United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R09-88/022
September 1988
SEPA
Superfund
Record of Decision
Ordot Landfill, GU
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REPORT DOCUMENTATION i 1. «PO«T NO. 2.
PAGE i EPA/ROD/R09-88/022
4. Title end Subtitle
SUPERFUND RECORD OF DECISION
Ordot Landfill, GU
First Remedial Action - Final
7. Author(s)
9. Performing Organization Nam* and Address
12. Sponsoring Organization Nam* and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
IS. Supplementary Notes
16. Abstract (Limit: 200 words)
The Ordot Landfill site is located on the island of Guam. The '.
volcanic upland region, where site runoff flows directly into the
River. Water wells have not been drilled in the volcanics near tY
3. Recipient's Accession No.
5. Report Date
09/28/88
6.
8. Performing Organization Rept. No.
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
»
andfill is in a ''
adjacent Lonfit ;
le landfill. There is
concern, however, that a suspected fault near the landfill may provide a hydrologic
connection between the contaminants at Ordot Landfill and Guam's major drinking water
acquifer located in the northern limestone province of Guam. The landfill is presently
managed and operated by the Guam Department of Public Works, and has been receiving
uncontrolled municipal wastes since before World War II. Because it is the only major
public waste disposal site on Guam it has received some hazardous waste during its
history, including spent industrial and commercial chemicals, PCB-contaminated oils from
transformers, and perhaps munitions. The facility uses almost the entire 47-acre waste
disposal area, with only approximately 4 to 7 acres of the oldest portion of the
landfill not currently in use. The current depth of disposed wastes is approximately
100 feet. In March 1986, EPA found Ordot Landfill in violation of the Clean Water Act
for discharging landfill leachate to the Lonfit River without an NPDES permit. The 1987
initial site characterization study concluded that surface flow through the landfill is
the source of leachate, the site is hydrologically isolated from the island's sole
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Ordot Landfill, GU
First Remedial Action - Final
Contaminated Media: gw, sw
Key Contaminants: iron, manganese
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
42
22. Price
(See ANSI-239.18)
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OPTIONAL FORM 272 BACK («-'
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EPA/ROD/R09-&3/022
Ordot Landfill, GU
Firs'. Remedial Action - Final
16. ABSTRACT {continued)
source aquifer, there is an absence of organic contaminants, inorganic contamination is
below the appropriate MCLs, and no air quality problems exist. The study concluded that
current threats to human health and t! ^ environment are a result of poor landfill
operation practices and not a result of the few acres of the landfill which are no
longer in operation. The primary contaminants of concern affecting the ground water and
surface water include iron and manganese.
The selected remedial action for this site is the no action alternative. EPA
concludes that threats to human health and the environment can best be mitigated through
addressing operation and maintenance of the landfill, and that the appropriate mechanism
for implementing these controls is through enforcement of the Clean Water Act. Further,
EPA concludes that any remedial action to address the inactive portion of the landfill
would be jeopardized or nullified unless operation practices at the active disposal
areas are improved. No costs are associated with the no action alternative.
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FINAL
RECORD OF DECISION
ORDOT LANDFILL
SUPERFUND SITE
GUAM
SEPTEMBER 1988
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 9
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Ordot Landfill, Guam
STATEMENT OF PURPOSE AND BASIS
This decision document represents the decision to take no
action under CERCLA but to defer clean-up of site threats to
the Clean Water Act as a more appropriate authority for the Ordot
Landfill in Guam. The decision was developed in accordance with
CERCLA as amended by SARA, and to the extent practicable, the
National Contingency Plan. This decision is based on the
administrative record for this site. The attached index identifies
the items which comprise the administrative record.
DESCRIPTION OF THE SELECTED REMEDY
EPA has determined, based on the available information, that
remedial action at the Ordot Landfill site under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA
or Superfund) 42 U.S.C. Section 9601 et seq. is inappropriate
at this time.
This determination is based on several facts: 1) Ordot
Landfill is an operating municipal landfill; 2) all but approxi-
mately 4-7 acres of the 47 acre site are active waste disposal
areas; 3) the 4-7 inactive acres are downgradient of the active
waste disposal areas or are immediately adjacent to active
waste disposal areas? 4) any remedy for the inactive areas
will likely be affected by activities at the active waste disposal
areas or continued surface flows through the landfill; 5) the
bulk of any environmental impacts from the landfill will result
from activities at the active waste disposal area; 6) the landfill,
by applying standard operation practices to control landfill
leachate, can effectively reduce or eliminate the surface flow of
leachate to receiving waters; 7) EPA has issued an order under
the Clean Water Act, 33 U.S.C. Section 1251 et seq., that requires
the Guam Department of Public Works to cease discharge of leachate
from Ordot Landfill to the Lonfit River; and 8) EPA data, although
too limited for comprehensive conclusions, has not demonstrated
any imminent and substantial endangerment to human health or
welfare or the environment.
EPA concludes that threats to human health and the environ-
ment currently identified at the landfill are due to poor operation
practices and can best be mitigated through addressing operations
and maintenance of the landfill itself including improved leachate
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control measures consisting of capping and surface water control.
EPA concludes that the appropriate mechanism for implementing
these controls is through enforcement of the Clean Water Act. The
responsibility for implementing-these controls lies with the
landfill operator/ the Territory of Guam. Expenditures from
the Superfund for these purposes are not appropriate.
Further/ EPA concludes that any remedial action to address
the inactive portion of the landfill potentially appropriate for
response under CERCLA would be jeopardized or nullified unless
operation practices at the active disposal areas are improved to
reduce leachate formation and to prevent discharge of leachate.
The design for improved operations at the active disposal areas
must consider the inactive portion due to the nature of the site
and thus would make a separate CERCLA remedial action unnecessary.
Based on these considerations/ EPA selects no action as the
preferred alternative under CERCLA. As part of the preferred alter-
native, EPA will continue to gather additional data to identify
any adverse impacts on human health or welfare or the environment
attributable to the landfill not currently identified and remediated
by the improved landfill operation practices. As part of this
continued monitoring program at Ordot Landfill, EPA will monitor
to detect as early as possible any migration of contaminants from
the landfill toward the sole source aquifer. The design of this
program will be based upon further hydrogeological investigations
at the site and in the vicinity of the site to characterize
geologic and hydrologic features necessary to define the
monitoring program.
In choosing the no action alternative EPA reserves its
authority to perform additional response actions should the new
information warrant such a decision.
DECLARATION
This decision document represents the selected alternative
for this site developed in accordance with CERCLA/ as amended by
SARA, and the National Contingency Plan.
The Territory of Guam has concurred on the selected remedy.
Date Daniel W. McGovern
Regional Administrator
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Record of Decision
Table of Contents
SECTION
I. Site Location and Description
II. Site History
III. Enforcement Activities
IV. Community Involvement
V. Remedial Investigation
A. Initial Site Characterization (ISC)
B. Site Geology
C. Site Hydrology
D. Water Quality Analysis
E. Air Sampling
VI. Endangerment Assessment
VII. Selected Alternative
PAGE
1
1
2
3
3
3
5
7
9
12
12
13
FIGURES/TABLES
Figure 1-1 Location of Ordot Landfill
Figure 1-2 Site Location Map
Table 3-2 Surface Water/Leachate Results
Table 3-3 Ground Water Results
FOLLOWING PAGE
1
1
10
10
APPENDICES
APPENDIX A
APPENDIX B
APPENDIX C
Index of Administrative Record
Responsiveness Summary
Concurrence Letter From GUAM
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DECISION SUMMARY
- ORDOT LANDFILL, GUAM
I. SITE LOCATION AND DESCRIPTION
Ordot Landfill (Ordot) is an operating municipal landfill
located on the island of Guam (Figure 1-1), and is the only major
municipal landfill on the island. It is currently operated by
the government of Guam through the Department of Public Works.
The site has been receiving uncontrolled municipal (and perhaps
hazardous) wastes since before World War II.
