TECHNICAL STUDY AND REMEDIAL ACTION FOR
            DENNY FARM SITE 1, AURORA, MISSOURI

                      Final Report

                   September 15, 1980
                                  Document No.:  EFSR80-09-0105

                                              TDD:  F7-8006-01

                                   EPA Contract No:  68-01-6056
ecology and environment,  inc.
ROSSLYN CENTER, 1700 NORTH MOORE ST., ARLINGTON, VA. 22209, TEL. 703-522-6065
International Specialists in the Environmental Sciences

-------
ecology  and environment, inc.
ROSSLYN CENTER, 1700 NORTH MOORE ST., ARLINGTON, VA. 22209, TEL. 703-522-6065
International Specialists in the Environmental Sciences
                                 Monday,  15  September  1980
  Mr. William Keffer
  Environmental Protection  Agency
  Emergency  Planning  and  Response Branch
  25 Funston Street
  Kansas City,  Kansas  66115

  Dear  Mr. Keffer:

       In  response to Technical  Direction  Document  (TDD)  F7-8006-01
  and subsequent modification, Ecology  and Environment,  Inc.,  (E  & E)
  is pleased to submit fifty copies  of  its final  report  entitled
  Technical  Study and Remedial Action for  Denny Farm  Site 1, Aurora,
  Missouri  (Document  No.:   EFSR80-09-0105).   This report is based on
  the preliminary report  (EFSR80-07-0104)  completed in July, 1980; on
  further  geophysical and engineering studies; on meetings with
  EPA-Region VII and  the  EPA Dioxin  Task Force; and on participation
  in the consent negotiations.

       This  final report  is the  culmination of an intensive effort by
  E & E's  Special Projects  Team  coordinated by the National Project
  Management Office  in Arlington, Virginia.   Expertise has been drawn
  from  several of the regional offices  involved in the Field Investigations
  Team  (FIT) project.  E  &  E appreciates the cooperation of EPA Regional
  Deputy Project Officers in making  FIT personnel available for this
  important  project.

       An  evaluation  was  made of the technologies available for meeting
  the objective of removing the  TCDD from  the environment. Treatment
  of the waste by ultraviolet photolysis and by incineration are
  currently  the most  promising techniques  for final disposal of the
  wastes.  However,  these technologies  are not yet proven nor  are they
  immediately available.

       E & E recommends that the waste  and associated contaminated
  material at Denny  Farm  Site 1  be excavated and  stored  in a temporary
  storage  structure  to be erected on site  until a suitable final
  disposal option is  available.  A conceptual design  of  this solution
  along with cost estimates are  presented  in this report. Our estimate
  is that  this will  cost  approximately  $2,486,000 and take six months
  to execute.  E & E  recommends  that EPA proceed  immediately with the
  final design of the recommended action and select an execution  con-
  tractor  to proceed  with the project.
recycled paper

-------
Mr. William Keffer
15 September 1980
Page Two
     We welcome the opportunity to discuss this report with you.  We
will provide continued support to you through our Region VII FIT
project office and the FIT National Project Management Office to see
this project through to a successful conclusion.
                                   Sincer
yours.
                                                      Project Manager
RJKrjbs

cc:  Paul Nadeau
     Roger J. Gray
     James Buchanan
     Les Greenbaum

-------
                            TABLE OF CONTENTS
                                                                Page
SECTION 1:  INTRODUCTION	     1-1
SECTION 2:  HISTORY OF DENNY FARM SITE 1   	     2-1
SECTION 3:  PREVIOUS STUDIES OF DENNY FARM SITE 1	     3-1
     INTRODUCTION  	     3-1
     SAMPLING DATA   	     3-4
          Groundwater Monitoring   	     3-4
          Soil Sampling	     3-4
          Surface Water  	     3-6
          Drums (Waste Source)   	     3-7
SECTION 4:  TECHNICAL BACKGROUND INFORMATION   	     4-1
     INTRODUCTION  	     4-1
     GEOGRAPHY    	     4-1
     DEMOGRAPHY	     4-3
     CLIMATOLOGY	     4-3
     GEOLOGY   	     4-4
          Regional    	     4-5
          Local	     4-8
     HYDROLOGY    	     4-17
     GEOPHYSICAL  RECONNAISSANCE OF THE TRENCH  .......     4-22
     REFERENCES FOR  SECTION 4	     4-27
SECTION 5:  SITE  CHARACTERIZATION	     5-1
     INTRODUCTION  	     5-1
     METHODS  USED FOR DISPOSING OF THE WASTE   	     5-1
     DESCRIPTION  OF  THE  WASTE	     5-1
     PUBLIC HEALTH AND ENVIRONMENTAL  CONCERNS  	   5-2
          Toxicological  Considerations of
          2,3,7,8,-Tetrachlorodibenzo-p-dioxin (TCDD)   .  .  .     5-4
          Environmental  Fate of Farm  Site Pollutants    .  .  .     5-9
          Public  Health  Routes of Expousre    	     5-11
          Acceptable Cleanup Levels   	     5-13
     REFERENCES FOR  SECTION  5    	     5-15
                                    11

-------
                       TABLE OF CONTENTS (CONT'D)

SECTION 6:  REMEDIAL APPROACH METHODOLOGY  	   6-1
     INTRODUCTION  	   6-1
     STATING THE OBJECTIVE   	   6-1
     DETERMINING THE MEANS   	   6-3
     METHODS   	   6-4
          Disposal   	   6-4
          Storage    	   6-5
          Treatment	   6-5
     CRITERIA	   6-5
          Proven Technology     	   6-5
          Risk   	   6-6
          Time   	   6-6
          Cost   	   6-6
          Legal Ramifications	   6-6
SECTION 7:  EVALUATION OF REMEDIAL ACTIONS    	   7-1
     INTRODUCTION  	   7-1
          Definitions	   7-3
          Required Information    	   7-3
     REMEDIAL APPROACH    	   7-4
          Disposal   	  ......  	   7-6
          Treatment	   7-9
          Storage    	   7-15
     SUMMARY OF POTENTIAL REMEDIAL ACTIONS CONCEPTUAL DESIGN     7-16
     REFERENCES FOR SECTION  7	   7-17
SECTION 8:  PROPOSED REMEDIAL ACTION CONCEPTUAL  DESIGN  	 8-1
     COMPONENT 1.  TEMPORARY STORAGE FACILITY  	   8-3
          Foundation   	   8-3
          Structure    	   8-4
     COMPONENT 2.  SITE SETUP AND MOBILIZATION    	   8-5
     COMPONENT 3.  EXCAVATION   	   8-7
          Excavation   	   8-10
          Drum Decontamination    	   8-10
          Waste and Drum  Removal    	   8-11
                                    ILL

-------
                      TABLE OF CONTENTS  (CONT'D)

         Worker  Safety   	     8-12
         Worker  Training  	     8-12
         Excavation Time	     8-12
         Worker  Fatique   	     8-14
         Component  3B Excavation	     8-16
     COMPONENT 4.  SITE  CLOSURE	     8-18
         Summary of Component Costs   	     8-19
     PLANNING CONSIDERATIONS  FOR IMPLEMENTING PROPOSED
         PROPOSED REMEDIAL ACTIONS  	     8-21
          Site Control   	     8-21
          Storage Controls   	     8-21
     REFERENCES FOR SECTION 8	     8-24
     LIST OF CONTACTS    	     8-25
SECTION 9:   CONCLUSIONS  AND RECOMMENDATIONS  	     9-1
          CONCLUSIONS	     9-1
          RECOMMENDATIONS  	      9-2
APPENDIX A:  SAMPLING DATA   	     A-l
APPENDIX B:  RISK ANALYSIS   	      B-l
APPENDIX C:  BORING LOGS   	      C-l
APPENDIX D:  OCCUPATIONAL HEALTH AND SAFETY CONSIDERATIONS       D-l
APPENDIX E:  COST TABLES FOR PROPOSED REMEDIAL ACTION  ...      E-l
APPENDIX F:  CREDENTIALS   	      F-l
                                    IV

-------
                             LIST OF FIGURES
Figure 2-1:
Figure 2-2:
Figure 2-3:
Figure 2-4:
Figure 3-1:
Figure 3-2:
Figure 4-1:
Figure 4-2:
Figure 4-3:
Figure 4-4:
Figure 4-5:
Figure 4-6:
Figure 4-7:
Figure 4-8:
Figure 5-1:
Figure 6-1:
Figure 7-1:
Figure 8-1:
Figure 8-2:
Figure 8-3:
Figure 8-4:
Map of Missouri   	   2-2
Denny Farm Site 1 Area Location Map   	   2-3
Aerial View of Denny Farm Site 1 Locale   ....   2-4
Aerial View of Fenced Disposal Trench Area  .  .  .   2-4
Plan View of Denny Farm Site 1	   3-2
Environmental Sampling Locations  	   3-5
Plan View of Denny Farm Site 1 Area   	   4-2
Contour Plot of EM Data   	   4-10
Bore Hole Locations   	   4-11
Fracture Patterns   	   4-15
Selected Geologic Features  	   4-16
Gaining and Losing Stream Locations   	   4-19
Plan View of Drum Distribution	   4-24
Radar Traverse—South to North of Disposal Trench   4-25
Exposure Routes of TCDD to the Public   	   5-12
Flow of Remedial Approach Methodology   	   6-2
Evaluation of Alternatives for Remedial Action  .   7-5
Temporary Storage Facility  	   8-6
Plan View of Site Setup   	   8-8
Site Excavation   	   8-13
Plan View of Component 3B Excavation	   8-17

-------
                             LIST OF TABLES

Table 3-1:  Summary of Sampling Data   	    3-8
Table 5-1:  Compounds of Known or Suspected
            "Presence at Denny Farm Site"	5-5
Table 7-1:  Summary of Alternative Remedial
            "Action Methods"	    7-2
Table 7-2:  Commercial Storage/Disposal Facilities   	    7-7
Table 8-1:  Remedial Action Cost Summary   	    8-20
Table 8-2:  Remedial Action Cost Summary with
            Additional Excavation  	    8-22
                                    VI

-------
                                SECTION 1
                              INTRODUCTION
     This  report  contains   the   results  of  an  investigation  into  an
uncontrolled hazardous waste  disposal  site  located in  Aurora,  Missouri.
The site,  called Denny Farm  Site 1,  consists  of a  trench in which  an
estimated  150  drums  of waste material have  been buried.   These  wastes,
which  are   from  a  hexachlorophene-manufacturing  process,   have  been
analyzed and are known to contain the highly toxic chemical TCDD.
     The investigation of Denny  Farm Site  1  was carried out  by  Ecology
and Environment  Inc.  (E & E) and included  background  data acquisition,
environmental  and geophysical  surveys of  the  site   and   its  environs,
evaluation   of   alternative   remedial  actions,   and   preparation   of   a
conceptual plan  for  a  proposed remedial action.   This  investigation was
undertaken at  the request  of the U.S.  Environmental  Protection  Agency
(EPA) to meet  the  EPA's objective of removing the waste and contaminated
material from the  environment.  A preliminary report was prepared in June
1980; the current  report is the final report of E & E's investigations.
     Historical  information on  the  Denny  Farm Site  1 is presented  in
Section  2,  which includes  a  discussion  of  the  relationship  between
Hoffman-Taft,   North  Eastern   Pharmaceutical   and    Chemical   Company
(NEPACCO), and  Syntex  Agribusiness,  Inc.   NEPACCO, the generator  of the
waste  disposed  at  the Denny  Farm,  manufactured  hexachlorophene.   The
chemical process for a chemical  intermediate to  hexachlorophene  was the
source of  the  TCDD,  and  the wastes  from this process  were  then disposed
of in a trench on  the Denny Farm.
     Section 3  presents  a discussion of the  thorough  research and field
investigations   previously  conducted  on  the  site.    This  information
concerns the general geological  and hydrological conditions of  the area
surrounding  the  Denny  Farm,  as  well  as  analytical  data on the  drum
contents.  Analytical  data  determined the presence of  TCDD in composite
samples  as  well  as  soil  and  water  samples  obtained  from  within  the
partially  excavated  trench.   Additional environmental monitoring included
                                  1-1

-------
water samples taken at the private wells closest  to  the  site,  as  well as
surface water samples from Calton Creek.  Samples were taken from borings
around  the  perimeter  of  the  disposal  trench  to  determine  lateral
migration of the waste.
     Section 4  presents  the  results of further  technical  studies  on the
site  and  the  characteristics  of  TCDD.   Although  previous studies  had
indicated  no  lateral  migration,  the  potential  for off-site  migration
existed; additional areas were  investigated  in greater  detail  to  confirm
and  develop necessary  engineering data  for the remedial action.   The
geohydrological  investigation  provided  more  precise  measurements  of
the configuration and approximate dimensions of the barrels in the trench.
The  presence of drums beyond  those visually noted  by  the EPA was  also
confirmed.     More   importantly,   lateral   off-site   migration  was   not
detected.
     Specific  information concerning   the  type  and quantity of  waste
disposed of in the trench at Denny  Farm  and the method of disposal are
presented  in Section 5.   Public health and  environmental concerns  with
respect  to TCDD  and   its  environmental   fate  and  its  toxicological
properties  are discussed.
     Section 6  presents the  basis  for  the  remedial  approach.    This
approach may be  defined  within the context of  this  report as  taking all
the     necessary    steps    required—identification,      investigation,
determination   of   means  and  methods,  and   execution  of  determined
methods—for achieving a satisfactory  solution to  a  specific hazardous
waste  problem.   The means of  dealing with  hazardous waste,  whether the
generator  is  a  manufacturer or  an uncontrolled  waste site  undergoing
cleanup,  include one  or more of the  following:   storage,  treatment, and
disposal.   Various methods may  be  selected to carry  out  a  given means.
     Since   those methods  and  means  must be  tested to determine their
applicability   to   a   particular  site,  selection   criteria  have  been
developed.     Generic  criteria  applicable   to  any   site  are  proven
technology, risk,  time, cost,  and  legal  constraints.   Site-specific
criteria  include the  characteristics of the  waste and of the site.
     Section 7  presents the process  employed  to   select   those  methods
which  are  considered  for  remedial action application.   The  first phase
                                   1-2

-------
                                SECTION 2
                      HISTORY OF DENNY FARM SITE 1
     During  the  1960s,  Hoffraan-Taft  used   its   facility   in   Verona,
Missouri, (see Figure 2-1) for the  production  of  2-4-5-T,  a  component  of
Agent Orange.   In  the late 1960s, Hoffman-Taft sold  the Verona  facility
to Syntex Agribusiness,  Inc.   In 1969,  Syntex sold the equipment  in the
Verona facility and  leased the space  to the North Eastern  Pharmaceutical
and  Chemical  Company (NEPACCO).   From 1969  through  1971,  NEPACCO,  now
defunct, used the Verona plant for the manufacturing of hexachlorophene.
     During  its  tenancy, NEPACCO had a number of  process waste  streams
with  dioxin  contamination,  including  still  bottom  residues,  solvent-
contaminated  waste  water, expended  filter media,  and  a   recrop  liquor.
These were either contained or disposed of at a number of  locations.   One
of these locations was the Denny Farm in Aurora, Missouri.
     The Denny Farm  is  located seven  miles south  of Verona,  Missouri,  on
Highway VV.  The farm consists of 160 acres  and  is located in Section 20
on the  Area Location Map (see  Figure  2-2).   The site of  the  disposed
material from NEPACCO is northwest  of  the  Denny  farm house.  Access  to
the  site  is via the north edge of  a pasture and along  a  dirt  logging
road.   The  site  is on  top  of  a ridge (see  Figures 2-3  and  2-4) .   A
spring-fed pond exists approximately 100 yards west of the  site.
     In  1979, the  Air   and  Hazardous Materials  Division  (ARHM)   of  the
Environmental  Protection Agency's  (EPA) Regional Office in  Kansas City,
Missouri, Region VII, received an anonymous complaint about  the  disposal
site on  the Denny  Farm.   The complainant  made  a  number  of allegations
about the waste handling and disposal procedures of NEPACCO.
     Surveillance and Analysis Division (SVAN)  personnel  from EPA-Region
VII,  accompanied by representatives  from ARHM and from the  Springfield,
Missouri,  MDNR  office,  conducted   a  two-week   investigation  of  these
allegations.    The   investigation  included  personal  interviews,  site
reconnaissance, and  photography  of  the  disposal  site.  The investigation
team interviewed twenty-five individuals,  including people  who had worked
for  NEPACCO as well as officials  and  employees  of  Syntex  Agribusiness
                                  2-1

-------
ro
I
                                                                                         CAPE
                                                                                         GIRARDEAU
                                              Figure 2-1.  Map of Missouri

-------
DENNY FARM SITE 1 AREA LOCATION MAP
 />• DENNY FARM SITE
                                       HDD  40CC XOOD f(T>
                 Figure 2-2
                    2-3

-------
Fig. 2-3.  Aerial View of
Denny Farm Site 1 Locale
(viewed to the west-northwest)
      Fig.  2-4.   Aerial View of
      Fenced Disposal Trench
      (southwest at top of photo)
                                 2-4

-------
Inc.   Some  of those interviewed were eyewitnesses  who  reportedly hauled
wastes  to the  Denny Farm,  dug the  trench,  and dumped  drums of  waste
materials into the trench.
     On conducting  a reconnaissance of the disposal  site,  investigators
noted a depression in the  ground  about  10  by  53 feet. Investigators also
found  a mound of excavated soil next  to  the  depression.   The excavated
material consisted of clay and  small rock.
     Based  upon information  obtained from the interviews,  it  appeared
that  there  were  between  thirty  and one  hundred  fifty  55-gallon  metal
caustic drums with  lids buried on  the  Denny  farm  site.   The  drums were
buried  in June, 1971.   According  to  those  interviewed,  the  drums were
dumped out of the back of  a dump  truck  and left as  they  fell.   They were
then  covered  with from  one  to three  feet of  soil.   The  most  reliable
eyewitness stated that  the drums  were in  marginal  condition  at  the time
of burial and at  least  one drum had leaked or spilled when an individual
walking around on the  top of  the  drums  in the back of the  truck fell
through one of  the drums when the lid gave way.
     The  EPA  investigators  concluded  after  their  initial  survey that
        ...  It  is  reasonable  to expect that most, if not all, of
        the drums have rusted through and  that  the contents have,
        to a  large extent, been absorbed by the surrounding soil.
        Although  from the  standpoint of safety, and sampling and
        analytical procedures,  the  worst must be assumed—there is
        (sic) no data,  information  or rumors to indicate that the
        contents of  this site include high strenght (sic) dioxin
        contaminated wastes.  Based  upon all the interviews, the
        material  in  this site is reworked  liquor or recrop
        material  from which no  additional hexachlorophene could be
        extracted.   Whether or  not  this residue contained
        dioxin is unknown.
     The  EPA  Regional Office  in Region  VII prepared a study plan for the
the  investigation of the  Denny Farm disposal site.  EPA designated the
site  as Denny Farm  Site 1.   The  objective  of  the  investigation  effort
was
        to document  the  presence or  absence of  dioxin, its precursors,
        and/or  degradation products  and any other hazardous wastes  in
        the buried drums,  adjacent  soil, and immediate area surrounding
        the disposal pit.
      Implementation  of  the plan  began  on 22  April  1980 and  lasted for
several days.
                                  2-5

-------
                                SECTION 3

                      PREVIOUS STUDIES OF DENNY FARM SITE 1
INTRODUCTION
     As a result of  the  anonymous  complaint received in 1979 by  the  Air
and Hazardous Materials  Division (ARHM) of  the  Environmental  Protection
Agency's  (EPA)   Regional  Office  in  Kansas  City,  Missouri,  about  the
disposal site on the Denny Farm in Aurora, Missouri, several actions were
taken.  A preliminary investigation was set in motion.  The investigation
included personal interviews, site reconnaissance, and photography of the
disposal site.
     Following  this  preliminary  investigation,  a study plan was  devised
for  an  investigation of  the  disposal  site.    The  objective  of  the
investigation was
        to document  the presence or absence of dioxin, its precursors,
        and/or  degradation products and any other hazardous wastes in
        the buried drums, adjacent soil, and immediate area surrounding
        the disposal pit.
The  final  plan  was  submitted to  EPA authorities on  1  April  1980,  and
implementation  of the plan began on 22 April 1980.
     Before any excavation was done  on the disposal trench, several bore
hole  soil  samples  were collected  from the perimeter of the  trench (see
Figure  3-1  for  a sketch  of  Denny Farm  Site 1   and  location of proposed
bore holes).   The purpose of these  borings was  to  document  any  lateral
migration of contaminants from the trench.
     As  seen  in Figure  3-1,  two  levels of bore  holes were planned:   one
level within five to ten feet of the  trench; the other between forty-five
to  fifty-five  feet  from the  trench.   The first  level holes  were bored.
Additionally, one sample bore hole blank was collected at  the edge of the
pasture  leading into the  site.   This blank was  collected  for purposes of
background and  analytical quality control.
                                  3-1

-------



1
4-14 •*-"
_. D..n— -n— -n-— n-- -D--D-
\ 3
\ | U— 20 — »+* 1S •-
D 1
i 2 L
0 .*/ -^ •«



, L
>- •*• •<
..n — D — D — n — n-— a--o
D
i
D
^-15' »|< 20— »J j
1 Q
4 '5 6 i
H -^- •<>• — r- .
DISPOSAL AREA 10' x S31 —7 T :
D ' ^ » D



D
• 12 111 ,
D -f- T~ -<
i
D

J
D
j

b H *"
24 b-D-~a~-o-~jp—o^
f ^T9^ * A *
' a ^ D t^.
-L^
DECONTAMINATION
AREA
S



1 '


XX/XX/ 1 !
? D
>i0 ^? -^-8-i ^
i
G
!
:
CHAIN LINK 	 »CI
!
10' i FENCE :
'I 0
22 A-1--D--U-— D--U--L1
i"-^.! -$-21 -$
— — ^(p*S>>^ DOUBLE SWINGING GATES


18
y —




*

19










20
> 	


/
1



!

t


i
B
j


P 1

> i


S







\



!




i





M
18



i
\




i
,' ^k. PERIMETER OF
CLEARED AREA




A 00 BORE HOLE
~AND BORE HOLE
NUMBER
SCALE


1" = 25'

Figure 3-1.  Plan View of Denny Farm Site  1
                    3-2

-------
     The second   level   of   planned   borings—holes   thirteen   through
twenty-four—with the exception of hole  twenty-two  was not done  on the
advice of a Missouri Department of Natural Resources, Division of Geology
and Land Survey,  geologist.    There  was  concern  that  water  percolating
through the   trench  would   migrate   vertically   and  cause   further
contamination.
     After the borings were completed, the disposal trench was excavated.
Through a  careful excavation,  thirteen  drums  were  exposed  to the  EPA
investigation team.  Several of the drums were found to be empty.  Others
contained  liquid and  residues  in volumes  ranging  from near-empty  to
full.  Samples taken from drums and soil in the trench at Denny Farm Site
1 were sent to the EPA-Region VII  Laboratory for analysis for 2,3,7,8-
tetrachlorodibenzo-p-dioxin  (TCDD).   The  original  analysis of  the four
samples indicated that  three  contained between  65 and 100 mg/kg (ppm) of
dioxin.  The  fourth sample contained less  than 29 mg/kg TCDD.  From these
results EPA concluded:
        .  . . the information  from the GC/NS scans supports the
        conclusion that the material in the three samples ... is very
        similar  to the  still bottom residue presently being treated by
        Syntex Agribusiness.  The  GC/MS scans tentatively identified
        2,4,5-trichlorophenol  and  at least two—and probably
        three—ethers formed by combination of trichlorophenol with one,
        two,  or  three molecules of ethylene glycol.  Syntex has stated
        that  trichlorophenol and ethers of the above description are the
        major constituents of  the  waste in their tanks. . .
     Based on the field investigation, excavation, and results of the
sampling,  the EPA further concluded that  immediate  action  was necessary
to protect human health and  the environment.   This decision necessitated
the  development  of  a  short-term  response  program  to  minimize  and/or
prevent the   release  of  contaminants  from  the  site   until  a  method
ameliorating  the hazard could be determined.   An immediate and temporary
measure was   taken  by  the  EPA  with FWPCA  Section  311   funding.    The
disposal trench  was  capped  with an  impermeable membrane.   Surface water
was  diverted  from the site.
                                   3-3

-------
     Subsequent to the investigation of the disposal trench, a monitoring
program for  surface  water and  groundwater in  the  general area  of  Farm
Site  1  was  developed.    A discussion   of  the  sample  data  follows.

SAMPLING DATA
Groundwater Monitoring
     Both on-site  and  off-site  groundwater monitoring were  carried  out.
Initial off-site  sampling was conducted  during April 1980  and  included
three  wells  with the  closest  proximity  to  the   Denny  Farm  Site  1:
Garnatz-Williams  (#4), Katherine  Lamp (#5), and Dick Wallace  (#13)  (see
Figure 3-2).  Sample analysis was based upon chemical process information
and  interviews.    A  false   positive  due to  cross  contamination  was
determined  in well #13, while results for wells #4  and  #5 were  negative
for signs of  contamination.   Further  groundwater  studies were undertaken
on 3 June 1980, following EPA's on-site investigation and sampling at the
Denny Farm  Site 1.  Laboratory  results confirmed the presence  of TCDD.
Subsequently, additional  sampling was  carried out by EPA:   wells #1, #2,
#3, #6, #7, #8, #9, #10, #11, and #12.
     Sample results revealed  the presence of phenolic compounds in wells
#3  and  #4;  2,4,5-trichlorophenol (TCP)  in well #2.    Well #13,  which
originally  had a false  positive,  was  sampled again  on  5 June  1980.
Contamination was  not detected.
     Results of all  the groundwater sampling  may  be  found in Appendix A,
Table A-1.   All samples  taken  after  6 June 1980 were analyzed  for  TCP.
None was detected.

Soil Sampling
     As previously mentioned, an  on-site  investigation  of the Denny  Farm
Site  I  was  conducted in  April-May  1980.   A  portion  of  the  suspected
disposal  trench was  excavated.   Samples  of  the soil  intermingled  with
drums were  obtained  for analysis.  Additionally, borings  were  initially
installed about the perimeter of  the  trench (cf. Figure 3-1), and samples
were obtained  for  analysis.
                                  3-4

-------
                                              I SEDIMENT SAMPLE

                                                           COLUMN
VSJT    (ft VI D G  E
  DICK WALLACE-WELL 113
                                               L,JAMES SHELDON-WELL
KATHERINE LAMP-WELL 15
             WDENNY FARM SITE,

C.W. THOMAS-WELL 16
JAMES DENNY-WELLI1

          EDWARDS WELL
         SONNY LAMP-WELL 18 ',5
                   E.D. MARBUT-WELLI11
          — .• 30
                  ' rCHILDERSS-WELL 110

                                                                        _S ft/'/c-^  -V
                     ~~-^-^t
      ELDON OLSON WELL <9 I
                       RESIN COLUMN SAMPLE
                                                   MAYNARD WILLIAMS-WELL 114
                      Figure 3-2.   Environmental Sampling Locations
                                               3-5

-------
     Geophysical test methods  were  subsequently employed to  define  more
accurately  the  disposal   trench   as   well   as  surrounding  subsurface
configurations.  Initial findings revealed an anomaly  extending from the
western end of  the  trench.   Additional borings were installed  along the
perimeter of  the fence surrounding  the disposal  trench and  also within
the confines of  the suspect anomaly.
     Results, as seen in Appendix A, Table A-2, revealed the presence of
TCDD  in concentrations of  92,000  ppt in the trench.   The  subsequent
geophysical test noted above uncovered  that boring #1,  originally thought
to be along the  perimeter of the trench, was  in fact part of the disposal
trench.
     Boring logs and sample results confirmed the existence of an anomaly
west  of the trench.   Data showed  the presence of  a  richer clay layer
rather  than  contaminate   soil  caused by   leachate   from  the  disposal
trench.
     Soil  test  results  indicate no  lateral  migration  of  contaminants
beyond  the  sides of  the  original  trench.    The  tests,  however,  do  not
eliminate the possibility of vertical migration.                      :

Surface Water
     Surface  waters were  sampled  to determine  both  the presence  and
levels  of contaminants.   Because  of the  topographical  and  geological
makeup of  the area, contaminated surface run-off and/or groundwater posed
a real threat for the contamination of area surface waters.
     Two  spring-fed ponds, one to  the east and one  to the west  of  the
disposal  trench, were  sampled.   Sediment and  fish  samples were  taken at
twelve different locations.  The affinity of TCDD for soils and sediments
in  addition  to its bioaccumulation  potential  required the sampling.   A
final  sample  station   on  Calton  Creek  was  established  for  the  above
samples  as well as a resin column  sample,  i.e.,  a sample  where  a large
quantity  of water  is  allowed  to  pass  over  resin  that   will  attract,
concentrate, and retain certain chemical compounds  found in the water.
     Results indicated  that in all cases contaminants were not present to
the  level  of detection.  Results of this sampling are show in Appendix A,
Table A-3.
                                  3-6

-------
Drums (Waste Source)
       On  28  April  1980,  the  EPA-Region VII  field investigation  team
exposed  thirteen drums in  the excavated disposal  trench at  Denny  Farm
Site  1.   Eight  of  the drums were sampled.   These  samples  consisted  of
multi-layered liquid samples which varied in color and consistency.  Some
of  the  sample   material  was  analyzed  on  a  drum-by-drum  basis;  other
portions of the  samples were composited.
     Wright State University  (WSU) prepared  a  four-drum  composite sample
based  upon volume  of  waste  contained  in  the  respective  drums.    An
additional composite sample was  prepared  by  EPA-Region VII  and consisted
of  sample material  from  a  second  set of  four  drums.   This  composite
sample was forwarded to WSU for analysis.
     TCDD,  TCP,  ethylene  glycol,  tetrochlorobenzene,  and  alkylbenzene
compounds  were  tentatively   identified.    Concentrations of  TCDD  were
confirmed  in  both   composite  samples:    319   ppm  in  the  WSU-prepared
composite,  and  1.3  ppb in  the EPA-prepared composite.   Results  of  the
drum sampling can be seen in Appendix A, Table A-4.
     Table 3-1 presents a summary of the results presented in Appendix A.
                                  3-7

-------
                                TABLE 3-1
                        SUMMARY OF SAMPLING DATA
Type of
Sample
Dates of
Sampling
Total Number
of Samples
Number of
Positive
Samples
Contaminants
Detected
Groundwater           4/3 to
 Wells and Springs    7/21/80
               115
                      TCP,  Phenolics
Soil
 Bore Holes
 Trench
4/22 to
6/16/80
23
 1
         TCP,  TCDD
         TCDD
Surface Water
 Water
 Sediment
 Fish
6/8 to
6/18/80
 4
12
33
0
0
0
Drums
 Random
 Composite Samples
4/28/80
                 4
                 2
             4
             2
         TCP,  TCDD
         TCDD, Toluene,
         Tetrachloro-
         benzene,  others
                                  3-8

-------
                            SECTION 4
                   TECHNICAL BACKGROUND INFORMATION
INTRODUCTION
     In its investigation of Denny Farm Site  1,  Ecology  and Environment,
Inc. ,   (E  & E)  has  carried out  several technical  investigations.    The
purpose  of   this   section   is  to  discuss  the   technical   background
information gathered in the areas of geography,  demography, climatology,
geology,  hydrology,  and  geophysical  reconnaissance   of   the   trench.

GEOGRAPHY
     The Denny  Farm Site  1 hazardous waste  disposal site  is  located  on
the Denny  Farm in  Barry  County near  the  town  of  Aurora,  in  southwest
Missouri.   Aurora   lies  approximately   twenty-nine miles  southwest  of
Springfield and twenty-five miles southeast of Joplin.
     The Denny  Farm is on the  west  side of county road  VV, south  of
Pleasant Ridge  and south-southeast of Calton Creek (see Figure 4-1).   The
site of the disposal trench  is  west of the  Denny  farm house and  about
three  quarters  of  a mile  from county  road VV.   It is  in  the northwest
corner  of section twenty on the area location map (cf.  Figure 2-2).
     The disposal trench (Denny Farm Site 1) is located on a ridge top in
the dissected hills bordering the Ozarks  and the rolling  plains of the
Springfield Plateau.  The  ridge  itself  is  on a topographically high  area
bounded by Calton Creek on  the  north and west,  and by the  Little  Flat
Creek  on the  south.
     In this  area,  the topography  and soil  relationship  is  sometimes
referred  to as  the Baxter-Bodine soil association.  Baxter areas,  i.e.,
ridge  tops, are wooded.   They  have the  potential,  however,  for  being
cleared and used  as pastures.   The  Bodine soils exist  primarily on the
steep  hilly areas  of the  ridges.  These hilly  areas generally have  more
chert  and  are used  primarily as woodlands.
                                  4-1

-------
                                                    VERONA
                                                                                 AURORA
            I
            o
            5
US HWY 60
i
NJ
                                     COUNTY ROAD Z
                          DENNY FARM SITE 1
                          LITTLE FLAT   "V
                            CREEK
                                                              AREA OF
                                                        AREA LOCATION MAP-
                                Figure 4-1.  Plan View of Denny Farm Site 1 Area

-------
DEMOGRAPHY
     Barry County, the location of Denny Farm Site 1,  is typically rural.
According  to  1980  figures,  the  overall  population of  Barry County  is
24,100.   Projections for  1985 indicate  that  this figure  will  rise  by
approximately 1,400 to a total population in 1985 of 25,500.
     The town of  Aurora,  Missouri—the most densely populated area  that
is  closest to  Denny Farm  Site  1—has a population of  6,200.    Aurora
Township,  in  which the town  of  Aurora is  located,  has a  population  of
7,110, including the population in the town of Aurora.
     Verona, Missouri, just west of Aurora, has a population of 680.
     Both  Aurora  and  Verona  are  in Lawrence  County—about  four  miles
north  of  the  Barry-Lawrence County  line.   Denny  Farm  Site 1 is  one  to
three miles south of that county line (1).

CLIMATOLOGY
     Officials  of the  National  Oceanic  and Atmospheric  Adminstration,
U.S. Department of Commerce,  have compiled valuable climatological  data
related to the  Aurora,  Missouri, area (2).   The statistics  are  for  the
Springfield,   Missouri   Municipal   Airport—the   information-gathering
station closest to  Denny  Farm Site  1.   The  data cover a fifteen-year
period.
     Prevailing wind  direction in the area  is  always  out  of  the south-
southeast  year  round.  Wind speeds are relatively constant throughout the
year with  a mean hourly speed  of  11.6 miles  per hour.   The general area
around  Denny Farm Site  I  historically  has  a  high  incidence  rate  of
tornado touchdowns.   The average tornado damage  area  has  been estimated
to  be  about  two  square  miles.    (More  detailed  information regarding
tornadoes  can be  found in Appendix R of this report.)
     Normal temperature averages during the reported period ranged from a
monthly  low in January of  33.6°F to a monthly  high  in July  of  78.8°F.
The yearly average temperature for the period covered was 56.5°F.
     Precipitation figures  for the observed period show a normal rainfall
average of a low  in January  of  1.96  inches  and a high  in May  of  5.28
inches.   The yearly  average  rainfall for  the  period  covered was  41.08
inches.   Figures  of snow and  sleet precipitation show a  low—a  "trace"
                                  4-3

-------
too small to be measured—in October and a high of 3.4 inches in February
and March.  The yearly average snow and  sleet  for  the period covered was

13.0 inches.
     The yearly averages for relative humidity in the area are:


         o  Midnight:  78 with monthly ranges from 71 to 85

         o  6 a.m.:  82 with monthly ranges from 77 to 89

         o  Noon:  57 with monthly ranges from 50 to 62
         o  6 p.m.:  61 with monthly ranges from 54 to 68
                       SUMMARY OF GEOLOGY AND HYDROLOGY
              The geology  and hydrology  of Denny  Farm Site  1  and  its
         environs were  studied by  acquisition of  existing data  and  by
         geophysical exploration.     E  &  E   initiated  remote-sensing
         geophysical exploration     to     determine:         (1)    local
         geology/hydrology, (2) boundaries of  the barrels and trench, (3)
         bottom of the trench, and  (4) subsurface anomalies in and around
         the trench.  After careful review of the geological/geophysical
         data obtained,   test   borings   were  made   to   confirm   the
         interpretations   and  obtain additional   soil  samples.    The
         geophysical methods   used   were  electromagnetic   conductivity,
         seismic refraction,  electrical  resistivity,  ground  penetrating
         radar, magnetometry,  and metal  detection.

