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The major components of the amended remedy for the oily sludge pit area in the source control
operable unit include:
In-situ stabilization/solidification of an estimated 9,000 cubic yards of sludge and 14,500
cubic yards of ancillary soil and debris in the oily sludge pit area capable of meeting the
more stringent performance standards for in-place management of the treated material
and protection of the Site ground water;
In-place management of the treated waste material within the area of the oily sludge pit
and ancillary soil area;
The collection and disposal of wastewater generated during the in-situ stabilization/
solidification process and construction activities; and
Implementation of appropriate fugitive emission controls during the in-situ stabilization/
solidification process.
This ROD Amendment modifies the scope of the natural soil cover to be installed on the landfill
by requiring the installation of a 2-foot thick natural soil cover over part of Area 1 of the landfill
and the treated oily sludge pit area in Area 2 of the landfill. In addition, the ground water
monitoring component identified in the 1994 ROD is now included in the remedy component for
the ground water operable unit. The remaining components of the landfill portion of the source
control remedy as identified in the 1994 ROD remain unchanged as follows:
Installation of appropriate erosion control features to minimize operation and
maintenance of the soil cover;
Installation of compensatory wetlands on-site to replace wetlands impacted during site
remediation efforts;
Placement of deed notifications or other institutional controls to ensure that any future
landowners will be notified that the land was a former Superfund site and waste has been
treated and is being managed at the site; EPA will attempt to negotiate a Consent Decree
implementing a deed restriction and/or other appropriate controls with the landowner of
the Site; and
Long-term operation and maintenance.
The major components of the selected remedy for the ground water operable unit include:
Natural attenuation of the hazardous substances in the ground water;
11
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Ground water monitoring and the installation of additional monitoring wells as
necessary;
Placement of deed notifications or other institutional controls to ensure that any future
land owners will be notified that the land was a former Superfund site and hazardous
substances remaining on-site in the ground water are above health-based concentration
levels; EPA will attempt to negotiate a Consent Decree implementing a deed restriction
and/or other appropriate controls with the landowner of the Site; and
Long-term operation and maintenance.
STATUTORY DETERMINATIONS
The amended remedy for the source control operable unit is protective of human health and the
environment, complies with Federal and State requirements that are legally applicable or
relevant and appropriate to the remedial action, nd is cost effective. This amended remedy
utilizes permanent solutions and alternative treatment or resource recovery technologies, to the
maximum extent practicable, and satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a principal element.
The selected remedy for the ground water operable unit is protective of human health and the
environment, complies with Federal and State requirements that are legally applicable or
relevant and appropriate to the remedial action, and is cost effective. The ground water
contamination does not represent a principal or low level threat at this Site. Therefore, treatment
to reduce the toxicity, mobility, or volume of contamination in the ground water is not
necessarily appropriate at this Site to achieve the remedial action objectives and goals.
Because both the source control amended remedy and the ground water remedy will result in
hazardous substances remaining on-site above health-based concentration levels, a review will
be conducted within five years of commencement of the remedial action to ensure that the
remedy continues to provide adequate protection of human health and the environment.
DATA CERTIFICATION CHECKLIST
EPA Region 6 certifies that the following information is clearly stated in the ROD Amendment:
Chemicals of concern (COC) and their respective concentrations for the ground water
operable unit;
Baseline risk represented by the COC(s) for the ground water operable unit;
111
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Clean-up level(s) established for the COC(s) and the basis for the level(s) [e.g.,
Applicable or Relevant and Appropriate Requirements ("ARARs") or risk assessment]
for the ground water operable unit;
Current and future land use assumptions from the baseline risk assessment for the ground
water operable unit;
Land use that will be available at the site as a result of the selected remedy;
Total estimated present worth, capital, and operation and maintenance (O&M) costs, and
the number of years covered by those costs; and
Decisive factors) that led to selecting the remedy (e.g., best balance of tradeoffs with
respect to the five balancing criteria).
Date
Regional Administrator
U.S. EPA Region 6
IV
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TABLE OF CONTENTS
SITE NAME, LOCATION, AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 4
HIGHLIGHTS OF COMMUNITY PARTICIPATION 5
SCOPE AND ROLE OF THIS RESPONSE ACTION 6
SUMMARY OF SITE CHARACTERISTICS 8
SUMMARY OF CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES
19
SUMMARY OF SITE RISKS 20
REMEDIATION OBJECTIVES 28
DESCRIPTION OF REMEDIAL ALTERNATIVES 31
SUMMARY OF COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES 35
SELECTED REMEDY 42
STATUTORY DETERMINATIONS 56
DOCUMENTATION OF SIGNIFICANT CHANGES 62
RESPONSIVENESS SUMMARY 63
APPENDIX A
ADPC&E CONCURRENCE LETTER 66
APPENDIX B
INDEX OF ADMINISTRATIVE RECORD 68
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LIST OF FIGURES
Figure 1 - Site Location Map 2
Figure 2 - Site Plan 3
Figure 3 - Areas for Installation of Soil Cover 11
Figure 4 - Ground Water Monitoring Well Locations 13
Figure 5 - Geologic Cross-Section 14
Figure 6 - Ground Water Elevations and Flow Direction 15
VI
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LIST OF TABLES
Tables la - If- Inorganic Contaminants in Monitoring Wells 17
Table 2 - Ground Water Contaminants of Concern 21
Table 3 - Summary of Human Exposure Assumptions for Ground Water 22
Table 4 - Weight of Evidence and Slope Factors for Oral Exposure to Ground Water
Contaminants of Concern 24
Table 5 - Ground Water Risk Characterization Summary - Carcinogens 24
Table 6 - Summary of Non-carcinogenic RfDs for Oral Exposure to Ground Water
Contaminants of Concern 25
Table 7 - Ground Water Risk Characterization Summary - Non-Carcinogens 27
Table 8 - Oily Sludge Pit Area Remedial Goals . 29
Table 9 - Ground Water Remedial Goals 30
Table 10 - Performance Criteria for Solidification/Stabilization of Waste Material 45
Table 1 la - lie- Performance Criteria for Solidification/Stabilization of Waste Material .... 46
Table 12 - Cost Estimate for the Amended Source Control Remedy 48
Table 13 - Cost Estimate for the Selected Ground Water Remedy 54
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SOUTH 8TH STREET LANDFILL SUPERFUND SITE
WEST MEMPHIS, ARKANSAS
AMENDED RECORD OF DECISION
DECISION SUMMARY
CERCLIS ID # ARD980496723
SITE NAME, LOCATION, AND DESCRIPTION
The South 8th St«»t Landfill Superfund Site ("Site"), CERCLIS ID # ARD980496723, is
located in West Memphis, Crittenden County, Arkansas. The U.S. Environmental Protection
Agency ("EPA") is the lead agency for Site activities and is issuing this Record of Decision
("ROD") Amendment. The Arkansas Department of Pollution Control and Ecology
("ADPC&E") provided technical assistance through a cooperative agreement with EPA.
EPA signed a ROD for the Site on September 29, 1994. Tn the 1994 ROD, EPA divided the Site
into a source control operable unit and a ground water operable unit. The source control
operable unit contains an oily sludge pit, which is identified as a principal threat, and a landfill
identified as a low-level threat. The selected remedy for the oily sludge pit area consisted of
excavating the waste material, stabilization, and off-site disposal in a Subtitle D landfill. The
remedy for the landfill portion included installation of a natural soil cover, institutional controls,
and long-term ground water monitoring. A remedy decision on the ground water operable unit
was deferred until additional information was collected and evaluated.
This ROD Amendment addresses both operable units by: 1) amending the remedy for the oily
sludge pit area in the source control operable unit; 2) modifying the extent of the natural soil
cover to be installed over the landfill in the source control operable unit; and 3) selecting a
remedy for the ground water operable unit. The ROD Amendment summarizes the information
that can be found in greater detail in documents contained in the Amended Administrative
Record for the Site, and will become part of the Amended Administrative Record as required by
the NCP.
The Site, which is approximately 30 acres, is located on the flood plain between the Mississippi
River and the St. Francis Levee as shown on Figure 1. Flooding of the Site is common between
the months of November through June to a maximum depth of 15 leet. Aerial photographs
indicate that the Site was excavated for gravel deposits resulting in a series of borrow pits that
were subsequently used for the disposal of industrial and municipal wastes. The former
unpermitted landfill area is approximately 16.3 acres in size and is subdivided into three separate
disposal areas as shown on Figure 2. Area 1 (4.3 acres) consists primarily of a former municipal
waste landfill. Area 2 (8.1 acres) is predominately an industrial waste landfill with a large oily
sludge pit occupying 2.5 acres of the area. Area 3 (3.9 acres) consists of several smaller
municipal and industrial waste disposal areas.
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Figure 1
Site Location Map
South 8th Street Landfill - West Memphis, Arkansas
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0 100 2SOn
^ .-; I' I
, ^ ARFA 2 I
U/SStSSffV fff\ifff
LEGEND
PROPERTY BOUNDARY
FENCE LINE
- OVERHEAD POWER UNC
MOMTOMNC «CU LOCATKM (RUOH OANtCL. It92)
PKZOMCTER LOCATION (FLUOR DAWEL. 1M2)
Figure 2
Site Plan - South 8th Street Landfill
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The Site is flanked by bottom land forest area and a police firing range along the western
boundary and a recreational vehicle ("RV") park to the north. Two barge terminals are located
at the midpoint and south end of the Site. Although security fences have been erected around
most of the Site, the public is still able to access the banks of the Mississippi River along the
gravel access road leading from South 8th Street. Land use immediately west of the St. Francis
Levee consists of industrial/petroleum storage facilities. There are currently no residential or
industrial populations within the Site boundaries. Residential areas are located approximately
*/2 mile northwest of the Site and an estimated 30,000 people live within 4 miles of the Site.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Site was first brought to the attention of the United States Government in 1979 in the
Eckhardt Survey conducted by the House Congressional Sub-Committee on Interstate
Commerce and Transportation. In this survey, the landfill was listed as the West Memphis
Landfill Site, South 8th Street.
Aerial photographs indicate that the Site was used for the disposal of waste material after 1957.
Most of the early disposal activities appear to have been conducted on a 2.61 acre parcel of land
(Area 2) leased by Mr. W. M. Gurley from the W. L. Johnson Company. Apparently, Gurley
Refining Company used the Site (Area 2) between approximately 1960 and 1970 for the disposal
of waste sludge from its re-refining process located on the land side of the St. Francis Levee
immediately west of the Site. The sludge waste in the pit has physical and chemical properties
similar to material typically identified at oil reclamation facilities.
Between 1981 and 1988, EPA conducted a series of soil boring investigations of the oily sludge
pit and surrounding landfill areas. Polycyclic aromatic hydrocarbons (PAHs), polychlorinated
biphenyls (PCBs), benzene, toluene, ethylbenzene, xylene, pesticides, and heavy metals were
detected in the samples.
A Hazard Ranking System package was prepared in August 1991. The Site was proposed for
listing on the National Priorities List ("NPL") as the "West Memphis Landfill Site" on February
7, 1992 (57 Fed. Reg. ^,827). The Site was listed final on the NPL as the "South 8th Street
Landfill Site" on October 14, 1992 (57 Fed. Reg. 47,184).
EPA issued a General Notice Letter/Information Request to 25 Potentially Responsible Parties
("PRPs") on February 7,1992. EPA evaluated the responses received and subsequently issued
Special Notice Letters to 26 PRPs on March 18,1992. Additional PRPs were added to the initial
list of PRPs based on information received from PRPs who responded to the February 7, 1992,
Information Request.
EPA issued a Unilateral Administrative Order ("UAO") to the PRPs (with the exception of the
City of West Memphis) on May 23, 1992. The UAO required the PRPs to construct a fence
around the former disposal areas and to investigate the large oily sludge pit. Construction of the
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fence was completed in July 1992. Although the PRPs initially undertook the pit investigation
on August 31,1992, EPA took over the pit investigation in September 1992 and performed the
Remedial Investigation/Feasibility Study ("RI/FS") for the Site.
EPA constructed a 1600 linear foot berm around the oily sludge pit under the CERCLA time-
critical removal authority to minimize the spread of contamination that could result from
flooding of the Site. Construction of the berm was completed between October 19, 1992 and
November 4, 1992. In May 1993, EPA determined that the most efficient manner to address the
oily sludge pit was to include the action as part of the remedial action for the entire Site.
EPA issued a Proposed Plan for the Site on July 27, 1993, and the public comment period closed
on September 24,1993. EPA signed a ROD on September 29,1994, for the source control
operable unit. By letter dated July 17,1995, EPA provided notice of its intent to conduct a pilot
Superfund cost allocation project at the Site as part of EPA's Superfund Administrative Reform
Initiative. On March 1,1996, EPA and a group of PRPs known as the South 8th Street Group
entered into an Administrative Order on Consent to cond zi the remedial design for the remedy
selected in the 1994 ROD. The PRP Group conducted field activities in 1996 and submitted the
remedial design reports in 1997.
EPA also proceeded with further characterization of the ground water to collect sufficient
information for a remedy decision on the ground water operable unit. The Remedial
Investigation ("RI") was initiated in 1995 and the final RI report was submitted on
November 22,1996. The Feasibility Study ("FS") for the ground water operable unit was
submitted on July 22, 1997.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The public participation requirements of CERCLA Sections 113(k)(B)(i-v) and 117 were met
during the remedy selection process.
EPA mailed to the local citizens and elected officials a fact sheet dated September 20,1996,
summarizing the status of the remedial design activities at the Site. EPA followed this with a
second fact sheet dated June 9, 1997, addressing both the remedial design activities at the Site
and a proposed change in the 1994 ROD remedy being evaluated by EPA and the South 8th
Street PRP Group. On June 10, 1997, EPA and ADPC&E met separately with City of West
Memphis officials, members of the local community group WIN (West Memphians Involving
Neighbors), and a reporter from the West Memphis Evening Times to discuss the Site activities
and the proposal to change the 1994 ROD remedy. A follow up meeting with the WIN group
was held on August 4,1997, to discuss the results of recent treatability testing by the South 8th
Street PRP group.
The public comment period for the Proposed Plan and Amended Administrative Record was
held from January 5, 1998, through February 4,1998. The notice of availability for these
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documents was published in the West Memphis Evening Times newspaper on January 4 and 5,
1998, and the Memphis Commercial-Appeal newspaper on January 4, 1998. The Amended
Administrative Record containing reports, documents, and correspondence related to the Site
was made available for review during the public comment period at the West Memphis Public
Library, the offices of ADPC&E in Little Rock, Arkansas, and at the EPA Region 6 offices in
Dallas, Texas.
A formal Public Meeting was held on January 26, 1998, at the West Memphis Neighborhood
Center located at the intersection of 14th and Polk Street. At this meeting, representatives from
EPA received comments and answered questions about the Site. Representatives from
ADPC&E presented information on environmental issues in West Memphis and responded to
community concerns. Representatives from the Arkansas Department of Health addressed
health-related issues from the community. A response to the comments received during the
public comment period is included in the Responsiveness Summary at the end of the ROD
Amendment.
This decision document presents the selected remedial action for the South 8th Street Landfill
Site, in West Memphis, Arkansas, chosen in accordance with CERCLA, as amended by SARA,
and to the extent practicable, the National Contingency Plan. The decision for this Site is based
on the Amended Administrative Record and the index is included as Appendix B to the ROD
Amendment.
SCOPE AND ROLE OF THIS RESPONSE ACTION
This Amended ROD provides a comprehensive Site cleanup strategy by selecting a remedy for
the ground water operable unit and amending the 1994 ROD remedy for the source control
operable unit. The source control operable unit contains an oily sludge pit and ancillary soil
which have been identified as a principal threat at the Site because these wastes, if left
unaddressed, would continue to present an acute threat to the public health and the environment.
This waste was identified as a principal threat based on the corrosive characteristic (pH < 2) and
high concentrations of toxic compounds. The landfill contains municipal and industrial waste
which has been identified as a low level threat to public health. The landfill contents pose a low-
level health risk because of the lower potential for these areas to impact human health and the
environment through direct contact or long-term exposure in the environment.
The source control remedy selected in the 1994 ROD included the following components:
Oily Sludge Pit
Excavation of an estimated 10,000 cubic yards of sludge and 12,000 cubic yards of
contaminated soil, and debris within the oily sludge pit area;
Treatment of contaminated water generated during the excavation of the contaminated
material;
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Pretreatment of the contaminated material as necessary to facilitate material handling
operations;
Separation and cleansing of contaminated debris and disposal of same in a Subtitle D
landfill located off-site;
Backfill of the areas that are excavated with clean soil;
Treatment of the contaminated sludges and soils in the oily sludge pit via
stabilization/solidification technology;
Disposal of treated sludge and contaminated soil in a Subtitle D landfill located off-site.
Landfill
Placement of a natural soil cover that complies with the State of Arkansas Solid Waste
Management Code over the former disposal areas;
Installation of appropriate erosion control features to minimize operation and
maintenance of the soil cover;
Placement of deed notifications to ensure that any future landowners will be notified that
the land was a former Superfund Site and has been cleaned up in accordance with
CERCLA;
Ground water monitoring;
Long-term operation and maintenance;
In the 1994 ROD Responsiveness Summary, EPA noted that there was uncertainty as to whether
stabilization would effectively immobilize the organic contaminants present in the waste. Under
the 1996 Administrative Order on Consent ("AOC") for Remedial Design at the Site, the PRP
Group performed a treatability study to evaluate the stabilization/solidification technology for
both ex-situ treatment (1994 ROD remedy) and in-situ treatment of the oily sludge pit. Results
of the treatability testing indicated that the in-situ stabilization/solidification technology is a
viable alternative for remediation of the oily sludge pit. EPA evaluated the implementation of
in-situ stabilization/solidification against both the original remedial objectives and goals for the
oily sludge pit as well as new performance standards to prevent future impacts to the Site ground
water. EPA also evaluated additional information regarding the extent of existing clean soil
cover on the landfill and whether the requirement for the installation of an additional 2 feet of
soil cover could be reduced.
The 1993 RI performed at the Site did not collect sufficient ground water data to determine
whether the hazardous substances present in the ground water posed a threat to human health and
the environment or what actions may be taken to address any such threats. EPA has completed
the additional characterization and this ROD Amendment will address the ground water
contamination at the Site. Following successful remedy implementation at the source control
operable unit, remedial action will be implemented at the ground water operable unit to address
hazardous substances that have already leached into the ground water.
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SUMMARY OF SITE CHARACTERISTICS
Source Control Operable Unit
The 1996 AOC includes a statement of work outlining the technical approach for the remedial
design of the 1994 ROD remedy. The remedial design included additional characterization of
the source control operable unit to generate the data necessary to facilitate the detailed
engineering design. This additional characterization supplemented the information gathered
during the 1993 RJ. The studies included further characterization of the oily sludge pit and
ancillary soils, a stabilization/solidification treatability study of the oily sludge material, a
landfill cover assessment, and a landfill gas assessment. Field activities were conducted in 1996
and the remedial design reports were submitted in 1997.
Oily Sludge Pit and Ancillary Soils
Four test pits excavated in the oily sludge pit re .aled a dense, black, tarry sludge with little free
liquid and no significant amounts of debris or stratification. Ground water in contact with the
sludge had a pH of zero. Air monitoring during the test pit excavations identified hydrogen
sulfide and sulfur dioxide as the major emissions with peak concentrations at approximately 30
to 40 parts per million ("ppm"). Volatile organic compounds were also infrequently detected at
approximately 1.2 to 7.5 ppm. Four test pits excavated in the ancillary soils adjacent to the oily
sludge pit revealed industrial landfill material with layers of oily stained material mixed with
soil. In addition to the test pits, 13 borings verified the horizontal and vertical extent of the
ancillary soils defined in the 1994 ROD.
Treatability Testing
The stabilization/solidification treatability study of the oily sludge waste evaluated both the
excavation and treatment process selected in the 1994 ROD ami an alternative process utilizing
in-situ stabilization/solidification. The in-situ process is performed using augers or mixing units
to mix the reagents with the waste while the material is still inside the pit area. The results of
the physical and chemical testing are presented in the "Treatability Study Evaluation Report -
Preliminary Design Submittal" dated February 5,1997, "Supplemental Treatability Study
Report" dated July 1997, and summary letter of September 29, 1997.