The Japanese and United States military occupational forces';
used the landfill during World War II, but the nature of the
waste placed in the landfill at that time is unknown. After
World War II and with the expansion of the highway system in the,;,
more populated areas of northern Guam, Ordot Landfill became the
primary repository of municipal waste for the island and is used
by both the civilian population and the United States military.
The landfill is presently managed and operated by the Guam Depart-
ment of Public Works. Although Ordo,t Landfill primarily received
municipal waste, because it is the only major public waste
disposal site on Guam, the Guam Environmental Protection Agency
(Guam EPA) feels that it has received hazardous waste during its
history, including spent industrial and commerical chemicals, PCB
contaminated oils from transformers, and perhaps munitions.
Unfortunately, records have never been kept as to the nature and
quantity of hazardous wastes disposed of at Ordot Landfill.
Ordot Landfill is located in the volcanic upland near the
divide between the southern volcanic and northern limestone
geologic provinces which comprise the island of Guam (Figure
1-2). The primary concern is that a suspected fault near the
landfill may provide a hydrologic connection between the contaminants
at Ordot Landfill and Guam's major drinking water aquifer located
in the limestone province. A second basis of concern regards
leachate runoff impacts on the adjacent Lonfit River, which flows
into Pago River, and ultimately Pago Bay. The source of leachate
flow was suspected to be a perennial stream fed by a spring
buried beneath the landfill and originating in the fault.
II. SITE HISTORY
Ordot Landfill is an operating facility and has been in
continuous operation for approximately 40 years. It continues to
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SOURCE: 208 PLAN FOR
THE ISLAND OF GUAM
* i I I f e i * t t £ 4
AAfJ
ftvllwt* ftoM
NORTHERN
•oundory TM<
•et»t»n
SOUTHERN
VOLCANICS
e t r i c
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t 01 t » 4
feM0
HB.CJ
ORDOT LANDFILL, GUAM
LOCATION OF ORDOT LANDFILL
-ISLAND OF GUAM
CAMP DRESSER A McKEE INC.[ Ftg. 1-1
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OROOT LANDFILL
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-2-
be operated more as an open dump than as an engineered landfill*
Ordot Landfill was established in a ravine which slopes steeply to
the Lonfit River. Current operations at the facility utilize almost
the entire historic 47 acre waste disposal area with only approxi-
mately 4-7 acres of the oldest portion of the landfill not
currently in use. The unused portions of the historic waste
disposal area are downgradient or adjacent to current operations.
One inactive area forms the steeply sloping toe of the landfill.
The current depth of disposed wastes is approximately 100 feet.
The toe of the landfill is approximately 1000 feet from the
Lonfit River and leachate streams emanate from points along the
contact of the landfill toe and the clay soils which comprise the
banks of the Lonfit River.
The Governor of Guam designated Ordot as Guam's highest
priority site for Superfund clean-up. It was included on the
initial National Priorities List (NPL) which was finalized on
September 8, 1983.
On March 26, 1986, EPA found Ordot Landfill in violation of
the Clean Water Act for discharging landfill leachate to the
Lonfit River without a National Pollutant Discharge Elimination
System (NPDES) permit. EPA ordered Ordot Landfill to cease
discharge. Ordot Landfill remains in violation of the EPA order.
III. ENFORCEMENT ACTIVITIES
A potentially responsible party (PRP) search has been
performed to identify responsibility for the contamination at
Ordot Landfill. The PRP search included a title search of the
Ordot Landfill, a trip to Guam to interview individuals and
agencies that have or may have interfaced with the landfill and
its operations, file reviews of federal and Guam government
agencies, contacts with consultants and other firms that may be
knowledgeable of Ordot Landfill or activities related to it, and
a field survey of the site to review operating practices.
The field survey was also performed to identify and locate
industrial properties surrounding the landfill that may have
contributed to the local groundwater contamination. During the
field survey, visual evidence of any type of industrial operation
or storage facility was used as the criterion to identify PRPs.
The result of the field survey found no industries or other
suspected practices in the vicinity of the landfill.
Results of the PRP search indicate that several PRPs can
possibly be identified based upon the information obtained: U.S.
Navy, Government of Guam, and the Department of Public Works.
Other agencies or businesses that are known to have disposed of
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waste in the landfill include the Agana Sewage Treatment Plant.
Guam EPA reported that private disposal companies and local
hospitals have also disposed of waste at Ordot. Those cited were
Guam Memorial Hospital and Commercial Sanitation Systems/ Inc,
but others may be active on the island.
IV. COMMUNITY RELATIONS
Community involvement was solicited at the conclusion of
EPA's Phase I Remedial Investigation. The notice of availability
of the Proposed Remedial Action Plan with supporting documentation,
which identified EPA's and Guam EPA's preferred remedial alter-
native of no action for this site, was published on June 27,
1988. The Proposed Remedial Action Plan and supporting documentation
was released to the information repositories on July 12, 1988. I >
The public comment period, initiated on this date, solicited .....v
public comment through August 12, 1988. A public meeting was
held July 26, 1988.
EPA prepared the attached Responsiveness Summary to address
the specific concerns raised during the public comment period, "^ ;
including comments made at the public meeting. A transcript of
the public meeting is available at the information repositories
at EPA, Region 9 offices, and Guam EPA.
V. REMEDIAL INVESTIGATION
A. INITIAL SITE CHARACTERIZATION (ISC)
An initial hazardous waste characterization study performed
by Black and Veatch Engineers — Architects (1983) was inconclusive
with regard to documenting the nature and extent of the threat
actually posed by contaminants from Ordot Landfill. EPA contracted
with Camp, Dresser and McKee, Inc. (CDM) to perform an Initial
Site Characterization (ISC) to determine: 1) the quality and
quantity of contaminants at or produced by the landfill; 2)
pathways by which these contaminants may leave the site; and 3).
the potential impacts of the contaminants.
CDM made a initial site visit on October 17-18, 1985 and
developed a workplan for the site characterization which was
finalized on June 2, 1986. Sampling of ground waters, surface
waters and landfill leachate was performed March 10-16, 1987.
Additionally, reconnaisance level air quality monitoring, and a
geologic reconnaisance were performed. The Final Initial Site
Characterization report was submitted September 18, 1987.
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The September 18, 1987 ISC report concluded that:
0 Surface flow through the landfill was the source of leachate
flows with the uncompleted landfill allowing for retention
of rain and surface inflow to produce the perennial leachate
flow. There was no indication of a spring.
0 The geologic reconnaisance indicated that the landfill is
underlain by fine grained volcanic deposits of very low
permeability, with an absence of any carbonate deposits.
On this basis and corroborated by the ground water studies/
the site appears to be hydrologically isolated from the
limestone aquifer. Groundwater flow is expected to be
along the bedding planes toward the Lonfit River and away
from the suspected fault. There was no indication of
presence of a fault at the site. Follow-up monitoring to
confirm the hydrologic isolation of the site from Guam's
sole source drinking water aquifer is recommended due to
data limitations from the geologic reconnaisance.
0 The water quality sampling was performed only during Guam's
dry season and was limited in number of samples. The samples
indicated a general absence of organic contaminants at the
time of sampling. The contract detection limit for vinyl
chloride was not sufficiently low to ascertain compliance
with the MCL. Two organic contaminants were detected at levels
below the contract detection limits but above the instrument
detection limits indicating the presence of some organics
at low levels. The samples indicated an increase in inorganic
constituents downgradient of the landfill which, however,
did not exceed MCLs for any inorganic constituent. Secondary
MCLs were exceeded only for Iron and Manganese, and no
adverse health effects would be expected. Several metals
were present in the landfill leachate and downgradiant
groundwater samples in excess of EPA ambient water quality
criteria (AWQC). However, based upon the observed relative
flow of leachate and the Lonfit River, adequate dilution
is expected to be available. No significant impact on the
Lonfit River was observed under conditions at the time of
sampling. Groundwater in the site vicinity is not used
for drinking or other purposes.
0 The air quality reconnaisance indicated the presence of
minor amounts of methane, predominantly in the older
landfill portions. No other air quality problems were
observed.