              Following are the conclusions drawn from  the study:

                 o  Movement  of  fluids  out  of  the  trench would occur
                    predominantly  in a  vertical  direction with  impetus
                    given   by  precipitation  percolation   (negated  by
                    impervious  cap  placed  recently)  or  by   a  sudden
                    release of large  volumes of material due to  corroding
                    drums.

                 o   A great variance of the  coefficient of permeability
                    of  the soil  should  be expected  with  water movement
                    through the  soil tending  to be  slow in the clay and
                    more  rapid in  the  cherty zones.   However, movement
                    into  the  bedrock would  be  very  rapid through  any
                    "pipes"  (open  soil  fractures)  that may exist under
                    the trench.

                 o   Upon entering  the weathered  Reeds Spring  Formation,
                    flow  or  seepage  would  continue  vertically  until the
                    water  table  is reached.   Flow would then  be  lateral

                                  4-4

-------
GEOLOGY
                      but   predominately  along  the  joint  and  fracture
                      patterns.   Because  of uncertainty as to  the precise
                      orientation of the various  joints,   fractures,  and
                      solution cavities,  calculations  of directions of
                      flow could be accomplished only on  a probabilistic
                      basis.

                   o  Some contaminant attenuation would  occur with  flow
                      through the  soil.    However,  should contaminants
                      move into  pipes  or  sinkholes,  little  attenuation
                      potential  would exist.

                   o  Although sinkholes are  common  in the vicinity of
                      Denny Farm Site  1, the  probability of one  forming
                      at any specific  point such  as under the trench is
                      exceedingly low.

                   o  Conditions  are  potentially  favorable   for  rapid
                      downward contaminant migration  to the groundwater.
                      Although the impervious  cap  has  greatly  reduced the
                      likelihood  of precipitation  percolation  dragging
                      the  contamination   deeper    and   closer   to   the
                      groundwater  supply,  corroded drums could  release
                      volumes of  fluid  into  the  surrounding  soil  and
                      movement     would     begin      independently    of
                      precipitation.   Therefore  the   local  geology of
                      this site  has conditions which could be  conducive
                      to the  seepage of liquid contaminants  out of  the
                      trench.

                   o  On-site geophysical  reconnaissance  showed  that  the
                      trench is  approximately 960  square feet  in area and
                      6 to 8 feet  in  depth.   It  is  estimated  that  the
                      trench  could   contain   140   to   150   drums.
Regional
     Denny Farm Site 1 is situated on the Springfield Plateau on the edge

of the Ozark Mountains'  foothills,  with  the Ozark  dome about  190  miles

east-northeast of the site.
     The region represents  a section  of the  Ozark peneplain  which  had

developed in mid-Tertiary times (approximately 30-40 million years  ago).
With subsequent uplifrt episodes from mid-Tertiary  to  present  time,  the
rejuvenated streams eroded  downward  to  maintain   gradient  and  created
incised valleys and thereby    the    existing   dissected    and   rugged

conditions.
                                  4-5

-------
     The  area  is  underlain  by  the  Osagean  and  Kinderhookian  Series
of Mississippian Age  bedrock.    The specific  unit  in  the vicinity  of
Denny Farm  Site 1  is the  Reeds  Spring Formation,  a  gray  to  blue-gray
limestone  with   alternating  bands  of   chert.     Thickness   of   this
formation within the  area  has  been  reported as 125  feet  to  about  225
feet in  the  southernmost portions of the  state.   In most  of  the  region
the  Reeds  Spring Formation lies  conformably  on the  Pierson  Formation.
However, the  rock  that immediately underlies  the Reeds  Spring  Formation
in the area of Denny Farm Site 1 is the Compton Formation, a thin-bedded,
crystalline,  crinoidal  limestone  with  some  chert  nodules (3).    The
Compton Formation ranges from 20 to 50 feet in thickness.
     The  ridge  tops  are  capped  with  a   thin  3-foot   veneer   of  loess,
an  aeolian-deposited  buff  silt.    The  loess  is   underlain   by  a  red
kaolinitic  silty clay and  silt  with  numerous angular  chert   fragments.
This soil  is  residual in  nature,  the  silty  clays  having  been derived
from  the   weathering  and  disintegration   of   the   underlying  parent
limestone  bedrock  and  the more  resistant  chert   left behind in  the
clay matrix.   In some  instances,  the  relict  fabric of  the chert bands is
visible in road cuts  in  the soil as dissected bands of angular chert.
     Colluvial  erosional   processes  have  prevented  ridge  sides  from
developing  soil  cover; thus bedrock  is present  at  the  surface in  these
areas.  Valley soils  developed  by colluvial  infilling  are thick, complex
mixtures of stratified and  non-stratified materials.
     Some  folding  and  faulting  of  the  strata occurred,  most  of  it
concurrent   with  the   Tertiary   uplift   episodes.      McCraken  (1971)
reports  several structural features  in the  area, including  the eastern
end of an east-west-trending normal strike-slip  fault with total vertical
displacements  of 150  feet  (4).   The end  of  this fault  (Ritchey  fault)
occurs  about  five  miles  north   of  the  site,  with   the  down-dropped
block  on  the  south.   The  north-northwest  axis   of  the  Osage-Verona
anticline  (an  upward folding of  rock)  also exists  about three  miles
east of Denny  Farm Site  1.
     The  uplift,  and  consequent   folding and   faulting,  created  many
fractures  in  the  relatively  soluble Reeds  Spring limestones.   Thus,
                                  4-6

-------
solution  activity  from  groundwater  has   created   a   classical  karst
topography  characterized by  sinkholes,  linear  and  right-angle  valley
formation,  pinnacle  weathering,   disappearing   streams,   springs,   and
caves.
     In many  instances,  infilling  of  fractures  or solution  cavities  in
the bedrock  occurs with  the  downward percolation of water  through  the
soil at the  bedrock interface.    Water seepage assisted by  mass  wasting
and gravity  gradually enlarges  or "stopes" upward  the resulting  void.
This stoping phenomenon continues  until  the void is within  7  to  10  feet
of the surface.   At this point,  the remaining  soil  overburden collapses
suddenly, forming a 40- to 70-foot-deep hole with nearly vertical  walls.
     Although sinkholes  have  developed independent of  man's activities,
it has been illustrated by Aley et  al.  (1972) that changes in drainage by
either the impoundment  of water or by  the  reduction or lowering  of  the
water  table  have  induced  sinkhole collapse  (5).   Examples  of  these
include the  West Plains, Missouri,  collapse of  1964  and  1966 in  which
effluent entered  the bedrock-groundwater system when a sinkhole developed
under  a  49-acre  two-cell   lagoon.   A  similar  incident  occurred  at
Republic, Missouri, in 1968.
     In addition to the rejuvenation of streams  and  erosion of numerous
valleys, gullies have  been  formed  by  the sequential  linear  formation of
sinkholes in  an uphill direction.   This phenomenon  is apparent  on  the
Verona, McDowell,  and Aurora topographic quadrangle  maps  as well  as  in
aerial observations and  photographs.   Many  of  these  linear  progressions
of  sinkhole  development,  as   well   as  cave  development,  have  been
associated with  solution and water  movements along joint fracture systems
within  the  bedrock.   This  is  illustrated  by  the  linear  nature  of  the
area's  valley-gully  orientation  and  periodicity,  as   well  as  by  the
right-angle turns observed in Calton Creek west of Denny Farm Site 1.
     The solutional processes also lead  to  pinnacle  weathering, which is
the enlargement  of  vertical fractures  at the bedrock surface to the point
where  the  fractures actually occupy more  space  than do the intervening
bedrock remnants.   These  enlarged fractures, commonly up to  20 feet wide
at the  top and  up to  30 feet deep, are usually  completely buried by the
residual soils  and  thus not visible on the  land surface.
                                   4-7

-------
Local
     The Denny Farm Site 1 is located atop a northwest-southwest ridge at
SE 1/4, NW 1/4, NW 1/4, Sec. 20, T25N, R26W, approximately one-third of a
mile south of Calton Creek (cf. Figure 4-1 which outlines the area of the
Figure 2-2 area location map).  The site is underlain by red, cherty clay
soils of  the  residual  nature previously discussed, which  grade into the
parent  material,  i.e.,   the   cherty  limestone   of   the  Reeds  Spring
Formation.    Typically,  this  rock  is  highly  fractured  and  exhibits
classical  sinkhole development  and pinnacle  weathering.    There  is  no
direct evidence of catastrophic  sinkhole  development  existing within 200
yards of the disposal trench on the Denny Farm.  However, numerous recent
collapsed sinkholes and piping were observed within a mile of the site.
     Little direct hydrological  investigation  by coring,  soil boring,  or
backhoe excavation had been done  in the vicinity  of the site  prior  to
June 1980.  In April 1980,  fourteen soil  borings were made by EPA-Region
VII around and adjacent to the trench.  An attempt  was made to sample the
soil  in  the interval 8  to 10  feet  below the  existing  grade.    In some
cases, auger  refusal occurred  before those  depths  were reached.  Because
of  the  possibility  of  penetrating  localized pockets  of  contaminated
seepage, no attempt was made to drill deeper  to define  the soil-bedrock
interface.      In any  case,  the  purpose  of the  boring program was  to
collect and analyze only  near-surface samples  adjacent to the trench for
the presence or absence of dioxin.
     However, it was still necessary  to ascertain if downward movement of
contaminants  was  possible.   In  view of the complex  geologic conditions
discussed above,  it was  not  deemed safe  to  begin  immediately drilling to
bedrock  in  the vicinity  of  the trench until  some of  the uncertainties
were removed by using geophysical methods that would not disturb the site
and trench soils.
     Therefore, E  & E initiated remote-sensing geophysical exploration to
determine:   (I)  local  geology/hydrology,  (2)  boundaries of  the barrels
and trench, (3) bottom of  the trench, and (4) subsurface anomalies in and
around  the  trench.  After careful review of  the  geological/geophysical
data obtained, test borings were then made to confirm the interpretations
and obtain additional soil samples.
                                  4-8

-------
    The geophysical methods used were the following:

              o  Electromagnetic Conductivity (EM)
              o  Seismic Refraction
              o  Electrical Resistivity (ER)
              o  Ground Penetrating Radar (GPR)
              o  Magnetometry
              o  Metal Detection

     The  EM  data  were  collected  along  continuous  northeast-southwest
traverses outside the site proper.   Each traverse was 800  feet  long  and
25 feet  apart.   Figure 4-2 is  a  contour  interpretation  of the  EM  data.
The  contours  are   representative   of  the  electromagnetic  conductivity
(reciprocal  resistivity)  of  the  upper  20   feet  of  the  soil-bedrock
complex.   The values  are a  function  of the  type of  soil and  bedrock
present, the  degree of  porosity in the soil and  bedrock,  and  the nature
of any fluids which may be present  in the pore spaces.
     By reference to Figure 4-2, several important statements can be made
concerning the geology  and soils  outside  Denny Farm Site  1.   First,  the
area  surrounding  the   site  has  a  relatively high  conductivity  (8-12
millimhos/meter),   which  diminishes   to  very   low   levels    in   the
northeasterly  and  southwesterly  directions (2-4  millimhos/meter).    In
both of  these low-conductive areas, field  investigation showed  that  the
soil cover ranges  from  very  thin  to non-existent.   The  limestone bedrock
is much less  conductive than the overlying soil.
     As shown on Figure 4-2, higher conductivity values were found in the
areas of Lines AB and CD.  Initially it was thought that  these anomalies,
particularly  AB, might be caused  by lateral migration  of contaminants.
However,  drilling  and  sampling of these areas  (see  Figure 4-3)  showed
that  the  anomalies  were  zones   of  localized   increases  in  clay  and
reduction  in  the  amount  of  chert  fragments  (7).    Apparently  the
anomalously high conductivities were caused by the higher  conductance of
the  clays,  which maintain  a higher moisture  content.    The clay  zones
containing less chert may be the result of differential weathering of the
original bedrock or remnants of clay-filled joints and  fractures of  the
original cherty  limestone.
                                  4-9

-------
                                DISTANCE IN FEET
                           LEFT & RIGHT OF CENTER LINE
                  -150    -100    -50     0      50    100 FT.
CONTOUR INTERVAL =
2 MILLIMHOS/
METER
     A

       100'
   I   SCALE    |
      FENCED
    PERIMETER
  ELECTROMAGNETIC
     TRAVERSES
                                                                          m
                                                                          oz
                                                                          m _
                                                                            ZTl
                                                                           . m
                                                                          Z
                                                                          m
                                                            -300
                      Figure  4-2.  Contour Plot  of  EM Data
                                     4-10

-------
                   -150
       DISTANCE IN FEET
  LEFT & RIGHT OF CENTER LINE
-100    -50      0      50     100 FT.
                                                               300
CONTOUR INTERVAL =
2 MILLIMHOS/
METER
       \
        100'
   |   SCALE    |
      FENCED
    PERIMETER
"NO. 15A IS LOCATED
BETWEEN NO. 15 AND
13."
   ELECTROMAGNETIC
      TRAVERSES

                                                               CENTER LINE   n
                                                                             m
                                                                             3D
                                                                             m
                                    -100
                                       "NO. 30 IS LOCATED ON
                                       ACCESS ROAD AT
                                       TRAILER TURN," EAST
                                       OF COMPOUND.
                                    -150
                                                                         BORE HOLE
                                                               -300
                         Figure 4-3.   Bore Hole  Locations
                                       4-11

-------
     Laboratory  analysis  of the soil  samples  was conducted by  the  U.S.
Environmental  Protection  Agency  Surveillance  and  Analysis Division  in
Kansas  City,  Kansas.   Results  of  the soil  samples  tested  have  been
negative for those samples  taken the week of July 14 through 19, 1980,  in
the area surrounding the fence (cf. Figure 4-3).
     The  results of  the  geophysical  tests  andsubsequent  ground-truth
borings  indicate a  three-layer system of 
-------
notable  that  these  deeper  and  very  old  soil  clays  were  extremely
disordered  (poorly  crystalline)  as  established  by  their  poor  X-ray
reflections.  .   .  ."(6).    This  horizon  is  also  characterized  by  low
seismic velocities,  albeit  somewhat higher  than  those  of the upper loess
horizon.  Seismic velocities  ranged from  2,400 to  3,500  feet per second.
Seismic and resistivity methods indicated that the residual clays,  which
are about 11 to  16 feet thick along the west fence line,  thicken to 29 to
37 feet along the east fence  line.  This  was fairly well corroborated by
the ground-truth borings.
     Ground  penetrating  radar detected an  additional  thin  soil  horizon
about 3 feet below grade.   This layer was interpreted  to be the fragipan
layer described  in discussion with  Dr.    J.   Hadley Williams  (3)  and in
various  publications  on  Missouri  soils   and  geology.    This zone  was
considered  important because  its  normally low permeability  could  play a
role in controlling  shallow drainage.   Radar data  showed that the zone is
generally broken and dissected but occurs  as  a  continuous  layer  in the
vicinity of the  west  and north corner of  the site  fence.   Augering, auger
sections, and split-spoon sampling were used in the borings  to define the
fragipan layer (see  Appendix  C for details of soil borings).  However, no
definite layers  were found.   It  is  likely that the  fragipan occurs as a
poorly developed and dissected subtle layer  so  that it is not observable
by  normal  drilling  procedures.    As  such,  it   does  not   seem   to  be
significant  in controlling  drainage.
     The  lowermost  horizon encountered  represents the top  of the highly
weathered and fractured Reeds Spring Formation.  The presence of residual
float  rock  somewhat  isolated a  short  distance above  the  parent bedrock
indicates that the distance to relatively unweathered  bedrock could be an
additional  10 to  30 feet  below  the  top  of the  weathered zone.   This
horizon consists of  chert  and cherty  limestone,  which the augers refused
to penetrate  during  drilling.  The  drilling characteristics about 2 to 3
feet above  the  refusal depth indicated that a high amount of weathering
has probably  occurred.  This  interpretation  is supported by  the fact that
the  highest  seismic velocity   measured  was  6,000  feet  per  second.
Velocities  in massive rock or  limestone  usually  exceed  10,000 feet per
second.
                                  4-13

-------
     Using Borings #21, #25, and #28  (see  Figure  4-3)  as references,  the
bedrock surface of  the lowermost  horizon encountered  slopes  to  the  east
at an angle of approximately 8° from the horizontal.
     A single  deep  boring was  drilled about 300  feet  south-southeast  of
the  site  along the  access  road (7).    At  that  location  (Boring  #30),
massive gray white chert was encountered in  a  layer from 35 feet to 47.4
feet below  grade.   A  combination  of  diamond coring and  tri-cone roller
rock bits were used.   This zone  probably  represents  a surface of  the
Reeds  Spring  Formation which has  been only moderately  weathered.   Core
recovery  was  very low and averaged about  50%  in  the upper 4  feet,  with
most of the deeper penetration requiring the use of rock bits.  The lower
depths  of bedrock  (below 44  feet)   represent  a relatively  unweathered
competent surface,  as shown by the  increase in core  recovery  (100%)  at
that depth and the slow rate of core water loss.
     During   field   inspections  of   the  geology,  joint  patterns  were
observed  along Calton Creek  in the  lower  portion  of the  Reeds Spring
Formation.   The  primary  joint pattern  trended northeast  to southwest,
with  a secondary  pattern trending  northwest  to  southeast  (see Figure
4-4).   As shown  in  the  figure, Calton Creek  negotiates two right-angle
turns  north of the  site,  indicating  structure-controlled flow,   probably
along  joints or  fractures.   The  rectilinear  trend  of  the  gullies  and
valley as  seen  in  aerial photographs  also  indicates  joint-controlled
features  in  northwest-southeast and  northeast-southwest  trends.
     Evidence of past sinkhole development  was apparent  from  the large
circular  depressions observed  on  the ground in the valley about  700 feet
northeast of the site and along the west  side  of Calton Creek about one
quarter mile north  of the point where Calton Creek  flows  into Little Flat
Creek.   In  addition,  the cirque-like headwalls  of some  of  the gullies
 indicate  that they originated  from the coalescing of  paleosinks  (3) (see
Figure 4-5).
          Small  sinkholes/pipes  2  to  5   feet  in diameter  have  also
developed as the result  of water-percolation piping.   These  features have
been observed along  the  gullies  surrounding the site  and about 30 feet
 southwest of the southwest fence  corner (4" diameter).   During  the field
                                   4-14

-------
J^
I
                  LEGEND:
                  OBSERVED FRACTURES
                  INFERRED FRACTURES    Illllllllllllll
      SCALE
     1000 FEET
      I	1

ADAPTED FROM TECHNOS
                                       Figure 4-4.   Fracture Patterns

-------
r
                                                                            30 FOOT WELL IN
                                                                          POSSIBLE PALEOSINK
                         LEGEND

                          •      SINKHOLE/PIPING
                      •*	SURFACE DRAINAGE PATTERN

                      •»	  LINEAMENT (INFERRED FRACTURE)
                      	  ELEVATION CONTOUR (100 FT)
SCALE

 I	1
500 FEET
                                                                    ADAPTED FROM TECHNOS
                                   Figure 4-5.  Selected Geologic Features

-------
geophysical survey, traverses were made with the ground penetrating radar
around the  perimeter  of the  fence  and along  the  access road.   Results
indicated that piping and  downward  percolation of  precipitation probably
occur at the site.
     No caves were found or are known to  exist in  the immediate vicinity
of Denny Farm Site 1.  The closest  known  cave  is Stansberry Cave located
at SE 1/4, SW 1/4, R26W, T25N, about 3 miles east-southeast of the site.

HYDROLOGY
     Denny Farm  Site  1  is located  in  the White River drainage  basin in
southwestern Missouri.  Precipitation in  this  area averages approximately
45 inches per year.  Half  of this amount  is evapo- transpired back to the
atmosphere, while  most  of  the remainder  infiltrates  the water  table.   A
small amount runs  off as surface drainage.
     Groundwater  movement  in  the  area generally  parallels  the surface
drainage.   In many geological  terrains this generalization can be useful
even at a site-specific level.  However,  in fractured limestone terrains,
the density and  orientation of  fractures, as well  as the degree of their
solution  enlargement,  can vary greatly over  very small distances.   For
example,  yields  from wells in  limestones may  vary  by several  orders of
magnitude in holes drilled only  a few feet apart.   Therefore, prediction
of directions and  rates of local groundwater movement is difficult.
     The  Denny  Farm Site  1 trench  is located  very  near the topographic
high  point  of   the  ridge  approximately   150   feet  above   Calton  Creek.
Immediate surface  drainage (cf.  Figure 4-5) is  to the east into a swale
opening  into a  tributary  valley,  which then opens to Calton Creek.   The
drainage  of Calton Creek flows south  into Little Flat Creek about two and
a half miles from  the site.  Flat Creek flows  east-southeast  to the James
River and then south to the Table Rock Lake reservoir on the White River.
The drainages cover a distance of roughly forty  miles.
          It should be noted that  little actual  surface flow occurs in any
of  the  swales,  gullies, and  tributaries.  There are seldom any defined
channels, wet  or  dry,  in  any  of them.   The  soils  and  bedrock in these
swales  are  so permeable  that  precipitation cannot  run  off the surface;
instead  water  percolates  downward  to the  water table and  then  moves
                                  4-17

-------
laterally  as groundwater  to  a  more  regional discharge  point such  as
Calton Creek.  Even on the tops of ridges, which are covered with a thick
mantle of clayey  soil,  infiltration  readily  occurs.   This phenomenon was
observed firsthand  by field  personnel  conducting the  geophysical  field
work.  During June  1980,  several  thundershowers deposited an estimated 3
inches of  precipitation on  the  site.   During  these  storms,  the  water
puddled over most of the  relatively flat ridgetop  surface.   Within  an
hour after the rain had stopped,  the water in the puddles had soaked into
the  soil.    The  high percolation  rate  was  also  apparent  during  aerial
reconnaissance of the area  with  Dr. Williams,  who pointed  out  several
unsuccessful attempts to create farm ponds.
     Once precipitation enters the soil in the vicinity of the trench,  it
moves  predominantly vertically.    The fragipan  layer  would  have  little
effect on vertical movement because of its dissection, variable presence,
and shallow  occurrence with respect to the anticipated trench base.   Some
lateral  movement would  occur along  the  thicker  relict  chert  horizons
bounded by the clay-rich lenses encountered (7).  However, because of the
discontinuity  of both  the relict  structures  and  the  clay  lenses,  the
basic movement is vertically  downward.   This  is further borne out  by the
absence  of  springs  on  the hillsides  in the  immediate  area and by  the
absence of stream flow in  the  swales running off the hillsides.
     It is also  apparent  from the flow of Calton Creek  as well as  other
tributaries  that  the  amount of surface flow is controlled by the jointing
and fracturing of the Reeds Spring Formation.  Certain segments of Calton
Creek have no  flow  and  are colloquially referred to  as  "losing."   Other
segments of  the creek that do have flow are referred to as "gaining" (see
Figure 4-6).  Recent  dye tests  (8)  on  the  creek  show  good hydrologic
connections  between  successive  losing  and  gaining  segments.   In  one
instance, dye released on  a gaining  segment  was soon  picked up in  a well
adjacent to  the next downstream gaining segment.  Apparently, the dye had
moved rapidly through the  bedrock  in  the intervening  losing segment.   It
should  be   noted  that   this   rapid   subsurface  movement  occurs  within
one-third mile of the Denny Farm Site 1.
     Rapid  infiltration of  surface  waters  can occur  through zones  of
piping within the  soil  horizon  or  through  sinkholes.   Because of  the
                                  4-18

-------
          S^A'l'.v
                                                        '0  NVsV
              -
        LOSING STREAM^
            ^
'^•mUT.
                                         0   1000  MOD  1000   «00  WOO  MOO
         Figure 4-6.  Gaining and Losing Stream Locations
                            4-19

-------
vertical voids in  these  structures,  water can be  directed  very quickly to
the fractured  weathered   Reeds  Spring  bedrock  and  to  the  water  table.
Williams and  Vineyard have  compiled  a  list  of  geologic  indicators  in
which subsidence or  collapse may occur  in karst  terrain (9).    This  list
is reproduced below:

        o  Collapses  are  more  likely to occur in  residual  soil ranging in
           thickness  from 40 to 100  feet (12-30 m)

        o  Collapses  are  more  apt to occur in  residual soil  retaining the
           fabric  of the  parent   material;  collapses  are  uncommon  in
           colluvial   deposits   or  in   alluvium  deposited   by  gaining
           streams

        o  Collapses  are  more  likely to occur where  the clay fraction has
           low plasticity (MH; A-7-5), common to kaolinitic and halloysitic
           clays

        o  Collapses  are not common where a  poorly drained  surface  soil
           exists  even if this  surface  soil is underlain by other features
           typical of collapse indicators
         o   Collapses  are more  apt  to occur  in  losing streams and watersheds
            than  in gaining,  but are as common  to  the  uplands  or slopes as
            floodplains  of  losing areas

         o   Sinkholes  per  se  are  not normally  indicative of  land surface
            failure by catastrophic  collapse

         o   Collapses  are  more frequent  in areas  underlain  by limestone,
            dolomite,  and gypsum,  but have  been reported in other types of
            bedrock

         o   Cave  systems developed  along the soil-bedrock contact are common
            in areas having a history of land surface failure by collapse
                                  4-20

-------
      o   Cave  passageways  are  periodically  or  continuously  drained  by
         streams

     These conditions are  essentially  satisfied  by the  geologic conditions
observed  at  Denny Farm  Site  1.    However,  the  absolute  likelihood of  a
sinkhole developing at any particular location is still very low.
     Within the  compound  clearings, no water  was observed in  the  borings
which would be indicative of a perched water table.  The deepest boring was
drilled 47.4 feet below grade (or about 60 feet below the existing grade of
the  compound  area),  and  the  water  table was   not  encountered.    It  is
estimated that  the water  table  is about  114  feet below  the site.   This
assumes a local  water-table gradient of 3%, which is typical  in karst  or
solution-developed terrain (8).
     In summary,  the  borings indicate that the  lateral  movement  of fluids
from  the  trench  is  unlikely.   The  fragipan  layer  has little effect  on
vertical movement because of its dissection, variable presence,  and shallow
occurrence with respect to the anticipated base of the trench.
     The  EM  anomalies investigated  were  attributed  to  a higher clay  and
moisture  content.   It  can be  inferred,  then,  that  any seepage from  the
trench would flow  around  zones  of high clay and  low  permeability  and  seep
into more pervious zones  (pockets  or dessication cracks) (8).  Due to  the
lack of continuity of the high-plastic clay  layer,  flow or  seepage would
occur  laterally  for  a short  distance  before  encountering  a  more  pervious
horizon  of cherty,  clayey  silt,  or  chert  fragments.    At   that  point,
vertical movement would continue.  The above scenario of seepage out of the
trench, to this point, assumes that similar soil  conditions exist under the
trench as were encountered in the borings.
     The  coefficient  of permeability  of  the  soil would vary depending on
the  viscosity  and temperature  of the materials  leaving  the  base  of  the
trench,  the grain size  distribution, dry  density,   and   stress  history.
However,  it   would   probably  range  from  10~-*cm/sec   (fine   sands   and
inorganic  silts,  stratified  clay  deposits)  to  lO'^cm/sec  (homogeneous
clays  below   zone of   seasonal   volumetric   change).     By  using  these
permeabilities  and assuming a  constant  head  and no  piping,   it   can  be

                                  4-21

-------
estimated that  after nine  years,  the  leachate  boundary  could  be  as
shallow as 1 foot   (10~7  cm/sec)   or   could   have   reached   bedrock
(10~3 cm/sec).  Again, this does not take into account piping.
     Although the sandstone was observed  as  a  float  rock  outcrop along a
few of the gullies surrounding  the  ridge, it was not observed  in  any of
the borings drilled during this program.  Therefore,  it  is  unlikely  that
seepage from the  trench  would occur  toward  the  west  ponds through  the
sandstone extrapolated to underlie  the trench (6).  The  geophysical  and
geological studies which have been  performed in  the  past  two months  have
been centered  on both  general and site-specific conditions.    Contam-
ination has not  been  detected in the  wells  which surround the  site  and
have been continually monitored by  EPA/SVAN  Region VII  (cf. Figure 3-2).
This simply means  that  contaminants  have not arrived  at  those  points.
The possibility   still   exists   that   the   water   table   can   become
contaminated.
         Therefore, it is a distinct possibility that liquid contaminants
or leachate could emanate  from  the  trench and reach the  groundwater  and
surface waters because of the following conditions:
         o  Variable  but predominately  high permeability  of  overburden
            "soils"

         o  Evidence of piping in the  immediate vicinity

         o  Highly fractured, permeable,  and soluble bedrock

         o  Remote possibility of catastrophic sinkhole collapse

         o  Evidence of  fracture-controlled  drainage

GEOPHYSICAL RECONNAISSANCE OF THE TRENCH
     Besides the  geophysical  reconnaissance  and  soil exploration outside
the Denny Farm  Site  1   perimeter,  E  &  E  used  similar  remote  sensing
techniques within the fenced  area to  define  the  trench,its  contents,  and
the subsurface  geology  in more detail.   In addition to  delineating  the
                                  4-22

-------
environmental  conditions  of  the   site,  data  were  necessary  for  the
conceptual design effort for remedial action.  Obvious concerns about the
site were

             o  Establishing the trench boundary and depth

             o  Defining  the spatial  distribution and  number of  drums
                buried

             o  Defining  the  subsurface  conditions around  and  below the
                trench

             o  Identifying  any  potential  movement of material  from the
                trench

     Originally,   the   trench  was   thought   to  be  delineated  by  the
1-foot-deep  surface depression as 53 feet long by  10 feet wide.  However,
the on-site  studies conducted  in June  1980 using magnetometers and metal
detectors led  to  the conclusion  that  the area occupied by the drums, and
thus the size  of  the trench,  is  somewhat larger.  Figure 4-7 illustrates
this area (shaded).   It  is  960  square  feet,  i.e., 80%  larger  than the
original estimate (outlined).    The shaded  area  as shown  on  Figure 4-7
does not indicate the boundary of the  original excavation, but rather the
edge of  the  outermost  drums regardless  of  the  depth.     Metal detector
data indicate  that,  in  addition   to  the buried   drums  in  the  trench,
smaller  metallic  debris  is  present  over  much of  the area.
     The depth of the  trench, as determined by ground penetrating radar
(GPR),  is between 6 and 8  feet.   The  trench, as shown on  the ground
penetrating  radar plot   (see Figure 4-8) appears  to be  shallower to the
south  and deeper  with steeper  sides to the north.   The GPR data also show
thai" thfi eastern  ond of the trench is  shallower  than  the western end.
The arrow  in Figure 4-8 locates the deeper  portion of  the  trench.   The
smaller  anomalies indicated on  the traverse of the  trench are  probably
associated with  reflection  from  the drums.
                                  4-23

-------
                               DISTANCE (FT.)



      -50    -40    -30    -20-10     0     10     20     30    40     50
    50
    40
    30
UJ
o


I
M

O
    -20-
    -30
    -40-
    -50
                 '12
 \
I 20 FEET  I
  SCALE
                                  E & E DETERMINATION
                                             t
                                             20'
                                            i
                                                  EPA ESTIMATE
LEGEND:

  EPA

  BORE

  HOLES
                Figure 4-7.  Plan View of Drum Distribution
                                  4-24

-------
i
M
Ul
            SOUTH
               -10'     +10'               NORTH

WS8BW
                                                         INDICATES POSSIBLE
                                                                          -o
                                                                          -3'
                                                                              ^ LOESS
                                                                          -6'
                                                      rJ'fJTRENCH BOTTOM WS
                                                      Iff',--       j -9-
                                                                                FRAGIPAN
                                                                                  LAYER
                                                                                TERRA ROSA
                                                                                 SOIL WITH
                                                                                   CHERT
                         Figure 4-8.  Radar Traverse - South to North of Disposal Trench

-------
     Resistivity  measurements  were  also  made  within  the  perimeter;
however, limited data were collected and  are  thought  to be  influenced  by
the metallic  drums.   From these measurements,  the bottom of  the  trench
was estimated to be  less  than 10 feet from the  surface,  which basically
confirms the GPR data.
     Based  on the GPR,  metal  detector,  and magnetometer  data,  E  &  E
estimates  that  the  trench could contain  approximately  140 to  150  drums.
Furthermore,  from magnetometer data, the concentration of drums increases
from east  to  west.   This conclusion is  also  supported by the  GPR data.
In  addition,  the GPR  data  show the  existence  of a  discontinuous  soil
horizon approximately 3 feet below the surface;  this horizon is suspected
to be the  fragipan horizon.
     Electromagnetic and  resistivity  data  from  inside the  perimeter  of
the site could not be applied  to data  outside because of the presence  of
the fence  and metallic materials within the perimeter.  Therefore,  the
lateral  migration  of  materials could not  be confirmed,  nor  could  the
condition  of  the trench bottom.
                                  4-26

-------
                        REFERENCES FOR SECTION 4
1.    Telephone  conversation  with  Mr.  Harmon  Chapman,  Transportation
     Planner,  Southwest  Missouri  Local  Government  Advisory  Council,
     Republic, Mo.

2.    U.S.  Department  of  Commerce,  National  Oceanic  and  Atmospheric
     Administration.    Climates  of   the   States   (Volume  II).     Port
     Washington, New York:  Water Information Center, Inc., 1974.

3.    Personal communication with J. Hadley  Williams, Missouri Department
     of Natural Resources.

4.    McKracken,  Mary L.    Structural  Features  of  Missouri,  Report  of
     Investigation No. 49.   Rolla,  Mo.:   Missouri  Geological  Survey and
     Water Resources, 1971.

5.    Aley, Williams, and Masello.  Groundwater Contamination and Sinkhole
     Collapse  Induced  by  Leaky Impoundments  in  Soluble Rock  Terrain.
     Rolla, Mo. :  Missouri Geological Survey and Water Resources,  1972.

6.    Technos, Inc.   Report of Geological and  Geophysical Investigation,
     Denny Farm Hazardous Materials Site, Barry County, Missouri.   Report
     prepared for Ecology and Environment, Inc., July 1980.

7.    Ecology  and  Environment,  Inc.   Results of Recent  Borings Conducted
     at Farm Site No. 1, Verona, Missouri.  FIT Region VII, July 1980.


8.    Williams,  J. Hadley.    Hydrologic  Aspects  of the  Farm Dump  Near
     Verona, McDowell Quadrangle, Barry County, Missouri.  Report  through
     Missouri  Department   of   Natural   Resources,   Engineering  Geology
     Section, June 4, 1980.

9.    Williams,  J.  Hadley  and Vineyard, Jerry D.   Geologic Indicators of
     Subsidence and  Collapse  in Karst  Terrain in Missouri.   Rolla,  Mo.;
     Missouri Department  of Natural Resources,  Division  of  Geology and
     Land Survey.

10.  Personal communication with Richard Benson, Technos,  Inc.
                                  4-27

-------
                           UNCITED REFERENCES


Bohra, Rex A.  Correspondence to Dan Harris, U.S. Environmental Protection
Agency, Surveillance and Analysis Division, Region VII through Missouri
Department of Natural Resources, Subsurface Geology and Oil and Gas
Section, December 11, 1979.

Rowe, N. and Koenig, J.  The Stratigraphic Succession in Missouri.
Volume XL, 2nd Series, Missouri Geological Survey and Water Resources,
1961.

Missouri Geological Survey.  Geologic Map of Missouri.  1:500,000, 1979.

Scrivner, C.L., Baker, J.C., Miller, B.J.  Soils of Missouri.  University
of Missouri Extension Division.

Terzaghi, K. and Peck, R.  Soil Mechanics in Engineering Practice.  2nd
Edition.  John Wiley and Sons,  Inc., 1967.

U.S. Department of Agriculture, Soil Conservation Service.  Soil Survey
Interpretations, Clarksville Series and Wilderness Series.

U.S. Geological Survey.  McDowell Quadrangle.  Missouri, 1:24,000, 1972.

Williams, J. Hadley.   Summary of Geologic Conditions at the McDowell Dump
Site,  Barry County. Missouri.   Report through Missouri Department of
Natural  Resources, Engineering  Geology Section, May 13, 1980.
                                   4-28

-------
                                SECTION 5
                          SITE CHARACTERIZATION
INTRODUCTION
     The hazardous  waste site in  Aurora,  Missouri,  identified  as  Denny
Farm Site 1 can be characterized by consideration of three elements:  the
methods used for disposing of  the  waste,  a description of the waste,  and
public health  and  environmental  concerns.  Such  characterization  is  the
purpose of this section.

METHODS USED FOR DISPOSING OF THE WASTE
     As  noted  in  Section   2   of  this  report,  the   North   Eastern
Pharmaceutical and  Chemical  Company (NEPACCO) caused  a trench to  be  dug
on  the  Denny Farm  near  Aurora,  Missouri,  for  the disposal  of  chemical
wastes.  Once  the  trench was  dug, a truck backed up  to  the  trench  and
haphazardly dumped  some  150 drums of chemical waste into the trench.  The
drums were  left  as they  fell.   No attempt was  made  to  make  an orderly
disposition  of the drums.   The  trench was then  filled  in  with between
one  and  three feet  of  soil.   No  attempt  was  made to  line or cap  the
trench.
     When the  trench was  first reported to EPA-Region VII and the initial
investigation  was  carried  out,   it  was  thought,  because  of  surface
depression,  that  the trench was  10 by  53 feet  in  dimensions—a  fairly
regular rectangle.  Subsequent investigations by Ecology and Environment,
Inc.  (E &  E),  have  determined that  the  trench  is  irregular in  shape,
somewhat the shape  of a  paramecium, and measures 20 by 65 feet.
     Initially,   the  depth  was   undetermined   by  the  EPA-Region  VII
investigation.    Based  on  E  &  E's  investigation with  electromagnetic
detectors, the trench depth has been estimated at 6 to 8 feet.

DESCRIPTION OF THE  WASTE
     Denny Farm  Site 1  contains some 150,  55-gallon drums with  chemical
       in liquid,  sludge, and tarry residue forms; water  that has  leaked
                                   5-1

-------
into  the trench  and accumulated  there;  and contaminated  intermingled

soil.

     In  more  specific  terms,  known  waste  components  (confirmed  by

analysis) at Denny Farm Site  1  are:   tetrachlorodibenzo-p-dioxin (TCDD),

2,4,5,-trichlorophenol  (TCP),  toluene,  xylene,   tetrachlorobenzene,  and

ethylene glycol.   Other  suspected components of  the  contaminated wastes

are:        benzene   ethers,   benzene,   phenol,   chlorinated   phenols,

polychlorinated   biphenyls,   chlorinated   benzene,    sodium   hydroxide,

sulfuric acid, carboxylic acid, formaldehyde, and hexachlorophene.


PUBLIC HEALTH AND ENVIRONMENTAL CONCERNS


                                SUMMARY
             Evaluation of  the  public  health hazards associated
        with a chemical waste site requires consideration of the
        toxic potency of the chemical spoils.  Also important in
        such  assessment  are  those physical  characteristics  of
        the  waste that  affect  dispersal  and longevity  of the
        hazard in the environment.
             The  overwhelming toxic feature  of the  Denny  Farm
        Site  1  is  the presence  of tetrachlorodibenzo-p-dioxin
        (TCDD) in amounts exceeding 300 mg/1  in the liquid waste
        material.   This  compound  is one of  the  most poisonous
        chemicals  known,   an  orally  administered  dose  being
        lethal  to the most sensitive  test  animal,  the guinea
        pig, in concentrations  less  than 2 yug/kg of bodyweight.
        A comparable toxic  dose in humans would be 140 yug, based
        on  a body weight of  70 kg.   This amount of  pure  TCDD
        would be barely visible to the human  eye. In addition to
        being  toxic  if  ingested,  TCDD   is  also  capable  of
        penetrating  the  skin  though   absorption  and   is  thus
        poisonous via  dermal contact.   In  rabbits,  the dermal
        lethal dose is about 2.5  times the  oral dose.
             The  above  toxicity discussion  is  based  upon acute
        or  short-term  exposure  situations.   Unfortunately,  TCDD
        levels required  for toxic activity  are  much  reduced in
        long-term or chronic  exposures.   This fact is supported
        by  laboratory  data  that report  toxic effects in guinea
        pigs at  dose  levels as low  as  0.008 >ig/kg administered
        on  a weekly basis.   The scientific literature describes
        diverse  harmful  effects  from  long-term  exposure  that
        include  cancers, fetal  deformity,  and  suppression  of
        immunity response systems.
                                  5-2

-------
          Presently, there are no  established  "safe levels"
        of TCDD exposure  to  humans in food or  drinking water,
        but the 300 mg/1 (ppm) measured level in the Denny Farm
        Site 1 wastes  is 300  million times more  concentrated
        than values  being discussed  as  tolerable to  humans.
        This fact  generates  concern  about  the health  hazards
        presented by the disposal site in terms of the toxicity
        potential.
             The solubility of TCDD in water is only  0.2/ig/l.
        This  fact  plus  laboratory  findings   that  indicate  a
        strong attachment affinity between  the toxin  and soil
        particles results in its low mobility in soil moisture.
        Several reports by independent investigators have found
        that TCDD disappears  at  a moderate  rate in  soils,  the
        calculated  half-life  being about  one  year.    The  low
        mobility  in soil moisture and  its  lack  of  prolonged
        persistence make TCDD a rare contaminant of groundwater
        at  distances   removed  from  the  pollutant   source.
        Environmental  contamination  from  dioxin  is  usually
        detected by  analysis  of  stream sediments, to  which it
        binds, and  of  aquatic and terrestrial  organisms  which
        bioaccumulate it.
             Two factors that  complicate  the hazard evaluation
        of the Denny Farm Site 1 are the lack of predictability
        of limestone karst  involvement in providing  a conduit
        for water  contamination,  and the unknown  solubilizing
        effects   afforded   by   the   other   organic   liquid
        co-pollutants    present    in    the    waste    trench.
        Conceivably, these site characteristics could singly or
        jointly provide abrupt and high-level  contamination of
        groundwater.  Such an occurrence could  be  devastatingly
        harmful to humans and animals living in the area.


     Evaluation of  the hazards  presented by Denny  Farm Site  1  entails
consideration of the acute and chronic toxicity of the chemicals known to
be  present  on  the  site  and  their  respective  environmental  fates.
Environmental  fate  assessment   includes  consideration   of   mobility,
persistence,  metabolism,  and  bioaccumulation  potential.     All  these
factors interact to  comprise  the  danger  imposed upon  the  public adjacent
to the disposal area and personnel involved  in  cleanup.

     Historical data on the  Denny Farm Site  1  indicate that  55-gallon
drums containing  the waste  materials were dumped  from a truck directly
into an open trench.   Based  on an estimated  150 drums  buried within  the

defined limits of the  trench,  a  general  assumption can be  made  that  the

initial waste volume dumped  into the excavation would equal  roughly 8,250

gallons.   This  also assumes  that  each drum was  completely full  at  the
time of disposal.

                                  5-3

-------
     Table 5-1  lists chemical  wastes  known to be present  in  the trench.
The presence  of these wastes  is  based on conclusive  analytical results
from EPA.   Also noted in the  table  are other chemicals suspected  to  be
present  in the  waste  due  to  their  association  with  the  manufacturing
process  for hexachlorophene.   This information was derived by reviewing
and reconstructing the synthesis scheme for that process.
     Quantitative analysis  on  a four-drum composite sample taken  by EPA
revealed TCDD  present  at  319 mg/1.   It should be noted  that  this  sample
was not  homogeneous  at  the  time of analysis.  Therefore,  this value may
not be representative of  the  entire  sample.   It  may be arguable  that
levels higher  that  this  reported  value may exist  in different components
in the trench.   At any rate the sample evidence indicated alarmingly high
TCDD levels within the confines of the trench.
     Although  the most toxic isomer (2,3,7,8-TCDD) has not been confirmed
through  analysis, it  is  of  assumed presence based on  its  known and well
documented  association  with  the production  of  2,4,5-trichlorophenol.
Isomer  anaytical studies  are  underway at  Wright  State  University  to
confirm  2,3,7,8-TCDD presence  in  the waste.   Although  it  is  likely that
numerous   other hazards  exist   at   Denny  Farm   Site  1,  this  report
concentrates on hazards associated with the TCDD isomer because the toxic
potential  it provides  is over  a million-fold higher than any of the other
chemicals  known or suspected  to  be  in the  wastes.   This  evaluation  is
based  on acute  toxicity  data.   Furthermore,  it  will  be  seen  that  the
remedial  alternatives  presented  in   this  document  will  provide  for
containment of all chemical wastes.

Toxicological  Considerations of 2,3,7,8-Tetrachlorodibenzo-p-dioxin
(TCDD)

A.  Acute  and  Chronic  Toxicity in Animals
     One of  the major  health concerns with TCDD contamination is that it
is one of  the  most  potently toxic substances known in mammalian species.
Depending  on  the  species,  the acute  and  chronic  toxic  doses generally
                                   5-4

-------
                        TABLE 5-1
          COMPOUNDS  OF KNOWN  OR SUSPECTED PRESENCE
                   AT DENNY  FARM SITE  1
                COMPOUNDS
TETRACHLORODIBENZO-p-DIOXIN (TCDD)*
2. 4, 5-TRICHLOROPHENOL (TCP)*
TOLUENE*
XYLENE*
TETRACHLOROBENZENE*
ETHYLENE GLYCOL*
BENZENE ETHERS
BENZENE
PHENOL
CHLORINATED PHENOLS
POLYCHLORINATED BIPHENYLS
CHLORINATED BENZENE
SODIUM HYDROXIDE
SULFURIC ACID
CARBOXYLIC ACID
FORMALDEHYDE
HEXACLOROPHENE
                           5-5

-------
show  a wide  variation in the  submicrogram to  microgram range.   As an
example,   the   following   values  have   been  excerpted   from   recent
literature:
    Species                  Dosage Regimen            Toxic Dose
    Rhesus Monkey            Single Oral LD50          70>ug/animal
    Guinea Pig               Single Oral LC$Q          2 jug/kg
    Mouse                    Single Oral LD50          284/ig/kg
    Rabbit                   Dermal LD5Q               275/ig/kg
    Rabbit                   Oral LD5Q                 115/ig/kg
     An  interesting   feature  of  short-term  toxicity  tests  with TCDD
is  that  they have  revealed  an unusual temporal dependence,  i.e., acute
toxicity tests  are  always  run  for a  time  interval  of a few  days.  Tests
with TCDD reveal mortality in  a  time  range of  five days  to several  weeks.
This prolonged  interval and  the variety of TCDD-induced tissue  anomalies
across the  species investigated have  thus  far confounded  attempts to
determine the exact cause  of death.

