemetery Road
portion of the site or the East and West Ravines. KDWM cannot
concur with this course of action, as it is based on a faulty risk
assessment. Our specific comments notwithstanding, procedurally,
the assessment contains many of the same elements with which fault
has been found in previous risk assessments. Examples include use
of the lead model, basing PCB action levels on the Toxic Substances
Control Act and not on a risk basis, establishing background levels
Printed on Recycled Paper
-------
with limited data, and the use of action levels less conservative
than the 10 E-6 excess cancer risk level required in Kentucky.
Taken together, these errors lead to an underestimation of risk and
do not afford an adequate level of protection for human health and
the environment.
As always, we will be glad to discuss these issues at your
convenience.
Sincerely,
P. Haight,/ Director
Division of Waste Management
cc: Randall McDowell, DOL
Rick Hogan, Superfund Branch
Jeffrey Pratt, Superfund Branch
-------
GREEN RIVER DISPOSAL LANDFILL
SUPERFUND SITE
RECORD OF DECISION
APPENDIX B
PROPOSED PLAN PUBLIC MEETING
TRANSCRIPTS
-------
1 UNITED STATES OF AMERICA
ENVIRONMENTAL PROTECTION AGENCY
2 "
3
4 MEETING
5
6 LOCATION: Maceo School Gymnasium
Green River Superfund Site
7 Maceo, Kentucky
8
9
10 The following is a transcript of the
11 public meeting held on August 4, 1994, beginning
12 at the approximate hour of 7:00 P.M. CTS, in the
13 Maceo School Symnasium, Maceo, Kentucky.
14
15
16
17
18
19 REPORTED BY: James A. Joplin, RPR
20
21
22
23
24
25
TRI-STATE
COURT REPORTING
P. O. Box 1566
-------
1 Maceo, Kentucky
2 August 4, 1994 - 7:00 P.M.
3
4 PROCEEDINGS
5 MS. DURHAM: Good evening and welcome. My
6 name is Suzanne Durham, and the purpose of tonight's*.
7 meeting is to discuss with you the long term investig-
8 ation which has been conducted here at the site, and
9 to tell you exactly what we have found and announce
10 EPA's proposed course of action, but more importantly,
11 we are here to solicit comments from the Community.
12 Before we go any further, I would
13 like to introduce a few individuals to you. This is
14 Nestor Young. Nestor is the Remedial Project Manager
15 who handles the day-to-day technical activities.
16 Here on the front row is Harold
17 Taylor. Harold is the Chief of the Tennessee-Kentucky
18 Section of the North Superfund Remedial Branch. Nestor
19 and I work for Harold. We are with the United States
20 EPA out of Atlanta, Georgia.
21 We have Rick Hogan who is with
22 the Superfund Program and Larry Moscoe who is with
23 the Department of Law Commonwealth of Kentucky.
24 We thank you all for coming.
25
-------
1 I don't believe we have any local officials with us
2 tonight, but we did meet with them today, and they
3 said they were very sorry, but they had other ""
4 commitments and could not be here today.
5 I am sorry. I missed Tracey Johnson
6 with the Superfund Program from Atlanta, Georgia.- '•
7 Nestor will be going over the site background and
8 Remedial Investigation summary. He is going to give
9 you a little bit of detail about EPA's proposal, and
10 in a few minute I will get back up and tell you all
11 about the public participation opportunities, and
12 then we will tell you the next step, what happens after
13 tonight.
14 Then we get to the most important
15 part, and that's the question and answer period. I
16 will ask you all to hold your questions and comments
17 until all of the presentations have been made, and I
18 promise we will get to each and every one of you. Nestor.
19 MR. YOUNG: Hi, and welcome. We
20 normally start by saying a few important things. If
21 you need to use the bathroom facilities, they are down
22 the hall toward the end of the hall. I am going to
23 basically talk about the investigation that we have
24 conducted; the results of the investigation and the
25 feasibility study.
-------
1 The Feasibility Study, basically
2 is looking at all possible alternatives that we can
3 implement. So let me start by talking a little bit
4 about the site background.
5 Most of you who are here tonight
6 I have spoken to before, and have a good understanding
7 about the background of the site, but for those of
8 you who have not, or who don't know about the site,
9 let me tell you a few words about that.
10 Green River Landfill is basically
11 composed of two separate areas, natural landfill
12 itself, and the area adjacent to the landfill that
13 we call the Kelly Cemetery Road Site.
14 By the way, if you didn't pick up
15 a handout, you might do so over there on the table
16 and you can follow along. It is a copy of the over-
17 heads I will be using. You can follow along in case
18 you can't see the screen too well, or in case you want
19 to take some notes.
20 On that table is a copy of EPA's
21 Fact Sheet, which is a summary of an investigation
22 and summary of a Feasibility Study, and I am going to
23 go through that tonight. Tonight' lecture or talk is
24 a little bit of a summary of that information on the
25 Fact Sheet. But anyway, the landfill is composed of
-------
two areas, the Kelly Cemetery Road Site. The Kelly
2
Cemetery Road Site is an area along the north side
3
of Kelly Cemetery Road. Let me show you a picture
4
of the site. Kelly Cemetery Road area is these squares
here.
6 ;
This diagram is toward the back
of that packet. This area used to contain about 776
Q
drums of ferrocyanide waste, and back in 1985 the
g
Commonwealth of Kentucky removed those drums. They
10
were disposed of on the ground, on the side of the
road, and they all removed those drums.
12
We included this area as part of
13
the investigation of the landfill to determine whether
14
or not there was any residual contamination or con-
tamination left behind by those drums in the surface
1 R
soil. The records were not very clear as to
exactly where the area was located, and where the drums
18
were located, so what we decided to do was to take this
19
area along the landfill and along the Kelly Cemetery
20
Road Site, and we broke it up in 25 different grids
21
and took samples in each one of those areas.