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The ISC report made clear recommendations for a remedial
program to improve landfill operation practices to prevent or
minimize any threats to human health and the environment posed by
disposal practices at Ordot. The remedial program includes:
0 implementation of perimeter control of surface flow run-on
to prevent current flow through the landfill;
0 capping unused portions of the landfill; and
0 continued monitoring to demonstrate the effectiveness of
the improved practices and substantiate the conclusions
of the ISC.
B. SITE GEOLOGY
B.I. REGIONAL GEOLOGY
Guam is the largest and southernmost island in the Mariana
Island Chain. The island chain is located atop a large submarine
ridge known as the Mariana Island Arc System, which is the boundary
between subducting tectonic plates. The Mariana Trench is located
east and south of the arc. Guam has two major physiographic
divisions (Figure 1-1). The southern half of the island is the
oldest and is characterized primarily by a dissected and relatively
rugged volcanic upland, on which limestones were sometimes
deposited. Ordot Landfill is located in the northern part of
this physiographic area.
The northern half of the island is characterized by a broad
and gently undulating limestone plateau which slopes from Mount
Santa Rosa (elevation 858 feet) on the northeast toward the Agana
Swamp area (near sea level) on the southwest (Figure 1-1). The
Limestone Plateau ends abruptly in near vertical cliffs along
most of the coast line of nothern Guam. Volcanic rocks are
exposed at the ground surface near the tops of Mount Santa Rosa
and Mataguac Hill and form the surface expressions of the volcanic
backbone on which the thick sequences of limestone were desposited.
The rocks of the northern province probably formed from volcanic
events that are both separate and younger than those in the south.
Limestone sequences grew on the submerged volcanic surfaces as
they were uplifted, and eventually connected with the southern
half of the island. The two physiographic provinces may be
separated by a major northwest-southeast trending fault/ located
northeast of Ordot Landfill.
At this time, the island appears to be in a period of relative
quiesence, with active fringing reefs being formed around the
coast of the Northern Plateau. However, because tectonic activity
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is sti.ll on-going in the region of the Mariana Trench, uplift of
the island arc and Guam is expected to continue into the geologic
future.
B.II. GEOLOGIC MATERIALS BENEATH THE SITE
The geologic materials which underlie the site consist of
thinly bedded, tuffaceous shales and sandstones, with grain sizes
ranging from clay to medium-grained sand (Tracey, et. al., 1963).
Bedding ranges from a few millimeters to several meters in thick-
ness. Typically, these deposits range in color from gray to
light orange in fresh exposures and gray-green to dark red in
weathered exposures. Gray-green beds are usually indicative of
the coarser-grained tuffaceous sandstones, with the darker colored
beds associated with the higher silica content of the matrix
material.
Most of the rocks observed at the site exhibited varying
degrees of weathering. In most unweathered exposures, the tuffs
are fairly hard, but show chemical altering around individual
angular grains. With weathering, the fine-grained matrix material
breaks down to clay and the grains continue to weather, eventually
to clay with little evidence of the original clastic texture.
Weathering is prominent in most of the rocks exposed in the upper
two to three feet of the surface. Rocks with little sign of
weathering are exposed in the area used by the landfill operators
as a source of cover material and in road cuts in and near the
site. These unweathered rocks originally existed over ten feet
below the ground surface. The weathered rocks, because of their
high clay content, appear to have extremely low permeabilities.
Unweathered rocks, because of their fine-grained matrix and
partially altered clastic texture, also appear to have low
permeabilities.
B.III. STRUCTURAL GEOLOGY
The rocks beneath the site are moderately folded and
fractured. Bedding is folded into an anticline with an east-west
axis. The north limb of the anticline dips 15 to 50 degrees.
The south limb dips between 40 and 60 degrees. Folding is
common within beds and appears to be due to depositional features.
Fracturing was commonly observed in the rocks. However, most of
the fractures are closed and, as such, may inhibit groundwater
movement.
Major faulting was not observed in the beds exposed in or
adjacent to the site area. Tracey, et. al. (1964) indicated a
major northwest-southeast trending fault which passes just north
of the Ordot site. This fault is thought to divide the northern
limestones and the southern vocanics. Reconnaissance of the area
did not substantiate the existence or absence of this fault. The
steep terrain north of the site could be explained as either a
major block fault or as a terrace (erosional) feature. A spring
was thought to issue from the fault zone and subsequently flow
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through the site. However, on closer examination of the area/
topography of the area appears to concentrate surface runoff and
channel it into the site.
B.IV. RESULTS OF GEOLOGIC RECONNAISSANCE
The results of the geologic reconnaissance indicate that the
landfill is underlain by fine-grained volcanic deposits. These
deposits appear to be of very low permeability, based on observa-
tions of the surficial material.
There does not appear to be any of the carbonate deposits
present in the immediate site vicinity, based on available outcrop
information. One of the initial concerns about the Ordot landfill
site was the potential for leachate contaminating the limestone
aquifer through a fault suspected to be in the vicinity. However,
the site appears to be hydrologically isolated from the limestone
aquifer based on the observations associated with the geologic
reconnaissance. Furthermore, any groundwater on site would
probably flow along bedding planes or along the contact between
the landfall material and the bedrock deposits, both of which dip
to the south away from the island's major limestone aquifer
toward the Lonfit River. Therefore, there does not appear to be
a pathway for groundwater contamination to affect the limestone
aquifer. Because the geologic reconnaisance was limited in scope,
confirmatory monitoring to further substantiate the isolation of
the site from the sole source aquifer is appropriate. The design
of this monitoring program will be based upon further hydrogeologic
studies at the site and in the vicinity of the site necessary to
define the program.
C. SITE HYDROLOGY
C.I. PRECIPITATION
The rainfall record indicates two distinct seasons in Guam.
The dry season runs from January through June, during which time
showers produce most of the little rain that falls. The seasonal
average rainfall during the dry season is approximately 5 inches
per month.
The wet season, runs from July through December. The wet
season rainfall is produced from major regional storm systems,
during which the seasonal average rainfall is about 12 inches per
month. The maximum monthly rainfall for the season generally
occurs in August and September and has historically ranged to
over 30 inches per month, but averages about 14 inches per month.
During typhoons, rainfall intensities are extreme and can be as
much as eight inches in two hours, 18 inches in 12 hours, and 24
inches in 24 hours (Tracey, et al; 1964). However, the long-term
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records show that monthly and annual rainfall are rather consistent
on Guam, with the exception of high intensity rain generated
during the occasional strong typhoons.
Unlike southern Guam, northern Guam does not have a well
established/ incised drainage system because the limestones are
so permeable that rainfall almost immediately infiltrates upon
reaching the ground. In developed areas of the interior, run-off
over streets is usually diverted to open trenches, or to dry wells.
Upon reaching storm water retention areas, the run-off infiltrates.
In southern Guam, the volcanics weather to a relatively thick/
impermeable soil zone. As a result, most of the rainfall ends up
as surface runoff which eventually flows to the ocean in well
established drainage courses/ such as the Lonfit and Pago Rivers.
C.2. GROUNDWATER PRODUCTION
The water supply of northern Guam comes almost exclusively
from the limestone aquifers of the Northern Plateau. Except for
a few privately owned wells in northern Guam, the production from
the groundwater system is managed by the Public Utility Agency of
Guam (PUAG), the Air Force, and the Navy. There are presently
over 70 municipal wells and one infiltration tunnel in operation
in northern Guam. These facilities have a maximum capacity to
yield about 21 million gallons per day (MGD).
Only a few low-yielding wells have been drilled in southern
Guam. Water wells have not been drilled in the volcanics near
Ordot Landfill.
C.3. GROUNDWATER MOVEMENT BENEATH THE SITE
The site appears to be geologically isolated from the lime-
stones of the Northern Lens Aquifer. The high clay content of
the tuffaceous shales and sandstones appears to restrict infil-
tration of rainfall or surface inflow. As such, most of the water
that enters the area, either as rainfall or as surface inflow/
will flow south along the original ground topographic surface
into the Lonfit River. However/ rainfall at the site may result
in a significant amount of infiltration into the landfill debris
due to the inadequate cover utilized at the site.
