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X ^W I U N I T E D S T A T E S E N V I R O N M E N T A L P R O T E C T I O N A G E N C Y •x)
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DECLARATION FOR THE RECORD OF DECT.STfTN
SITE NAME AMD LOCATION
VERTAC, INC., Jacksonville, Arkansas
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action forVenae, Inc. in Jacksonville. Arkansas, which was chosen inaccordance with CERCLA, as amended by SARA, and, to the extentpracticable, the National Oil and Hazardous Substances PollutionContingency Plan (NCP). This decision is based on theadministrative record for this site.
The State of Arkansas concurs with the selected remedy (seeAppendix E ) .
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances froin thiss i te , if not addressed by implementing the response action selectedin th is Record of Decision ( R O D ) , may present an imminent andsubstant ia l endangerment to public health, we l fa re , or theenvi rorunent.
DESCRIPTION OF THE SELECTED REMEDY
This Record of Decision is for the Vertac off-si te areas. The of f -site areas include the active and abandoned sewage collectionlines, abandoned Old Sewage Treatment Plant, active West WastewaterTreatment Plant, and the Rocky Branch Creek and Bayou Meto floodplain and sediments.
The major components of the selected remedy include:
o Sewage Collection Lines -- Sediments would beremoved from the active sewage collection linesbetween the Vertac plant site and the WestWastewater Treatment Plant and incinerated onsite.Pipe liners would be installed in the cleaned sewerlines. The abandoned line would be filled withgrout to reduce the migration of contaminants in theline.
o Old Sewage Treatment Plant -- The sludge would beremoved f rom the sludge digester and incineratedonsite. The sludge drying beds would be capped wi th
one foot of clean soil. Accumulated water in thetreatment units would be removed, treated anddischarged, and the treatment units would bedemolished and capped with one foot of clean soil.A notice would be placed in the deed recommendingthat the Old Sewage Treatment Plant site zoningremain commercial/industrial and access berestricted.
o West Wastewater Treatment Plant — The aerationbasin would be drained, the dikes demolished, andthe entire basin capped with one foot of clean soil.A notice would be placed in the deed recommendingthat the West Wastewater Treatment Plant site zoningremain commercial/industrial and access berestricted.
o Rocky Branch Creek and Bayou Meto Flood Plain -- Inorder to minimize ecological damage to thefloodplain and to the downstream areas, thefloodplain areas that are currently residentiallyzoned will be resampled and only those areas withactual 2 , 3 , 7 , 8 tetrachloro-dibenzo-p-dioxin ( 2 , 3 , 7 , 8TCDD) levels greater than 1 . 0 ppb will be removedand incinerated onsite.
o Rocky Branch Creek and Bayou Meto -- Monitor fishin these streams for dioxin and continue ban oncommercial fishing and advisory discouraging sportfishing as long as fish fillet tissue dioxin levelsare above Food and Drug Administration alert level.
The residuals from wastewater dewatering and treatment (such asfilter spools, spent activated carbon, e t c . ) would be incineratedonsite. Onsite refers to areas within the Vertac Plant fence line.Incinerator ash would be disposed of onsite.
The drummed wastes onsite are currently being incinerated under astate contract. The State of Arkansas is using the funds from atrust fund that was established when Vertac went bankrupt for thisincineration project. A Remedial Investigation/Feasibility Study(RI/FS) for the onsite facility, structures, soils, groundwater,etc. , is in progress. This RI/FS will be conducted under twooperable units ( O U ) . The RI/FS for OU #1 (tank contents, above-ground structures, e t c . ) will be completed by December 19 9 0 . TheRI/FS for ou #2 (soils, groundwater, e t c . ) is scheduled forcompletion in March 19 9 2 .
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and theenvironment, complies with Federal and State requirements that arelegally applicable or relevant and appropriate to the remedial
t^<£>00action, and is cost-effective. : This remedy utilizes permanent <
solutions and alternative treatment technology, to the maximum (^extent practicable, and satisfies the statutory preference forremedies that employ treatment that reduces toxicity, mobility, orvolume as a principal element.
Because this remedy will not result in hazardous substancesremaining onsite (that is, in the off-site areas addressed by thisROD) above health-based levels, the five-year review will not applyto this action.
SEPim000___ ^^Date Robert E. Laytoi
Regional Administrator
VERTAC SUPERFUTJD SITERECORD OF CONCURRENCES
The Vertac Superfund Site Record of Decision for the Off-SiteOperable Unit has been reviewed and I concur:
h< >.fc.^/kN.I S. Ramesh, Rei.} S. Ramesh, Remedial Project ManagerSuperfund Enforcement - Arkansas/Louisiana Section (6H-EA)
Suparfund Enforcement - Arkansas/Louisiana Section (6H-EA)
A^ 7<^___________________Sam Becker ,Ch ie fSuper/f\m^ EnfoYceprSnt Branch (6H-E)/ J / / / / / ^ } . I f
lark Peycke, ChiefWaste Enforcement, ALON Section (6C-WA)
'6'eorge R. AlexanderRegional Counsel (6C
Allyn M . Davis, DirectorHazardous Waste Management Division ( 6 H )
Mel McFarIan(f7Waste Enforcement, ALON Section (6C-WA)
THE DECISION SUMMARYVERTAC OFF-SITE
JACKSONVILLE, ARKANSASSEPTEMBER 1990
UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION 6 , DALLAS, TEXAS
TABLE OF CONTENTS §
00
I. SITE NAME, LOCATION, AND DESCRIPTION . . . . . . . 1 0SITE NAME AND LOCATION . . . . . . . . . . . . . . . . . 1 0GEOGRAPHY . . . . . . . . . . . . . . . . . . . . . . . 1
I. SITE NAME, LOCATION, AND DESCRIPTION . . . . . . . 1^ SITE NAME AND LOCATION . . . . . . . . . . . . . . . . . 1
GEOGRAPHY . . . . . . . . . . . . . . . . . . . . . . . 1LAND USE/POPULATION . . . . . . . . . . . . . . . . . . 4
f GEOLOGY . . . . . . . . . . . . . . . . . . . . . . . . 6GROUNDWATER . . . . . . . . . . . . . . . . . . . . . . 10
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES . . . . . . . 13HISTORY OF THE VERTAC SITE . . . . . . . . . . . . . . . 13HISTORY OF SITE INVESTIGATIONS . . . . . . . . . . . . . 16PRE-1985 REMEDIAL INVESTIGATION (RI ) DATA . . . . . . . 161985 OFF-SITE REMEDIAL INVESTIGATION . . . . . . . . . . 181986 ENDANGERMENT ASSESSMENT . . . . . . . . . . . . . . 191986 FEASIBILITY STUDY . . . . . . . . . . . . . . . . . 19POST-1985 RI DATA . . . . . . . . . . . . . . . . . . . 20REMOVAL ACTION BY HERCULES . . . . . . . . . . . . . . . 211990 SUPPLEMENTAL FEASIBILITY STUDY . . . . . . . . . . 21HISTORY OF ENFORCEMENT ACTIVITIES . . . . . . . . . . . 22
III . HIGHLIGHTS OF COMMUNITY PARTICIPATION . . . . . . . . . 24
IV. SCOPE AND ROLE OF VERTAC OFF-SITE OPERABLE UNIT WITHINSITE STRATEGY . . . . . . . . . . . . . . . . . . . 25
V. SUMMARY OF SITE CHARACTERISTICS . . . . . . . . . . 27SOURCES OF OFF-SITE CONTAMINATION . . . . . . . . . . . 27EXTENT OF CONTAMINATION . . . . . . . . . . . . . . . . 28DATA COMPARISON . . . . . . . . . . . . . . . . . . . . 38
VI . SUMMARY OF SITE RISKS . . . . . . . . . . . . . . . . . 47TARGET CLEANUP AREAS AND ACTION LEVELS . . . . . . . . . 52
VI I . DESCRIPTION OF ALTERNATIVES . . . . . . . . . . . . . . 54COMMON REMEDIAL ACTIVITIES . . . . . . . . . . . . . . . 78RCRA ARAR'S . . . . . . . . . . . . . . . . . . . . . . 92
VIII . SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES . . . 94
IX. THE SELECTED REMEDY . . . . . . . . . . . . . . . . . 101
X. THE STATUTORY DETERMINATIONS . . . . . . . . . . . . 103
XI. DOCUMENTATION OF SIGNIFICANT CHANGES . . . . . . . . 106
X I I . RESPONSIVENESS SUMMARY . . . . . . . . . . . . . . . 107
LIST OF FIGURES
FigureFigureFigureFigureFigureFigureFigureFigure
PlantFigure 9 -
Site Location Map . . . . . . . . . . . . . . . .Venae Off-Site Investigation Area . . . . . . . .Zoning Map . . . . . . . . . . . . . . . . . . . .General Geology . . . . . . . . . . . . . . . . .Local Aquifers . . . . . . . . . . . . . . . . . .Vertac Plant site . . . . . . . . . . . . . . . .Areas Sampled in Recent Investigations . . . . . .TCDD Levels Measured in Residential Area South ofSite . . . . . . . . . . . . . . . . . . . . . . .