22
We pretty much determined more or
23
less where the drums were disposed of, and they are
24
sort of along in here, but we didn't find a whole lot.
25
They did a pretty good job of picking up drums and
-------
1 residual contamination. There were a few contaminants
2 we did find, but they were not found to pose a hazard
o
or environmental risk.
4 Tonight I am going to be talking
about something other than the. Kelly Cemetery Road
- •
area because it is pretty much cleaned. If you don't'
know where the site is located, it's just north of
Highway 60 along Kelly Cemetery Road.
EPA listed the site on the National
Priorities List back in 1990. The National Priorities
List is a listing of the most contaminated sites in the
Country, and what we do is initially the states, I believe
13 referred this site to EPA.
We went out there and took a few
samples, studied the site a little bit and calculated
a number that will determine whether or not it gets
placed on this list, and back in 1990 we determined
that there was enough risk at the site that it- warranted
19 an EPA investigation. EPA Superfund Investigation, and
basically the threat that we were looking at back
in 1990 was, you know, a threat to the residential
water supply as well as in the area, the neighborhood,
23 and uncontroled discharge of leachate.
24 Leachate is the water that gets
25
percolated through the landfill and it comes out the
-------
bottom. It is usually contaminated with waste
2
material, so I will be referring to leachate quite
3
a bit tonight.
4
The Green River site is approx-
imately 14 acres, and it was operated by the Green ,
6 ' *•
River Disposal Company, more or less from 1970
to 1983, and it was a permitted landfill, and accepted
p
basically general trash from local merchants and
companies.
However, there was industrial waste
that was also disposed of here. The waste was
12
basically pushed into ravines. It is something like
13
when you dig a hole and bury the waste in the hole.
14
In this particular case, the waste was pushed into
ravines and covered with soil.
1 fi
Let me show you a general picture
of what that looks like. If you would look at the
18
profile of the site, it looks something like that,.
19
Generally, this is a natural ground here and the darker
20
is the waste that was pushed over the side.
21
So the landfill looks more or less
22
like this. If you haven't noticed, I have pinned up
23
on the wall an aerial photograph of the site, and I
04
would encourage you to take a look at that. It gives
25
you an overall picture of the site, and a view from
-------
the sky. However, it is very deceiving because it is
two-dimensional, and you really don't get a feel for
o
how deep the landfill is, or how high the top is
compared to the bottom of the hill, but it looks more
or less like this.
fi
0 The remedial investigation
basically consisted of these items here that I have
Q
listed. I won't be going through all of those. I will
be basically summarizing the data that we collected
and the results of that data.
As you can see, the investigation
1 9
was quite extensive. We did a lot of work out there.
We took samples from soil, ground water, sediment, air.
We surveyed the area. We trenched the landfill and
collected samples of leachate and did ecological
1 fi
assessments.
17 Let me say a few words about the
trenching. Because of the drums that were disposed
19 of along the Kelly Cemetery Road Site and because of
several references in the file to drums being located
21 at the landfill, we thought that there was a good
chance that there might be drums that were buried in
the landfill that may contain waste and generally the
types of waste that were put in the metal drums were
25
either liquids, solids of material, or sludge that would
-------
have to be contained by a metal container, and over
o
time the metal container rusts, and this liquid leaks
o
and comes out, and if you don't take care of that
early on, you know, years down the line you may see
that coming in the leachate or seeping out of the
ground.
So they thought there would be a
potential for buried drums at this landfill and the
one way to find out is to trench it. You could
install holes and try to look for them that way, but
that's like trying to look for a needle in a hay stack.
What we did was, we identified
areas on the landfill using different types of field
instruments that would give us a good chance of hitting
some of those drums. Some of these would be like a
16 metal detector, for instance.
So we have identified certain
containers in the landfill that would possibly^contain
these drums, and we installed trenches in those areas
20 to make sure, as you can see here.
2' The trenches were about twenty
22 feet deep, fifty feet wide and fifty feet long and
six feet wide, and the two reasons for the trenches
24 were, one mainly to look for buried drums, and two,
25 to look for hot spots.
-------
1 When I say a hot spot, I am saying
2 areas of the landfill that may contain highly toxic
mobile waste or contaminants where leachate or water
percolated through which might get very concentratedr
and essentially take away those contaminants, so we
were looking for hot spots and looking for the buried
drums.
The results of the investigation
was, we didn't find any buried drums. We found a few
crushed drums, but it was very clean. The waste in
11 the area, in the trenches, was the same, It was no
12 different on the east side from the west side.
13 It was basically the same kind of
14 waste all the way through. There wasn't one area
particularly different form the other, and as far as
hot spots were concerned, we took samples from each
one of those trenches, and sampled for everything
that we could think of and again, we didn't find any
hot spots at all.
20 The results pretty much shows that
21 the waste was pretty much the same throughout, so
22 that's actually good news, because we don't have to
23 necessarily treat one area of the landfill differently
24 than all of the rest. We can basically treat the entire
25 landfill the same.
-------
Just to give you an idea of how many
samples we took, this list kind of shows you a number
of samples that we took in each type of media, surface
soil, surface water and sediment, ground water, and
these would be the trench samples and leachate, and
again, we basically sampled for everything from metals
to organic materials. Organics are compounds normally
found in gas, say, or in an oil, and this overhead
shows you the breakdown of the types of contaminants
that we found in each one of those media.
11 As you can see, we did find a whole
12 lot of normal contaminants. The main point is with
metals, and this is inorganic compounds, and that's
fairly good, because they don't travel as quickly as
15 organic compounds. Organic compounds are lighter
than water and tends to float.