The background monitoring well in the northern part of the
site contained only a small amount of water/ indicating extremely
low permeabilities for the rocks underlying the site. The
apparently small amount of groundwater which flows through the
site area probably follows the solid waste bedrock contact/ which
dips in a southerly direction beneath most of the site toward the
Lonfit River. Groundwater beneath the southern portion of the
site appears to be related to the alluvium associated with the
Lonfit River. The groundwater gradient in the alluvium probably
-------
-9-
follows the topography and, as such, flows parallel to the Lonfit
River and eventually enters Pago Bay on the eastern shore of the
island.
D. WATER QUALITY ANALYSIS
COM performed field sampling March 10-16, 1987 to determine
quality of surface water, ground water and leachate in the vicinity
of the site or potentially impacted by the site. This sampling
effort was for purposes of making an initial site characterization
and therefore limited numbers of samples were taken. The samples
were collected during Guam's dry season where average monthly
rainfall is 5 inches versus a 12 inch per month average (with
short intense storms) during the rainy season. Although sampling
during the dry season may represent worst-case with respect to
contaminant loading, this assumption could be incorrect if
channeling of flows within the landfill occurs during low flow
conditions. Additional sampling would be required to fully
characterize the site with respect to seasonal variation in flows
and concentrations, and to expand the current data base.
As detailed in the following analysis of results, the sampling
results indicated that although the landfill leachate and down-
gradient groundwater are generally poor quality with respect to
inorganic constituents, essentially no volatiles, semi-volatiles,
or pesticides/PCBs were detected in any samples. Analysis of
downqradient groundwater samples indicated the presence of barium,
iron, manganese, zinc, vanadium and aluminum. Leachate samples
contained these metals and additionally chromium, cobalt, copper,
cyanide, potassium and lead. Although no samples exceeded the -
inorganic primary maximum contaminant levels (MCLS), secondary
MCLs were exceeded for iron and manganese in leachate samples and
downgradiant groundwater. Comparison of concentrations of metals
in groundwater and leachate to Ambient Water Quality Criteria
(AWQC) for freshwater aquatic life show some concentrations are
in excess of these criteria. However, based upon the observed
relative flow of leachate and the Lonfit River, adequate dilution
is expected to be available. No significant impact on the Lonfit
River was observed under conditions at the time of sampling. The
Endangerment Assessment addresses the potential impacts of these
contaminants on human health and the environment.
D.I. ANALYTICAL DATA
All of the surface water, groundwater and leachate samples
collected during the sampling effort were analyzed for Routine
Analytical Services Hazardous Substances List (RAS HSL) volatile,
semi-volatile, pesticide/PCB, and inorganic constituents. All
data were validated by Region 9 using standard review protocols
and the data quality was considered in analysis of the data and in
reaching the decision.
-------
-10-
The following samples were taken and the results of the
laboratory analysis are reported in Table 3-2 (from the ISC) for
surface water and Table 3-3 (from the ISC) for groundwater:
Sample
Number
Description
SW-01 Lonfit River, upstream of
landfill
SW-02 Lonfit River, downstream
of landfill
SW-05 Leachate spring, south
side of landfill
SW-07 Leachate pond area, south
side of landfill
SW-10 Leachate stream, west
Sample
Number
Description
GW-01 Municipal Well A-ll
GW-03 Municipal Well A-12
GW-04 WERI Background
Monitoring Well
GW-05 WERI Downgradient
Monitoring Well
GW-06 WERI Well «4
Downgradient
Duplicate sample pairs are as follows:
02 and SW-13; and GW-06 and GW-07.
GW-01 and GW-02; SW-
D.2 ANALYSIS OF DATA
Inspection of the data indicate that water quality of the
leachate is generally poor, particularly considering the high
concentrations of the inorganic constituents. However,-none of
the inorganic constituents exceed the USEPA maximum contaminant
limits (MCLs), although iron and manganese generally exceed the
secondary maximum contaminant limits (SMCLs) for all of the
leachate samples. With regard to organic constituents, only
trace levels of carbon disulfide and chlorobenzene were detected
in sample SW-7, and phenol was detected in SW-10. Each of
these constituents were detected in amounts below the Contract
Recommended Detection Limit (CRDL) and are qualified as such.
All of the other organic constituents analyzed under the CLP RAS
program were either undetected or detected in the method blank,
indicating laboratory contamination. The CRDL for vinyl chloride
(10 ug/1) is not low enough to determine compliance with the
MCL for vinyl chloride (2 ug/1).
Samples were also collected from the Lonfit River to determine
the potential impact of the landfill on the water quality of the
river. Sample SW-01 was collected from the Lonfit River upgradient
of the landfill, whereas sample SW-02 was collected downgradient.
Sample SW-13 represents a duplicate of SW-02.
-------
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llt-IM «A
in-n-t «/i
fin-n-i *n
tiii-N-i nr\
tiu-n-t M/t
tMi-n-i K^I
tMHI-f «/l
T«MM H/l
TIM-TM K/l
tHMT-1 it/l
TMI «-« icA
TMI-M-I n/l
TI-N-I *ft
tm-IM K/l
tm-n-i «/i
toi-n-i «/i
tm-H » n^i
WM It-l K/l
i«ii-n-i n/i
T«i-n-i «/i
mt-tt-t *
-------
Table 3-J
Ill
tl» MHrlit tM MtvMJIir, M M Hi (total. t
MMrliil fil« It M fitM* fttKtlM IIMI tar IM M*lt.
n» MMClttrt MMflMl ftNt It M tllUlt* l Mllclmltii lMHIItM«* lltll Ml t«|wM
A tk» »«!•» r*t«rM ••» MtiMlt ** It ttf*•*»•! IV ll«*tr rwf*.
H n» II)M rtt«l«4 Mt ttliMlt ** It t»llt rtctwrltt Mltl«t IMIH.
JC t*» *«|«t rtt*IH Mt ttliMtt Mt It l*tlraw*l ctlitrtliM frtllMt.
• l(*Nll| Ml tottlM riMfWlkMt Ml tWiflM Mt It Mtfll.
M tMllllf* KwdllttllM tl I MIIMl « Itel It Ml M Ikt MltrMN MttMt
lilt. MiMtllat Ml rtMlftlt It Mtttttrf tar (trltltttlM.
-------
11-
Examination of the data for the Lonfit River indicate that
the water quality is generally better than the leachate quality.
This is particularly true for the inorganic constituents* which in
many cases are an order of magnitude less than the inorganic
constituent concentrations detected in the leachate samples. In
addition, none of the constituent concentrations detected in the
Lonfit River exceeded the MCLs or SMCLs, and none of the organic
constituents were detected in any of the samples. Finally,
comparison of the data for the downgradient sample (SW-02) with
the data from the upgradient sample (SW-01) indicates that the
leachate discharging to the Lonfit River had little impact on the
river water quality at the time of the sampling effort. For
example, a comparison between many of the major ions in the
samples indicate that there was little to no change in the water
quality. However, based upon observed practices at the landfill,
an impact on the river may occur due to improper disposal of
highly contaminated wastes resulting in a more highly contaminated
leachate discharge to the river over a short time period.
Samples GW-01 and GW-03 were collected from municipal wells
located in the vicinity of the landfill. Sample GW-02 represents
a duplicate of GW-01. Samples GW-04, GW-05, and GW-06 were
collected from monitoring wells located within the site boundary.
Samples GW-07 represents a duplicate of GW-06. Sample GW-04 was
collected from the upgradient monitoring well.
The samples collected from the on-site downgradient monitoring
wells (GW-05 and GW-06) show a general degradation in water
quality when compared to the sample collected from the upgradient
well (GW-04). For the most part, every major inorganic constituent
increased in concentration downgradient. In some cases, there
was an order of magnitude increase in concentration (e.g., sodium,
zinc). Furthermore, iron and manganese in both of the downgradient
groundwater samples exceeded the SMCLs. Organic constituents were
not detected in any of the on-site monitoring wells, with the
exception of a phthalate in the upgradient well. The presence of
phthalate indicates the possible presence of plasticides.