• Most Recent TCDD Levels Measured in West WWTPFacilities and Vicinity . . . . . . . . . . . . . . . .
Figure 10 - Most Recent TCDD Levels Measured in Old STP andVicinity . . . . . . . . . . . . . . . . . . . . . . . .
Figure 11 - Most Recent TCDD Levels Measured in Bayou Meto &Flood Plain - 0.1 to 0.88 River Miles Below West WWTPOutfal l . . . . . . . . . . . . . . . . . . . . . . . .
Figure 12 - Most Recent TCDD Levels Measured in Bayou Heto &Flood Plain - 0.88 to 2 . 4 0 River Miles Below WWTPOutfa l l . . . . . . . . . . . . . . . . . . . . . . . .
Figure 13 - Most Recent TCDD Levels Measured in Bayou Meto &Flood Plain - 2 . 4 0 to 3 .23 River Miles Below West '.-,'WTPOut fa l l . . . . . . . . . . . . . . . . . . . . . . . .
Figure 14 - Most Recent TCDD Levels Measured in Bayou Meto andFlood Plain - 3 .23 to 4 . 0 9 River Miles Below West WWTPOut fa l l . . . . . . . . . . . . . . . . . . . . . . . .
FigureFigureFigureFigureFigureFigureFigureFigureFigureFigureFigure
15
161718192021^ '"
23"> 1<— "T
25
1984 TCDD Levels in Sewage Collection LinesAssembled Remedial Action Alternatives . .Alternative 2 Flow Diagram . . . . . . . .Hydraulic Cleaning Procedure for Sewer LineAlternat ive 3 Flow Diagram . . . . . . . .Pipe Liner Installation . . . . . . . . . .Al ternat ive 4 Flow Diagram . . . . . . . .Alternative 5 Flow Diagram . . . . . . . .Alternat ive 5a and 6b Flow Diagram . . . .Onsite Incineration Process Schematic . . .Wastewater Treatment Process Schematic . .
LIST OF TABLES
Table 1 - Generalized Geologic Section . . . . . . . . . . . 7' Table 2 - Vertac Information Sources . . . . . . . . . . . . 17
Table 3 - Sampling Data Comparison for 2,3,7,8-TCDD . . . . . 41Table 4 - 1986 Endangerment Assessment (Summary of Site
Problems and Associated Risks) . . . . . . . . . . . . . 48Table 5 - Identification of Potential Remedial Actions . . . 55Table 6 - 1990 FS Estimated Volumes of Material Considered For
Remediation . . . . . . . . . . . . . . . . . . . . . . 57Table 7 - Alternative-Specific Rotary Kiln Incineration
Scenarios . . . . . . . . . . . . . . . . . . . . . . . 80Table 8 - Air Contaminants, Regulations, and Standards . . . 84Table 9 - Solids Dewatering Data . . . . . . . . . . . . . . 86Table 10 - Volume & Disposition of Wastewater . . . . . . . . 87Table 11 - Identification of Potential Location-specific
ARAR'S . . . . . . . . . . . . . . . . . . . . . . . . . 90Table 12 - Comparative Analysis of Alternatives . . . . . . . 95
LIST OF APPENDICES
Appendix A - EPA Memorandum on Sediments, dated January 2 6 ,1989
Appendix B - ATSDR Memorandum, dated April 24, 1986Appendix C - ATSDR Memorandum, dated June 1 1 , 1990Appendix D - Applicable or Relevant and Appropriate
Requirements (ARAR's)Appendix E - ADPC&E Concurrence Letters
THE DECISION SUMMARYFOR VERTAC, INC. OFF-SITE
OPERABLE UNIT
I. SITE NAME, LOCATION, AND DESCRIPTION
SITE NAME AND LOCATION
The Vertac, Inc. Superfund Site is located in Jacksonville,Arkansas (Figure 1) and consists of the Vertac Plant Site (orOnsite) and the Vertac Off-Site area (Figure 2 ) . The VertacOff-Site area addressed in this Record of Decision includes:
o Wastewater collection lines between the Vertac Plant siteand wastewater treatment facilities, including 10,350 feetof active lines and 4 ,350 feet of the abandoned Rocky BranchCreek interceptor.
o Old (abandoned) sewage treatment plant (Old S T P ) , includingclar i f iers , trickling filters, sludge digester, sludgedrying beds, and surface soils.
o West Wastewater Treatment Plant (West W W T P ) , including thethree-acre aeration basin (lagoon) and two 22-acre oxidationponds.
o Rocky Branch Creek and Bayou Meto flood plain, including theresidentially-zoned area south of the Vertac property lineand north of the fork in Rocky Branch Creek.
o Rocky Branch Creek and Bayou Meto sediments.
GEOGRAPHY
The investigation area occupies approximately 36 square milesin and to the west , south, and east of the City ofJacksonville, Arkansas. The surface gradient in the area isgenerally to the south-southeast. There are two majordrainageways in the area, Rocky Branch Creek and Bayou Meto.Minor drainageways are intermittent streams that f low intoRocky Branch and Bayou Meto in the spring or during periods ofheavy rainfall .
Rocky Branch originates near the northern boundary ofJacksonville and flows generally south, traversing the Vertacplant property along the west side. About two miles south ofthe Vertac plant it empties into Bayou Meto. Being a youngstream. Rocky Branch is characterized by low sinuosity, lowlevels of suspended sediments, and a high bed-load potential.Sediment load of Rocky Branch is derived from erosion ofupgradient and surrounding terrain. Average sediment depth is
BOUNDS OFOFF-SITE FS
0 4000
SCALE IN FEET
Figure 2
VERTAC OFF-SITEINVESTIGATION AREAVenae OM-Site FSJacKsonville. ArKansas
»about 10 inches. Channel deposits are predominantly silt and v^clay. ^
0Generally, both banks are steep, but there are occasional small Qpoint bars at meanders. Lag gravels are found on point bars (^and along the upper reaches of the stream. As the streamapproaches Bayou Meto, the channel becomes wider and deeper andthe sediments become finer.
Bayou Meto begins in the Atoka Formation approximately one milenorthwest of Jacksonville. At the Fall Line, Bayou Metochanges course from south to east, and due to bedrock changes,becomes broad and sinuous. Also, the gradient decreases,resulting in sluggish water flow. Abandoned and partly filledchannels with interconnecting oxbow lakes, ponds, and minortributaries are common.
Sediments in Bayou Meto are generally fine grained sand, silts,and clays. Due to the sluggish water flow, gravel deposits arerare. Organics from vegetation decay also make up a largeportion of the sediment. About 130 miles southeast ofJacksonville, Bayou Meto empties into the Arkansas River.
Precipitation is well distributed throughout the year, thoughspring is the wettest season. August and October are thedriest months. September is not a dry month, however, and highintensity rainfall is not uncommon. Thunderstorms are verycommon, particularly in the summer and fall. An average of 56days a year have thunderstorms, often accompanied by strongwinds and hail.
Evaporation is an important element in the area meteorologicalsystem. During the summer, as much as 1/3 inch of water perday evaporates. Abundant sunshine and high temperatures canresult in drought and a significant loss of soil moisture.Severe droughts occur once every 10 to 15 years.