When you have an organic contamin-
ant, it tends to spread very easily along the ground
water whereas metal will tend to move much slower.
20 They bind off in soils, so you don't generally find
21 a huge ground water problem, or a nasty contaminated
22 area with metals.
23 Metal tends to say fairly
24 confined to the local area, and it is not quite as
25 toxic. Generally, with organics, we find organic
-------
compounds tend to post an excess cancer risk where that
o
is not the case with metal. With metals, you find those
pose a more toxic risk other than cancer.
There are a few metals that do pose
a cancer risk, but they are very few. The results
fi *
of the samples that we took in the remedial investigation,
like I mentioned before, there was really no contamin-
ation in the landfill. The COC's don't pose a human
health risk, and by that I mean we looked at the
types of concentrations of the compounds, the concen-
trations and types of exposures that someone would come
12 in contact with those contaminants, and looking at
all of those various things, we came up with these risk
numbers that will give you an idea how toxic or how bad
this contamination would pose to someone being exposed
16 to it.
17 So we didn't really find any human
18 health risk with the compounds that we found* The
19 ground water, we installed monitoring wells all around
the site and let me show you the map of some of
21 the ground water wells that we installed.
22 Each one of those black dots here
represents a monitoring well, and well you can see we
24 installed monitor wells all around the site looking for
possible contaminants migrating from the site.
-------
What we found out from the data
that we collected is that there is not a significant
q
ground water problem. Like I mentioned before, most
of the contaminants found were metals and not organics,
so we didn't find a significant contamination problem.
As a matter of fact, there were *,
only a few contaminants and in a few monitoring wells: that
really posed a risk to human exposure, but it is not
quite clear whether those contaminants came from the
landfill or are naturally occurring, because they are
11 metal, beryllium and manganese, mainly.
12 So what we decided to do is at this
point in time we are not going to decide to do anything
with the ground water other than to continue monitoring
it. We want to collect more data to accurately deter-
16 mine the relationship between the landfill and the
ground water, because like I said, some of those could
be naturally occurring, but we haven't established that
19 yet
20 The data doesn't, demonstrate that. ..
21 We need to collect more data to accurately determine
the relationship between the landfill and the ground
water, so what we are proposing now is to continue the
24 ground water monitoring for about a period of two years
25 and collect samples roughly quarterly, and hopefully
-------
by then we will have enough data to make an accurate
o
determination of whether or not the ground water is
o
being impacted by the landfill.
But again, there is not a signifi-
cant problem here, so by continuing monitoring, there
wouldn't be a problem in doing so.
What we did find, though, is that
o
there are three major problems with the landfill. The
q
waste itself presents a problem. The leachate that is
being generated from the waste is a problem, and we
found that there are some sediments in a small creek
1P
in the valley of that area, and that sedimentation
-JO
pond that is contaminated with some metals that pose an
ecological risk.
So part of the remedy, well, the
remedy will take care of those three problems, and like
17 I mentioned before, there were no hot spots or buried
drums in the landfill, and there didn't seem to be any
harmful levels of gas emitted by the landfill.
Let me just give you a point of
21 reference where the sedimentation pond is. This little
dark area right here. This line here represents the
stream along the valley. We also mentioned the Kelly
Cemetery Road Site and Chestnut Grove Road along this
area, which is along the rim of this hill, and all of
-------
this area in between slopes in towards the stream, towards
o
the pond, and then out. The water flows out towards the
west, and this sedimentation pond was constructed,
I believe, at the request of the State back in the
nineteen-eighties, and what it was designed to do was
/j
to stop sediment that was coming from the landfill from
flowing down the creek.
Q
So it has accumulated quite a bit
g
of sediment. I believe the deepest portion is about
six or seven feet deep, and like I mentioned, some of
that sediment is contaminated with a few metals, so
1P
'* we will be implementing a .clean-up remedy for that.
Like I mentioned, the three problems
at this point are the landfill, leachate and the stream
and sedimentation pond sediment.
The feasibility study that we
conducted is basically a study to evaluate the various
1ft
0 clean-up alternatives that we could possibly implement
1Q
for the clean-up problems.
20
What we did in this particular case
21
was sort of shorten that study period. Instead of
22
looking at the possible alternatives, and some of those
23
being to dig it out and take it somewhere else, or dig
it up and burn it. Those alternatives for the most
part are costly and not very practical.
-------
1 We did what we call a presumptive
2 remedy. That is, EPA has been involved in many of a
3 number of landfill clean-ups and through our experience
4 in doing these studies, we have also reached the same
5 conclusion, that typically when you have a very common
6 type of landfill, you usually construct a landfill-, cap
7 and try to contain the waste.
8 That seems to be the most reasonable
9 and appropriate remedy for these types of sites, so
10 what we did was, we implemented a bridge to shorten
11 the study period and look at the different types of
12 landfill caps we could implement instead of looking
13 at the other remedies that we know are too costly and
14 are not ;very appropriate.
15 What I want to talk about next is
16 basically run through the various problems and look at
17 the objectives to those problems, and look at the
18 alternatives to be considered for remedying the problems.
19 The first problem at the landfill is
20 the actual waste itself. The problem with the waste is
21 it produces leachate, and the way leachate is produced
22 is, basically you have rain water falling on top of the
23 landfill that seeps into the waste and migrates or
24 flows through it and end up at the bottom of the hill,
25 and starts coming out at concentrated amounts in the
-------
1 water in these sediments. Some of the waste in this
2 landfill are currently exposed, meaning they are not
3 under a cover. And the waste I am talking about is
4 aluminum dross salt cake:. That's the type :of waste
that has been disposed of here at the site.