The water quality data for the samples collected from the
off-site municipal wells are similar to the data for the upgradient
monitoring well, when considering the concentration of some of
the major metals such as sodium and magnesium. In that the water
quality is similar to the upgradient well and there does not
appear to be a degradation in water quality similar to that
observed in the downgradient monitoring wells, it appears that
the off-site municipal wells are unaffected by the landfill.
Phenol was detected at a concentration of 5.0 ug/1 in sample
GW-03. However, this value was qualified since it was detected
below the CRDL. The source of the phenol is not known. No other
organic constituents were detected in the off-site municipal
wells sampled.
-------
-12-
E. AIR SAMPLING
A rcconnaisance air sampling effort was conducted at Ordot
Landfill using portable field instruments.
The results of the reconnaissance-level air quality survey
indicate that air emissions from the landfill do not present a
major problem. For example, the average response of most of the
instruments along the transects were either zero or not above
background levels. The exceptions were the responses observed
for the Organic Vapor Analyzer (OVA). In general/ the OVA
consistently maintained readings on the order of 2 to 7 ppm above
background over the entire transect. In addition, at several
locations along the transects, elevated readings on the OVA were
observed, particularly along the southern portions of the land-
fill. The OVA readings obtained at these locations ranged from 2
to 100 ppm, although the upper levels generally represented short
spikes which were not sustained for extended periods of time.
The type of instrument responses observed at the landfill
suggest that small amounts of methane are being produced and
emitted from the landfill. For example, the HNu, which does not
respond to methane gas, did not respond while conducting the
transects. However, the OVA, which does detect methane gas,
generally responded above background along the entire course of
the transects. These instruments would not detect emissions of
chlorinated hydrocarbons and if future sampling indicates presence
of chlorinated hydrocarbons at the landfill, additional monitoring
to screen for air emissions is recommended.
The reconnaissance-level air sampling data collected indicates
that methane is being produced from the southern portion of
the landfill. This portion of the landfill is the oldest and/
consequently, the waste has had the most opportunity to degrade.
However, other portions of the landfill are presently not genera-
ting much methane. Furthermore, the instrument responses at the
southern portions of the landfill were not sustainable at the
higher levels, indicating that the methane production was not
sustainable. Given these aspects, it appears that the landfill
does not represent an air quality problem.
VI. ENDANGERMENT ASSESSMENT
ICF/Clements was tasked to write an Endangerment Assessment
(EA) report to evaluate the magnitude and probability of actual
or potential threat to public health or welfare and the environ-
ment posed by the hazardous substances present at the site. The
EA, based on the limited data from the Initial Site Characteriza-
tion, supports the conclusion that current conditions at the
landfill do not demonstrate a significant and substantial endanger-
ment to human health or the environment with regard to hazardous
contaminant impact appropriate for response under CERCLA
authorizations.
-------
-13-
VII. SELECTED ALTERNATIVE
The Superfund law requires that each remedy selected for a
site must be protective of human health and the environment, cost
effective, and in accordance with statutory requirements.
Permanent solutions to toxic waste contamination problems are to
be achieved wherever possible. According to the National
Contingency Plan under which the Superfund program operates,
specifically 40 CFR Part 300.68(j), the cost-effective remedy is
the lowest cost alternative that is technically feasible and
reliable and which effectively mitigates and minimizes damages to
and provides adequate protection of public health, welfare, and
the environment.
EPA has determined, based on the available information, that
remedial action at the Ordot Landfill site under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA
or Superfund) 42 U.S.C. Section 9605 et seq. is inappropriate at
this time.
This determination is based on several facts: 1) Ordot
Landfill is an operating municipal landfill; 2) all but approxi-
mately 4-7 acres of the 47 acre site are active waste disposal
areas; 3) the 4-7 inactive acres are downgradient or adjacent
to the active waste disposal areas; 4) any remedy for these
inactive areas likely will be affected by activities at the
active waste disposal areas or continued surface flow through the
landfill; 5) the bulk of any environmental impacts from the
landfill will result from activities at the active waste disposal
areas; 6) the landfill, by applying standard operation practices
to control landfill leachate, can effectively reduce or eliminate
the release of leachate to receiving waters; 7) EPA has issued an
order under the Clean Water Act, 33 U.S.C. Section 1251 et seq.,
that requires the Guam Department of Public Works to cease
discharge of leachate from Ordot Landfill to the Lonfit River;
and 8) EPA data, although too limited for comprehensive conclusions,
has not demonstrated an imminent and substantial endangerment to
human health or welfare or the environment.
EPA concludes that threats to human health and the environment
currently identified at the landfill are due to poor operation
practices and can best be accomplished through addressing operations
and maintenance of the landfill itself including improved leachate
control measures consisting of capping and surface water control.
EPA concludes that the appropriate mechanism for implementing
these controls is through enforcement of the Clean Water Act. The
responsibility for implementing these controls lies with the
landfill operator, the Territory of Guam. Expenditures from the
Superfund are not appropriate for these purposes.
-------
-14-
Further, EPA concludes that any remedial action to address
the inactive portions of the landfill potentially appropriate
for CERCLA response would be jeopardized or nullified unless
operation practices at the active disposal areas are improved
to reduce leachate formation and to prevent discharge of leachate.
The design for improved operations at the active disposal areas
must consider the inactive portions due to the nature of the
site and thus would make a separate CERCLA action unnecessary.
Based on these considerations/ EPA is choosing no action
as the preferred alternative. As part of the preferred alter-
native; EPA will continue to gather additional data to identify any
adverse impacts on human health or the environment attributable
to the landfill not currently identified and remediated by the
improved landfill operation practices. As part of this continued
monitoring program at Ordot Landfill, EPA will monitor to detect
as early as possible any migration of contaminants from the
landfill toward the sole source aquifer. The design of this
program will be based upon further hydrogeological investigations
at the site and in the vicinity of the site to characterize
geologic and hydrologic features necessary to define the monitoring
program.
In choosing the no further action alternative EPA reserves
its authority to perform additional response actions should the
new information warrant such a decision.
-------
ORDOT LANDFILL
GUAM
RESPONSIVENESS SUMMARY
This responsiveness summary is required by Superfund policy
for the purpose of providing EPA and the public with a summary of
citizen comments and concerns about the site, as raised during
the public comment period, and EPA's responses to those concerns.
All comments received are factored into EPA's final decision for
a site.
For the Ordot Landfill site, community involvement was
solicited at the conclusion of EPA's Phase I Remedial Investi-
gation (the Initial Site Characterization). A notice of the
availability of EPA's Proposed Remedial Action Plan (PRAP) with
supporting documentation was published on June 27, 1988 in Guam's
Pacific Daily News. The notice identified EPA's and Guam EPA's
preferred alternative of no action for this site under CERCLA.
A public comment period was conducted from July 12, 1988 through
August 12, 1988. EPA held a public meeting on July 26, 1988
at Guam EPA's offices in Harmon, Guam. Press releases and
notification to the Commissioner of Ordot/Chalan Pago, the nearest
village to the landfill, and to Senator Sam Agustin of the Guam
legislature's Committee on Health were prepared and made by Guam
EPA to further assure notification of the affected community and
their representatives.
EPA received no comments from the community at the public
meeting and no written comments were received during the public -
comment period. On that basis EPA is unaware of any community
concerns that have not been addressed by the preferred alternative
of no action at the Ordot Landfill site under CERCLA.
-------
ORDOT LANDFILL SUPERFUND SITE
Ordot, Guam
ADMINISTRATIVE RECORD INDEX
(Indexed by Date)
This Index Was Compiled July 1, 1988 and Includes Documents 1-75
-------
ORDOT LANDFILL SUPERFUND SITE
Ordot, Guam
ADMINISTRATIVE RECORD INDEX
(Indexed by Date)
This Administrative Record Index lists the documents contained in the Administrative
Record for the Ordot Landfill Superfund Site in Ordot, Guam. The Index presents
the documents in ascending chronological order, which is consistent with the arrangement
of the documents in the Administrative Record itself.