B.  Carcinogenicity
     A two-year chronic toxicity and oncogenicity study of TCDD has been
completed  in  rats  by  Kociba  and  co-workers  (1).   Ingestion  of  0.1
/ig/kg/day  caused an increased  incidence  in carcinomas  of  liver,  lungs,
and  mouth  while  decreasing  the incidence   of tumors  of   the  uterus;
pancreas;  and  pituitary,  mammary,  and adrenal  glands.    Tissue  samples
from animals at this  dose level contained 24  ppb  TCDD in the liver, and
8.1 ppb  in  fat.  Interestingly,  the  increased incidence of tumors  in the
lungs  and  liver at the  high  dose of this study occurred  only in  female
rats while  the  oral-nasal tumors were significant in males.   The  authors
also  noted  that at this  dosage  the animals  manifested other  signs of
significant   toxicity  including  increased  mortality;   decreased   weight
gain;  depressed erythroid parameters;  increased excretion of porphyrins
and aminolevulinc  acid;  as well  as evidence  of liver damage determined by
elevated   serum  activities   of   alkaline   phosphatase,  gamma-glutamyl
transferase,  and glutamicpyruvic  transferase.  At  dosages   ten  and one
hundred  times  lower   than 0.1 yjg/kg/day,  the chronic  toxicity  of TCDD

                                  5-6

-------
diminished  to  nothing  and   there   were   no  sigificant   increases  in
identifiable carcinomas when  compared to the control  animals.   Thus,  it
was concluded  that  during this  two-year study  in  rats, no  increase  in
tumors occurred at dosages of TCDD causing slight or no manifestations of
toxicity.  This suggests that  the increased incidence of cancer observed
at high-dose levels may  be due to increased  cell  death and replacement,
since an  increase in  cell  turnover during  constant exposure to cellulary
toxic   compounds   provides    increased   opportunity    for   spontaneous
carcinogenesis.  It should also  be re-emphasized that TCDD decreased the
natural incidence of  tumorigenesis of some  organs  in this  study and that
another   study  (2)   using    the  two-state   inttation/promotion   test
demonstrated that  the TCDD exhibited potent  anticarcinogenic  effects  on
papillomas induced by demethybenz(a)anthrene.

C.  Teratogenicity; Fetotoxicity; Reproductive Effects
     TCDD is  fetotoxic  at maternally   toxic  doses  in rats,  mice,  and
monkeys  (3).    In  mice,  doses of  1 ^ig/kg/day  or  greater consistently
produce  fetal  defects such  as cleft  palate and  kidney anomalies.   At
doses  lower   that  1  yjg/kg/day  no  teratogenic  or   fetotoxic  effects
occurred, establishing that  there is a "no effect"  dosage.   It has been
established  (4,5)  that  chronic   dosages of  1 jug/kg/day or  higher have
effect  on  the reproductive  capacity  of   rats  and  monkeys.    Yet  the
increased abortion rates  occur   at  dosages  which  again  are  maternally
toxic.   Barsotti et  al.  (4), using  rhesus monkeys,  concluded  that the
debilitating toxicity seen at the dosage used  (2 yug/kg) may have  caused
the  reproductive dysfunctions  seen.   The authors  also found  that the
surviving animals returned to  a  normal reproductive  status  once they were
removed  from the exposure  to TCDD.   In another study  (6) which determined
the  effect  of TCDD on three  generations of  reproduction in  the  rat,  it
was  concluded  that  0.001  /ig/kg/day  had no  effect  while  0.01  and O.I
/JR/kg/day clearly  affected normal  reproduction.   These data correlated
well  with the chronic toxicity  and  tumorigenesis  study in this species.
That  is,  overt toxicity correlates with  the effect.   In summary, a  review
                                   5-7

-------
 of  the  literature  indicates  that  TCDD  is  teratogenic  and  does  affect
 reproduction in animals,  but  it  also demonstrates  that  there  is  clearly  a
 "no effect"  dosage  level.

 D.   Other  Chronic Effects
      Guinea  pigs receiving doses of TCDD of  0.008,  0.004,  0.002,  and   1.0
yug/kg body weight per week were affected (7).  All animals receiving  1
/jg/kg levels died or became moribund.  They all exhibited atrophy  of  the
 lymphoid  organs,   lymphopenia,  and   severe  loss   in  body  weight.
 Additionally, cell-mediated  immunity  was suppressed at  levels  of 0.002
 and 0.004  yug/kg.  At the  extremely  low dose of 0.008 /ig/kg/week,  guinea
 pigs showed  significant  reduction in lymphocyte 'number.

 E.   Human  Effects
      Probably the  best  data  on  human response are the findings  from  the
 Seveso incident in  Italy (8).  A study of the human exposure    from this
 incident divided persons into two groups labeled Zones A and B.  In Zone
 A  the  average  contamination was  50 ^ug/sq.m.  for the  447  inhabitants
 studied.   Zone  B   was  comprised  of  362   inhabitants  with  3  _/ig/sq.m.
 exposure  plus   156  plant workers  of  the  factory where  the  explosion
 occurred.    Chloracne was  the major  and most  consistent effect.    The
 peripheral nervous  system studies  revealed  subclinical  signs  in  10% of
 the people  living  in the area  of  highest  contamination.   There was no
 correlation  between the neurological  findings  and chloracne.   Transient
 signs of liver damage without functional disorder  occurred in 10% of both
 groups.   The  imraunologic responses of  the  two  populations  were   not
 impaired.    There  was  no increase  in  fetal  deaths,   birth  defects,  or
 growth  retardation  out  of the  7,350  births' occurring in  the  first  two
 years  after  the incident.   Chromosome examinations did  not reveal  any
 changes from the normal  pattern.   Thus, the  author concluded  "that  man
 has a higher degree of  tolerance to TCDD than  a  direct  extrapolation from
 animal  data  would  suggest."    The  conclusion  is   supported  by  the data
 gathered on  the one exposed person who died during this  study.   The body
                                   5-8

-------
of  a  55-year-old  woman  who  died   seven  months  after  exposure  from
pancreatic  carcinoma  unrelated  to   the  accident  was  analyzed,  after
autopsy, for TCDD.  The woman had been exposed to TCDD from the explosion
and had  lived in a  contaminated area  (162-1847 yjg/sq.  m.)  for  fifteen
days.  The  total body burden of  TCDD was  calculated to be 40 jig at  the
time of  death.   Of course, she  had  to have eliminated some TCDD in  the
seven-month interval between  exposure and death.   Even though the amount
eliminated cannot be  calculated,  the analysis indicates that  the people
comprising  this  study   accumulated  large  amounts  of  TCDD  without
exhibiting any serious adverse effects thus far.   It should also be noted
that the amount of TCDD absorbed  was  1000 to  3000   times higher than  the
tolerable  amounts calculated  using  rat  or  guinea  pig  acute  toxicity
data.

Environmental Fate of Farm Site Pollutants
     Evaluation of  the  significance  of environmental  contamination of  a
particular  toxin  requires  knowledge  of  its  environmental  mobility,
persistence,  and bioaccumulation potential.    Poisons that  lack  these
characteristics,  even  though  highly  toxic,  have  reduced  impact   as
pollutants.
     Reports  in  the  science   literature  describe   the   environmental
mobility and persistence of TCDD.  One study (9)  using 34  ppm TCDD showed
loss of  less  than 0.3% of the  total  after  elution with 150 ml of water
through a sandy loam soil column  2.5 cm in length.   This lack of mobility
through  the  soil is due  to  TCDD  having  extremely low water  solubility
(0.2jug/l) and a tenacious binding affinity, particularly  in  soils having
a high  ion-exchange  capacity  because of clay or  organic  content.  This
strong  affinity  is  illustrated  by  the  rigorous  extraction  methods
required   to   remove  dioxins    from   soils   cnmtaminated  with  known
concentrations.    Often   efficient   extraction   is   only   achieved   by
extracting the soils with boiling organic solvents  for long periods.
     Several  investigators   (10,11,12)  have  found   the   environmental
half-life  of  TCDD  in  soils  to be  about  one year.    The  mechanism  of
                                  5-9

-------
destruction is thought to be tnicrobial, but no one has been successful in
attempts  to isolate  microbes  capable of  efficient  TCDD breakdown  in
vitro.  There  is  an apparent negative correlation  between the  degree of
in vitro  microbial degradation  and the  extent  of  dioxin chlorination.
Since TCDD  is  a heavily  chlorinated isomer,  it  was  not  susceptible to
attack in laboratory studies.
     In a field study  (13),  no  TCDD residues were detected in soils that
had recieved repeated  applications of TCDD-contaminated 2,4,5-T at a rate
of  1,000  Ibs/acre/year  over a  seven-year period.   The  destruction of
surface applications of TCDD is probably due largely to its photolability
to ultraviolet  light.   One  study reported 100% loss  of  TCDD  in methanol
solutions irradiated with simulated  sunlight for a 24-hour period (14).
     In evaluating the  possibility  of TCDD movement  at  the  Denny Farm
Site  1,  one must  recognize typical  disposal-site features  which  could
promote migration.   The site  contains  large  concentrations  of  dioxin
relative  to an agriculturally-contaminated area,  and  the  toxin is  mixed
in  an undefined matrix of organic  liquids.   Conceivably these organic
wastes could  increase TCDD movement by effectively  increasing  its  water
solubility  and by  tying  up the soil  binding  capacity.    However,  it is
felt that these effects will be minimal in increasing soil migration, if
the  clay  soils are continuous  and sufficiently deep  to accommodate the
total binding  load.   The known organics present in  the  site  are also of
low  water solubility  and would  not  be expected  to  increase  greatly the
solubility  of  the  dioxin.   Also,  the rapid dilution of these organics in
the  soil  as migration  proceeded would  prevent maintenance  of high  dioxin
load over long distances.
     In  summary,   dioxin contamination of  groundwater at  sites removed
from the  source is unlikely.   Low  water solubility  and  tenacious soil
binding largely account for this lack of mobility.  Environmental spread
is more apt to occur   in  the  form  of contaminated soil particle movement
either by wind or  surface water  erosion.   Consequently, a  likely place to
detect  the  movement of dioxin  is  in  surface  waste sediments where soil
surface   fines  can  accumulate.     Additionally,  aquatic  animals  are
                                   5-10

-------
documented accumulators of  TCDD in apparently uncontaminated  waters  and
could  provide  additional  evidence   of  dioxin  contamination.    It   is
suggested  that  benthic  organisms  and  associated  predator  species  be
sampled in Calton Creek and any other surface waters near the  site as  a
check for dioxin migration.
     Because of  lower mammalian toxicity, the other organic pollutants at
the Denny Farm Site 1 have  received less scientific attention in terms of
environmental  fate.  Trichlorophenol has the greatest water solubility of
the known organic pollutants  on the  disposal site, and  it  is  present in
the highest  concentrations.  Therefore,  it would apparently  possess  the
largest  potential  for  environmental  movement  via  groundwater  flow.
Monitoring of  groundwater  in  the  area for  TCP contamination has thus  far
been negative,  indicating the absence of groundwater pollution from  the
organic wastes.   However,  this  monitoring does not  absolutely rule  out
the  possibility  that  groundwater  pollution  has  occurred in the  past or
even  is presently  a  problem  in  channelized  water flows  not confluent
with the monitoring wells.  There  are no direct scientific data available
on the  soil-binding characterisitics or bioaccumulation potentials of TCP
or  the other  known  waste  organics  in the disposal  pit.    Their common
aromatic  structures would predict a high  probability of similarity  with
dioxin,  i.e.,  moderate  to  high  soil  affinities  and  bioaccumulation
potentials.   The comparatively low mammalian  toxicities associated  with
these  chemicals, however,  reduce the  potential  for detrimental public
health  impact  relative to  dioxin.

Public  Health  Routes of Exposure
     Exposure  to  the  resident  population  near  the  site could  occur
through a  number of different  pathways  as  shown on Figure 5-1.  The most
probable  route would  be by ingestion of contaminated water or  food or by
dormal  or  respiratory contact  with contaminated soil or  other  particulate
matter.   Accurate evaluation  of  the  risk  associated with dermal contact
with contaminated soil  particles is  difficult due to a  lack of knowledge
regarding  the partitioning characteristics  of the  organics,   especially
                                   5-11

-------
          DIRECT HUMAN EXPOSURE
            VIA DERMAL CONTACT
              AND INHALATION
                                     DEPOSITION ON CROPS-
                                   INDIRECT HUMAN EXPOSURE
                                      VIA INGESTION AND
                                 BIOACCUMULATION IN GRAZING
                                GAME AND AGRICULTURE ANIMALS
                                                                                      FALL OUT
Ul
I
                                                 AIRBORNE
                                                 PARTICLES
                                                                                       FISH STREAMS
                                                                                    BIOACCUMULATION
                                                                                     HUMAN EXPOSURE
                                                                                       VIA INGESTED
                                                                                    FISH AND SEDIMENT
                                                                                         CONTACT
                     SURFACE EROSION OF
                 CONTAMINATED SOIL PARTICLES
  SINK HOLE
DEVELOPMENT
  COLLAPSE
                     POTABLE WATER CONTAMINATION
                               Figure 5-1.  Exposure Routes of TCDD to the  Public

-------
TCDD, between human skin and soil.  It would  undoubtedly  depend  upon the
degree of soil contamination, nature of pollutant mixture, soil type, and
extent  of  exposure.    Additionally,  potential  for  contaminated  soil
movement  would  be maximum  following  soil  disturbance in  and  over the
disposal  trench.   The  soil would  then exist  in a  loosely  packed and
friable state, being more readily translocated  by air and  water.   Since
the  trench  was   covered  with  ground  vegetation prior  to   the  recent
opening,  it is likely that soil-borne contamination has been low.  Future
plans  involving   soil  disturbance must  consider  control  of  soil-borne
spread,  i.e. , dust  and  surface  erosion  control.    An   additional  site
feature  minimizing airborne  spread  is  the  density  of  tree and  shrub
vegetation  around the  site that  serves  to  retard  wind  and to  filter'
aerial particulates.
     Ingestion of food  produced  in  the  area that might  be  directly  or
indirectly contaminated with soil-carried  pollutants  is also of concern.
The most  probable exposure route of this sort would come  from eating fish
taken  from streams with  contaminated  sediment.   Dioxins  are  known  to
concentrate   in   aquatic  organisms   and  this   contamination  in  fact
represents  a  frequent  indication  of TCDD movement  from a concentrated
source.    Plants do   not   translocate   accumulated   dioxins  or  other
nonaqueous soluble organics  in  appreciable quantities.   Contamination of
agricultural  crops  would   occur via  surface  retention   of  airborne
particulates.  Grazing animals could conceivably  accumulate TCDD or other
dioxins   from  ingest ion  of  contaminated  plants,  thus  serving  as  an
indirect  human exposure source in the  form of milk and meat products.
     With regard  to worker  safety,  the  same routes of  exposure apply.
Obviously,  the  risk  is  increased.    Due  to the  high  toxicity  of  TCDD
isomers,  the  most  stringent   safety  procedures are  warranted  during
activities  in and around the  opened site.   This includes  use  of  fully
encapsulated  rubber   suits,  SCBA,   and  thorough   decontamination  of
personnel and equipment as discussed in Appendix  D.

Acceptable Cleanup Levels
     The  assessment  completed  during  this   study  (Section  4)  warrants
tnt.il  removal of the  drum  contents  and  heavily  contaminated  soils.
                                  5-13

-------
However,  a  determination  of  the  acceptable  TCDD  level  in  the  soil
remnants remains to be  determined.   Ideally, a zero-contamination  level
is desired  for  TCDD.  In view  of  the low mobility  of  this substance  in
soil, this level of cleanup may be obtainable.  The  final  decision  on  an
acceptable  cleanup level  currently  is  the  purview  of EPA.    Several
factors, however, should be taken  into consideration in establishing this
level,  These include:

        o  Detectable limits  of TCDD.   (This  will also  affect  sample
           turnaround time.)
        o  Turnaround time required for sample analysis.   This time directly
           affects excavation and  the length of time the trench must be kept
           open.
        o  The  possibility  of  cross-contamination due  to  the  amount  of
           manpower and equipment  in and around the trench.
        o  Mobility of dioxin in soil.
        o  Known acute and chronic toxicity data.
                                  5-14

-------
                        REFERENCES FOR SECTION 5

1.   Kociba,  R. J.  et al.   Results of  a two  year  chronic toxicity  and
    oncogenicity  study  of  2,3,7,8-Tetrachlorodibenzo-p-dioxin  in  rats.
    Tox.  App.  Pharmacol. 46:279-303.   1977.

2.   Berry, D.  L.,  et al.   Studies  with chlorinated  dibenzo-p-dioxins,
    polybrominated  biphenyls,  and polychlorinated biphenyls in a
    two-stage  system of mouse  skin tumorigenesis;	potent
    anticarcinogenic effects.   Ann. N.Y. Acad. Sci.  320:405-414.  1979.

3.   Smith, F.A., et  al.   Teratogenicity of  2,3,7,8-Tetrachlorodibenzo-p-
    dioxin in CF-1  mice.  Tox. Appl.  Pharmacol. 38:  517-523.   1976.

4.   Barsotti,   D.  A.,  et  al.   Hormonal  alterations  in  female  rhesus
    monkeys fed  a  diet  containing  2,3,7,8-Tetrachlorodibenzo-p-dioxin.
    Bull. Environ.  Contain. Tox. 21:463-469.   1974.

5.   Courtney,   D.  C.    Mouse   teratology studies  with  Chloridobenzo-p-
    dioxins.  Bull.  Environ. Contain.  Tox. 16:674-681.  1976.

6.   Murray, F. J. ,  et  al.  Three generation reproduction study  of rats
    given  2,3,7,8-Tetrachlorodibenzo-p-dioxin.   Tox.  Appl.  Pharmacol.
    50:241-252.  1979.

7.   Vos, J. G., et al.   Effects of 2,3.7.8-Tetrachlorodibenzo-p-dioxin on
    the  immune system  laboratory  animals.    Environ.  Hlth.  Perspect.
    5:125.  1973.

8.   Reggiani, G.   Estimation  of  the TCDD toxic potential  in  the light of
    the Seveso accident.  Arch. Toxicol. Suppl. 2:291-302.  1979.

9.   Matsumura, F. and Benezet, H.  J.   Studies on the bioaccumulation  and
    microbial degradation of  2,3,7,8-Tetrachlorodibenzo-p-dioxins.
    Environ.  Hlth. Perspect.  5:253.  1973.

10. Helling,  C.  S.,  et  al.    Chlorodioxins  in  pesticides,  soils,   and
    plants.  J. Environ. Qual. 2:  171.   1973.

11. Kearney,   P.   C.,   et  al.     Tetrachlorodibenzo-p-dioxin  in   the
    environment;    sources,  fate  and  decontamination.    Environ.  Hlth.
    Perspect. 5:273.  1973.

12.  Young,  A. L.,  et   al.    Fate  of 2,3,7,8-Tetrachlorodibenzo-p-dioxin
    (TCDD) in the environment;  Summary  and decontamination
    recommendations.  USAF Technical Report USAFA-TR-76-18.   1976.
                                  5-15

-------
13.   Woolson,  E.A.,  et  al.    Dioxin residues  in Lakeland  sand and  bald
     eagle samples.   Advances in Chemistry  Series,  No.  120, Chapter  12.
     American Chemical Society,  Washington,  D.C., 1973.

14.   Crosby,  D. G. ,  et  al.    Environmental  generation and  degradation  of
     dibenzodioxins and  dibenzofurans.   Environ.  Hlth.  Perspect.  5:259.
     1973.
                                  5-16

-------
                        UNCITED REFERENCES
Bughman,  Robert  and  Meselson,   M.    Analytical  method  for  detecting'
TCDD  (Dioxin);    Levels  of TCDD in  samples  from  Vietnam.    Environ.
Health Perspectives, No. 5:27.   1973.

Bently, P. W.,  Vaughn, W. K.,  and Neal,  R.  A.   Effect of  alteration of
rat hepatic mixed-function oxidase activity on the toxicity of
2,3,7,8-Tetrachlorodibenzo-p-dioxin.          Tox.    Appl.     Pharmacol,
45:513-519.  1978.

Crow, K. D.  Effects of dioxin exposure.  Lancet 2:82.   1977.

Drinking Water  and  Health.    National Academy  of  Sciences, Washington,
D.C.  1977.

Giovanne,  S.   Q.   et   al.    Effects  of   pretreatment   with  2,3,7,8-
Tetrachlorodibenzo-p-dioxin on    the    capacity    of    hepatic    and
extra-hepatic mouse tissues to  convert  procarcinogens  to  mutagens  for
Salmonello  typhirium  auxotrophs.   Tox.  Appl.  Pharmacol.  50:229-239.
1979.

Goodman,  L.  S.  and   Oilman,   A.   E.    The   phartnacologic  basis  of
therapeutics, 5th Ed., New York:  MacMillan Publishing.  1975.

Harris,  M.    W.,  et  al.    General  biological  effects  of  TCDD  in
laboratory  animals.    Environmental  Health  Perspectives,  No.  5:101.
1973.

Kenkyujo,  K.  G.  S.   Toxic and  Hazardous  Industrial Chemicals  Safety
Manual, International Technical Information Institute.   1976.

Kimbrough,   R.   D. ,    et   al.       Epidemiology and pathology of the
tetrachlorodibenzodioxin  poisoning  episode.     Arch.  Environ.  Health
27:77-86.  1977.

Laporte, J. R.  Effects of dioxin exposure.  Lancet 1:1049.   1971.

McConnell,  E.   E.,   et al.    The comparative   toxicity  of  chlorinated
dibenzo-p-dioxins  in  mice  and   guinea  pigs.    Tox.  Appl.  Pharmacol.
44:335-356.  1978.

McConnell, et  al.   Toxicity  of 2,3,7,8-Tetrachlorodibenzo-p-dioxin in
rhesus  monkeys  following  a single  oral  dose.    Tox. Appl.  Pharmacol.
43:175-18&.  1978.

Miller, R. A.,  et al.     Toxicity of 2,3,7,8-Tetrachlorodibenzo-p-dioxin
(TCDD)  in  aquatic  organisms.    Environmental  Health  Perspectives,  No.
5:177.  1973.

Noal,  R.  A.,  et  al.    Studies on the mechanism of toxicity  2,3,7,8-
tPtrachlorodibenzo-p-dioxin.  Ann. N.Y., Acad. Sci. 320:204-213.  1979
                                  5-17

-------
Patty, F. A.   Industrial  Hygiene  and Toxicology, 2nd Edition,  Volume  2.
York:  John Wiley & Sons.   1963.

Schiffs, L.   Diseases of the  Liver,  4th Edition,  Lippincott  Publishing
Co.  1975.

Schwetz,  B.  A.,  et  al.    Toxicology  of chlorinated  dibenzo-p-dioxins.
Environmental Health Perspective,  No. 5:87.   1973.

Verschueren, K.   Handbook of  Environmental Data on Organic  Chemicals.
New York:  Nostrand Reinhold Co.   1977.
                                  5-18

-------
                                SECTION  6

                      REMEDIAL APPROACH  METHODOLOGY
INTRODUCTION
     In order to proceed with any remedial  action  for a hazardous  waste
site, it is necessary to devise an appropriate methodology.  The  purpose
of this section is to communicate to  the  reader  the  remedial  approach
methodology that has been designed by Ecology  and  Environment, Inc.,  to
determine the most effective means for solving the  waste disposal problem
at Denny Farm Site 1.  This  methodology   is  summarized  in  Figure  6-1.
Application of the methodology to  the specific situation  at Denny  Farm
Site 1 will be found in Sections  7 and 8  of this report.

STATING THE OBJECTIVE
     As with any task, the   most   important—though    often   the   most
frequently forgotten—first step is setting the task's objective.   Simply
stated:  What is the desired result of the work that will be done in this
task?  The answer to that question is critical.  Without it, the specific
work to be done cannot be determined.   Furthermore, the more specific the
answer is, i.e., the more specific  the  statement of  the  objective,  the
more helpful it is in determining the work to be done.
     A simple example will make  the above  notion clear.   There is a vast
difference between the following  statements of  an objective  for  Denny
Farm Site 1:

        o  Objective A:  To clean up Denny Farm Site 1

        o  Objective B:  To remove TCDD and associated
                         contaminated material from the
                         environment at Denny Farm Site 1

     Objective A is  clearly  too   vague.    "To  clean  up"  can  mean  many
different things, e.g., to dig up and remove  the drums  that were dumped
at Denny Farm Site 1; and then to fill  up  the  pit,  level  the  site,  and

                                  6-1

-------
                         SITE
                       IDENTIFI-
                        CATION
                         AND
                       INVESTI-
                        GATION
STATEMENT
    OF
 REMEDIAL
 OBJECTIVE
  INVESTI-
  GATION
 OF MEANS
TO ACHIEVE
 OBJECTIVE
                                                                           MEANS
                                                                           • STORAGE
                                                                           • TREATMENT
                                                                           • DISPOSAL
K>
 DETERMI-
NATION OF
 METHODS
                                                          \
                                                                             ELIMINATED
                                                                              METHODS
                                                                              REMAINING
                                                                              AVAILABLE
                                                                               METHODS
                                                    '/ X XX / / /
                                                    X FILTERING OF/
                                                    X  SELECTED  X,
                                                    X  METHODS  X
                                                    '/  THROUGH  X
                                                    '/ SELECTION  '/
                                                    \Ss  CRITERIA  'A
                                                     CRITERIA
                                                     • PROVEN TECH
                                                     • RISK
                                                     • TIME
                                                     • COST
                                                     • LEGAL
                                                       RAMIFICATIONS
                                        Figure 6-1.   Flow of  Remedial Approach Methodology

-------
plant grass.   "To clean  up"  can be  defined any  way  one  wants  to  de-
fine it.
     Objective B is much more  specific and paradoxically  calls  for  a more
far reaching and widespread delineation  of subtasks (specific work)  for
its accomplishment.
     Stating the objective is, therefore, of paramount  importance  and the
sine qua non first step of a remedial  approach methodology.

DETERMINING THE MEANS
     Once  the  objective has  been  clearly  stated,  the next  step  is  to
determine  the  means for  achieving  the  objective.   In  the instance  at
hand, those means have been determined by Federal regulation.
     The Federal Register (Volume 45, Number  98) of  19 May  1980  presents
three means  that  are legally available  for the management of hazardous
waste materials:   disposal,  storage,  and treatment.   Thus, any  remedial
approach for the handling of  hazardous waste  materials is  limited  to one
or a combination of these three federally regulated means.
     These legal means are defined as follows:

       o   Disposal:    "the    discharge,   deposit,    injection,   dumping,
                     spilling, leaking,  or  placing of  any solid  waste or
                     hazardous waste into or on any land  or water so that
                     such   solid   waste   or   hazardous   waste  or  any
                     constituent thereof may  enter the environment  or be
                     emitted  into the air  or  discharged  into  any waters,
                     including ground waters  (sic)."

       o  Storage:     "the holding  of hazardous  waste  for a temporary
                     period,  at  the  end  of which  the  hazardous  waste is
                     treated,  disposed of, or stored elsewhere."

       o   Treatment:  "any  method,   technique,   or   process,   including
                     neutralization,  designed  to change   the physical,
                     chemical, or biological  character or  composition of
                     any hazardous waste so as  to  neutralize  such waste,
                     or  so  as  to  recover  energy  or  material resources
                                  6-3

-------
                      from the  waste,  or  so as  to  render  such  waste
                      non-hazardous,   or   less   hazardous;   safer   to
                      transport, store, or  dispose  of; or amenable  for
                      recovery,   amenable   for  storage,  or  reduced  in
                      volume."
     Thus, at present, anyone involved in  providing  a remedial  approach
for solving problems arising from hazardous wastes has the means defined
by Federal regulation.

METHODS
     With the means for remedying a hazardous waste problem established,
various methods to be used in each one of the means can be examined.   As
might be expected, methods are extremely varied and of greater or lesser
complexity.
     Without attempting to be exhaustive,  several methods  can be listed
here for each of the available means noted above.

Disposal
     The definition of disposal as given in the  Federal  Register cited
above  really appears  to cover a  variety of  disposals:    accidental,
careless,  intentionally   destructive,  and  controlled.   Obviously,  in
discussing  disposal  as   a   remedial   approach,  one   is  talking  about
controlled disposal.   The definition also suggests  some  of  the methods
needed in the use of this remedial means:

        o  excavation
        o  transportation
        o  burial

     Connected  with  controlled  disposal  is  the  notion  of   a  disposal
facility.  "Disposal facility" is defined by the Federal regulations as:
"a  facility  or  part  of  a   facility  at  which  hazardous  waste  is
intentionally placed  into or on any land  or  water,  and at  which waste
will remain after closure."
                                  6-4

-------
Storage
     When storage is being explored  as  a possible means  for  remedying a
hazardous waste  problem,  a  number  of  potential  methods  can be  given
consideration:  on-site or off-site  storage,  above-ground or  underground
storage, type of  storage  facility,  etc.   Each  of  these  presents  it  own
set of methodological components, for example:

        o  engineering design
        o  excavation
        o  structure design
        o  construction

Treatment
     The presently available  methods for the treatment of hazardous waste
materials are three:

        o  chemical, e.g., UV photolysis
        o  biological, e.g.,  biodegradation
        o  physical, e.g., incineration

CRITERIA
     Once the means and various methods have been listed, it is necessary
to apply certain  criteria  which  further  delineate  the appropriateness of
any one or combination of means.  The criteria are applied to the methods
that  comprise the  means.   At  a minimum,  the  following criteria  are
applicable:
        o  proven technology
        o  risk
        o  time
        o  cost
        o  legal ramifications

Proven Technology
     The question that must  always  be  asked  is  whether a technology  that
is being  presented for  solving the problem is proven,  i.e.,  is there
sufficient scientific evidence  to demonstrate that  it works effectively.
                                  6-5

-------
For  example,  is  it  accepted  by  the  scientific  community  that  UV
photolysis   is    an   effective   method    for    the    treatment    of
dioxin-contaminated waste?

Risk
     Whatever  the  remedial approach  that  is  being  considered,  a  risk
analysis  must  be  performed  that  takes  into account  the methods  under
study.   The purpose of  this  risk analysis  is  to  answer  satisfactorily
questions that arise concerning  the  health and safety of  the  public and
the protection of the environment.

Time
     This criterion  must be  applied  in  order  to ascertain whether the
methods being considered can  be  used  and  still  meet any time constraints
placed upon the remedial approach in the statement of the objective.  For
example,  if   the   objective  states   that   certain  results  must  be
accomplished within  sixty days,  any method under  consideration requiring
more  than sixty days  would  be  eliminated (unless the  time requirement
stated in the objective is changed).

Cost
     The  need   to  apply  this  criterion  is   obvious   and   needs  no
explanation.

Legal Ramifications
     When considering  any method  in  a  remedial  approach  to a hazardous
waste  site,  Federal, State,   and  local  regulations must  be  investigated
and applied.  Again, the criterion is obvious.

     Once the various remedial approaches  and methods have been subjected
to  scrutiny  by the application  of  agreed upon criteria,  some means and
methods  will  undoubtedly be  eliminated  for application to  a  particular
site.    The  remaining  available  means  and  methods  may  then  undergo
whatever discussions are deemed necessary  to arrive at an  appropriate and
acceptable approach  for the required remedial operation.
                                  6-6

-------
                                SECTION 7
                     EVALUATION OF REMEDIAL ACTIONS
INTRODUCTION
      This section contains  the  results  of an evaluation of  the  remedial
action alternatives potentially available  for removing  the TCDD waste  and
associated  contaminated   material   at  Denny  Farm   Site   1  from   the
environment.   In  accordance with the  Resource  Conservation and  Recovery
Act (RCRA), 40 CFR 260,  there  are several general means for  dealing with
hazardous waste:  disposal,  storage,  and treatment.   A number of methods
are  possible  in  each of  these   categories,  and  the method  chosen  for
dealing  with  any  particular   uncontrolled  hazardous  waste   site   is
dependent on  site-specific conditions  and the objectives of  the  planners
involved.  The objective of  the  project, as directed by the EPA,  was  the
development of a remedial  action  plan, in  conjunction with  an engineering
assessment of Denny Farm Site  1,  to minimize and/or  eliminate the impact
to the public and the environment from the  TCDD-contaminated  waste at  the
site.
      During  the course  of this  study, the available methods  for meeting
this objective were  first  evaluated in relation  to the environmental  and
demographic characteristics  of Denny Farm Site 1 and  the characteristics
of the waste  material buried in  the trench.  Further  evaluation  criteria
were applied  to various  methods depending on  their compatibility  with  the
site  and waste  characteristics.    These  criteria  included  cost,  risk,
time, proven  technology, and legal  ramifications.
      Table 7-1  presents  a summary of  the  alternative  remedial  action
methods,  along with  the  various  selection  criteria  (generic   and  site
specific) that  were  investigated for  each  method.    Evaluation  continued
until a  criterion indicated that the method  in question  should  not  be
further  considered.     The  asterisks  on   the  table  indicate  that  the
particular  criterion was  considered,  but  in  no way do  the  asterisks
indicate whether that investigation  was  carried  out  to completion.  Also,
no weight has been assigned to  the  asterisks with respect  to  positive or
negative impact on the particular remedial  method.

                                  7-1

-------
                                     TABLE  7-1
                  SUMMARY  OF ALTERNATIVE  REMEDIAL  ACTION  METHODS
                                          EVALUATION CRITERIA
      METHOD
 Site    Waste   Proven
Charac. Charac.   Tech.  Cost  Risk  Time  Legal  Other
Disposal
As is *
Monitoring wells *
Designated facilities
Deep well injection
In-situ containment *

* *
* *
* * * *
* * * *
* * *
Treatment
U.V. photolysis
Solidification (Chemical)
Biological treatment
Incineration—land
Incineration—ocean
Encapsulation
Carbon
Solidification
  (Physical)
           *
           *
           *
*
*
                    *
                    *
Storage
Designated facilities
On-site
^Indicates that the particular criterion was considered, but in no way does it
me.in that investigation was carried out to completion.
                                       7-2

-------
Definitions
      The following definitions are quoted from 40 CFR 260 (l).
      "Disposal"  means  the   discharge,   deposit,   injection,   dumping,
spilling, leaking, or placing  of any  solid waste  or  hazardous waste into
or on  any  land or water so that such solid  waste or hazardous  waste  or
any constituent thereof may enter  the  environment  or be  emitted  into the
air or discharged into any waters,  including groundwaters.
      "Storage" means  the holding of  hazardous  waste  for a  temporary
period, at the end of which the hazardous  waste  is treated, disposed of,
or stored elsewhere.
      "Treatment"  means  any  method,   technique,   or process,  including
neutralization, designed to change the  physical,  chemical,  or  biological
character or composition of any hazardous  waste  so as to neutralize such
waste, or so as to  recover  energy  or  material resources  from  the waste,
or so as to render  such waste  non-hazardous,  or  less hazardous;  safer to
transport, store, or  dispose  of;  or amenable  for  recovery, amenable for
storage, or reduced in volume.

Required Information
      The  complexities  of any given   site are  such that  site-specific
remedial actions must be developed.   First of all,  basic  information is
required to characterize the  site  with  respect to existing and  potential
hazards both to workers and the public.
      Identification of the wastes present, whether  from records, actual
chemical analysis,  or  investigation will provide  some insight as to the
options available.  The  waste at Denny  Farm  Site 1  has  been  identified
through  a  combination  of   investigation  and   chemical   analysis  as
TCDD-contaminated waste from a hexachlorophene-manufacturing process (see
Appendix A).   The quantity of waste within the disposal  trench  has been
estimated   at   approximately   150   drums   without   an   established
concentration.
      In determining the existing  and  potential hazards,  it is  essential
to have information on the toxicological  effects  on  human beings, flora,
and fauna, in  addition  to  information  on  the environmental fate of the
wastes involved.  TCDD has a  high  acute toxicity, is mutagenic,  and has
been considered to  be very persistent  and to bioaccumulate  in  animals.
                                  7-3

-------
The  mobility  of  a compound  in  the  environment  is  determined  by  the
physical and chemical characteristics of the compound  in question as well
as those of the environment.
      The  hydrology  and geology  of  the  area in  which an  uncontrolled
hazardous  waste  site  is  located may  either  help  or  hinder  remedial
actions.    The  intricate  relationship  of  the  two  must  be  carefully
scrutinized to determine the existence or probability of migration of the
contaminant off site.
      Aurora,  Missouri,  is  located  in  an  area   known for  its  karat
geology, which  is  characterized by  solution cavities  and the free mixing
of surface  and  groundwater.   Additionally,  the  soils  in the area consist
of clay lenses and cherty  soils  with as much  as  a  30%  gravel  content.
Therefore,  it  is highly probable  that  the  retention of liquids  in the
soil matrix is  quite low.
      Indirect  geophysical methods have been used to define the limits of
the  disposal trench at Denny Farm Site 1.  These tests have confirmed the
shape of the trench and  its approximate depth  and  have  indicated that
lateral migration  beyond the  trench walls has not occurred.  The vertical
migration  of  the chemical waste and/or  leachate has  not been determined
to date.   The  negative results obtained  from  the borings  and indirect
geophysical measurements   should  not  be   construed  to  indicate  that
vertical migration has  not  occurred.

REMEDIAL APPROACH
      The  remedial approach  initially entails a review of available  means
and  those  methods  applicable  to  each  means  that  have   a   potential
application to  the  uncontrolled  hazardous  waste  si,.?   in   question.
Consideration  of off-site  versus  on-site methods and existing versus new
facilities must be taken into account during the evaluation of  the  means
and  methods (Figure  7-1).
      This section reviews  the methods  evaluated and  provides the  reasons
for  eliminating those which  are  not  appropriate for Denny  Farm Site  1.
Those   methods  which  were  singled  out  for  more  in-depth review are
discussed  in the next section.
                                   7-4

-------
Ul
f^
Y

I


LEAVE IN PLACE
|_


^


REMOVE WASTE MATERIAL ^

i

NO [-- RISKS


'

t
I _.
IMMOBILIZE ft °N
STABILIZE IN SITU
1
1
— ^

"^^
1 YES
|
Y
SITE ALTERNATIVI
t
STORAGE |

r Y
r LONG-TERM |SHORT-1
ENVIRONMENTAL
MONITORING

t t
FEASIBLE? |-
f
YES |
r-[ CHEMICAL H 	 F

-{BIOLOGICAL ~* ' TREAT
-{ PHYSICAL hJ |
t

•^ FEASI
1

MENT

BLE? /
/
jH YES HH NO 	 '
1
ULTIMATE DISPOSAL
ON-SITE FEASIBLE
virc .•<- ,1 ,.w MO

/+
•\S

Y» FINALIZE &
^^
^ IMPLEMENT PLAN ^


[--- RISKS

1


r

ES p»- OFF-SITE ALTERNATIVES
Y


STORAGE |

Y
PERM LONG-TERM |
V



t
SHORT-TERM |
t

a r FEASIBLE? [-3,
Y Y
WO h YES |

1
T
NO J-J
i
/ TREATMENT)—
*~\ UMtMIUAL |


/ *-| BIOLOGICAL |
/


/ \**\ PHYSICAL
CCACIRI ft 1 —
rtAolDLCf l —
T
H YES [— H NO
Y
ULTIMATE DISPOSAL
OFF-SITE FEASIBLE






h



H



>
^B

STORAGE



                            Figure  7-1.   Evaluation of Alternatives for Remedial Action

-------
Disposal
      Disposal may be achieved by any number of methods;  however,  in all
cases,  the  potential release  of  the waste  to the  environment must  be
considered.

A.  Uncontrolled Disposal
      The two  possibilities considered  included  (1) no  action and  (2)
leaving  the  waste  buried  but  installing  monitoring  wells.    Use  of
monitoring wells to  identify off-site migration would be  contingent upon
a  complete  geohydrological investigation  of the  area  to  determine  the
proper  siting of  these wells.    Use  of  this  approach  would also  be
contingent upon  the  fact that the  wells were  indeed properly  sited and
could detect any off-site migration of contaminants.
      These two options  offer  no protection  to  the environment  or  to the
population at risk and at best offer an early warning system comprised of
monitoring wells.  Since this  approach  is  not  in  line with the objective
as set  forth by the EPA, this method has been eliminated.