LAND USE/POPULATION
Land use in the investigation area is a mixture of residentialand agricultural with extensive undeveloped and uninhabitedwoodlands in the area near the confluence of Rocky Branch Creekand Bayou Meto. Land use zoning is shown on Figure 3 . Theportion just south of the Vertac plant site, between MarshallRoad and the Missouri-Pacific railroad tracks, south to W . MainStreet, is residential, a combination of single-family homesand apartments. The section immediately west of the railroadtracks and north of W . Main Street is undeveloped. The areabetween W . Main Street and S. Redmond Road is commercial andlight industrial. Just south of S. Redmond Road isundeveloped, uninhabited land that includes the JacksonvilleSewage Treatment Plant, DuPree Park, and Lake DuPree. The rest
1069071R 1
ZONING MAPVertacO: Site FSJacksonville, Arkansas
of the investigation area is either farmland, mainly irrigated t>rice fields in-the area south of Jacksonville and Bayou Meto, —woodlands, or residential. There is substantial suburban wresidential development on the strip of higher ground alongHighway 161 and in the area north of Bayou Meto.
00C5
The investigation area is partly within and partly adjacent tothe City of Jacksonville. The population growth ofJacksonville has been as follows: 1950 - 2 , 4 7 4 ; 1960 -1 4 , 4 8 8 , 1965 - 18 , 0 7 8 ; 1970 - 1 9 , 8 3 2 ; and 1980 - 2 6 , 7 8 8 . Thepopulation in the area of investigation outside Jacksonvilleis estimated to be about 3 , 3 0 0 .
GEOLOGY
The investigation area lies along the Fall Line, a boundary ofmajor physiographic provinces in Arkansas. Northeast of theFall Line, the Arkansas Valley Province generally consists ofconsolidated Paleozoic Era materials with recent alluvium instream valleys. Southeast of the Fall Line are unconsolidatedQuaternary sediments of the Mississippi Embayment.
Table 1 presents a generalized geologic section of theinvestigation area. Figure 4 illustrates the general geologyof the area. The central area of the City of Jacksonville lieson Wilcox Formation. Wilcox is made up of weathered brownshale, gray micaceous shale, gray and gray-green siltstones andclay, and thick sand beds. The general strike of Wilcoxdeposits is northeast-southwest, with a southeasterly dip ata rate of 20 to 50 feet per mile. Some of the thick sand bedsmake excellent aquifers.
Underlying the wilcox and on the outskirts of the city is theMidway Formation. Most of the Vertac plant lies on Midwaydeposits. Midway is found throughout the Mississippi Embaymentsubsurface and outcrops along the Fall Line. In theJacksonville area it lies unconformably on Paleozoic bedrock.In the study area, the Midway Group is undifferentiated, butin other locations it has been divided into two members. Anupper member is blue-gray to dark gray, fissile, flaky shale,containing sideritic, concretionary layers. The lower memberconsists of soft gray, calcareous, fossiliferous shale withbasal lenses of white limestone. Structurally, the strike ofthe Midway is northeast-southwest, with horizontal beds alongthe Fall Line. Under the embayment, beds dip slightlysoutheast. In the investigation area, the Midway Formation isnot known to provide water for wells. The basal limestone andsandstone lenses furnish water to domestic wells southwest ofLittle Rock, however.
Outside Jacksonville to the south and east, and underlyingapproximately three-fourths of the study area are Quaternary
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alluvial and terrace deposits of the Mississippi Embayment. These 0are Pleistocene Age deposits that are lithologicaily similar, 0overlain by fine sand, silt, and clay of recent age. The terrace 0deposits are on one or more terrace levels. Quaternary recent 0alluvium has been divided into two units on the basis of where theunits are found:
o Deposits of local streams or of overbank flows ofmajor streams (in some areas these include depositsin abandoned meanders of major streams);
o Deposits in major stream channels or in mappablemeanders of major streams (in some areas theseinclude alluvial deposits in natural levees).
These deposits can be further broken down into two distinctlithologic units:
o Surface or upper alluvium is predominantly clay orsilt with basal sand and gravel;
o A lower alluvial unit consists of a coarse basalsand and gravel grading upwards to a fine sand, siltand clay.
The northwest part of the area of investigation is AtokaFormation. The Atoka Formation is the most commonly foundsurface formation in the Arkansas Valley and is thought tounderlie most Mississippi Embayment sediments. A small portionof the Vertac plant lies on Atoka Formation. It outcrops alongthe Fail Line escarpment, or is often covered '.-:ith a thinveneer of Quaternary recent deposits and soil. South of theFall Line the Atoka dips steeply to the southeast. North ofthe ,Fall Line the formation is very thick, perhaps 7,000 to9 ,000 feet, and thins rapidly to the east. Atoka Formationconsists of gray to black, splintery, finely to coarselytextured micaceous shale containing lenses of white, tan, orgray siltstone and fine to medium grained shaly sandstone.The Lower Atoka member found in the study area may also becharacterized by dark colored chert and an interval of mediumto dark gray flaky shale.
Water is found in fractures in the rock, which become fewer andless open with depth. For this reason, water wells in theAtoka are shallow and rarely greater than 50 to 60 feet daep.
Isolated subsurface remnants of undifferentiated Cretaceousdeposits are found near the Fall Line, though they do notoutcrop in the investigation area. Hydrologically they areunimportant. Water found in them is often salty.
^GROUNDWATER QQ
<S>In the investigation area, all rock formations are capable of 0containing groundwater. Figure 5 shows the local aquifers. 0In the relatively impermeable Atoka Formation rocks northwest 0of the Fall Line, most of the groundwater movement is throughbedding planes and fractures. The unconsolidated rockssoutheast of the Fall Line are more permeable, and so havegreater quantities and higher rates of groundwater flow. inthe area of investigation only the Wilcox and Quaternaryformations can be considered aquifers.
Wilcox Aquifers
The Wilcox Formation provides two distinct aquifers. The LowerWilcox aquifer is the most important. This aquifer can yield500 gpm to 2,000 gpm in some places. It is utilized as a watersource east of Jacksonville, but not in Jacksonville or theinvestigation area.
The other Wilcox aquifer is referred to as the Minor Wilcoxaquifer. At this location the Wilcox can be considered ashallow aquifer. Throughout the rest of the area, however,where it underlies Quaternary alluvial and terrace deposits,it is considered a deep aquifer. Wilcox aquifers in theinvestigation area consist of thin sand beds interbedded withclay. The yield and chemical quality of water from Wilcoxaquifers differs widely due to the discontinuous nature of thesand matrix.
Quaternary Aquifers
Quaternary aquifers are also found in alluvial and terracedeposits in the area of investigation. These are shallowaquifers and recharge is primarily by infiltration fromprecipitation. Substantial seasonal water level variationsoccur because the majority of wells in these aquifers are usedfor irrigation. During the summer growing season, water levelscan drop 10 to 15 feet because of over-pumping. These aquifersare part of the Mississippi River Valley alluvial aquifer whichextends 380 miles from north to south and covers most of thewest side of the Mississippi Embayment.
Formerly, the Jacksonville municipal water source was fromQuaternary alluvial aquifers. Currently, Jacksonville gets itswater from sources outside the investigation area.
There are three categories of Quaternary alluvial aquifers inthe investigation area: surface and lower alluvial aquifers,based on surface and lower lithologic units, and an alluvialaquifer in stream valleys overlying Atoka deposits. Except for
10
low pumpage domestic wells, the surface aquifer is rarely used ^due to its low yield of less than 50 gpm. The lower alluvial !^0aquifer constitutes the most important aquifer in the area, 0with yields similar to Wilcox, ranging from 500 gpm to 2,000 0gpm. The alluvial aquifer in stream valleys overlying Atoka 0deposits exists in the northwest part of the area of 0investigation, but is not known to be used as a water source.
Major Quaternary water-bearing zones are generally confined,being overlain by sediments with lower permeability. Aquifercharacteristics depend on the size and sorting of the hostlithologic unit. Because these vary considerably from placeto place, a quantitative statement on hydraulic characteristicscannot be made.