The documents contained in the Administrative Record were used by the U.S.
Environmental Protection Agency in identifying remedial activities appropriate for
use at the Ordot Landfill Superfund Site.
-------
Page Ho. 1
07/01/88
ORDOT LANDFILL SUPERFUHD SITE
ORDOT, GUAM
Administrative Record File Index
DOC. • DATE
FROH/ORGANIZ.
TO/ORGANI2.
DESCRIPTION/SUBJECT PAGES
37 11/18/80
Dan W. Crytser, To* Jones, EPA
Guam EPA Region IX
60 06/24/81
50 08/06/81
49 08/27/81
30 10/08/81
48 10/26/61
29 12/24/81
47 01/25/82
Dan Crytser, Guaa US EPA
EPA
33 01/26/82
Dr. Jake
Mackenzie, EPA
Region IX
Dr. Jake
Mackenzie, EPA
Region IX
Ricardo C.
Duenas,
Administrator,
Guam EPA
Ricardo C.
Duenas,
Administrator,
Guam EPA
William Flores,
Public Works,
Guai
Ricardo C.
Duenaa,
Adiiniatrator,
Guam EPA
Howard Karris,
HOAA, OHPA
Ricardo C.
Duenas,
Administrator,
Guam EPA
Ricardo C.
Duenas,
Administrator,
Guam EPA
Dr. Jake
Mackenzie, EPA
Region IX
Dr. Jake
HacKenzie, EPA
Region IX
Carl Aguan, Dir.
of Public Vorks,
Guam
Sonia F. Crow,
Administrator,
EPA Region IX
Keith A. Takata,
EPA Region IX
Cover Itr. vith 7
attached progress
report for the Ordot
Landfill engineering
plan (Re: GHP
Assoc.)
Notification of 10
Hazardous Waste Site,
Ordot Landfill
Ltr: Seeking EPA 1
Guam verification of
Ordot Landfill as
priority site
Ltr: Transmittal of 1
HOTIS printout
shoving hazardous
waste TSD sites in
Guam
Ltr: Vith attached 43
Mitre model
components and Mitre
•odel (Superfund)
verification
Ltr: Re: Hazardous 1
vaste pollution
threat at Ordot
Landfill
Memo: Ordot Landfill 3
requirements (Re:
12/18/81 inspection)
Ltr: Transmittal of 32
attached verification
documents for Mitre
hazardous vaste cite
ranking model
ROC i Harris called 1
Takata Re: Interim
Priority List cites
-------
Pag* Ho.
07/01/68
ORDOT LANDFILL SUPERFUND SITE
ORDOT, GUAM
Administrative Record File Index
DOC. t DATE
FROM/ORGANIZ.
TO/ORGANIZ.
DESCRIPTION/SUBJECT PAGES
45 02/26/62
44 05/03/82
David S. Movday,
EPA Region IX
William N.
Hedeman, Jr., US
EPA
43 06/01/82
Sonia F. Crow,
Administrator,
EPA Region IX
57 07/10/82 Daily News Staff
31 07/28/82
42 07/29/62
41 06/24/82
56 08/30/82
Sicardo C.
Duenas,
Administrator,
Guam EPA
Rita H. Lavelle,
US EPA
Paul H. Calvo,
Governor, Guae
Sonia F. Crow,
EPA Region IX,
William
HcAliater, EPA
Guam, and Paul H.
Calvo, Governor,
Guae
Herman L.
Lovelace, EPA
Region IX
Korean L.
Lovelace, EPA
Region IX
James 6. Branch,
Adiiniftrator,
Guai EPA
Newspapers
Readers
Public Record
Ltr: Update on
current Superfund
activities, including
Ordot Landfill
Memo: Requesting
authorization to
undertake remedial
planning at four
sites, including
Ordot Landfill
Ltr: Approval of
Guae's request for
CERCLA remedial
action at ORDOT
Landfill
Mevs: "EPA teaa
coming to Guae for
hazardous caste
study*
Agreement between the
Territory of Guai and
Region IX of the US
EPA for FY-83
Nachaa Siren,
Environmental
Protection Board,
Trust Territories
Ricardo C.
Duenas,
Administrator,
Guae EPA
Korean L.
Lovelace, EPA
Region IX
Ltr: Transeittal of
draft RI stateeent of
work
Ltr: Transeittal of
RI comprehensive Work
Plan
Ltr: Response to EPA
Region IX request to
document Guae EPA
activities to involve
public in RI and
action
-------
Page *°'
07/01/88
ORDOT LANDFILL SUPERFUNO SITE
ORDOT. 6UAH
Administrative Record File Index
DOC. I DATE
FROH/ORGANIZ.
TO/ORGANIZ.
DESCRIPTION/SUBJECT PAGES
32 10/22/82
40 10/27/82
26 11/01/82
39 11/03/82
75 12/01/82
34 01/13/83
74 05/20/83
Norman L.
Lovelace, EPA
Region IX
David S. Monday/
EPA Region IX
Keith A. Takata,
EPA Region IX
Keith A. Takata,
EPA Region IX
COM & Barret,
Harris & Assoc.
Kathleen G.
Shimmin, EPA
Region IX
Vernon M. Reid,
Black & Veatch
Joseph Egan, Ltr: Response to
Vorld Information 10/16/82 letter
Systems requesting Pacific
Basin hazardous vest*
information
Eicardo C.
Duenas,
Administrator,
Guas EPA
Ltr: Current
Superfund actions
regarding hazardous
waste in Insular
Territories
(Including Ordot
Landfill)
Stephen Caldvell, Memo: MRS scores for 15
US EPA
Stanley L.
Carlock, P.E.,
U.S. Army Corps
of Engineers
Guam EPA
EPA Region IX
Nancy Villis,
EPA
US
Region IX sites -
documentation for
Insular Territories
(10/25/82 HRS package
for Ordot attached)
Ltr: Discussion of
Corps role in RI/FS
project
Final Rpt: 'Northern
Guam Lens Study,
Groundvater
Management Program/
Aquifer Yield Report*
Issue: Vhat is the
status of the sites
of the Insular
Territories under
CERCLA?
Rpt: ^Remedial
Investigation/
Insular Territory
Hazardous Vacte
Sites/ Draft Report*
219
113
-------
Page D°«
07/01/68
ORDOT LANDFILL SUPERFUND SITE
OBDOT. GUAH
Administrative Record Filt Index
DOC. t DATE
FROH/ORGANIZ.
TO/ORGAMIZ.
DESCRIPTION/SUBJECT PAGES
36 06/08/63
55 06/06/83
53 06/22/63
54 06/29/83
52 07/21/83
51 09/07/83
58 09/30/83
59 10/18/84
Antonio B. Von
Pat, Member of
U.S. Congress
Korean L.
Lovelace, EPA
Region IX
Margaret
Sizemore, Daily
News Staff
Margaret
Sizemore, Daily
Rev* Staff
Norman L.
Lovelace, EPA
Region IX
James B. Branch,
Administrator,
Guam EPA
Harry
Seraydarian, EPA
Region IX
James B. Branch,
Administrator,
Guam EPA
Villiam D.
Ruckelshaus,
Administrator,
EPA
Ltr: Information
request Re: Toxic
vaste disposal in
Guam (with attached
6/29/83 ROC Re: Von
Pat letter)
Herman D. Sablan, Ltr: Transmittal of
Administrator, 'Remedial
Guai EPA investigation of the
Iniular Territory
hazardous waste
sites'
Revspaper Readers Dews: 'Ordot du«p
saeplea declared
non-toxic*
Newspaper Readers News: 'Vaste cleanup
hinges on EPA*
Herean D. Sablan, Ltr: Vith attached
Administrator, suggested language
Guam EPA for ROD public
comment period
notification
Norman L.