B.  Controlled Disposal
      Controlled disposal is carried out in designated federal, state, or
private   facilities   which  meet   a  minimum   requirement   of  primary
containment.    This   containment  may  consist  of  one  or more  of  the
following:     synthetic  liners,   grouts,   slurry  walls,   or  natural
soils.  The facilities operate under the RCRA guidelines.
      The majority of commercially designated  facilites  have  refused to
accept  the waste either  because of  the  facility  design  or the public and
political   sensitivities  associated  with  receiving  TCCD-contaminated
waste.   Although several facilities did agree  to consider accepting the
waste,  this avenue is not currently being pursued  (Table  7-2).
      Det;p  well  injection  is  a  controlled  disposal  method  currently
employed  at  various  locations throughout  the  continental United States.
It must be emphasized that  the geohydrological status of  the area must be
sufficiently determined  prior  to  the use of this method.  Although this
method  releases  hazardous  waste to  the  environment, it  does  so  at such
depths  and  locations that  these wastes are not  expected to contaminate
groundwater resources utilized by the public.
                                  7-6

-------
                                            TABLE 7-2
                               COMMERCIAL STORAGE/DISPOSAL FACILITIES
Company and Address
Contact
                                                      Comments
Newcn Chemical Waste System
of Ohio
5092 Aber Road
Williamburg, Ohio
Mjtch McGee,
Tech. Rep.
(513) 793-3090
Landfill can handle dioxm-contaminated waste.
Will not dispose of liquids or sludge  (Minimum
flashpoint of 150°).  Ohio EPA approves
disposal on case-by-case basis.
New Chemical Waste System, Inc.
4526 Royal Avenue
Niagara Falls, New York

Waste Management of Alabama,
  Inc.
P.O. Box 1200
Livingston, Alabama
(716) 285-6929
(716) 731-3281
Ed Brashier
(205) 652-9531
Will handle dioxin  (see above).
proves disposal.
New Yoi k ap-
AIthough the  facility design  is  such  that
diox in-contaminated waste  could  be  taken,
political and public relation  aspects are
deterrents to acceptance
SCA Chemical Services, Inc.
1500 Ralmer Road
Model City, New York 14107

Wes-Con,  Inc.
P.O. Box  564
Twin Falls, Idado

Chem-Nuclear Systems,  Inc.
P.O. Box  1269
Portland, Oregon 97205

Casmalia  Disposal
539 Ysidso Road
P.O. Box  5275
Snnta Barbara, California
  93108
(716) 754-8231
(208) 834-2275
Sandy Davis
(503) 223-1912
Jim McBnde
(805) 969-4703
Does not handle  diox in-cont ammat ed  waste.
Will not handle  dioxin.
Will not handle  dioxin  wastes.
Will  handle  dioxin-contam mated  waste.   State
has not  approved  out-of-state  shipments  of
d i ox i n.
Nurleni Engineering Company
9200 Shelbyville Road
Louisville, Kentucky 40207
(Site  is  located in Realty,
  Npvada)

Knllms (Tnvi i onment al Sei vices,
  Inc.
21)27 Battleground Road
View Paik, Texas 77536

Hi owning FPIiis Industries,
  Inc. (BFI)
1020 llolcomhe Road
Houston, Texas 77030

Kamm Industrial fnviionmental
')PI V ir-f!!J
Wirhitn, Kansas 67201
Vicki L ynn
(502) 426-7160
Rolen  Cains
(713)  479-6001
 (713)  790-1611
State  approval  for acceptance of dioxm-con-
taminated material is  not  forthcoming because
of  political  ramifications.   Therefore,  the
facility will not  accept  the waste.
Will  not  handle  dioxin or  dioxin-cnnt ami narpd
wastes.
Does  not  handle  dioxm-contaminated waste.
                     Does not  dispose of diox in-contaminated materials;
                     however,  it  has experience in transportation nf
                     materials.
                                                   7-7

-------
      Although deep  well  injection  is  widely  practiced,  its  use  for
disposing of such a  toxic  material  as TCDD  is  questionable.    Currently
there are no facilities specifically  permitted for handling dioxins.   As
a result, this method  cannot  be considered  for  the  waste at Denny  Farm
Site 1.
      Controlled disposal  by  in-situ containment  of waste must  prevent
the waste or any  constituent   thereof  from  entering  the  groundwater,
surface water, and  air (2,3).   Such a  concept  involves  surface  runoff
control, capping or  surface sealing,  and impermeable barriers.   Surface
runoff control may be implemented via proper engineering design of dikes,
berms, ditches,  channels,  culverts,  surface  stabilization,   subsurface
interceptor drains and/or  any combination  of  the above.   This  control
seeks to minimize  surface  infiltration  into  the  disposal   trench  by
diverting water away from the  trench.
      Capping  and  sealing of   the  disposal  trench  surface  eliminate
airborne contamination and minimize  infiltration  caused  by precipitation
(2).  Proper grading also enhances surface  runoff.   This  seal  and/or cap
may consist of any one or  combination of the following:   synthetic liner
material, fly  ash,  oils,  soil-cement,  lime stabilized  soil,  bituminous
concrete and asphalt/tar materials.
      Impermeable barriers constructed  of  bentonite,  slurry,  cement  or
chemical grouts,  or  sheet  piling can be installed vertically  to  prevent
off-site migration of leachate and contaminated groundwater and to divert
non-contaminated  groundwater  around  or  away  from the disposal  trench.
Construction involves drilling,  boring,   pressure  injection,  pile  driving
and excavation.  These methods  are applied to those  sites which  have an
impermeable layer whether  it  be  low  porosity  soils  such  as  clay  or
continuous bedrock.
      In-situ containment was not  considered feasible  for the  following
reasons:

         o  Lack of  data  on  the subsurface condition  below the  trench
            floor, as  well as  the  possibility  for  disturbance  of  the
            geological structure and  stability  of the bedrock  below the
            trench.     Concerns   for  fractures,  piping,  and  increasing
            contaminant migration have been raised.
                                  7-8

-------
         o  The quantity and type of sealant  needed  to isolate  the  trench
            was deemed highly speculative  because of the  karst  conditions
            and  the  effects  of  the  organic wastes may  have  on  the
            sealants.   Although it is realized that  sealant  selection is
            contingent upon waste identification, that identification has
            not been completed to date.

Therefore,  in-situ  containment  is  not considered  further  due  to  time
limits and problems with the feasibility of applying the  technology.

Treatment
      Although  removal  of  the  material  from  the  enviroment  is  the
short-term objective of the project, treatment must  be considered at some
time so that indefinite storage is not required.   The following treatment
technologies have been  investigated  in relation the  their  applicability
to Denny Farm Site 1.

A.  Chemical Treatment
      Ultraviolet photolysis of TCDD is a potentially promising method of
treatment.     Three  conditions  are   required   for  significant   TCDD
breakdown:  dissolution  in a light-transmitting (307  nanometers)  liquid
film, the presence  of an organic hydrogen donor such as a  solvent,  and
irradiation with ultraviolet light (4,5).
      This  process  is  currently  under  development  by  three  firms:
Syntex  Agribusiness,  Inc.,  Westgate Research,  and  Vertac,  Inc.    The
Syntex process has  received  U.S.  EPA approval as a  treatment  method for
dioxin  and  is  presently undergoing  testing  at the  Syntex facility in
Verona,  Missouri (6,7,8,9).   TCDD  is not  totally  eliminated by  this
process.  Residual  concentrations approximating  500,000  ppt,  in addition
to other waste products, are generated by this process.
      Vertac,   Inc., of Jacksonville, Arkansas,  has developed  a process
for treating and/or destroying dioxin.  Vertac,  Inc., has indicated that
Vertac has  filed a patent  application  for the  process, which  has been
successfully demonstrated Co the State of Arkansas and the EPA (10).
Commercial availability is anticipated by Vertac.
                                  7-9

-------
      A  treatment   process  that   uses  ultraviolet   irradiation   in
conjunction with ozonization has been developed by Westgate  Research (11)
for the  detoxification  of  chlorinated  organics.    Westgate furnishes  a
portable treatment  system,  thus enabling wastes  to be  treated on  site.
For treatment in the Westgate process, the liquid waste does not  have to
be clear;  it  may contain  some  color or  sediment.    Further,  it  may be
feasible to  extract  the  dioxin from  contaminated sludge  waste  with  a
solvent such as methanol prior to treatment.   As with the  Syntex process,
the Westgate process  operates at low temperature and pressure; thus the
potential for release to the environment is minimized.
      The  Westgate  process   is    presently   being  tested   for   the
decontamination of PCB-containing oils for the General Electric Resistors
facility at Hudson Falls, New York.  Tests to  date  have been successful,
with  99   percent   removal   achieved.     The   system was   also   tested
successfully for the detoxification of bottom sediments  contaminated with
kepone  in  Hopewell, Virginia.   These tests  were done  for  an EPA  task
force investigating alternative  mitigative measures (12).
      Ultraviolet photolysis  appears to  be  a  feasible,  environmentally
sound, and safe means of treating the TCDD content of at  least  the liquid
portion  of the  waste at  the  Denny Farm Site  1.    The  possibility of
treating the  sludges  and soils  after  extraction is  not  viable  at  this
time.    Although  photolysis of   chlorodioxins  has  appeared in  research
articles and is  known within  the scientific  community,  its  acceptance as
                    i   \
a  proven technology is  limited.   As previously mentioned,   there  are at
least  three  commercial  firms developing  this  treatment  method.   In all
cases  the  methods   are  classified  as   proprietary  and  therefore  not
available  to  the  authors  of  this  report.   As  a  result,   treatment
efficiencies,  byproducts,  and   disposal   and/or  storage  of  these  by-
products could not be evaluated  in this  report.   However,  this is not to
preclude future considerations of this alternative.
      The  chemical  solidification  of waste  involves  a  chemical reaction
between  the waste and the  solidifying  agent.  The proper selection  of  a
solidification  agent  is dependent upon  a thorough chemical analysis of
the waste  in  question.   In each  case,  one must  consider  short-term and
                                  7-10

-------
long-terra stability  of the matrix  and the  propensity towards  leaching
into the environment.   Cement-based  solidification techniques cannot  be
used with  particular organic matter  because of  interference with  set,
cure, and permanence of the cement-waste matrix.   Lime-based  applications
cannot be  considered because the  porosity of  the  final material  would
inevitably allow the TCDD-contaminated material  to leach.   Thermoplastics
solidification was  also considered,  but  available literature  indicates
that  this  procedure  should  not   be  used  for  solidifying  materials
containing organic  solvents  or  wastes which  may break down  when  heated
(13).  Organic polymer techniques,  although applicable to a broader range
of  compounds,  involve  the  mixing  of waste material  with  the  organics
followed by  a  chemical reaction between  the various  resins,  catalysts,
and waste.  The waste  must  be  properly dried prior to the  process since
the  resultant  solidified  matrix has  a tendency  to weep  or  release  any
uncombined water.   This water is often laden with pollutants.
      Biological   treatment  through  commercially   available   mutant
microorganisms  is  an   established  and  proven  technology  for  certain
applications—food  processing,  waste  treatment,  and  limited  subsurface
hydrocarbon spills  (14).    In  each case  the basic  requirement for  the
existence of the microorganism in the environment has been predetermined.
The  commercially  available  organism mixture known  as Phenobac  has  been
demonstrated   to   effectively   biodegrade  2,3,5,-trichlorophenol   and
1,2,4,5-tetrachlorobenzene, which are  known to  be present in  the  wastes
at Denny Farm Site 1.  However, the other  components  of  the  waste  at the
site may be toxic to Phenobac.   In  addition, the demonstrated destruction
efficiencies   of    100%    for   2,3,5-trichlorophenol    and   80%   for
1,2,4,5-tetrachlorobenzene  were based  on  experiments in  a  controlled
environment in concrete pits (15).  Data  indicating positive results and
reinforcing a proven technology for application to uncontrolled hazardous
waste sites have  not been produced.    The  material  at Denny  Farm  Site 1
cannot be  left  in the  ground  to await the  development  of  a  mixture  of
organisms specific  to  the waste at this  site.   However,  testing  of the
microorganism for  applicability to the waste  is recommended  and  can  be
accomplished during removal and sampling the drums.
                                  7-11

-------
B.  Physical Treatment
      Physical  treatment  methods  are  also  available for  dealing  with
hazardous wastes.   Incineration  is a process in which organic  materials
are degraded  via the application  of controlled  heat.  This  degradation
occurs through  the  thermal oxidation of  the  organic  molecule.   Inorganic
constituents may not be affected.  The  proper method of incineration must
be  selected  based  upon  certain  considerations:     waste  components,
physical  characteristics,  residence time,  temperature requirements  and
destruction efficiencies (16).
      The TCDD-contaminated material at the Denny Farm Site 1  consists of
liquid waste,   tarry  still  bottoms, and  soil.    Incineration  of  dioxin
requires   a  temperature  of   2,300°F  to   2,600°F  and  a   residence
time of 5 seconds (16).
      Land-based  incineration   provides   the  feasibility  of  on-site
treatment  through   the  possible use  of  a mobile  unit  currently  under
construction for the  EPA  by  NB Associates of San Remon,  California,  and
was scheduled  for   completion  by August  1980.   Any  on-site  application
will be subject to initial testing and  permitting (17).
      A thorough investigation of  incineration facilities  throughout  the
United  States  reveals  that   none  are   willing  to  burn   dioxin and  the
associated contaminated materials at this time (2).   Currently,  there are
no permits issued for the specific purpose of incinerating dioxin and the
dioxin-contaminated  material.    Such  a  permitting  program, similiar in
scope to  the  PCB program,  would provide the  criteria  upon which private
industry  could  develop  facilities to  handle  the  incineration  as  a
land-based operation.   Although  a  modular  unit is  under  construction for
the EPA,  test burns have yet to be conducted.  The two byproducts of this
process,  scrubber residue and  ash,  must  be dealt with.   In summary,  the
lack  of  land-based  facilities  eliminates  this  particular  method  for
consideration this time.
      The only  documented burn of dioxin-contaminated material is that of
Herbicide Orange incinerated  in  the Pacific  Ocean west of Johnston Atoll
from July to  September  1977.   The  burns were performed on  board  the M/T
Vulcanus,  an  incinerator  ship chartered  by Ocean  Combustion  Services,
                                  7-12

-------
B.V. , of the Netherlands (19).   The  wastes  were burned in  two  identical
refractory-lined  incincerators  with  a  calculated  residence   time   of
approximately  1  second  at  a flame  temperature  between   2,372  °F  and
2,732 °  F  (2).   Results  of  EPA calculations from  the  test burns were
promising since they indicated a  minimum destruction efficiency  of 99.96%
(2).   However,  the destruction  efficiency  during  actual  incineration
could  not   be  determined  because  no  traceable  amounts  of  TCDD were
detected in the stack samples.
      The potential problems with incineration at  sea  are  based upon  the
fact that traces of TCDD and  related  compounds were  found  in incinerator
residues and within stack residues despite the undetectable levels in  the
stack emissions.   Also,  the  M/T Vulcanus incinerators are  not equipped
with scrubbers on  the  premise that many  of  the  materials   that  would be
pollutants if emitted from land-based incineration are greatly diluted by
the ocean where they are natural  constituents.
      Ocean-based  incineration  costs  are  much  lower  than  land-based
operations—$80  to $90  per  metric   ton.   However,   transportation  and
storage costs must  be  added  to obtain the total costs, and  time must be
considered.  The  EPA has proposed the  possibility of employing  the  M/T
Vulcanus for  the  incineration of dioxin-contaminated herbicides  during
the  spring of  1981  (2).     This  is  an  option  for  the   liquid  phase
contaminants but not for the contaminated soils or other  debris.
      Encapsulation  is  the   process   by which  hazardous  wastes  are
physically   enclosed   by   a   synthetic   encasement   to    facilitate
environmentally  sound  transport, storage and disposal.    As a remedial
action, encapsulation may be used to seal particularly toxic or corrosive
hazardous wastes which have been removed  from disposal sites.
      Theoretically,  encapsulation  appears  to  be  a  viable answer  for
dealing with the  waste once it  has  been excavated and removed from  the
disposal trench.  However, the major disadvantage is that the process  has
yet to  be  applied  on  a  commercial  scale under  actual field conditions.
Additionally, the  binding resins  required for this process are  expensive
and  the process   requires  large  expenditures  for  energy  and  capital
equipment  costs.    For  these  reasons,  this  approach  is  not  being
considered further.
                                  7-13

-------
      Carbon treatment utilizes the physical phenomena of absorption  and
adsorption.    This  technology was  developed for  water  purification  and
chemical processes, but recent applications have emerged for response  to
chemical spills in surface water  and  groundwater.   However, application
of carbon is dependent upon  the physical and chemical characteristics  of
the waste in question.  Carbon  treatment may  not be appropriate  for  the
viscous, tarry, still  bottoms at Denny Farm  Site 1.   The  waste at  the
site would  coat  the  carbon  material  and  reduce the efficiency of  the
system  to the  point  where it would not be  feasible  to  use.   In  theory,
this particular treatment would remove the  TCDD  from a  quantity  of  waste
and concentrate the  TCDD in  the  carbon.    Although  this  may  reduce  the
bulk volume of the waste  containing TCDD,   the TCDD component  must  still
be  dealt  with.   The  time  constraints  with  respect to  removal of  the
material from  the  ground  prohibit consideration of this approach to  the
waste  itself.   It  may be possible to use  it  to process wastewater  for
decontamination of  personnel and  equipment during the  handling of  the
contaminated material.
      Physical solidification involves a number of techniques designed to
seal  the  wastes  in  a  hard,  stable,  immobile  mass.    High  costs  are
associated with this  process, and a thorough  chemical  identification of
the  waste  is  necessary.    These waste-specific  processes  are  not
applicable to all liquid wastes and must be thoroughly  evaluated for each
waste.
      This   application   involves  physically  surrounding   the   waste
particles with a solidifying  agent.  Short-term fixation is  achievable in
some  cases;  however,  long-term  prelections   for  the   stability of  the
material must  be  made via  ageing and other  tests (20).   Consideration
must  also  be  given  to the  potential  future  release  of waste  material
before  this  method  is  chosen.    Common  methods  include  use  of  cement,
lime,   thermoplastics  or   organic  polymers;    self-cementation;   and
glassification.
      Solidification of a hazardous waste is primarily  used  to insure the
safe  handling and  transport of  the waste.    The  application  of  this
technology  for  some  hazardous   wastes   has   been  proven.     In   this
                                  7-14

-------
case, however,  there is  concern about  the interaction  of the  organic
content  of  the  waste  with  the  solidifying  agent(s).    Although  the
technology  has  been  in  existence  for  some  time,  its  application  to
hazardous  waste  is  a  recent  innovation  and   therefore  may  require
additional research (21).

Storage
      Storage involves the holding of the properly containerized material
over a period of time in such a manner as to remove the material from the
environment.  This method may have both on- and off-site applications.
      Operators of designated  storage/disposal facilities  were  contacted
initially  to  determine  their  storage  capabilities and  willingness   to
accept the TCDD-contaminated waste and soils.  Existing facilities  would
certainly  eliminate  the  need  for construction of an  on-site  structure,
thus saving time and decreasing capital investment.
      Naturally,  prerequisites to storage  at commercial  facilites  are
excavation, temporary storage,  and  transportation.   The  first  two  areas
are  dealt  with  in  Section  8,  while  transportation  via  commercial
permitted  carriers  would  have  to be investigated  beyond  the  limits of
this report.  The waste  and associated contaminated material would have
to  be  properly   containerized  in  Department  of  Transportation  (DOT)
approved  hazardous  waste drums.   In  addition  to federal regulations,
transporters would have to comply with applicable state regulations based
upon  the routes  of  transportation  chosen.    The commercial  facilities
which were contacted and  their  replies  are given  in Table  7-2.    The
replies obtained from the commercial facilities indicated that an on-site
      storage structure  would have  to  be  considered  in  the  conceptual
design stages of  the  remedial  approach  (Table  7-2).   Standard approaches
such as tanks, buildings,  etc., as well as innovative approaches, will be
reviewed.   At a minimum,  a viable  concept at  this  time  would  have to
accommodate the anticipated  volume  of waste material  to  be stored, have
structural integrity  consistent  with  the potential hazards  posed  by the
release of  the materials,  and meet the requirements of applicable  codes
and regulations.
                                  7-15

-------
SUMMARY OF POTENTIAL REMEDIAL ACTIONS
      Application of the  generic  selection criteria  (proven  technology,
time, cost, risk, legal constraints)  and site-specific criteria (site and
waste characteristics)  have eliminated a substantial  number of potential
remedial action methods.   Storage and treatment and/or a  combination of
both are the remaining  viable means,  and both of these require removal of
the waste and associated contaminated material from the disposal trench.
      A  logical  sequence  of  events  would   involve  excavation  of  the
material with  immediate  temporary storage  until such time as treatment,
disposal, or permanent storage  are  available.   Section 8  of  this  report
presents criteria for  the  excavation and storage  methods proposed for
Denny Farm Site 1.  These  two phases  are  prerequisite to  the  application
of  any treatment method.     The most promising  treatment   methods  are
chemical treatment  by  ultraviolet photolysis  and  physical treatment by
incineration.   These are  not  yet  available commercially and  require full
investigation at  some future date.
                                  7-16

-------
                       REFERENCES FOR SECTION 7
 1.   Federal Register, Volume 45, No. 98, 33073-33067.

 2.   Ecology  & Environment,Inc.  Remedial  Action for Denny  Farm Site 1
     Aurora, Missouri - A Working Paper.  Washington, D.C., June  1980.

 3.   Ecology  & Environment, Inc.   Technical  Study  and  Remedial Actions
     for  Denny Farm  Site  1, Aurora, Missouri.   Washington,  B.C., July
     1980.

 4.   Crosby,  D. G.  and  Wong,   A.  S. "Photodecomposition  of Chlorinated
     Dibenzo-p-Dioxins," in Science. Volume 173,  748-749,  1971.

 5.   Crosby, D. G.  and Wong A.  S.   "Environmental Degradation of  2,3,7,8-
     Tetrachlorodibenzo-p-dioxin   (TCDD),"   in   Science,   Volume   195,
     1337-1338, 1977.

 6.   Personal  communication with  Howard Beard,  Office of  Solid Waste,
     U.S.  EPA,  Washington,  D.C., June 12, 1980.   (202) 755-9205.

 7.   Inside  EPA,  Inside Washington Publishers,   Inc.,  Washington, D.C.,
     May  30,  1980.

 8.   Personal  communication with  Scott Ritchey,  Region  VII,  U.S.  EPA,
     Kansas City, Missouri,  June 13, 1980.  (816) 374-6534.

 9.   Personal  communication with Russ  Wyer,  Deputy Director  of Oil  and
     Specialty Materials,  U.S. EPA,  Washington, D.C.,  June  12, 1980.
     (202)  245-3048.

10.   Wilcox,  Jack,  TAIL, Region  IX, memo to  Jim Buchanan,  FITL,  Region
     VII,  June 12,  1980.

11.   Personal   communication   with  Jack  Zeff,   President,   Watergate
     Research, Inc., Santa Monica, California,  June  16,  1980.   (213)
     473-4541.

12.   Personal   communication  with   Charles   Terrel,  U.S.  EPA,   Aquatic
     Protection,  Washington, D.C.  (202)  472-3400.

13.   U.S.  EPA.   Survey  of Solidification/Stabilization  Technology   for
     Hazardous Industrial Wastes,    EPA-600,     2-79-056,    Cincinnati,
     Ohio,  1979.

14.   Personal   communication with   Michele  Telepchak,  Sybron/Biochemical
     Corporation  of  America,   Technical Data  Sheets,  Farmingham,  N.Y.
     1979-1980.

15.   Wilkinson, R.  R.,  Kelso,   G.  L. ,  and Hopkins,  F.  C.   State-of-the-
     Art  Report:   Pesticide Disposal Research.   EPA-600/2-7B-183,  August
     1978.
                                  7-17

-------
16.   U.S.  EPA.  Incineration in  Hazardous  Waste Management Publication.
     SW 141,  Office  of Solid  Waste  Management  Programs,  1975.

17.   Personal communication  with  E.   Martin,  U.S.  EPA  Oil  &  Special
     Materials  Control  Division,  Washington,  D.C.,  August   27,  1980.
     (202)  755-9203.

18.   Personal communication  with  Steven  Dorreler,  U.S.  EPA  Emergency
     Response Team,  Edison, New Jersey, June  25,  1980.

19.   Stevens, J. J., Grumpier,  E., and Shin, C.  C.   "Thermal  Destruction
     of Chemical  Waste,"  Presented  at 71st  annual  meeting  of  AICE,
     November 14,  1978.

20.   U.S.  EPA.   Survey  of  Solidification/Stabilization  Technology  for
     Hazardous Wastes.  EPA-600/2-79-056. Cincinnati, Ohio,  1979.

21.   Personal  communication  with  Robert  B.  Pojasek,  Ray  F.  Weston,
     Woburn,  Massachusetts,  June 1980.
                                  7-18

-------
                                SECTION 8

              PROPOSED REMEDIAL ACTION:  CONCEPTUAL DESIGN
      This section discusses  in  detail  the conceptual design recommended
for cleanup  of  the Denny Farm Site  1.   It  provides  the general  concept
for gaining  control  of  the  TCDD-contaminated  waste  and  presents  the
basis for Ecology  & Environment,  Inc.'s (E & E's) recommendations.   Each
component of the remedial action  is discussed  and  cost estimates  are made
for the elements.  Preliminary drawings are  provided  which  illustrate the
sequence of events.  Finally, the total cost and  time associated  with the
completion of the  components  of  the remedial action are  presented.
      E & E  has  concluded from the prior  studies  of  options for  gaining
control of the TCDD-contaminated  waste  that, in the short  term,  the  drums
of waste  and the  contaminated  soil  must be  removed from the  disposal
trench and placed  in temporary storage.  This  recommendation  is  supported
by:

         o  The human toxicity of TCDD.

         o  The confirmed presence of TCDD.

         o  Poor condition of the barrels  in the  trench.

         o  Geological and hydrological conditions of the  area  which
            contribute  to significant uncertainty  of  the integrity of the
            trench bottom and suggest the  possibility of vertical
            migration of  contaminants into the subsurface  formation  and
            groundwater.

         o  Risk of human exposure by leaving  material in  the trench is
            significantly higher  than removing.
                                   8-1

-------
      Both  the release  of  toxic  material  from  uncontrolled  hazardous
waste sites and the remedial actions taken to  deal with  them pose  certain
risks to the environment and to  the  public.   E & E performed  an analysis
of the risk of exposure in numerical terms for the public.   This analysis
compared  the   the  risk of  several  alternative remedial  actions  to  the
option of taking no action.
      A  detailed  discussion  of the  E &  E  risk  model  is  contained  in
Appendix B.  A review  of Table  B-l indicates  that a  combined  total  human
exposure of 121.6 occurs if  absolutely nothing else  is  done  to  the  Denny
Farm Site  1 other  than acknowledge  its existence.   The mere  presence  of
monitoring  wells  reduces  this  figure  to  53.7  exposures  (predicated  on
monitoring wells which will  intercept  any release of  contaminants).   The
importance  of  proper  well  location, if possible,  in a karst  geological
setting cannot be over emphasized.   A  further  reduction  in exposures, and
the  lowest value,  occurs  from  the  implementation   of  the  recommended
remedial  action  of excavation  and  on-site storage.    This value  is  48.3
exposures and  is primarily due  to  short-term worker  exposure.
      The  off-site  transportation of  the  waste to the  Verona,  Missouri,
facility  offers  a  slightly  increased  element of  risk  (48.7  exposures)
because  the  population at  risk  increases  with  the  inclusion  of  the
transportation route  and  the  population  in  Verona,  as  well  as  the
production  employees.   This analysis  lends  credence  to the  decision for
undertaking the recommended  remedial action.
      The  temporary  storage  on  site  provides the flexibility of utilizing
treatment  technologies  in   the  future  such  as  ultraviolet  photolysis.
      The remedial action consists  of  four major components:
         1.  Temporary  storage  facility
        2.  Site setup and mobilization
        3.  Excavation
        4.  Site closure
      As  presented,  each component  is  a  product of  a refinement  process
in  which engineering  and  cost  estimating techniques were  applied  in an
effort  to  obtain the most  practical  and cost-effective option.  The costs
were developed for  each individual  component  based  on data  obtained from
a  limited  number   of   potential  suppliers  and  contractors,  estimating
manuals,  price  lists,  and  knowledge  of  local  costs  for   labor  and
                                   8-2

-------
materials  (1)  (See  also List  of Contacts  following  References).  Where
appropriate,  these  base  costs were  adjusted  to  reflect  the hazardous
nature of  the project  by  adding a  premium  to  the   costs  for labor  and
equipment usage.
      The design concept  will  be discussed  in  the  sequence in which  the
individual components must be  executed.   In many cases  the  component  is a
set of engineering  procedures  rather than an actual  design  element,  thus
making the  remedial action  an integrated  process.   Each component  will
have  criteria defined,  elements  identified, and cost  and   activity  time
estimated.

COMPONENT 1.  TEMPORARY STORAGE  FACILITY
      To  establish  control  over  the  waste  materials  and  to  provide
acceptable  storage  until  final disposition is determined,  a  temporary
storage structure must  be constructed.  On-site  storage has  been selected
because  there are  no  immediate  facilities nationally  that  will  handle
dioxin-contaminated  wastes.     Thus,   the  risks  of   exposure   through
transport  to a  distant  storage  facility  cannot  be  considered  at  this
time.  On-site  storage is the most  reasonable  approach since  it  limits
the handling  and  transportation to  a minimum until the  final  disposition
of the waste  is determined.
      The  storage  facility  is comprised  of two units:    foundation  and
structure.

Foundation
      Preliminary geotechnical investigations  of  the area  indicate  that
sinkhole development could threaten  the  stability  of  a storage structure.
Two   alternative   foundations   were  considered:     a   structural   slab
constructed  on  bedrock  and  a  structural  slab  constructed  on  grade
supported  by  a  system of grade  beams  supported by caissons which extend
into  the  bedrock.    For  estimating  purposes,  the   structural   slab  on
bedrock and  the  caisson-grade  beam  system were designed to  span a sink-
hole 40 feet  in  diameter.   The caisson-grade beam alternative was chosen
because it was more economical.  The detailed design  effort would include
a geotechnical  study  for  purposes of selecting  a site where risk of sink-
hole  formation  is low and determining  the placement  of the  caissons.

                                  8-3

-------
      For  considering  foundation  requirements,  the  storage   facility
should be located near the disposal trench on the Denny Farm.  This  would
minimize  the  risks  associated  with  transportation.   The  cost  for  a
foundation is  somewhat proportional  to  the  amount  of  overburden on  the
bedrock; therefore,  an area with minimal  overburden should be  selected.
For this analysis, the assumption was made that  a  location with only 12
feet  of overburden  above  the  bedrock  would  be  used.     The   proposed
location should not be subject to flooding.

Structure
      Two  structural  systems  were  considered:    a  reinforced  concrete
system  and  a steel system.  The  steel  system is  similar  to the  systems
employed for standpipe water storage  tanks.  Both  systems  can be  designed
to resist natural  phenomena, have  an  expected  life  in  excess of 20 years,
and are resistant  to fire  and unauthorized  entry.
      However,  the  steel  plate   structure   offers   several   additional
advantages  over  and above  the  reinforced  concrete  systems.    First,  the
structure  itself   is  a containment  vessel, thereby  providing secondary
protection  against contaminant  escape.     Secondly,  since this   type  of
structure is a  standard  commercial item,  it can be  procured,  fabricated,
and  erected  quickly  and  economically.     Thirdly,   the   structure  can
withstand high wind  loads,  extremes in  temperature, and certain  types of
stress  better  than  a  reinforced  concrete  structure.     Finally,  the
structure has  a salvage  value  either as  a containment  structure  or  as
scrap metal.  The  size of  the structure was determined  by  the  following:

      o  Anticipated maximum storage  of 5,000  drums.
      o  Access for inspection and  removal  of  individual drums.
      o  Ventilation.

A  commercially  available  unit  meeting  estimated  volume   and dimensional
requirements was selected.
      The major elements  of the temporary  storage  component  are:

      o   Select  a  number of  potential   sites  on the   Denny Farm  for
         subsurface    investigation.      Perform    detail  geotechnical

                                   8-4

-------
            investigations  to  determine  the  depth  to  bedrock  and  the
            competency  of the  rock and  to  evaluate  the  factors  which
            would indicate potential sinkhole  development.

         o  Prepare the necessary engineering  designs  for  the  foundations
            and the structure.

         o  Prepare  permit  applications  as  required—state  and  federal
            regulations.

         o  Prepare site  for storage facility.

         o  Construct storage  facility.

      The total estimated cost  for  completion of  Component 1  is $360,000.
The  detailed  cost  estimate is  presented  in Table  E-l  of  Appendix  E.
Figure  8-1  provides  a  conceptual  layout  of  the  foundation  and  section
view of the storage facility.
      The anticipated construction  time  for this  component is  four months
from  execution  of  the  geotechnical investigation  to  completion of  the
facility. The time  requirement for obtaining  permits  was  not  included in
this time projection.

COMPONENT 2.  SITE  SETUP  AND MOBILIZATION
      Site  setup and  mobilization  include  preparing the  site  for  the
excavation  and  providing the  necessary  support facilities.  The  major
elements of this  component  are:

         o  Clear additional  land  to provide space  for support facilities
            and  for the excavation  area.

         o  Move on  site  and  install  utility systems;  provide trailers
            for  the command post,  equipment storage,  and crew facilities

         o  Establish the necessary sanitary and  water supply systems.

                                   8-5

-------
CO
 I
                                                                   CAISSON
                                         PLAN VIEW OF FOUNDATION
                                                             TANK BOTTOM
                                                      •.••.'V°'.-'-'.'  SAND

                                                             CONCRETE SLAB
                                             *	^
                                              PRIMARY
                                              GRADE
                                               BEAM
                                                               SECONDARY
                                                               GRADE BEAM
                                                             • CAISSON
                                                                 BEDROCK
                                       DETAIL OF GRADE BEAM
                                         AND CAISSON (A-A)
                                                                                                                      GRADE
                                                                                             SECTIONAL VIEW
                                                                                                nrxx
                                                                                                             H = 58.78"

                                                                                      t
                                                                                                ..-.
                                                                                               K i x x Y it >uOi 1 1 ij.
                                                                                n
      PLAN VIEW
PROPOSED DRUM LAYOUT
                                                 Figure 8-1.   Temporary  Storage  Facility

-------
         o  Procure  and  provide   on  site  all   personnel  protection
            equipment.

         o  Conduct  a  worker training  session  once  all  systems  are  in
            place and ready for use.

         o  Expand the  fenced area to provide sufficient area for
            equipment operation and material handling.

         o  Set up the  drum and personnel decontamination facilities,
            install  air  supply  systems   for   the  totally  encapsulated
            suits; and  install construction lighting  systems.

         o  Construct runoff control  system.

         o  Remove the existing  impervious  cap  and  place  the canvas  tarp
            system in place.

      The total  cost for Component 2 is  $358,670,  which  includes  moving
equipment  onto  the  site,  mobilizing  labor  and  materials,   and  doing
initial  site  preparation  prior  to commencing   the  excavation.     In
addition, all  personnel  protective equipment are  procured   and  personnel
properly  trained  for its use.   Detailed cost  estimates  are provided  in
Table E-2 of Appendix  E.   Figure 8-2 shows a plan  view of  this  proposed
site  setup.   Component  2  will  require  about  10  days  and  will  run
concurrently with  portions of  Component  1 so  that  the excavation  phase
can start at completion of  Component  1.

COMPONENT 3.  FXCAVATTON
      Component   3  deals   specifically   with   the   excavation  of   a
predetermined  volume of  soil  (for purposes  of cost  estimates)  and  the
removal  of  the  drums and their  contents.  Since  the extent of  vertical
migration has  not  been determined, this  component  has been divided  into
two subcomponents.   Component 3A  involves  excavation of  the trench  area
as defined  by  the  previous  E & E geotechnical  study—perimeter  150 feet,
                                  8-7

-------
                            SHOWER TRAILER
                                                         PERSONNEL
                                                      DECONTAMINATION
                                                          STATION
«_ LOADING RAMP
                                                                                  (w) i—BULK DECON
                                                                                  ^T^ STORAGE
                             STORAGE /"*^1
                             TRAILER /   /
CO
 I
CD
                                                                                                  TARP
                            TO AIR
                         COMPRESSOR
                                                                                                   CAP STORAGE
                                                                                                  COMMAND POST
                                                    Figure  P-2.   Plan  View of Site  Setup

-------
depth 8 feet, total  surface  area  1,000  square feet, and 1:1 side  slopes.
An assumption is made  that  contamination has not migrated  laterally  from
the  trench.   Component 3B  involves excavation  of  additional  volumes  of
contaminated  soil.   Soil volume  is based  upon  contamination  reaching  4
feet below  the  anticipated  trench floor, 8  feet  below grade for  a  total
of 12 feet below grade.   This  volume is calculated for the  entire length
of  the  trench  with additional  material  for  sides lopes  based  upon  1:1
slopes.   Since  volumes have been used,  more excavation may occur  in  one
area of the  trench  than others and  not  affect  cost  estimates.
      The proposed  excavation  and storage plan which  formed the  basis  of
the  cost  estimates  for Component  3A are:

         o   Removal  of  the  contents of  the  drums and the drums  from the
             trench.

         o   Removal  of  contaminated  soil  to  an  acceptable  limit  to
             prevent  any residual  material  from being  transported  into the
             groundwater by  precipitation/percolation.

         o   Minimizing excavation   time  to  reduce   potential   off-site
             environmental contamination.

         o   Removal  of   the  TCDD-contaminated   waste  from  the  trench
             without  spreading  contaminants  into  presently uncontaminated
             material.

         o   Utilizing  excavation  methods which present the lowest risk of
             rupturing  a drum.

         o   Decontaminating containers  and personnel  on  exit   from  the
             s ite.

         o   Isolating  the workmen  and  all  other  personnel  on site  from
             the  contaminated material.   The level  of  protection  provided
                                   8-9

-------
            would be dependent on  the  task being performed,  i.e.,  those
            people who are in direct contact with the waste will have the
            highest level of protection.

         o  Reducing the  physical  stress on  the  workers  created  by the
            protective gear and the environment (rotating  shifts).

         o  Using  dust  control  to  minimize  the  spread  of   loosened
            contaminated soil by wind action.

         o  Using runoff control to minimize  the  spread of contamination
            by a precipitation event and subsequent  surface runoff.

         o  Using  weather  protection   for   the   open  trench  to  keep
            precipitation  from  entering the  trench  and transporting the
            material into  the groundwater.

Excavation
      Test  boring  and  soil analysis during  geophysical surveys  indicate
no lateral migration of waste outside the limits of  the  trench  as defined
by ground penetrating radar and metal detectors (2).
      The objectives  of 3A  are to  uncover  the drums without  rupturing
them and to remove  the  contents  of the  original drums while removing  the
minimum amount of soil.  The  cost  estimate  is based on  utilizing a small
tractor-mounted  backhoe,  in conjunction with hand  labor,  to  place  soil
into 55-gallon drums.  The volume  of  soil  to be removed during  3A  of  the
excavation  process  should  be viewed as  an upper  limit.   It is  anticipated
that the  1:1  side slopes  used  for the  purpose of  the estimate could  be
reduced.  The soil  contains chert  and clay  and  should  provide  a safe side
slope  at  a  steeper  angle,   thereby  reducing  the  volume   of  the   3A
excavation.    A  portion of  the excavated  soil could be  stored  on  the
floor and be removed as  part of  the 3B  excavation.

Drum Decontamination
      The exterior  of all containers leaving the  trench  area  would  have
to be  thoroughly decontaminated.  This  would be accomplished  by washing
the drums with  decontamination solution to  remove any  contaminated  soil
                                  8-10

-------
particles or liquid. To  facilitate  drum decontamination, roller  or  idler
bar conveyors would be used.  An assembly  line  approach  for  drum
decontamination would then  be  possible.   A small ramp would  be  excavated
at the end of this conveyor  to allow  the  trucks  to  back  up  level with the
conveyor.   Drums will  be moved  by  use  of  hand  trucks.   A  collection
trough and pumping system would be  placed  beneath  the  conveyor  to collect
the water  used  to wash  the  drums.   Once  the  trough  becomes   full,  the
pumping  system  would  drain  the trough  to a  bulk  storage  tank.    At  this
time,  it  is  not known if  the  water used  to  decontaminate  the  drums and
personnel will  contain levels  of contamination  above the allowable limits
for discharge.   All  decontamination  water  could be sampled  and analyzed
from the bulk storage tank.
      If   the   decontamination   water   does   not   contain  levels   of
contamination  above  the  allowable  limit,  water would  be  discharged  or
reused.   Should  contamination be  found,  the  water would  be   placed  in
storage.  The volume and  cost  estimates  are  based  on the above  procedure.

Waste and Drum  Removal
      After  nine  years it  is reasonable  to assume  the drums in the trench
are corroded, and this has  been partially confirmed.  It has been assumed
that it  is  unsafe to lift any full  or  partially full drums  directly out
of the trench.  The  procedure  developed  for removal of the  waste  from the
trench consists of  pumping  the contents  from the original  drum into the
55-gallon  closed  drums   located   on  the   side   of   the   trench.    An
air-operated positive  displacement  pumping system  would  be  utilized
because  it will help  prevent the  possibility of an  explosion and has the
ability  to  pump viscous  liquids.   Once  the  liquid  contents  are  removed,
the old  drum would be placed into  an overpack (85-gallon drum) and lifted
out of  the  trench.   A crane would  be used to lift  all  material  from the
trench.
      The  chemical  properties of  the waste  would have  to  be  determined
prior  to drumming so  that proper materials can  be  selected for  the wetted
surfaces  of  the pumping  system  and the drums.   Samples of  waste may be
obtained  from   EPA-Ttegion VII.
                                  8-1 i

-------
Worker Safety
      Providing   for   the   health  and  safety   of  personnel   requires
isolating the  workmen  and  other personnel  on  site from the  contaminated
material.
      As  discussed  in  a previous  section,  the  exposure  routes  for  TCDD
include  skin  absorption,  ingestion,  and inhalation.   Therefore,  it  is
E & E's recommendation that all on-site  personnel  be  completely protected
when  in  contact  with  any  potentially   contaminated  material.     The
personnel protective equipment  for the different  operations  is  defined in
Appendix  D.   The possibility  of a  spill,  accident,  and  potential  IDLH
(immediately dangerous  to  life and health)  atmosphere  precludes  the  use
of a  lesser  degree  of  protection.  Totally encapsulated suits  should be
adequate  for personnel within the fenced area.   Once  the drums  are sealed
and decontaminated,  the  level  of protection  can be reduced.   Disposable
coveralls with  hood,  gloves,  boots,  and full  face respirators  should be
adequate  for  the off-site  personnel,  including  the  personnel  at  the
storage facility.
        A metal  grate walkway  instead  of  a  conveyor  will  be  used  for
personnel decontamination  prior to leaving  the  fenced area.   A  collection
trough  and  water  handling   system  similar  to  that  used   for  drum
decontamination   would   be  used.  Separate  personnel   exits  have  been
provided  to  limit  movement  across the  excavated  area.    The  work  will
always progress  from low to high  contamination  (See Figure   8-3).

