PB96-964012
EPA/ROD/R04-96/269
August 1996
EPA Superfund
Record of Decision:
Tri-City Disposal Company
(Operable Unit 2), Brooks, KY
3/29/1996
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Tri-City Industrial Disposal Site
Operable Unit Two
Brooks, Bullitt County, Kentucky
RECORD OF DECISION
U.S. ENVIRONMENTAL PROTECTION AGENCY
Region IV
Atlanta, Georgia
March 1996
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\
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Tri-City Industrial Disposal
Highway 1526, Brooks Hill Road
Bullitt County, Kentucky
STATEMENT OF BASIS AND PURPOSE
This document presents the decision made by the U. S. Environmental Protection
Agency (USEPA) for the second phase of remedial action (Operable Unit #2) at the Tri-City
Industrial Disposal Site. The decision was made in accordance 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),
based on the information contained in the Operable Unit #2 Administrative Record for the
site.
The Commonwealth of Kentucky Department of Environmental Protection (KDEP) is
aware that USEPA has concluded its work on this Operable Unit. KDEP has not concurred
with USEPA's decision at this time because it is pursuing an independent additional study of
the site.
DESCRIPTION OF THE REMEDY
Based on the results of additional sampling at Tri-City, monitoring reports, and risk
evaluation, no further remedial action is necessary at the site to ensure protection of human
health and the environment. This decision is the final remedial action for the site.
Although EPA has determined that no additional Superfund action is warranted for the
second operable unit, treatment and monitoring of contaminated groundwater (OU1) will
continue at the site as necessary. The Record of Decision for the first operable unit outlines
the groundwater remedial activities.
DECLARATION STATEMENT
Previous response actions at this site, including emergency removal and treatment of
contaminated groundwater, appear to have eliminated the need for additional remedial action.
The current decision for no further action is not expected to result in hazardous substances
remaining on-site above health-based levels. Therefore, the five-year review requirement
will not apply to this operable unit. EPA has completed its response action at this site and
:lares that the site now qualifies for Construction Completion status.
Richard D. Green, Acting Director Date
Waste Management Division
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TABLE OF CONTENTS
SECTION PAGE
1. 0 SITE LOCATION AND DESCRIPTION 1
1.1 Site Location 1
1.2 Site Description 1
2 . 0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 4
2 .1 Site History 4
2.2 Initial Investigations 5
2.3 Removal Actions 6
2.4 Remedial Investigation/Feasibility Study (OUD...10
2.5 Record of Decision (OU1) J...... 12
2.6 Remedial Design/Remedial Action (OU1) 13
3 . 0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 14
4.0 SCOPE AND ROLE OF RESPONSE ACTION 15
5 . 0 SUMMARY OF SITE CHARACTERISTICS 15
5 .1 Site Geology and Hydrogeology 15
5.2 Nature and Extent of Contamination 17
5.2.1 Surface Soils 18
5.2.2 Subsurface Soils 18
5.2.3 Surface Water 19
5.2.4 Sediment. i 19
5.2.5 Air 20
6.0 SUMMARY OF SITE RISKS 20
7. 0 CONCLUSION 22
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LIST OF FIGURES
FIGURE
1 Site Location Map 2
2 Site Layout 3
3 Geophysical Investigation Area 7
4 Electromagnetic Anomalies 8
5 Magnetic Anomalies 9
6 Test Pits and Trenches 11
7 Generalized Geological Cross Section 16
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RECORD OF DECISION
TRI-CITY INDUSTRIAL DISPOSAL
1.0 SITE LOCATION AND DESCRIPTION
1.1 Site Location
The Tri-City Industrial Disposal Superfund Site is located
in the community of Brooks in Bullitt County, approximately 15
miles south of Louisville, Kentucky. See Figure 1. The site
consists of approximately 349 acres and it is located on the
south side of State Highway 1526 (also known as Brooks Hill
Road), approximately four miles west of U.S. Interstate 65 (see
Figure 2). The geographical coordinates for the site are
38°2'50.9n north latitude and 85°46'06.1" west longitude.
1.2 Site Description
The site is located in the Blue Grass Region of the Interior
Low Plateaus Physiographic Province. The Blue Grass Region lies
'within the Ohio River drainage basin and it is generally an area
of rolling uplands which range in elevation from less than 800
feet above mean sea level (msl) in the northwest to about 1000
feet in the southeast. The site is within the Knobs Regional
Subdivision of the Blue Grass Region.
The climate in the Blue Grass Region is moderate with a mean
annual temperature of 67°F. The average annual precipitation in
Bullitt County is 55 inches and the mean annual lake evaporation
is 35 inches, resulting in a net precipitation of 20 inches.