Lovelace, EPA
Region IX
Herman D. Sablan,
Administrator,
Guam EPA
Ltr: Re: Public
comment on Draft
Remedial
Investigation
Notice Itr:
Violation of 40 CRF
Part 265 - Interim
Status Standards for
hazardous vaste TSD
facilities
Francis K.Y. Kau, Ltr: Comments on
Environmental Scope of Vork for
Branch, Dept. of confirmation of IAS
the Navy sites on U.S. Navy
properties in Guam
(Re: 10/2/64 Itr.)
-------
Pag* Bo.
07/01/68
ORDOT LANDFILL SUPERFUND SITE
ORDOT, GUAM
Adainiatrative Record Fila Indax
DOC. t DATE
FROH/ORGANIZ.
TO/ORGANIZ.
DESCRIPTIOR/SUEJECT PAGES
36 03/27/65
35 05/16/65
22 06/13/65
73 09/10/85
24 11/06/85
64 06/02/66
16 06/25/66
Jaaaa B. Branch,
Adainiatrator,
Guaa EPA
Doria Lee-Betuel,
EPA Region IX
Marvin Young, EPA Jerry Clifford,
Region IX EPA Region IX
Jaaea L. Canto,
Guaa EPA
Doria Lee-Betuel
EPA Region IX
Jaaea A.
Goodrich, CDH
Jaaea A.
Goodrich, CDH
72 11/20/65 CDH
Jaaea A.
Goodrich, CDH
Terry L. Stuaph,
EPA Region IX
Keith A. Takata
and Thoaaa A.
Hix, EPA Region
IX
Thoaaa A. Hix,
EPA Region IX
EPA Region IX
EPA Region IX
71 07/24/86 CDH
Keith A. Takata,
EPA Region IX
EPA Region IX
Cover Itr. with 13
attached project
•ynopaia for VERI'a
Ordot Landfill
Leachate Study
Heao: Quarterly 2
report - Ordot
Landfill, Cuaa - Jan
1965-Har 1985
, Ltr: Tranaaittal of 6
Guaa Vater and Energy
Research Institute
project for
inveatigationa
aurface and
ground«ater
contaaiaation
Rpt: "Work Plan 25
Heaorandua for Ordot
Landfill, Guaa*
Heao: Ordot Landfill 4
Initial aite
inspection
Rpt: ^Revised Vork 26
Plan Beaorandua for
Ordot Landfill, Guaa"
Rpt: Ordot Landfill, 61
Guaa RI, Vork Plan
Vol. I - •Technical
Scope of Vork*
Heao: Review of 4
Ordot Landfill aaaple
plan
Rpt: 'Quality 95
Aaaurance Project
Plan, Reaedial
Inveatigation, Ordot
Landfill Site, Guaa*
-------
Pag* Bo.
07/01/68
ORDOT LANDFILL SUPERFUND SITE
OtDOT, GUAM
Adainiatrative Record File Index
DOC. t DATE
FROM/ORGANIZ.
TO/ORGAMIZ.
DESCRIPTION/SUBJECT PAGES
10 08/13/86
68 08/14/86
17 08/18/86
69 08/20/86
67 09/25/86
70 11/06/86
11 12/01/86
7 12/12/86
13 01/26/87
Harry
Seraydarian,
Region IX
James B. Branch,
EPA Guam EPA
Peter Rubenstein, Thoeas A. Mix,
EPA Region IX EPA Region IX
Jaees B. Branch,
Guam EPA
Terry L. Stuiph,
EPA Region IX
James A.
Goodrich, CDH
Carl Aguan, Dir.
of Public ¥orka,
Guam
Keith A. Takata,
EPA Region IX
EPA Region IX
Terry L. Stuiph,
EPA Region IX
Patricia
Connaughton, EPA
Region IX
Patricia
Sanderson Port,
U.S. Dept. of
Interior
Jeff Zelikaon,
EPA Region IX
Keith A. Takata,
EPA Region IX
Thomas A. Mix,
EPA Region IX
Bruce Blanchtrd,
U.S. Dept. of
Interior
notification of
propoaed aelection of
Ordot Landfill a* a
Superfund cite
Memo: Review of
Ordot Landfill
sampling and analytic
plan dated 7/16/86
(plan found
inadequate)
Notice of violation
Re: Uncontrolled
scavenging at Ordot
Landfill
Memo: Diacuasion of
Ordot Landfill QAPP
(7/24/86 reviaion)
review
Rpt: 'Final Quality
Assurance Project
Plan, Reaedial
Investigation, Ordot
Landfill Site, Guam"
Hemo: Dlacuaaion of
Roae Fong'a review of
the Quality Aaaurance
Project Plan
Heeo: Evaluation of
Ordot aaaple piana
Heao: Preliminary
natural reaourcea
•urvey report
CAPT Donald Ltr: CERCLA 104
O'Shea, U.S. Navy information requeat
Re: U.S. Havy
responsibility at
Ordot Landfill
99
-------
Page lo.
07/01/88
ORDOT LANDFILL SUPERFUND SITE
ORDOT, GUAM
Adainiatrative Record File Index
DOC. I DATE
FROH/ORGANIZ.
TO/ORGAN12.
DESCRIPTION/SUBJECT PAGES
63 02/02/87
8 02/03/87
12 02/04/87
9 02/09/87
66 02/10/87
3 05/04/87
5 05/27/87
62 06/08/87
Jaaes A. EPA Region IX
Goodrich, COM
Jeff Zelikson,
EPA Region IX
Lawrence J.
Caplan,
Coaaercial
Sanitation
Systems, Inc.,
Toauning, Guaa
Peter Rubenstein, Stewart Simpson,
EPA Region IX EPA Region IX
Patricia Thoaas A. Mix,
Connaughton, EPA EPA Region IX
Region IX
Neil E. Botts, Nancy Lindsay,
CDH EPA Region IX
Rpt: 'Final Stapling
and Analysis Plan,
Phase I Reaedial
Investigation, Ordot
Landfill, Guaa'
Ltr: Re: Involvement
with Ordot Landfill
250
Jaaes A.
Goodrich, Caap,
Dresser £ McKee
(CDK)
Thoeas A. Mix,
EPA Region IX
Kent K. Thoaas A. Mix,
Kitchingnan, EPA EPA Region IX
Region IX
Jaaes A. EPA Region IX
Goodrich, CDH
Heao: TransBittal
and approval of
proposed Ordot
Landfill air saapling
plan
Heao: Ordot Landfill
saapling and analysis
plan review
Rpt: 'Final Quality
Assurance Project
Plan, Reaedial
Investigation, Ordot
Landfill Site, Guam-
Ltr: Revised
schedule, Phases I £
II Reaedial
Investigation/ Ordot
Landfill, Guta
Review of analytical
data - staples
HY0195, HY2095-2100,
HY0789-0791, HY0167
(13 waters)
Rpt: 'Addendua to
Final Saapling and
Analysis Plan for
Second Quarter of
Saapling for the
Reaedial
Investigation for
Ordot Landfill, C- <-••
300
57
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Page No.
07/01/68
ORDOT LANDFILL SUPERFUHD SITE
ORDOT, GUAM
Administrative Record File Index
DOC. I DATE
FROH/ORGANIZ.
TO/ORCANIZ.
DESCRIPTION/SUBJECT PAGES
2 06/16/87
61 02/11/88
21
46
Debra L. Bogen,
Lockheed
Engineering,
Hanageeent
Services
25 11/18/87 CD«
Kent M.
Kitchingean, EPA
Region IX
EPA Region IX
Kent M.