Because the stabilization treatment standards identified in the 1994 ROD are not protective of
the Site ground water, alternative treatment standards are necessary to address any leachate
generated by the treated waste material during the periods of Site flooding or the fluctuating
ground water table. The alternative treatment standards are established to minimize the amount
of leachate and ensure that contaminants found in the leachate do no adversely impact the
ground water quality. These criteria are:
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A more stringent performance criteria of 1x10"6 cm/sec for the permeability of treated
waste;
Contaminant concentrations in a leachate extracted from treated waste sample using the
Synthetic Precipitation Leaching Procedure ("SPLP"), Method SW-846 1312, cannot
exceed ground water maximum contaminant levels ("MCLs") established under the
Federal Safe Drinking Water Act, or background ground water concentrations whichever
is higher; and
pH for the treated waste within the range of 7 < pH <; 11.5. Contaminants present in the
treated waste, e.g., lead, may preferentially leach out of the treated waste material above
apHof1lc.
The ability to achieve these alternative performance standards has been successfully
demonstrated by mixing the waste material with different reagents supplied by vendors
contracted by the PRP Group. However, due to the expected variability in the metal
concentrations in the sludge, particularly lead, an allowable range of the SPLP results is
necessary to allow for some limited variability in the trer 2d material. For this Site, an
allowance is made for 20 percent of the samples collected from the treated oily sludge material
to exceed the SPLP criteria by a factor of two times, and 10 percent of the samples to exceed the
criteria by a factor of five times. This allowance will still provide for a leachate generated by
the treated waste to meet the Site ground water standards while providing for variances in the
treatment process.
Landfill Cover Evaluation
One of the remedial action objectives for the landfill area in the source control operable unit is to
prevent direct contact with and ingestion of the landfill contents. In addition, the closure
requirements for permitted and unpermitted landfills under the Arkansas Solid Waste
Management Code are an ARAR for this Site. To meet the remedial action objective and the
ARAR, the 1994 ROD stipulated the installation of a 2-foot thick natural soil cover capable of
supporting vegetation over the landfill area. As part of the remedial design activities under the
1996 AOC, the PRP Group was required to further evaluate the existing landfill cover and
identify potential source areas for material to cover the landfill. The results of the assessment
and field work is presented in the "Landfill Cover Evaluation Report - Preliminary Design
Submittal" dated February 5, 1997.
Evaluation of the existing landfill cover included a review of historic aerial photographs and the
excavation of shallow trenches in the upper two feet of the landfill soil cover. These trenches
provide additional data to supplement the information collected during the 1993 RI. The landfill
contents consisting of industrial and municipal solid wastes are mixed within the flood plain clay
deposit in Areas 1,2, and 3. Soil trenching revealed at least 2 feet of native soil with minimal
amounts of landfill waste material/debris in parts of Area 1, Area 2 outside the oily sludge pit
and ancillary soils, and throughout Area 3.
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EPA conducted additional soil sampling and analyses in May 1997 to verify that the apparent
2-foot soil cover did not contain contaminant concentrations that posed a risk to human health.
The contaminants identified in the 1994 ROD that contributed to the excess risk are carcinogenic
PAHs, pesticides (including toxaphene, DDD, DDE, and DDT, PCBs) and the inorganic
compounds, arsenic and beryllium. Analyses of soil samples did not detect any organic
chemicals, including PAHs and pesticides, which formed the principal risk to human health at
the Site. Similarly, the concentration of arsenic and beryllium were below the range identified
from the 1993 RI and did not pose a risk to human health. Consequently, reduction of the aerial
extent of the landfill cover will still meet the criteria for prevention of direct contact with and
ingestion of the landfill contents. The selected areas of the landfill requiring the installation of a
2-foot soil cover is shown in Figure 3.
Landfill Gas Evaluation
The 1994 ROD description of Alternative 3, Natural Soil Cover in Conjunction with Institutional
Controls, referenced the low concentrations of landfi'l gas detected during the 1993 RI as the
rationale for not lequiring a landfill gas collection system. However, the 1994 ROD also
stipulated that additional data collection and review during the remedial design may determine
that a landfill gas collection system is necessary. The 1996 AOC required the PRP Group to
perform a landfill gas evaluation to determine the presence of landfill gas or the potential future
buildup of landfill gas which may require the installation of a landfill gas collection system.
During the remedial design activities, three landfill gas probes were installed in Areas 1, 2, and 3
for a total of nine gas probes at the Site. The probes were installed with a ten foot screen from a
depth of 3 to 13 feet below the ground surface. Air monitoring during installation of the gas
probes did not detect volatile organic compounds using a photoionization detector or hydrogen
sulfide and sulfur dioxide using chemical specific detectors. Two subsequent gas monitoring
events of the probes did not detect methane, carbon monoxide, or hydrogen sulfide. Based on
the results of the landfill gas evaluation, a landfill gas collection system is not required as part of
the amended remedy for the source control operable unit.
Ground Water Operable Unit
EPA designated the ground water as a separate operable unit in the 1994 ROD, and initiated a RI
for the ground water operable unit in 1995. The results of the investigation are presented in the
September 30, 1996 RI Report for the ground water operable unit. The focus of the 1996 RI was
to evaluate background water quality in the alluvial aquifer, determine the nature and extent of
the inorganic contamination in the ground water, and determine the physical properties of the
aquifer to assess contaminant fate and transport. EPA determined that only inorganics would be
the focus of the ground water RI based on the results of ground water sampling during the 1993
RI. The 1993 ground water sample analyses did not detect volatile organic contaminants,
pesticides, or PCBs above detection limits. Semi-volatile organic contaminants detected during
the sampling are considered attributable to laboratory contamination or were reported below the
analytical method detection limit. The 1993 risk assessment performed for the Site identified
10
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MISSISSIPPI RIVER
Figure 3
Areas for Installation of Soil Cover - South 8th Street Landfill
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arsenic and beryllium as contaminants of potential concern for consideration in ground water.
Subsequent ground water samples collected in May and August of 1997 verified that only
inorganic contaminants are present in the ground water. Monitoring wells were installed at the
Site to determine the impact of contaminants leacliing from the landfill and oily sludge pit into
the ground water. Site characterization performed under the 1993 RI included the installation of
nine (9) monitoring wells. Five (5) additional monitoring wells were installed during the 1996
RI. The fourteen (14) monitoring wells (locations are shown on Figure 4) include: 1) eight
shallow wells (e.g., MW 3S) which monitor a depth of 10 to 35 feet below ground surface to
account for the fluctuating water table; three (3) intermediate wells (e.g., MW 31) which monitor
a depth of 50 to 70 feet below ground surface; and three deep wells (e.g., MW 3D) which
monitor a depth of approximately 135 to 145 feet below ground surface at the base of the
alluvial aquifer. Six of the monitoring wells (MW3S, 31, 3D, 4S, 41 and 8S) are located near the
oily sludge pit. Two wells (MW1S, ID) monitor background water quality unaffected by Site
conditions.
The geologic conditions beneath the Site were c iluated from data collected during the
installation of the monitoring wells. The Site is located on a flood plain clay deposit ranging in
thickness from 5 to 15 feet at the surface. Below this clay unit, the sediments consist of clayey
silts with minor amounts of sand and gravel to an approximate depth of 20 to 30 feet below
ground surface. The clayey silts grade downward into a fine sand that continues to coarsen with
depth into a basal gravel layer. The Jackson Clay is a local confining unit that underlies the
alluvial aquifer and is present at an approximate depth of 120 to 150 feet beneath the ground
surface. A geologic cross-section of the Site is shown on Figure 5.
Ground water levels, flow direction, and the hydraulic gradient in the unconfined alluvial aquifer
fluctuate seasonally with the rise and fall of the adjacent Mississippi River. The water table
varies between 5 feet and 30 feet below the ground surface. Figure 6 illustrates flow direction
and elevation when the ground water flows toward the river during the low river stage. The
flow direction is reversed during seasonal flooding events at the Site.
During the 1996 RI, four rounds of ground water samples were collected from the fourteen
monitoring wells, two irrigation wells located in the county, and one upstream and one
downstream location in the Mississippi River adjacent to the Site. These four rounds of samples
were analyzed for the Target Analyte List metals and selected water quality parameters. Ground
water samples for metals analysis were both filtered and unfiltered. Analytical results from the
unfiltered samples were used to support the risk assessment. Two additional rounds of samples
were collected from the fourteen monitoring wells and two river locations in May and August of
1997 and analyzed for the Target Analyte List metals, volatile organics, and semi-volatile
organics. The six rounds of samples were collected between June 1995 and August 1997.
Monitoring wells MW 3S, 31, 3D, 4S, 41, and 8S nearest the oily sludge pit contained inorganic
contaminants, principally lead, arsenic, manganese, aluminum, and barium (Tables la - If).
Lead was generally detected at concentrations of 2 //g/1 or less across the Site.
12
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£a£:2-~
\ T':i
MISMSS1PPI RIVER
Figure 4
Ground Water Monitoring Well Locations - South 8th Street
-------
SCREENED
INTERVAL
TO-TOTAL DEPTH(ELEVATION)
BS-BASE OF SCREEN
__^ KNOWN CONTACT
INFERRED CONTACT
NOT TO SCALt
WATER LEVEL (MICH tt LOW)
Figure 5
Geologic Cross-Section - South 8th Street Landfill
-------
LEGEND .
0 NEW MONITORING WCLL
0UONITORINC WELL
SURFACE WATER SAMPLE PONT
P PIEZOMETER
^ BENCH MARK
P POWER LINE
~^_--. ' 'SEE UNC
// CHAIN LINK FENCE
^ GROUND WATER FLO*
TIRING RANGE
MISSISSIPPI RIVER
Figure 6
Ground Water Elevations and Flow Direction - 2nd Quarter (9/95) - South 8th Street Landfill
-------
However, samples collected in May 1997 from the wells surrounding the oily sludge pit had lead
concentrations ranging from 19 to 133 /ug/1 in the shallow, intermediate, and deep intervals
within the aquifer. This sampling event was conducted after the Site had been flooded in March
and April of 1997 and the water level in the aquifer was approximately 10 feet below the ground
surface and flow direction was variable across the Site. The oily sludge pit contains high
concentrations of lead (maximum detected concentration of 33,600 mg/1) and is the likely source
of lead in the ground water. However, lead concentrations had returned to 2 /^g/1 in the same
wells during August 1997 after the water table had dropped approximately 15 feet
(approximately 25 feet below ground surface) and the ground water was flowing toward the
Mississippi River.
Manganese exceeded the background concentration of 614 /^g/1 in all wells surrounding the oily
sludge pit except in the deep monitoring well MW-3D. The highest concentrations were
observed in well MW 8S with a range of 3,190 to 11,200 /^g/1. The peak concentrations in well
MW 8S were detected in September 1995 and August 1997 when the water table was at its
lowest elevation and the ground water was flo1 Ing toward the Mississippi River. Similarly, well
MW 4S also detected peak concentrations during the same sampling events. Both wells are
downgradient of the oily sludge pit when the ground water flow is toward the river.
Arsenic was generally detected at concentrations less than 10 ,ug/l in all wells with the exception
of well MW 8S. Arsenic concentrations in well MW 8S fluctuated between 27 to 227 /^g/1 with
the highest concentrations also occurring in September 1995 and August 1997.
The oily sludge pit contains high concentrations of arsenic and manganese and the pit is the
principal source of the manganese and arsenic observed in the monitoring wells. However,
similar concentrations of arsenic and manganese were also detected in a sample collected from
one trench (TR 3.4) excavated to a depth of 12 feet in the landfill approximately 200 feet from
well MW 8S. Other nearby trenches did not detect similar manganese and arsenic
concentrations in the soil. This area of the landfill is upgradient of Well MW 8S during the
September 1995 and August 1997 sampling events and may represent a secondary source of the
arsenic and manganese concentrations observed in well MW 8S.
Barium was detected above the background concentration of 587 //g/1 only in well MW 3D with
a range of 1210 to 1610 /^g/1. Beryllium was present at or below background concentrations in
all monitoring wells. Aluminum was also detected in the shallow and intermediate intervals of
the aquifer with concentrations ranging below the background concentration of lOl /^g/1 to a
high of 6410 /^g/1. Organic contaminants were not detected in the ground water samples
collected during the 1993 RI, or in the supplemental sampling of May and August 1997.
16
-------
Table la
Inorganic Contaminants in Monitoring Well MW-3S
Parameter
Arsenic
Manganese
Lead
Barium
Beryllium
Site
Background
(ug/1)
10.6
614
1.7
587
0.76
Sample Results (ug/1)
1993 Rl
1.1
1790
0.9
475
16
Qtr. 1
(6/95)
2.3
948
1.2
268
L 0.76
Qtr. 2
(9/95)
3.8
1170
147
230
0.4
Qtr. 3
(12/95)
3.4
1380
0.9
330
0.2
Qtr. 4
(3/96)
3.7
1470
1
318
0.5
Qtr. 5
(5/97)
2.1
28.7
27.6
148
0.1
Qtr. 6
(8/97)
4
560
2
197
1
Table Ib
Inorganic Contaminants in Monitc...ig Well MW-3I
Parameter
Arsenic
Manganese
Lead
Barium
Beryllium
Site
Background
(ug/1)
10.6
614
1.7
587
0.76
Sample Results (ug/1)
Qtr. 1
(6/95)
9.1
1360
1.2
496
0.5
Qtr. 2
(9/95)
3.8
980
3.9
349
0.4
Qtr. 3
(12/95)
2.7
762
0.9
465
0.2
Qtr. 4
(3/96)
3.7
756
1
501
0.5
Qtr. 5
(5/97)
6.4
848
31.4
302
0.1
Qtr. 6
(8/97)
4.3
1250
2
498
1
Table Ic
Inorganic Contaminants in Monitoring Well MW-3D
Parameter
Arsenic
Manganese
Lead
Barium
Beryllium
r-.e
Background
(ug/1)
10.6
614
1.7
587
0.76
Sample Results (ug/1)
1993 RI
I.I
85.3
0.9
1210
0.6
Qtr. 1
(6/95)
2.3
97.1
1.2
1610
0.77
Qtr. 2
(9/95)
3.8
73.6
1.7
1520
0.4
Qtr. 3
(12/95)
2.7
70.4
0.9
1510
0.6
Qtr. 4
(3/96)
3.7
68
1.2
1480
0.5
Qtr. 5
(5/97)
2.1
66.7
19.1
1390
0.1
Qtr. 6
(8/97)
4
66.6
2
1450
1
17
-------
Table Id
Inorganic Contaminants in Monitoring Well MW-4S
Parameter
Arsenic
Manganese
Lead
Barium
Beryllium
Site
Background
(ug/l)
10.6
614
1.7
587
0.76
Sample Results (ug/l)
1993RI
1.1
476
0.9
121
1.1
Qtr. 1
(6/95)
2.3
28.3
1.2
104
0.5
Qtr. 2
(9/95)
3.8
1140
1.7
181
0.4
Qtr. 3
(12/95)
2.7
85.8
0.9
159
0.2
Qtr. 4
(3/96)
3.7
32.1
1
128
0.5
Qtr. 5
(5/97)
2.1
3.9
107
114
0.1
Qtr. 6
(8/97)
4
2660
2
204
1
Table le
Inorganic Contaminants in Monitoring Well MW-41
Parameter
Arsenic
Manganese
Lead
Barium
Beryllium
Site
Background
(ug/0
10.6
614
1.7
587
0.76
Sample Results (ug/l)
Qtr. 1
(6/95)
2.3
1070
1.7
197
0.4
Qtr. 2
(9/95)
3.8
2980
1.7
263
0.4
Qtr. 3
(12/95)
2.7
2210
0.9
194
0.2
Qtr. 4
(3/96)
3.7
2010
2.1
171
0.5
Qtr. 5
(5/97)
2.1
2310
133
193
0.1
Qtr. 6
(8/97)
4
8.4
2
145
1
Table If
Inorganic Contaminants in Monitoring Well MW-8S
Parameter
Arsenic
Manganese
Lead
Barium
Beryllium
Site
Background
(ug/l)
10.6
614
1.7
587
0.76
Sample Results (ug/l)
Qtr. 1
(6/95)
27
5850
1.2
305
0.5
Qtr. 2
(9/95)
227
11200
7.3
510
0.4
Qtr. 3
(12/95)
55
5220
0.9
286
0.2
Qtr. 4
(3/96)
68
5510
1.3
262
0.5
Qtr. 5
(5/97)
53.2
3190
45.7
236
0.1
Qtr. 6
(8/97)
138
8130
2
300
1
18
-------
The estimated rate of ground water discharge to the Mississippi River is approximately 14.46
cubic feet per second (cfs) while the flow rate of the river ranges from 78,000 to 2,000,000 cfs.
The high flow rate of the river is such that the concentration of contaminants in the ground water
is diluted upon entrance to the river.
EPA's Ground water Protection Strategy and Classification Guidelines define the various ground
water classes based on the ground water use. There are no known populations currently
obtaining drinking water from the shallow alluvial aquifer. The RV park does utilize an
irrigation well located north of the camping area but obtains drinking water from the City of
West Memphis. Because the aquifer is not considered irreplaceable (i.e. no reasonable
alternative source of drinking water would be available to substantial populations) nor
ecologically vital to any habitat, the Class I classification can be eliminated. The aquifer does
not have a total dissolved solids value of 10,000 mg/L or higher eliminating the Class III
classification. The aquifer is not currently being used, eliminating the Class IIA classification.
However, there is potential for drinking, agriculture, or other beneficial uses, and is best
classified as Class IIB.
SUMMARY OF CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES
The Site is located on the flood plain between the Mississippi River and the St. Francis levee and
is anticipated to flood every year to a maximum depth of 15 feet. The Site is currently zoned for
industrial use and two barge terminals on the Mississippi River are located at the midpoint and
southern end of the Site. The barge terminals are not manned on a regular basis and the workers
are present only when a barge is expected. There are currently no other industrial or residential
populations within the Site boundaries. Future industrial or residential development on the Site
is unlikely since the Site may flood to a depth of 15 feet and such development should be
avoided or minimized in areas considered as flood plains and/or wetlands (40 CFR 6).
Adjacent land use consists of a RV park to the north of the Site. The RV park is generally
occupied from late April or early May (depending upon the flood season) until mid-November.
The RV park is currently separated from the Site bv a fence. Recreational use of the Site is a
possible land use scenario based on the adjacent RV park and the Site had at one time been
considered for a State park.
There is no cuirent ground water usage within the Site boundary. The adjacent RV park is
connected to the water supply from the City of West Memphis, but does utilize an irrigation well
located north of the camping area to obtain water from the alluvial aquifer. There are no known
populations currently obtaining drinking water from the alluvial aquifer. The drinking water
supply for the City of West Memphis is obtained from wells withdrawing water from the Wilcox
Formation at an approximate depth of 1500 feet, approximately 2 miles north of the Site. The
Jackson Clay separates the West Memphis water supply from the alluvial aquifer.
19
-------
The alluvial aquifer can be classified as a Class IIB, with a potential for drinking, agriculture, or
other beneficial use. If a possible land use scenario involving development of the property as a
multi-use recreational park were to occur, the alluvial aquifer has the potential to supply
drinking water to park visitors or park workers. However, since there are no known populations
obtaining drinking water from the alluvial aquifer, and the City of West Memphis currently
supplies drinking water to the adjacent RV park, there is no anticipated usage of the alluvial
aquifer as a drinking water supply within the immediate future.
The discharge of ground water from the alluvial aquifer beneath the Site is not considered to be
ecologically vital to any habitat or the adjacent Mississippi River.
SUMMARY OF SITE RISKS
The baseline risk assessment provides the basis for taking action and indicates the exposure
pathways that need to be addressed by the remedial action. It serves as the baseline indicating
what risks could exist if no action were taken at .lie Site. This section of the Amended ROD
reports the results of the baseline risk assessment conducted for the ground water operable unit.
EPA had previously prepared a baseline risk assessment to evaluate risks to human health
associated with hazardous substances from the landfill and the oily sludge pit. A summary of
the risk assessment for the source control operable unit is presented in the 1994 ROD.
Ground Water Operable Unit
A ground water baseline risk assessment was prepared to evaluate the potential risks to human
health from hazardous substances in the ground water. Human health risks are determined by
comparing actual contaminant concentrations at a Site to the exposure concentration known to
have an adverse impact. In the baseline risk assessment, both carcinogenic and non-carcinogenic
risks are calculated using conservative assumptions that weigh in favor of protecting human
health. The ground water baseline risk assessment supplements the landfill and oily sludge pit
(source control operable unit) baseline risk assessment by recalculating the previous risk
estimates (utilizing the additional sampling data) associated with exposures to ground water at
the Site.
The risk assessments conducted at the Site do not use either residential or industrial exposure
scenarios because the frequent flooding of the Site precludes the use of such typical scenarios.