Approximately 300 people live within one mile radius of the
site. The site and surrounding area are rural. The land use is
predominantly agricultural and residential. Several residences
exist on and adjacent to former disposal areas at the site. A
portion of the site is used for agricultural purposes, mainly as
pastures and small gardens. Other areas of the site are covered
with grass and trees. Notable surface features on-site include a
shallow trench partially filled with water at the southern end,
and two shallow ponds which are used to water livestock.
Situated on a broad ridge known as the Beghtol Ridge, the
site slopes moderately to the south. The elevations across the
site range from 800 feet to 840 feet above msl. The southern
boundary and portions of the eastern and western boundaries drop
into steep, vegetated ravines with bottom elevations ranging from
600 feet to 800 feet above msl.
The original soils of the site are classified as Crider Silt
Loams which are formed on long, steep hillsides and broad, gently
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9^n^s'^r^^ A '""
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Tri-City Industrial
Disposal Site
Study Area
EL 800 Ft.
EL 600 Ft
EL 600 Fl. V
BEGHTOL
RESIDENCE
BROOKS HILL ROAD (Hwy. 1526}
LEGEND
RESIDENCE
SPRING
X ELEVATION ABOVE MSI.
FORMER TRI-CITY
DISPOSAL AREA
0 830 Ft.
SCALE IN FEET
FIGURE 2. Site Layout
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RECORD OF DECISION
TRI-CITY INDUSTRIAL DISPOSAL
sloping to moderately steep ridge tops and shoulder slopes above
deep valleys. Crider soils are described as deep and well
drained with upper loamy zones and subsoils containing a high
proportion of clay.
The site is drained to the west, south, and east by Brushy
Fork Creek which is a perennial stream. The springs and seeps at
the site represent sources of groundwater which contribute to
surface water runoff to Brushy Fork Creek. The source for the
creek is a small spring approximately 3,000 feet southeast of the
site at an elevation of approximately 750 feet above msl. Brushy
Fork Creek flows westward for approximately two miles where it
joins Knob Creek and becomes part of the Ohio River drainage
network.
Brushy Fork Creek is used seasonally for recreational
purposes and for irrigation of nearby farms. The creek appears
to be a healthy stream supporting diverse communities of
macroihvertebrates and small fish. Adequate feeding habitat for
endangered species of bats and the bald eagle were determined to
be absent within Brushy Fork Creek and the tributaries which are
affected by the site.
The site is not located in a 100-year floodplain. According
to the U.S. Fish and Wildlife Service (FWS) , the Brushy Fork
Creek is not a habitat for endangered species and the site is not
on a wetland, nor does it affect a wetland.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1 Site History
.The site was an industrial waste landfill known to have been
operated by Tri-City Industrial Services, Inc. from late 1964 to
late 1967. The majority of the material reportedly disposed of
at the Site was from several Louisville, Kentucky industries.
The bulk of the waste consisted of scrap lumber and fiberglass
insulation materials. The remaining waste consisted of drummed
liquid wastes and bulk liquids that were poured onto the ground.
In 1968, State officials reported that highly volatile liquid
wastes resembling paint thinners were disposed of on-site.
Records indicate that an attendant was present at the site
at least during a portion of the time that the landfill was
operated. The duties of the site attendant included pushing each
day's collection of refuse over the working face of the landfill
into the surrounding ravines. In at least one instance, the
attendant was instructed to pour liquid waste material directly
onto the ground to help alleviate fire and explosion hazards.
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RECORD OP DECISION
TRI-CITY INDUSTRIAL DISPOSAL
The site was a source of local citizen complaints and
concerns to state and county government officials on numerous
occasions during the disposal operations. In 1965, residents
near the site first complained to local officials regarding the
unkempt condition of the landfill, explosions, fires, and smoke
which was said to irritate eyes. The residents also reported
breathing difficulties and frequent offensive odor.
Additionally, deposition of ash and fire debris on neighboring
property led to a civil lawsuit for creating a public nuisance.
The Bullitt County Health Department, County Attorney, and
the Commonwealth of Kentucky Department of Fish and Wildlife
Resources (then the Division of Fisheries) along with the
Department of Health (then the Division of Environmental Health)
investigated these complaints. An indictment, served to Tri-City
Industrial Services, Inc. and others in November 1967, resulted
in the arrest of the company's president, Mr. Harry Kletter, on
the nuisance charge. After Mr. Kletter's arrest, a settlement
was negotiated whereby the charges would be dropped if the
company agreed to stop disposing of and burning waste at the
site. At about the same time as the arrest, a fire erupted on
the site that burned for two years. Tri-City Industrial
Services, Inc. reportedly ceased all waste disposal activity
shortly after the fire began.