This waste comes in generally two',
tyoes, in a block, a very hard block, and in pov/der form
We encountered these blocks when we were trenching.
As a matter of fact, the cutting tips were sort of
ripped off the teeth of the backhoe we v/ere using when
we tried to chip into it.
12 It was very, very hard, but the
dross is exposed> and is located at the top of the
14 landfill. It is sort of a mound, and you can kind of
see it in that area. So that's an additional problem
16 here.
We've got the aluminum dross at the
18 top of the landfill that is currently exposed, not
covered by anything. And also, long term, you've got
20 potential erosion problems, you know, over a long period
21 of time. The soil cover that's on there will eventually
22 degrade and just slump into the creek, and so you've
23 ot erosion problems.
24 So the objectives of correcting
25 these problems are basically to prevent direct exposure
-------
to the waste, to put some kind of a cover on it so that
humans or animals can't come in contact with the waste
o
and therefore be contaminated by them.
4 And also, the infiltration of rain
causing the generation of leachate. So those are
c
basically the objectives of the remedy that we are- ',
' considering for the landfill.
Now, we studied basically five
alternatives, clean-up alternatives for the landfill.
The very first one is 'no action1. We are required
11 by law to evaluate not taking any action, meaning just
walking away from the site and leaving it like it is.
That also provides us a baseline
14 to compare all of the other ones too, so we are
15 ., -required by law to consider that.
The next alternative that we
considered was capping with a soil cover, more or
° less what's out there now, but sort of augmenting the
soil cover that's there, and basically, that's all it is,
just putting another layer of soil on top of the
landfill and compacting it and grading it so that not
much infiltration occurs.
The next alternative was capping
with a clay cover. The clay adds the benefit that clay is
very dense, and it provides a fairly impervious cover
-------
1 over the landfill. It is harder and resists erosion
2 better than the soil cover.
The other two are basically combi-
4 nations. The next one is capping with single barrier
5 geomembrane. This geomembrane is a very thick hard
plastic, and I have some samples here for you to sete.
After the meeting, you can come up and take a look, at
them and touch them. It is basically a hard plastic
that, again, prevents water from going through it,
and that alternative would just consider putting a
11 sheet of plastic over the entire landfill and covering
12 it with a layer of soil.
13 The next alternative is basically
14 a combination of the two previous alternatives, which
15 is the clay and geomembrane. Basically, that remedy
16 is the. combination of those two, a layer of clay and
a layer of geomembrane.
18 And that adds obviously an added
benefit to just one of those alternatives alone.
20 The next problem that we looked
21 at is leachate. The problem with leachate, again, is
22 that the water doesn't generate from the site.
23 Currently, what we have done, we have installed a
24 temporary system recirculating that water through the
25 landfill, so we are collecting it at the bottom in
-------
1 berms, and we are pumping it back up to the top and
2 recirculating that part. What we have found out, is
3 that we are nearing the expected lifespan of that"
4 system. You have to understand that that system was
5 a temporary system. It was not meant to last for
6 years and years. ;
7 I think it has been running for
8 about three years now, and again, it wasn't meant to
9 last a very long time. We are nearing the end of its
10 life-expectancy. What we determined is that the landfill
11 is presently pretty much -saturated with water, and there
12 is a whole lot of water in the landfill itself.
13 Again, leachate presents unacceptable
14 risks. These affects are to the local environment. The
15 concentrations aren't high" enough to produce a human
16 health risk, but they are high enough to present an
17 unacceptable ecological risk.
18 And that is it puts local species
£.
19 of animals in danger if they drink it, or if they live
\
20 in the water, for example. Some of those contaminants
21 are metals, again, and primarily ammonia. There is
22 a high concentration .of ammonia being generated there,
23 and we as .1 previously mentioned, the aluminum dross
24 salt cake.
25 It is a by-product of the reaction of
-------
the waste and water. So the objectives, again, are to
2
prevent direct contact with this water and prevent the
o
migration of those hazardous substances to the stream
and into the around water.
Some various alternatives, again,
that we evaluated were, again, no action, limited'
institutional action, and what that is is basically
Q
not necessarily cleaning up the leachate, but
q
preventing contact with that waste.
In other words, maintain your
fence around the site to prevent people from coming
1 9
in contact with it, continue monitoring it to see if
1 ^
the contaminants in that waste are decreasing over
time, .to prevent deed restrictions for the property
so that anybody in the future looking to maybe purchase
the property at the site or near the site would
. know that there is a problem there, and that's
° basically limited institutional action.
^ You are not dealing with the
20 problem, but dealing with the symptoms of the problem.
i
And the third remedy is collection of the leachate,
rjn
*•*• treating it and discharging the clean water.
So those are the three alternatives
24 we considered for leachate. The next problem area
that we looked at was sediment. Like I mentioned
-------
before, the sediment, the main problem with the
p
sediment was the contaminants in the sediment which
3
are high enough to pose an unacceptable ecological
4
risk. In other words, the danger to animals coming
in contact with it, but not high enough to present a
c
human health risk, so people coming in contact won't"
be affected as would animals coming in contact with it.
So the objectives mainly are to
Q
prevent exposure to the environment of the contamin-
10
ants that are in the sediment, and the various
alternatives to be evaluated for the sediment is
again, no action, limited institutional, again, just
keeping a fence around the site, putting deed
14 restrictions and continuing sampling or monitoring
to make sure the problem is not getting worse.
1 fi
And the third one is excavation of
. those contaminants, sediments, and disposing of those
1fl
sediments in the landfill itself.
19
In other words, putting it into
90
the landfill waste. After evaluating all of the
91
alternatives that we came up with, what we decided
to do was go ahead and install a cap that is a combi-
nation of the clay and the geomembrane.