The establishment of a residence or a business (other than the barge transfer operations) is highly
unlikely since such development should be avoided or minimized in areas considered as flood
plains and/or wetlands (40 CFR Part 6).
EPA has determined that it is appropriate to use a site specific recreational setting in order to
develop the exposure scenario for the baseline risk assessment. The recreational scenario is
based on the adjacent RV park and past consideration of the Site as a State park. Visitors from
the nearby RV park had access to the Site before it was fenced. Current visitors and workers at
20
-------
the RV park would not be exposed to Site ground water since potable water for the RV park is
supplied from a pipeline from the City of West Memphis. The 1994 ROD also utilized this
recreational exposure scenario in evaluating potential risks from contaminants in the source
control operable unit.
Since the Site could be developed as a multi-use recreational park, a hypothetical future
recreational worker (i.e., adult worker at the Site) and recreational visitor (i.e., both adult and
child visitor) could be exposed to contaminated ground water if potable water were to be
supplied from on-site wells. The potential pathways of exposure to contaminants in the ground
water include inge°*:on by the future recreational worker (it is assumed that the recreational
worker will not shower at the Site) and ingestion and dermal contact by the future recreational
visitor. Exposure via inhalation was not a concern since there were no volatile organic
chemicals detected in the ground water.
The contaminants of concern ("COCs") are chemicals present in the ground water at the Site that
could pose a risk of adverse health effects to exposed hur an populations obtaining water from
on-site wells. The COCs were identified from the analyses of unfiltered ground water samples
collected from the shallow monitoring wells (MW-1S through MW-8S); intermediate
monitoring wells (MW-3I, MW-4I, and MW-6I); and deep monitoring wells (MW-1D, MW-3D,
and MW-6D). A chemical was eliminated from consideration as a COC based on nondetection,
infrequent detection, and nutrional essentiality.
An exposure point (i.e., a drinking water well installed on-site) is an area where humans are
expected to come in contact with the contaminated ground water. The landfill is divided into
Areas 1,2, and 3 (see Site Characterization), and the monitoring wells were assigned to either
Area 1 or Area 2/3 of the landfill in order to assess potential differences that could exist if
potable water were drawn from wells in different areas of the landfill. The use of separate
exposure points for Area 1 and Area 2/3 is consistent with the base-line risk assessment utilized
in calculating the risk for the source control operable unit as presented in the 1994 ROD. The
exposure point concentrations (EPCs) for each COC in Area 1 and Area 2/3, is defined as the
maximum arithmetic mean of all wells in the area. The chemicals identified as COCs and their
respective EPCs at the Site are listed in Table 2.
Table 2
Ground Water Contaminants of Concern
Chemical
Aluminum
Arsenic (c)
Barium
Exposure Point Concentrations (ug/L)
Areal
135
4.5
775
Area 2/3
1610
94.6
1290
21
-------
Table 2
Ground Water Contaminants of Concern
Chemical
Beryllium (c)
Cadmium
Cobalt
Cyanide
Iron
Lead
Manganese
Mercury
Nickel
Vanadium
Exposure Point Concentrations (ug/L)
Area 1
0.6
1.92
8.71
2.57
9770
13.3
352
9.40xlO'J
17.7
9.44
Area 2/3
0.746
2.53
9.09
11.6
35900
36.2
6950
0.2
19.5
16.1
(c) carcinogen for oral ingestion
Exposure to the COCs was quantified through the use of standard exposure factors, except for
the exposure frequency and duration which were adjusted to match the future recreational
scenario developed for the Site (Table 3). Although the risk from both the average and
reasonable maximum exposure (RME) scenarios were calculated in the risk assessment, the
RME risks were used to evaluate threats at the Site because current EPA policy mandates the use
of the RME when evaluating the need for response actions at Superfund sites. RME risks are
greater, and thus more conservative, than average risks.
Table 3
Summary of Human Exposure Assumptions for Ground Water
Parameter
Body weight, kg
Exposure Frequency,
days/year
Exposure Duration, year
Future Adult Recreational
Worker
Average
70
152
9
RME
70
250
25
Future Recreational
Visitor - Child
Average
16
7
6
RME
16
28
6
Future Recreational Visitor -
Adult
Average
70
7
9
RME
70
28
30
22
-------
Table 3
Summary of Human Exposure Assumptions for Ground Water
Parameter
Average Time
(noncancer), year
Average Time (cancer),
year
Ground Water Intake
Rate, L/day
Exposure Time, dermal,
min/day
Future Adult Recreational
Worker
Average
9
70
0.7
-
RME
25
70
t
-
Future Recreational
Visitor - Child
Average
6
-
0.7
7
RME
6
--
1
12
Future Recreational Visitor -
Adult
Average
9
70
1.4
7
RME
30
70
2
12
For carcinogens, risks are generally expressed as the incremental probability of an individual
developing cancer over a life-time as a result of exposure to the carcinogen. Excess life-time
cancer risk is calculated from the following equation:
Risk = GDI x SF
where: risk = a unit less probability (e.g., 2 x 10'5) of an individual developing cancer
GDI = chronic daily intake averaged over 70 years (mg/kg-day)
SF = slope factor, expressed as (mg/kg-day)'1
These risks are probabilities that usually are expressed in scientific notation (e.g., 1 x lO'6). An
excess lifetime cancer risk of 1 x 10"6 indicates that an individual experiencing the reasonable
maximum exposure estimate has a 1 in 1,000,000 chance of developing cancer as a result of site-
related exposure. This is referred to as an "excess lifetime cancer risk" because it would be in
addition to the risks of cancer individuals face from other causes such as smoking or exposure to
too much sun. A cumulative risk estimate above 1 x lO'6 (but less than or equal to 10"4) may be
acceptable, if justified based on site-specific conditions, the level of certainty in the nature and
extent of impact (level of certainty in the site characterization and analytical data), the level of
certainty in the nature and extent of exposure, the level of confidence in the risk assessment
results, and technical factors.
The weight of evidence for the carcinogenic COCs and the corresponding SFs are provided in
Table 4.
23
-------
Table 4
Weight of Evidence Carcinogenic Effects and Slope Factors for Oral Exposure to
Ground Water Contaminants of Concern
Chemical
Arsenic
Beryllium
Lead
Weight of Evidence
A
(Known Human Carcinogen)
B2
(Probable Human Carcinogen)
B2
(Probable Human Carcinogen)
Slope Factor (mg/kg/day)'1
1.5
4.3
--
The lifetime excess cancer risk for future recreational workers in Area 1 is estimated to be
3 x 10'5 (RME), taking into account the risks from COCs in ground water via oral ingestion.
This risk is within EPA's acceptable risk range of 1 x 10"4 to 1 x 10'6 (Table 5).
The lifetime excess cancer risk for future recreational workers in Area 2/3 is estimated to be
5 x 10"* (RME), taking into account the risks from COCs in ground water via oral ingestion.
This risk exceeds EPA's acceptable risk range of 1 x 10"4 to 1 x 10"*. The primary COC which
contributes to the excess cancer risk is arsenic (Table 5).
The lifetime excess cancer risk for future recreational visitors is estimated to be 9 x 10"* (RME)
for Area 1 and 1x10"* (RME) for Area 2/3 taking into account the risks from COCs in ground
water via oral ingestion and dermal contact. The primary risks from each COC are associated
with oral ingestion. The excess cancer risk is within EPA's acceptable risk range of 1 x 10" to
Table 5
Ground Water Risk Characterization Summary - Carcinogens
South 8th Street Landfill - Ground Water Operable Unit
Exposure Scenarios That Trigger the
Need for Cleanup
Future Adult Recreational Worker
Exposure to Ground Water from
Aquifer Via Ingestion
Future Adult Recreational Visitor
Exposure to Ground Water from
Aquifer Via Ingestion and Derma)
Contact
Chemical
Arsenic
Beryllium
Total
Arsenic
Beryllium
Total
Carcinogenic Risk
Area 1
Average
4x IO-*
1x10-*
5X10-6
3 x 10-'
1 x 10-'
4 x ID'7
Area 1 RME
2 x 10-'
9x 10-6
3 x 10-'
6x10-*
3x 10-*
9x IO-6
Area 2/3
Average
8 x 10 '
2x10-*
8 x 10 '
TxlO-6
2 x lO'7
7x 10"*
Area 2/3
RME
5x10-"
1 x 10-'
SxlO-1
1 x 10^
4x ID"6
Ix 10-*
24
-------
The potential for non-carcinogenic effects is evaluated by comparing an exposure level over a
specified time period (e.g., life-time) with a reference dose (RfD) derived for a similar exposure
period. An RfD represents a level that an individual may be exposed to that is not expected to
cause any harmful effect (Table 6). Estimated intakes of COCs from environmental media (e.g.,
the amount of a COC ingested from contaminated ground water) can be compared to the RfD.
The ratio of exposure to toxicity is called a hazard quotient (HQ). A HQ < 1 indicates that a
receptor's dose of a single contaminant is less than the RfD, and that toxic non-carcinogenic
effects from that chemical are unlikely. The Hazard Index (HI) is generated by adding the HQ's
for all chemicals of concern that affect the same target organ (e.g., liver) within a medium or
across all media t" which a given population may reasonably be exposed. A HI < 1 indicates
that, based on the sum of all HQ's from different contaminants and exposure routes, toxic non-
carcinogenic effects from all contaminants are unlikely. A HI > 1 indicates that site-related
exposures may present a risk to human health.
The HQ is calculated as follows: Non-cancer HQ = CDI/RfD
where: CDI = Chronic daily intake
RfD = reference dose
CDI and RfD are expressed in the same units and represent the same exposure period (i.e.,
chronic, subchronic, or short-term).
Table 6
Summary of Non-carcinogenic RfDs for Oral Exposure to Ground Water
Contaminants of Concern
Chemical
Aluminum
rsenic
Barium
Beryllium
Cadmium
Cobalt
Cyanide
Iron
Lead
Subchronic
RfD<»
(mg/kg/day)
- .
3x 10"
7xl02
5 x 10°
-
-
2 x lO'2
-
-
Chronic RfD ft>
(mg/kg/day)
-
3x10"
7 x 10'J
5 x 10°
5x10-*
-
2xlO'2
-
-
Confidence
-
medium
medium
low
high
-
medium
--
-
25
-------
Table 6
Summary of Non-carcinogenic RfDs for Oral Exposure to Ground Water
Contaminants of Concern
Chemical
Manganese
Mercury
Nickel
Vanadium
Subchronic
RfD">
(mg/kg/day)
4.7 x 10'3
3.0 x!0-<
2.0 x lO'2
7.0x10'
Chronic RfD <"
(mg/kg/day)
4.7 x 10'2
3.0 xlO-1
2.0 x 1C'2
7.0 x 10°
Confidence
medium
--
medium
-
(a) 1995 HEAST Subchronic RfD values
(b) 1 996 IRIS Chronic RfD values
For non-carcinogenic threats to future recreational workers in Area 1, the HI is estimated to be
0.3 (RME), taking into account the risks from contaminants in ground water via oral ingestion.
This HI value is below EPA's acceptable action level of 1.0 (Table 7).
For non-carcinogenic threats to future recreational workers in Area 2/3, the HI is estimated to be
4.0 (RME), taking into account the risks from contaminants in ground water via oral ingestion.
This HI value exceeds EPA's acceptable action level of 1.0 (Table 7).
For non-carcinogenic threats to future recreational visitors in Area 1, the HI is estimated to be
0.08 (adult) and 0.2 (child) RME, taking into account the risks from contaminants in ground
water via dermal contact and oral ingestion. The HI values for the future recreational visitor in
Area 1 is below EPA's acceptable action level of 1.0 (Table 7).
For non-carcinogenic threats to future recreational visitors in Area 2/3, the HI is estimated to be
1.0 (adult) and 3.0 (child) RME, taking into account the risks from contaminants in ground
water via dermal contact and orJ ingestion. The HI value for the future recreational visitor
(child) in Area 2/3 exceeds EPA's acceptable action level of 1.0 (Table 7).
The primary COCs which contribute to the non-carcinogenic threat to the future recreational
worker and visitor (child) are arsenic and manganese. While arsenic damages blood cell
formation, blood vessels, the kidney, liver, and nerve function, manganese primarily produces
neurological affects.
26
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Table 7
Ground Water Risk Characterization Summary - Non-Carcinogens
South 8th Street Landfill - Ground Water Operable Unit
Exposure Scenarios That Trigger the
Need for Cleanup
Future Adult Recreational Worker
Exposure to Ground Water from
Aquifer Via Ingestion
Future Adult Recreational Visitor
Exposure to Ground Water from
Aquifer Via Ingestion and Dermal
Contact
Future Child Recreational Visitor
Exposure to Ground Water from
Aquifer Via Ingestion and Dermal
Contact
Chemical
Arsenic
Barium
Manganese
Total
Arsenic
Barium
Manganese
Total
Arsenic
Barium
Manganese
Total
Non-Carcinogenic Risk
Area 1
Average
6xl02
5 x ID'2
3 x ID'2
2 x 10''
6 x 10°
4 x 10"J
3 x 10"J
2 x lO'2
1 x 102
9 x 10 J
6 x 10°
3 x lO'2
Area 1 RME
1 x ID'1
1 x 10-'
7x 10-2
3 x 10"'
3 x 10-J
2x ID'2
2x 10'2
8xI02
7x 10'2
5 x 10'2
4x 10'2
2 x 10-'
Area 2/3
Average
I
8xl02
6 x 10-'
2
1 x 10-'
7 x 10°
6x lO'2
2x ID'1
3 x 10-'
2 x 10 2
1 x JO'1
4x 10"'
Area 2/3
RME
3
2x10-'
1
4
7x ID'1
4xlO'2
3 x 10"'
1
2
9x 10'2
7x 10'
3
Since there are no EPA approved toxicity values for lead, it is not possible to evaluate the non-
cancer risks of lead in the risk assessment. An alternative approach is to estimate the likely
effects of lead exposure in the ground water using the Integrated Exposure Uptake Biokinetic
(IEUBK) model for children. The IEUBK model utilizes a residential exposure scenario which
would produce a more sevtre effect for a child than the recreational visitor scenario. The U.S.
Centers for Disease Control goal is for not more than 5 percent of the population to exceed
10 Mg/dL. The maximum calculated value from the IEUBK model for the Site ground water is
3.7 ug/dL. Therefore, the lead concentrations in the Site ground water are not a concern for a
future child visitor.
Comparisons of the Site contaminant concentrations with background concentrations suggest
that excess risks and hazard contributions of arsenic, barium, and manganese are likely to be Site
related. For beryllium, the possibility still exists, although evidence is not strongly convincing.
Aluminum was not considered a primary contributor to the excess risk because there are no EPA
approved toxicity values for aluminum, and it is not possible to evaluate the non-cancer risks of
aluminum in the risk assessment. The background water quality of the ground water was not
considered in the baseline risk assessment.
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Estimations of exposure and risk are subject to a number of uncertainties that may lead to either
an overestimate or an underestimate of risk. Assumptions made in the risk assessment that are
likely to overestimate risk include the use of conservative exposure factors; use of conservative
EPCs; and the use of conservative RfDs and SFs. Factors that are likely to underestimate risk
include toxicity values that are not available for every chemical, for every exposure duration or
for all exposure routes. For the non-carcinogenicity risks, adding all the non-cancer risks can be
considered an additional source of uncertainty rather than grouping the affects according to
target organ toxicity.
Actual or threatened releases of hazardous substances from this Site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
REMEDIATION OBJECTIVES
Source Control Operable Unit
The 1994 ROD identified the oily sludge pit and ancillary soil and debris in Area 2 of the
landfill as a principal threat and the remaining landfill contents in Areas 1,2, and 3 as a low-
level threat at the Site. The Remedial Action Objectives identified in the 1994 ROD for the
principal and low-level threats remain unchanged and are as follows:
Oily Sludge Pit Area
1. Prevent current and future direct contact with the highly corrosive wastes.
2. Prevent current and future direct contact, ingestion, and inhalation of contaminants in the
waste and ancillary contaminated soil and debris.
3. Prevent the future migration of contaminants from the oily sludge pit area to other areas
both on and off the Site which may result from Site flooding.
4. Prevent the potential for future migration of contaminants to the ground water at
concentrations above appropriate action levels.
Landfill Areas
1. Prevent direct contact with and ingestion of the landfill contents.
2. Ensure that contaminants present in the landfill do not migrate into the ground water at
concentrations above appropriate action levels
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The Remedial Goals identified in the 1994 ROD remain unchanged for the oily sludge waste and
ancillary soil and debris. The Remedial Goals are listed in Table 8 and are based on direct
contact with the waste material.
TableS
Oily Sludge Pit Area Remedial Goals
Contaminant
Total PAHs as measured by benzo(a)pyrene equivalents
< CBs (total)
Lead
Remedial Goal
3 mg/kg
lOmg/kg
500 mg/kg
Ground Water Operable Unit
The expectations for contaminated ground water under lb- National Oil and Hazardous
Substances Contingency Plan (NCP) Section 300.430 (a)(l)(iii)(F) are as follows: "EPA expects
to return usable ground waters to their beneficial uses wherever practicable, within a time frame
that is reasonable given the particular circumstances of the site. When restoration of ground
water to beneficial uses is not practicable, EPA expects to prevent further migration of the
plume, prevent exposure to the contaminated ground water, and evaluate further risk reduction."
The overall remedial objectives that are generally applicable to sites involving contaminated
ground water are the following:
Prevent exposure to contaminated ground water, above acceptable risk levels;
Prevent or minimize further migration of the contaminant plume (plume containment);
Prevent or minimize further migration of contaminants from source materials to ground
water (source control); and
Return ground waters to their expected beneficial uses wherever practicable (aquifer
restoration).
The Remedial Action C jjectives for the ground water operable unit at the Site are the following:
1. Prevent exposure to Site contaminated ground water, above acceptable risk levels for
potential receptors; and
2. Restore the Site ground water to human health-based standards following remediation of
the oily sludge pit.
The general remedial objective of preventing or minimizing further migration of the contaminant
plume (plume containment) is not a Remedial Action Objective at this Site. Further contaminant
migration is not a concern because: 1) based on dilution by the Mississippi River, the discharge
of ground water to the Mississippi River has not been shown to adversely impact the water
29
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quality in the river; 2) the ground water contaminants will not further degrade the
uncontaminated aquifer surrounding the area; 3) the ground water contaminants have not
migrated off-site toward the City of West Memphis or the adjacent RV park, nor are they
anticipated to in the future; and 4) the confining layer of the Jackson Clay beneath the alluvial
aquifer prevents downward migration of the inorganic contaminants eliminating any potential
threat to the City of West Memphis water supply.
The general remedial objective of preventing or minimizing further migration of contaminants
from source materials to ground water (source control) is listed as a Remedial Action Objective
for the source control operable unit. Integration of the source control remedial action with the
ground water remedial action is critical to achieving the NCR expectation of aquifer restoration.
For this Site, the amended remedy for the source control operable unit will reduce or eliminate
further leaching of contaminants to the ground water from the oily sludge pit.
The Remedial Goal for each contaminant in the ground water is established to accomplish the
objective for restoration of the ground water to human health-based standards. The results of the
baseline risk assessment indicate that the hazardous substances present in the ground water
beneath the Site may present a potential threat to public health or welfare. The principal area of
concern is the inorganic contamination present in the ground water surrounding the oily sludge
pit in Area 2 of the landfill. The Remedial Goals established for the ground water are identified
in Table 9 and are protective of human health for the consumption of drinking water obtained
from the alluvial aquifer beneath the Site. The Remedial Goals for arsenic, barium, and
beryllium are based on their respective maximum contaminant level (MCL) specified under the
Federal Safe Drinking Water Act ("SDWA"). The Remedial Goal for lead is based on the action
level under the SDWA. For manganese, a health-based risk level concentration was used since
no MCL has been established. The risk assessment did not identify aluminum as a risk to human
health.
Table 9
Ground Water Remedial Goals
Contain *nant
Arsenic
Barium
Beryllium
Lead
Manganese
Remedial Goal (Mg/l*)
50
2000
4
15
4,088
* A«g/l = microgram/liter
30
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DESCRIPTION OF REMEDIAL ALTERNATIVES
Source Control Operable Unit
The 1994 ROD remedy for the source control operable unit included separate response actions
for the landfill and the oily sludge pit. In this ROD Amendment, EPA is changing the extent
rather than the nature of the response action for the landfill portion of the source control remedy.