Worker Training
      The use  of  safety  equipment presents  specific problems for workers,
such  as communications,  visibility, dexterity,  and psychological changes.
A  training  period has been  included  to provide experience  in equipment
and procedures  on order  to acclimate  the worker  to the  restricted working
environment.

Excavation Time
      In  order  to reduce the risk of  spreading contaminated material, two
eight-hour shifts are  used.   The third  shift  would be used  to replenish
                                 8-12

-------
                                    SHOWER   CREW
                                    TRAILER  TRAILER
                                                                            EXIT FROM
                                                                          DECONTAMINATION
                                                                                              TARP
CO
                                                                                    COMMAND POST
                                                 Figure 8-3.   Site  Excavation

-------
supplies and service equipment.  The shifts would be  arranged  to  minimize
work activity during adverse  temperature periods of  the day.  A  five-day
workweek was used as the basis of  the cost and  time estimate.
      Six-  and  seven-day workweeks were also  evaluated.   The  seven-day
workweek  was  not  cost effective,  while there did  not  appear  to be  a
significant cost difference between the  five- and six-day  workweeks.   The
five-day  workweek  was selected,  however,  to  minimize  any  cumulative
worker fatigue.

Worker Fatigue
      Performing  physical  work  in the  encapsulated  suit  will  increase
fatigue and decrease productivity.  An  analysis of the workmen  per shift
was made to develop cost estimates  for the labor  component  of  the various
work elements.  For Component 3A,  approximately 42  people  per  shift would
be  required on site until  all  the drums  were  removed  from  the  trench.
Approximately 20  people  would be  required  for  36  on site, and  the  work
would be  reduced  to one shift,  since  the majority of the  contamination
would have  already been removed.
      Only  19 of  the 42  workmen required for  the 3A excavation  would be
on  the site at any one time.  The  proposed distribution  of the 19 workmen
is  as follows:

         o  Six  will  be  in  the  trench  digging,  filling  drums,   and
            removing the contaminated material.

         o  Six will  be  at  trench  side  assisting  in the  removal  of  the
            material and handling  of drums as required.

         o  Six will be in the drum decontamination area.

         o  One would  operate  the backhoe.    With  the  exception  of  the
            workmen in the  trench, the  on-site  personnel would  rotate to
            other areas at any time to provide  temporary  assistance.
                                 8-14

-------
The remaining personnel are distributed as  follows:

   o  Six workmen  would be  utilized  for  personnel decontamination;  two
      stations  with  three workmen  each were  used  as  the  basis  of  the
      estimate.

   o  Four workmen would  be  utilized to  load,  unload, and  transport  the
      drums from the decontamination  area  to  the  storage  facility.

   o  One person would  be required  to operate  the crane  to lift  materials
      in and out of the trench.

   o  One safety  officer, one  foreman, and  one  engineer would also  be
      required.

      Nine personnel,  who would be  located off  site  at   a  rest  station,
would  relieve   personnel  doing the  work  to  reduce  worker  fatigue.    A
rotation  system has  been considered  which would provide for a  one-hour
rest after two  hours of work.  The  rotation system would  also provide  for
the workmen rotating  among  the  hand excavation assignments,  the  material
handling  assignments,  and   the  drum  decontamination  assignment.    The
equipment operators,  decontamination  personnel,  and personnel  used  to
load, unload, and  transport  the  material to storage  could rotate  jobs on
a daily basis to help minimize any  cumulative  fatigue.
      The major elements of  Component 3A are:

         o  Begin excavation at either  the  west  or east  end of the  trench
            by  digging  down  and uncovering the  drums for  the  full  width
            of  the  trench.   This  excavation  would be   accomplished  by
            using a  backhoe  in conjunction with  hand excavation.   Place
            all  the  soil  in drums  and  move  to   the  decontamination  area
            and then to the  storage facility.

         o  Hand excavate around  the  exposed  drums  to gain  access  to  the
            bung or high point in the drum. Place soil  removed  into
                                 8-15

-------
            drums  which  will   be  lifted   from  the  trench   to  the
            decontamination  area  and  then  transported  to   the  storage
            facility.

         o  Withdraw the contents of the drum by  placing the  suction hose
            through the bung or opening by special equipment  and pump the
            contents to  a drum  located on  the  edge  of  the excavation.
            When the drum has  been emptied,  the  new drum will  be  sealed
            and moved to the decontamination area.

         o  Remove  the  original  drum  from  the  excavation after  all the
            liquid has been  removed  and place in  an over pack.   Seal the
            overpack   and   lift    it   from  the   trench   to  the  drum
            decontamination area.

         o  Decontaminate drums.

         o  Remove  the  decontaminated drums  to   the  storage facility  in
            truckload lots.

         o  Continue  the above  sequence  of excavation  to  uncover the
            drums,  remove   the   liquid   fraction  of  their  contents,
            decontaminate the  drum,  and remove  the  decontaminated  drums
            to the  storage  facility  until  all the drums are  removed  from
            the trench.

      The anticipated  activity  time for this  component is  approximately
23 days.  The estimated  cost  for Component  3A is $467,930.   Table  E-3  of
Appendix E  contains the detailed  cost estimates  and  supporting data  on
materials and volumes of water required.

Component 3B Excavation
      Excavation  in 3B  includes  all  the work required to  determine  the
extent  of contaminated soil and  its  removal.   The  soil  will be  removed
and placed  in 55-gallon  drums.   Layout of the 3B excavation is  shown  on
Figure 8-4.

                                 8-16

-------
CO
                           SHOWER TRAILER
                                                       LOADING RAMP
      PERSONNEL
    DECONTAMINATION
BULK DECON-
 STORAGE
                                   CREW
                                  TRAILER
                           STORAGE
                           TRAILER
                                              BACKHOE
                                               o
     DRUMS
                                                                  BULK OECON
                                                                   STORAGE
                                                             RAMP tt PLATFORM
                     -CONCRETE PAD
                                                                        —•TARP
                                                      TRENCH BOTTOM
                                                                u-
                                 -CAP STORAGE
                                                                          COMMAND POST
                                                                            o
                                Figure  8-4.  Plan View of Component 3B  Excavation

-------
      The major elements of this component are as follows:

         o  Sample  the  trench  bottom and  side  to  determine compliance
            with acceptable cleanup level.

         o  Based on the results of  the  sampling and analysis,  determine
            the location and  volume  of contaminated  soil  to be  removed.
            If none, close out site as defined in Component  4.

         o  Set up drum loading area.

         o  Excavate the contaminated soil and  place  the  soil  in  drums.
            Remove the drums  to  the  decontamination area, decontaminate,
            and then move to  the temporary storage  structure.

         o  Sample  the  trench bottom  and other  areas  inside the  fenced
            area to determine compliance  with  acceptable  cleanup levels.

      The activity  time, which  is  based  on the  capacity  of  the   storage
structure,  is  10.5 days  of soil  excavation.    There   are  two  costs
associated with the Component 3B.  The initial  sampling  ($44,000)  of  the
trench  to confirm levels  of  TCDD  and TCP contamination  will be  a fixed
cost.   If  there  is  a positive  analysis, an  additional  fixed cost  of
$3,110  will  be   incurred  for  construction  of  the  loading  platforms.
Variable  costs,  which  include  labor,  equipment rental,  and  materials,
amount  to $11,340  per day or $380 per  cubic  yard  of  soil  removed.   An
estimated  detailed cost  for Component  3B  is   found  in  Table  E-4  of
Appendix E.

COMPONENT 4.  SITE CLOSURE
      Site  closure  consists  of  removing  all equipment,  tools,  and
materials used to do the work, and backfilling and  grading of the site.
      The major elements of this component are:

         o  Decontamination of all equipment and reusable  tools.

                                 8-18

-------
         o  Removal  to Che  temporary  storage  facility  of  all  contaminated
            tools,  equipment,  and  supplies  which are  expendable or  are
            unable  to  be  decontaminated,  and  all  the   decontamination
            water.

         o  Backfilling  the  trench  with  virgin material and  regrading the
            area  inside  and  outside of  the  fence.

         o  Removal  of  all  trailers  and  support  facilities  (note  the
            fence will remain).

      The estimated  activity time for this component  is  10 days,  and the
estimated cost  is $23,810.   A detailed  cost estimate  is included  in  Table
E-5 of Appendix E.

Summary of Component Costs
      As shown  on  Table  8-1, the direct  cost to complete the  excavation
and storage of  drums  and contaminated soil around the drums  is estimated
at  $1,219,000.   An  estimated  total  project  cost has  been   developed  by
adding to  the sum of  the component  costs  an allowance  for  contractors'
overhead and  profit  and  a contingency to  account  for  unforeseen problems.
The value of  70% of  the  direct  cost was used to  compute  the  contractors'
overhead and  profit.
      Overhead  is  estimated at  45% while profit has  been assigned  25%.
These values  appear to  be  reasonable because they  are  within the  range
used  by  contractors who are engaged in  this type  of cleanup work.   A
value of 20%  of the direct costs  was  used  to  compute  the  contingency, but
the  contingency can  he   reduced  once  the  plans and  specifications  are
defined.   Normal  engineering projects estimate contingency ar  10% at the
conceptual  design   level;   however,   the  20%   contingency   factor  is
reasonable due to the nature of  the work  and  safety  requirements.
      The  total  estimated   project   cost  without  the  Component  3B  is
$2,486,000  (Table  8-1).   (Component  3B considers  only   the  requirements
for  further  excavation.   Storage  through  3B   is  accommodated  in  the
orginal structure.)   The maximum costs,  which  include  Component 3B and
                                 8-19

-------
                                TABLE 8-1
                             REMEDIAL ACTION
                         COMPONENT COST  SUMMARY
COMPONENT                    DESCRIPTION                AMOUNT
                           Storage Facility           $360,000
                           Site Setup and              367,000
                           Mobilization
    3A                     Excavation                  468,000


    4                      Site Closure                 24,000

                                         Subtotal   $1,219,000

                              Overhead and Profit
                                    (70%)              853.000

                                         Subtotal    2,072,000

                                Contingency (20%)      414,000

                               TOTAL PROJECT COST   $2.486.000
                                  8-20

-------
provide  for  excavation  of the  trench  to  an  equivalent  of  12  feet  in
depth, is $2,915,000  (Table 8-2).   Not  including permit preparation,  the
estimated duration of the  effort is six  months.

PLANNING CONSIDERATIONS FOR IMPLEMENTING PROPOSED REMEDIAL  ACTION
      A number of controls should  be  instituted for  storage  of  the waste
material.  These controls  are necessary  to  protect  workers  on-site  and to
prevent off-site migration of contaminants.

Site Control
      A  site control  plan should  be  developed implemented which  will
address the  following areas:

      o  Designated hazard areas.

      o  Access control points.

      o  Establishment of  on-site  vehicle  and personnel travel routes.

      o  Establishment of  administrative command post area.

      o  Possible  subdivision  of  the  site  for  predetermined  storage
         areas, rest  area, and  other  miscellaneous  areas as needed.

Storage Controls
      Storage  control involves a  complete  plan to organize  and  maintain
proper records of  all material placed within  the storage  structure.  The
storage structure must meet certain basic  requirements:

      o  The  facility  should  be   able  to  accommodate  the  anticipated
         volume required  for  stored material.

      o  Ample  room  should   be  provided  for  the  operation of storage
         equipment  such  as forklifts.
                                  8-21

-------
                                TABLE 8-2
                             REMEDIAL ACTION
                              COST SUMMARY
                       WITH ADDITIONAL EXCAVATION
Cost Summary for Trench
      Excavation/Storage                              $1,219,000
Excavation*
Fixed:   $91,000
Variable Total:  $119,000                                210.000

                                      Subtotal         1,429,000

                           Overhead and Profit         1,000,000
                                  (70%)

                                      Subtotal         2,429,000

                             Contingency (20%)           486,000

                                         TOTAL        $2.915.000
*Based on 10.5 days of work with an additional 405 drums being stored.
 "Excavation will lower trench to 12 feet."
                                  8-22

-------
      o  Ample room is needed for  the  inspection  and removal of selected
         containers.

      o  The  structure  should  meet  applicable  codes  and  be able  to
         withstand local weather and geologic conditions.

      o  Security must be provided  for  possible vandalism and  accidental
         entry.

      o  The structure should provide for containing a spill.

      o  Utilities must be provided.

      o  Venting should be provided

      o  Fire extinguishers,  alarms, vapor  detectors,  and  other  safety
         equipment should be provided.

A  comprehensive   storage  site   control  plan   should  be   formulated
including:

      o  Spill prevention, control,  and  countermeasures  plans.

      o  Periodic  inspections of  storage structure  and waste containers.

      o  Proper  record-keeping  to  document  all  inspections,  material,
         movement, regulatory requirements, etc.

      o  Additional security requirements  such  as barriers,  warning signs
         emergency numbers, etc.

      o  Area drainage.
                                  8-23

-------
                        REFERENCES FOR SECTION 8


1.   Godfrey,  R.S.  (ed.),  Building Construction Cost  Data,  R.S.  Means
         Company,  Inc.,  Kingston, Mass.,  1980.

2.   TECHNOS,  Inc.,  Report of Geologic and Geophysical Investigation:
         Denny Farm Hazardous Material Site,  Barry County, Missouri.
         Miami, Florida,  1980.
                                  8-24

-------
                   LIST OF CONTACTS MADE IN PREPARING
            MATERIALS AND LABOR COST ESTIMATES FOR SECTION 8
EQUIPMENT
     Contractors Supply Company, Kansas City,  Mo.
     Halco Equipment Company, Kansas City,  Ks.
     Donco Equipment Company, Kansas City,  Mo.
     Potter Equipment Company, Springfield, Mo.
(816) 221-7788
(913) 281-5700
(816) 229-3422
(417) 852-9275
UNION LABOR RATES
     Builder's Association of Kansas City
(816) 531-4741
ACTIVATED CARBON SYSTEMS FOR DIOXIN REMOVAL
     John Bellinger/Calgon Carbon Service,
        St. Louis, Mo.
     Dr. Dave Stallins, Columbia National
        Fisheries Research Lab, Columbia, Mo.
(314) 863-3200
(314) 442-2271
STRUCTURES FOR WEATHER PROTECTION
     Rockhill Building Company, Kansas City, Mo.
     Munlake Construction Company, Kansas City, Mo.
     Sutherland Lumber Company, Kansas City, Mo.
     Payless Cashways, Kansas City, Mo.
     Roth Farm Supply, Kansas City, Mo.
     Kansas City Tent & Awning, Kansas City, Mo.
(816) 761-4993
(816) 254-5444
(816) 587-9200
(816) 474-4950
(816) 737-3650
(816) 924-1883
ANALYSIS OF TCDD AND TCP IN AQUEOUS SOLUTIONS
     Dr. Mike Taylor, Brehm Laboratory, Wright State
        University, Dayton, Ohio
(513) 873-2202
                                  8-25

-------
                            LIST OF CONTACTS
                   MADE IN PREPARING SECTION 8 (CONT'D)
WELL DRILLING and PUMPING EQUIPMENT
     Gerald Sill Drilling, Springfield,  Mo.
     Boyles Brothers' Drilling, Springfield,  Mo.
     Action Rotary Drilling, Wheat land,  Mo.
     Layne-Western Company, Kansas City, Mo.
(417)  866-7341
(417)  869-1298
(417)  282-5270
(816)  931-2353
CONTAINERS
     Cortland Container Company, Kansas City, Ks.
     U.S. Steel, Kansas City, Mo.
(913) 321-1212
(816) 221-8311
PROTECTIVE EQUIPMENT AND DECONTAMINATION FACILITIES
     Mine Safety Appliances, Lenexa
     Arrowhead Grating Company, Kansas City, Mo.
     Donahower and Associates, Kansas City, Mo.
(913) 888-2628
(816) 471-3121
(816) 432-9306
                                  8-26

-------
                                SECTION 9
                     CONCLUSIONS AND RECOMMENDATIONS
     Based on  the  geological,  hydrological,   and  toxicological  studies
carried out by Ecology and Environment,  Inc.  (E & E),  and the geophysical
reconnaissance and risk analysis that have been conducted,  E & E presents
to EPA  the  following  conclusions and  recommendations concerning  Denny
Farm Site 1.

CONCLUSIONS
     The  geotechnical  data,   the   toxicity   of   the  waste,   and  the
environmental factors require the following actions:

     o   Removal  of  the waste and associated contaminated  materials from
        Denny Farm Site 1

     o   Storage  of  the waste and associated contaminated  materials in a
        structure to be erected at Denny Farm Site  1

     To achieve the required storage, the following excavation procedures
are recommended:

     o  Consideration of weather protection

     o  Commitment to personnel safety

     o  Commitment  to  minimize  time  spent   in the  excavated  disposal
        trench

     o  Ensurance that no contaminants leave the disposal site other than
        in containment vessels, i.e., drums

     o  Provision of sufficient  storage  to accommodate  the  removal  of
        contaminated soil and material from the disposal site
                                  9-1

-------
     To accomplish   the   recommended   work,    the   cost   estimate   is
$2,486,000.00.

RECOMMENDATIONS
     In addition  to  the  conclusions of this  report  noted  above,  E &  E
makes the following recommendations:

     o  That  EPA  proceed immediately  to  acquire the  permits needed  to
        excavate  and  store  the hazardous waste  materials  at Denny  Farm
        Site 1

     o  That  EPA  select a  design  engineering  firm to  prepare a  final
        design and also  select an execution contractor to  carry out the
        required work at Denny Farm Site 1

     o  That EPA  execute the  recommended  excavation  and  storage  at  Denny
        Farm Site 1

     o  That EPA continue with a long-term investigation of treatment and
        ultimate  dispoal methods  for the hazardous waste  and associated
        contaminated  materials at  Denny  Farm Site  1  that may meet the
        proven  technology   criterion   before  the  expiration  of  the
        short-term    storage   solution   presented    in    this   report
                                  9-2

-------
 APPENDIX A
SAMPLING DATA

-------
         TABLE A-1



GROUNDWATER MONITORING DATA
Sample No.
AN3412


AN3413

AN3438

AN3502


AN3503


AN 3504


AN3505


AN3506


AN3507


AN3508


AN3509


AN3510


Well
No.
13


5

4

1


2


3


4


5


6


7


8


9


Date
4-03-80


4-03-80

4-03-80

6-03-80


6-03-80


6-03-80


6-03-80


6-03-80


6-03-80


6-03-80


6-03-80


6-03-80


Parameter (s)
Analyzed
Phenohcs
TCOO

Phenolics
TCDD
Phenolics
TCDO
Phenolics
TCP
TCDD
Phenolics
TCP
TCDD
Phenolics
TCP
TCDD
Phenolics
TCP
TCDD
Phenolics
TCP
TCDD
Phenolics
TCP
TCDD
Phenolics
TCP
TCDD
Phenolics
TCP
TCDD
Phenolics
TCP
TCDO
*Quantity
Detected
17,000
None

None
None
None
None
None
None
None
None
30
None
8,000
None
None
14,000
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
•Detect ion
Limit
5,000
2

5,000
2
5,000
2
5,000
3
20
5,000
3
20
5,000
3
20
5,000
3
20
5,000
3
20
5,000
3
20
5,000
3
20
5,000
3
20
5,000
3
20
Comments
False positive

*ppt
































-------
                                                                TABLE A-1 cont.



                                                          GROUNDWATER MONITORING DATA
to
Sample No.
AN3511
AN3512
AN3513
AN3514
AN3515
AN3516
AN3517
AN3518
AN3519
AN3520
AN3521
AN3522
AN3523
AN3524
AN3525
AN3526
AN3527
AN3528
JW3553
Well
No.
Sprmi
10
11
12
13
1
2
4
13
5
6
7
8
9
Spnnc
10
11
12
13
Date
6-03-80
6-03-80
6-03-80
6-03-80
6-05-80
6-11-80
6-11-80
6-11-80
6-11-80
6-11-80
6-11-80
6-11-80
6-11-80
6-11-80
6-11-80
6-11-80
6-11-80
6-11-80
6-07-80
Parameter (s)
Analyzed
Phenolics
TCP
TCOD
Phenolics
TCP
TCDO
Phenolics
TCP
TCDD
Phenolics
TCP
TCDD
TCP
TCDD
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
•Quantity
Detected
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
Mone
None
•Detect ion
Limit
5,000
3
20
5,000
3
20
5,000
3
20
5,000
3
20
3
20
3
3
3
3
3
3
3
3
3
3
3
3
3
3
Comments
*ppt



















-------
       TABLE A-1 cont.



GROUNDWATER MONITORING DATA
Sample No.
AN3554
AN3555
AN3557
AN3558
AN 3559
AN3560
AN3561
AN 3 562
AN3563
AN 3 564
AN3565
AN3566
AN 3567
AN3544
AN3545
AN 3 546
AN 3547
AN 3548
AN3549
AN3550
AN3551
AN3552
AN3573
Well
No.
5
4
1
2
6
7
8
9
14
Sprint
10
11
12
1
2
4
13
5
6
7
8
9

Date
6-07-80
6-07-80
6-08-80
6-08-80
6-08-80
6-08-80
6-08-80
6-08-80
"6-08-80
6-08-80
6-08-80
6-08-80
6-08-80
6-26-80
6-26-80
6-26-80
6-26-80
6-26-80
6-26-80
6-26-80
6-26-80
6-26-80

Parameter-Is)
Analyzed
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
No data available
•Quant ity
Detected
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None

*0et ect i on
Limit
3
3
3
3
3
3
3
3
3
3
3
3
3
10
10
10
10
10
10
10
10
10

Comments
»ppt























-------
          TABLE A-1 cont.
GROUNDWATER MONITORING DATA
Sample No.
AN3574
AM3575
AN3?76
AN3577
AN3578
AN3579
AN3580
AN3581
AN3582
AN3583
AN3584
AN 3585
AN3586
AN3587
AN3588
AN3589
AN3590
AN3591
AN3592
AN3593
Well
No.
Sprinc
14
10
11
12
1
2
4
13
5
6
7
8
9
Spnnc
14
10
11
12
1
Date
6-26-80
6-26-80
6-26-80
6-26-80
6-26-80
6-30-80
6-30-80
6-30-80
6-30-80
6-30-80
6-30-80
6-30-80
6-30-80
6-30-80
6-30-80
6-30-80
6-30-80
6-30-80
6-30-80
7-07-80
Parameters}
Analyzed
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
•Quantity
Detected
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
•Detection
Limit
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
Comments
*ppt




















-------
          TABLE A-1 cont.
GROUNDWATER MONITORING DATA
Sample No.
ANI3594
AN3595
AN3596
AN3597
AN3598
AN3599
AN5002
AN5003
AN5004
AN5005
AN 5006
AN5007
AN5008
AN5009
AN5010
AN 5011
AN5012
AN5013
AN5014
AN5015
AN 501 6
AN5017
Well
No.
2
4
13
5
6
7
8
9
Sprint
14
10
11
12
Melvir
Manor
1
2
4
13
5
6
7
8
Date
7-07-80
7-07-80
7-07-80
7-07-80
7-07-80
7-07-80
7-07-80
7-07-80
7-07-80
7-07-80
7-07-80
7-07-80
7-07-80
7-07-80
7-14-80
7-14-80
7-14-80
7-14-80
7-14-80
7-14-80
7-14-80
7-14-80
Parameters}
Analyzed
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
•Quant ity
Detected
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
•Detect ion
Limit
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
Comments
*ppt






















-------
      TABLE A-1 cont.



GROUNDWATER MONITORING DATA
Sample No.
AN5013
AN5019
AN5020
AN 5021
AN5022
AN5023
AN5024
AN5025
AN5026
AN5027
AN 5028
AN5030
AN5031
AN5032
AN5033
AN5034
AN5035
AN5036
AN5037
AN5038
Well
No.
9
Sprmc
14
10
11
12
Billy
Edwarc
1
2
4
13
6
7
8
9
Sprint
14
10
11
12
Date
7-14-80
7-14-80
7-14-80
7-14-80
7-14-80
7-14-80
7-14-80
s
7-21-80
7-21-80
7-21-80
7-21-80
7-21-80
7-21-80
7-21-80
7-21-80
7-21-80
7-21-80
7-21-80
7-21-80
7-21-80
Parameters}
Analyzed
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
TCP
•Quantity
Detected
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
*Detection
Limit
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
Comments
*ppt




















-------
      TABLE A-2



SOIL SAMPLING DATA
Sample No.
AN 3400
AM3401
AN 3402
AN 3403
AN 3404
AN 3405
AN 3406
AN 3407
AN 3408
AN3409
AN 3410
AN 3411
AN3421
AN 3446
AN8001
Description
Borehole 01
Borehole 92
Borehole #3
Borehole #4
Borehole //5
Borehole it 6
Borehole //7
Borehole C/8
Borehole #9
Borehole #10
Borehole #11
Borehole #12
Borehole #22
Trench soil sample
Boring #13
Date
4-22-80
4-24-80
4-24-80
4-24-80
4-23-80
4-26-80
4-26-80
4-26-80
4-26-80
4-25-80
4-25-80
4-24-80
4-22-80
4-29-80
6-15-80
Sample
Type
Soi 1 /composite
Soil/composite
Soil /composite
Soil/composite
Soi 1 /composite
Soi 1 /composite
Soil/composite
Soil /composite
Soi 1 /composite
Soil/composite
Soi I/compos jt(
Soil/composite
Soil/composite
Composite
Composite
11 1/2-13 ft.
Parameter^;
Analyzed
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCOD
TCP
TCDD
TCDD
TCP
TCDD
•Quantity
Detected
63,000,000
4,000
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
42,000
None
None
•Detection
Limit
200,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
3,000
1,000
20,000
70
Comments
*ppt












WSU Analysis
EPA Analysis

-------
                                                                     TABLE  A-2  cont.

                                                                   SOIL  SAMPLING DATA
>
oo
Sample No.
AN8002
AN8004

AN8007

AN8008

AN8009

AN 801 6

AN8024

AN8034

AN8036

Description
Boring #13
Boring #15

Boring #15

Boring #15

Boring #15

Boring #16

Bonnq #21

Boring #28

Boring #28

Date
6-15-80
6-15-80

6-15-80

6-15-80

6-15-80

6-15-80

6-16-80

6-16-80

6-16-80

Sample
Type
Composite
13-14 1/2 ft.
Composite
16-17 1/2 ft.
Composite
5-6 1/2 ft.
Composite
6 1/2-8 ft.
Composite
8-9 1/2 ft.
Composite
14-15 ft.
Composite
10-14 ft.
Composite
8-9 1/2 ft.
Composite
19-20 1/2 ft.
Parameters)
Analyzed
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
•Quantity
Detected
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
•Detect ion
Limit
2,000
' 70
2,000
70
2,000
70
2,000
70
2,000
70
1,000
70
1,000
70
1,000
70
1,000
70
Comments
EPA Analysis
EPA Analysis

EPA Analysis

EPA Analysis

EPA Analysis

EPA Analysis

EPA Analysis

EPA Analysis

EPA Analysis


-------
                                                                        TABLE  A-3



                                                             SURFACE  WATER  MONITORING DATA
vo
Sample No.
AN3556

AN3568
AN3569


AN3570



VR5301

VR5302

VR5303

VR5304

VR5305

VR5306

VR5307

VR5308

VR5309

Description
Pond west of Farm
Site
Pond near Well 02
Calton Creek


Calton Creek



Spring River
Highway 166
Spring River
Highway 96
Spring Rivei
Highway 37
Spring River
County Road P
Spring River
U.S. U6
Calton Creek
County Road VV
Little Flat Creek
County Road C
Flat Creek
County Road U
Flat Creek
McDowell Mill Dam
Date
6-9-80

6-9-80
6-11-80


6-11-80



6-17-80

6-17-80

6-17-80

6-17-80

6-17-80

6-17-80

6-17-80

6-17-80

6-17-80

Sample
Type
Water (grab)

Water (grab)
Resin Column
water

Resin column
water


Sediment

Sediment

Sediment

Sediment

Sediment

Sediment

Sediment

Sediment

Sediment

Parameter(s)
Analyzed
TCP
TCDD
TCP
TCP
Extractable Priority
pollutants
TCP
Extractable priority
pollutants
Extractable orgamcs
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD
•Quantity
Detected
None
None
None
None

None
None

None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
•Detect ion
Limit
3
20
3
1


1



5,000

5,000

20,000

5,000

1,000

5,000

5,000

5,000
5,000
5,000
5,000
Comments





























-------
       TABLE A-3 cont.



SURFACE WATER MONITORING DATA
Sample No.
VR5310

VR5311

VR5312

VR5313


VR5314

VR5315


Description
James River
Nelson Mill Bridge
James River
Frazier Bridge
Table Rock Lake
Highway 76
Table Rock Lake
Highway 76

Table Rock Lake
Highway 86
Table Rock Lake
Highway 86

Date
6-17-80

6-17-BO

6-18-80

6-18-80


6-18-80

6-18-80


Sample
Type
Sediment1

Sediment

Sediment

Fish Samples
18 total
6 diff. species
Sediment

Fish
15 total
7 diff. specie:
Parameters)
Analyzed
TCP
TCDD
TCP
TCDD
TCP
TCDD
TCP
TCDD

TCP
TCDD
TCP
TCDD

•Quant ity
Detected
None
None
None
None
None
None
None
None

None
None
None
None

*Detection
Limit
5,000
5,000
5,000
5,000
5,000
5,000
1,000
2,000

5,000

1,000
3,000

Comments















-------
      TABLE A-4
DRUM (SOURCE) SAMPLE DATA
Sample No.
AN 34*0




AN 3441
AN3443

AN3444
AN3445
AN3441
AN3443
AN3444
AN3455
AN3440
AN 3448
AN3449
AN3450

AN3441
AN3443
AN3444
AN3445
AN3440
AN344B
AN 3449
AN3450
Description
Drum Sample Rusty
Colored Liquid.




Drum Sample
Black residue.
Drum sample, blact
granular residue.
Drum sample,
black residue.
Drum sample,
black residue.
Drum samples, EPA
Weighted average.


Drum samples.



26% Drum
65> samples.
323
36%
35?o Drum
10% samples.
40%
15S
Date
4-2B-80




4-28-80
4-28-80

4-28-80
4-28-80
4-28-80



4-28-80



4-28-80

4-28-80



Sample
Type
S i nq le




Single
Single

Single
Single
Volumetric
Composite


Volumetric
Composite



Volumetric
Composite

Volumetric
Composite


Parameter(s)
Analyzed
Not analyzed, see
composite sample
informat ion below.



TCP, others
TCDD
TCP, others
TCOD
TCP, others
TCDD
TCP, others
TCDD
TCDD



TCP
Ident if led



TCDD

TCDD



•Quantity
Detected





Ident if led-r
110,000,001
Identified-r
None
IdentiFied-r
65,000,001
Ident ified-r
87,000,00(
Weighted
average is
81,000,001

19,000,001
Tetrachloro-
benzene
toluene,
others
319,000,OOC

1.39C



•Detection
Limit





o quantity spec.
20,000,000
o quantity spec
29,000,000
o quantity spec
29,000,000
o quantity spec
29,000,000




Not specified
No quantity
specified

1,300,000

100



Comments
Analysis by EPA.
Each drum sample
is actually a com-
posite of the var-
ious liquid layer:
within the drum.









No single analysis
conducted on these
samples.


Wright State Uni-
verstiy analysis

Wnqht State Uni-
versity analysis



-------
 APPENDIX B
RISK ANALYSIS

-------
                               APPENDIX  B
                              RISK ANALYSIS
INTRODUCTION:  GENERAL APPROACH
     The  risks  to  human  health  posed  by  several  alternative  remedial
actions  for Denny Farm Site  1 can be  quantitatively  estimated by making a
number of simplifying assumptions.  This  section defines  what is meant by
the  terms "risk" and "exposure" and describes  the general  philosophy and
methodology  used to estimate  the  risks.   The second  section  summarizes
the  risk results,  the   third  section  describes in  detail  the  exposure
scenarios  and assumptions  that were  used  to arrive  at  these  results,
while the last section presents details  of the methods of calculation.
     The  major hazard  to human health  due to  the wastes at the  site is
assumed  to  be the  toxicity  of  dioxin  (TCDD);  for  simplicity,  only  this
hazard is considered.   An  "exposure" is  considered  to occur  whenever  a
person comes  directly  in contact  with TCDD  in  high  enough  concentrations
that the dose  of TCDD to his body exceeds  an assumed safe level, which is
taken  to be  1  part per  trillion   (ppt)  of body weight.   The  level  of
effect,  that  is,  severity of health  impairment, produced  in  the exposed
person by this dose  of TCDD  cannot  easily  be predicted, and therefore the
person is counted  as potentially subject  to some adverse  health effect.
Depending on  the  actual  magnitude  of the  dose,  which  in turn  depends on
time  duration of  the  contact  and  other pharmacological   factors,  the
actual  level   of  effect  suffered   may  range  from   a  mild  and  probably
reversible case  of  chloracne to cancer  of  the  liver.
     In order  for exposure  to TCDD  from the trench  at  the  site to occur,
a curtain  amount of TCDD  must  escape  from the  trench,  spread  from the
site via some physical  environmental  pathway and  ultimately  enter  the
human body directly.  An effort  has been  made  to systematically consider
all  possible  pathways and  to identify those exposure  scenarios which are
most credible  for four alternative  actions.
                                  B-l

-------
     In general,  TCDD can enter  the  human body  through several  routes:
oral, respiratory,  and dermal.   In this case,  the  route  of  body  entry
affecting  the  greatest number  of  people  is  oral ingestion  of  drinking
water   contaminated  with   dangerous   concentrations   of   TCDD   after
environmental   spread   off    site    through    groundwater    ("Dangerous"
concentrations are  those  above the safe  level  of 1  ppt).   This  type  of
pathway  leads  to  the greatest  contamination  spread  to the  public  off
site.   By  comparison,  the only other  possible  exposure routes  occur  via
relatively short-range physical  pathways and  can potentially affect  only
a  few  workers  on  site.   These other  routes  are direct  skin contact  or
inhalation of TCDD-laden  particulates  or direct skin contact with liquid
wastes.
     Once  the  credible  types of  release and  spread  of  TCDD  from  the
trench  are identified, the extent of  the  resulting exposure of  people  can
be quantitatively estimated.  By making  simplifying  assumptions  about  the
physical mechanisms of the release  and environmental  spread and  by taking
into  account known  physical  properties  and  principles,   simple  model
calculations can  be used to predict  conservative distances of  spread  of
the  contaminant away  from the site.   In  particular,  one can compute  the
maximum  distance  around  the  site  within  which  any  sources  of  drinking
water such as wells would be  subject  to  dangerous concentrations of TCDD.
Using a circular  zone of  influence around the  site,  the total  number  of
people  within  this zone  can be  calculated.    This  number is   the  total
exposures  for the assumed release scenario.
     In addition  to  the  maximum  extent  of exposure,  the probability  of
occurrencp   of  such   a   release   scenario  must  be   considered.    The
probabilities  of   the  various  scenarios  can   also   be   quantitatively
estimated  by  using  historical  data where   available  (e.g.,   for  the
probability  of  a  tornado strike)  and  by making reasonable  assumptions
where  numerical  values  are  unavailable   (e.g.,  the   probability  for  the
sudden  formation of a  sinkhole  under  the trench).  The "risk" of  a given
exposure  scenario  is  then  defined as  the  mathematical product  of  the
number  of exposed  people  and  the  probability of  occurrence  of  this
scenario.  Therefore,  the risk of  a given alternative  action is  the  sum
of  the  risks  calculated for  each  of   the  credible  release  scenarios
                                  B-2

-------
identified  for  that  alternative.    The  risks  of   several  alternative
actions computed in this way  can  be  compared quantitatively as an  aid  in
deciding which action to take.
     The most  difficult part  of  this  methodology is the initial  stage  of
defining  the  credible exposure  scenarios.   The greatest  problem is  to
combine the available bits  of information, sometimes  inconsistent,  about
physical  properties of  the  contaminant  TCDD,  the  geologic   conditions
around the trench,  and known  physical fluid flow principles to arrive  at
a  plausible,   yet  consistent  set  of assumptions  which  can  be  used  to
describe  the  spread  of  TCDD  away  from  the  trench  in groundwater.
Quantitative  calculations  of extent  of  spread of  TCDD   away   from  the
trench  were   carried  out  only for  this  groundwater  pathway.    It  was
credible  to   assume that   successful  mitigation  methods  such  as  dust
control would be used to  cut off the only other possible environmental
pathway,  i.e.,  wind-borne spread  of  TCDD-contaminated  dust  particles
generated during trench excavation.
     Although  the  resulting combinations of methods used  are  necessarily
simplified, this  analysis demonstrates  that  it  is  possible to arrive  at
quantitative  answers for  the  risks by making credible  assumptions.   These
answers,  which  are  presented   in   the  next   section,   should   not  be
considered   absolute.      They   are   initial   guidelines  for   further
refinements but  can be used in the meantime  for  discussing and comparing
the several alternative actions.

SUMMARY OF ESTIMATED RISKS
     Table  B-l  presents  the  maximum  and  average  numbers   of  people
estimated to  be  exposed  to dangerous  concentrations  of TCDD for each  of
several alternative  remedial  actions.  Here,  "dangerous"  is taken to mean
high enough to lead  to a  dose of  1  part  per  trillion  (ppt) or  greater  in
the average human  body.  For  drinking water,  this threshold concentration
of  TCDD  is  0.035   parts  per  billion  (ppb)  (see Numerical  Calculations
section).  The 1 ppt dose  in  the  body  is considered  here  as the allowable
safe human dose  of  TCDD for either oral  or dermal exposures.
     The  exposures  in Table B-l  are  categorized  into  workers  on  site and
public  off  site, and also  into  short term  and  long  term.  "Short term"
                                   B-3

-------
                                                                           TABLE B-1
                                                                  SUMMARY OF ESTIMATED RISKS
                                                            MAXIMUM AND AVERAGE NUMBERS OF PEOPLE
                                                         EXPOSED TO DANGEROUS CONCENTRATIONS OF TCDD
                                                    DURING SHORT TERM
DURING LONG TERM
D
I

Workers Public
Alternative Remedial Action on site off site
1.

2.

3.

4.


Leave buried 0 1446 max
14.46 ave
Install & maintain a groundwater '0 379 max
monitoring system 0.13 ave
Excavate & store material 43 max 170 max
on site 20.6 ave 25 ave
Excavate + transport drums via 45 max 180 max
truck to Syntex facility in 21.0 ave 25 ave
Verona, Mo.
Workers Public
on site off site
0 119 max
107.10 ave
0 119 max
53.55 ave
0 67 max
2.7 ave
0 67 max
2.7 ave

Total Total Combined
on site off site Total exposures
0 121.6 ave 121.6 ave

0 53.7 ave 53.7 ave


20 ave 27.7 ave 48.3 ave

21.0 ave 27.7 ave 48.7 ave

             a  "Average"  is the maximum number multiplied by the estimated probability of occurrence; see Table B-2
             b  "Dangerous" means high enough to lead to a dose of 1 ppt or greater  in the average human body;  in drinking water,  this
                     threshold concentration is 0.035 ppb.
             c  "Short term" means during excavation period, approximately 1 month.
             d  "Long term" means greater than 1 year (assumes no other future actions are taken which lead to  increased worker exposures).

-------
refers  to  a  time of about  1  month  (about the  length  of  time the  trench
would be open during the excavation in Alternative  3).  "Long term" means
greater  than  a year;  it  is assumed  that  no further  worker actions  are
taken  in  the  future  which would  lead  to  increased  opportunities  for
worker exposure.
     In  each  case shown  in Table B-l,  the  maximum  number  of  exposures
given is that calculated for  a  specific  release  scenario,  as described in
the following section.  For example,  for Alternative  1  (leave buried)  the
value 1,446  is  the maximum number of people estimated to be exposed  to
concentrations of TCDD in  drinking water greater than 0.035  ppb.   In  the
event  of  a   hypothetical   catastrophic   geologic  collapse  or   sinkhole
beneath  the  trench, the  groundwater  and  ultimately  the  drinking  water
wells from which  these people are supplied would  be rapidly contaminated.
This  particular  scenario  might  be   called  the  worst   case  for  this
alternative.
     In  addition to the  maximum value  shown  in Table B-l, an  average
value for  exposures is  also  given in  each case.   This  average  is  the
maximum number of exposures above multiplied by  the estimated probability
of its occurrence.  The following section details how  this probability of
occurrence is  estimated  for each scenario,  and  Table B-2  summarizes  the
estimated  probabilities.     For  example,   for  the   sinkhole   scenario
described  above   for  Alternative 1,  the probability  of  occurrence  was
estimated to be 1 percent,  or 14.46 exposures.
     For each  alternative,  the   total average  exposure value is  found  by
adding  the average values  for  short  term and  long term.   This  is  done
separately for on-site and  off-site  classifications, and   finally  the  sum
of these two averages  is  the  combined average risk  (see far-right column
in Table B-l).
     Several  general  conclusions can  be drawn  from the results  in Table
B-l:
       o  Alternative  1  (leaving the  trench as  is) has the  highest  risk
          (121.6)  of  any  of   the   alternatives,   while   Alternative  3
          (excavate and store on site) has the  lowest  (48.3)
                                  B-5

-------
                                                                     TABLE B-2
                                                      SUMMARY OF CREDIBLE EXPOSURE SCENARIOS
              Alternative Remedial Action
              1.   Leave  buried
to
i
a\
              2.  Install  & mamtajn a
                 groundwater  monitoring
                 system
Exposure Scenarios Considered

(a) Catastrophic sinkhole  leads
    to rapid release of contents
    of all 150 drums to water
    table below trench; subse-
    quent horizontal flow  of
    contaminants in "under-
    ground river" straight to-
    ward nearest private drink-
    ing water wells; people
    drink contaminated water
    from these wells (worst
    case).