Another question is, later on, how
" this cap would be constructed, and I really don't want
-------
to get into that because at this point in time I don't
2
have any details of how it will be constructed, and.
3
we want to evaluate all of the alternatives and
4
determine how that is to be done, but we believe this
5
alternative provides the best way to address the
6 *•
concerns that we have uncovered.
As far as leachate is concerned,
Q
I think it is very clear what we need to do with it, and
Q
we intend to collect the leachate, treat it, removing
the contaminants from the water and discharge the clean
water into that unnamed stream, or the stream at the
12
bottom of the valley, and for the sediment, I think
13
the best thing to do is dig it up and place it in
14
the landfill which will prevent the hazard for humans
and animals as well, just cover it with a cap.
1 fi
As Suzanne mentioned- the purpose
of this meeting is to summarize the results of the
18
investigation and to present to you EPA's recoiftmendations
19
for this site. Your comments are very important to
20
the Agency, and as a matter of fact, you all play a
21
very important role in selecting the remedy, so the
22
purpose of this meeting tonight is merely to solicit
oo
your comments, and we have been working very closely
with the Community group that has been organised here
pc
tonight that Patsy Gordon represents.
-------
1 As a matter of fact, we met with
2 them last night and went through the findings again,
3 and we have been working very closely with this" group.
4 We have been sending them draft
5 documents all along, and results of the testing data.
6 We have informed them of everything that has been \
7 happening at the site, and so they are fairly
8 knowledgeable, So if you have any questions later
9 on, and you can't get ahold of one of us, Patsy would
10 be a very good resource in the local Community that
11 could probably answer the question and help you out.
12 The other good source is the
13 Administrative Record. The Administrative Record is
14 a formal official file that is set up that contains
15 all of the information that we have gathered, and that
16 provides the basis for our remedies selection. We
17 have located that file at the Owensboro-Daviess County
18 Public Library in the Reference Section of the library.
19 It has all of the reports that
20 have been generated. It has data. It has communications
21 between EPA and the potential responsible parties,
22 and with the Community group..
23 If you have any questions, or if
24 you would like more detailed information, I would highly
25 recommend you visit the Administrative Record because,
-------
again, the Record represents the basis for us taking
2
an action here, and it contains very detailed information.
Q
If you have even more questions,
4
or would like to talk to me directly, I am as close
as the telephone. Again, my name is Nestor Young, and
f*
Suzanne Durham was just up here before me, and here is
our direct phone number.
Q
Again, these are in your handouts,
Q
and we also have a toll free number, so if you have any
other questions after tonight and you visited the
Administrative Record, and would like to talk to me
12
in more detail, I am as close as a phone call.
That is more or less my presentation.
That is the summary of the Remedial Investigation,
established Feasibility Study, and I believe up next is
Suzanne Durham, who is going to. talk about Community.
relations and how you get involved in this process.
1 ft
Suzanne.
19 MS. DURHAM: Well, Nestor pretty well
20 covered the Community relations portion satisfactorily.
Thank you, Nestor. I do want to remind you, and for
those of you who came in after the meeting began, if
you did not sign in at the registration table, you might
want to do that before you leave.
- Choosing a final clean-up remedy is
-------
1 probably the most important decision ever made at a
2 Superfund site/ and that's why we are here tonight,
3 to ask for your help in making that final decision.
4 We mailed to all of you a Fact
5 Sheet about two weeks ago, which summarizes some of
6 the things in the Administrative Record, and that- ;.
7 Administrative Record is basically our legal file.
8 It contains all documents that
9 the EPA has used in proposing this clean-up remedy.
10 It's eight volumes. It is at the Owensboro Public
11 Library, so I strongly urge you to go by there and
12 familiarize yourself with that file.
13 The public comment hearing began
14 July 19 and extends to August 17, 1994, and that will
15 provide, you know, an opportunity for public participation
16 All comments and concerns must be carefully considered
17 before we make a final decision.
18 We hope to sign a Record Decision by
.=
19 the end of September of this year. When that occurs,
20 I will publish a notice in the local paper telling you
21 exactly what the final clean-up remedy is going to
22 be, and in the meantime, as Nestor said, if you have
23 a question or comment, you can reach us at that address
24 or telephone number in your handout. Thank you.
25
-------
MR. YOUNG: Basically, I want to talk about
2
what is next. So we are at the stage where we_ have
3
completed the investigation. You know, we have con-
sidered various remedial alternatives, clean-up alter-
natives, and we are now faced with the decision of
;.
choosing one of those alternatives and what's next?
Basically, out of this meeting
p
and after the public comment period ends, the Agency
q
* will issue what is called a Record of Decision, which
is a document that establishes what the final remedy
is. And we hope to get that document out by September
of this year.
-10
So after that point in time, after
we decide what the remedy is going to be, we go back
5 out and look at all the potentially responsible parties
"1R
that we have identified previously.
Currently, we have four companies
18
that have conducted the investigation, and there are
1Q
other numerous companies that also have disposed of
PO
waste here, but did not actively participate in the
investigation that we will be contacting to get them
pp
^ to participate in actually implementing the remedy . So
the next phase really is to identify these reponsible
^ parties and try to see if we can work out an agreement
25
between the EPA and those responsible parties to aet them
-------
1 to perform the clean-up remedy. The next step would
2 be to actually design the remedy, design the landfill
3 cap, design the leachate collection system and plan
4 out how we intended to construct this.
5 After we have completed that, which
6 I imagine will take a few, several months, the next ',
7 step would be to implement remedy, go out in the field
8 and construct it. Let me say that all along this
9 process the Community is invited to participate and to
10 comment, and as a matter of fact, we intend to stay
11 in contact with you, the local Community group, and
12 keep you involved in actually designing, having input in
13 the designing of the remedy and during construction.