2.2 Initial Investigations
EPA's involvement with the site commenced in 1985, following
notification by the Kentucky Natural Resources and Environmental
Protection Cabinet. The Cabinet conducted a Preliminary
Assessment (PA) of the site in September 1985, and recommended a
high priority for inspection. The Cabinet performed a Site
Investigation (SI) in April 1987, to determine the site's
eligibility for inclusion on EPA's National Priority List (NPL).
The investigation included identification of several private,
potable water supplies near the site and multi-media sampling
(waste, soil, and groundwater). Several hazardous substances
were detected in site soils and wastes, including PCBs, phenols,
heavy metals, and various organic compounds. One residential
spring, utilized by the Klapper family as a source of potable
water and located several hundred yards west of the site, was
sampled and found to contain levels of tetrachloroethene (also
known as perchloroethylene, or PCE) above Maximum Contaminant
Levels (MCLs) .
Following the Cabinet's release of the sampling results, EPA
conducted additional sampling and provided an alternate water
supply to the two Klapper residences in May 1988. EPA also
discovered that another spring closer to the Site was being used
as a source of potable water by Mr. and Mrs. William D. Cox, Sr.
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RECORD OF DECISION
TRI-CITY INDUSTRIAL DISPOSAL
Bottled water was supplied to the Cox, Sr. residence until
sampling results were obtained. Sampling of the Cox Spring was
included in a May 1988, survey of potable water sources conducted
by EPA within a radius of approximately one-half mile of the
site. The sampling confirmed again the presence of PCE in the
Klapper Spring, and elevated levels of PCE and trichloroethene
(TCE) were found in the Cox Spring. This survey identified the
two Klapper residences and the Cox, Sr. residence as the only
affected households within the investigated area.
The findings of the potable water survey prompted EPA to
conduct an additional study in June 1988. The emphasis of the
study was to assess the site's potential impact on area residents
via ingestion of grouhdwater, inhalation of soil dust, and direct
contact. Sample locations included sensitive areas such as
yards, gardens, and potable water supplies from where five
composite surface soil samples, three waste samples, and four
groundwater samples were collected.
The site was proposed for inclusion on the NPL on June 24,
1988, (53 FR 23988) based primarily on the potential hazard from
contaminated groundwater. The site became final on the NPL on
March 31, 1989, {54 FR 13302) with a Hazard Ranking Score (HRS)
of 33.82.
2.3 Removal Actions
The site received further attention in June 1988, when EPA
responded to a telephone call from the Cox, Sr. family regarding
a "black ooze" emanating from their side yard. EPA's Technical
Assistance Team (TAT) contractor, Roy F. Weston, collected two
samples from the reported stained area and also from a solid
material resembling paint waste. The samples indicated elevated
levels of xylene, toluene, ethylbenzene, and lead.
NUS Corporation, EPA's Field Investigation Team (FIT)
contractor, conducted a geophysical survey and field analytical
screening procedures (FASP) at the site in August 1988, to
delineate waste disposal areas and provide additional subsurface
information. Magnetometry, resistivity, and electromagnetic
terrain conductivity surveys were performed during the
geophysical investigation. The study area is shown in Figure 3.
The results of the electromagnetic and magnetic surveys are shown
in Figures 4 and 5, respectively.
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HO08IER
RESIDENCE
COX 8R.
RC8IOENCE
0 100 It.
SCALE
GEOPHYSICAL INVESTIGATION AREA
TRI-CITY INDUSTRIAL DISPOSAL
BROOKS, BULLITT COUNTY, KENTUCKY
FIGURES
PBNUS
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HOO8IER
RESIDENCE
COX 8R.
RE8IOKNCE
SPRING? 0
0
LEGEND
---4 ELECTROUAQNETIC ANOMALIES
ELECTROMAGNETIC ANOMALIES
TRI-CITY INDUSTRIAL DISPOSAL
BROOKS, BULLITT COUNTY, KENTUCKY
FIGURE A - ....
MUS
CXDRPCFUXTXDM
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SPRING * 0
o
LEGEND
MAGNETIC ANOMALIES
HOOSICR
RESIDENCE
FIELD
PONO
Q 100 ft.
8CALI
MAGNETIC ANOMALIES
RI-CITY INDUSTRIAL DISPOSAL
(ROOKS, BULLITT COUNTY, KENTUCKY
FIGURE 5 ....
IMUS
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RECORD OF DECISION
TRI-CITY INDUSTRIAL DISPOSAL
The results of the FASP were found to substantiate the
geophysical findings by detecting VOCs in significant concentrations
close to the anomalies. Based on the correlation between the two
surveys, waste disposal at the site was determined to be concentrated
at the southern half of the landfill.