Kitchingaan, EPA
Region IX
Thoaas A. Mix,
EPA Region IX
EPA Region IX
Organic analytic
screen with
transeittal letter
Rpt: Final initial
•ite characterization
report, Ordot
Landfill - Island of
Guaa
Heao: Revie* of
analytical data,
saeples Y4953 to
¥4962, Y4964, Y4965,
T4795, YB196, YB199 &
YB200
Briefing docuaent:
Description of Ordot
Landfill site
Comprehensive
reiedial response
fact sheet, Insular
Territories
58
14
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SUPPLEMENT No. 1
ORDOT LANDFILL SUPERFUND SITE
Ordot, Guam
ADMINISTRATIVE RECORD WITH INDEX
(Indexed by Date)
This Supplement Was Compiled September 22, 1988 and Includes Documents 76-96
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SUPPLEMENT No. 1
ORDOT LANDFILL SUPERFUND SfTE
Ordot, Guam
ADMINISTRATIVE RECORD WITH INDEX
(Indexed by Date)
This Administrative Record Index lists the documents contained in the attached
Administrative Record Supplement No. 1 to the Administrative Record for the
Ordot Landfill Superfund Site in Ordot, Guam. The Index presents the documents
in ascending chronological order, which is consistent with the arrangement of the
documents in the Supplement itself.
The documents contained in Supplement No. 1 to the Administrative Record were
used by the U.S. Environmental Protection Agency in identifying remedial activities
appropriate for use at the Ordot Landfill Superfund Site.
Supplement No. 1 to the Administrative Record contains documents identified for
inclusion In the Administrative Record following the initial compilation, which was
placed near the site on July 11, 1988.
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Page Ho.
•9/21/88
OBDOT LANDFILL SUPERFUHD SITE
Ordot, Guaa
Adainiatrative fiecord File Index
Suppleaent Mo. 1
DOC. I DATE
FBOH/ORGANIZ.
TO/OB6ANIZ.
DESCBIPTIOR/SUEJECT
•o. of
PAGES
76 63/26/86
77 ei/ei/ee
Frank H.
Covington, EPA
Begion IX
Kathy Diehl, EPA
Begion IX
Carl J. C. Aguon,
Guaa D«pt. of
Public Work*
Bick Sugarek, EPA
Begion IX
7e ei/ei/ee
Arnold Den, EPA EPA Begion IX
Begion IX
79 63/15/88
Bick Sugarek, EPA Files
Begion IX
Cover Letter:
Tranaaittal of
attached Finding of
Violation and Order
Heeo: Coaaenta on
Proposed Beeedial
Action Plan of 6/22/88
(Document date
aaaigned for indexing;
actual date unknown)
Coaaenta on Saapling
Performed at Ordot
Landfill (Document
date aaaigned for
indexing;
actual date unknown)
Heao: teaponae to
Coaaenta Begarding
Ordot Landfill PRAP
and ISC by Begional
Senior Scientiat
66 66/22/68
81 66/24/68
Bick Sugarek, EPA
Begion IX
Jaaea L. Canto,
Guaa EPA
Jaeea L. Canto,
Guaa EPA
Faye Vaaapolli,
Pacific Dally
Reva
62 66/29/88
Jaaea L. Canto, Bick Sugarek, EPA
Guaa EPA Begion IX
Cover Letter:
Tranaaittal of
attached Propoaed
Beaedial Action Plan
(PBAP)
Letter: Publication
of Federal EPA'a
Motice on the Ordot
Landfill Superfund
Site froa the
California Rewapaper
Exchange
Letter: Coaaenta on
6/22/88 Propoaed
Beaedial Action Plan
21
-------
Pag* Ho.
89/21/66
DOC. • DATE
ORDOT LANDFILL SUPERFUND SITE
Ordot, Guaa
Adainiatrative Record File Index
Supplement Ho. 1
FROH/ORGANIZ.
TO/ORGAHIZ.
DESCRIPTIOH/SUBJECT
•o. of
PAGES
63
64
85
87
88
69
98
67/66/68
67/66/88
66/68/88
68/11/88
Jaaes L. Canto,
Guam EPA
Jane Hoppin, JCF
Clement
87/68/85 Herman L.
Lovelace, Doric
Lee-B«tuel, EPA
Region IX
67/68/88 ICF/Clement
67/68/88 Jeff Zelikaon,
EPA Region IX
Gerald F. S.
Hiatt, EPA Region
IX
Herman L.
Lovelace, EPA
Region IX
Doric Lee-Betual,
EPA Region IX
Rick Sugarek, EPA
Region IX
Files
CH2H Hill
David Roweka»p,
Harry Seraydarian
•t al
Rick Sugarek, EPA
Region IX
Rancy Boon*, U.S.
Dept. of Interior
68/13/88 Rick Sugarek, EPA File*
Region IX
Heao: Coaaents on the
Endangeraent
Assessment
Heao: Prelleinary
Diacuaaion of Leachate
for Inclusion in the
Endangeraent
Aaaeaaaent for Ordot
Landfill
Heao: Proposed
De-Listing of Ordot
Landfill froa the MPL
Report: Preliminary
Endangeraent
Aaaeaaaent for the
Ordot Landfill, Guaa
Heao: Tranaaittal of
6/22/88 Proposed
Remedial Action Plan
to EPA Managers for
Cowent
Heao: Coaeents on
Ordot Risk Aasessaent
Latter: Discussion of
Proposed Authorisation
of 41.7 Billion for
Expansion and
iaproveaent at Ordot
Landfill
Heao: Response to
Comments of Regional
Toxicologist re: Ordot
Landfill
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Page Ho.
•9/21/88
DOC. • DATE
ORDOT LANDFILL SUPEEFUND SITE
Ordot, Guaa
Adainlatratlve Record Fil« Index
Suppleaent Ho. 1
FROH/ORCAHIZ.
TO/ORGAHIZ.
DESCRIPTIOH/SUBJECT
Do. of
PAGES
91
92
93
94
95
68/17/88
68/29/88
69/66/88
69/66/88
Kelvin Okava, EPA
legion IX
Kent Kitchlngaan,
EPA Region IX
Harry
Seraydarian, EPA
Region IX
Rick Sugarek, EPA
Region IX
Lead Reviewer,
OGV
Rick Sugarek, EPA
Region IX
Jeffrey Zelikaon,
EPA Region IX
Kent Kitchingaan,
EPA Region IX
69/68/88 Jaaee L. Canto, Doria Lee-Eetuel,
Guai EPA EPA Region IX
96
69/26/88 EPA Region IX
EPA and the
Public
Heao: Review of
6/22/68 Propoaed
Remedial Action Plan
Heao: CoHent« on
Propoaed Reaedial
Action Plan for Ordot
Landfill, Guaa
He»o: Coaaent* on
Propoaed Remedial
Action Plan
Meao: Reaponae to
Concerna of 6/29/88
•eao Coaaenting on the
Propoaed Reaedial
Action Plan
Cover Letter:
Tranaiittal of Hinutea
of 7/26/88 Public
Meeting on the Ordot
Landfill Remedial
Action Plan
Reaponaiveneaa Suaaary
-------
EBCXARAIIQN FOR THE KRXRD OF DECISION"
Site: Norman Poer Farm Site
HancocJc County, Indiana
Statement of By?is and Purpose
This decision document presents the selected remedial action for the
Norman Boer Farm Site, in Hancock County, Indiana, developed in accordance
with the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, 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. This decision is based on the
contents of the Administrative Record for this site. The attached index
identifies the items that comprise the Administrative Record upon which
the selection of the remedial action is based.
The State of Indiana has concurred on the selected remedy.
No Further Action Alternative
This Record of Decision concludes that once monitoring wells have been
successfully abandoned, no further action is needed at the site. This
conclusion is based on the results of the Raredial Investigation (RI) for
the site which show that the previous' removal actions were adequate to
protect human health and the environment.
Declarat ions
The "no further action" remedy is protective of human health and the
environment, attains Federal and State requirements that are applicable or
relevant and appropriate, and is cost-effective. Without significant
contamination there is no need to satisfy the statutory preference for
remedies that employ treatment which reduces toxicity, mobility, or volume
as a principal element and utilizes permanent solutions to the maximum
extent practicable. Because this remedy will not result in hazardous'sub-
stances remaining onsite that are a threat to human health and environ-
ment, the 5-year review will not apply to this action.
DftTE Valdas V. _
^>U> Zy 1988 Regional Administrator
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