14 So the current schedule, as it
15 stands, is the Agency will issue the Record of the
16 Decision in September. We are currently negotiating
17 or talking to the responsible parties that conducted
18 the investigation, to try to expedite things and
19 hopefully work things out so that we can actually
20 have designed a remedy by the next construction season,
21 so we can actually go out and start construction of
22 the remedy.
23 But let me just caution you, that this
24 is the 'best case' scenario. We are working with
25 those responsible parties, which up to this point have
-------
been very, very cooperative. I think there has been a
good relationship between the Community group, EPA and
the responsible parties, working together to reach the
final goal, and that is the final clean-up, and so
far we have worked pretty well, and we don't see a
R •
problem with continuing that relationship in the future,
so I hope that we could go ahead and quickly implement
Q
the remedy.
But under the best conditions what
we could possibly have is complete the design in the
next few months, and have a design ready for the next
1")
construction season, and .that will be next summer.
However, things don't always work
out as you planned, so Superfund is a very complicated
* program, and there are a lot of steps you have to go
through, and there are a lot of road blocks that tend
17 to pop up, unforeseen things, and something may happen
1 fl
10 that we may not be able to get to it in the next
1Q
constructions season.
20 That would be the 'worse case'
scenario. I don't think that's going to happen. I am
nn .
very confident we can work things out and move things
23 alon.
24 Again, we've got a pretty serious
commitment from the current PRPs, potential responsible
-------
1
parties, and again, we have a very good working re-
2
lationship, and I am very confident we can work..things
3
out and move forward. That's pretty much it. The
4
next step, issue a Record of Decision, and proceeding
5
with the designing of the remedy and implementing the
6 ' V
remedy, and by then it's pretty much operation and
7
maintenance.
8
The current laws require that after
9
you close the landfill, after you construct the cap,
10
there will be a period of about thirty years where
11
you continue to minitor the site, taking ground water
12
samples and making sure there are no new leachate
13
outbreaks, and make sure the landfill cap that was
14
constructed is in good condition,
15
That will continue to occur after
16
the landfill cap is constructed. That will be pretty
much it. Again, we will be working with the local
18
Community group in the next few months, and they will
19
be involved in the process.
20
That's pretty much my presentation
21
as to what is next. I believe next on the agenda are
22
questions and answers, and what I would like to do
23
before we get into that is, I know that Patsy Gordon, the
24
President of the local Community group, has a few things
25
to say, and before we get into the question and answer
-------
1 period. I am going to invite Patsy up here to make
2 a few comments, and after that we will go ahead and
3 open it up for the questions and answers.
4 MS. GORDON: Thank you. My name is Patsy
5 Gordon, President of the Green River Toxic Waste
6 Clean-up Association. We support the EPA's proposed \
7 plan as announced by the EPA in the newspaper, to cap
8 the landfill with a composite barrier cover, which is
9 option number four, treat the leachate by collection
10 with sub-surface drains, chemical and physical treatment,
11 and discharge of treated water into the stream, which
12 is option three, and to contain the stream and sedi-
13 mentation pond sediment by consolidating it with the
14 landfill wastes, which is option three also.
15 Who are we, and what are we trying
•16 to do? Our group is an outgrowth of the Maceo Concerned
17 Citizens Group. We formed our group because as citizens
18 we were concerned about the site's impact in the long
19 and short term on our environment, and on our local
20 Community's economy. After studying the situation for
21 some time, we also became concerned about the impact
22 of the clean-up's costs on the financial well-being of
23 some of the area's premier employers.
24 For the last two years, our purpose,
25 as stated in our Mission Department, has been to
-------
encourage public participation in bringing about a
o
prompt, cost effective and permanent solution of the
o
highest quality of the Green River Disposal Superfund
4 Site.
This involves working with the
6 •
Potential Responsible Parties or companies and the
United States Environmental Protection Agency, sharing
o
knowledge, concerns and comments about the issues
involved.
Our group's Mission Statement is
available for you on the table. Our effort builds
19
^ on the work begun by our neighbor, Mr. George Thompson,
1 *3
ten years ago.
As all of you who have attended
our local citizens group meetings for -the last two
1 R
years know, we have had a continuous sharing of
information between our group, the companies and the
1 fl
0 EPA during this time.
1Q
We have not always agreed. But
on
^u we have always communicated. Those of'you who attended
1 :
' ' all of our monthly meetings probably think we have
pp
" communicated too much, and are tired of getting copies
23
of all of our long letters back and forth with the EPA.
But if this proposal can be
pc
implemented next year instead of seven or eight years
-------
from now as originally.proposed, it will all have been
p
worth it.
3
Where did this proposal come from
4
and what will happen next? This remedial investigation
feasibility study has been developed by consultants.
6 " '•
hired by the companies with oversight by the EPA.
We are happy to report that our
Q
group has been asked for input and some of our input
Q
is reflected in the report you see today. The
EPA will consider the RIFS Report and the input here
tonight, and next it will select what it feels is the
12
optimum solution, balancing risks and economics, and then
13
move on to the design phase..
It will call for bids for design
of that solution. At a later stage, once the design
1 fi
has been approved, bids for implementing the solution
will be solicited. Then construction will begin.
1 R
What do we think about this proposal?
1Q
We have always believed the main threat from this dump
on
*• was water contamination. To us, the dump material is
?1
sort of like toxic coffee grounds, and the leachate,
22
which is the stuff running out of the dump, is like
23 coffee.