Quaternary alluvial water in the investigation area istypically of the calcium bicarbonate type. The calcium contentranges from 4 to 85 ppm; magnesium 1 to 21 ppm; sodium 3 . 4 to20 ppm; and bicarbonate 15 to 282 ppm. Analysis of water fromwells indicates that the water north of Bayou Meto is less hardand contains less calcium and dissolved solids than typicalalluvial aquifer water. Most alluvial aquifers throughout thearea have a high iron content, ranging from 0.12 to 6 . 8 ppm.
Other units in the area are the Atoka and Midway formations,and undifferentiated Cretaceour, deposits. These do not yieldsufficient water for domestic use, however.
12
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
HISTORY OF THE VERTAC SITE
The Vertac plant was first used in the 1930's as the ArkansasOrdnance Plant, a federal government munitions factory (seeFigure 6 for the plant's location.). In 1948, the Reasor-Hill Company purchased the site and built a plant to formulateinsecticides and herbicides. At first, Reasor-Hillmanufactured insecticides such as DDT, aldrin, dieldrin, andtoxaphene. During the 1950's, Reasor-Hill began production ofthe herbicides 2,4-dichlorophenoxyacetic acid ( 2 , 4 - D ) ; 2 , 4 , 5 -trichlorophenoxypropionic acid ( 2 , 4 , 5 - T P or Silvex); and 2 , 4 , 5 -trichloropehenoxyacetic acid ( 2 , 4 , 5 - T ) . The dioxin compound2,3,7,8-tetra-chlorodibenzo-p-dioxin (TCDD) is an impurityformed during the production of 2 , 4 , 5 - T and is the majorcontaminant of concern at the site. During Reasor-Hill'soperations, untreated process wastewater was discharged fromthe west end of the plant and channeled into Rocky BranchCreek. Rocky Branch Creek flows into Bayou Meto a few milessouth of the site.
Jacksonville residents complained about odors from the Reasor-Hill discharge and about the quality of fish caught in theBayou. In 1 9 6 1 , the City of Jacksonville's sewage treatmentplant (referred to as the Old STP) was upgraded by a'^ing asludge digester, sludge-drying beds, and two 22-acre ox iationponds. At that time, the city agreed to accept and treatwastes from the pesticide plant, and Reasor-Hill begandischarging some of its process wastewater into the City ofJacksonville's sewage treatment plant.
In 1 9 6 1 , the Hercules Powder Company (now Hercules, I n c . )purchased the plant and continued to manufacture he sameproducts. When Hercules purchased the site, drums c stainingorganic wastes that had been stacked by Reasor-Hill 'ithwestof the plant production area were buried there. T: burialarea became known as the Reasor-Hill landfill (see Fi 6 forlocation).
In 1 9 6 4 , Hercules t-.uilt a pretreatment facility consi ig ofequalization ba s : " s and neutralization systems, .ftercomplaints continued regarding water quality downstream • theJacksonville sewage treatment plant, it was determined th - theexisting plant was overloaded. In 1 9 6 9 , Hercules and th :ityconstructed a three-acre aerated lagoon upstream o theoxidation ponds, using a federal grant. After that t i m e , allprocess wastewater from the plant was discharged into theJacksonville wastewater treatment facilities.
13
AND rDllNOAIIONS
glEPLAM
Figure 6
VERia68A(3l&|TE
J \iNDusi^inN69p/i_\nr,y 7 uwr,
0QO0
In 1 9 6 4 , Hercules began to treat its product using a solvent 0process. The process removed most of the dioxin from the 0product, resulting in contaminated liquid and solid waste 0residues. These contaminated still bottoms were pumped intodrums and allowed to solidify. The drums were then buried inan area north of the plant production area. This area iscommonly known as the Hercules-Transvaal landfill area (seeFigure 6 ) .
During 19 6 7 - 6 8 , Hercules produced "Agent Orange," a mixture of2,4-D and 2 , 4 , 5 - T , for the Department of Defense. Agent Orangewas used as a defoliant in the jungles of Vietnam. A findingof possible teratogenic effects of Agent Orange by the NationalCancer Institute resulted in a ban on the use of Agent Orangein Vietnam. Soon after the ban became effective, many otheruses of 2 , 4 , 5 - T were discontinued. Hercules then ceasedoperations at the Jacksonville plant.
From 1971-76, Hercules leased the plant to the TransvaalCorporation. Transvaal resumed production of 2,4-D andintermittently produced 2 , 4 , 5 - T . In 1 9 7 6 , Transvaal purchasedthe property from Hercules. Transvaal buried toluene stillbottom wastes in the Hercules-Transvaal landfill. However, in1974 Transvaal discontinued burying these wastes and beganstoring drums of the waste above ground.
In 1 9 7 8 , Transvaal was reorganized through bankruptcyproceedings and the reorganized company, Vertac ChemicalCorporation, operated the plant until 1987. When EPA bannedmost uses of 2 , 4 , 5 - T in 1 9 7 9 , Vertac halted 2 , 4 , 5 - T production.However, Vertac continued to produce 2 , 4 - D , using the equipmentpreviously used to formulate 2 , 4 , 5 - T . Therefore, the 2,4-Dwaste may have been cross-contaminated with dioxin. In 1982,Vertac began recycling 2,4-D waste liquids and also reportedlyeliminated the potential for cross-contamination by using newequipment. Vertac continued to accumulate drums of 2 , 4 , 5 - Twaste until 1979 and 2,4-D waste until 1987, when pesticideproduction at the site was discontinued.
In 1 9 7 9 , the Arkansas Department of Pollution Control andEcology (ADPC&E) issued an order that required Vertac, Inc. toimprove their hazardous waste practices, and in 1980 the U . S .Environmental Protection Agency (EPA) and ADPC&E jointly filedsuit in federal district court against Vertac, Inc. andHercules, Inc. A Consent Decree entered into by EPA, ADPC&E,Vertac, and Hercules in January 1982 required an independentconsultant to assess the conditions of onsite wastes and todevelop a proposed disposal method for the wastes. Theproposal, called the "Vertac Remedy," was deemed by EPA to beunsatisfactory and EPA returned to court in early 1984 for a
15
resolution. The court decided in favor of the proposed remedy, "'which was implemented in the summer of 1984 and completed in
00<3?0
July 1986.
As part of the remedy, the Vertac plant cooling water pond andthe equalization basin were closed and sediments from theseunits were removed and placed in a sediment vault (shown onFigure 6 ) . The burial area was capped and a French drain andleachate collection system were installed around the burialareas. Groundwater monitoring wells were also installed anda groundwater monitoring program was initiated. The remedy didnot address: 1) 28,500 drums of still bottom wastes from themanufacturing process stored onsite or 2) contaminated processequipment, surface soils, and buildings.
Vertac abandoned the plant in February 1987. However,Hercules, Inc. remained onsite to operate and maintain theleachate collection system and treatment facil i t ies. Since1987, EPA and its contractors have made improvements to thesite by repairing leaking tanks, constructing concrete storagebuildings for drums, improving existing storage areas fordrums, and overpacking leaking drums.
In 1989, ADPC&E signed a contract to have the 2 8 , 5 0 0 barrelsof waste incinerated onsite. The State used funds from a trustfund that was established through litigation. Incineration ofthese wastes is scheduled to begin in Fall 1990.
HISTORY OF SITE INVESTIGATIONS
A great deal of data have been collected since the Vertac Plant•••••as iden t i f ied as a potentially hazardous site in 1978. Thesedata have formed the basis for several reports covering onsiteand of f - s i te contamination, environmental conditions,groundwater , and geology. The major documents are listed inTable 2.
PRE-1985 REMEDIAL INVESTIGATION ( R I ) DATA
ADPC&E and EPA conducted prel iminary environmental sampling forpesticide contamination in the Vertac off-s i te investigationarea before the 1985 R I . This sampling occurred between June1975 and Hay 1983. ADPC&E compiled the sampling results intheir 1983 report. The pre-RI sampling was not conducted underrigorous f i e ld and laboratory quality control practices, andaccurate records concerning sampling methods and locations arenot avai lable for all cases. Consequently, these data are ofquestionable qua l i ty . Subsequent data, described in thefo l lowing discussions, are much more extensive and werecollected, handled, and analyzed under strict data qualityprocedures. The data f rom more recent site investigations are
16
Table 2Vertac Information Sources
Source
Aerial reconnaissance of Venae. Inc., Jacksonville,Arkansas; U.S. EPA. Las Vegas. Nevada,November-May 1979.