For the oily sludge pit, the remedial alternatives evaluated in this ROD Amendment included the
original remedy selected in the 1994 ROD and the alternative remedy utilizing in-situ
stabilization/ solidification. A summary description of each alternative is provided below.
Neither alternative includes operation and monitoring costs since these costs are included with
the landfill component of the remedy for the source control operable unit.
Alternative 1 - Stabilization, Off-Site Disposal at Subtitle D Landfill (1994 ROD)
Capital Costs: $6,900,000
Time of Implementation: 10 months
The elements of this alternative as described in the 1994 ROD include:
Excavation of an estimated 22,000 cubic yards of sludge, contaminated soil, and debris
from the oily sludge pit area. The volumetric estimate is based on data indicating that the
sludge and contaminated soil encompass an area of 3.5 acres to a depth of 18 feet below
the ground surface.
The collection and disposal of contaminated water generated during the excavation of the
sludge, contaminated soil, and debris from the oily sludge pit area. Sources of
contaminated water include water contained within the waste material, accumulated
rainfall within the area of remedial activities, and water used for decontamination of
personnel and equipment. Disposal options for the contaminated water include: 1) reuse
during the stabilization process of the sludge and soil; and/or 2) discharge the water to a
stream or river following treatment to meet the applicable and relevant and appropriate
requirements (Clean Water Act, Arkansas Water and Air Pollution Control Act) or a
publicly owned wastewater treatment plant which may require less stringent treatment
requirements.
Pretreatment of the sludge to improve the handling characteristics during excavation and
transportation. The sludge exhibits the characteristic of a corrosive hazardous waste and
is a thick, viscous tar material that will likely adhere to the excavation and transportation
equipment. Pretreatment would require the addition of material handling agents such as
kiln dust or nearby soils and sands.
Treatment of the excavated sludge and soil via stabilization to reduce the mobility of the
contaminants.
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Disposal of the treated sludge and soil in a Subtitle D landfill located off-site.
Debris encountered during excavation of the contaminated soil will be separated and
decontaminated prior to disposal in a Subtitle D landfill. Non-contaminated debris will
also be disposed of at a Subtitle D landfill.
Backfill the excavated areas with clean soil. Compensatory wetlands may also be created
in the excavated area.
Alternative 2 - In-Situ Stabilization/Solidification
Capital Costs: $3,971,000
Time of Implementation: 5 months
The elements of this alternative include:
In-situ stabilization/solidification of an stimated 9,000 cubic yards of sludge in the oily
sludge pit and an estimated 14,500 cubic yards of ancillary soil and debris. Waste
material exceeding the Remedial Goals will require treatment through the
stabilization/solidification process. The volumetric estimate is revised based on
additional data collected at the Site. Augers can be used to thoroughly blend and mix the
sludge and reagent grout into a homogeneous mixture which is then cured in place.
Excavators can be used to mix the soil and debris with the reagent slurry. Pulverizing
equipment can be used to reduce the size of the debris to facilitate mixing and
homogenization during the stabilization/ solidification process. The soil and debris will
be treated within the bermed pit area and cured in place. The in-situ stabilization/
solidification process is estimated to produce a 40% volumetric expansion in the treated
waste. Performance standards for the treated waste are established to prevent or minimize
the movement of water through the treated material, and prevent further leaching of
contaminants from the treated waste into the ground wacer above MCLs or background
ground water concentrations, whichever is higher.
The collection and disposal of contaminated water generated during the dewatering of the
oily sludge pit area. Sources of contaminated water include water contained within the
waste material, accumulated rainfall within the area of remedial activities, and water used
for decontamination of personnel and equipment. Disposal options for the contaminated
water include: 1) reuse during the stabilization process of the sludge and soil; and/or 2)
discharge the water to a stream or river following treatment to meet the applicable and
relevant and appropriate requirements (Clean Water Act, Arkansas Water and Air
Pollution Control Act) or a publicly owned wastewater treatment plant which may
require less stringent treatment requirements.
Implementation of appropriate fugitive emission controls during the in-situ
stabilization/solidification process.
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Ground Water Operable Unit
The ground water operable unit FS Report describes a range of alternatives to address the
contaminated ground water at the Site. Each of the alternatives was developed with the
assumption that the source will be removed or remediated prior to implementation of the
alternative. EPA also utilized its guidance entitled "Presumptive Response Strategy for
Contaminated Ground Water" (Directive 9283.1-12) and "Use of Monitored Natural Attenuation
at Superfund, RCRA Corrective Action, and Underground Storage Tank Sites" (Directive
9200.4-17) from EPA's Office of Solid Waste and Emergency Response (OSWER) to facilitate
the development ~f remedial action alternatives for the Site. The following alternatives 'vere
developed to address the potential risks posed by the contaminated ground water at the Site:
No Action
Monitored Natural Attenuation and Institutional Controls
Ground Water Extraction & Treatment
A summary description of each alternative is provided below.
Alternative 1 - No Action
Capital Costs: $0
Annual Operation & Maintenance Costs: $0
Total Cost: $0
Time of Implementation: 0 months
Evaluation of the No Action Alternative is required by the NCP (40 CFR § 300.430), and is used
as a baseline for comparing other alternatives. This alternative assumes that no action would be
taken to monitor or treat contaminated ground water at the Site. The No Action alternative also
does not provide a means to verify the effectiveness of the source remediation and a subsequent
reduction in contaminant concentrations in the ground water.
Alternative 2 -Monitored Natural Attenuation and Institutional Controls
Capital Costs: $5,500
Annual Operation & Maintenance Costs: $18,200 - $68,200
Total Cost: $643,700
Present Worth Cost: $383,461
Time of Implementation: 30 years
Alternative 2, EPA's selected remedy, is the reliance on natural attenuation processes to achieve
the remedial action objectives and goals within a time frame that is reasonable for this Site. The
natural attenuation process that is at work at this Site is the physical process of dispersion and
dilution created by the movement of ground water through the aquifer. The ground water
movement, or flushing, is effective at this site due to the high ground water flow rate and short
travel distance (approximately 600 feet or less) before discharging into the Mississippi River.
33
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To a lesser extent, the contaminant concentrations may be reduced through adsorption of the
contaminants onto soil particles in the aquifer. The expected effectiveness of the natural
attenuation process for this Site is demonstrated by the localized extent of ground water
contamination around the oily sludge pit. After eliminating or reducing leachate from the oily
sludge pit area following source area remediation, these natural attenuation processes will further
reduce contaminants below current concentrations in the ground water.
Natural attenuation is an appropriate remedial approach since the Site contaminant
concentrations do not impact other aquifers supplying drinking water or the Mississippi River
due to dilution by the river. Since there is no reasonably anticipated demand for the alluvial
aquifer in this immediate area, a specific time frame has not been established for achieving the
Remedial Goals in the ground water. Institutional controls, such as deed notices, will be filed to
notify future land owners of the hazards associated with the contaminated ground water in the
area of the Site.
The elements of this alternative include:
Implementation of a long-term ground water monitoring program following completion
of the oily sludge pit remediation. Performance of the natural attenuation alternative in
achieving the remedial action objectives and goals will be evaluated under the
monitoring program.
The installation of additional monitoring wells to supplement the existing monitoring
system and provide additional data to ensure the effectiveness of the source remediation.
Placement of deed notifications to ensure that future landowners are notified that the
property was a former Superfund Site, that hazardous substances are present at the Site,
and the actions taken to address the contamination; EPA will attempt to negotiate a
Consent Decree implementing a deed restriction and/or other appropriate controls with
the landowner of the Site.
Alternative 3 - Ground Water Extraction and Treatment.
Capital Costs: $3,260,792
Annual Operation & Maintenance Costs: $18,200 - $558,440
Total Cost: $4,909,572
Present Worth Cost: $ 4,572,975
Time of Implementation: 30 years
Alternative 3 includes all of the monitoring activities and institutional controls outlined in
Alternative 2. In addition, Alternative 3 utilizes ground water extraction wells to restore the
contaminated aquifer to its beneficial use by pumping contaminated ground water to a treatment
system on the ground surface at the Site. The ground water extraction wells would probably be
34
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located between the oily sludge pit and the Mississippi River to take advantage of the
predominant ground water flow direction.
The same Site characteristics that make natural attenuation EPA's preferred alternative, limits
the practicality of implementing a pump and treat system at the Site. Based on modeling of the
ground water flow beneath the oily sludge pit to the Mississippi River, four extraction wells
pumping at a daily volume of 5.76 million gallons per day would be necessary to capture the
contaminants in the aquifer. For comparison purposes, the water supply wells for the City of
West Memphis pump an average volume of 6 to 11 million gallons per day for the city water
supply. Given such a large volume of water, the Site ground water extraction system may only
operate for a relatively short period of time. For cost purposes, the ground water extraction and
treatment system was estimated to operate for only two years followed by a 28 year monitoring
period for a total operational period of 30 years.
The elements of this alternative in addition to those identified in Alternative 2 include:
Installation of ground water recovery wells near the oily sludge pit to recover
contaminants in the aquifer.
Installation of a treatment system to remove contaminants from the recovered ground
water. Disposal options for the treated water include discharge into a stream or river
following treatment to meet the applicable and relevant and appropriate requirements
(Clean Water Act, Arkansas Water and Air Pollution Control Act) or a publicly owned
wastewater treatment plant which may require less stringent treatment requirements.
SUMMARY OF COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES
The following discussion presents the results of an evaluation using the nine criteria to compare
the 1994 ROD source control remedy for the oily sludge pit with the alternative remedy for the
oily sludge pit utilizing in-situ stabilization/solidification. A summary is also presented of an
evaluation of the ground water remedial alternatives using the nine criteria. These nine criteria
are categorized into three groups: threshold, balancing, and modifying. The threshold criteria of
overall protection of human health and the environment and compliance with applicable or
relevant and appropriate requirements must be met in order for an alternative to be eligible for
selection. The balancing criteria of long-term effectiveness and permanence, reduction of
toxicity, mobility or volume through treatment, short-term effectiveness, implementability, and
cost are used to weigh major tradeoffs among alternatives. The modifying criteria of State and
community acceptance are taken into account after State and public comment is received on
EPA's preferred alternative as identified and described in the Proposed Plan of Action.
35
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Overall Protection of Human Health and the Environment
Overall protection of human health and the environment addresses whether each alternative
provides adequate protection of human health and the environment and describes how risks
posed through each exposure pathway are eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls.
Source Control Operable Unit
Both the 1994 ROD remedy (oily sludge pit) and the amended remedy will provide effective
protection of human health and the environment by treating the principal threat posed by the oily
sludge pit wastes. Both remedies require treatment of the waste so that it is no longer corrosive.
The 1994 ROD remedy would also have treated the waste to meet specific performance
standards for disposal at an off-site landfill. The amended remedy will treat the waste to new,
more stringent performance standards that wili reduce or eliminate the leaching of contaminants
from the treated waste material. The threat of vrect contact will be eliminated following
treatment and placement of a 2-foot natural soil cover over the treated material (remedy for the
landfill portion of the source control remedy).
Ground Water Operable Unit
Alternative 2 (Monitored Natural Attenuation and Institutional Controls) and Alternative 3
(Ground Water Extraction and Treatment) provide adequate protection of human health and the
environment. Alternative 2 provides for control of this exposure route through institutional
controls and ground water monitoring to evaluate the effectiveness of natural attenuation in
achieving the Remedial Goals. Alternative 3 achieves this goal through the physical extraction
and treatment of the contaminated ground water combined with institutional controls. Since
there are no adverse impacts identified to either the Mississippi River or any private or City of
West Memphis drinking water well, the level of overall protection to human health and the
environment provided by Alternative 2 is comparable to the level provided by the ground water
pump and treat system in Alternative 3. Both alternatives 2 and 3 rely on source remediation to
achieve the remedial coals. Alternative 1 does not provide a means for monitoring the
effectiveness of the source remediation or the reduction in contaminant concentrations in the
ground water. Alternative 1 does not provide adequate protection of human health and the
environment.
Compliance With Applicable or Relevant and Appropriate Requirements (ARARs)
CERCLA Section 121 (d) requires remedial actions to attain applicable or relevant and
appropriate requirements (ARARs). Applicable requirements are those cleanup standards,
requirements, criteria, or limitations under Federal or State law applicable to the hazardous
substance or relevant and appropriate under the circumstances of the release. Compliance with
36
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ARARs addresses whether a remedy will meet all of the applicable or relevant and appropriate
requirements of other Federal and State environmental statutes.
Source Control Operable Unit
The original ROD remedy (oily sludge pit) complies with all of the chemical, location, and
action-specific ARARs. Since the amended remedy has many of the same components as the
original ROD remedy, the amended remedy will also comply with the ARARs. The amended
remedy does not include off-site disposal of the treated sludge. Therefore, ARARs associated
with off-site disp^al do not apply to the amended remedy.
Ground Water Operable Unit
Alternatives 2 and 3 are both expected to achieve the ARARs for the contaminants in the
monitoring wells. Alternative 3 (Ground Water Extraction and Treatment) would also have to
meet the substantive requirements of the NPDES permi*''ng program including the development
of the discharge limitations to the river and the monitoring of the discharge. Alternative 1 would
not provide a means to verify the achievement of ARARs at the Site.
Long-term Effectiveness and Permanence
Long-term effectiveness and permanence refers to expected residual risk and the ability of a
remedy to maintain reliable protection of human health and the environment over time, once
cleanup goals have been met.
Source Control Operable Unit
The original ROD remedy (oily sludge pit) achieves long-term effectiveness through excavation
and treatment of the waste followed by disposal in an off-site permitted landfill. Treatment
requires neutralization of the corrosive wastes and stabilization/solidification of the organic and
inorganic contaminants in the waste to meet landfill requirements.
The amended remedy is expected to achieve the same long-term effectiveness through more
stringent treatment of the waste. Treatment requires neutralization of the corrosive wastes and
stabilization/solidification of the organic and inorganic contaminants in the waste so that it will
not leach either organic or inorganic contaminants to the ground water above levels protective of
human health.
Ground Water Operable Unit
Alternatives 2 and 3 will both be able to provide the same long-term effectiveness and
permanence. Both alternatives include long-term monitoring to verify that contaminant levels
37
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remain below the Remedial Goals for the ground water and institutional controls to prevent
exposure to potential receptors.
Reduction of Toxicitv. Mobility, or Volume Through Treatment
This criterion refers to the anticipated performance of the treatment technologies that may be
used in a remedy.
Source Control Operable Unit
Both the original ROD remedy (oily sludge pit) and the amended remedy achieve a reduction in
toxicity and mobility through treatment of the waste by neutralizing the corrosive wastes and
immobilization of the organic and inorganic contaminants in the waste. Testing conducted as
part of the remedial design showed that stabilization/solidification of the waste can effectively
reduce leaching of either organic or inorganic contaminants to the ground water.
Ground Water Operable Unit
The ground water contamination does not represent a principal or low level threat at this Site.
Therefore, treatment to reduce the toxicity, mobility, or volume of contamination in the ground
water is not necessarily appropriate at this Site to achieve the remedial action objectives and
goals. Alternative 3 will achieve the reduction through the removal of metals from the extracted
ground water followed by off-Site disposal. Since Alternatives 1 and 2 do not involve treatment
to remove metals from the ground water, these alternatives are not equivalent to Alternative 3.
All of the alternatives rely on source remediation to achieve the remedial goals.
Short-term Effectiveness
Short-term effectiveness refers to the time needed to complete the remedy and any adverse
impacts on human health and the environment during implementation of the remedy.
Source Control Operable Unit
The short-term risks associated with the 1994 ROD remedy (oily sludge pit) are greater when
compared with those risks associated with the proposed amended remedy. The multiple waste
handling steps involved in the 1994 ROD remedy (excavation, handling, and pretreatment of the
waste) will result in more opportunities for air emissions from the waste and potential exposure.
Potential risks from accidents and spillage of the waste are also associated with transport of the
stabilized waste to the off-site landfill. The excavation and treatment process in the original
remedy may not be accomplished during the dry period, and the treatment component of the
remedy may have to be completed on the land side of the St. Francis Levee during the seasonal
flooding of the Site.
38
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The amended remedy will minimize these air emissions by in-situ treatment, thereby reducing
potential exposure. The amended remedy will also require a shorter time frame to implement
and can be completed during the dry period (i.e., June - October) which reduces short-term risks
to the river and surrounding areas associated with waste being released from the Site during
seasonal flooding.
Ground Water Operable Unit
Over the short-term, implementation of Alternatives 1 and 2 would not affect the levels of risk to
the community or Site workers. There would be no significant changes to the current status of
the Site. Alternative 3 poses a small potential for risk to the Site workers and people who may
travel across the Site either to or from the banks of the Mississippi River during construction or
operation of the ground water collection and treatment system on the surface of the Site.
Implementability
Implementability is the technical and administrative feasibility of a remedy, including the
availability of materials and services needed to implement the remedy.
Source Control Operable Unit
The equipment and personnel for both remedies are readily available in the remediation and
construction industries. Both remedies can be completed using conventional construction
equipment. The 1994 ROD remedy (oily sludge pit) may face administrative obstacles in
obtaining access to property on the land side of the St. Francis Levee to complete treatment
during seasonal flooding and obtaining a Subtitle D landfill to accept the treated waste.
Ground Water Operable Unit
With the exception of Alternative 1, Alternative 2 would be the simplest to implement requiring
only the installation of additional monitoring wells, the implementation of a long-term ground
water monitoring plan, and the filing of deed notices for the Site. Implementation of Alternative
3 is technically feasible and can be accomplished following the completion of remedial design
plans for the construction of the system. The general expertise is available in the industry to
design, constivct and operate a ground water extraction system. Similarly, the equipment
necessary for the treatment system are also readily available in the industry. Any design of such
a system will have to take into consideration the annual flooding of the Site and the impacts on
the equipment on the land surface of the Site.
Cost
Cost includes an evaluation of the capital cost and the cost of operation and maintenance of the
remedy in a present worth calculation.
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Source Control Operable Unit
The estimated capital cost for the 1994 ROD remedy for the oily sludge pit area is $6,900,000.
The estimated capital costs for in-situ stabilization/solidification of the oily sludge pit area is
$3,978,249. The primary difference in the two cost estimates is the elimination of the sludge pit
excavation and off-Site disposal costs.
Ground Water Operable Unit
Since there are no current adverse impacts identified to human health and the environment,
Alternative 2 provides the most cost effective approach to meet the remedial action objectives
and remedial goals for the Site. Alternative 2 has a present worth cost for 30 years of $383,461,
while Alternative 3 (Ground Water Extraction and Treatment) has a present worth cost for 30
years of $4,572,975.
State Acceptance
State Acceptance indicates whether the State concurs with, opposes, or has no comment on the
selected alternative.
ADPC&E has been provided the opportunity to review the treatability studies, remedial design
documents, and the draft ROD Amendment. ADPC&E concurs with the amended remedy for
the source control operable unit (Appendix A).
ADPC&E has been provided the opportunity to review the ground water RI/FS and the draft
ROD Amendment. ADPC&E concurs with the selected remedy for the ground water operable
unit (Appendix A).
Community Acceptance
EPA recognizes that the community in which a Superfund site is located is the principal
beneficiary of all remedial actions undertaken. Community acceptance has been assessed
through the written comments received during the public comment period held from
January 5, 1998, to February 4, 1998. In addition, comments were received from the community
during a public hearing held on January 26,1998. A court reporter recorded the hearing and
prepared a transcript which is included in the amended Administrative Record. EFA has
addressed those comments in the Responsiveness Summary included in this ROD.
Comments received during the public comment period did not oppose the alternative remedy as
the preferred alternative for the source control operable unit or Alternative 2 as the preferred
alternative for the ground water operable unit.
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Summary of Comparative Analysis
Both the 1994 ROD remedy and the amended remedy for the source control operable unit are
protective of human health and the environment and comply with ARARs. Of the five balancing
criteria (long-term effectiveness and permanence, reduction in toxicity, mobility, or volume
achieved through treatment, short-term effectiveness, implementability, and cost), the criteria of
short-term effectiveness and cost are the most decisive in the selection decision. The short-term
effectiveness of the amended remedy is most evident in the reduced risks from air emissions
during the treatment process, the shorter time frame for completing the treatment process, and
the ability to ma'«*ain the treated wastes on-site as opposed to transporting the wastes on public
roads to an off-site landfill. The cost effectiveness of the amended remedy is a 42% reduction in
the total costs compared to the 1994 ROD remedy.