Based on the results of the sampling conducted by EPA's TAT
contractor and the proximity of the contamination to the Cox, Sr.
residence, EPA conducted an Emergency Removal Action in August and
September 1988, to excavate and remove approximately 165 drums
containing chemicals, many crushed and empty drums, metal containers
of various sizes, auto parts, 400 gallons of free liquids, and over
800 cubic yards of suspected contaminated soil. The resulting trench
in the side yard was approximately ten feet deep, twelve to fifteen
feet wide, and thirty feet long.
Following this removal action, numerous test trenches were
employed to identify additional waste disposal areas. The results of
previous geophysical surveys were used to aid in determining the
trenching locations.. As shown in Figure 6, the trenches were
excavated in the Cox, Sr. side yard, throughout a pasture east of the
.Cox, Sr. residence, and on the Hoosier's property of more than five
acres in size. A number of empty drums and drums containing solids
were excavated and staged, but no additional liquids were located. In
addition, the operators encountered fiberglass insulation materials,
wires and ashes, probably from the historical fires. The test
excavation was discontinued in September 1988, and the trenches were
backfilled and graded.
2.4 Remedial Investigation/Feasibility Study (OU1)
In November 1988, and May 1989, EPA invited the parties
responsible for the wastes at the site (PRPs) to conduct a Remedial
Investigation (RI) in order to determine the nature and extent of
contamination. The PRPs elected not to undertake the studies.
Therefore, EPA began the RI in July 1989. Since the geophysical
survey and FASP indicated that the disposal of waste was concentrated
in the southern half of the landfill, the field activities of the RI
were concentrated in that area.
The RI activities included topographic mapping, geological
assessment, surface water and sediment sampling, spring sampling,
surface and subsurface soil sampling, ecological studies, geophysical
evaluation, groundwater studies, aquifer tests, and air monitoring.
All work was conducted by EPA's contractor, Ebasco Services, Inc.
During the RI, six groundwater monitoring wells were installed
and sampled. Installation of seven other wells was attempted. The
wells were not completed because of insufficient groundwater.
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Cox Property
Pre-exlsten
Depression
Drum Staging
Cell
Command Post
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oooooooooo
Primary Drum
Excavation Trench
Not To. Scale
WESTON MAJOR PROGRAMS Region IV TAT
ACTIVITY PFSCRIPTIDN- Size Edited Site Sketch With
Approximated Test Pits and Trenches FIGURE 6
SITF.- Tri-Gity Industrial Disposal Site
TDD NQ.r 04-8810-20 PCS# 2020
HATF-
1989
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RECORD OF DECISION
TRI-CITY INDUSTRIAL DISPOSAL
The RI activities included topographic mapping, geological
assessment, surface water and sediment sampling, spring sampling,
surface and subsurface soil sampling, ecological studies,
geophysical evaluation, groundwater studies, aquifer tests, and
air monitoring. All work was conducted by EPA's contractor,
Ebasco Services, Inc.
During the RI, six groundwater monitoring wells were
installed and sampled. Installation of seven other wells was
attempted. . The wells were not completed because of insufficient
groundwater. Initially, four springs were sampled, and six
surface water samples were taken from Brushy Fork Creek and the
two tributaries that discharge to the creek. Twelve sediment
samples were collected in the areas of the springs and Brushy
Fork Creek. Twenty surface soil samples and twenty-five
subsurface soil samples were collected. In addition, sixteen air
samples were collected at three locations that were selected
based on prevailing wind directions and the locations of
residents. The final stage of the RI field activities included
additional sampling of one monitoring well and several springs,
including the Cox and the Klapper springs in December 1990, to
verify previous sampling results.
Following the RI, the Feasibility Study (FS) was conducted
to evaluate remedial alternatives for addressing the site's
contamination problems. The study was completed in April 1991.
Reports of the RI and FS were published in May 1991.
2.5 RECORD OF DECISION (OU1)
Based on the results of the RI and FS studies, EPA selected
a preferred cleanup plan for the site after consultation with
Kentucky officials and the public. The cleanup plan which was
detailed in the Record of Decision (ROD) issued in August 1991,
included the following. (1) treatment of contaminated
groundwater, (2) continued provision of drinkable water to
affected residents, (3) temporary restriction of groundwater
usage, (4) confirmatory sampling of site soils, sediment and air
to ensure that all possible areas of contamination are
investigated, and (5) long-term monitoring of groundwater,
sediment, and ecology to identify additional site-related
impacts. The ROD further specified that the results of the
Confirmatory Sampling would be evaluated by USEPA and designated
OU2 to address the findings of the evaluation.