Final Report for Environmental Assessment Study,Venae Chemical Corp. Site, Jacksonville, Arkansas.Developers International Service Corp. (DISC),Memphis. Tennessee. October 1982.
Supplemental Report for Environmental AssessmentStudy, Venae Chemical Corp. Site, Jacksonville,Arkansas. DISC, December 1982.
Technical Report for Rocky Branch, Bayou Melo, andLake DuPree. Environmental ToxicologicalConsultants, March 1983.
Summary of Technical Data, Jacksonville. Arkansas.Arkansas Department of Pollution Control andEcology, no date (mid-1983).
Offsite Remedial Investigation Final Report.Prepared by CH2M HILL and Ecology andEnvironment for U.S. EPA Region 6, December 1,1985.
Venae Off-site Endangerment Assessment. FinalRepon. Prepared by CH2M HILL for U.S. EPARegion 6, June 1986.
Venae Off-site Feasibility Studv, Final Report.Prepared bv CH2M HILL for U.S. EPA Region 6,June 1986.'
Report on Fine Grid. Sampling Plan (For TCDD and2.3.7,8-TCDD). Prepared by IT Corporation forHercules Inc., October 1988.
Venae Chemical Plant Draft Report. Prepared byJacobs Engineering Group Inc. for U.S. EPARegion 6. September 28, 1988.TES IV Work Assignment #649- Venae SoilSampling. Prepared by Jacobs Engineering Groupfor U.S. EPA Region VI, June 1. 1989
Hercules/Venae Off-site Study Final Repon, May1990
Description
Historical photographs used to document changesat Venae site and locations of spills andcontamination.
Developed to satisfy the requirements of 1982Consent Decree; contains assessment of onsileconditions.
DISC response to EPA questions that followedreview of previous DISC repon. Includes resultsof recent testing and outlines proposed remedialmeasures.
Summarizes off-site data collected since 1979 forthe three water bodies. (Final report with recentsampling data published in late 1983.)
Compiles data collected in conjunction with theVenae Plant. Includes vinually all sampling dataand excerpts of reports listed above.
Presents results of environmental sampling, plusspecial studies including delineating sonar survey.water use inventory, sewer lamping, and aquaticbiota survey. Also, characterizes the off-site areaand site history.
Evaluates potential for contaminant migration.exposure pathways and scenarios, and risksassociated with off-site contamination.
Based on the 1985 Rl. Includes an evaluation ofalternatives for remediating potential hazardsposed by off-site contamination. Identifies sevenpotential remedial alternatives.
Summarizes off-site sampling results from 1988sampling effort sponsored by Hercules Inc.
Includes results of analysis of duplicate samplestaken by IT Corporation.
Includes results of fine-grid and dusi sampling.
Includes results of 1987 Hercules-sponsoredsampling.
0assumed to best represent the nature and extent of q^contamination. ^
01985 OFF-SITE REMEDIAL INVESTIGATION 0
The RI for the Vertac off-site area was performed between thefall of 1983 and spring of 1985. The purpose was to determineif TCDD migrated beyond the plant site and, if it had, toidentify contaminated areas.
Previous studies suggested that contamination in theinvestigation area would be concentrated in the sewagecollection and treatment system and along the nearbywatercourses (Rocky Branch Creek and Bayou Meto). TCDD isknown to have an extremely low water solubility and a strongtendency to bind to soils or sediments. Therefore, the RIfield work consisted of soil and sediment sampling andanalysis, as well as a series of special investigations,including:
o A flood plain delineation study to estimate theamount of soil that may have been contaminated byflooding
o A sewer lamping study to estimate the amount ofsediment in the sewage collection system
o A sonar survey to estimate the amount of sedimentin the impoundments, including aeration basin andoxidation ponds
o An aquatic biota survey
The soil and sediment sampling results are tabulated in VolumeII of the 1985 off-site RI report ( E P A , December 1 9 8 5 ) . Atotal of 324 soil and sediment grab samples were collectedduring the RI and tested for TCDD. Of the 324 samples:
o 74 samples were taken in December 19 8 3 ; 40 samplescontained measurable quantities of TCDD
o 21 samples were taken in June 1984; one containeda measurable quantity of TCDD
o 225 samples were taken in August 198 4 ; 79 containedmeasurable quantities of TCDD
TCDD method detection limits for these analyses generally werewithin the range of 0. 0 1 to 1 . 0 ppb.
Groundwater sampling and analysis were not included in thestudy plan. EPA's decision to exclude groundwater sampling
18
was based on the low water solubility of TCDD and on the 0results of a limited testing of wells in the early stages of ^the R l , which showed no measurable TCDD in groundwater. ®
0Air was considered a potential pathway of contaminant ^migration. Air monitoring off-site was not pursued because thearea is heavily vegetated, minimizing airborne transport ofsoil and sediment.
0
Previous studies indicated the presence of contaminants otherthan TCDD in the investigation area, such as 2 , 4 - D , 2 , 4 , 5 - T ,2 , 4 , 5 - T P , chlorinated benzenes, and chlorinated phenols. TheRI concentrated on TCDD because it was determined to be themost hazardous contaminant in the area, and remediation forTCDD would likely remediate other contamination problems.Limited exploratory testing was performed for the othercompounds. Elevated levels of chlorobenzenes, chlorophenols,and other contaminants were found principally in the sewagesystem, to a much lesser degree at surface locations near theVertac Plant, and sporadically at locations distant from theplant in Rocky Branch Creek. Findings on these othercontaminants appear consistent with the known tendency of thesecontaminants to degrade more readily than TCDD. In the areaswhere contaminants other than TCDD were found, TCDD was foundat concentrations of greater concern than concentrations of theother contaminants. This supported the assumption thatremediation for TCDD will also remediate other compounds.
1986 ENDANGERMENT ASSESSMENT
Based on the Remedial Investigation results, an endangermentassessment ( E A ) was performed in 1986 to evaluate the potentialhealth and environmental effects if no remedial action istaken. Potential exposure pathways to contaminants includedirect skin contact or ingestion of sediments or soilsoriginating from the sewer system, sewage treatment plants,Rocky Branch, Bayou Meto , or the flood plains; inhalation ofvolatilized organics, if any, from contaminants in the sewersystem, creek, or flood plain sediments or soils; ingestion offish and other aquatic organisms from Rocky Branch or BayouMeto; and ingestion of agricultural products that have beengrown in contaminated soils.
1986 FEASIBILITY STUDY
The initial Feasibility Study was completed in June 1 9 8 6 .Several alternatives, including no action, onsite and offsitedisposal, containment in place, and onsite or offsiteincineration, were developed. A public meeting was held inJacksonville on July 1 5 , 1 9 8 6 , to explain the results of theFeasibility Study, answer questions, and accept comments.However, in October 1 9 8 6 , Congress passed the Superfund
19
^Amendments and Reauthorization Act (SARA) , which amended CERCLA <7Sand set new requirements for the Superfund RI/FS process. 0Because of this new development, the selection of a remedy was ®postponed. 0
0POST-1985 RI DATA
Several sampling efforts have been conducted in the Vertac off-site area since 1985. A brief description of these samplingevents is given below.
1 . 1987 Hercules Grab Sampling. Samples were collectedfrom many of the locations sampled in the 1985 RIstudies. This investigation included:
o TCDD analysis of fish tissue from Lake DuPree
o TCDD and partial priority pollutant analysisof sediment samples from the West WWTP aerationbasin and oxidation ponds, and TCDD analysisfrom areas in and around the Old STP and WestWWTP
o TCDD analysis of soils and sediments from RockyBranch Creek, Bayou Meto, and Lake DuPree, andland adjacent to Rocky Branch Creek and BayouMeto
2. 1988 Hercules Fine-Grid Sampling. Soil and sedimentsamples were collected for TCDD analysis from the RockyBranch Creek banks, the residentially-zoned flood plainimmediately west of the east leg and immediately east ofthe west leg of Rocky Branch Creek, and the West WWTPfacilities. Fish samples from Lake Dupree were alsoanalyzed for TCDD. The results of this sampling effortare compiled in the Report on Fine Grid Sampling Plan(For TCDD and 2 , 3 , 7 , 8 - T C D D ) , Volume I (Hercules I n c . ,October 1 9 8 8 ) .