Both the 1994 ROD remedy and the amended remedy provide similar degrees of long-term
effectiveness and permanence, and reduction in toxicity and mobility through treatment. While
the implementation of the 1994 ROD remedy presents r me administrative obstacles (e.g.,
obtaining a Subtitle D landfill, property access west of the St. Francis levee to complete
treatment), these obstacles alone are not significant enough to influence the selection decision.
While the 1994 ROD remedy was the preferred alternative by both the State and community
during the 1994 remedy selection, the amended remedy has also received State and community
acceptance.
Of the two ground water alternatives (Nos. 2 and 3) that are protective of human health and the
environment and comply with ARARs, the criteria of cost was the most decisive of the five
balancing criteria (long-term effectiveness and permanence, reduction in toxicity, mobility, or
volume achieved through treatment, short-term effectiveness, implementability, and cost) in the
selection decision.
The contaminated ground water at the Site poses a potential threat to human health if the Site
should be developed for recreational purposes. However, the existing ground water
contamination does not pose a threat to the surrounding uncontaminated aquifer or Mississippi
River, or threaten the txisting drinking water supply for the City of West Memphis. Each of the
two alternatives is dependent on the implementation of a source control remedy that will
eliminate or significantly reduce further leaching of contaminants into the ground water. The
contaminant concentrations are expected to decrease in the aquifer following remediation of the
source area and return to concentrations safe for human consumption within a reasonable time
frame. As a result, there is limited practicality to implementing a ground water extraction
system with a daily flow rate of 5.76 million gallons to achieve a reduction in risk that can also
be achieved through natural attenuation processes.
41
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SELECTED REMEDY
Source Control Operable Unit
Based upon the requirements of CERCLA, and the comparative analysis of the 1994 ROD
remedy (oily sludge pit) and the amended remedy using the nine criteria, EPA has determined
that the amended remedy of in-situ stabilization/solidification is equally protective of human
health and the environment and will achieve the same remedial objectives and goals in a shorter
time frame utilizing a more cost-effective process. The amended remedy for the oily sludge pit
replaces the 1994 ROD remedy of excavation, stabilization, and off-site disposal. The in-situ
stabilization/solidification remedy addresses the principal threat at the Site and remains
consistent with the presumptive remedy for landfills guidance (OSWER Directive 9355.0-49FS).
In the 1994 ROD Responsiveness Summary, EPA had previously noted that there was
uncertainty as to whether stabilization would effectively immobilize the organic contaminants
present in the waste. This uncertainty has been addressed by the treatability studies which
demonstrated that stabilized waste material can successfully pass the leaching tests set by EPA
for both organic and inorganic contaminants.
The in-situ stabilization/solidification remedy for the Site consists of the following components:
In-situ stabilization/solidification of an estimated 9,000 cubic yards of oily sludge waste
capable of meeting the more stringent performance standards for in-place management of
the treated material and protection of the Site ground water. Augers can be utilized
during the treatment process to mix the sludge and reagent mix grout into a homogeneous
mixture which is then cured in place.
In-situ stabilization/solidification of an estimated 14,500 cubic yards of ancillary soil and
debris surrounding the oily sludge pit capable of meeting the more stringent performance
standards for in-place management of the treated material and protection of the Site
ground water. Hyojaulic excavators can be utilized during the treatment process to mix
the soil and debris with the reagent slurry. Pulverizing equipment can be used to reduce
the size of the debris to facilitate mixing and homogenization during the
stabilization/solidification process. The soil and debris will be treated within the bermed
pit area and cured in place.
In-place management of the treated waste material within the area of the oily sludge pit
and ancillary soil area.
The collection and disposal of wastewater generated during the in-situ stabilization/
solidification process and construction activities. The sources of wastewater include
water produced during the dewatering of the ancillary soil and debris, accumulated
rainfall within the area of remedial activities, and water used for decontamination of
42
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personnel and equipment. Disposal options for the contaminated water include: 1) reuse
during the stabilization process of the sludge and soil; and/or 2) discharge the water to a
stream or river following treatment to meet the applicable and relevant and appropriate
requirements (Clean Water Act, Arkansas Water and Air Pollution Control Act) or a
publicly owned wastewater treatment plant which may require less stringent treatment
requirements.
Implementation of appropriate fugitive emission controls during the in-situ
stabilization/solidification process.
The schedule for completion of the major construction activities is expected to occur between
June and early November. During mobilization and project startup in June, the vegetation
around the oily sludge pit area will be cleared and a working platform will be constructed along
the length of the oily sludge pit. A pilot test for the in-situ augers and the hydraulic excavators
will be performed prior to full-scale production to determine the effectiveness of the reagent mix
design and the mixing technology. Extensive sampling and testing will be completed as part of
the pilot test to determine the effectiveness of the mix design and develop performance curves
for quality control during full-scale production.
Full-scale in-situ stabilization/solidification of the oily sludge pit area will begin after
completion of the pilot test. Air monitoring will be conducted during the production process and
the appropriate fugitive emissions control implemented at the Site. In addition, dewatering of
the ancillary soil and debris may be necessary based on the results of the pilot test. Treated
material will be graded in place to promote drainage away from the area and allowed to cure
within the pit area. Design calculations based on the treatability studies show that approximately
9,000 cubic yards of oily sludge material will produce 12,600 cubic yards of treated material,
and 14,500 cubic yards of the ancillary soil and debris will produce 20,300 cubic yards of treated
material.
This ROD Amendment modifies the scope of the natural soil cover to be installed on the landfill
by requiring the installation of a 2-foot thick natural soil cover over part of Area 1 of the landfill
and the treated oily sludge pit area in Area 2 of the landfill. The extent of the soil cover was
revised in response to additional data collected during the remedial design activities. The extent
of the landfill cover as estimated in the 1994 ROD consisted of 16 acres, including the 2.5 - 3.5
acre oily sludge pit. Additional Site characterization has established that 2 feet of soil cover
currently exists over part of Area 1 and all of Area 3. The reduced size of the landfill cover will
still meet the remedial action objectives established for the landfill and comply with the
Arkansas Solid Waste Management Code. The extent of the landfill cover as identified in the
remedial design documents is illustrated in Figure 3. Erosion control features, such as
vegetation, will be installed to maintain the integrity of the landfill cover during the annual
flooding events. In addition, the ground water monitoring component identified in the 1994
ROD is now included in the remedy component for the ground water operable unit. The landfill
43
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portion of the source control remedy as identified in this ROD Amendment includes the
following components:
Installation of a 2-foot thick natural soil cover over part of Area 1 and the treated area of
the oily sludge pit and ancillary soils in Area 2 of the landfill. The natural soil cover will
prevent exposure to human and ecological receptors at the Site and comply with the
requirements of the Arkansas Solid Waste Management Code.
Installation of appropriate erosion control features to minimize operation and
maintenance of the soil cover.
Installation of compensatory wetlands on-site to replace wetlands impacted during Site
remediation efforts.
Placement of deed notifications or other institutional controls to ensure that any future
landowners will be notified that the lar ' was a former Superfund site and waste has been
treated and is being managed at the site; EPA will attempt to negotiate a Consent Decree
implementing a deed restriction and/or other appropriate controls with the landowner of
the Site; and
Long-term operation and maintenance.
The natural soil cover will be installed after completion of the in-situ stabilization/solidification
of the oily sludge pit area. Part of the landfill in Area 1 will be cleared and graded as necessary
prior to installation of the soil cover. Erosion control methods will be employed until the
vegetation is reestablished on the newly installed landfill cover. In addition, functional wetlands
will be established at the Site, most likely in the on-Site borrow areas used to obtain fill material
for the landfill cover. The ground water monitoring requirements for the closed landfill will be
performed as a component of the selected remedy for the ground water operable unit. The deed
notification for the property, or other institutional control (e.g., a deed restriction) with the
existing landowner, will alert current owner(s) and prospective purchasers that hazardous
substances are present at the Site and explaining actions taken to address contamination at the
Site. The deed notification or other institutional controls will document the restricted activities
that would interfere with or adversely affect the integrity or protectiveness of the remedy
implemented at the Site. The deed notification, or other institutional control (e.g., a deed
restriction) with the existing landowner, will be filed with the appropriate land records office.
Remedial Goals
The remedial goals to be obtained at the conclusion of the remedial action for the source control
operable unit remain the same as those identified in the 1994 ROD. The remedial goals were
previously identified in Table 22 of the 1994 ROD and are repeated in Table 8 of this Amended
44
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ROD. Waste material with contaminant concentrations exceeding the remedial goals will be
treated during the in-situ stabilization/solidification process.
Performance Standards
The new, more stringent, Site-specific performance standards have been developed to ensure that
the oily sludge pit wastes and ancillary soil and debris can be treated and managed on-Site
without further degrading the ground water quality at the Site. The new performance standards
are listed in Tab'*** 10 and 1 la - lie, and replace the performance standards listed in the 1994
ROD.
Table 10
Performance Standards for Solidification/Stabilization of Waste Material
Test
Toxicity
pH
Unconfined Compressive Strength
Hydraulic Conductivity
Wet/Dry Dur-bility
Volumetric Expansion
Method
SW 846 1312
SW 846 9045
ASTMD2166
SW 846 9100
ASTM D4843
On-Site Measurements
Design Criteria
SPLP Performance Criteria listed in
Tables 11 a- lie
7.0
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standard by a factor of five times. While the treatability testing demonstrated the success of the
stabilization/solidification process, the inclusion of the allowance procedures acknowledges the
likelihood that variabilities will exist in oily sludge material. Without the allowances in the
SPLP performance standards, the treatment process may be unrealistically stringent resulting in
higher costs without an appreciable increase in the protectiveness of the remedy.
Table 1 la
Performance Standards for Solidification/Stabilization of Waste Material
Volatile Organic Compound
Vinyl Chloride
Methylene Chloride
1,1-Dichloroethene
cis- 1 ,2-Dichloroethy lene
trans- 1 ,2-Dichloroethylene
Chloroform
1 ,2-Dichloroethane
1 , 1 , 1 -Trichloroethane
Carbon Tetrachloride
Bromodichloromethane
1 ,2-dichloropropane
Trichloroethene
1 , 1 ,2-Trichloroethane
Benzene
Bromoform
Tetrachloroethene
Toluene
Ethylbenzene
Styrene
Xylenes
Lcachate Concentration (mg/l)
0.002
0.005
0.007
0.07
0.1
0.1
0.005
0.2
0.005
0.1
0.005
0.005
0.005
0.005
0.1
0.005
1
0.7
0.1
10
Basis
MCL
MCL
MCL
MCL
MCL
MCL
MCL
MCL
MCL
MCL
MCL
MCL
MCL
MCL
MCL
MCL
MCL
MCL
MCL
MCL
46
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Table lib
Performance Standards for Solidification/Stabilization of Waste Material
Semi-Volatile Organic Compound
1 ,3-Dichlorobenzene
1 ,4-Dichlorobenzene
1,2-Dichlorobenzene
Hexachlorobutadiene
1 ,2,4-Trichlorobenzene
Hexachlorocyclopentadiene
Hexachlorobenzene
bis(2-ethylhexyl)phthalate
Benzo(a)pyrene
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
Di benzo(a,h)anthracene
Ideno( 1 ,2,3-cd)pyrene
Pentachlorophenol
PCBs
Leachate Concentration (mg/l)
0.6
0.075
0.6
0.001
0.07
0.05
0.001
0.006
0.0002
0.02
0.02
0.2
2
0.002
0.02
0.001
0.0005
Basis
MCL
MCL
MCL
MCLG
MCL
MCL
MCL
MCL
MCL
(a)
(a)
(a)
(a)
(a)
(a)
MCL
MCL
(a) Benzo(a)pyrene MCL adjusted for relative potency
Table l!c
Performance Standards for Solidification/Stabilization of Waste Material
Inorganics
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Leachate Concentration (mg/l)
0.101
0.0459
0.05
2
0.004
0.005
Basis
Background
Background
MCL
MCL
MCL
MCL
47
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Table He
Performance Standards for Solidification/Stabilization of Waste Material
Chromium
Copper
Iron
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
0.1
1.3
15.1
0.015
0.614
0.002
0.1
0.05
0.1
0.0047
5
MCL
MCLG
Background
MCL
Background
MCL
MCLG
MCL
SMCL
Background
SMCL
Cost Summary
Table 12 identifies the estimated costs for the revised source control remedy including the in-situ
stabilization/solidification of the oily sludge pit area and the reduced soil cover on the landfill.
The cost estimate was prepared by the PRP Group during the remedial design. Modifications
during the construction process may result in some changes to the cost estimate. One specific
area subject to change is the cost of wastewater disposal during the construction process. The
wastewater is produced by dewatering the soil and sediment surrounding the oily sludge pit prior
to the in-situ stabilization/solidification process, rainfall entering the pit area, and wash water
produced during the decontamination process for personnel an J equipment. The amount of
wastewater produced during the dewatering process is subject to the fluctuating water table
beneath the Site. The final method of disposal has not been selected but is listed in the cost
estimate as disposal at a commercial facility. The cost for wastewater disposal may change
based on the volume of water and/or the method of disposal. In addition, a 25% contingency has
been added to the cost estimate to account for the uncertain nature of the oily sludge pit and the
potential volume of wastewater requiring disposal.
TABLE 12
COST ESTIMATE FOR THE AMENDED REMEDY
SOURCE CONTROL OPERABLE UNIT
Description of Capital Costs
Bonds and Insurance
Mobilization
Units
LS
LS
Unit Cost
Quantity
Cost
$150,000
$105,000
48
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TABLE 12
COST ESTIMATE FOR THE AMENDED REMEDY
SOURCE CONTROL OPERABLE UNIT
Description of Capital Costs
Health & Safety
Plan Development
PPE Level B
PPE Level C
PPE Level C Modified
Temporary faculties & Controls
Field Office
Decontamination Facility
Hygiene Facility
Roads
Site Security
Execution Requirements
Field Surveying
Demobilization & Closeout
Wastewater Treatment Systems
Wastewater Treatment Facility
Sanitary Waste Disposal
Solidification & Stabilization
Dewatering
In-Situ Auger
On-Site Hydraulic Excavator
Pilot Test
Emissions Control
Site Clearing - Oily Sludge Pit
Soil Cover - Placement & Compaction
Excavation - On-Site Borrow Area
Soil Erosion & Sediment Control
btraw Bale
Silt Fence
Constructed Wetlands
Grading
Landscaping
2 Year Maintenance
Security Gate
Hydraulic Seeding
Air Monitoring Program
Analytical Costs
Monitoring Equipment
Units
LS
manhour
manhour
manhour
LS
LS
LS
SY
day
LS
LS
LS
LS
LS
CY
CY
LS
LS
acre
CY
CY
feet
feet
LS
SY
LS
LS
1000 SF
LS
LS
Unit Cost
$25
$15
$10
$3,000
$20,000
$14,450
$5
$250
$3,900
$60,000
$0.5
$5
$30,000
$60
$50
$50,000
$75,000
$4,000
$3.50
$2
$2
$2
$25,000
$3
$2,500
$1,250
$45
$32,500
$19,000
Quantity
176
1056
1328
3950
120
700,000
250
9,000
14,500
2.5
20,000
20,000
1000
1000
12,100
110
Cost
$45,000
$4,400
$15,840
$13,280
$3,000
$20,000
$14,450
$19,750
$30,000
$3,900
$60,000
$350,000
$1,250
$30,000
$540,000
$725,000
$50,000
$75,000
$10,000
$70,000
$40,000
$2,000
$2,000
$25,000
$36,300
$2,500
$1,250
$4,950
$32,500
$19,000
49
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TABLE 12
COST ESTIMATE FOR THE AMENDED REMEDY
SOURCE CONTROL OPERABLE UNIT
Description of Capital Costs
Characterization Sampling
Confirmatory Sampling
Verification Sampling
Deed Restrictions
Subtotal - All Capital Costs
Contingency (25%)
Engineering (20%)
Total Capital Costs
Units
allowance
allowance
allowance
allowance
Unit Cost
Quantity
Cost
$2,300
$402,700
$15,000
$5,000
$2,926,370
$731,592
$585,274
$4,243,236
Notes:
Capital Cost estimates are not discounted because the construction work will be performed in the first year.
LS = Lump Sum
CY = Cubic Yard
SF = Square Foot
SY = Square Yard
Expected Outcome of Selected Remedy
The amended source control remedy is expected to be completed between the months of June
and early November at the Site. This time frame corresponds to a period between the seasonal
flooding events that would otherwise prevent further construction activities. The newly installed
portions of the landfill cover will be vegetated to prevent erosion during the flooding season.
The presence of a healthy vegetative cover over all of the landfill cover is important to the long-
term maintenance of the selected remedy.
The ability of the selected remedy to achieve the remedial action objectives and goals will be
verified during the initial round of pilot testing conducted at the Site. A pilot test will be
performed prior to full-scale production and used to determine the effectiveness of the reagent
mix design and the stabilization/solidification mixing technology. An extensive series of
sampling and analyses during the pilot test will provide data to develop performance curves for
quality control purposes during full-scale production.
Following completion of the in-situ stabilization/solidification process for the oily sludge pit and
ancillary soil and debris, there are no further operation and maintenance activities for this part of
the remedy. Long-term reliability of the stabilized/solidified waste material is predicted through
the new, more stringent performance standards which are expected to prevent further
50
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degradation of the underlying ground water. Ground water monitoring activities will be
performed as a function of the selected remedy for the ground water operable unit.
Installation of the remaining soil cover over Area 2, including the treated oily sludge pit, and
part of Area 1, will require periodic inspections to ensure that a suitable vegetative cover has
been established for the Site. In addition, the vegetation established to support the newly created
wetlands will also have to be verified. Following this initial period, periodic inspections will be
expected to occur as a component of the scheduled ground water monitoring events for the Site.
Five-year reviews conducted for this operable unit will be performed according to existing
guidance ["Structure and Components of Five-Year Reviews" (OSWER Directive 9355.7-02),
"Supplemental Five-Year Review Guidance" (OSWER Directive 9355.7-02A), and Second
Supplemental Five-Year Review Guidance" (OSWER Directive 9355.7-03A)] and any updated
guidance.
The resulting land and resources uses following completion of the selected remedy will allow for
a recreational use of the property. However, activities at the Site must not interfere with or
adversely affect the integrity or protectiveness of the selected remedy. Activities that result in
erosion of the landfill cover during flooding events and subsequent exposure to the landfill
contents and treated waste material must be prevented.
Ground Water Operable Unit
Based upon consideration of the requirements of CERCLA, and the detailed analysis of the
alternatives using the nine criteria, EPA has determined that the Monitored Natural Attenuation
and Institutional Controls alternative is the selected remedy for the ground water operable unit.
Monitored natural attenuation has been selected based on predictive analysis and the use of
contingency planning incorporated into this ground water remedy. Based on information
currently available with respect to the evaluation criteria and the other alternatives, EPA believes
the selected remedy provides the best approach to achieve the remedial objectives and goals.
Ground water monitoring will be performed to evaluate the effectiveness of natural attenuation
in achieving the reduction in contaminant concentrations in the ground water following
remediation of the oily sludge pit. Implementation of institutional controls through a deed notice
or other appropriate mechanisms will ensure that recreational exposure scenarios do not occur
prior to the achievement of the remedial goals. The elements of the selected remedy include:
Implementation of a long-term ground water monitoring program following completion
of the oily sludge pit remediation. Sampling and analyses of ground water monitoring
wells will be used to evaluate the effectiveness of natural attenuation in achieving the
Remedial Goals and the effectiveness of the source remediation.
The installation of additional monitoring wells to supplement the existing monitoring
system and provide additional data to ensure the effectiveness of the source remediation.
51
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Placement of deed notifications or other institutional controls to ensure that future
landowners are notified that the property was a former Superfund Site, that hazardous
substances are present at the Site, and the actions taken to address the contamination;
EPA will attempt to negotiate a Consent Decree implementing a deed restriction and/or
other appropriate controls with the landowner of the Site.
The deed notification for the property will alert current owner(s) and prospective purchasers that
hazardous substances are present at the Site and explaining actions taken to address
contamination at the Site. The deed notification will document that ground water beneath the
Site should not be used for either drinking water or non-drinking water uses until the Remedial
Goals for the ground water have been achieved. The deed notification, or other institutional
control (e.g., a deed restriction) with the existing landowner, will be filed with the appropriate
land records office. During the performance of routine ground water monitoring activities at the
Site, a Site evaluation will be conducted to ensure that there is no use of the contaminated
ground water prior to attainment of the remediation goals.