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RECORD OF DECISION
TRI-CITY INDUSTRIAL DISPOSAL
2.6 REMEDIAL DESIGN/REMEDIAL ACTION (OU1)
In March 1992, three of the PRPs, Ford Motor Company, Waste
Management of Kentucky, inc., and Dow Corning Corporation agreed
to implement and fund the Remedial Design and Remedial Action
(RD/RA) which OU1 ROD required. Under a contract with the PRPs,
RUST Environmental and Infrastructure performed the RD/RA
activities. USEPA and Kentucky officials reviewed and/or
inspected the various phases of RUST'S work before approval.
In November 1992, Rust began the RD/RA field activities at
the site. Long-term monitoring of groundwater, surface water,
sediment and ecology for site-related impacts was initiated.
Performance Standards Field Sampling for baseline data and for
managing groundwater treatment at the site was conducted. In
addition, Confirmatory Sampling required by the ROD for OU1 was
accomplished.
The results of the sampling events formed the basis for the
RD which included a comprehensive equipment specification,
construction layout and management plan, quality control
provisions and other components of the groundwater treatment
system for cleaning contaminated springs at the site. Details of
the RD are contained in two reports, (Final Remedial Design
Report and Final Remedial Action Work Plan). These were made
available to the public at the repositories for the site in 1993.
Construction and installation of the RA facilities were
completed in June 1994, including two separate systems of flow
lines, temporary holding tanks, pumps and granular activated
carbon adsorption beds. The two affected springs (Cox and
'Unnamed Spring #1) were remediated concurrently by pumping
contaminated water from each spring through the appropriate
carbon adsorption system. The springs were sampled regularly to
monitor progress of the remediation process. USEPA certified
that the groundwater cleanup was complete in May 1995, after
several analytical results consistently indicated that the
cleanup goals established for the compounds of concern were met.
USEPA initiated supplying potable water to affected
residents in May 1988, to prevent the use of the contaminated
springs. Although, the springs have been remediated, the PRPs
have continued to supply drinkable water where necessary and are
in the process of connecting affected homes to the public water
system. Usage of the springs remains restricted by institutional
control.
Long-term monitoring activities as well as Operation and
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RECORD OF DECISION
TRI-CI-TY INDUSTRIAL DISPOSAL
Maintenance of the site are in progress at this time. Results of
laboratory analyses and progress reports prepared monthly by the
PRPs are reviewed regularly by USEPA. Current evaluations
indicate that conditions at the site are stable and are
protective of human health and the environment.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
A Community Relations Plan (CRP) for the Tri-City Site was
finalized in May 1989. This document included a list of contacts
and interested parties throughout government and the local
community. The CRP also established how USEPA would ensure
timely dissemination of pertinent information to the public.
A fact sheet describing the site and the nature of the RI/FS
process was distributed to the public in May 1989. USEPA held an
availability session in Shepherdsville, Kentucky on June 1, 1989,
to discuss site-related problems, the process of site evaluation
and the procedures for choosing the necessary clean-up measures.
On April 19, 1991, a Proposed Plan Fact Sheet (OU1) was
published to announce EPA's preferred alternative for site
remediation in two phases (two operable units). The document
elaborately discussed various cleanup options for OU1 and
solicited comments from the public on USEPA's preferred
alternative. The comment period began on May 2, 1991, and ended
on June 1, 1991. During the period, a Public Meeting was held
locally to discuss the Proposed Plan. All comments received by
USEPA during the period were addressed in the Responsiveness
Summary section of the ROD for OU1.
The Proposed Plan Fact Sheet for OU2 was distributed on
January 25, 1996. The Fact Sheet announced that no further
Superfund Remedial Action was warranted at the site based on the
results of the Confirmatory Sampling conducted under OU1 and
because previous response actions at the site have been
successful. Comments on the proposal were requested to be
submitted to USEPA by February 29, 1996. No comments were
received on the proposal.
All pertinent information used by USEPA to select CERCLA
response actions for both Operable Units has been included in the
Administrative Records at the information repositories. The
repositories, located in the Ridgeway Memorial Library,
Shepherdsville, Kentucky and EPA's Records Center, Atlanta,
Georgia were established in 1989.
In summary, USEPA provided ample opportunity for community
involvement throughout the duration of the project. With respect
to interpreting and understanding the technical aspects of the
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RECORD OF DECISION
TRI-CITY INDUSTRIAL DISPOSAL
project, availability of the Technical Assistance Grant was
announced to the public at the early stage of the project.