3 . 1988 EPA Fine-Grid Sampling. Soil samples were collectedfrom the undeveloped residentially-zoned flood plainimmediately west of the west leg of Rocky Branch Creekand south of the Vertac property. The samples wereanalyzed for TCDD.
4 . 1989 EPA Fine-Grid Sampling. The extent ofcontamination was delineated by sampling areassurrounding the soil grids found to contain TCDD levelsgreater than 5 . 0 ppb in the 1988 EPA sampling effort.
20
<5 . Ongoing United States Fish and Wildlife Services <-5&
(USFWS) Wood Duck Studies. The effect of contamination ^on wood duck reproduction is currently being studied. ®
REMOVAL ACTION BY HERCULES °
In 1988, EPA signed an Administrative Order on Consent (AOC)with Hercules. The AOC required Hercules to remove soils fromresidential yards. South of Vertac plant, that werecontaminated above 1 ppb TCDD. It also required Hercules toperform some onsite excavation and drainage control. Areasthat were excavated are shown on Figure 8. Excavated soilswere bagged and placed in a storage facility on the plant site.These bagged soils are being addressed as part of the onsiteRI/FS.
1990 SUPPLEMENTAL FEASIBILITY STUDY
Several developments since the June 1986 report created a needto revise the 1986 Feasibility Study report. Thesedevelopments included:
o Several major sampling efforts were conducted by Hercules,Inc. (one of the potentially responsible parties, or PRPs)and EPA that further defined the extent of offsitecontamination by TCDD.
o The Agency for Toxic Substances and Disease Registry (ATSDR)and EPA have delineated TCDD remediation levels that aresite-specific and area-specific.
o Remedial technologies that are potentially applicable toTCDD contamination, such as incineration, were furtherdeveloped and evaluated.
o In October 1 9 8 6 , Congress passed the Superfund Amendmentsand Reauthorization Act (SARA) , which amended CERCLA and setnew requirements for the Superfund RI/FS process. Chiefamong these new requirements is the preference for remedialactions that ( 1 ) permanently reduce volume, toxicity, ormobility of hazardous substances and ( 2 ) meet Federal andState Requirements.
o Some remedial actions were taken in offsite areas at Vertacsince 1 9 8 6 . Contractors for Hercules, Inc. removed somecontaminated soils from developed residential areas in theRocky Branch flood plain. Access to certain contaminatedareas in the Rocky Branch flood plain was also restrictedby fencing.
As a result of these developments, EPA revised the FeasibilityReport in June 1 9 9 0 .
21
HISTORY OF ENFORCEMENT ACTIVITIES ^03
A Potentially Responsible Party (PRP) search was not conductedsince the Agency knew the identities of former owners,operators, and some generators of waste at the Vertac site, andsince litigation was already going on prior to CERCLAactivities. However, CERCLA Section 104(e) informationrequest letters were mailed in March 1990 and later to severalcompanies, some of which had "tolling agreements" with theVertac Chemical Corporation and/or Hercules, Inc.
The following is a chronology of enforcement activity at theVertac site:
1. Litigation was filed in 1980 under RCRA Section 7003 andother statutes by the United States and the State ofArkansas against Vertac Chemical Corp. and Hercules, Inc.(the "Parties"). In January 1982, EPA and the State ofArkansas entered into a Consent Decree with Vertac ChemicalCorp. and Hercules, Inc. in the litigation for developinga remedial plan for certain onsite and off-site areas.After EPA invoked dispute resolution and a hearing on theremedy, the court ordered the implementation of "VertacRemedy" in July 1984. (See Site History for a discussionof the action taken.)
2. On July 15, 1986, pursuant to an agreement between theparties and entered by the court, Vertac established a TrustFund, as part of a bankruptcy agreement. Placed in thisFund were $ 6 , 7 0 0 , 0 0 0 and a $ 4 , 0 0 0 , 0 0 0 letter of credit tobe used to remediate portions of the plant. Both EPA andthe State of Arkansas have access to this fund, and it isbeing used to incinerate the 2 8 , 5 0 0 drums.
3. In August 1986, EPA issued a Unilateral Administrative Orderto ail PRP's to require posting of warning signs and thefencing of portions of the West Wastewater Treatment Plantand certain areas of Rocky Branch Creek. This work wasperformed by Hercules.
4. In January 1987 EPA issued a notice letter to VertacChemical Corp. that required Vertac Chemical Corp. tocontinue operation and maintenance of leachate collectionand treatment system.
5. In June 1988 EPA signed an Administrative Order on Consentwi th Hercules to allow Hercules to implement f ine gridsampling for of f -s i te areas.
22
0000
^6 . In September 1988 EPA signed an Administrative Order on
Consent with Hercules that required Hercules to remove Qcontaminated soils from residential yards. Q
07. In July 1989 EPA signed an Administrative Order on Consent Q
with Hercules that required Hercules to conduct the onsiteRI/FS.
8. In March 1990 EPA sent CERCLA Section 104 ( e ) informationrequest letters to several companies which had been involvedin business deals with Vertac Chemical Corp. and Hercules,I n c . , including "tolling agreements".
9 . In July 1990 EPA sent General Notice letters to the PRP'sregarding the proposed off-site remedial plan and other siteactions.
10. A consent decree between the U . S . government and companiescreated from Vertac Chemical Corp. is currently pendingbefore the court. These companies would contributeapproximately $1,800,000 to the Trust Fund, plus apercentage of future profits over twelve years, in returnfor a release from liability.
11. In September 1 9 9 0 , Hercules, Inc. filed a motion in Federalcourt to stop EPA from selecting a remedy for the off-siteareas. Hercules' position is that the entire Vertacfacility and off-site areas are under the jurisdiction ofthe court, according to the 1982 consent decree. The U . S .government disagrees with this position, and the motion isstill pending.
23
III . HIGHLIGHTS OF COMMUNITY PARTICIPATION
A Community Relations Plan for the Vertac site was completedin 1983. This plan lists contacts and interested partiesthroughout government and the local community. It alsoestablishes communication pathways to ensure timelydissemination of pertinent information. Numerous fact sheets,open houses and workshops have been conducted on the Vertacsite. A satellite community relations off ice was establishedin Jacksonville in July 1990 to provide easy access todocuments and information. The Supplemental Feasibility Study(SFS) and the Proposed Plan were released to the public in July1990. These documents were made available at five localrepositories. The Administrative Record is maintained at theCity Hall . A public comment period was held from July 9 toSeptember 7 , 1990. In addition, an open house was held on July12 and a public meeting on July 17 to present the results ofthe SFS and the proposed plan. All comments received by EPAprior to the end of the public comment period, including thoseexpressed verbally at the public meeting, are addressed in theResponsiveness Summary section of this Record of Decision.
24
<^9050
IV. SCOPE AND ROLE OF VERTAC OFF-SITE OPERABLE UNIT WITHIN 0SITE STRATEGY 0
0Since the Vertac Superfund Site is a very large and complexsite, the site is divided into'the following operable units:
1. "Vertac Remedy". As required by the 1984 ConsentDecree, the Vertac plant cooling water pond and theequalization basin were closed and sediments from theseunits were removed and placed in a sediment vault. Theburial areas were capped and a French drain andleachate collection system were installed around theburial areas. Groundwater monitoring wells were alsoinstalled and a groundwater monitoring program wasinitiated.
2. Vertac Off -S i te . This Record of Decision addresses theclean-up of the off -s i te areas that were contaminatedas a result of untreated and partially treated surfaceand underground (city sewer) discharges of waste waterfrom the plant.