The selected remedy is considered more cost effective because the same degree of protectiveness
to human health is realized at a much lower cost. No risks were identified to existing off-Site
residents or off-Site recreational visitors or workers. Since there are no known populations
currently obtaining drinking water from the shallow alluvial aquifer, the most likely potential
receptors were determined to be future recreational visitors and workers that will utilize on-Site
wells to obtain water for drinking or other uses (e.g., irrigation). Potential risks from Site
contaminants were only identified under the hypothetical future recreational visitor and worker
scenario. Although this scenario is possible, it may not be likely considering the existing RV
park is connected to the water supply from the City of West Memphis.
The selected remedy for the ground water operable unit is protective of human health and the
environment and complies with Federal and State requirements that are legally applicable or
relevant and appropriate to the remedial action. Since the ground water contamination does not
represent a principal or low level threat at this Site, treatment to reduce the toxicity, mobility, or
volume of contamination is not necessarily appropriate at this Site to achieve the remediation
goals.
Remedial Goals
The Remedial Goals to be obtained at the conclusion of the remedial action for the ground water
operable unit are identified in Table 9. The natural attenuation process will have achieved the
remedial action objectives when the sampling program indicates with reasonable confidence that
the concentrations of contaminants are less than the remedial goals outside of the waste
management area.
52
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Points of Compliance
Since wastes are left in place at this Site, the landfill is designated as the waste management
area. For ground water, remedial goals should be attained at and beyond the edge of the waste
management area. Thus, the edge of the landfill will be the point of compliance because the
remedial goals are not expected to be attained in ground water within the waste management
area.
Contingency Planning
Following the first five year period after the implementation of Alternative 2, the groundwater
analytical results will be evaluated to determine and document the effectiveness of natural
attenuation. To ensure that the remedy remains protective of human health and environment, the
conditions which were established or which existed as the basis for implementation of
Alternative 2 will be verified during the review of the natural attenuation effectiveness. If any
conditions change during the five year period the situat: n will be reevaluated and appropriate
action will be taken.
One action which may be evaluated is establishing Alternate Concentration Limits (ACLs) for
the ground water. ACLs may be established during the remedial action for Site contaminants in
the ground water in accordance with CERCLA § 121(d)(2)(B)(ii). ACLs are ground water
protection standards that remain protective of human health and the environment under Site-
specific settings. The circumstances under which ACLs may be established are the following:
The ground water must have a known or projected point of entry into surface water. At
this Site, the ground water is directly influenced by and discharges into the Mississippi
River.
There must be no statistically significant increase of constituents in the surface water
body at the points of entry or points downstream. The contaminant concentrations are
reduced significantly by dilution upon entrance to the Mississippi River based on the
ground \vater fiow rate of 14.46 cubic feet/second and the river low flow rate of 78,000
cubic feet/second.
Human exposure to the contaminated ground water can be prevented through the use of
institutional controls. At this Site, the use of a deed notice or other institutional control
will alert current and future property owners of the hazardous substances that remain
beneath the landfill and in the ground water. Periodic ground water monitoring will also
provide an opportunity for visual confirmation that the ground water is not being utilized
inconsistent with the institutional controls.
The ground water remedial goals for this Site are based on MCLs, which are applicable ARARs,
and risk-based standards.
53
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ACLs established for the Site may utilize an exposure rate under the recreational setting that
would produce remedial goals less stringent than the MCLs but still protective of human health.
In addition, ACLs established for the Site may utilize only one exposure route (e.g., dermal
contact through showering) resulting in less stringent remedial goals but still protective of
human health as long as institutional controls remain in effect.
Cost Summary
Table 13 is the detailed cost estimate for the selected ground water remedy. Specific areas
subject to change are the number of monitoring wells and the frequency of sampling conducted
at the Site. Following the source area remediation, the initial two years of monitoring are
expected to be conducted quarterly to develop a statistical data base to monitor the progress of
the natural attenuation process. Sample analyses will be for both organic and inorganic
contaminants to verify the effectiveness of the in-situ stabilization/solidification process. The
frequency of monitoring following this initial period is expected to decrease and may be
continuously adjusted during the long-term monitoring period. However, the rate of the natural
attenuation process in reducing contaminant concentrations at the Site may alter the expected
sampling frequency resulting in a change in the cost estimate for the remedy. For the purposes
of the cost estimate, the frequency of monitoring is expected to decrease to semi-annually for
years 3-10 followed by semi-annually during years 15, 20, 25, and 30. Sample analysis during
years 3-30 is expected to be for inorganics only.
Table 13
Cost Estimate for the Selected Ground Water Remedy
Ground Water Operable Unit
Description of Capital Costs
Mobilization
Drilling
Personnel
Engineering (15%)
Contingency (15%)
Total Capital Costs
Description of Operation &
Maintenance Costs
Sample Analyses for 9
Monitoring Wells
Units
LS
per well
day
LS
LS
Units
LS
Unit Cost
$500
$1,750
$75
$600
$600
Unit Cost
$8,000
$3,000
$3,000
Quantity
2
4
Quantity
Quarterly/Years 1 - 2
Semi-Annually/Years 3-10
Semi-Annually/Years 15, 20, 25,
30
Total Cost
$500
$3,500
$300
$600
$600
$5,500
Total Cost
$64,000
$48,000
$24,000
54
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Table 13
Cost Estimate for the Selected Ground Water Remedy
Ground Water Operable Unit
Data Management
Sampling 8 Monitoring Wells
Five Year Review
Maintenance
LS
LS
Year
Year
$2,250
$3,600
$50,000
$500
Quarterly/Years 1 - 2
Semi-Annually/Years 3 - 10
Semi-Annually/Years 15, 20, 25,
30
Quarterly/Years 1 - 2
Semi-Annually/Years 3-10
Semi-Annually/Years 15, 20, 25,
30
6
30
Total O&M Costs
$18,000
$36,000
$18,000
$28,800
$57,600
$28,800
$300,000
$15,000
$638,200
Summary of Cost Estimate
Total Costs*
Total Present Worth Costs'*
$643,700
$383,461
Notes:
* Capital Cost estimates are not discounted because the construction work will be performed in the first year.
** Present worth estimates use a 5% discount rate for a 30 year duration.
Cost estimates are within +50% to -30% accuracy expectation.
LS = Lump Sum
Expected Outcome of Selected Remedy
The ground water remedy will be implemented following completion of the in-situ
stabilization/solidification of the oily sludge pit and ancillary soil and debris at the Site.
Installation of additional monitoring wells can be accomplished within a short time frame
followed by implementation of the ground water monitoring program. Performance of the
selected remedy in achieving the remedial action objectives and goals will be evaluated under
the monitoring program.
The operation and maintenance activities for the selected remedy are expected to include
collection of ground water samples, measurement of the ground water levels, and inspection of
the monitoring well to verify the integrity of the well. The above ground portion of the
monitoring wells is subject to damage from debris transported across the Site during flooding by
the Mississippi River. Five-year reviews conducted for this operable unit will be performed
55
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according to existing guidance ["Structure and Components of Five-Year Reviews" (OSWER
Directive 9355.7-02), "Supplemental Five-Year Review Guidance" (OSWER Directive 9355.7-
02A), and Second Supplemental Five-Year Review Guidance" (OSWER Directive 9355.7-03A)]
and any updated guidance.
The selected ground water remedy is expected to return the alluvial aquifer to its beneficial use
as a potential source of drinking water after the remedial goals have been achieved. If the
contingency planning indicates that ACLs are appropriate for the Site, then institutional controls,
such as deed notices, may remain in effect indefinitely. Implementation of ACLs for this aquifer
may result in a ban on the installation of any water supply well at the Site, or limitations on the
use of water supplied by a well at the Site (e.g., water used for bathing or irrigation but not for
drinking), or some other restriction that will ensure protection of human health.
STATUTORY DETERMINATIONS '
Under CERCLA section 121, EPA must select .'medics that are protective of human health and
the environment, comply with applicable or relevant and appropriate requirements (unless a
statutory waiver is justified), are cost-effective, and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent practicable. In
addition, CERCLA includes a preference for remedies that employ treatment that permanently
and significantly reduce the volume, toxicity, or mobility of hazardous wastes as their principal
element. The following sections discuss how the selected remedies for the source control and
ground water operable units meet these statutory requirements.
Protection of Human Health and the Environment
The amended source control remedy for the oily sludge pit protects human health and the
environment through the in-situ stabilization/solidification of the oily sludge pit waste. The
stabilization/solidification process will treat the waste so that u is no longer corrosive and
immobilize the hazardous substances present in the oily sludge waste and ancillary soils. The
matrix binding the waste together will have a high unconfined compressive strength, low
permeability, and will prevent or significantly reduce further leaching of contaminants from the
waste into the ground water. The utilization of an in-situ treatment process will also reduce the
short-term risks by reducing the quantity of air emissions and allow for more effective methods
to control these emissions. The placement of 2 natural soil cover will also prevent direct contact
with the treated material. Institutional controls will inform current and future owners that the
Site contains hazardous substances.
The ground water remedy protects human health and the environment through implementation
of a ground water monitoring program to confirm the natural attenuation of contaminants in the
ground water and institutional controls to prevent accidental human exposure. The current
cancer risk to human health through the ground water exposure pathway is 5 x 10"4 (RME) for a
future recreational worker in Area 2/3 of the landfill. For non-carcinogenic threats, the hazard
56
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index is 4 (RME) for a future recreational worker and 3 (RME) for a future recreational visitor
(child) in Area 2/3 of the landfill. By implementing the amended source control remedy for the
oily sludge pit, the principal source of contaminants leaching into the ground water will be
eliminated. Natural attenuation processes are then expected to steadily decrease the existing
contaminant concentrations below the Remedial Goals set for this Site. There are no adverse
impacts identified to either the Mississippi River or any private or City of West Memphis
drinking water well. Implementation of institutional controls will provide notification to current
and future landowners of the existing contamination at the Site. The monitoring program will
evaluate the changes in ground water contaminant concentrations following source area
remediation and tV>° effectiveness of institutional controls in preventing future exposure
scenarios.
Compliance with Applicable or Relevant and Appropriate Requirements
The selected remedy for the source control and ground water operable units will comply with all
applicable cr relevant and appropriate requirements (AP \Rs). The ARARs listed in the 1994
ROD are listed below and identified as to whether the ARAR remains applicable to the amended
source control remedy and/or the ground water remedy. ARARs in addition to those identified
in the 1994 ROD are also presented below.
Chemical-specific ARARs
Clean Water Act (1994 ROD) - If wastewater is generated and discharged on-Site
during implementation of the amended source control remedy, it will have to
meet the substantive requirements of the Clean Water Act and the applicable
standards for discharges to waters of the State of Arkansas as specified by
ADPC&E. EPA has determined that the Water Quality Criteria developed in
accordance with the Clean Water Act § 304 are relevant and appropriate to the
amended source control remedy at the Site. The State of Arkansas has identified
several potential uses for the Mississippi River near the area of the Site, including
primary contact recreation, secondary contact recreation, domestic and industrial
water supply as a perennial delta fishery. Since both humans and aquatic life may
potentially use the surface water near the Site, EPA has determined that the
criteria that apply to both human health and the protection of aquatic life are
relevant and appropriate to the remedial action at the Site. The amended source
control remedy will comply with this ARAR through treatment of any wastewater
before it is discharged from this Site to the Mississippi River.
ADPC&E Regulation No. 6 incorporating 40 CFR SS 122 and 125.3 (1994 ROD)
If wastewater is discharged from the Site to a surface water of the State of
Arkansas during implementation of the amended source control remedy, it must
meet: 1) certain technology-based requirements for the removal of pollutants
from the wastewater prior to discharge, and 2) certain monitoring requirements.
57
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Specific numerical effluent limitations or treatment efficiency requirements will
be established prior to discharging the wastewater. A final method for disposal of
any wastewater collected at the Site has not been selected.
ADPC&E Regulation No. 6 incorporating 40 CFR § 403 (1994 ROD) - If
wastewater is discharged from the Site to a publicly owned treatment works
(POTW) during implementation of the amended source control remedy, it must
meet discharge standards that prevent pass through or interference with the
POTW. A final method for disposal of any wastewater collected at the Site has
not been selected.
Safe Drinking Water Act - The ground water beneath the Site is a potential
source of drinking water. The selected remedies shall attain the non-zero
Maximum Contaminant Level Goals or the corresponding Maximum
Contaminant Level where appropriate under the Safe Drinking Water Act. An
Alternate Concentration Limit may be established during the remedial action for
Site contaminants in the ground water in accordance with CERCLA §
Location-specific ARARs
40 CFR § 6. Appendix A (1994 ROD) - The amended source control remedy
must minimize the potential for harm to the wetlands and restore and preserve
natural and beneficial values of the flood plain. This requirement is applicable to
the amended remedy because the Site is located in the two-year flood plain of the
Mississippi River. The amended remedy will restore and preserve the natural and
beneficial uses of the flood plain by eliminating the severe threat to the
environment associated with the corrosive oily sludge pit and the restoring the
area to its natural conditions through the introduction of native grasses and soils.
40 CFR S 230 and 231 (1994 ROD) - The discharge of fill material into a wetland
without a permit. is prohibited. The substantive requirements of this regulation
are applicable to the amended source control remedy because portions of the Site
are wetland areas. Generally, a permit for discharging fill material into a wetland
will only be granted where the permittee agrees to either create compensatory
wetlands or take other appropriate abatement action. The amended remedy will
comply with this ARAR through the creation of compensatory wetlands during
the excavation of the natural soil material that will be used to construct the soil
cover.
Migratory Bird Act of 1918 H6 U.S.C. SS 703-712) (1994 ROD) - Prohibits the
unregulated and unintentional "taking" of native birds in the U.S., such as would
be the case if a bird landed in the oily sludge pit and was chemically burned or
58
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poisoned. The amended source control remedy will comply with this ARAR
through the in-situ stabilization/solidification of the pit wastes and installation of
a native soil cover because there will be no hazard to native birds after these
actions are completed.
Action-specific ARARs
ADPC&E Regulation No. 22. Section XII.B. incorporating 40 CFR S 258.61 -
Post closure of the landfill must be conducted in accordance with State
regulations. The Operation and Maintenance Plan developed in the remedial
design phase of the project will specify appropriate inspection procedures
designed to maintain the integrity and effectiveness of the final cover. In
addition, the selected remedy requires ground water monitoring to ensure that any
migration of contaminants remaining in the landfill is detected and evaluated
appropriately to ensure they do no create or pose an unacceptable risk to the
public health and the environment. ADPC&E concurs that the existing soil cover
over parts of Areas 1 and 2 of the landfill and all of Area 3 meets the
requirements for the Arkansas Solid Waste Management Code.
Arkansas Pollution Control and Ecology Commission ("APC&EC") Regulation
No. 23. S 264 (1994 ROD) - The systems utilized to effectuate waste treatment or
storage prior to waste treatment must conform to the design and operating
standards set forth in this regulation for hazardous waste treatment and storage
units. Systems that may be utilized in the treatment process include tanks, surface
impoundments, and waste piles.
APC&EC Regulation No. 23. 6 268.42 (1994 ROD) - This regulation requires
treatment to remove the corrosive characteristic [EPA Waste Code D002 - 40
CFR § 261.22 (a)(l)] from the oily sludge pit waste. The amended source control
remedy will treat the oily sludge pit waste in place during the
stabilization/solidification process to neutralize the corrosive characteristic.
APC&EC Regulation No. 23. S 268.41 (1994 ROD) - This regulation requires
treatment to remove the characteristic of lead [EPA Waste Code D008 - 40 CFR §
261.24(a)] from the oily sludge pit waste. The amended source control remedy
will treat the oily sludge pit waste in place during the stabilization/solidification
process such that the concentration of lead in the leachate does not exceed 5.0
mg/L.
The following action-specific ARARs identified in the 1994 ROD are no longer
applicable to the amended source control remedy.
59
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APC&EC Regulation No. 23. $ 264.111 (1994 ROD) - This ARAR is not
applicable to the amended source control remedy. Portions of this regulation
address the excavation of the oily sludge pit waste and placement of clean backfill
which is analogous to closure of a RCRA Subtitle C storage or treatment unit.
The amended source control remedy will treat the oily sludge pit waste in place
during the stabilization/solidification process rather than excavate and dispose of
the waste off-Site. In addition, the waste was disposed in the oily sludge pit prior
to November 19,1980, the effective date of the regulation.
To Be Considered Criteria
Methods for Evaluating the Attainment of Cleanup Standards - In implementing
the selected ground water remedy, the reference document Methods for
Evaluating the Attainment of Cleanup Standards. Volume 2: Ground Water.
(EPA 230-R-92-014, July 1992) provides a variety of standard statistical methods
that may be useful in evaluating he uncertainty of whether the ground water
cleanup standard for a Site has been met.
/
The following criteria considered in the 1994 ROD are no longer applicable to the
amended source control remedy.
Off-Site Disposal Policy (1994 ROD) - This criteria is no longer applicable to the
amended source control remedy ?;nce the wastes will now be treated and
managed on-Site. The policy directs that CERCLA wastes may only be disposed
in a regulated landfill that is in compliance with all environmental laws. The
policy was applicable to the 1994 ROD source control remedy because the oily
sludge pit wastes were to be disposed at an off-Site landfill following treatment.
Performance Criteria for Stabilization (1994 Ri>D) - The stabilization
performance goals specified in the 1994 ROD are not applicable to the amended
source control remedy. Instead, new, more stringent, Site-specific chemical
perforrpance criteria have been developed to ensure that the oily sludge pit wastes
can be treated and managed on-Site without impacting the ground water. The
new performance criteria are listed in Tables 10 and 1 la - lie.
Cost-Effectiveness
EPA believes the amended source control remedy will eliminate the risks to human health at an
estimated cost of $4,243,236. The cost of the amended source control remedy is significantly
lower than the $9,100,000 estimated cost for the 1994 ROD remedy due to a reduction in the
waste material handling during treatment, a reduction in the time necessary to treat the waste,
and a reduction in the size of the landfill cover necessary to protect human health and the
environment and comply with the Arkansas Solid Waste regulations. The amended source
60
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control remedy will meet the same remedial action objectives and goals established in the 1994
ROD utilizing a more cost-effective approach.
EPA believes the ground water remedy will eliminate the risks to human health at an estimated
present worth cost of $383,461. The cost of the selected ground water remedy is significantly
less than the present worth cost of $4,572,975 for the ground water extraction alternative while
still achieving the same remedial action objectives and goals. The selected ground water remedy
is considered more cost effective because the same degree of protectiveness to human health and
the environment is achieved at a much lower cost.
Utilization of Permanent Solutions and Alternative Treatment Technologies for Resource
Recovery Technologies) to the Maximum Extent Practicable
The in situ stabilization/solidification remedy meets the statutory requirement to utilize
permanent solutions and alternative treatment technologies to the maximum extent practicable.
The selected remedy treats the principal threats posed b; the oily sludge pit by neutralizing the
corrosive characteristic of the waste material and isolating the waste contaminants to prevent or
significantly reduce further leaching into the ground water. The selected remedy provides the
most'effective treatment method and will cost less than off-Site disposal. The amended remedy
remains consistent with program expectations that principal threat wastes are a priority for
treatment. EPA has determined that the amended source control remedy provides the best
balance of trade-offs in terms of long-term effectiveness and permanence, reduction in toxicity,
mobility, or volume achieved through treatment, short-term effectiveness, implementability, and
cost, while also considering the statutory preference for treatment as a principal element and
considering state and community acceptance.
The selected ground water remedy meets the statutory requirement to utilize permanent solutions
and alternative treatment technologies to the maximum extent practicable. Natural attenuation
rather than active treatment processes is the most practicable and cost efficient treatment method
available. While natural attenuation is not a treatment technology, it is an alternative means of
achieving the remedial objectives and goals within a reasonable time frame compared to the
other alternative. EPA has determined that the selected ground water remedy provides the best
balance of trade-offs in terms of long-term effectiveness and permanence, reduction in toxicity,
mobility, or volume achieved through treatment, short-term effectiveness, implementability, and
cost, while also considering the statutory preference for treatment as a principal element and
considering state and community acceptance.
Preference for Treatment as a Principal Element
The amended source control remedy satisfies EPA's preference for treatment to address the
principal threat at the Site during the remedial action. The principal threat at the Site is the oily
sludge pit containing the corrosive sludge. The in-situ stabilization/solidification process will
effectively neutralize the corrosive waste by raising the pH of the treated material to between 7
61
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and 11.5. Hazardous substances in the sludge and ancillary soil and debris are a source of long-
term risk at the Site. Treatability studies of the waste material confirmed that the stabilization/
solidification process can effectively reduce the mobility of the hazardous substances in the
waste material. Leachate from the the on-Site management of the treated and solidified waste
material is not expected to impact ground water above the standards set for the Site.