(b) No sinkhole; instead,  drums
    gradually leak maximum con-
    centration at an assumed
    rate; waste leaches down
    conduit to water table,
    where dilution occurs  be-
    cause of greater water
    flow rate horizontally;
    again, "river" flows
    straight toward wells;
    people drink contaminated
    water from wells (most
    likely case).

(a) Monitoring well system is
    successful in warning  near-
    by residents in time not
    to drink water in the  event
    contamination of wells does
    occur (via either of scena-
    rios at>pve).
Estimated Probability
    of Occurrence

   1 chance in 100
  (i.e., 1 percent)
Estimated Max. No. jjf
People Exposed to TCDD

       1,446
(total Barry County pop-
 ulation within 4.29
 miles of site)
  90 chances  in 100
  (i.e., 90 percent)
         119
(total Barry County pop-
 ulation  within 1.23
 miles of site)
     (0.01) (1/30) H
     (0.90) (0.50)
       = 5.94 x 10-'

-------
                                                                     TABLE B-2
                                                      SUWARY OF CREDIBLE EXPOSURE SCENARIOS
             Alternative  Remedial  Action
             2.  Cont'd.
CD
I
Exposure Scenarios Considered

(b) Catastrophic sinkhole
    occurs right after a well
    sampling time, with rapid
    contamination reaching water
    table and wells as above,
    and monitoring system does
    not warn residents in time;
    as a result, a certain
    limited number of people do
    drink contaminated water
    before a warning is issued
    (Maximum warning delay time
    of almost a sampling
    interval, say 29 days.)
    (worst case).

(c) Gradual release of wastes to
    the water table occurs, and
    monitoring system does not
    warn residents in time; as a
    result, a limited number of
    people do drink contaminated
    water before warning is
    issued (On average, assume
    "safe time" before
    contamination of wells
    occurs is about half the
    well sampling interval, so
    there is a 50 percent chance
    that detection and warning
    will occur in time, and 50
    percent that a delay of
    about a half sampling
    period, or 2 weeks, will
    occur.) (more likely case).
Estimated Probability
    of Occurrence

    (0.01) x (1/30)
     =3.3 x 10-*
Estimated Max. No. of
People Exposed to TCDD
        379
                                                                                     (0.90) x (0.50)
                                                                                       =0.45
                                   119

-------
                                                                 TABLE B-2
                                                  SUMMARY OF CREDIBLE EXPOSURE SCENARIOS
         Alternative  Remedial  Action

         3.   Excavate and store
              material on  site
03
CO
Exposure Scenarios Considered

(a) Workers on site are exposed
    directly to higji concentra-
    tion of TCDO because of a
    common accidnet during
    excavation (either by
    getting liquid or dust on
    skin, or in a wound, or
    inhaling contaminated dust).

(h) Tornado strikes site during
    excavation of drums, when
    trench is open, thereby
    spreading contaminated soil and
    perhaps liquids over a 2 square
    mile damage area around the
    site; people within this area
    are thereby exposed to contam-
    ination.
                                                                             Estimated Probability
                                                                                 of Occurrence
0.20 over short term
                        Estimated Max. No. of
                        People Exposed to TCDD
2-3 workers
                                                                                3.2 x 10'5 for
                                                                                  short term
                               50
                                           (c) After excavation is complete,
                                               trench closed, and all
                                               excavated waste is stored  in
                                               secure building nearby, gradual
                                               leaching of residual contamina-
                                               tion remaining around the
                                               trench occurs, with ultimate
                                               contamination of wells; people
                                               drink low concentrations of
                                               TCDD in drinking water
                                      0.95 over  long  term

-------
                                                                     TABLE  B-2
                                                     SUMMARY  OF  CREDIBLE  EXPOSURE  SCENARIOS
             Alternative Remedial Action
             3.  Cont'd.
03
I
VO
Exposure Scenarios Considered

(d) After excavation  is
    complete, trench closed, and
    excavated waste stored
    securely, a sudden sinkhole
    occurs releasing all
    residual contamination
    around trench to water
    table; wells are quickly
    contaminated and people
    exposed through drinking
    water.

(e) Workers  in full suits are
    imperfectly decontaminated
    and leave site with amounts
    of TCDD on their bodies high
    enough to spread  to other
    people off site.
Estimated Probability
    of Occurrence

 0.04 during long term
Estimated Max. No. of
People Exposed to TCDD
                                                                                                                      67
                                                                                   0.1  x 0.25 = 0.025
                                                                                   probability of escape
                                                                                   for  each worker
                                 40 workers
                                120 off site
             4. Excavate and transport
                liquids and  residues  via
                truck to Verona, MO
                (Syntex facility) for
                treatment
(a) All 5 scenarios for
    Alternative 3 above apply,
    so risk contribution due to
    these is same as overall
    risk for Alternative 3.
    Additional possible
    scenarios are discussed
    below.

-------
                                                       TABLE  B-2
                                        SUMMARY OF CREDIBLE  EXPOSURE  SCENARIOS
Alternative Remedial Action

4.  Cont'd.
I
I-
o
Exposure Scenarios Considered

(b) Truck accident occurs
    during transport to Verona,
    leading to release (spill)
    of liquid waste, which runs
    into Calton Creek because
    accident occurs just as
    truck passes over Calton
    Creek; despite spill
    contingency planning, 1 or
    2 workers are exposed; no
    members of the public are
    exposed.

(c) Truck arrives safely at
    Verona, but an accident
    occurs at or near the
    Syntex facility, releasing
    some liquid wastes which
    run  into nearby surface
    stream and ponds despite
    spi11 contingency measures;
    no workers are exposed, but
    about 10 members of public
    drink contaminated water or
    get  contaminated dust on
    their skin (blown by wind
    after spilled  liquid
    evaporates).
                                                                    Estimated Probability
                                                                        of Occurrence
                                                                                    (2.5
1Q-6)
(0.5)
Estimated Max. No. of
People Exposed to TCDD

    1-2 workers
                                                                     x  (14 miles)  x  (0.02)*
                                                                     =  3.5 x  10"7
                                                                     •coincidence factor for
                                                                      accident  to occur right
                                                                      near Calton Creek

                                                                         sane as above
                                                                                                                        10

-------
      o    The  second lowest risk is associated with Alternative  4,  which
          considers  an  additional  component,  transport  via  truck  to
          Verona.  The increase in risk of this alternative  over that of
          Alternative  3  is  small  (48.3  to  48.7)  and  is  due  to  the
          additional  possibilities  for  exposures occurring during  the
          truck transport  and  when  the  truck arrives at  the more highly
          populated  area of Verona.

      o    Installing  a  monitoring  well system  (Alternative 2)  could be
          expected to reduce  the  risk to the public  from drinking water
          to  less  than  half  its  value  without   the  monitoring system
          (Alternative 1)  (53.7 compared to 121.6), by  providing  adequate
          warning in the event groundwater contamination did occur.

      o    For  Alternative  1,  even   through  the  catastrophic   sinkhole
          scenario leads  to  the largest  number  of exposures (1,446), the
          gradual leaching scenario  contributes  more to  the risk,  since
          its probability  of occurrence is much  greater  (107.10 average
          compared with 14.46 average).

CREDIBLE EXPOSURE SCENARIOS  CONSIDERED FOR EACH ALTERNATIVE
     This section describes  the credible  scenarios which were considered
for  each  alternative  and  the  simplifying  assumptions   necessary  to
describe  the  consequences of  the  hypothesized environmental  release  of
TCDD  in  each  case.    This will provide  the  maximum  exposure  numbers  in
Table B-l.  The major parameters  whose values were unknown  and  for  which
values  had  to  be  assumed  are  identified.    Table  B-2  summarizes  the
scenarios and gives  as  separate  factors the  estimated  probability  of
occurrence and maximum  number  of  exposures in each  case.   These  are the
factors which are used  to develop the average risk number  shown in  Table
B-l.
                                  B-ll

-------
Alternative 1:  Leave Buried
     The first scenario considered is a catastrophic  geologic  collapse  or
sinkhole formation leading  to  a  rapid  release of the contents of  all  150
drums  from  the trench.   Even though a  sinkhole would  be  only about  40
feet deep (1), it is hypothesized that a  large  amount of the  liquid  waste
from  the  trench  could  still  make  its  way  rapidly  down  through  the
intervening  clay  layers  to the  water  table  about  120 feet  below  the
trench.  The  contaminant  is  assumed  to  reach the water  table  in  the form
of  a  curtain  1 foot wide.   The  aquifer  flows  horizontally in a  channel
assumed to be  100 feet wide  and  1  foot  deep.  An initial section  of this
aquifer assumed to be  50  feet  in downstream length is taken  as  the  known
volume of water which  is  instantly contaminated with TCDD  to  the  highest
possible concentration of 0.2/jg TCDD/liter of water,   or  200 ppt .   The
total  mass  of TCDD  which  actually dissolves in this volume  of water  is
limited by the known solubility  of TCDD in  water,  which  is  extremely low.
This  mass  is  2.83   x   10"^  kg  of  TCDD  (see   Numerical   Calculation
section).
     The  contaminated  water  then flows  horizontally  in  an  underground
river  assumed to  be 100  feet  wide and  1  foot  deep,  in a straight line
toward  the  nearest   drinking wells.    Ultimately,   people  are exposed  to
TCDD by drinking well  water  which has concentrations  of  TCDD  greater than
0.035  ppb.
     A mathematical  model  must be used  to  calculate  how great  a  distance
away  in  any  one direction concentrations  this  high  will  occur.    It  is
recognized that prediction  of  groundwater flow  using  standard approaches
is  impossible for  the  particular  geologic  setting of  Denny  Farm Site 1
(1,2).     Such  a   prediction   will  nevertheless  be  necessary   if   a
quantitative  estimate  of  the  risk  is to be  made.
     The  basic law  of fluid  flow  through  a  porous  medium  is  known  as
Darcy's  Law  (3).    This  principle  has   been  used  to  make  practical
predictions  of groundwater  flow rates  in  assessing leachate  production
from  landfills (3,  4,   5)  and in  analysis  of  the  impact  of  groundwater
pollution  on  human  health  (6).    By  assuming  reasonable  values  for  the
porosity and  hydraulic conductivity  of  the  karst  limestone through  which
the aquifer  flows  (1,  3),  the estimated  3% hydraulic gradient  away from
                                   B-12

-------
the trench area can be used  in Darcy's  Law to calculate a steady  seepage
or pore velocity of 401 feet/day.
     This steady  flow velocity  can  then be  used  with a one-dimensional
mass transport convection-diffusion equation  (5) to  calculate  dilution  of
the initial spill mass.  For  simplicity,  the  aquifer is modeled as  if  it
were a river, and standard dispersion equations  applicable to  a river  are
used (7, 8).  Using the equation for  an instantaneous spill of  a  mass  of
2.83  x  10~5  kg  of  TCDD   into  the   river   flowing  at  the  average
velocity of 401  feet/day,  it is  calculated that a  maximum  concentration
of 0.035 ppb will occur at a  downstream distance of  4.29 miles.
     Groundwater  flow  from  the  site  is generally  expected  to  be  within
the directional  sector between northwest  and southwest (1,  2), but  this
is not  certain  (1).    Hence,  it  must be  conservatively assumed that  all
drinking wells  and hence  all people  who  live  within a  radius of  4.29
miles  from  the  trench  may  be exposed to  concentrations of TCDD in  water
of 0.035 ppb  or  greater.   Since  the  average  population density of  Barry
County is known to be  about  25  people per square mile  (9),  a  circle  with
a  radius  of 4.29 miles  includes about  1,446  people, which is  therefore
the maximum number of  exposures  for  this  scenario  (Table  B-2).
     In  the absence  of better  information  (1, 2),  the  probability  of
occurrence  of  a  sudden  sinkhole  and   the   ensuing instantaneous  spill
scenario described  above is  assumed  to be 1   percent.   Thus  the  average
or mathematically, the expected  value of exposures  is 0.01  times 1446, or
14.46  persons, as shown  in Table B-l.
     The other  scenario  for groundwater contamination  to occur and  reach
the public  off  site  involves a gradual, continuous  release  of waste from
the trench,  with  the  liquid  assumed  to be dripping  down a  "hollow tube"
of  "piping"  in  the  karst   limestone   to  the water table  below.    This
scenario considers the event to  occur in the  present without reference to
the 9  years  the  drums  have  been  buried.  Even assuming there is a nominal
drum  leak  rate  of 5  gallons  per  hour and  only 0.3%  of the  TCDD entering
the clay  layers  at the top  comes through in solution at the  bottom, there
is still enough TCDD  reaching the water table to  saturate  the water.   In
othor  words,  assuming the  underground  aquifer  is the  same  river  flowing
with  the  seepage  velocity of 401  feet/day as before,  the  effective rate
                                   B-13

-------
of mass spill of TCDD into  this  river  is  limited only by the volume  rate
of river flow and  the  known maximum solubility  of  TCDD  in  water  (0.2 ^ug
TCDD/liter  of  water).    The rate  of solution  is  not controlled by  the
supply  rate of  TCDD in  organic  liquid  wastes  dripping down   from  the
trench, and  the  effective  rate of mass spill of TCDD  into the  water  is
thus  computed  to  be 2.58  x  10~9  kg/sec.    The  concentration  of  TCDD
in water at  the  first point of contact with  the  water table  is  limited  to
200 ppt by  solubility.
     Using  the  equation  for  downstream dilution   in  a  river  from  a
continuous  spill at this  rate  (7),  it   can  be  computed that  a maximum
concentration  of  35  ppt  of   TCDD  occurs  in  the   water  at  a  distance
downstream  of about  1.23 miles.   Taking the  distance to  define  a circular
zone of influence  as before,   the  maximum number of  residents  exposed  is
119, assuming a  population  density of 25  people/square mile  (Table B-2).
     The probability of occurrence  of  this  gradual leaking scenario  is
assumed to  be  quite high,  say  90 percent.   Hence,  the  average  (or  in
mathematical terms,  expected) number  of  exposures   due  to  this  gradual
leaking case is  0.90 times  119,  or 107.1  (Table  B-l).
     Note that  during  the  remaining 9 percent of  the time, it  would  be
necessary to assume  that  no release of TCDD  from the trench occurs which
results in  groundwater  contamination.  This  is  the  case  in  which the clay
layer  beneath  the  trench actually does  retain  the  waste and  keeps  TCDD
from entering the water  table  (2).   This  case is not an  exposure scenario
since  no exposures occur.
     In summary, there  are  actually three  mutually  exclusive  scenarios
assumed possible for Alternative 1:
                  Scenario                    Estimated         Max, no. of
                                         percent  probability    Exposures
o Gradual release to water  table                 90                 119

o No release  (clay  retains  TCDD)                  9                   0
o Catastrophic  (instantaneous  release
  to water table  through  sinkhole)                1               1,446
                                   B-14

-------
No  spread of  TCDD  away  from the  site  via  atmospheric  transport   is
considered possible  in Alternative  1  since  the  trench  remains  closed.
Even if a tornado strikes the area, it is assumed  that  the waste  will  not
be disturbed since the trench  is  covered  with a plastic cover and  2  feet
of clean soil.

Altenative 2;    Leave Trench  as  is. But  Install Groundwater Monitoring
System
     Alternative  2  is geologically  the  same as  Alternative 1,   with  the
addition  of  a  warning  system.    Thus,   the   possible  scenarios   for
contamination of  drinking water  are  the  same as  for Alternative  1,  i.e.,
rapid  release  through a  sinkhole or  gradual continuous  leaking  of  the
drums.  The probabilities  that  these  two  types of release will  occur  are
also  the  same  as they were for  Alternative 1,   namely  1  percent  and  90
percent,  respectively.   However,  there  is   now  the  possibility  that  the
sampling of the monitoring  wells  may provide adequate warning to some of
the residents not to  drink  the well  water if water  contamination occurs.
As a  result,  the  probability of  exposures  occurring,  the maximum number
of  possible  exposures,  and  therefore  the risk   (average  number   of
exposures), are all less than  those  for Alternative  1.
     To  estimate  the probability that the  well  monitoring system  will
warn  the  residents  in the  event  of  a  rapid  release,  it is  assumed  that
well sampling is  done once  a month.   If  the  time  between  the  release  and
the arrival  of contamination  at  the  wells  is  about  1  day,  sufficient
warning can be given  only  if  the  release  occurs within  1 day  just before
a  well sampling  time (neglecting  for simplicity the  time required  to
analyze the well  sample).   Thus,  about 1/30  of  the time a  warning will be
issued in time and no exposures will occur.   On  the  other  hand,  the worst
case  would  occur  if  the  sinkhole formed within 1 day  after a  sampling
time.   This occurrence would potentially  lead to the maximum time elapsed
between time of well  water  contamination  and its detection  (29 days),  and
hence  the greatest number  of  people  would be potentially  exposed to  this
drinking water before a warning is issued.   This worst  case  warning delay
                                  B-15

-------
also has a chance of roughly 1/30 of occurring,  if the time  of  occurrence
of the sinkhole is random.  Since the geologic occurrence of the  sinkhole
and  the  well  sampling are  independent events,  the probability of  the
joint  occurrence  just  described  is  0.01  times  1/30,  or  about  3.3  x
10~4 (Table B-2).
     Since it has already  been  assumed  that the groundwater  flows  at  the
seepage velocity  of  about  400  feet/day, the leading edge of contaminated
water  from the  assumed  instantaneous   spill  would  reach  a  downstream
distance of about 2.2 miles after 29 days.  The  maximum  number  of persons
exposed to concentrations  of TCDD  greater  than 35  ppt  in  well  drinking
water can be no more  than  the  total population within this  distance  from
the  site in any direction.  Using the known average  density  of  population
in  Barry  County,  25 people/square  mile (9),  this  total   population  is
about 379 people  (Table B-2).
     The  other possibility  for  well  water   to  become  contaminated  is
through the  gradual  release of wastes  from the leaking drums,  resulting
in a continuous  spill  into the underground river  (probability  assumed to
be 90 percent).   In  this  case, the average warning delay would  be  about
half the well sampling  interval, or 2 weeks.   Thus,  there  is roughly a 50
percent chance  that  detection and  warning  will  prevent  exposures,  while
the  other  50  percent  of  the  time,  a delay of  about  2  weeks  will  occur
before residents  are warned.   At the constant flow  velocity assumed  (400
feet/day), the front of the pollutant will  reach a distance  of  about 1.23
miles  downstream  from  the  site.    Therefore,   the  maximum  number  of
exposures  in  this event  will be  no greater  than  the  total  population
within the distance, which  is  about 119 people.   This  is the same maximum
number  of exposures  as would  occur if no  warning were   provided  (see
Alternative  1);  however,   the  probability   of  this  case  occurring  is  now
only 0.90 times 0.50,  or 0.45  (Table  B-2).
     For Alternative 2, there  are no  possibilities for worker exposure or
for  any above-ground spread of contaminant.

Alternative 3;  F.xcavate and Store  Contaminated  Material On  Site
     For  Alternative 3,  there  are more possibilities  for   exposures  of
humans to TCDD to occur than  for either of  the previous  two  alternatives.
                                   B-16

-------
Because of the excavation,  the  workers  could  be exposed directly  to  high
concentrations of TCDD  as  a result of  an  accident  during the  excavation
operations.  Workers could get  liquid waste or  contaminated  soil  directly
on their  skin  or inhale contaminated  fine soil  particulates.   Types  of
possible accidents envisioned include one worker  inadvertently  striking a
co-worker with a pick or shovel, thereby penetrating his protective  suit,
or  a  worker  losing  a  glove.    Workers   would  be   trained   to  follow
procedures  to  minimize  chances for  such   accidents,  and communications
with and between workers in full encapsulated suits would  be provided.
     The total number of workers on site at any one shift  is estimated  to
be about  42  (see Section 7), with  19  of these in  full protection  suits
inside  the  fenced  area.  The  workers   farthest from  the  trench,  outside
the  fence  (about  17),  will  have  at  least  coveralls   and   face-mask
respirators  with  filters,  which   are  efficient  enough  to  remove  any
respirable clay  particles which might be contaminated  with TCDD.
     It  is  assumed  that  some  form of  dust  control  such  as  calcium
chloride will  be used  during excavation  to keep the  amount of  airborne
contaminated soil particles to  a minimum.   Most of the  excavation of the
highly  contaminated  soil  intermingled with  the drums will be  done  by
hand,  which  will not  have  as  great a  potential  for   generating  airborne
clouds  of contaminated  dust  as  would  the excavation of  larger  amounts  of
soil by heavy  machinery.   This  machine excavation phase would  begin only
after  the  drums  themselves and highly  contaminated  soil  were  removed  by
hand,   and   the   soil   remaining   would   therefore   not  be   as   highly
contaminated.  Even  if  the dust-control measures were to fail,  the site
is located in  a  wooded  area,  and the trees  surrounding the clearing would
effectively  prevent  long-range  transport  of a dust   cloud  off  site,  so
that off-site  exposures  to  airborne contamination are  prevented.
     Nevertheless,  there  might be a  20  percent  chance  that   2  or  3
workers  might   be  involved  in   accidents   (not  necessarily   the  same
accident)  which  result  in  their  direct  exposure.    That  is,  it  is  not
credible that, for instance,  10 or  more workers could  be exposed.
     Another  possible  scenario is  that a  tornado  could  strike  the site
during  the  exact  time  when  the  trench  is   open,   thereby   spreading
contamination  over a wide area.  The probability  of such a tornado strike
                                   B-17

-------
can be  estimated  using available historical  data  (11) on occurrences  of
tornadoes  at  about  3.2  x  10"^  (See  Numerical   Calculation   section).
The consequences of a  tornado strike would actually  be limited  in  area  to
the average  tornado  damage  zone, which  is known  from historical  data  to
be about  2  square miles (11).   The  number of  people  off site who  might
conceivably  be exposed directly to high  concentrations of  TCDD in  the
event of  such  a strike would be  approximated by the  resident  population
within  a  circular area this  size (about 0.8  mile radius) centered on  the
site, or  about  50 people.  (Storm casualties  are not  considered.)
     Even  if no  exposures  occur during the  1  to  1.5  month  excavation
period,  residual  TCDO contamination  remaining in  the  soil  around  the
excavation may  still  reach  groundwater and thereby contaminate  wells.   A
rapid release  may  occur following the  formation  of a sinkhole,  or  there
may be  a  gradual  release  fed by  leaking drums  in  the trench.   These  two
types of  release  are  somewhat more  likely to occur than  in Alternative 1
because  of  the  geologic  disturbance   created  by  the  excavation   (2).
Therefore,  the probabilities of  occurrence  are now  taken  as 95  percent
(compared  to 90  percent)  for  the  sudden  sinkhole,  and A  percent  (as
compared  to  1 percent)  for the  continuous  release  case (Table B-2).
     To estimate  the extent  of  the exposures  that  could  occur through  the
drinking  of  TCDD-contaminated  well  water for either  of these cases  of
residual  release,  the residual   source  strength of TCDD  remaining around
the trench after  the  excavation must be estimated.  This residual amount
will depend  on  both  the cleanup level  that is decided upon as  a stopping
point for soil  excavation and on the extent  of spread  of TCDD in the soil
in lower  concentrations beyond  this  level.
     However,  a representative  calculation can  be  made  if it  is  assumed
that the  source strength  is now  effectively  weakened to the extent  that
the residual amount  of TCDD which  actually  dissolves  in the  groundwater
is conservatively 1/10 of that  originally  assumed.   Thus, for the case of
the  sinkhole  formation and  subsequent  instantaneous  spill,  the  total
spill mass   is  now  taken  to be  only  2.83 x  10~"  kg  of TCDD  (compared
to   2.83   x   10~5    kg   TCDD  in    the   calculations   for   previous
alternatives).  Assuming  a  spill of  this  amount  into the  same  river  as
before   (average   seepage   velocity  of   400  feet/day),  the   greatest
                                  B-18

-------
downstream distance  at which  a concentration  of 0.035  ppb of  TCDD  in
drinking water  occurs  is  about 0.93  miles.    At an  average  population
density  of  25  persons/square  mile,  this distance  potentially  includes
about 67 residents (Table R-2).
     For the  other  scenario  of gradual release, the effective  continuous
mass spill rate  of  TCDD into the water table is  taken  to be 1/10 of  its
value  previously,  or  2.58  x  10~10  kg  TCDD/sec.     The   corresponding
downstream distance  at which  the  maximum concentration  of  0.035 ppb  of
TCDD  in  water  occurs  is  1/10  of  the previous  distance,   or  649  feet.
There are essentially  no drinking wells within  this  distance of the  site,
and therefore, there  are no  exposures  for  this  scenario  (Table  B-2).

Alternative 4:  Excavate and Transport Both Liquids  and  Residues  Via
Truck to Verona, Mo.
     Alternative  4  includes  the same  possibilities  for exposure  to  TCDD
as  Alternative   3,  and  the  contribution  to  the overall   risk  of  this
alternative  due  to all these   scenarios  is  the  same  as  the  total  risk
computed  for  Alternative  3.     However,  there  is  now  an  additional
contribution  to risk  because of  the opportunities  for  exposure  of workers
and members  of  the public.  A truck  accident  resulting  in  a  release  of
some  of  the  liquid  wastes  from the  bulk  tank carrying  them  may  occur
either  on   the  highway during  the  trip to   Verona  or  at  the  Verona
facility.
     The probability  of a  truck  accident  is known from historical data to
be  about   2.5   accidents  per  million   truck-miles,  or   2.5   x   10~°
accidents per truck mile  (12).  Further,  the  chance of  such an  accident
resulting in  a  release or  spill of hazardous  material,  if  the  truck  was
carrying such a cargo,  is  about  0.5,  given the  occurrence of the  accident
(12).  The  length of  the  highway route from Denny Farm Rite 1 to Verona
is  about 14  miles  (north  on Highway W,  west  on Highway  Z to  U.S.  60,
and  back east  to Verona).  Hence the  probability  of  a truck  accident
resulting in  a  spill  somewhere over  this  route can  be calculated  as  the
product of the above  factors.   The  worst  case would be  that  in which  the
accident occurred  just  as  the  truck was crossing a stream.   The only such
                                  B-19

-------
crossing on  the route  to  Verona is  that  of Highway VV  at  Calton  Creek
just  north  of  the  site.    It  is  assumed  that Calton  Creek  could  be
contaminated  if the  accident  occurred within an  eighth  of  a mile of  the
crossing.   The chance  that  the accident,  if  it occurs  at  all over  the
14-mile route, will  occur  within this quarter  of a mile, is roughly 0.25
mile/14 miles, or 0.02.  This  coincidence  factor  would  further  reduce the
probability  of this  scenario  (See Table B-2).
     Even  if  a truck accident  were  to occur, however, it is assumed that
mitigating measures  would  be  applied  to minimize  exposures  resulting from
the  spill.    Contingency measures  could include  having properly  trained
and  equipped workers  travelling with  the  trucks or  stationed near  the
Calton  Creek bridge  before   the  transport  of  the waste  begins.   As  a
result,  it  could  be  assumed  that  no members  of  the  public  could  be
exposed; however,  as  with the  possibility of  accidents  in  the  trench
during excavation, it  is  possible  that I  or 2   workers could  be  exposod
(Table B-2).
     The other  possibility remaining  is  that  the  truck arrives  without
incident   at  Verona,   but  an  accident   occurs  after  arrival.     The
probability  of occurrence  of  this  would be  the  same  as for the  accident
on the highway.  However,  because of  the proximity  of  the greater  numbers
of  people   to the   accident   (the  Southwest  Local  Government  Advisory
Council projects  a  1980 population  of 680  for  Verona),  it is  credible
that  despite spill  contingency  measures,  a  liquid  spill  could  reach
surface  streams  or  ponds  in  the  area.    As many  as  10 members  of  the
public could  thereby be exposed.  Exposures could  be either by  drinking
water  or  by  direct  skin   contact  with contaminated  water   or  wind-borne
dust after the liquid  spill evaporates.

Additional Risk Due  to  Decontamination Accidents
     Alternatives  3   and   4  involve  trench  excavation  and necessitate
decontamination  of  the trench  workers  wearing  full  protection  suits
following oach working  interval.   There is thus  the possibility  that the
personnel  decontamination  procedures  may  be   less  that   completely
effective,  and  some  workers  may be  directly exposed  to TCDD.    If such
exposure is  not observed  by  the  supervisor,  such  a  worker  could  then
                                 B-20

-------
leave  the  site with high  concentrations of  residual  TCDD contamination
still  on  his  body  or  clothes  and   could   subsequently   spread   this
contamination  by direct contact with other members  of  the  public  off  site
(e.g.,  his  family).    This  scenario,  which  might   be   called  "decon
accidents,"  could   lead  to  a significant  number  of   exposures  of  both
workers and public  and therefore  increases the  risk of Alternatives 3 and
A.  The  following  paragraphs describe how this  risk can be  estimated  by
making several reasonable simplifying assumptions.
     Decontamination  of workers  in  full protection   suits  may  not  be
completely  effective because  of  both  (1) human error  in following the
prescribed  decon  procedures  and  (2)  the purely  physical  limitations  of
reducing the amount  of TCDD  contamination remaining on the  outside  of the
suits  and  equipment, even  when  the  procedures  are  carried  out  without
obvious accident due to human  error.  Human  error is especially likely to
occur  during  the  early  stages of  work, before  extensive experience  at
carrying out  the  decon  procedures  is  gained.   Workers could  be  exposed
directly to liquid wastes  by skin  contact  or  could  inhale  contaminated
particulates,  if,  for  example,  they  rush through  procedures  because  of
panic  or  if  the   contamination   is  not  visually  obvious.   It  is  also
possible that  the  supervisory  personnel  observing the  decon  procedure may
not always  adhere  strictly  to the specified  safety procedures  or  may not
not Lee an  opportunity  for  inadvertent  worker  contamination  in the  event
the worker  has a  minor  accident such  as mentioned  above.   It  is  less
likely that  a  worker  might  inadvertently  take off  site  with him  some
piece  of his  external  suit  or  equipment (e.g.,  a  camera)  which was not
fully decontaminated and which should have been  left  in the  decon area.
     In  order  for  worker  exposure  occurring  during  decontamination  to
ultimately  lead  to off-site  exposure  of other  people, three  successive
events  must   happen:     (L)     the  worker  must   become   accidentally
contaminated himself, as a result of an  accident  or incomplete  washing of
his  suit,   and this must   further  go  unnoticed  or   unchecked   by   the
supervisor; (2)    the  level  of  residual contamination  of the escapee's
body must he great  enough  and in  such  a physical form that  contamination
C.TII he spread  n»adily to another  person off  site via  direct  contact; and
(  1)  the  worker musf come  Into  direct  contact  with  one  or  more  other
                                 B-21

-------
people off site.  Tho likelihood of  each  of theso events, as wf:l 1  as  the
average number of exposed  people  involved at each step, can  be  estimated
as follows.
     First,  consider the  likelihood  of  a worker  escaping  decon  with
undetected contamination.  Taking  account of the possibilities  discussed
above, it  is  reasonable to assume  that  there is as high  a chance as  50
percent  that   a  given  worker,  especially  an  inexperienced  one, might
encounter  some   difficulty   or   accident   during  the   decontamination
operation  and  become contaminated  to  some  degree.  However,  most of these
will be of minor  consequence, and most  incidents will be obvious enough
to be  noticed by  the  observer,  so  that  more  intensive  efforts  can  be
immediately applied  to  counter the  accident (e.g., washing off  a minor
splash onto skin).   Assume that only  10  percent  of the workers entering
the decon  procedure will both suffer  such  an accident  and  go unnoticed by
the observer  and  hence  leave the  site with some  level of  residual  TCDD
still on their bodies.
     However,  in  most  of  these cases of  "escape",  the worker  may still
not be  highly enough contaminated to cause  additional exposures  of  the
people he  comes in contact with off  site.   The  great affinity of TCDD for
soil particles and human  skin,  as  compared  to other substrates  or water,
is  a  factor   limiting  the  ease   of  further  spread   of  TCDD  from  the
contaminated  escapee.   For concreteness,  suppose that   only  1  in 4, or 25
percent, of the escapees are  so contaminated that  they are able  to spread
contamination  to another person upon  contact.
     Finally,  suppose  that  as he  leaves   the  site  each  worker has  a
certain definite chance of coming  into direct contact   with  0, 1 ,  2,  or 3
people off site.   (For  simplicity,  assume  that  the chance  of  contacting
more than  3 people is negligible.)   Assume  further  that each such contact
leads  to  the  other  person being exposed  to residual  TCDD.   Suppose  a 5
percent  chance  of   not  contacting  anybody,  a  70  percent  chance  of
contacting 1   person, a  20  percent  chance  of contacting 2  people,  and  a 5
porcpnt  chanro of  contacting  3  other people.    Therefore, the  average
number of  secondary off-si to  exposures caused by  each  highly contaminated
worker who has escaped  decon  is nbout  1.25  persons.
                                  B-22

-------
     To  estimate  the numbers  of exposed  people corresponding  to  these
assumed  probabilities,  consider  that  at  any  one   shift  there  will  be
approximately  20  workers  in  full  protection   suits  who  will  have  to
undergo  the  decontamination  procedure.   On  average,  about  10 percent  of
these, or 2 workers per shift (4 workers per day), escape decon  and  leave
the site  with  some  residual contamination.   However,  only  1  of  these  4
workers  is  actally  highly contaminated  enough   to be  capable of  causing
secondary exposures off site.   On average,  this  1 worker  per day  causes
1.25  secondary exposures  per  day.   Assuming  a rough  duration  of  the
intensive hand  excavation  phase of  about  20 days,   this  means  that  over
this short term an average of 20 workers have become exposed  to  this high
level, have escaped decon, and  have  caused 20 times  1.25 or  25  secondary
off-site exposures, for a total of 45 exposures.
     The  worst possible case  could  be  envisioned   as  follows:    On  the
first  shift,  all  20  suited  workers  become  contaminated  and vet  escape
decon;   all  20   are  highly  enough  contaminated   to  cause   secondary
exposures;  and finally,  each  of  these 20  thereby  exposes  the  maximum
number of 3  other people  off site.   Thus, 20 workers  are  exposed  and  60
secondary off-site  exposures occur,  for  a  total of 80  exposures  during
the one  shift.  If  this worst  case  persists  and also happens during the
second shift,  then during the whole  day,  a maximum  of 40 workers  and 120
off-site  people have  been exposed,  for  a total  of  160  exposures  (Table
B-2).
     Repetitions  of  this  worst  possible event  over  shifts on  successive
days would  not really  lead  to  new  exposures.    The  same  2  crews  of  20
fully suited workers would be assumed to return  for  the 2  shifts the next
day, and the set  of secondary contacts of  a  given worker would  likely not
change greatly  from day to day.
     For any individual worker,  the  probability  of the worst  case  assumed
.ibovp  would be  O.I  times  0.25  times  0.05  or 1.25  x  10~^.    These
factors  are,   respectively,  the  probability   of   escaping   decon,  the
probability  of   being  highly   contaminated,   and   tho  probability  of
contacting 3 secondary  people.   Thus,  the  probability of the  worst  case,
where every  one  of  the  20  crew members  is  assumed  to  cause 3  off-site
                                 B-23

-------
exposures,  is  the above  value  raised to  the  20th  power,  assuming  that
thhe workers are  independent.   This  probability is very small,  since  the
worst case  assumes a multiple coincidence of individual worst  cases.

Total Exposures Shown in Table B-l for All Scenarios
     The  average  numbers  of  exposures  of  both  workers  (20)  and  of
secondary  off-site members  of  the public  (25) estimated  above for  the
20-day  duration  of the  excavation  period must  be added  to  the  average
numbers of  exposures in each  category (on site  and off  site) due to  other
possible  exposure  scenarios,  described  earlier.     For  example,   for
Alternative  3,  the average  number of  workers  exposed during  the  short
term will  be 0.6  (average from accidents  occurring  while  working in  the
trench) plus  20   (from decon  accidents  described  above),  or  20.6.    The
average  number  of public  or  off-site  exposures  is  similarly  1.6  x
10~3  (from  the   tornado   strike  scenario)  plus  25  (secondary  contact
due  to  escaped contaminated  workers  as above), or  still  essentially  25
(Table B-l).  Similar average values  apply for  Alternative 4,  except  that
an average  of 1.0 replaces the value 0.6 above.
     The maximum  possible  numbers  of  exposures  shown in each  category  in
Table B-l  are similarly  the sums  of  the  maximum  numbers  estimated  to
occur  for   each  of the  several exposure  scenarios.   For  example,  for
Alternative  3,  the maximum  number of  workers  exposed during  the  short
term is shown  as  3 (due  to accidents  during work  in the  trench) plus  40
(the maximum due  to decon  accidents), or  43  workers.  The maximum number
of off-site  public  exposures is 50 (from  the  tornado scenario)  plus  120
(secondary  exposures due to escaped contaminated workers),  or  170 maximum
total.
     Similar  additions   are  performed   and   shown  in  Table   B-l   for
Alternative 4:  For on-site  exposures  there  is  a maximum of 5  (estimated
for accidents during working—3  during  work in  trench,  another  2 due  to
the truck accident scenario)  olus 40  (maximum due  to  decon  accidents),  or
45  total.    For   off-site  exposures,   the  maximum shown  is:    50  (from
tornado scenario  during  open trench  phase),   plus  10 (due   to a  truck
accident occurring near  the  populated area of  Verona), plus 120 (maximum
secondary  contacts  of  the 40 escaped contaminated workers  above),  for a
total of 180.
                                 B-24

-------
NUMERICAL CALCULATIONS
     This section presents some of the calculations made  and  methods  used
in the course of the risk analysis.

Formulas Used to Compute Maximum Concentrations  in River  Flow
     Table B-3  summarizes  the formulas  for  non-tidal river  flow  used  to
make the calculations of concentrations  of TCDD  downstream of the  assumed
spill  into  the  water table  (7, 8).   The diffusion  coefficients  used  in
these  formulas  are  those given in Reference  7.

Instantaneous Release (Sinkhole Scenario) Spill  Source  Strength
     The total  mass of  TCDD released  from  the trench  in  organic  liquids
is  26.4  Ib  =   12.0  kg  =  total  amount  in  all  drums  (see  separate
calculation).   However,  because of  the limited  solubility  of  TCDD  in
water, only  a small fraction of  this amount can actually dissolve in the
water  when it reaches the water table.
     Assume  that  the  initial volume of  water  in the aquifer beneath the
trench into  which  the  spill falls is 100 feet wide,  1  foot  deep,  and  50
feet long.