3. Drummed Wastes Incineration. When Vertac abandoned theplant in 1987, approximately 28 ,500 drums of 2 ,4 -D and2 , 4 , 5 - T wastes (mostly still bottoms) were left onsite.In 1989, ADPC&E signed a contract to have these drummedwastes incinerated onsite. EPA w i l l provideincinerat ion support, and has performed an engineeringanalysis/cost evaluat ion for incinerat ion support.Incinerat ion of these wastes is scheduled to begin inFall 1990.
4 . Onsite Operable Unit =1. In July 1989, Hercules, Inc.( a Potential ly Responsible Party or PRP) signed anAdministrat ive Order on Consent ( A O C ) wi th EPA toconduct a Remedial Investigation/Feasibil i ty Study( R I / F S ) for ail above-ground items, such as b' . Idings,process equipmen-: , tanks and their contents, hreddedtrash and pallets, bagged soils (removed f r c ' dioxincontaminated residential ya rds ) . This I " ^S isscheduled for completion in late 1990.
5. Onsite Operable Unit ^2 . This operable unit ad' -.-essessurface and subsurface soils , underground storag • tanksand piping and groundwater. Hercules is cone 3tingan RI/TS for this operable unit LL. -r the terms f theabove-mentioned AOC and this RI/FS is scheduled forcompletion by March 1992.
The Vertac O f f - S i t e Operable Unit RI /FS and this Record ofDecision address the areas described below. Figure 7 shows the
25
study area. No further remedial actions are expected to be ;E>necessary for off-site areas following the implementation of ^the selected remedy. 0
0o Wastewater Collection Lines. Included are 0
approximately 10,350 linear feet of the active 0Rocky Branch creek interceptor collection systemand approximately 4,350 linear feet of theabandoned Rocky Branch Creek interceptorcollection system.
o Old (Abandoned) Sewage Treatment Plant. Includedare treatment units (clarifiers, tricklingfilters, sludge digester, sludge drying beds) andsurrounding plant surficial soils.
o West Wastewater Treatment Plant. Included are athree-acre aeration basin and two 22-acreoxidation ponds.
o Rocky Branch Creek and Bayou Meto Flood Plain.
o Rocky Branch Creek and Bayou Meto StreamSediments.
The following are not included in the scope of this study:
o Groundwater. Potential groundwater contaminationwas not included in the 1986 Off-site FS or the1990 supplemental FS. Potential groundwatercontamination is being addressed as part of theOnsite RI/FS. Groundwater contamination found tohave migrated beyond the Vertac plant site willbe investigated as part of the onsiteinvestigation.
o Non-TCDD Contaminants. Previous studies indicatedcontaminants other than TCDD exist in theinvestigation areas, such as 2 , 4 - D , 2 . 4 , 5 - T ,2 , 4 , 5 - T P , chlorinated benzenes, and chlorinatedphenols. The 1985 RI and recent siteinvestigations have concentrated on TCDD becauseit is considered the most hazardous contaminantin the area, and remediation for TCDD is presumedto remediate most other contamination problems.
o Bagged Onsite Soils. Soils removed fromresidential properties and excavated onsite soilscurrently stored in bags on the plant site are notwithin the scope of the Off-site FS. These baggedsoils will be addressed during the Onsite RI/FS.
26
COOS
V . SUMMARY OF SITE CHARACTERISTICS §
0The Vertac off-site investigation area is shown in Figure 2. QSurface runoff from the Vertac Plant site flows into RockyBranch Creek, which flows into Bayou Meto, a larger watercourse
- . that flows into the Arkansas River. Currently, Herculesoperates an onsite system that collects and treats initial siterunoff prior to discharge to Rocky Branch Creek. The treatmentsystem consists of pH reduction, filtration, carbon adsorption,and pH neutralization. This system treats collected liquidsfrom the French drain system as well as surface runoff to lessthan 1 ppb TCDD. Four sumps, with a total capacity of over6,000 gallons, are used to collect initial site runoff fortreatment.
The pesticide plant and adjacent residential, commercial, andindustrial areas are served by a sanitary and storm seweragesystem. Wastewater from these areas in the city and treatedeffluent from Vertac French drains are now conveyed directlyto the aeration basin and treatment occurs in the aerationbasin and oxidation ponds, collectively referred to as the WestWastewater Treatment Plant. Adjacent to the West plant is theabandoned or " O l d " Sewage Treatment plant that consists ofsludge drying beds, two primary clarifiers, two tricklingfilters, two secondary clarifiers, and a sludge digester.
A new EPA-funded wastewater treatment plant has beenconstructed for the City of Jacksonville (see Figure 2 ) . Thisfacility treats Jacksonville municipal wastewater and isintended to treat sewage currently conveyed to the west WWTP.However, the federal construction grant for the new plantstipulates that the new plant not receive TCDD-contaminatedwaste. Therefore, before the collection lines servingresidences south of the Venae Plant site can be connected tothe new wastewater treatment plant, the lines must be cleanedor replaced.
SOURCES OF OFF-SITE CONTAMINATION
Off-site contamination is the result of 1 ) direct dischargesof process wastewater to Rocky Branch Creek; 2 ) discharge ofpretreated process wastewater to the city sewer; and 3 )stormwater runoff from Vertac plant site.
Release Of TCDD-COntaminants to off-site areas probably datesback to 1 9 4 8 , when pesticide production began, and became moresubstantial during the production of Agent Orange in the1 9 6 0 ' s .
The Arkansas Ordnance Plant sewer lines were constructed in1941 and were in operation when Reasor-Hill purchased the
27
plant. During the Reasor-Hill period, it is likely that ,^pesticide wastes were continuously discharged into the sewer w?
lines and into Rocky Branch Creek. Stormwater runoff andflooding probably contributed to the migration of contaminantsfrom the Vertac Plant site to off-site areas.
0000It is likely that, prior to 1 9 6 1 , operational problems in the
Old STP were caused by discharges from the pesticide plant,which did not have arrangements to treat pesticide wastes. Aprocess waste outfall line was constructed in 1961 to conveyplant wastes to the Rocky Branch Creek interceptor, the mainline of the area's sewage collection system. Pretreatment ofthe process waste consisted only of pH neutralization andstabilization. However, other sewer lines existed between theArkansas Ordnance Plant and the Rocky Branch Creek interceptor,and some plant wastes may have entered the sewer system throughthese lines before and after the construction of the processwaste outfall.
Before arrangements were made to treat pesticide plant waste,commercial fishermen and residents along Bayou Meto frequentlycomplained of odors in the Bayou, odd odors and tastes in fish,and occasional fish kills. After the Old STP began acceptingthe plant waste for treatment, the complaints continued butwere fewer. As a result of the complaints, the ArkansasPollution Control Commission conducted a special survey in theupper Bayou Meto basin in the first half of 1 9 6 7 . The studylinked the problem with high 5-day biochemical oxygen demand(BOD ) loading and ineffective phenolics removal in the sewagetreatment system.
Since 1 9 6 9 , process wastewater from the Vertac Plant site wasconveyed via the sewage collection lines to the aerationbasin/oxidation ponds complex known as the West WWTP.Currently, the West WWTP receives sanitary sewage fromresidential and commercial areas and treated effluent from theonsite leachate collection and treatment system.
Because treated leachate and sanitary sewage are the onlydischarges from the plant, and because the initial site runoffis collected from a series of sumps and treated, no additionalcontamination is believed to be migrating from the Vertacplant facility to the off-site areas.
EXTENT OF CONTAMINATION
Fia'ire 7 is a base map showing all areas sampled during theinvestigations referenced above. Data on TCDD concentrationsin the off-site areas are available from severalinvestigations. These areas are enlarged in Figures 8 through1 4 , which summarize the most recent TCDD sampling dataavailable for the Vertac off-site investigation area.