Since the ground water contamination does not represent a principal or low level threat at this
Site, treatment to reduce the toxicity, mobility, or volume of contamination in the ground water
is not necessarily appropriate at this Site. In addition, the use of natural attenuation instead of
active treatment for the ground water is more cost effective because the same degree of
protectiveness to human health and the environment is achieved at a much lower cost.
Therefore, treatment of the ground water is not necessarily appropriate at this Site to achieve the
remedial action objectives or goals.
Because both the source control amended remedy and the ground water remedy will result in
hazardous substances remaining on-site above health-based concentration levels, a review will
be conducted within five years of commencement of the remedial action to ensure that the
remedy continues to provide adequate protection of human health and the environment.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the South 8th Street Landfill Site was released for public comment on
January 5, 1998. The Proposed Plan identified in-situ stabilization/solidification as the preferred
alternative for the oily sludge pit, and monitored natural attenuation for the ground water. EPA
reviewed all written and verbal comments submitted during the public comment period. Upon
review of these comments, it was determined that no significant changes to the remedy, as
originally identified in the Proposed Plan, were necessary.
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SOUTH 8TH STREET LANDFILL SUPERFUND SITE
WEST MEMPHIS, ARKANSAS
AMENDED RECORD OF DECISION
RESPONSIVENESS SUMMARY
This Responsiveness Summary is prepared from written and oral comments received during the
public comment period on the Proposed Plan. The comment period began January 5, 1998, and
closed on February 4, 1998. A formal Public Meeting was held on January 26, 1998, at the
community center located at the corner of 14th and Polk Street in West Memphis, Arkansas.
Approximately 40 people attended the meeting and a transcript of the oral comments received at
the meeting was prepared. EPA also received three (3) written comment letters concerning the
remedial alternatives in the Proposed Plan and the status of the City of West Memphis as a PRP.
The comments were generally supportive of the proposed amended remedy for the oily sludge
pit and the preferred remedy for the ground water. Written comments and the public meeting
transcript are part of the amended Administrative Record.
Summary of Major Comments Received
1. Comment: The status of the taxpayers and the City of West Memphis, as a Potentially
Responsible Party (PRP), should be clearly defined as it relates to the South 8th Street
Superfund Site. The City of West Memphis and its citizen taxpayers should be
eliminated as PRPs and should not bear any cost for the proposed remedial alternatives at
the Site.
Response: The City of West Memphis is a PRP for the South 8th Street Superfund Site
based on the past disposal of hazardous substances, pollutants, or contaminants at the
Site. EPA's Municipal Settlement Policy outlines the enforcement policy regarding
municipal liability. EPA has not made a determination on the nature of any settlement
with the City of West Memphis.
2. Comment: An official with the Arkansas Department of Pollution Control and Ecology
(ADPC&E) stated in a conversation on July 24, 1997, that the City of West Memphis
would not have PRP responsibility for the South 8th Street Superfund Site.
Response: ADPC&E has formally responded to this comment in a letter dated January
22,1998, (see amended Administrative Record index). Specifically, ADPC&E's
understanding is "... that the City is a PRP at the Site based on information in the
Eckhardt survey that indicates the City transported waste to the Site" and that"... the
City's status as a PRP has not changed." The Eckhardt survey was conducted by the
U.S. House Congressional Sub-Committee on Interstate Commerce and Transportation.
In addition, ADPC&E and the Governor's Office have previously stated in letters of
September 23, 1993, and November 17, 1993, that EPA should minimize the cost to the
City of West Memphis.
63
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3. Comment: The South 8th Street Superfund Site is outside the West Memphis City limits
and has not been owned or operated by the City of West Memphis.
Response: On the West Memphis and Marion City map published by the Chamber of
Commerce, portions of the South 8th Street Superfund Site are within the West Memphis
City limits. The South 8th Street Superfund Site is an unpermitted disposal site located
on land owned by the W. L. Johnson Company.
4. Comment: The responsibility for the sludge pit and the landfill area should be separated
since the source of the two problems is different.
Response: The comment does not affect the selection of a remedial alternative for the
Site. EPA has not completed a settlement agreement with any of the potentially
responsible parties (PRPs) which assesses actual monetary costs for remediation of the
South 8th Street Superfund Site.
5. Comment: Has EPA determined whether the source of the ground water contamination is
from the oily sludge pit, the Mississippi River, or some other source?
Response: As discussed in the Proposed Plan and ROD Amendment, ground water at the
Site was evaluated through the installation of fourteen monitoring wells in the sand and
gravel aquifer. Ground water samples collected from monitoring wells nearest the oily
sludge pit (wells MW 3S, 31, 3D, 4S, 41, and 8S) contained the contaminants of concern
such as lead, arsenic, and manganese. These contaminants are also found in high
concentrations in the oily sludge pit which indicates that the oily sludge pit is the
principal source of ground water contamination at the Site. A secondary source of
arsenic and manganese were also detected in samples collected from Area 2 of the
landfill outside of the oily sludge pit.
6. Comment: Several comments were raised at the public meeting about environmental
issues in West Memphis. These comments were directed to issues concerning waste oil
in and around the 7th Street ditch, an illegal dump site under the 1-55 bridge, and air odor
issues in West Memphis.
Response: Representatives from the Arkansas Department of Pollution Control and
Ecology were present at the public meeting. The representatives answered questions
concerning these environmental issues prior to the start of the public meeting. The
environmental issues are being addressed separately by ADPC&E and are unrelated to
the South 8th Street Landfill Superfund Site or the remedy selection at the Site.
7. Comment: Health concerns in West Memphis from the consumption offish and air
pollution were raised at the public meeting.
64
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Response: A public health official from the Arkansas Department of Health (ADH) was
present at the public meeting and answered questions concerning the public health
assessment, dated November 22, 1994, performed by ADH. The health concerns are
being addressed separately by the ADH and a copy of the meeting transcript was also
sent to the public health official at ADH. The health issues are unrelated to the South 8th
Street Landfill Superfund Site or the remedy selection at the Site.
8. Comment: The scope of the proposed ground water monitoring should be in the vicinity
of the oily sludge pit and ancillary soil area with the objective of monitoring the
effectiverx^s of the oily sludge pit remedy. Such a monitoring program would include
wells MW3S, MW3I, MW3D,MW4S, MW4I, MW8S and the two new wells installed
adjacent to the solidified/stabilized material. The South 8th Street Site Group does not
agree with the need for the proposed ground water monitoring for the municipal waste
portion of the landfill.
Response: While EPA's selected ground water r^ nedy has the flexibility to increase or
decrease the scope of the ground water monitoring program at the Site, the expected
program will include wells MW3S, MW3I, MW3D,MW4S, MW4I, MW8S and two
new wells installed adjacent to the solidified/stabilized material. In addition, ADPC&E
has requested the inclusion of well MW7S for at least the first two years of the
monitoring program. EPA has moved the ground water monitoring component originally
identified in the 1994 ROD for the landfill component of the source control remedy to
the selected ground water remedy.
65
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APPENDIX A
ADPC&E CONCURRENCE LETTER
66
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STATE OF ARKANSAS ,_ ^ _ .
DEPARTMENT OF POLLUTION CONTROL AND ET>Ot
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APPENDIX B
INDEX OF ADMINISTRATIVE RECORD
68
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Prepared for
United States Environmental Protection Agency
Region 6
Administrative Record Addendum Index
for
South 8th Street Landfill Superfund Site
Record of Decision Amendment for Source Control
Operable Unit/Ground Water Operable Unit
EPA ID No. ARD980496723
ESS VI
Work Assignment No. ESS8033
Vincent Malott
Remedial Project Manager
U.S. EPA Region 6
Prepared by
Tech Law, Incorporated
750 N. St. Paul Street, Suite 600
Dallas, Texas 75201
July 29,1998
P. 6833.06H8
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INTRODUCTION
Section 113(j)(l) of the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA), 42 U.S.C. Section 9613(j)(l)> provides that judicial review of any issues concerning
the adequacy of a response action shall be limited to the administrative record compiled for the site.
CERCLA, as amended by the Superfund Amendments and Reauthorization Act (SARA), requires
the U.S. Environmental Protection Agency (EPA) to compile documents which form the basis for
the selection of the remedial CERCLA and SARA response actions. These supporting documents
form an "administrative record" (AR) which the Agency must provide for public review. The ARs
are maintained at relevant EPA Regional Offices as well as "at or near the facility at issue."
The following AR Addendum Index was compiled in accordance with Office of Solid Waste
and Emergency Response Directive Number 9833.3A-1, "Final Guidance on Administrative Records
for Decisions on Selection of CERCLA Response Actions" (December 3, 1990). The AR Addendum
Index supplements the Administrative Record for the Record of Decision dated September 29, 1994;
documents from the previous AR are incorporated by reference. Documents listed as bibliography
sources in response decision documents may not be listed in the AR Index. All documents that are
clearly relevant and non-privileged are placed in the record file, entered into the index, and made
available to the public as soon as possible. The documents included in the index are predominately
arranged in chronological order. EPA may send additional supplemental AR volumes and indexes
to the designated repository. These supplements should be placed with the initial record. Documents
attached to or referenced in the Proposed Amended Record of Decision are incorporated by reference
into the AR.
The AR index plays a key role in-enabling both lead agency staff and members of the public
to help locate and retrieve documents included in the record file. In addition, the index can be used
for public information purposes or identifying documents located elsewhere, such as those included
in the compendium of guidance documents. The index also serves as an overview of the history of
the response action at the site. The AR Addendum Index helps readers locate and retrieve documents
in the file. It also provides an overview of the response action history. The index includes the
following information for each document:
AR Page No. - The sequential numbers stamped on each page of the AR. The six-digit
numbers are located in the upper right-hand corner of each page.
Document Date - The date the document was published and/or released. "Undated" means
no date was recorded.
No. of Pages - Total number of printed pages in the document, including attachments.
Author - Name and title of the originator.
Company/Agency - Originator's affiliation.
Recipient Name, title, and affiliation of the recipient.
Document Type General identification, e.g., correspondence, Remedial Investigation
Report, Record of Decision, etc.
Document Title - Descriptive title or synopsis.
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009518 - 009522
01/31/90
5
F.K. Cartledge, H.C. Eaton, M.E. Tittlebaum
Risk Reduction Engineering Laboratory, U.S. EPA Region 6
Site Project Files
Report
The Morphology and Microchemistry of Solidified/Stabilized
Hazardous Waste Systems
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009523 - 009529
10/31/91
7
Staff Members
Office of Research and Development, U.S. EPA Headquarters
Site Project Files
Fact sheet
Control of Air Emissions From Materials Handling During
Remediation
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009530 - 009542
05/31/93
13
Staff Members
Office of Emergency and Remedial Response, U.S. EPA
Headquarters
Site Project Files
Fact sheet
Solidification/Stabilization of Organics and Inorganics
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAG^S:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009543 - 009556
10/29/93
14
Allyn M. Davis, Director, Hazardous Waste Management Division
(HWMD)
U.S. EPA Region 6
HWMD Staff
Memorandum
HWMD Superfund Program Guidelines: Region 6 Superfund Program
Criteria for Determining the Effectiveness of
Stabilization/Solidification
A-l
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009557 - 009586
09/30/94
30
Unknown
U.S. EPA
Site Project Files
Report
Method 1312 - Synthetic Precipitation Leaching Procedure
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009587 - 009590
10/26/95
4 . />
Edward Bates, START Team Leader, Site Management Support
Branch
U.S. EPA, National Risk Management Research Laboratory,
Cincinnati, Ohio
Susan Webster, RPM, U.S. EPA Region 6
Memorandum
Comments on "Proposed Statement of Work Remedial Design (RD)
for Source Area Operable Unit" dated October 1995
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009591 - 009601
01/15/96
11
Craig Hepburn
Conestoga-Rovers & Associates
Susan Webster, RPM, U.S. EPA Region 6
Correspondence
Ke: Monthly Progress Report No. 1 - December 1995/RD for
Source Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009602 - 009608
01/22/96
7
Craig Hepburn
Conestoga-Rovers & Associates
Susan Webster, RPM, U.S. EPA Region 6
Fax Transmittal; Map; Table
Transmittal of the figures and tables omitted from the June
15, 1996 Request for Statement of Interest Letter
A-2
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009609 - 009611
01/30/96
3
Bruce Monteith
Conestoga-Rovers & Associates
Devon Hobby, Arkansas Department of Pollution Control and
Environment (ADPC&E)
Corre spondence
Re: Transportation of the stabilized/solidified sludges from
the oily sludge pit to an off-site Subtitle D landfill
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009612 - 009614
02/14/96
3
Craig Hepburn
Conestoga-Rovers & Associates
Susan Webster, RPM, U.S. EPA Region 6
Correspondence
Re: Monthly Progress Report No. 2 - January 1996/RD for
Source Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009615 - 009724
03/14/96
110
Unspecified
U.S. EPA Region 6
Site Project Files
Administrative Order
Administrative Order on Consent for RD for Source Control
Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009725 - 009728
04/15/96
4
Craig Hepburn
Conestoga-Rovers & Associates
Susan Webster, RPM, U.S. EPA Region 6
Corre spondence
Re: Monthly Progress Report No. 4 - March 1996/RD for Source
Control Operable Unit
A-3
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
009729 - 009731
05/15/96
3
Craig Hepburn
Conestoga-Rovers & Associates
Susan Webster, RPM, U.S. EPA Region 6
Correspondence
Re: Monthly Progress Report No. 5 - April 1996/RD for Source
Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
009732 - 009734
06/12/96
3
Craig Hepburn
Conestoga-Rovers & Associates
Susan Webster, RPM, U.S. EPA Region 6
Correspondence
Re: Monthly Progress Report No. 6 - May 1996/RD for Source
Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TTLE:
009735 - 010224
07/04/96
490
Craig Hepburn
Conestoga-Rovers & Associates
Susan Webster, RPM, U.S. EPA Region 6
Correspondence; Work Plan
Submitt- il of RD Workplan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010225 - 010226
07/10/96
2
Craig Hepburn
Conestoga-Rovers & Associates
Susan Webster, RPM, U.S. EPA Region 6
Fax Transmittal; Correspondence
Re: Approval of Contractors for the South 8th Street Landfill
Site
A-4
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010227 - 010236
07/10/96
10
Craig Hepburn
Conestoga-RoverB & Associates
Susan Webster, RPM, U.S. EPA Region 6
Correspondence; Fax Transmittal
Re: Solidification/Stabilization Treatability Study Vendors
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010237 - 010239
07/15/96
3
Craig Hepburn
Conestoga-Rovers & Associates
Susan Webster, RPM, U.S. EPA Region 6
Correspondence; Report
Re: Monthly Progress Report No. 7 - June 1996/RD for Source
Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010240 - 010242
07/18/96
3
Craig Hepburn
Conestoga-Rovers & Associates
Susan Webster, RPM, U.S. EPA Region 6
Corre spondence
Re: RD field activities schedule
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010243 - 010243
07/22/96
1
Susan Webster, RPM
U.S. EPA Region 6
Bruce Monteith, Conestoga-Rovers & Associates
Corre spondence
Notice that the EPA approves the RD Work Plan dated July 4,
1996
A-5
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
010244 - 010248
07/24/96
5
Bruce Monteith
Conestoga-Rovers & Associates
Ross Hopper, Crittenden Memorial Hospital
Correspondence
Submittal of emergency plan for the South 8th Street site
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010249 - 010251
08/06/96
3
Craig Hepburn and Lou Almeida
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Fax Transmittal; Sampling and Analysis
Submittal of PAH, PCB and lead results for the sludge
treatability characterization samples collected from the site
on July 31, 1996
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010252 - 010257
08/14/96
6
Craig Hepburn
Coneetoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Corre spondence
Re: Monthly Progress Report No. 8 - July 1996/RD for Source
Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010258 - 010280
09/06/96
23
Edward Bates, START Leader, Site Management Support Branch
U.S. EPA, National Risk Management Research Laboratory,
Cincinnati, Ohio
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Memorandum; Report/Study
Physical assessment of the viability of implementing in-situ
(auger) treatment of the oily sludge pit and ancillary area
A-6
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADDENDUM
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
010281 - 010328
09/12/96
48
Craig Hepburn
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Correspondence
Re: Monthly Progress Report No. 9 - August 1996/RD for Source
Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010329 - 010360
09/12/96
32
J. Douglas Cheek, Project Hydrologist and Robert K. Franke,
ARCS Program Manager
Flour Daniel, Inc.
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Correspondence; Report
Submittal of the Field Activities Report for Oversight of the
Treatability Study
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010361 - 010823
09/30/96
463
Staff Consultants
Fluor Daniel, Inc.
U.S. EPA Region 6
*" aport
Remedial Investigation Report, Ground Water Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010824 - 010826
10/15/96
3
Craig Hepburn
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Corre spondence
Re: Monthly Progress Report No. 10 - September 1996/RD for
Source Control Operable Unit
A-7
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADDENDUM
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
010827 - 010831
10/16/96
5
MaryAnn Abrahamson, RPM
U.S. EPA Region 6.
Devon Hobby, ADPC&B
Correspondence; Health Assessment
EPA's responses to ADPC&E's September 13, 1996 comments on
Baseline Risk Assessment, Groundwater Operable Unit, Human
Health Evaluation (August 30, 1996)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010832 - 010933
10/21/96
102
Stephen D. Luftig, Director, Office of Emergency and Remedial
Response
U.S. EPA Headquarters
Director, Office of Site Remediation and Restoration, Region
1, et.al
Memorandum; Contact List; EPA Guidance
Pre-publication copy of Final Guidance: "Presumptive Response
Strategy for Contaminated Ground Water"
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010934 - 010943
10/28/96
10
Craig Hepburn
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Correspondence; Sampling and Analysis
Summarization of preliminary results from
solidification/stabilization treatability studies performed on
homogenized oily sludge material
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010944 - 010947
10/30/96
4
Edward Bates, START Leader
U.S. EPA, National Risk Management Research Laboratory,
Cincinnati, Ohio
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Memorandum
Comments on preliminary results from the treatability study
A-8
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
SOOTH 8TH STREET LANDFILL SITE
ARD980496723
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
010948 - 011016
11/08/96
69
Craig Hepburn
Conestoga-Rovers Associates
MaryAnn Abrahamson, RPM, U.S.
Corre spondence
Re: Technical Letter Report
EPA Region 6
- Landfill Cover Evaluation
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011017 - 011020
11/11/96
4
Craig Hepburn
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Corre spondence
Re: Monthly Progress Report No. 11 - October 1996/RD for
Source Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011021 - 011024
11/26/96
4
Craig Hepburn
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Correspondence
Re: Disposal of 22 55-gallon drums of decontamination water
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011025 - 011028
12/02/96
4
Bruce Monteith
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Correspondence
Re: A request for an extension of the schedule for the
submission of the 30% design submittals
A-9
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
011029 - 011029
12/03/96
1
Craig Hepburn
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Corre spondence
Re: Landfill Cover and Landfill Gas Field Activities
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011030 - 011034
12/16/96
5
Craig Hepburn
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Corre sponence
Re: Monthly Progress Report No. 12 - November 1996/RD for
Source Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011035 - 011051
12/19/96
17
Craig Hepburn
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EI-« Region 6
Fax Transmittal; Sampling and Analysis
Submittal of preliminary analytical results from
solidification/stabilization treatability studies for South
uth Street
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011052 - 011056
01/02/97
5
Ian Mendes
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Pax Transmittal; Sampling and Analysis
Submittal of second mix design from SOUND Environmental
A-10
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
011057 - 011066
01/08/97
10
J. Douglas Cheek, Project Hydrologist and Robert K. Franke,
ARCS Program Manager
Flour Daniel, Inc.