4.0 SCOPE AND ROLE OF RESPONSE ACTION
By the time OU1 ROD was finalized for this site, an
extensive contaminant source characterization had been
accomplished by conducting numerous sampling and laboratory
analyses. Contaminant source areas were well defined including
locations where contaminated soils, groundwater or other media
could release hazardous materials through leaching or other
mechanism into the environment. As a result of the efforts,
several containerized wastes and liquids were removed from the
surface of the site. In addition, contaminated soil and other
buried hazardous materials were excavated and properly disposed
of. At that point, all that remained was to verify that all
contaminant source locations had been investigated. Because
local residents used springs predominantly for potable water, it
was decided to initiate immediate cleanup of the contaminated
groundwater. Management of any unacceptable health and/or
environmental risks, not associated with contaminated springs,
found by verifying the results of previous investigations and
source removals was deferred to OU2. Thus, the scope and role of
OU2 response action were defined specifically as the confirmatory
sampling of site soils, sediment, and ambient air, and their
cleanup, if needed.
5.0 SUMMARY OF SITE CHARACTERISTICS
5.1 Site Geology and Hydrocreology
The local geology at the Tri-City site is dominated by
sedimentary rocks of Mississippian age. These formations include
(from top to bottom), the Salem Limestone, the Harrodsburg
Limestone, and members of the Borden Formation (the Muldraugh,
the Holtsclaw Siltstone, and the Nancy) . The stratigraphy of the
area is shown in Figure 7.
The Salem formation, consisting of limestone and shale,
forms the caprock on most of the hills in the Knob Region, west
of Sun Rise Ridge. Formation thickness in the vicinity of the
site ranges from 18 to 25 feet. The contact of the Salem
Limestone with the underlying Harrodsburg Limestone is generally
identifiable by the weathered, silicified bed of granular
limestone with fossil fragments.
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west
850ft-
800ft.-
750ft.
700ft.
TRI-CITY SITE AREA
east
850ft.
r- 800ft.
750ft.
700ft.
BORDFN FORMATION
BORDEN FORMATION
LEGEND
Qal QUATERNARY ALLUVIUM
MS SALEM LIMESTONE
Mhb HARRODSBURGH LIMESTONE
Mbm MULDRAUGH MEMBER
HQLTSCLAW MEMBER
EBASCO SERVICES WGORPOfUTEO
GENERALIZED GEOLOGICAL CROSS SECTION
TRI-CITY INDUSTRIAL DISPOSAL SITE
BULUTT COUNTY, KENTUCKY
FIGURE 7
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RECORD OF DECISION
TRI-CITY INDUSTRIAL DISPOSAL
The Harrodsburg forms the caprock on most of the ridges and
consists of fragmented limestone. The Harrodsburg is underlain
unconformably by Muldraugh, a member of the Borden formation.
The surficial aquifer, composed of the Salem Limestone and
the Harrodsburg Limestone, is unconfined with thickness of
between 10 and 50 feet. The groundwater moves along preferential
flow pathways' within the irregular contact between the partially
decomposed and completely decomposed overburden, thin fractures,
and the solution channels along the bedding planes. Springs and
seeps sporadically occur where the geologic units that comprise
the aquifer are exposed.
The various members of the Borden formation consist of
varying proportion of dolomite, siltstone, limestone and shale.
Groundwater flows through interconnected fractures, bedding
planes, and dissolution pathways in the formation.
The formations at Tri-City are generally productive.
However, because productivity of wells in the aquifers is
sporadic and unpredictable, springs are used as water supply
sources more frequently than water wells in the area.
Recharge to the aquifers occurs in the area, principally by
infiltration of precipitation into the overburden or by
infiltration of runoff directly into the aquifers. Most of the
infiltration appears to occur in the northern part of the site
(near the Cox, Jr. and Hoosier homes) where the overburden is
thin due to past earthmoving operations. Movement of groundwater
occurs predominantly down-dip to the south-southwest, primarily
along bedding planes. The groundwater appears to discharge
through springs and seeps which are located mostly on the south
and west sides of the site.
Hydraulic communication between the different aquifers at
the site is appreciable based on hydrogeologic data. Also, the
overburden and the Salem /Harrosdsburg aquifer appear to
communicate effectively based on analyses of spring samples.
5.2 Nature and Extent of Contamination
The primary objective of this Operable Unit is to define and
address additional cleanup requirements at Tri-City following the
removal and other response actions already conducted at the site.