100  ft x 50  ft  x 1  ft =  5000 ft3 =  141.6 m3  =  1.42 x  105  1 of water

Since  the  maximum  solubility  of  TCDD in  water  is only  0.2 ug TCDD per
liter  of water,  the amount  of  TCDD dissolving in  the  above  volume  of
water  is

     M  =  (1.42 x lO5 1 water) x (0.2 jug TCPD  per  1  of  water)
       =  2.83 x  lO^yag TCDD
       =  2.83 x  10~5 kg TCnn

     This  is then  taken  as  the total mass of an  instantaneous  spill  in the
formulas in  Table  B-1.
                                  B-25

-------
                                                   TABLE B-3


                                     FORMULAS FOR MAXIMUM CONCENTRATION


                                             IN RIVER DISPERSION*
         INSTANTANEOUS SPILL
                                            max
                                                  NEAR FIELD


                                                         2M
                                                           (4lt    )3/2Je-7-e-
                                                              max    N x y z
                                                                                       FAR FIELD
                                                                                  max =
                                                                                                      M
                                                                                                  max
00
I
NJ
Oi
         CONTINUOUS SPILL
                                           max
                                                        H
                                                       (e e
                                                         X
C    =   M
 max   	
        UA
for large t.
                                                                                            max
         MEANINGS OF SYMBOLS;


         C    = maximum concentration of pollutant at downstream distance x (at midstream, on water surface),
          max
                in
                                                                                     X/U,  in sec
            x = downstream distance from spill, m

                time after spill when maximum concentration occurs at x ,t
         "max   	 	  "* "                                           max

            U = average river flow velocity, m/sec
                                                                     2
            A = cross-sectional flow area = width x depth of river, m

            M = total mass of pollutant in instantaneous spill, kg

            M = constant mass spill rate of pollutant for continuous spill, kg/sec
                                                                         ^                                  \
E, e ,  e ,  e  = turbulent diffusion coefficients appropriate for river, m /sec (values given in Reference  13J
            *See Reference 13

-------
Gradual Leaking (Continuous Release) Spill Source Strength
     Assume the drum leak rate is 5 gal/hour of liquid organic wastes.
Taking the density of the waste to be 1.2 g/1, this  is

    5 gal x 1.2 g/rol x 3.785 x 103 ml/gal = 2.27 x 104 g
                                          = 50.07 Ib  organic  liquid  waste/hour

(Incidentally,  at  this  rate,  the entire  8,250  gallons  of  liquid  waste
would be spilled after 1,650 hours, or about 2.3 months.)
     Assuming  a maximum  concentration  of  TCDD   in  these  waters  of  319
ppm,  the total  amount  of  TCDD  contained in  this  volume  of  water  is

     (2.27 x 10~2 million g waste) x  (319 g TCDD  per million  g waste)
                                               =  7.24 g TCDD
                                               =  1.60 x 10~2  Ib  TCDD

Thus,  the  effective rate of  TCDD leaving  the  trench in  the liquids  is

1.60 x 10~2 Ib/hr =  7.26 x 10~3 kg/hr =  2.02 x 10 ~6 kg TCDD/sec

However,  in  this case,  assume that  both  clay adsorption  in the  layers
passed by the  liquids  as they  seep vertically  downward to the water table
and  the  minimal  solubility  of  TCDD  in  water  reduce  the  effective
rate  of  mass   entering  the   water  table  as  a   spill,   as   follows:
     First,  assuming a 99.7%  retention  factor  for  adsorption of  TCHD by
tlie clay, the  effective  rate  at  which TCDD arrives  at the  water table is
only 0.3% of  the above,  or 6.06 x 10~9 kg TCDD/sec.
     Secondly,  flie  solubility of TCOD  limits  the  rate  of  dissolving:
Effective  mass  spill   rate   M   =   (river  water   volume  Flow  r.ite)  x
(Solubility of  TCDD).
     Assume  river  dimensions;  contaminant  arrives  at  water  table  in
"rain" or "curLain"  100  feet wide:
                                  B-27

-------
       100 feet wide = 30.48 m( cross-sectional  flow area
         1 foot deep =  0.3 mi       A = 9.14 m2
The average river velocity is the seepage velocity calculated  using
Darcy's Law (see separate calculation).
                        U = 401.1 feet/day
                          = 4.64 x 10~3  feet/sec
                          = 1.41 x 10~3  m/s

Thus, volume flowrate of river is

    Q = UA
      = (1.41 x 10~3 m/sec) x  (9.14 m2)
      = 1.29 x 10~2 m3 of water/sec

Hence

      M = (1.29 x 10~2 m3 water/sec) x  (103  1/m3)  x  (0.2 yug  TCDD/1  water)
        = 2.58yig TCDD/sec
        = 2.58 x 10~9 kg TCDD/sec

This value was then used in the continuous  spill  river  dilution equations
in Table B-3 to calculate downstream concentrations  of  TCDD.

Calculations of Downstream Concentrations
     The equations in Table R-3 yield mass  concentrations  of TCDD in kg/m3
To express these as  percent  by weight  of water,  they are divided  by the
mass  density  of   water  (103  kg/m3)   and  then   the   power  of   ten
adjusted so  as  to  express the result  in ppm, ppb,  or  ppt,   depending  on
the magnitude.
                                 Tl-28

-------
Calculation of Seepage Flow Velocity for Horizontal Movement
       For karst limestone, assume

                         porosity n = 10%
           hydraulic conductivity K = 104 gal/day/ft2
                                    = 4.72 x  10"1 cm/sec

       These values are within the range of values given  in  the  literature
literature (3) for karst limestone and are likely to  be  reasonable  for the
area of Denny Farm Site 1  (1).
       The hydraulic head  gradient away  from  the  site  is  about  a 50-foot
drop over a distance of a  third of a mile (1760  feet),  or
              = (-50 ft)/1760 ft = -0.03  (about  3%  gradient)

Hence, from Darcy ' s Law  (3, 5), the velocity  is

       v = (-K) x (AH/AX)
         = -(104 gal/day/ft2) x (1 ft3/7.48 gal)  x  (1  day/8
         = 4.64 x 10~4 ft/sec   (Darcy  velocity)

Hence the seepage velocity  is
         Vs
            =  (4.64 x 10~4  ft/sec)/0.l
            =  4.64 x 10~3  ft/sec
            =  1.41 x 10~3 m/sec
            =  401.1 feet/day
                                   B-29

-------
Calculation of Total Amount of TCDD at Denny Farm Site 1

A.  Assumptions

       1)  150 55-gallon drums, each  full  (known to  be conservative)
       2)  Average density of organic  liquid wastes  in drums
             =1.2 g/ml
       3)  All drums contain TCDD at  the highest concentration  measured,
           which is 319 ppm.

R.  Calculation:
              150 drums  x 55 gal/drum  x  1.2  g/ml  x (3.785  x  103 ml)/gal
                        = 3.747 x  lO^grams  (total  mass  of  liquid waste)
                        = 37.47 million  grams

        (37.47 million  grams) x  (319  grams  of  TCDD per million grams liquid)
                  =  11953  grams  of  TCDD

     Dividing by 453.6  grams  per pound,  the total amount  of TCDD is 26.4 Ib.
     Note:  This  is  consistent with a recent  report that  the total amount
of TCDD contained in the 4,300 gallons  of  waste  at the Syntex plant in
Verona, Mo. prior to photochemical  oxidation  was 13 pounds  (14).
     There  is  reason to believe  that  the  density of  the liquids  stored in
the  drums  at  Farm Site 1 may be  about  the  same  as that  in  the Syntex bulk
storage tank.   In  the above calculation, the  assumption  that  all  drums are
full .means  a  total  liquid  waste  volume of  8,250  gallons.   According to the
above  calculation,  half of this  volume of liquid, which is  4,125 gallons,
or  approximately  the same  volume as the  Syntex storage tank  (4,300 gal),
would  contain  13.2  pounds  of  TCDD.   Therefore, the  assumption   of  an
average liquid  density  of  1.2 g/ml  seems reasonable.
                                  B-30

-------
 Calculation of the Safe Concentration of TCDD in Drinking Water
      Once  a given dose of TCDD  is  taken as a  "threshold"  or "no effect"
 level for  the human  body  for  oral  exposure,  the  corresponding "safe"
 concentration level of TCDD in drinking water can be calculated.  This  is
 the  concentration  in  water  which,  when  ingested,  will  lead  to   the
 establishment of the given  threshold  dose  within the  human  body.   To  do
 this, it is necessary to take into account three factors:

    o  The  average ingestion rate of drinking water of  a person
       assumed to be 2 liters per day;

    o  The  average body weight of a person taken to be  70 kg;

    o  The  average retention efficiency  for TCDD ingested in  drinking
       water taken for simplicity to be  100% (that is,  100% of all
       ingested TCDD in drinking water is assumed to  be delivered  to
       the  body as dose).

      For simplicity, the  question  of possible  bioaccumulation of TCDD  in
 the human  body from drinking water is not considered here.
      If 0.001 yjg/kg/day (i.e.,  1 ppt  of body  weight  per day) is  taken  as
 the   threshold   concentration   in   the   human   body,   CD>    and    cw
 denotes the corresponding concentration  in drinking  water  averaged  over a
 day, then:

      cb =  (2  liters of water) x cw x  1.0 x 106/70 kg

      (•  =  threshold concentration in  body, averaged  over a day,  in
      C  =  corresponding concentration in drinking water, g/1
270 kg   =  average body weight
  liters =  average amount of water drunk  per day
 1.0     =  assumed retention efficiency  factor
                                  B-31

-------
 Solving  the  above  for  Cw yields  C^, =  3.5  x  10~8 g/1,  or C^, = 3.5 x 10 2
Jig/kg  of water, which  is  0.035  ppb or 35  ppt  in water, averaged  over a
 day.
     For comparison,   it  is  worth  noting  that  the  maximum  possible
 concentration  of TCDD  in  water  is 0.2 ^ig/kg = 0.2  ppb =  200  ppt, since
 the  solubility  of  TCDD in water  is 2  x 10"^ g/1.
     The value  of  0.001 jig/kg/day above is  being considered as a possible
 practical drinking water standard and  is considered  by some  to  be a  "no
 observed effect level" (NOEL) for oral exposure  to TCDD based on  feeding
 studies  with rats  (10).
     To   allow  for   uncertainty  in  the   assumed   threshold   dose  Cjj
 above,  a safety factor  of 100 could  have  been introduced  to extrapolate
 the  animal data to  humans,  so  that  the  threshold level in  humans could
 instead   be  assumed  to   be  10"^  jsg/kg/day.    The  corresponding  safe
 concentration   in  drinking water  sould  then  be  1/100  of  that  computed
 above,  or only  0.35 ppt in water, daily average.

 Calculation  of  Probability of a  Tornado Striking the Site
 1.   Denny Farm  Rite 1  is located in a 2-degree quadrangle defined  by
     92°  and  94°W meridians of longitude,  and 36°N and
     38°N parallels of  latitude.

 2.   The  area A  of  this 2-degree  square is approximately

              A  = (109.5 miles longitude)  x (138.8 miles latitude)
                = 15,198.6 square miles

 3.   The  total  number of tornadoes that have first touched ground within
     this 2-degree  square has  been tabulated historically (11):

              T  = 111 tornadoes
         over N  = 46  years (1916-1961)
                                  B-32

-------
    See  Figures  15A,  16A,  or  16B  in  Reference   11.    On   average,
    T/N =  111/46  = 2.413  tornadoes per  year  have  occurred  within  this
    2-degree square.

4.  The average area D damaged by a tornado  is 2 square miles  (11,  p.  31)

5.  The probability per  year of a  tornado  striking any particular  point
    within  the 2-degree  square  (in  particular, Denny  Farm  Site  1)  is
    therefore  (11, p.28):

        p = (T/N) x (D/A)
          = (2.413 per year) x (2/15,198.6)
          = 3.175 x 10~4 per year

    This  assumes  that  the  Denny  Farm  Site  1  is  effectively  a  point
    target,  i.e.,  its  area is  small compared  to  that  of  the  tornado
    damage zone (D = 2 square mi.).

6.  Over  an extended  period,  say  50  years, the probability  of  at  least
    one tornado striking the site is  therefore:

         1 - (1 - P)50 = 50 p
                       = 0.0158, or 1.6 percent

7.  For the possibility  of  a  tornado  striking the site during the  period
    when  the  trench is  open  for excavation  (Alternative  3),  assume  the
    trench  is  open  for about 1/10  of a year.   Thus,  the probability of
    this scenario is about:

        p = (3.2 x 10"^ per year) x (0.1  year)
          = 3.2 x 10~5
                                 B-33

-------
                       REFERENCES  FOR APPENDIX  B
 1.   Personal   Communication  with  Boyd  Possin,   E   &  R   hydrologist,
     August  20,  1980

 2.   Williams,  Dr.  J. Hadley.   Hydrologic Aspects  of  the  Farm Dump  Site
     Near  Verona,  McDowell  Quadrangle,  Barry County, Missouri.  Geology  &
     Land  Survey,  State  of  Missouri, June  4,  1980.

 3.   Freeze,  R.  Alan, and  John A. Cherry.   Groundwater.    Prentice-Hall,
     Inc.,  Englewood  Cliffs,  N.J.,  1979.

 4.   Boyle,  William  C. , and  Robert  K.   Ham (University  of  Wisconsin).
     Assessment  of Leaching Potential  from  Foundry Process  Solid  Wastes.
     pp.  129-147 in Proceedings of  the 34th Industrial Waste  Conference,
     May  8, 9,  and 10,  1979,  Purdue University, Lafayette,  Indiana,  J.M.
     Bell,  Ed.,  Ann  Arbor  Science Publishers Inc.,  Ann Arbor, Michigan,
     1980;  see  pp.  137-139.

 5.   Cleary,   Robert   W. ,   David   W.   Miller,   and  George   F.   Pinder.
     Groundwater  Pollution   and   Hydrology.      Princeton   University,
     Princeton,  N.J.,1980  (course notes  in  3-ring binder).

 6.   Del   Pup,   John,  et  al.  (Ecological  Analysts,  Inc.),  and  Robert
     Stadelmaier (RFCRA  Reasearch Inc.).  An Assessment of  the Potential
     Impact on Human  Health from Operation of a  Chemical Waste Management
     System.   pp.  270-276  in Proceedings of 1980  National  Conference  on
     Control of  Hazardous  Material  Spills,  May  13-15, 1980,  Louisville
     Kentucky,  published by Vanderbilt  University,  1980; see p. 273.

 7.   Department  of Transportation, U.S. Coast Guard.  Assessment Models in
     Support of the Hazard  Assessment  Handbook.    CG-D-65-74,  prepared  by
     A.D.  Little,Inc.,  January  1974[NTIS AD-776  617];  see  Chapter  4,
     "Mixing and Dilution".

 8.   Eisenberg,  N.A., et_ a\_.   A Critical Technical Review  of  Six Hazard
     Assessment  Models.   Prepared for  U.S.  Coast Guard  by  Enviro  Control,
     Inc.,  CG-D-122-76,  December  1975  [NTIS AD/A-035  599  See  Chapter  3,
     "Mixing and Dilution Model."

 9.   State  of  Missouri,   Division  of  Budgeting  &  Economic  Planning;
     contacted by John Caoile, E & E,  August, 1980.

10.   The  FIFRA  Scientific Advisory Panel  Evaluation of the  Oncogenicity,
     Fetotoxicitv,  and Exposure Characteristics  for 2,4,5-T,  Silvex,  and
     TCDD,  Appendix  I,  p.   72325,  in   Final  Determination  Concerning  the
     Rebuttable   Presumption  Against   Registration  for  Certain  Uses  of
     Pesticide  Products  Containing 2,4,5-T...,  Environmental  Protection
     Ap.ency,  Federal  Register,  Vol.   44,  Thursday,  December  13,  1979,
     72316-72328.

                                  B-34

-------
11.   Court,  Arnold.  Tornado  Incidence Maps.   ESSA Technical  Memorandum
     ERLTM-NSSL 49, U.S.  Dept.  of  Commerce,  Environmental  Science  Services
     Administration,  National  Severe Storms Laboratory, Norman, Oklahoma,
     August  1970.

12.   Menzie, Charles A. (EG&G Environmental Consultants).  An Approach  to
     Estimating   Probabilities   of   Transportation-Related   Spills   of
     Hazardous  Materials.    Environmental  Science  &  Technology  13(2),
     February 1979, 224-228.

13.   Department of Transportation,  U.S. Coast  Guard.  Assessment Models  in
     Support of the Hazard Assessment  Handbook.  CG-D-65-74, prepared  by
      A. D. Little, Inc.,  January  1974 (NTIS AD-776-617), see  Chapter  4,
     "Mixing and Dilution".

14.   Hazardous Materials Intelligence Report.   15 August 1980,  p.  8.
                                  B-35

-------
APPENDIX C
BORING LOGS

-------
                           Field Boring Log
Project:    Farm Site No.  1
                      Date:
Drilling Company: Terracon  Consultants

Driller:  Jim Murphy
             July 15.  1980
                      E & E Geologist:   John  Caoile

                      Boring  No.:     13	
Assistant Driller:   Tom Tillman
                      Surface  Elevation:   100.2
                                          Water  Table:   Completion    dry
                                                         24 hours      dry
  Depth, ft.
 Method of
Advancement
N-value
Soil Description
0.0-10.0
10.0-11.5
11.5-13.0
13.0-14.5
14.5-16.0
16.0-17.5
17.5-19.0
19.0-20.5
20.5






PA
* 2" SPT
* 2" SPT
* 2" SPT
* 2" SPT
* 2" SPT
2" SPT
2" SPT
Drilling Discontinued






^^_
—
	
—
___
—
105
49







Reddish Brown Clay, silty, cherty,
moist, stiff
Same, but more moist to very moist
Same
Same
Same
Same
Same
Same







REMARKS:

  * - 2" SPT were sampled by push-
      ing spoon hydraulically into
      soil.

  No HNU Photo-ionizer Response
  during drilling.
                                c-i
   recycled paper
                                   KEY

                   PA - Rower  Auger

                   SPT- Standard  Penetration Test
                        (split-spoon sampling)

                   ST - Shelby Tube

                   DC - Diamond Coring

                   RB - Rock Bit         FT - Finger Tooth Bit

                   WB - Wash Bore       FH - Fish Tail Bit
                               tr and environment, int. .

-------
                           Field Boring Log
Project:     Farm Site No.  1
Drilling Company: Terracon Consultants
Driller:  Jim Murphy	
                      Date:    July 15.  1980
                      E & E Geologist:  John Caoile
                      Boring No.:    14	
Assistant Driller:   Tom Tillman
                      Surface  Elevation:   99.9
  Depth, ft.
                                          Water Table:   Completion    dry
                                                         24 hours      dry
 Method of
Advancement
N-value
Soil Description
0.0-3.0
3.0-5.0
5.0-6.5
6.5-10.0
10.0-11.5
11.5-15.0
15.0-16.1
16.1-20.0
20.0-21.2
21.2-27.0
27.0




PA
PA
2" SPT
PA
2" SPT
PA
2" SPT
PA
2" SPT
PA
Auger Refusal




—
^^^
69
—
50
—
50/1"
—
60/3"
—





Reddish Gray cherty gravels & sands,
some clay, dry, loose
i
Same but becoming more clay-like
Red. Clay, very cherty, slightly
moist, very stiff
Red Silty Clay, cherty, dry to
slightly moist, stiff . .
Red Silty Clay, cherty, dry to
slightly moist, stiff
Red Silty Clay, cherty, dry to
slightly moist, stiff
Red Silty Clay, cherty, dry to
slightly moist, stiff
Red Silty Clay, cherty, dry to
slightly moist, stiff
Reddish Brown Silty Clay, chertv,
slightly moist, stiff
Reddish Brown Silty. Clay, cherty,
slightly moist, stiff
'




REMARKS:
   No HNU Photo-ionizer Response
   during drilling.
                                C-2
   recycled paper
                                   KEY
                   PA - Power  Auger
                   SPT- Standard  Penetration Test
                        (split-spoon sampling)
                   ST - Shelby Tube
                   DC - Diamond Coring
                   RB - Rock Bit         FT - Finger Tooth  Bit
                   WB - Wash Bore       FH - Fish Tail  Bit
                               erolupj anil « nvintiiiuriil. inr

-------
                           Field Boring Log
Project:   Farm Site No.  1
    Date:
Drilling Company: Terracon Consultants
Driller:   Jim Murphy	
July 15. 1980
    E & E Geologist:  John  Caoile
    Boring No.:	15	
Assistant Driller:  Tom Tillman
    Surface Elevation:    100.8
                                          Water  Table:   Completion    dry
                                                         24 hours	dry
                     Method of
                    Advancement
N-value
    Soil Description
0.0-5.0
5.0-6.5
6.5-8.0
8.0-9.5
9.5










PA
2" SPT
2" SPT
2" SPT
Drilling Discontinued











80
40
39











Reddish Brown Silty Clay, slightly
moist to moist, stiff
Same
Same
Same











REMARKS:

   No HNU Photo-ionizer Response
   during drilling.
                                 C-3
   recycled paper
                 KEY
 PA  -  Rower  Auger
 SPT-  Standard Penetration Test
       (split-spoon sampling)
 ST  -  Shelby Tube
 DC  -  Diamond Coring
 RB  -  Rock Bit        FT - Finger Tooth Bit
 WB  -  Wash Bore       FH - Fish Tail  Bit
              «•( nli>K) mid riitinmiiiriii inr.

-------
                           Field Boring Log
Project:     Farm  Site No.  1
Drilling Company: Terracon Consultants
Driller:   Jim Murphy	
         Date:     July 15. 1980
         E & E Geologist:   John Caoile
         Boring  No.:	ISA	
Assistant Driller:    Tom Tillman
         Surface  Elevation:     100.5
         Water Table:   Completion
                        24 hours
                                                                       dry
Method of
Depth, ft. Advancement N-value Soil Description
0.0-20.0
20.0













PA
Drilling Discontinued









i


















Reddish Brown Silted ay, some
chert, moist, stiff














 REMARKS:
 The purpose of B-15A was to charac-
 terize the anomaly area with respect
 to an HNU-Photoionizer prior to
 sampling  at the other locations.
   No meter response was observed
 during drilling.
    recycled paper
C-4
                KEY
PA - Power Auger
SPT- Standard  Penetration Test
     (split-spoon sampling)
ST - Shelby Tube
DC - Diamond Coring
RB - Rock Bit         FT - Finger Tooth Bit
WB - Wash Bore       FH - Fish Tail Bit
            rrolog) and rnvirtimiient. inr.

-------
                           Field Boring Log
Project:
             Farm Site No.  1
Date:
                   15,  1980
Drilling Company:  Terracon Consultants   E  &  E  Geologist:   John Caoile
Driller:   Jim Murphy	Boring No.:	16	
Assistant Driller:    Tom  Tillman
    Surface Elevation:
                       99.2
                                          Water Table:   Completion   dry
                                                         24 hours     dry
                     Method of
                    Advancement
N-value
              Soil  Description
0.0-2.0
2.0-3.5
3.5-5.0
5.0-6.5
6.5-10.0
10.0-14.0
14.0-15.5
15.5-19.5
19.5






PA
2" SPT; low recovery
2" SPT
2" SPT
PA
PA
2" SPT
PA
Auger Refusal
(Cherty Limestone)







30
32
25
	

85/3"








Buff Silt (Loessial Topsoil),
dry, loose
Red Cherty Clay, slightly moist,
stiff
Red Cherty Clay, slightly moist,
stiff
Reddish Brown Silt & Clay, slightly
moistj stiff, some chert fraaments-
Reddish Brown Silt & Clay, slightly
moist, stiff, somp chert fraaments
Same, less cherty
Same, becoming more cherty
Reddish Brown Silt & Clay, slightly
moist, stiff, some chert fraaments







REMARKS:

   No HNU Photo-ionizer Response
   during drilling.
                                C-5
   recycled paper
                 KEY
 PA - Power Auger
 SPT- Standard Penetration Test
      (split-spoon sampling)
 ST - Shelby Tube
 DC - Diamond Coring
 RB - Rock  Bit        FT - Finger Tooth Bit
 WB - Wash  Bore       FH - Fish Tail Bit
             ••f ul\ nini f M\imiimrrii, inc. .

-------
                           Field Boring Log
Project:    Farm Site No. 1
                      Date:
Drilling Company:  Terracon Consultants
Driller:   Jim Murphy	
             July 15,  198P
                      E & E Geologist:  John Caoile
                      Boring No.:    17	
Assistant Driller:
   Tom Tillman
    Surface Elevation:
         99.3
                                          Water Table:  Completion   dry
                                                        24 hours     dry
  Depth,  ft.
 Method of
Advancement
N-value
Soil Description
0.0-2.0
2.0-3.5
3.5-5.0
5.0-6.5
6.5-14.0
14.0-15.5
15.5-17.5
17.5-19.6
19.6-24.0
24.0





PA
2" SPT
2" SPT
2" SPT
PA
2" SPT; low recovery
PA
2" SPT
PA
Drilling Discontinued





— _
29
30
48
—
34
--
51







Buff Silt, come clay, dry,
loose
Red clay, silty, some chert frao-
ments ,' slightly moist, stiff
Red clay, siltv, some chert frao-
ments, sliqhtlv moist L stiff
Red clay, silty, some chert fraa-
ments, slightly moist, stiff
Same, but more clay & moisture at
8.5' - 10'
Red clay, silty, some chert fraaments
slightly moist, stiff
Red silty clay, numerous
Same
Same






REMARKS:

  No HNU  Photo-ionizer Response
  during  drilling.
  recycled paper
                                C-6
                                   KEY
                   PA  -  Power  Auger
                   SPT-  Standard  Penetration Test
                         (split-spoon sampling)
                   ST  -  Shelby Tube
                   DC  -  Diamond Coring
                   RB  -  Rock Bit         FT - Finger Tooth Bit
                                       WB - Wash Bore
                                         FH - Fish Tail Bit
                                                        mi rntinmnirni. inc.

-------
                           Field Boring LOG
Project:    Farm Site No.  1
                      Date:    July 16. 1980
Drilling Company: Terracon Consultants     E  &  E  Geologist:   J°hn Caoile
Driller:     Jim Murphy	  Boring No.:	£0	
Assistant Driller:   Tom Tillman
                      Surface  Elevation:
                           100.9
  Depth, ft.
                                          Water  Table:   Completion   dry
                                                         24 hours	dry
 Method of
Advancement
N-value
Soil Description
0.0-6.1
6.1-25.0
25.0-26.5
26.5











PA
PA
PA
Auger Refusal











—
—
—












Buff Silt (Loessial Topsoil),
dry, loose
Red Clay, Silty. Cherty, becoming
very cnerty below 20', moist, sti
Red Silty Clay and bedded chert,
slightly moist, very stiff












                                                                                 iff
REMARKS:

   No HNU  Photo-ionizer Response
   during  drilling.
                                C-7
   recycled paper
                                   KEY
                   PA -  Power  Auger
                   SPT-  Standard Penetration Test
                         (split-spoon sampling)
                   ST -  Shelby Tube
                   DC -  Diamond Coring
                   RB -  Rock Bit        FT - Finger Tooth Bit
                   WB -  Wash Bore       FH - Fish Tail Bit
                               i-iiiluei tun) pimninmi in. inr.

-------
                           Fielc Boring Log
Project-    Farm Site No.  1
Drilling Company: Terracon Consultants
Driller:     Jim Murphy
    Da te:     July  16,  19RO
    E & E Geologist:  John Caoile
    Boring No.:      21	
Assistant Driller:  T°m Tillman
    Surface Elevation:    101.3
                                          Water  Table*   Completion    dry
                                                         24 hours      dry
                     Method of
                    Advancement
N-value
Soil Description
0.0-0.5
0.5-5.0
5.0-6.5
6.5-8.0
8.0-9.5
9.5-14.0
14.0-15.5
15.5-19.0
19.0-19.1
19.1





PA
PA
2" SPT
2" SPT
2" SPT
Jar Sample taken
10'-14' auger cuttings
2" SPT
PA
2" SPT
Auger Refusal





	
—
59
33
40
-

	
25/1"






Buff Silt (Loessial Topsoil),
slightly moist to dry, loose
Red Clay, silty, cherty, slightly
moist, stiff
Same
Red Silty Clay, some chert frag-
ments, moist, stiff
Red Silty Clay, cherty, slightly
moist, stifr
Red Clay, some silt & chert,
moist, stiff
Same
Red Clay with chert fragments,
moist, stiff
Red silty clay and chert,
moist, hard






REMARKS:
   No HNU Photo-ionizer Response
   during drilling.
   recycled paper
                 KEY
 PA - power  Auger
 SPT- Standard  Penetration Test
      (split-spoon sampling)
 ST - Shelby Tube
 DC - Diairo'nd Coring
 RB - Rock Bit         FT - Finger Tooth  Bit
 WB - Wash Bore       FH - Fish Tail Bit
              ft nltip\ mid i lit irnfiiMt in. ini
                                 C-8

-------
                           Field Boring Log
Project:     Farm Site No.  1
  Gate:     July 16.  19RO
Drilling Company:  Terracon Consultants   E I E Geologist:   John Caoile
Driller:   Jim Murphy	  Boring No.:	^	
Assistant Driller:  Tom Tillman
  Surface  Elevation:
100.2
  Water  Table:   Completion
                 24 hours
                                                                      dry
Method of
Depth, ft. Advancement N-value Soil Description
0.0-1.5
1.5-5.0
5.0-6.5
6.5-8.3
8.3










PA
PA
2" SPT
PA
Auger Refusal











—
56
—











Buff silt (Loessial Topsoil),
slightly moist, loose
Red Clay, trace silt, cherty, dry
to slightly moist, stiff
Same
Same












 REMARKS:

   No HNU-Photoionizer response
   during drilling.
                                  c-9
    recycled paper
                KEY
PA - Rower Auger
SPT- Standard  Penetration Test
     (split-spoon sampling)
ST - Shelby Tube
DC - Diamond Coring
RB - Rock Bit         FT - Finger Tooth Bit
WB - Wash Bore       FH - Fish Tail Bit
            ft u)ȣ\ HI id rm-iromnrni, inc.

-------
                           Field boring Log
Project:
Farm Site No.  1
    Date:
Drilling Company:  Terracon Consultants
Driller:	Jim Murphy	
Assistant Driller:  Tom Tillman
July 16. 19RO
                             E & E Geologist:   John Caoile
                             Boring  No.:	24	
                             Surface  Elevation:
                           100.5
                                          Water Table:   Completion   dry
                                                         24  hours      dry
  Depth,  ft.
        Method of
       Advancement
N-value
    Soil  Description
0.0-3.2
3.2-5.0
5.0-5.5
5.5-10.0
10.0-11.5
11.5-14.0
14.0-14.5
14.5







PA
PA
2" SPT (no recovery)
PA
2" SPT
PA
PA
Auger Refusal









30/4"
—
24
—
__








Buff Silt (Loessial Topsoil); very
cherty at 2 - 3 deep, moist, loose
Red Silty Clay, cherty, slightly
moist, stiff.
Same
Same
Same
Red Silty Clay, Cherty, moist,
stiff
Numerous chert float rock, hard








REMARKS:
Offset S% feet'west of stake due to
tree branches overhead.
No HNU-Photoionizer Response
during drilling.
                                c-io
   recycled paper
                                          KEY
                          PA  -  Power Auger
                          SPT-  Standard Penetration Test
                                (split-spoon sampling)
                          ST  -  Shelby Tube
                          DC  -  Diamond Coring
                          RB  -  Rock Bit        FT - Finger Tooth  Bit
                          WB  -  Wash Bore       FH - Fish Tail  Bit
                                      rrolugt and rmirvmmrnl. inr

-------
                           Field Boring  Log
Project:
Farm Site No.  1
Drilling Company:  Terracon Consultants

Dri11er:   Jim Murphy	

Assistant Driller:  Tom Tillman
    Date:    July 16. 1980
                            E & E Geologist:   John  Caoi'le

                            Boring No.:	25	
                            Surface Elevation:
                           99.8
                                          Water Table:   Completion  dry
                                                        24 hours    dry
  Depth,  ft
       Method of
      Advancement
N-value
Soil Description
0.0-1.8
1.8-2.0
2.0-3.5
3.5-5.0
5.0-6.5
6.5-8.0
8.0-14.0
14.0-15.5
15.5-19.0
19.0-20.5
20.5-27.5
27.5



PA
PA
9" CDT 1°W
i jr! recovery
2" SPT
2"SPT
2" SPT
PA
2" SPT
PA
2" SPT
PA
Auger Refusal




—
31
33
52
73
—
52
—
53
—




Buff Silt, tr. clay (Loessial
topsoil) , dry, medium
Red Clay, Silty, some chert 'frag-
ments, moist, stiff
Same, very cherty, moist, stiff
Red Silty Clay, cherty, moist,
stiff
Red Clay and chert fragments,
moist, stiff
Same
Same, but moist to very moist
about 8.5'
Same
Red Clay, some chert & silt,
moist, stiff
Same
• Interbedded Red Cherty Clay, and
chert float rock, hard.




REMARKS:


  No HNU-Photoionizer Response

  during drilling.
                               c-n
   ri»< vclrd naner
                                         KEY

                         PA - Power  Auger

                         SPT- Standard  Penetration Test
                              (split-spoon sampling)

                         ST - Shelby Tube

                         DC - Diamond Coring

                         RB - Rock Bit         FT - Finger Tooth Bit
                         WB - Wash Bore       FH - Fish Tail Bit

-------
                           Field Boring Log
Project:
Farm Site No.  1
Date:    July  16.  1980
Drilling Company:   Terracon  Consultants   E & E Geologist:   John  Caoile
Driller:    Jim Murphy	  Boring No.:	26	
Assistant Driller:   Tom Tillman
                             Surface  Elevation:
                        98.1
                                          Water Table:  Completion    dry
                                                        24  hours      dry
                     Method of
                    Advancement
                         N-value
             Soil  Description
0.0-3.9
3.9-34.0
34.0












PA
PA
Drilling Discontinued













—













Buff Silt, trace clay (loessial
topsoil), moist, loose
Red Silty Clay, some chert, moist
to very moist, stiff













REMARKS:
  Penetrated chert float rock  about
  10.5',  5"  thick

  No HNU-Photoionizer Response
  during  drilling.
   recycled naoer
                                C-12
                                          KEY
                           PA  -  power Auger
                           SPT-  Standard Penetration Test
                                (split-spoon sampling)
                           ST  -  Shelby Tube
                           DC  -  Diamond Coring
                           RB  -  Rock Bit        FT - Finger Tooth  Bit
                           WB  -  Wash Bore       FH - Fish Tail  Bit
                                       ••colon* mid rmiraninrni. inr.

-------
                           Field Boring Log
Project:
Farm Site No. 1
Drilling Company:  Terracon Consultants

Driller:     Jim Murphy	
    Date:
July 16. 19BO
                            E & E Geologist:   John Caoile

                            Boring No.:	27	
Assistant Driller:
         Tom Tillman
    Surface Elevation:
            99.0
  Depth, ft.
                                          Water Table:   Completion     dry
                                                         24  hours       3ry~
       Method of
      Advancement
N-value
   Soil  Description
0.0-2.5
2.5-6.0
6.0-6.5
6.5-32.7
32.7-33.3
33.3









PA
PA
PA
PA
PA
Auger Refusal









—
—













Buff Silt & Clay (Loessial topsoil),
moist, loose
Red Silty Clay, some chert fragments,
slightly moist, stiff
Chert - float rock
Red Silty Clay, trace chert fragments,
plastic; moist, stiff . .
Chert fragments, hard










REMARKS:


  No HNU-Photoionizer Response

  during drilling.
   recycled paper
                                C-13
                                         KEY

                         PA - Rower Auger

                         SPT- Standard  Penetration Test
                              (split-spoon sampling)

                         ST - Shelby Tube

                         DC - Diamond Coring

                         RB - Rock Bit         FT - Finger Tooth Bit
                                       WB - Wash Bore
                                      ulue
                                               FH - Fish Tail Bit
                                          and « minmmrnl. inc.

-------
                           Field Boring Log
Project:     Farm Site  No.  1
                      Date:
              July  16.  1980
Drilling Company:   Terracon  Consultants   E & E Geologist:  John Caoile
Driller:	Jim Murphy	  Boring No.:	28	
Assistant Driller:  Tom Tillman
                      Surface Elevation:
                             99.9
  Depth, ft.
                                          Water Table:   Completion   dry
                                                         24  hours     dry
 Method of
Advancement
N-value
Soil Description
0.0-2.1
2.1-5.0
5.0-6.5
6.5-8.0
8.0-9.5
9.5-14.0
14.0-15.5
15.5-19.0
19.0-20.5
20.5-25.0
25.0-32.2
32.2-33.2
33.2


PA
PA
2" SPT
2" SPT
2" SPT
PA
2" SPT
PA
2" SPT
PA
PA
PA
Auger Refusal


	

45
36
64
—
60/5"
—
35
—
—
—



Buff Silt, trace clay (loessial
topsoil), sliqhtlv moist, stiff
Red Silty Clay, some chert, "moist,
stiff
Same
Same
Red. Clay, moist to very moist,
Same
Same, but becoming less moist
Red Clay, some chert fragments,
moist, stiff
Same
Red Silty Clay, cherty, slightly
moist, stiff
"Same, becoming more cherty
Interbedded chert and Red Silty
Clay



REMARKS:

  No HNU-Photoionizer Response
  during  drilling.
  recycled paper
                                C-14
                                   KEY
                   PA - Power  Auger
                   SPT- Standard  Penetration Test
                        (split-spoon sampling)
                   ST - Shelby Tube
                   DC - Diamond Coring
                   RB - Rock Bit         FT - Finger Tooth Bit
                   WB - Wash Bore       FH - Fish Tail Bit
                               rrologt and riitiniiinirni, inc.

-------
                           Field Boring  Log
Project:
Farm Site No.  1
Date:
Drilling Company:  Terracon Consultants
Driller:     Jim Murphy	
Assistant Driller:  Tom Tillman
July 17, 1980
                            E  &  E  Geologist:   John Caoile
                            Boring No.:     29	
                            Surface Elevation:
                       100.3
                                          Water Table:   Completion   dry
                                                        24 hours     dry
                     Method of
                    Advancement
                        N-value
             Soil Description
0.0-2.5
2.5-4.5
4.5-5.0
5.0











PA
PA
PA
Auger Refusal












—
—












Buff Silt, some clay (loessial
topsoil), slightly moist, loose
Red Silty Clay, Cherty, moist,
stiff
Sandstone boulder












REMARKS:
   No HNU-Photoionizer Response
   during drilling.

   Additional hole was drilled 5'
   south of B-29 and designated
   B-29A.
                               C-15
                                        KEY
                         PA - Power Auger
                         SPT- Standard Penetration Test
                              (split-spoon sampling)
                         ST - Shelby Tube
                         DC - Diamond Coring
                         RB - Rock Bit        FT - Finger Tooth Bit
                         WB - Wash Bore       FH - Fish Tail Bit

-------
                           Field Boring Log
Project:
Farm Site No. 1
Date:    July  17.  19BO
Drilling Company. Terracon Consultants     E & E Geologist:   John Caoile
Driller:     Jim Murphy	  Boring  No.:	29A	
Assistant Driller:    Tom Till man
                             Surface Elevation:
                        100.3
                                          Water  Table:   Completion    dry
                                                         24 hours      dry
Method of
Depth, ft. Advancement N-value Soil Description
0.0-2.3
2.3-4.5
4.5-4.7
4.7-34.0

34.0









	
PA
PA
PA
PA

	
—
—
	




















Buff Silt, trace clay {loessial
topsoil), sliahtly moist, stiff
Red Clay, some silt, cherty;
moist, stiff
Chert boulder or. zone
Red Clay, some silt & chert fraa-
ments , moist to very moist, very.
stiff










REMARKS:
   Offset 5 feet south of B-29 due
   to chert boulder.
                                C-16
   recycled paper
                                          KEY
                          PA - Rower Auger
                          SPT- Standard  Penetration Test
                               (split-spoon sampling)
                          ST - Shelby Tube
                          DC - Diamond Coring
                          RB - Rock Bit         FT - Finger Tooth Bit
                          WB - Wash Bore       FH - Fish Tail Bit
                                      fitting* miH cininmrnrnu inc

-------
                           Field Boring Log
Project:
Farm Site No. 1
    Date:    July 17 to 19, 1980
Drilling Company: Terracon  Consultants     E & E Geologist:   John Caoile

Driller:     Jim Murphy	  Boring No.:    30  (well hole)
Assistant Driller:  Tom Tillman
                             Surface Elevation:
                             1.6
                                          Water Table:   Completion see remarks
                                                         24  hours
  Depth, ft.
       Method  of
      Advancement
N-value
Soil Description
0.0-3.6
3.6-11.8
11.8-17.0
17.0-25.2
25.2-27.5
27.5-34.0
34.0-35.0
35.0-37.5
37.5-39.4
39.4-39.7
39.7-10.9
40.9-41.9
41.9-42.8
42.8-47.4
47.4
PA
PA
PA
PA
PA
PA
RB
DC (NX-size) 24%recove»
DC - 80% recovery
DC- 100% recovery
RB
DC- 100% recovery
DC- 100% recovery
RB
Drilling Discontinued
--
•V K
--
_ _
_ _
__

y Runtfl
Run # 2
Run # 3

Run # 4
Run # 5


Buff silt (loessial topsoil),
slightly moist, stiff
Red silty clay, some chert, "slight-
ly moist, stiff
Olive gray silty clay (shaley),
slightly moist to dry, stiff
Olive silt, dry, stiff
Cherty limestone, broken, hard
Alternating red clay and chert,
hard
Chert, very hard
Chert, ^gray-white, dense crystalline,
some fracture Tines
Same
Same
Same
Same
Same
Same

REMARKS:  No HNU-Photoionizer
   Response during drilling.

Lost circulation at 44', continued
with rock bit.   After 1 hour of
drilling, water was at 39.5'.
Core water level dropped to 41' in
2% hours, and was at 41' when the
well pipe was installed.
                               C-17
   recycled paper
                                         KEY

                          PA -  Power Auger

                          SPT-  Standard Penetration Test
                               (split-spoon sampling)

                          ST -  Shelby Tube

                          DC -  Diamond Coring

                          RB -  Rock Bit        FT  - Finger Tooth Bit

                          WB -  Wash Bore       FH  - Fish  Tail  Bit
                                      milii|;\ imrl rmircirimt lit. inr.

-------
                           Field Boring Log
Project:   Farm Site No.  1
    Date:   July IE.  igp.n
Drilling Company:  Terracon Consultants
Driller:  Jim Murphy	
    E & E Geologist:   John  Caoile
    Boring No.:   31	
Assistant Driller:   Tom Tillman
    Surface Elevation:    101.0
                                          Water Table:   Completion    dry
                                                         24  hours       dry
                     Method of
                    Advancement
N-value
Soil Description
0.0-0.8
0.8-11.2
11.2-12.5
12.5-15.5
15.5










PA
PA
PA
PA
Auger Refusal











^_
	
—











Buff Silt (Loessial topsoil), dry,
loose
Red Silt and Clay, some chert
fragments, moist, stiff
Same, but more chert fragments
Gray-White Cherty Limestone,
weathered, hard











REMARKS:
   No HNU-Photoionizer Response
   during drilling.
   recycled paper
                                C-18
                 KEY
 PA - Rower Auger
 SPT- Standard  Penetration Test
      (split-spoon sampling)
 ST - Shelby Tube
 DC - Diamond Coring
 RB - Rock Bit         FT - Finger Tooth Bit
 WB - Wash Bore       FH - Fish Tail Bit
             Prolog) and rnvirnnmrm, inc.