MaryAnn Abrahameon, RPM, U.S. EPA Region 6
Correspondence
Submittal of the Field Activities Report for the South 8th
Street Landiill
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011067 - 011068
01/09/97
2
Unknown
Conestoga-Rovers & Associates
Site Project Files
Agenda
Project Status Review (1/9/97) South 8th Street Landfill
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITL2-
011069 - 011075
01/14/97
7
Craig Hepburn
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Correspondence
1 2: Monthly Progress Reports No. 13 - December 1996/RD for
Source Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011076 - 011083
01/17/97
8
Craig Hepburn
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Fax Transmittal; Sampling and Analysis
Re: The stabilizaton performance goals for treatment of the
oily sludge requires a reduction in the total contamination
concentrations
A-ll
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
011084 - 011088
01/27/97
5
Edward Bates, START Leader, Site Management Support Branch
U.S. EPA, National Risk Management Research Laboratory,
Cincinnati, Ohio
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Memorandum; Sampling & Analysis
Technical review comments on Conestoga-Rovers & Associates
Treatability Study results
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011089 - 011090
02/05/97
2
Bruce Monteith
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Correspondence
Re: Transmittal of the Preliminary Design Submittals
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011091 - 011271
02/05/97
181
Staff Consultants
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Report; Sampling ard Analysis
Data Collection Summary Report Preliminary Design Submittal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011272 - 011588
02/05/97
317
Staff Consultants
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Report
Treatability Study Evaluation Report - Preliminary Design
Submittal
A-12
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
011589 - 011774
02/05/97
186
Staff Consultants
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Report
Landfill Cover Evaluation Report Preliminary Design Submittal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011775 - 011779
02/17/97
5
Craig Hepburn
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Correspondence
Re: Monthly Progress Report No. 14 - January 1997/RD for
Source Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011780 - 011783
02/21/97
4
Edward Bates, START Leader, Site Management Support Branch
U.S. EPA, National Risk Management Research Laboratory,
Cincinnati, Ohio
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Memorandum
Comments on "Treatability Study Evaluation Report Preliminary
Design Submittal* dated February 5, 1997
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011784 - 011784
02/21/97
1
Bruce Montieth
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Ragion 6
Memorandum
Re: Submittal of a proposed Record of Decision (ROD)
Amendment Document
A-13
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011785 - 011787
02/21/97
3
Edward Bates, START Leader, Site Management Support Branch
U.S. EPA, National Risk Management Research Laboratory,
Cincinnati, Ohio
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Memorandum
Comments on *RD Criteria Report Preliminary Design Submittal'
dated February 5, 1997
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011788 - 011792
02/24/97
5
Craig Hepburn
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Memorandum
Re: EPA Prescribed SPLP Performance Criteria
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011793 - 011910
02/28/97
118
Staff Consultants
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Record of Decision
Proposed Amendment to ROD (Source Control Operable Unit)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011911 - 011929
03/17/97
19
Craig Hepburn
Conestoga-Rovers & Associated
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Correspondence
Re: Monthly Progress Report No. 15 - February 1997/RD for
Source Control Operable Unit
A-14
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
011930 - 011941
03/27/97
12
MaryAnn Abrahamson, RPM
U.S. EPA Region 6
Bruce Monteith, Conestcga-Rovers & Associates, Inc.
Correspondence; Report/Study
BPA's review comments on the February 6, 1997, Preliminary
Design
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011942 - 011947
04/10/97
6
J. Douglas Cheek, Project Hydrologist and Robert K. Franke,
ARCS Program Manager
Fluor Daniel, Inc.
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Correspondence; Meeting Notes; Agenda
Minutes from Design Meeting held on April 4, 1997
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011948 - 011962
04/14/97
15
Craig Hepburn
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Corre spondence
Re: Monthly Progress Report No. 16 - March 1997/RD for Source
Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011963 - 011967
04/14/97
5
Bruce Monteith
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Corre spondence
Re: Remaining RD Task and Implementation Schedule
A-15
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011968 - 011975
04/16/97
8
Craig Hepburn
Conestoga-Rovers & Associates
Edward Bates, START Leader, Site Management Support Branch,
U.S. EPA - Cincinnati, Ohio
Fax Transmittal; Scope of Work
Re: Additional review of the proposed scope of work for
treatability studies on the South 8th Street oily sludge
material
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011976 - 011976
04/18/97
1
Edward Bates, START Leader, Site Managment Support Branch
U.S. EPA, National Risk Managment Research Laboratory,
Cincinnati, Ohio
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Memorandum
Commonts on Treatability Testing proposed by Conestoga Rovers
& Associates in April 16, 1997 letter
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011977 - 011986
04/23/97
10
Craig Hepburn
Conestoga-Rovers & Associates
Rich McManus, Sound Environmental Services Inc. and attached
addressees
Corre spondence
Re: Additional Solidification/Stabilization Treatability
Studies
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
011987 - 012223
04/24/97
237
Bruce Monteith
Conestoga-Rovers & Associates
Devon Hobby, ADPC&E
Memorandum; Record of Decision
Re: Proposed Amendment to ROD Remedy/Landfill Cover Component
A-16
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
012224 - 012224
04/25/97
1
Craig Hepburn
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Corre spondence
Re: Transmittal of responses to BPA's and ADPC&B's comments
on the South 8th Street Landfill Preliminary Design Submittal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012225 - 012266
04/25/97
42
Staff Consultants
Conestoga-Rovers & Associates
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Report
South 8th Street Preliminary Design (30%) Comment/Response
Document US EPA Comments
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012267 - 012267
05/02/97
1
MaryAnn Abrahamson, RPM
U.S. EPA Region 6
Bruce Monteith, Conestoga-Rovers & Associates
Corre spondence
Notice of a change in the EPA project officer for this site
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012268 - 012269
05/07/97
2
Edward Bates, START Leader, Site Management Support Branch
U.S. EPA, National Risk Management Research Laboratory,
Cincinnati, Ohio
MaryAnn Abrahamson, RPM, U.S. EPA Ragion 6
Memorandum
Comments on "Additional Solidification/Stabilization
Treatability Studies" dated April 23, 1997
A-17
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
SOOTH 8TH STREET LANDFILL SITE
ARD980496723
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012270 - 012270
05/07/97
1
Edward Bates, START Leader, Site Management Support Branch
U.S. EPA, National Risk Management Research Laboratory,
Cincinnati, Ohio
MaryAnn Abrahamson, RPM, U.S. EPA Region 6
Memorandum
Comments on Preliminary Design (30V) Comments/Response
Document U.S. EPA Comments" dated April 25, 1997
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012271 - 012272
05/08/97
2
MaryAnn Abrahamson, RPM
U.S. EPA Region 6
Bruce Monteith, Conestoga-Rovers & Associates
Correspondence
Re: The Agency's denial of Conestoga-Rover & Associates'
proposal to revise th«* schedule
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012273 - 012276
05/09/97
4
Unknown
U.S. EPA Region 6
Site Project Piles
Agenda; Meeting Attendee List
3outh 8th Street Site Meeting to Transition to New RPM
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012277 - 012280
05/15/97
4
Craig Hepburn
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Corre spondence
Monthly Progress Report No. 17 - April 1997/RD for Source
Control Operable Unit
A-18
-------
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
012281 - 012289
05/16/97
9
Bruce Monteith
Conestoga-Rovers & Associates
Rich McManus, Sound Environmental Services Inc. and attached
addressees
Correspondence; Tables
Re: Regarding request for one final mix design for further
testing
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012290 - 012291
05/23/97
2
Bruce Monteith
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Letter
Re: Transmittal of the Intermediate Design Submittals
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012292 - 012345
05/23/97
54
Staff Consultants
Conestoga-Rovers & Associates
Vincent Malott. RPM, U.S. EPA Region 6
Correspondence
Construction Health and Safety and Air Monitoring Plan
Intermediate Design Submittal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012346 - 012359
05/23/97
14
Staff Consultants
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Report
Deed Notification Plan - Intermediate Design Submittal
A-19
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012360 - 012384
05/23/97
25
Staff Consultants
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Report
Release Prevention/Contingency Plan Intermediate Design
Submittal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012385 - 012431
05/24/97
47
Staff Consultants
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Report
Construction Quality Assurance Project Plan - Intermediate
Design Submittal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012432 - 012672
05/24/97
241
Staff Consultants
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Report
Intermediate Design Report - Source Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012673 - 012728
05/24/97
56
Staff Consultants
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Report
Operations, Maintenance, and Groundwater Monitoring Plan -
Intermediate Design Submittal
A-20
-------
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
012729 - 012789
05/24/97
61
Staff Consultants
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Report
Sampling and Analysis Plan - Intermediate Design Submittal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012790 - 012808
05/24/97
19
Staff Consultants
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Report
Wetland Mitigation Plan - Intermediate Design Submittal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012809 - 012812
06/03/97
4
Edward Bates, START Leader, Site Management Support Branch
U.S. EPA, National Risk Management Research Laboratory,
Cincinnati, Ohio
Vincent Malott, RPM, U.S. EPA Region 6
Memorandum
Leaching performance standard for on-site disposal of soils
and sludges by solidification/stabilization
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012813 - 012815
06/03/97
3
Bruce Monteith
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Correspondence; Map
Re: The site group proposes to erect a new security fence
along the top of the earthen berm
A-21
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADDENDUM
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
012816 - 012816
06/05/97
1
Vincent Malott, RPM
U.S. EPA Region 6
Bruce Monteith, Conestoga-Rovers & Associates
Corre spondence
Notice that the EPA submits its approval of the proposal to
erect a new security fence around the top of the earthen berm
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012817 - 012820
06/13/97
4
Craig Hepburn
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Correspondence; Report; Graph
Re: Monthly Progress Report No. 18 - May 1997/RD for Source
Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012821 - 012826
07/01/97
6
Vincent Malott, RPM
U.S. EPA Region 6
Bruce Monteith, Conestoga-Rovers & Associates
Correspondence; Report
Submittal of the Agency's comments on the Intermediate Design
Reports for the Source Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012827 - 012842
07/15/97
16
Craig Hepburn
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Correspondence
Monthly Progress Report No. 19 - June 1997/RD for Source
Control Operable Unit
A-22
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
012843 - 012844
07/16/97
2
Ian L. Mendes
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Corre spondence
Re: Installation of a temporary six foot fence along the top
soil berm
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012845 012848
07/21/97
4
Gary P. Gengel
Oppenheimer Wolff & Donnelly
Vincent Malott, RPM, U.S. EPA Region 6
Corre spondence
Confirmation of the understanding reached between the EPA and
the Group regarding performing the RD according to the
anticipated amended ROD
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012849 - 012849
07/22/97
1
William K. Honker, Chief, Arkansas/Oklahoma/Texas (AR/OK/TX)
Branch
U.S. EPA Region 6
Jean Koeninger, Superfund Manager, ADPCtE
Correspondence
The Agency is requesting that ADPC&E evaluate whether a waiver
of the landfill cover requirements can be granted for a
reduced cover size at the site
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012850 - 012850
07/25/97
1
Craig Hepburn
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Correspondence
Re: Supplemental Treatability Study Report
A-23
-------
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
012851 - 012852
07/25/97
2
Vincent Malott, RPM
U.S. EPA Region 6
Gary P. Gengel, Oppenheimer Wolff & Donnelly
Corre spondence
Agency's response to a request to proceed with the remedial
design according to the proposed amendment to the ROD
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012853 - 012974
07/30/97
122
Staff Consultants
Fluor Daniel, Inc.
U.S. EPA Region 6
Report/Study
Feasibility Study Report, Ground Water Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012975 - 012975
07/31/97
1
Mike Bates, Chief, Hazardous Waste Division
ADPC&E
William Honker, Chief, AR/OK/TX Branch, U.S. EPA Region 6
Correspondence
Response to EPA's request that the requirements for additional
soil cover at the site be reduced
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012976 - 012992
08/01/97
17
Craig Hepburn
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Correspondence
Re: Intermediate Design Comment/Response Document and Amended
Remedy Cost Estimate
A-24
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012993 - 012994
08/14/97
2
Bruce Monteith
Conestoga-Rovera & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Correspondence
Final Design Submittal, Source Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
012995 - 013052
08/14/97
58
Staff Consultants
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Report
Construction Health and Safety and Air Monitoring Plan - Final
Design Submittal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013053 - 013098
08/14/97
46
Staff Consultants
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Report
Construction Quality Assurance Project Plan - Final Design
Submittal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013099 - 013120
08/14/97
22
Staff Consultants
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Report
Deed Notification Plan - Final Design Submittal
A-25
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
013121 - 013331
08/14/97
211
Bruce A. Monteith
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Report
Final Design Report Source Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013332 - 013387
08/14/97
56
Staff Consultants
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Report
Operations, Maintenance, and Groundwater Monitoring Plan -
Final Design Submittal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013388 - 013413
08/14/97
26
Staff Consultants
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Report
Release Prevention/Contingency Plan - Final Design Submittal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013414 - 013471
08/14/97
58
Staff Consultants
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Report
Sampling and Analysis Plan - Final Design Submittal
A-26
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPfc:
DOCUMENT TITLE:
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
013472 - 013489
08/14/97
18
Staff Consultants
Conestcga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Report
Wetland Mitigation Plan - Final Design Submittal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013490 - 013493
08/15/97
4
Craig Hepburn
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Corre spondence
Re: Monthly Progress Report No. 20 - July 1997/RD for Source
Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013494 - 013527
09/13/97
34
Office of Solid Haste and Emergency Response (OSWER)
U.S. EPA Headquarters
Site Project Files
Report/Study
OSWER Directive No. 9200.4-17 "Use of Monitored Natural
Attenuation at Superfund, RCRA Corrective Action, and
Underground Storage Tank Sites" (Draft)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013528 - 013531
09/15/97
4
Craig Hepburn
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Corre spondence; Table
Monthly Progress Report No. 21 - August 1997/RD for Source
Control Operable Unit
A-27
-------
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
013532 - 013542
09/16/97
11
Vincent Malott, RPM
U.S. EPA Region 6
Bruce Monteith, Coneatoga-Rovers & Associates
Fax Transmittal; Correspondence; Sampling and Analysis
Re: EPA's review of the Final Design submittals for the
Source Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013543 - 013556
09/16/97
14
Edward Bates, START Leader, Site Management Support Branch
U.S. EPA, National Risk Management Research Laboratory,
Cincinnati, Ohio
Vincent Malott, RPM, U.S. EPA Region 6
Memorandum; Other
Solidification/Stabilization of Soils and Sludges Containing
Inorganic and Organic Volatile Compounds
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013557 - 013560
09/29/97
4
Craig Hepburn
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Correspondence; Table
Additional Lead Analyses, Solidification/Stabilization
Treatability Studies
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013561 - 013564
10/14/97
4
Craig Hepburn
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Correspondence; Table
Monthly Progress Report No. 22 - September 1997/RD for Source
Control Operable Unit
A-28
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013565 - 013568
10/16/97
4
Devon Hobby
ADPC&E
Vincent Malott, RPM, U.S. EPA Region 6
Corre spondence
Comments on Final Design Submittal, Source Control Operable
Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013569 - 013588
10/24/97
20
Craig Hepburn
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Correspondence; Report
Final Design Comment - Response Document
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013589 - 013606
11/05/97
18
Staff Consultants
Conestoga-Rovers & Associates
Site Project Files
Report
Wetland Mitigation Plan - Final Design Submittal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013607 - 013631
11/05/97
25
Staff Consultants
Conestoga-Rovers & Associates
Site Project Files
Report
Release Prevention/Contingency Plan
- Final Design Submittal
A-29
-------
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013632 - 013686
11/05/97
55
Staff Consultants
Conestoga-Rovers & Associates
Site Project Files
Report
Sampling and Analysis Plan - Final Design Submittal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013687 - 013698
11/05/97
12
Staff Consultants
Conestoga-Rovers & Associates
Site Project Files
Report
Deed Notification Plan - Final Design Submittal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013699 - 013701
11/06/97
3
Craig Hepburn
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Correspondence
Final Design Documents, Source Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013702 - 013746
11/06/97
45
Staff Consultants
Conestoga-Rovers & Associates
Site Project Files
Report
Construction Quality Assurance Project Plan - Final Design
Submittal
A-30
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ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADDENDUM
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
013747 - 013800
11/06/97
54
Staff Consultants
Conestoga-Rovers & Associates
Site Project Files
Report
Operations, Maintenance, and Ground Hater Monitoring Plan
Final Design Submittal
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013801 - 013859
11/06/97
59
Staff Consultants
Conestoga-Rovers & Associates
Site Project Files
Report
Construction Health and Safety and Air Monitoring Plan
Design Submittal
- Final
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
013860 - 014073
11/06/97
214
Staff Consultants
Conestoga-Rovers & Associates
U.S. EPA Region 6
Report
final Design Report - Source Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
014074 - 014075
11/07/97
2
Vincent Malott, RPM
U.S. EPA Region 6
Site Project Files
Memorandum; Table
Summary table of water level measurements in monitoring wells
for quarters 1-6
A-31
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
014076 014078
11/07/97
3
Vincent Malott, RPM
U.S. EPA Region 6
Site Project Files
Memorandum; Graph
Charts illustrating 1996 and 1997 site flood occurences
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
014079 - 014086
11/07/97
8
Vincent Malott, RPM
U.S. EPA Region 6
Site Project Piles
Memorandum; Graph; Table
Contaminant concentrations profiles for selected monitoring
wells
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
014087 - 014172
11/07/97
86
Vincent Malott, RPM
U.S. EPA Region 6
Site Project Files
Memorandum; Sampling & Analysis; Table
Ground water analytical results for May 1997
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
014173 - 014216
11/07/97
44
Vincent Malott, RPM
U.S. EPA Region 6
Site Project Files
Memorandum; Sampling & Analysis; Table
Ground water analytical results for August 1997
A-32
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
014217 - 014260
11/07/97
44
Vincent Malott, RPM
U.S. EPA Region 6
Site Project Files
Memorandum; Map; Meeting Minutes; Sampling & Analysis
Source Control Operable Unit, Analytical Results and Risk
Calculation for Contaminants in the Landfill Surface Soils
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
014261 - 014287
12/01/97
27
Unspecified
U.S. EPA Region 6
Site Project Files
Proposal
Proposed Plan of Action
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
014288 - 014290
12/15/97
3
Craig Hepburn,
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Report; Schedule
Monthly Progress Report No. 24 - November 1997, Remedial
Design for Source Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
014291 - 014291
01/06/98
1
Joe E. Baker
Resident of West Memphis, Arkansas
Devon Hobby, Hazardous Waste Division, ADPC&E
Public Comment
Comment on proposed plan
A-33
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY /AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
014292 - 014295
01/07/98
4
Becky Allison, Customer Service Division
ADPC&E
Devon Hobby, Hazardous Waste Division, ADPC&E
Memorandum; Meeting Attendee List
Re: 01/06/98 West Memphians Involving Neighbors meeting
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
014296 - 014297
01/15/98
2
Craig Hepburn
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Report
Monthly Progress Report No. 25 - December 1997, Remedial
Design for Source Control Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
014298 - 014302
01/22/98
5
Devon Hobby, Hazardous Waste Division
ADPC&E
Joe E. Baker, Resident of West Memphis, AR
Corre spondence s
Attached letters urging EPA to minimize cost to City of West
Memphis
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
014303 - 014400
01/26/98
98
Sheryl G. Weatherford, Registered Professional Reporter
Daniel, Dillinger, Dominski, Richberger, Weatherford
U.S. EPA Region 6 Superfund Site Files
Transcript
Meeting Re: Proposed Plan of Action
A-34
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SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
ADMINISTRATIVE RECORD INDEX
ADDENDUM
SOUTH 8TH STREET LANDFILL SITE
ARD980496723
014401 - 014402
01/27/98
2
Lenice Watkins, Evening Times Staff Writer
Evening Times
U.S. EPA Region 6 Superfund Site Files
Media Clipping
Future uncertain at Eighth Street site
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
014403 - 014403
01/28/98
1
Lenice Watkins, Evening Times Staff Writer
Evening Times
U.S. EPA Region 6 Superfund Site Files
Media Clipping
Ferguson requests study of river fish
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
014404 - 014408
02/03/98
5
Bruce A. Monteith
Conestoga-Rovers & Associates
Vincent Malott, RPM, U.S. EPA Region 6
Public Comment
Comments on proposed plan of action
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
014409 - 014409
02/04/98
1
Joe B. Baker
Resident of West Memphis, AR
Vincent Malott, RPM, U.S. EPA Region 6
Public Comment
Comments on proposed plan
A-35
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ADMINISTRATIVE RECORD INDEX
ADDENDUM
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
SOUTH 8TH STREET LANDFILL SITE
ARD9S0496723
014410 - 014422
06/29/98
13
Vincent Malott, RPM
U.S. EPA Region 6
Site Project Piles
Memorandum; Report
Updated cost summary for Alternatives 2 and 3 as presented in
Feasibility Study for Ground Water Operable Unit
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
014423 - 014425
06/29/98
3
Unspecified
Unspecified
Site Project Files
Map
West Memphis & Marion City Map
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
014126 - 014463
07/28/98
38
TechLaw, incorporated
Contractor for U.S. EPA Region 6
Site Project Piles
Index
Administrative Record Addendum Index, Record of Decision for
Source Control Operable Unit/Ground Water Operable Unit
A-36
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