Groundwater issues were assigned exclusively to OU1. Therefore,
determining the nature and extent of contamination for OU2
concentrated on the following:
1. Sampling of soils and surface water to assess the
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RECORD OF DECISION
TRI-CITY INDUSTRIAL DISPOSAL
effectiveness of the emergency removal performed in 1988
near Cox, Sr. residence. The primary, contaminants of
concern were metals, perchloroethylene (PCE) , toluene, ethyl
benzene, xylene, and polychlorinated biphenyls (PCBs).
These compounds were found in drummed wastes during removal
actions.
2. Sampling of the disturbed area in the northern portion of
the site to investigate possible contamination from drum
disposal.
3. Sampling of surface soils along the eastern edge of former
disposal area where polycyclic aromatic hydrocarbons (PAHs)
and one species' of PCB (Ardor 1254) were found during OU1
RI.
4. Sampling of sediment in the tributary of the Brushy Fork
creek where one previous sample indicated elevated levels of
chromium and lead concentration.
5. Air sampling along the slope of the Cox Lobe to identify the
source of one instance of detected PCE during the RI for
OU1.
The sampling events described below were performed in
November 1992, by the PRPs as specified by USEPA. The results
were presented in the "Sampling and Analysis Summary Report -
November 1992 Quarterly Sampling Events, Operable^ Unit No.l
Remedial Design Volumes 1 - 3," of February 1993. Copies are in
the Administrative Record for this ROD.
5.2.1 Surface Soils
Ten samples of surface soil were collected along the eastern
edge of the former disposal area to establish the extent of any
residual PAH or PCB. PAHs were not detected in the samples. PCB
Aroclor 1254 was found at below detection limit in two samples
and at the concentration of 66 ppb in one sample.
5.2.2 Subsurface Soils
. Thirty-two subsurface samples were analyzed, including
duplicates, from eleven borings at the site. Six of the borings
were drilled in the drum removal area, adjacent to the Cox, Sr.
residence. The other five borings were drilled in the northern
portion of the site where disposal or storage of drums was
suspected. The samples represented soils from 7 to 20 feet below
the ground surface. The following is a summary of the analytical
results for the various compounds detected in the removal area
and the northern portion of the site.
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REMOVAL AREA (21 SAMPLES ANALYZED)
COMPOUND AVERAGE # OF SAMPLES
CONC. PPB AFFECTED
1,2 Dichloroethene (DCE) 537 6
2-Butanone 418 4
4-Methly-2-Pentanone 880 2
Acetone 1400 . 15
Ethylbenzone 2400 8
Styrene 510 1
Toluene 6100 7
Trichloroethene (TCE) 740 1
Xylenes 149000 9
2-Methlypthalene 910 1
Bis(2-Ethlyhexyl)phthalate 470 2
Nephtalene 1000 1
Aroclor 1254 150 3
Aroclor 1260 470 1
NORTHERN AREA (11 SAMPLES ANALYZED)
COMPOUND AV. CONC., PPB SAMPLES AFFECTED^
Acetone 52 8
Tetrachloroethane. (PCE) 60 2
Toluene 21 2
5.2.3 Surface Water
One surface water sample was collected from each of the
three ponds near the removal action and the northern portion of
the site. Laboratory analysis of the samples did not reveal
presence of landfill contaminants.
5.2.4 Sediment
Nine sediment samples from the Brushy Fork Creek were
analyzed for contaminants of concern. Acetone was detected at a
concentration of 140 ppb in one sample. Two samples contained
chromium at the concentrations of 85 ppb and 89.9 ppb
respectively. Lead was found in four samples at concentrations
of 38, 36, 280 and 67.3 ppb respectively. In one sample, nickel
was detected at a concentration of 32 ppb.
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5.2.5 Air
Five air samples were taken along the slope of the Cox Lobe
to confirm the presence and source of PCE identified during the
RI for OU1. PCE was not detected in any of the current samples.
6.0 SUMMARY OF SITE RISKS
USEPA is directed by CERCLA to protect human health and the
environment from current and future exposure to hazardous
substances.at Superfund sites. At Tri-City, EPA has taken
several steps to eliminate unacceptable risk to human health and
the environment. Previous response actions included:
1. Removal of contaminated soil, containerized chemicals stored
at the site and buried wastes to eliminate further release
of hazardous materials to the environment.
2. Provision of potable water to affected residents and
imposition of restriction on usage of spring water.
3. Remediation of polluted springs per OU1 ROD.
The present operable unit was planned to mitigate human
health and environmental risk from exposure to hazardous
materials possibly remaining at the site following the above
remedial activities. Therefore, USEPA Region IV Risk Assessment
Department evaluated the confirmatory sampling results and the
Baseline Risk assessment for OU1. In addition, the Region
studied reports on previous response actions and the on-going
site performance monitoring.