2 We have always said, if you put a
OK
good clay tea cup upside down over the grounds so the
-------
water can't percolate through them, you stop making
2 coffee.
o
We think .the composite barrier
can be that tea cup. Then if you filter and treat
* the bad coffee so it is safe to drink, and if the
fi
material that spilled from the dump as sediment is
picked up and put back under the clay cup, you have
Q
done about all you can do.
We understand this is the solution
proposed here by..the EPA. We endorse the solution
published in the EPA's Notice. Naturally, we want to
see the design to make sure it really is the best tea
cup to keep the water out and really will do a good
job of covering the bad material.
We have always urged an expedited
approach with each step taken being a part of a final
solution. We have always opposed steps, even as a
temporary solution, like pumping the leachate up the
19 hill and letting it recirculate through the dump in a
loop, which is what has been going on for the last
several years.
22 This type of response only delays
facing the problems and permits the pollution to
24 increase its damage to the environment as rainfall adds
to the water going through the soup. The steps we see
-------
1 proposed here tonight are moving toward a solution.
p
fc Is this study perfect? We have
o
0 questions about certain aspects of the ground water
flow, but even if we are right, a properly deisnged
cap is still the best answer. If this proposal is
accepted, what remains is to see it properly designed
and implemented, in a prompt high quality manner.
° When you consider that the problem
and the need to clean it up was pointed out clearly
by Mr. George Thompson in 1984, ten years ago, you can
see what a struggle it has been and why we fear the
12 struggle isn't over yet.
Why do we favor the EPA published
proposal? Given the reasonable alternatives, we
feel this proposal best meets the test of being a
1" prompt, cost effective, permanent fix of the highest
quality.
This proposed solution of aapping
the dump site with a composite barrier cover consisting
20 of clay and a geomembrane, coupled with pump and
21 treatment of the leachate pool, is clearly what we
22 have believed in from the beginning, and represents
23 the best realistic solution for the environment, the
24 Community and the companies.
25 We believe strongly in a maximum
-------
quality cap as it will tend to degrade gracefully. We
believe that in evaluating the proposed remedial
Q "~
actions, of key importance are the total short and
4 long term costs of such actions, including the costs of
operation and.reality of long term maintenance.
" We favor the treatment of the
7 leachate because it reduces the volume of the
hazardous substances and lessens the likelihood of
its escape.
Placing the sediment back under
the well-designed cap places all the problem material
^2 in one place, where if there are'further problems,
it will be easy to locate and deal with.
Why is speed important? Everybody
is losing by delay. The longer we wait, the more
leachate is built up, or escapes, and the environment
'7 suffers by delay.
'" Our Community and the adjoining
landowners remain under a cloud of uncertainty as to
20 the safety and value of our Community as a place .to live
2' and do business.
22 The companies' expenses at this
23 site increase greatly by delay. Remember, the public,
24 as consumers and stockholders and wage earners, will
ultimately pay the companies' expense.
-------
1 No one is winning by delay except
2 the paper pushers. While it was not mentioned in the
EPA Information Sheet, in addition to the five
million dollars spent on testing and containment, and
the ten million dollars proposed for a clean-up, well
over five hundred thousand dollars has been spent *•:
on EPA oversight to date.
. The companies are paying every
dime spent. Even all of the EPA expenses. These
clean-ups are very expensive. At this site, we are
11 talking about a million dollars per acre.
12 Expeditious action tends to hold
13 these costs down. The four companies listed are
14 some of our area';s premier employers, and benefit our
Community in many ways.
16 They have assumed large financial
burdens in undertaking this clean-up. Their sound
financial health is important to us locally, and
nationally.
20 These companies must compete
nationally and internationally, and cannot afford large
22 unproductive expenses. We have no desire to see these
23 companies unnecessarily injured.
24 We are especially glad to' see the
25 EPA try an expedited solution of implementing a common
-------
sense solution to the problem how and monitor the
2
results.
3
They call this common sense approach
4
a presumptive remedy. The alternative is studying the
site for years in search of some theoretically perfect
solution while the pollution spreads and becomes moire
difficult to clean up. We want this site expedited.
o
How did we get in this mess?
g
Probably this material shouldn't have been dumped
here in the first place, considering the soil type
and the folks running the dump shouldn't have been
12
doing it the way they were.
13
It may have been legal and a commonly
14
accepted business practice at the time, but it was short-
15
sighted. However, hindsight is always perfect. This
1 R
is history, and we have to do the best we can now
for the future generations.
1R
Is the problem permanently solved now?
19
While this proposal puts us on the right path, we are
20
not at the end of the journey. It is important to
21
all of us to be sure this really is the best tea cup
22
we can find to do the job.
23
I urge support for these proposals
and their"expedited implementation. We also ask your
25
continued involvement in helping making sure they are
-------
1 implemented in a way that will protect our environment
2 and future generations. Everyone knows things go
better when someone is watching. Help us watch.
4 MR. YOUNG: Now I am going to go ahead and
5 open the floor to questions. .But first I .would like
to lay some ground rules. We have a court reporter yho
is taking down every word that is said, so for the
sake of the court reporter, if you could, stand up,
speak very clearly and very slowly. State your name
10 and if the name is difficult to spell, please spell
11 it for us, so we have an accurate record of the
12 comments you make.
13 . We would also like to kind of
14 limit the number of questions to two every time I
call on you, because what we would like to do is get
everybody involved. We don't want any particular
group to monopolize the time.
18 What I would like to do, if you
have more than two questions, ask those two first and
20 then I will get back to you as soon as we have given
21 everyone else an opportunity to ask. So with that,
22 i will go ahead and open it up for questions. Does
23 anybody have any questions? Yes?
24 MR. TIM GOETZ: My name is Tim Goetz. I
25 Was just curious, is there any background wells
-------
1 drilled outside of the area to help determine if there
2 were metal found in the ground water?