-------
                     SOIL SAMPLES TAKEN





Sample No.                Boring No.               Depth
AN8000
AN8001
AN8002
AN8003
AN8004
AN8005
AN8006
AN 8007
AN 8008
AN8009
AN8010
AN8011
AN8012
AN8013
AN8014
AN8015
AN8016
AN8017
AN8018
AN8019
AN8020
AN 8021
13
13
13
13
13
13
13
15
15
15
14
14
14
14
16
16
16
17
17
17
17
21"
lO'-ll1
11V-131
13'-14V
14V -16'
16'-17V
17V-191
19 '-20V
5'-6V
6V -P1
8'-9V
5'-6V
lO'-HV
15'-16J
20'-21'
3is' -5'
5'-6Js-
14--15'
2'-3i5'
3% '-5'
5'-6H'
17is'-19'
5 '-6^'
                           C-19

-------
                  SOIL SAMPLES TAKEN
                         (cont.)

Sample No.              Boring No.               Depth
AN8022
AN8023
AN8024
AN8025
AN8026
AN8027
AN8028
AN8029
AN8030
AN8031
AN8032
AN8033
AN8034
AN8035
AN8036
21
21
21
23
24
25
25
25
25
25
28
28
28
28
28
6V -8'
8'-9V
1CT-141
5'-6V
12'-14'
3V -5 '
5'-6V
6V -8'
14 '-15y
20' -2m1
5 '-6V
6V -8'
8 '-9V
14 '-1 5V
19 '-20V
                        C-20

-------
                 APPENDIX D
OCCUPATIONAL HEALTH AND SAFETY CONSIDERATIONS

-------
                               APPENDIX D
              OCCUPATIONAL HEALTH AND SAFETY CONSIDERATIONS
     In  developing remedial  actions  for  the  Denny  Farm Site  1  cleanup,
E & E examined   carefully    the    safety    requirements   for    contractor
personnel.   This  appendix  addresses  the  occupational  health  and  safety
considerations   for      excavation   and  cleanup   of   dioxin-contaminated
materials.
     Because  of   the   extreme  toxicity  of   2,3, 7,8-tetrachlorodibenzo-p-
dioxin   (TCDD),  the   unknown  airborne  concentrations  of   other   organic
vapors,  e.g.,  trichlorophenol,  and  the possibility of  oxygen depletion  in
the trench, utmost  concern must be  given to  the safety  and  health of  the
personnel  performing   the  excavation.    (For   all   intents,   an  IDLH—
Immediately  Dangerous   to  Life   or  Health—atmosphere  must   be   assumed
during the excavation phase.)
     Personnel  safety  must  take   into  consideration   these  hazards  and
provide  maximum  protection  from  exposure  via  skin  or  mucous  membrane
absorption  and  inhalation.    It   is  evident  that  full  body  protective
clothing  and  supplied  air  must  be  provided  for  the  excavation  crew  and
personnel   working   directly   with    contaminated    material    prior   to
decontamination.    The  personnel   protective  equipment  (PPE)   has   been
selected  based  on the  need for worker safety,  the nature  of  the  required
operation,  and  the  duration of  the  operation.   The  specified  PPE  for
different  work  crews  affords the  maximum  protection  and follows  accepted
guidelines  (NIOSH).     Since   the   degree  of  hazard,   i.e.,  exposure  to
dioxin,  is  different  for  a  number  of  operations  necessary in  the  cleanup,
different levels of protection are recommended as defined below:
     Excavation Team in and around Trench—Possible IDLH conditions
     Fully  encapsulated   suit  with   cooling  apparatue  (vortex  tube  and
       manifold)
     Airline   and   self   contained   breathing   apparatus   (airline   in
       pressure-demand mode)
     Impermeable gloves
     Impermeable boots with steel shank
                                  D-l

-------
Decontamination Crew—Contact with drums and equipment

Fully  encapsulated  suit  with cooling  apparatus  (vortex  tube  and
  manifold)
Airline   and   self-contained   breathing   apparatus   (airline   in
  pressure-demand mode)
Impermeable gloves
Impremeable boots with steel shank

Personnel Decontamination Crew—Contact     with     personnel     and
equipment

Airline suits/helmets with cooling apparatus
Impermeable clothing
Impermeable gloves and boots

Depending  upon  the  location  of  the  decontamination  area,  the
appropriate respiratory protection may be  lowered to  a  full-face
piece  air purifying respirator.

Back Hoe Operator in and around Trench

Self-contained breathing apparatus
Impermeable clothes (vinyl or tyvek)
Impermeable gloves and boots

Because  of  the possibility  of  damage  to  the airline hose  and the
impracticability  of  attaching an airline  to  mobile equipment,  SCBA
is  the  only   alternative.    Stay  time should  be  longer   for  the
operator  since activity is minimal.   By rotating  two operators there
should be no  loss of efficiency during  the  overburden removal.

Crane  Operator

Coveralls
Gloves
Boots

The  low  level of  protection  assumes that an enclosed  and powered air
cab  is  available.     If   an open  cab  is  used  an   air  purifying
respirator   and  impervious   clothing  will   provide   the   proper
protection  for the  operator.  Vapor  and dust levels may change the
PPE  assessment for  the  crane operator.

Off-site  Personnel

Protective  equipment will  be dictated  by  vapor  concentrations and
the  degree  of airborne  particulate  (dust particles).

Upwind personnel will  probably not  need  any  PPE;  however,   in the
event  that  the above conditions  exist, an air purifying  respirator
along  with  coveralls  will  provide necessry protection.
                              D-2

-------
Additional Safety Support Equipment


1.  Decontamination Trailer

    For on-site  personnel showers  and  laundry  facilities  to  minimize
    transport of contaminated material from site.

2.  Air Compressors

    To supply Grade  0 breathing  air.   The  compressor must be  equipped
    with  either  a high  temperature  alarm or  carbon  monoxide  alarm  or
    both.

3.  Water

    It is  necessary   that  water  be  available  for  decontamination,
    showering, and laundry purposes.

4.  Steam Decontamination System

    For equipment.

5.  Organic Vapor Monitor

    The possibility  of organic  and flammable  vapor  buildup  within  and
    around the  trench excavation  area  must  be considered  for personnel
    safety.   Regular monitoring for explosive  vapor should  occur during
    operations.   Several  types  of explosion  meters  are  available  from
    suppliers.

6.  Miscellaneous

    There  are numerous  other safety  and personnel protection  measures
    which  should  be  considered  during  a hazardous  operation   of  this
    nature,   especially   for   the   excavation    contractor.      These
    considerations may directly  influence the total cost of the cleanup.
    They  include:
       o  Medical monitoring
       o  Non-sparking tools

       o  Explosion-proof  equipment
       o  Fire-extinguishing materials
       o  Varying  levels of  personnel  protection  dependent  on   specific

          task within or without  secured  area  of  site
       o  Providing  for  adequate  rest,  well-balanced  meals, and other

          personal hygiene during  operations

       o  Daily  safety briefings  on site
       o  Training   of   personnel   in   safety   and    work   procedures

                                  D-3

-------
               APPENDIX E
COST TABLES FOR PROPOSED REMEDIAL ACTION

-------
                                  TABLE E-1

                                 COMPONENT 1

                         TEMPORARY STORAGE FACILITY
ASSUMPTIONS
     o   Site for storage facility is available near waste site
     o   Shallow soil overburden
     o   Total storage requirement is 5000 drums.
ESTIMATED COSTS FOR THE ELEMENTS OF THIS COMPONENT:

  Geotechnical Investigations                                       $  25,000
  Land - 1 Acre 3 $l,000/per acre (assuming purchase  of  land)           1,000
  Engineering Design Lump sum ID $25,000 (design of pad,  caissons)      25,000
  Steel plate fabrication, transport, and erection                    190,000
  Site Preparation - 1 acre at $l,000/per acre                          1,000
  Foundations
     a.  Excavation - 1200 C.Y. at S3/C.Y.                              3,600
     b.  Caissons - 37 caissons X 12 V.F. ® $32/V.F.                   Ui,200
     c.  Grade Beams - 95 C.Y. at $285 C.Y.                            27,100
     d.  Slab - 200 C.Y. at $165 C.Y.                                  33,000

  Dium Rack, Misc. Interior                                            25,000
  Electrical, Ventilation & Vandal-proof Access                        15,000

                                          TOTAL FOR COMPONENT  1      $360,000
*Cost estimate for fabrication & erection by Pittsburgh - Des Moines
 Corporation
                                 E-1

-------
                               TABLE E-2

                              COMPONENT 2

                       SITE SETUP \ MOBILIZATION
ASSUMPTIONS:
   o  Protective Equipment1 Mill be used by all personnel
   o  Offsite facilities to be available duration of project
   o  Requires installation of complete utilities
   o  Ten days for this component
ESTIMATED COSTS FOR ELEMENTS OF THIS COMPONENT:

SITE CLEARING
   expanding road, additional clearing                                      	
   2 acres, $4,000/acre                                                    $ 8,000

UTILITIES
Telephone
   $200 to connect phone
   $l,000/mth phone bill                                        $1,200
Sanitary Facilities
   $200/mth. 1 month                                               200
Lighting System
   2-30' lighting-towers
   $600/mth. each                                                 1,200
Power System
   7.5 KW Generator
   $300/mth. plus $30/day
   operating cost for 30 days                                     1,200       	
                                                                  3,800       3,600
OFFSITE BUILDINGS (TEMP.)

Command Post 12' x 8' Trailer
   $300/mth plus $100 delivery                                     400
Storage Area 12' x 8' Trailer
   materials, equipment, suits, etc.
   $300/mth. plus $100 delivery                                    400
Crew Trailer 20' x 8
   $500/mth x 1 month + $150 delivery                              630
Shower Trailer
   $350/day x 40                                                14,000      	
                                                                13,450       15,450
                                  E-2

-------
                                TABLE E-2 con't
SITE PREPARATION

Material
Remove Portions of Existing Fence
         $3.00/linear ft. x 100 linear ft.                   $300
Relocate Old Fence
         $3.00/linear ft x 100 linear ft.                     300
Install New Fence
         $10.00/linear ft x 100 linear ft.                  1,000
Personnel Gates
         2 x $50.00                                           100
Vehicle Gate
         1 x $120.00                                          120
Canvas Trench Cover
          Canvas
          $1.05/5.F. x 60' x 100'                           6,300
          Materials
          (anchors, ropes, springs)                         2,000      	
                                                           10,120      10,120
Equipment
  Backhoe rental
  1 x $550/wk. x 2/wks                                      1,100
  Backhoe operating
  1 x 40 hrs/wk. x 2/wks. x $3.50/hr.                         280       	
                                                            1, 3BO        1,380
Laboi
  Laborers
  6x8 hrs/day x  10 days x $13.93/hr.                      6,690
  Foreman
  1 x 8 hrs/day x  10 days x $19.85/hr                       1,590
  Supervisor
  I x 8 hrs/day x  10 days x $40.00/hr                       3,200
  Backhoe Operator
  1 x 8 hrs/day x  10 days x $16.85/hr                       1,350
  Per Diem
  9 people x $45/day x 14 days                              5,680       	
                                                           18,510       18,510

Training
  (84 people for 2, 8-hour tinining sessions)
  Assume average daily laboi cost
  Labor
  2 days x $10,100/day (Daily Labor)                       20,000
  Living expenses  (per diem)
  3 days x $5,670/day                                      17,000       	
                                                           37,000       37,000
                                     E-3

-------
                                     TABLE  E-2 con't
DRUM DECONTAMINATION EQUIPMENT
   Idler Conveyors
   Water Storage Tank
   Water Supply System for Drum Wash.
   Decontamination Water Collection
   System

   Bulk Storage Tanks installed
   Sampling
       3 samples per Bulk Tank
     2  x  $  500
     1  x  $  200
     1  x  $  500

     2  x  $  700

     2  x  $1000

     9  x  $  700/sample
PERSONNEL DECONTAMINATION EQUIPMENT
   Water Storage A Supply Systems         2 x $700
   Metal Grate Walkways 4 Decon Line      2 x $650
   Water Collection Systems               2 x $700
PROTECTIVE EQUIPMENT
Personnel  for Set up and within Fence
  Fully Encapsulated Suits           2 shifts x 28 people x 2
  Airline Mask with Escape Cylinder
   Vortex Cooling Tubes
   Cooling Manifolds
   Disposable Splash  Suits  & Gloves

         Setup
          Excavation
   Boots
   Hardhats
   Full  Face  Respiratois  (when
   off-site)

   Respirator Cartridges

          Setup


          Excavation
                                     per person + 20 x $800/unit
27 people +13 spares
x $925
40 x $230
40 x $50
9 people x $12/day
x 10 days + 10%

2 shjfts x 28 people/shu ft
x $12 day x 23 days +10%
2 shifts x 35 (7 spares)
x $30.00
35 (7 spares) x $3.50
32 (4 spares) x $70
9 x 8/day/person
x $3.85 x 10 days + 10%

2 shifts x 32 people x
4/day/person x 23 x $3.85
$1,000
   200
   500

 1,400

 2,000

 6,300
11,400
                                     1,400
                                     1,300
                                     1.400
                                     4,100
                                   105,600
                                                                                     11,400
                                                                                      4,100
 37,000
  9,200
  2,000
                                                                          1,190
 17,000

  2,100
    125
  2,240
  3,050
                                                                          22.670
                                                                         202,180      202,180
                                            E-4

-------
                                           TABLE E-2 con't
Equipment Operators
Self Contained Breathing Appartus        2 x $680
Spare Tanks                              4 x $220
Cooling vests                            4 x $600
                                                                                       4,640
An Supply Equipment
   Air Hose:  Excavation Personnel

        Decontamination Personnel
   Air Hose Manifolds
   An Compressor Systems
        Rental
        Operating Costs
Decontamination Personnel
   Full Face Respirators
   Boots
   Hardhats
   Disposable Splash Suits & Gloves

   Respirator Cartridges

   Robert Shaw Escape Masks

Personnel Outside Fenced Area
   Full Face Respirators

   Boots


   Hardhat s

   Disposable Splash Suits & Gloves

   Respirator Cartridges

   Robeit Shaw Escape Masks
20 hoses x 150 ft/hose
x $1.70/Ft.
12 hoses x 75 Ft x $1.70
32 connect x $121/4 connect

250/wk for 5 wks. x 3 units
3 x $30/day x 23 days
8 (2 spares) x $70
8 x $30 x 2 shifts
8 x $3.50
2 shifts x 6 people x $12/day
x 23 days + 10% for spares
2 shifts x 6 people x 8/day/
person x 23 days x $3.85 + 10%
8 x $200
10 (8 + 2 spares) x $70  x
2 shifts
10 (8 + 2 spares) x $30  x
2 shifts

10 (8 + 2 spares) x $3.50
x 2 shifts
2 sh i f ts x 8 peop le x
$12/day x 23 days + 10%
2 shifts x 8 people x 8/day
x 23 days x $3.85 + 10%
0 people x $200 each
 5,100
 1,530
   970

 3,750
 2,070
13,420
   560
   480
    30

 3,645
 1,400
   600
    70
 4,860

12,470
 1.600
21,000
                                                                                      13,420
                                              15,670
                                                          TOTAI  FUR POMPONENI 2
                                            E-5

-------
                                TABLE E-3

                               COMPONENT  3A

                                EXCAVATION
ASSUMPTIONS:
    o  Union Wage Rates for Barry County are used and include a $4.50
       per/hour premium
    o  Overall productivity is 70%
    o  The Excavation is established by a perimeter of 150 feet with an area
       of 1000 S.F. and a trench depth of 8 feet.
    o  '150 drums of contaminated waste material exists in trench
Estimated Costs for Elements of this Component:

EQUIPMENT*

   Crane
     Rental
     $3,900/mo. + 1 week ® $900/wk.                   $ 4,800
     Operating
     $5/hr. x  16/hr/day x 23 days + $400 Delivery       2,240
   Backhoe
     Rental
     $2,025/mo. + 1 week HI $470/wk.                     2,495
     Operating
     $3.50/hr. x 16/hr/day x 23 days +  $200 Delivery    1,488
   Forklift
     Rental
     $l,050/mo. + 1 week ® 245/wk. + $160  for  drum
     handling  attachment                                1,455
     Operating
     $4/hr. x  16 x 23 daya + $200 Delivery             1,672
   Flatbed Truck
     Rental
     $750/mo.  + 1 week ffl  $173/wk. x 2 trucks            2,225
     Operating
     $l/hr. x  16 hr. x 23 days  x 2 trucks                  736
   Water  Truck
     Rental
     $l,900/mo. + 1 week ® $439/wk. x 1  truck           2,470
     Operating
     $4/hr. x  2 hrs/day x 23 daya                          184      	
                                                        19,765       19,765

   * Includes  50% surcharge  for  two shift  operation
                                     E-6

-------
                               TABLE E-3 con't
MATERIALS

  Drums
      Soil (from Tables E-3.1  & E-3.2)
      2,370 drums x $25/drum                         $59,250
      Waste drums
      150 drums x $25/drum                             3,750
      Waste Overpacks
      150 drums x $75/drum                            11,250
      Decontamination Water (assuming positive
      sampling) 610 drums x $25/drum                  15,250
  Water  (from Table E-3.2)
      Drum Decontamination
      5,875/gal. x $0.05/gal                             295
      Personnel Decontamination
      24,800/gal. x 0.05/gal                           1,240
      Showers, Miscellaneous
      46,370/gal. x $0.05/gal                          2,320

  Waste  and Water Pumping System (purchase)
  (Air operated pumps with anti-corrosive coatings)    3,000
  Hand Truck for Drums                                   250
  Disposable Supplies,  Trashbags, Etc.                  1000
  Calcium Chloride for  Dust Control                     1000      	
                                                      98,610      98,610

  LABOR

      Laborers
      36/shift  x 23 days x 8 hrs/day
      x  2 shifts/day x  $13.93/hr.                     184,500

      Equipment Operators
      Crane
      1  x 23 days x 8 hrs/day  x
      2  shifts/day x 17.33/hr.                          6,380
      Backhoe
      1  x 23/day x 8 hrs/day x
      2  shifts/day x $16.85/hr.                         6,200
      Forklift
      1  x 23/days x 8 hrs/day  x
      2  shifts/day x $16.25/hr.                         5,980

      Foreman & Supervisors
      Project engineer
      1  x 23/days x 8 hrs/day  x
      2  shifts/day x $40.00                             14,720
      Offsite  foreman
       1  x 23/days x 8 x $19.85 x
      2  shifts/day                                      7,300
                                      E-7

-------
                            TABLE E-3 con't
Safety officer
1 x 23/day x 8 x $19.85 x
2 shifts/day x 19.85/hr.                             7,300     	
                                TOTAL LABOR        232,380     232,380
Living Allowance (per diem)
42 people x $45/day per x 32 days
x 2 shifts                                         117,180

                      TOTAL COST FDR COMPONENT 3A
                                  E-8

-------
                                  TABLE E-3.1

                                  COMPONENT 3A

                              SOIL & WATER VOLUMES
SOIL EXCAVATION

  Volume of Soil to be Excavated
     Trench
     1,000 S.F. x 8' deep
     Sideslopes
     150 linear feet x 32 C.F./L.F.

  Volume Machine Excavated
     Trench
     1,000 S.F. x 2 feet
     Sides lopes
     4,800 C.F x 50%
  Volume Hand Excavated
     12,800 C.F. - 4,400 C.F.

WATER REQUIREMENTS
  Drum Decont amination
   2670 drums x 2 gal/drum
  Personnel Decontamination
   Inside Fence: 28 people/shift x 2 shifts
       x 15 gal/day/person x 23 days

   Outside Fence: 4 people/shift x 2 shifts
       x 5 gal/day/person x 23 days

                            Contingency 10%

  Personal Hygiene
   42 people x 2 shifts x 20 gal/peison/day
   x 23 days
                            Contingency 20%
 8,000 C.F.

 4,800 C.F.
12,800 C.F.
 2,000 C.F.

 2,400 C.F.

 8,400 C.F.

          GALLONS     GALLONS

            5,875       5,875

           19,320



            3,220

            2,260
           24,800      24,800
           38,640
            7,730
           46,370      46,370

    TOTAL WATER        77,045
                                     E-9

-------
                                  TABLE E-3.2

                                  CONPONENT 3A

                               DRUM REQUIREMENTS
SOIL*
   Machine Excavated
    4,400 CF x 1.35/7.3 CF/Drum

   Hand Excavated
    8,400 CF x 1.35/7.3 CF/Drum
* Assumes 35% swell factor for soil

DECONTAMINATION WATER
   Drum Decon
    5,875 gal/55 gal/dium
   Personnel Decon
    24,800 gal/55 gal/drum + 10%
WASTE MATERIALS
    Contents
    Waste Drums in Dverpacks
        Drum

         815


       1,555

TOTAL  2,370
         110

         500

TOTAL    610
         150
         150
                                                                          2,370
                                                                            610
300
                                                       TOTAL DRUM REG.     3,280
                                     E-10

-------
                              TABLE E-3.3

                             COMPONENT 3A

                          LABOR REQUIREMENTS
ASSUMPTIONS
   o  Productivity of personnel in safety equipment at 100% is 15 CF/hr
      for hand excavation
   o  Productivity of backhoe opeiatoi in safety equipment at 100%  is
      50 C.F./hr.
   o  Productivity of personnel in safety equipment at 100% foi
      handling drums is the following:
        a.  Waste drums in trench
        b.  Excavated soil drums
        c.  Machine excavated drum
        d.  Drum decontamination
2 man-hrs/drum
1 man-hr/drum
1/2 man-hr/drum
1/2 man-hr/drum
   o  Labor rates with $4.50/hr premium on Union rates  for Barry County

       a.  Laborer                                $13.93/hr.
       b.  Light, Fork Lift Equipment Operator     16.25/hr.
       c.  Medium Backhoe Equipment Operator       16.85/hr.
       d.  Heavy Crane Equipment Operator          17.33/hr.
       e.  Foreman, Safety Officer                 19.85/hr.
       f.  Supervisor, Project Engineer            40.00/hr.
LABOR REQUIREMENTS (On site)
Hand excavation
           Soil excavation within trench
           8,400 C.F. © 15 C.F./manhour
           Removal of waste from drums 4 removal
           of empty drum  in overpack
           150 x 1 man hr./drum
           Removal of drums filled with hand
           excavated soil
           1,555 x 1/2 man hi./dium
                                      TOTAL
     Hours
     560
     150
     780
   1,490    1,490
                                 E-11

-------
                                TABLE  E-3.3 con't
 Machine  Excavation
 4,400  C.F./50  C.F./hr

 Drum Handling
 1.   New  Drums  with  Waste  & Overpacks
     150  drums  x  1 man  hour/drum
 2.   Drums Containing Hand Excavated Soil
     1,553 x  1/2  man hour/drum
 3.   Drums Containing Machine Excavated Soil
     815  drums  x  1/2 man hour/drum
                  Hours    Hours
                    88       88
 Drum Decontamination
 2,370 drums + 300 new drums & overpacks +
 x 1/2 man hrs./drum
110
                 1,410


        1,390    1,390

TOTAL HOURS*     4,298
» Does not  include offsite support and supervisory personnel

TOTAL PERSONNEL REQUIREMENTS PER SHIFT
     a.  Trench excavation
     b.  Backhoe operation
     c.  Drum Decontamination
     d.  Drum handling, drum removal,
         transport to D-con
     e.  On-site backup personnel
     f.  Personnel decontamination
     g.  Crane operator
     h.  Off-site mateiial handling
     i.  Fork lift
     j.  Foreman
     k.  Safety officer
     1.  Project engineer
 Outside  Inside
  Fence    Fence
             6
             1
             6
     6
     1
     3
     1
     1
     1
     1
             6
             9
                6
                9
                6
                1
                3
                1
                1
                1
                1
                                                                    42 per  shift
                                         E-12

-------
                                   TABLE E-4

                                  COMPONENT 3B

                                   EXCAVATION
ASSUMPTIONS
    o  Drums and intermingled soil removed  from trench
    o  Sample trench floor and walls to determine concentration  of  TCP  &  TCDD are
       within acceptable  limits
    o  Only firm cost would be the first  time sampling  and,  if positive results,  the
       platform construction.
    o  Single shift  activity due to  lower hazard
FIXED COST
  Sampling of Trench                                                      $44,000
  (WSU estimate on analysis of  40  samples)

  Drum platform and  loading ramp construction
   Concrete pad 35' x  10'  x 6"
   for 50 drums
     o Formwork and  preparation                           $ 200
     o Concrete,  1 C.Y.  load, delivered                      350
     o Backhoe
       2 day 
-------
                                TABLE E-4 con't
MATERIAL
   Drums (See Table E-4.1)
   204 drums/day x $25/drum

   Water (See Table E-4.1)
   (Decontamination water)-t-(shower water)
   = 944/gal/day x $0.05/gal

   Personnel Protection Equipment
   1.  Respirator cartridges
       16 people x 8 cart/day x $3.85 +  10%
       4 people x 4 cart/day x $3.85 •»- 10SS

   2.  Disposable splash  suits
       20 people x $12/unit + 10%

                                       TOTAL
$5,100/day
    50/day
   550/day
    70/day
   270/day
$6,040/day
$6,040/day
 EQUIPMENT
          a.   Crane  with Clamshell
              Rental & operating

          b.   Backhoe Loader
              Rental & operating

          c.   Forklift
              Rental & operating
 $   340/day


 $   210/day


 $   130/day
          d.  Flatbed Truck
              Rental & Operating                      $   85/day

          e.  Water Truck
              Rental A Operating                      $  130/day

          f.  Shower Truck
              Rental + operation                      $  350/day

          g.  Miscellaneous equipment & utilities     $  350/day

                                            TOTAL     $1,550/day
                  $1,550/day
                                      E-14

-------
                                TABLE E-4 con't
LABOR (see Table E-4.1)
   Laborers
   15 people x 8 hrs/day x $13.93/hr
   Equipment operators
   1.  Crane
       1 person x 8 hrs/day x $17.33/hr
   2.  Backhoe
       1 person x 8 hrs/day x $16.85/hr
   3.  Forklift
       1 person x 8 hrs/day x $16.25/hr

   Supervisors
   1.  Project engineer
       1 peison x 8 hrs/day x $40/hr
   2.  Safety officer
       1 person x 8 hrs/day x 19.85/hi

   Per Diem
   20 people x $45/day
BACKFILL
   Virgin Soil:  38.5 C.F. x $7.5/C.F.
                                        TOTAL
$ 1,675/day



    140/day

    135/day

    130/day



    320/day

    160/day


    900/day
 $3,460/day
                                        TOTAL VARIABLE COST  FOR
                                                  COMPONENT  3B

                                        THE COST FOR REMOVING
                                                  1 CUBIC  YARD IS
S 3,460/day


$   290/day

$11,340


$   380
                                    E-15

-------
                                 TABLE  E- 4.1

                               EXCAVATION DATA
     Labor requirement:   20 personnel
     IZ on-SJte laborers (2 backup)
      3 off-site laborers
      1 crane operator
      1 backhoe operator
      1 folk lift operator
      1 supervisor
      L safety officer
SUPPORTING CALCULATIONS

SOIL
     Volume of soil to be excavated
     6 people x 4 drums/hour x 8 hours
     192 drums x 7.3 C.F./drum x 1.35 (swell factor)
     1040 C.F./day/27 C.F./C.Y.

     Volume to be machine excavated
     38.5 C.Y./day
WATER
     Volume of decontamination water
     Drums
          192 drums x 2 gal/drum/day
     Personnel
          16 people x 10 gal/person/day
     Volume of shower watei (not stored)
     20 people/day x 20 gal/person
 192 drums/day
1040 C.F./day
  38.5 C.Y./day
 384 gals/day

 160 gals/day
 544 gals/day
 400 gal/day
DRUM REQUIREMENTS
     Drums
          192 drums contain soil

     Personnel A Drum Contamination
         544 gal/day/55 gal/dium

     Micellaneous
 192 drums


  10 drums

   2 drums
 204 drums
                                     E-16

-------
                             TABLF E-5

                            COMPONENT 4

                            SITE  CLOSURE
 ASSUMPTIONS
   o  Remove  all  materials  From site
   o  Close site  and secure storage facility
   o  All .contaminated material placed in storage
   o  No surcharge  on equipment use
 ESTIMATED COSTS FOR COMPLETION OF THIS COMPONENT:

 EQUIPMENT

   Steam cleaner
      Rental + operating costs 2 wks 0 $250/wk     ¥500
   Flatbed truck
      Rental
      2 wks x $150/wk                               300
      Operating
      4 hrs/day x 10 days x $l/hr                    40
   Water truck
      Rental
      2 wks @ $380/wk                                760
      Operating
      4 hrs/day x 10 day x $1 hr                   _ 40    _
                                                   1 ,640    $1 ,640
PERSONNEL PROTECTION EQUIPMENT

   Disposable coveralls
      6 people x 1 unit/day x $12/unit
      x 10 days + 10S                                790
   Respirator cartridges
      6 people  x 8 cart /day x
      $3.85/cart + 1055                               190
                                                     980        980
 MATERIALS

   Drums
      Drums for disposables
      2 drums/day x  10 days x $25/drum               300
   Water
      Steam cleaning
      150 qal/day x 8 days x $0.05/qal                 60
      Personnel
      6 people x  10 days x 5 qal/day  x
      $0.05/gal                                        75
                                 E-17

-------
                              TABLE E-5 con't

Disposable supplies
   Gloves, tiashbags, etc.                          $200
                                                     840        840

LABOR
Laborers
    5  people x 8 hr/day x 10 days
    x $13.93/hr                                    5,575
Supervisor
    1 person x 8 hr/day x 10 day
    x $40/hr                                       3«2DO
Per diem
          60 man days x $45/man days               2,700   	
                                                  11,480    11,480
DEMOBILIZATION

      Remove all equipment                                    3,000
Trench Backfill
(Based on Phase I Excavation)
Virgin Soil                                                	
640 C.Y. x 7.5/C.Y.                                4,800      4,800

    Bulldozer Rental
    1 wk. x $400/wk. +  $200  Delivery                  600
    Bulldozer Operating Cost
    3 days x 8 his/day  x $4.00/hr.                    100
    Bulldozer Operatoi
    3 days x $16.85/hr. x 8  hrs./day                  405
                                                    1,110     1,100
                                        TOTAL  COST  OF
                                              COMPONENT 4   $23.840
                                    E-18

-------
APPENDIX F
CREDENTIALS

-------
                               APPENDIX  F
                               CREDENTIALS
     The selection of  the  remedial action necessary  for  the Denny  Farm
Site 1 cleanup has necessarily been a multidisciplinary effort.   Ecology
and Environment's  (E  & E)  Region  VII  FIT office has  been developed  to
support the investigation requirements  of the contract.    In  considering
both  the  technical  and time  requirements for  the completion  of  this
present study, the E  & E FIT  National  Project Management Office  (NPMO)
developed a Special Projects  Team composed of  specialists  from throughout
the  country.    Regional  direction was  maintained  with  technical  and
publications support  provided by the NPMO.
     The following  persons  were assigned to   the  Special Projects  Team
either through the duration of the study or for special support.

JAMES J. BUCHANAN
Discipline:   Project Management
Team Assignment:   Project Manager
Educational Credentials:  Postgraduate Studies in Analytical  Chemistry;
                          B.S., Aquatic Biology/Chemistry
Summary of Work Experience;
Mr. Buchanan has had extensive  experience in  the management  of hazardous
waste  and  pollution  control  projects.   At the  present time, he  is  the
manager of  Ecology and  Environment's  Field  Investigation Team  Regional
Office  in  Kansas  City  (Region  VII).    Mr.   Buchanan  has also  been  an
instructor in the  control of hazardous  materials for  various groups, and
he has been an Environmental Emergency  Response  Team Leader  in the State
of Ohio.

RUSSKLL J.  ENDS
Disciplines:  Toxic and Hazardous Waste Identification; Solid Waste
              Management; Transportation of Hazardous  Wastes
Team Assignment:   Deputy Project Manager
                                  F-l

-------
Educational Credentials:   B.S.,  Botany and Chemistry;  Pharmacy
Summary of Work Experience:
Mr. Enos  has over  five  years of  project management  experience in  the
investigation  of  solid waste  and hazardous  waste facilities  including
background  information search;   environmental monitoring  (air,  surface
water,   groundwater);    short-term/long-term   remedial   measures;    and
alternate methods of disposal and  treatment.   In  addition, Mr.  Enos  has
served  as  a  private  consultant  to  those  generating,  transporting,  or
disposing of hazardous wastes.

ROBERT J. KING
Disciplines:  Mechanical Engineering  and Public Health
Team Assignment:  Resource Coordinator
Educational Credentials:   M.P.H., Public Health;  United Nation1s Graduate
                          Program on  the Human Environment; B.M.E.,
                          Mechanical  Engineering
Summary of Work Experience;
Mr. King is  the Assistant  National  Project  Manager  for Training  and
Safety for the Field Investigation of Uncontrolled Hazardous Waste Sites.
Mr. King has  also been  responsible  for environmental  work  on a  $40
million  technical  support   contract   with  the  Department  of  Energy's
Division of Fossil Fuel Processing coal conversion program.

JON R. BARKHURST
Discipline:  Mathematics
Team Assignment:  Risk Analyst
Educational Credentials;   M.S.,  Mathematics
Summary of Work Experience;
Mr.  Barkhurst  works   in  Ecology  and Environment's  Risk  and  Hazards
Management  Group.    He has  evaluated  leaks  associated   with  petroleum
transportation systems and has  formulated mathematical  models to predict
expected damage  from  large  pipe breaks.  He  applied  probability theory,
statistical methods, pipe fractional  mechanics, and computer modeling for
this study.
                                  F-2

-------
EDWARD M. BRIESCH
Discipline:  Chemical Engineering
Team Assignment:  Chemical Engineer
Educational Credentials:   Professional Engineer
Summary of Work Experience:
Mr.  Briesch  has  extensive  experience in  engineering investigations  of
industrial accidents  (including  fire  and explosions), defective  product
designs, and accident preventions.  He also has  been  responsible  for the
analysis  of  hazards  connected  with  various  chemical products  and  the
installation of chemical facilities.

JOHN A. CAOILE
Discipline:  Civil Engineering and Geology
Team Assignment;  Geologist
Educational Credentials:  B.S.,  Geology;  Senior  Undergrduate  Standing in
                          Civil Engineering (1980)
Summary of Work Experience:
Mr.  Caoile's  previous  work  experience  has   been in  the  geotechnical
consulting  field.    His  work included supervision and field  logging of
drill crews, laboratory testing of soil and rock,  preparation of geologic
maps  and cross sections, and  field inspections.  Mr. Caoile's  previous
projects  have  included  seepage studies for wastewater treatment  plants,
foundation  soil  investigations,  sewage   lagoon  studies,  development  of
criteria   for   compaction   requirements   using    bentonite   to   control
permeability,  drainage of excavations, and settlement analysis.

GARY  P.  Cl.EMONS
Discipline:  Biology
Team  Assignment:  Toxicologist/Puhlic Health
Educational  Credentials:   Ph.D.,  Fungicide  Toxicology;  M.S., Insecticide
                          Toxicology; B.S., Entomology
Summary  of Work Experience:
Dr.   demons   has   seven  years   of   experience   in   laboratory  research
investigation  dealing with  the  mode  of  action  and  animal  metabolism of
agricultural toxins and  the purification and  chemical nature of red-tide
algae toxins.   He  has  also had  five years  of  experience  with  the U.S.
                                   F-3

-------
National Park  Service  and Ecology and  Environment  in the  environmental
management of natural areas.

FRANK COATES
Discipline:  Biology
Team Assignment:  Safety Officer
Educational Credentials:  B.A.,  Biology
Summary of Work Experience:
Mr. Coates  was hired by  Ecology  and Environment,  Inc.,  in  April  1980.
Before joining E & E, he worked for a period  of  three years with OSHA in
St. Louis,  Missouri    Mr. Coates has  also  had one year's  experience at
the Loyola  (Chicago) University Medical Center.

RICHARD P. HARRINGTON
Discipline;  Safety Management
Team Assignment:  Safety Officer
Educational Credentials:  M.S., Public Safety
Summary of Work Experience:
Mr. Harrington is experienced  in handling  emergency  situations  and  has
several years  of  experience  in establishing  and  operating  fire fighting
programs  at Air Force missile  bases.   He is  knowledgeable in emergency
response  field organization  and practices.   Mr. Harrington  has studied
public  safety, accident  investigation,  physical security,  and  law in
recent graduate studies.

JOSEPH H. HOFFMAN
Disciplines:   Mathematics and Physics
Team Assignment:  Risk  Analyst
Educational Credentials:  M.A., Mathematics;  B.S., Physics
Summary of  Work Experience:
Mr. Hoffman is a member  of  Ecology  and  Environment's  Risks and Hazards
Management  Group.    As  such, he  analyzes the  hazards to  public safety
associated  with a number of E  & E's  projects,   e.g.,  the  transport  and
terminal  transfer  of liquefied natural gas and  liquefied petroleum  gas.
In order  to quantify  these risks in an  objective  way, Mr. Hoffman applies
the  best  available  scientific knowledge  and  methodolopgy  to develop
                                  F-A

-------
mathematical models which can   be   used   to   predict   the   physical
consequences of an accident.   This requires an interdisciplinary approach
to the description or modeling of several distinct types of problems.

BOYD N. POSSIN
Discipline:  Hydrology/Geology
Team Assignment:  Hydrologist/Geologist
Educational Credentials:  B.S.,  Earth  Science;  M.S.,  Water  Resources
                          Management; M.S., Geology
Summary of Work Experience:
Mr. Possin has over seven years  field  and  office experience  in defining
groundwater-surface water relationships in soil and bedrock  regimes.   He
has conducted landfill hydrology  and  groundwater  containment  movement
studies in residual soil, carbonate bedrock environments in Pennsylvania,
and in glacial soil, multiple   lithological   bedrock   environments   in
Wisconsin, Illinois, Minnesota, and Indiana.

JOHN B. SCHULTZ
Disciplines:  Information/Documentation Management and Public Affairs
Team Assignment:  Public Information/Documentation Officer
Educational Credentials:  M.A.,   Education;    M.A.,    Religion;    B.A. ,
                          Philosophy
Summary of Work Experience:
Mr. Schultz has nearly twenty  years  of experience  in the  gathering  and
dissemination of information and  in  writing  and editing for publication.
This experience has included  work with  highly  technical  data and  with
sensitive, secret, and top secret material.   Since  1973,  Mr.  Schultz has
been working mainly in the areas  of  medical  education (particularly drug
abuse), energy, and environmental studies.

JACK E. WILCOX
Discipline:  Environmental Engineering
Team Assignment:  Environmental Engineer
Educational Credentials:  Professional   Engineer   in   Training   (EIT);
                          B.S.E., Environmental Engineering
                                  F-5

-------
Summary of Work Experience:
As a member of  Ecology and  Environment's  Technical  Assistance  Team  in
Region VI for EPA, Mr. Wilcox  observed  and monitored the cleanup of  the
Vertac waste  site near Little  Rock,  Arkansas.   He  also organized  the
sample results and provided requested  technical assistance for that  job.

JOHN ZIRSCHKY
Disciplines:  Environmental Civil Engineering
Team Assignment:  Cost Estimating and  Earthwork Evaluation
Educational Credentials:   M.S.,  Environmental Engineering;   B.S.,  Civil
                          Engineering
Summary of Work Experience:
Mr. Zirschky  has   one  year   of  research   experience   involving  the
construction and operation of land treatment systems.  He has also worked
with conventional treatment systems.

     The  following subcontractors were used for the study:

F.C. Hart Associates,  Inc.
     Subcontractor to  E  & E on the FIT program; provided  resources and
     expertise  on the  evaluation  of mitigative options.

Gross, Shuman,  Brizdle. Laub &  Gilfillan, P.C.
     E &  E  corporate legal counsel; provided review of legal  requirements
     of the Denny Farm Site 1 cleanup.

Dr. Raymond D.  Harbison
     Discipline:  Pharmacology  and  Biochemistry
     Team Assignment;  Health Advisor
     Educational  Credentials:   Ph.D., Pharmacology and Biochemistry
     Summary of Work Experience:
     Dr.  Harbison  directs  the  National   Hazardous  Materials  Training
     Course which is  sponsored by the Toxic Substance Control Institute.
     He has also  worked as a consultant  to  E & E on the  Oil  and Hazardous
     Materials  TAT  program for EPA and  on E  & E's  corporate Health  and
     Safety Committee.
                                  F-6

-------
Dr. Robert C.  James
     Discipline:   Toxicology
     Team Assignment;   Toxicologist
     Educational  Credentials:   Ph.D.,  Pharmacology;  B.S.,  Chemistry
     Summary of Work Experience:
     As  a  toxicologist  for  AWARE,  Inc. ,   Dr.  James  assisted  in  the
     assessing of  the  impact  of  toxic  and  organic materials  on  the
     environment   from various  hazardous waste  treatment  and  disposal
     sites.  Dr.  James also has authored various  publications on clinical
     pharmacology and toxicology.

LaBella Associates, P.C.
     Engineering   and  management  firm in the  design of waste  management
     systems;   provided  engineering expertise  in   the  design  and  cost
     estimates for storage operation.

Technos, Inc.
     Geophysical   survey  firm;  provided  field  evaluation  of  geology  and
     hydrology by use of remote geophysical sensing technology.

Terraeon, Inc.
     Well drilling firm;  completed drilling for sampling program.
                                  F-7

-------