A review of the confirmatory sampling results (Section 5)
'indicates that landfill related contaminants were measured at
elevated concentrations in various relatively small percentages
of the surface soil, subsurface soil and sediment samples. The
interpretations of the results follow.
Surface Soil
The most notable chemical found in the surface soil at the
site during previous sampling efforts included three carcinogenic
and one non-carcinogenic PAHs, and Aroclor 1260 which is a PCB.
These were found in one of twenty samples collected from the
southern portion of the Cox Lobe. These contaminants were below
their respective detection limits in the other nineteen samples.
Risks were calculated based on the one positive sample during the
Baseline Risk Assessment. The BRA examined two potential future
pathways, ingestion of garden vegetables and ingestion of beef.
Maximum literature values were assumed in modeling the risks
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associated with these pathways. The risk associated with
ingestion of beef was calculated at approximately 1.6E-4 with a
Reasonable Maximum Exposure (RME) of 43 ppb. Actual
concentration value of 490 ppb was measured for the sample.
Because this risk slightly exceeds USEPA's acceptable range, the
confirmatory sampling of surface soil was conducted. PAHs were
not detected during the confirmatory sampling. Aroclor 1254 was
below detection limit in two of ten samples and was detected at
66 ppb in one sample. All three samples were from the vicinity
of the previous positive sample within the Cox Lobe. Therefore,
presence .of this compound at the site, most likely, was isolated
and has been minimized effectively by previous removal action.
The concentrations of PCB detected are below levels that would
pose unacceptable human health risk.
Subsurface Soil
As in the previous cases involving fifty subsurface soil
samples, the current thirty-two samples exhibited presence of
volatile organic compounds (VOCs) predominantly. These
contaminants were detected as before, mainly in samples from the
former emergency removal area. The samples containing the
compounds and the concentrations detected did not suggest a wide
spread case of contamination or levels that pose a risk to human
health or the environment. Similarly, the levels of semi-
volatiles and PCBs detected are deemed inconsequential as threats
to human health or the environment.
The major concern for the presence of these compounds in the
subsurface soils is their potential effect on groundwater.
Therefore, fate and transport processes for the compounds were
reviewed as well as groundwater monitoring reports.
The VOCs constituting majority of the chemicals in the
subsurface are soluble and leachable into water. As an evidence,
several of these compounds were detected at unacceptable levels
in samples of spring water during previous investigations. The
affected springs were remediated and are being monitored monthly.
Reports of approximately one year of monitoring have indicated
that levels of these compounds in the groundwater are no longer a
threat to human health or the environment. Therefore, the
presence of VOCs in the subsurface soil at the site does not
constitute a significant concern at this time. The current
condition indicates that these compounds are no longer present in
the soils in soluble and/or leachable quantity, apparently due to
the success and effectiveness of emergency removal actions at the
site.
Semi-volatiles and PCBs detected in the soils are unlikely
to dissolve or leach into the groundwater due to their relatively
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high sorption properties. Therefore, they pose limited
contamination threat to the groundwater.
Sediment
An ecological evaluation of the sediment contamination data
has concluded that despite exceedance of Sediment Screening
Values, no sediment cleanup is warranted at the site. The
evaluation has observed that the aquatic communities present in
the area streams (Cox Spring Run and Brushy Fork Creek) do not
reflect a significant impairment from site related toxicity. The
Cox Spring Run is small. . Therefore, it does not possess an
appreciable capacity to support aquatic communities. Due to the
intermittent flow characteristic of the Brushy Fork Creek, it
will continue to provide a limited aquatic habitat. Removal of
sediments from these streams would cause greater impairment than
presently exists.
As discussed previously, contaminants in site soils are
below risk levels. Therefore, eroded and runoff materials from
the site which may become part of the sediment are not expected
to impact the streams or aquatic biotas adversely.
7.0 CONCLUSION
For the purpose of OU2, no remedial action will be taken at
Tri-City, because the site does not pose an unacceptable risk to
human health or the environment. Previous emergency response
activities at the site were successful and the removal actions
accomplished have reduced sources of contaminants to levels
within acceptable risk. If the on-going monitoring events at the
site, additional information and/or new data reveal an
unacceptable risk, EPA may initiate further CERCLA clean-up
actions without re-ranking the site.
At this time, the Commonwealth of Kentucky is pursuing
additional field sampling and evaluation. As expected, results
of the first round of Kentucky's re-sampling efforts recently
indicated that the target compound, Dioxin, was below USEPA
action level. The Region will continue to monitor Kentucky's
results.
This document finalizes USEPA's response action at the site
other than evaluating reports of the monitoring activities being
conducted under OU1. Therefore, the site is recommended for
Construction Complete classification.
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