MR. YOUNG: Yes, we do have some background
wells and metals show up in the well as well, so that's
what we want to establish clearly, whether or not they
are coming from the landfill or naturally occuring. ;;
MR. GOETZ: And I have one more question.
about the leachate collection. I am assuming it is
going to be below the cap?
10 MR. YOUNG: Right.
MR. GOETZ: Will the leachate eventually
12 stop producing?
13 MR. YOUNG: Correct, over time. If you
14 understand how leachate is generated, it is generated
15 from the storm water that permeates waste, so over
time we expect there would be no leachate.
17 After the cap is built and we
prevent water from percolating through the waste, there
19 is not going to be any leachate coming up. So we expect
20 in the first year or two years to treat the water
21 leachate, but after that period of time it will drop
22 off significantly, so over a long period of time there
will be essentially no leachate.
24 Anyone else? I know this takes
25 a little bit of time before you feel a little bit
-------
more comfortable. I know there are a lot of questions
out there. Yes?
MR. GEORGE HAWES: My name is George Hawes.
I would like to know, number one, who is going to do
the detailed engineering design, and number two, will
we get a chance to review those design drawings befdore
' the contract is awarded to do the work?
8 MR. YOUNG: Yes. Like I said, we are working
° with the current potentially responsible parties that
did the investigation. We are currently working with
them to have them begin the design work. They will
'2 select the contractor that has experience and is
competent in landfill design and construction to do
that work.
° EPA really has no input'as to who
1° those contractors are. The only rule that we have
'' is to be sure the contractor is competent and exper-
ienced.
19 MR. HAWES: I am talking about the engin-
20 eering drawings, the detailed engineering drawings.
2"1 MR. YOUNG: Yes, the detailed engineering
22 drawings, as well as the construction both, the
23 responsible parties will be responsible for doing that.
24 MR. HAWES: Will we get to review them
before the contract is awarded?
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
MR. YOUNG: I don't know, because the
contract needs to be awarded first, and then the
drawing will be done.
MR. HAWES: You do the design first and
then award it?
MR. YOUNG: Well, there is a bid package,
that goes out to the contractors, and the contractor
is chosen, and correct me if I am wrong, Mike.
MR. MIKE MILLER: We will put out a request
proposal and we will do design according to Patsy and
rest of her group; that we have no problems with
having them review the design as we proceed along.
When that design is finalized by EPA, it will be
prepared in a bid package before construction.
Just for the record, my name is
Mike Miller.
MR. YOUNG: Any other questions?
MS. BRENDA PAYNE: Once construction is
started on the site, how long will it take to get it
finished?
MR. YOUNG: The actual construction of the
cap and ,leachate and all of that I anticipate won't
take longer than a few months, say six months. I don't
know exactly. I can't tell you exactly how long it is
going to take because I don't know what the design is,
-------
and I don't know what the plans are for implementing
2
that design, so I can't tell you exactly how long it
g
is going to take, so I know certainly within a few
4
months during the construction period, during the
5
summer months, maybe Mike has a better idea.
6 - •
MR. MILLER: Mike Miller again. I agree '
it should be done in one construction season, but it
Q
depends on what kind of design it is. As you can see,
Q
we have just gone through the dry months, and it has
rained every single day.
You can't go out there and put down
1P
a clay cap when it is raining every day. You have
"13
to have the proper content to get the compaction of
the clay. Hopefully, this is not the summer we will
have next summer.
16 If we do, it may be delayed because
of the rain.
18
MR. YOUNG: That's a very important point.
The weather plays a very important role in this. The
20
clay is very susceptible to weather conditions, and you
21
don't want to lay it down when it is wet.
22 MR. HAHES: This clay cover, that is not
23
coming from this area, or is it going to be brought in?
24 MR. YOUNG: We will try to get as much
25
clay from the area as possible. We will look on the site
-------
itself first and get as much clay from the site as
2
possible. The next thing is to look at areas close
3
to the site so there is a possibility that there will
4
be dump trucks coming in on Kelly Cemetery Road or
Chestnut Grove Road for the clay, but we are going
6 •
to try to get as much clay as we can from the site ',
7 itself.
o
We don't want to disrupt the
Q
neighborhood with trucks coming in and out, and it's
more costly to do so anyway, so we are looking as
much as possible on-site and get as much material as
12
we can from right there.
13
Any other questions? Well, we are going
14
to be around. I am going to be here until everybody
leaves, so if you want to continue talking about it,
*i fi
I will be here to answer any questions that you may
. have, and you are welcome to come up here and look at
1R
the samples I have of the geomembrane, and also look
19
at the aerial photograph, and please, if you haven't
20
gotten a copy of the proposed Fact Sheet on the table
21
there, I would recommend looking at that and also
pp
making a trip out to look at the Administrative Record.
23
I want to thank everybody for being
here tonight and I will be around to answer any questions
pc
you have. Thank you.
-------
REPORTER'S CERTIFICATE
2
STATE OF KENTUCKY)
3 ^ ss
STATE AT LARGE )
4
I, James A. Joplin', Registered Professional
Reporter and Notary Public, State at Large for the
c
Commonwealth of Kentucky, do hereby certify that-1
reported the foregoing proceedings at the time and
o
place set forth in the caption hereof, and thereafter
g
I reduced the same to typewritten form, and the foregoing
45 pages, including this page, constitute a true, correct
and complete transcript of said proceedings.
12
This the 14th day of August, 1994.
13 '
14
18
19
20
21
22
23
24
25
James A. Joplin
Registered Professional Reporter
Notary Public, State at Large
My Commission Expires: 8/9/97.
-45-
------- |