28
FIGURE 7
AREAS SAMPLEDIN RECENT
INVESTlQOr lsQOVertac OM-SKe FSJacksonville. Arkansas
[A] - 1986 HERCULES FINEGRID SAMPLING
-- 1987 HERCULESGRAB SAMPLING
- 1984 EPA Rl DATA
SOUTH OXIDATION POND
MiddleUnnamedImpoundment
S C A I I IN F t It I
FIGURE 9
MOST RECENTTCDD LEVELSMEASURED INWEST WWTPFACILITIESAND VICINITYVertac Oil-Site FSJacksonvill
WffiTOS
000103
I A] - 1988 HERCULES FINEGRID SAMPLING
[B]- 1987 HERCULESGRAB SAMPLING
TCDD LEVELSMEASURED INBAYOU METO ANDFLOOD PLAIN0 88 TO 2.40 RIVER MILESBELOW WWTP OUTFALLVertac OM-Sile FSJacksonville. Arkansas
000105
\ ^ \ ^•\ \-/7-'\ \< n J ^v\^ ^ '---^,^=:^">'-< '::::-- - ^ IIISEXCAVATED
v/ \ ^0 .'<'"' ^ ~" : : ::.::" :^ <1 pp1'
'^, / . ,—,/y ,. \ 1 IAJ- 1988 HERCULES FINE
-_^^-_,-/ ;''' \ ! ORIOSAMPUNO
| / . " ' i 3 (fi] - 1987 HERCULES|| ,;-'" / ;; GRAB SAMPLING
,;' / .; i—i/ 'I \Q\ - 1984 EPA Rl DATA
.//!" ^ I"-'"''" / \"'' ' - - - - - ?,
1 FIGURE 1 3
| MOST RECENT/ / -- .- . - , TCDD LEVELS/" MEASURED IN
BAYOU METO AND( FLOOD PLAIN
|__________________________________________________j^__________________________________| 2 40 TO 3 23 RIVER MILES
100 0 100 700 100 «00 DtLUW WCO I ^ ^ a f\ ^
s^,T».,,T— — WWTP OUTFAQ-0 0 1 U bVertac OH.Sne FS
' Jacksonville. Alkansas
100 U 100 t00 100 400
1".,',«, , 7"' V,rtac ox-Site FSJacksonville, Arkansas
UUIHOV
I B] .o,
- ' ^ ' - \ \ ^
\' '' \ „ "--"" 1;' \ l-N < ,--- --..,--'•-- (;
'V ^^ ''—^^'~"'^::^.^''""-^- "v- .'•;\" \ \ '""'-^1-''" -.-, '"':^—^, i1
\. - '''''~~-— -^ "7- / ^~\^^-'- ''~' - , \ ' '.- \, •-• / / ^ \ \ ''"~'
•'-' ' \'-»3'WV~---:.-... . • / / "- v- "~'^- '' ^y .---"\\
s ~ " - • ; - - - - , ^~!f '~^^ - - -- •s s """[-"-'•"—"•* ^^"^ ~'~^^^"~^.-~ - - - ' ' ' ^.^•"^'^^ — — — ^ \\
i /'"''. ~------ ^/ i \\
^ - - - - ^ ,-^---^ ;;--. '--—-' "^Lfivees ,.-— ~^^;-!i
- ~ ^ i ^ - — — — \ \ \'.•' > \\
/'~\ ^^--- -^^>-- - ~"-~~- \\/ \ —-- i \\/ ^ ^ u
/ Levees ^- \\
/-^^--''^ \1;
<
/ ,/ '
.y^A.-'\-. ^^ !1i N ^' H/ --/ ,1
'I
(
EXCAVATED
:./ ND
)^^^ 1-5 PPb
HBH '-• 5 ppb
l—"
v^^
LEGEND
•.•-'.•••.'•••:;;.• <1 ppb
[A] - 1988 HERCULES FINE-GRID SAMPLING
[B] - 1987 HERCULESGRAB SAMPLING
|C| - 1984 EPA Rl DATA
FIGURE 1 4
MOST RECENT
TCDD LEVELS
MEASURED IN
BAYOU METO AND
FLOOD PLAIN3 23 TO 4 09 RIVER MILES
BELOW WESTWWTP OUTFALL
000
Different investigations and the resultant data vary with T^respect to time, sampling protocols, and quality "E'assurance/quality control (QA/QC) procedures. This is c-
discussed further in the subsequent data comparison section.
Figure 8 presents the sampling results for the floodplainsimmediately south of the Vertac plant site. This datarepresents fine grid sampling conducted by EPA in 1988 andHercules in 1988-89. This land south of the Vertac Plant siteis zoned for residential use. This figure shows where soilcontaining TCDD concentrations above the 1 . 0 ppb action levelhas already been excavated from currently developed residentialareas. These soils were placed in bags and temporarily storedon the Vertac Plant site. However, there is still soil withTCDD levels greater than 1 . 0 ppb in undeveloped portions ofthis residentially-zoned area. A strip of land along the westflood plain of the west leg of Rocky Branch Creek contains TCDDconcentrations between 1 . 0 and 5 . 0 ppb (Figure 8 ) . In addition,the sections immediately south of the Vertac property in thesame flood plain area contained greater than 5 . 0 ppb (maximumof 9 . 6 5 ppb) TCDD (Figure 8 ) .
The land east of the west leg of Rocky Branch Creek north ofthe confluence with the east leg also contains TCDD levels
"" between 1 . 0 and 5 . 0 ppb (Figure 8 ) . The wide section ofelevated contamination in the middle of this parcel of landencompasses the location of former creek meanders. HerculesInc. has purchased this property and fenced the area torestrict access.
Other than the areas mentioned above, sampling has shown thatthe remaining soil within the Rocky Branch Creek flood plainresidential area contains TCDD concentrations lower than the1 . 0 ppb action level.
Figure 9 presents the results of sampling of the West WWTPfacilities. This sampling was performed in both 1984 and 1988.As the figure indicates, only the eastern half of the aerationbasin sediments contained TCDD levels greater than 1 . 0 ppb.Composite sample concentrations were 2 . 8 3 ppb in the southeastquadrant and 1 . 4 1 ppb in the northeast quadrant of the aerationbasin. The most recent sampling of the western half of theaeration basin, the north and south oxidation ponds, theoutfall ditch, and the outfall delta sediments in Bayou Metofound TCDD levels that were less than 1 . 0 ppb or nondet-ec-cable(Figure 9 ) .
The old STP facility was sampled as shown on Figure 10. Acomposite sample of the sludge-drying beds contained 2 . 7 9 ppbTCDD. A composite sample of the soil surrounding the sludgebeds contained 1 . 0 1 ppb TCDD. The soil surrounding the other
37
facilities of the Old STP contained less than 1.0 ppb of TCDD. ^The contents of-the treatment units have not been sampled since o1984. At that time, the sludge in the digester contained a "r^maximum of 12.46 ppb TCDD, the east primary clarifier contained -01 . 6 2 ppb TCDD, and the west primary clarifier contained 0.23 0ppb TCDD. The trickling filters and the secondary clarifiers 0were not sampled. However, because the trickling filter andsecondary clarifiers receive sewage already treated in theprimary clarifiers, it is highly likely that any contaminationin these units will be less than that in the primaryclarifiers.
Figures 10 through 14 show that the most recent samples of theBayou Meto flood plain and the Rocky Branch Creek flood plaindownstream from the Old STP contained TCDD concentrations lowerthan 1 . 0 ppb.
The sewer collection line sediments were sampled only in 1984.The 1984 data are shown in Figure 15. At that time, thesediments in the active sewer line contained a maximumconcentration in excess of 200 ppb TCDD. The abandoned RockyBranch Creek interceptor contained a maximum sedimentconcentration of 70.5 ppb TCDD.
Rocky Branch Creek and Bayou Meto sediments have been sampledin 1984, 1987, and 1988. Figures 9-12 show the most recentsediment data. Three additional samples were taken in RockyBranch Creek but are not shown on these figures. One was takenat the Vertac plant boundary in the west leg, one was takennear the plant boundary in the east leg, and the third wastaken at the confluence of the two legs. Figure 12 shows thattwo sediment samples from Bayou Meto contained TCDDconcentrations between 1 . 0 and 5 . 0 ppb. It should be notedthat the actual concentrations in these samples were 1 . 0 and1.03 ppb. All other samples were below 1 . 0 ppb.
DATA COMPARISON
Sampling Techniques and Locations
The 1985 RI report presented TCDD data for grab samplescollected from the soils, sediments, and sludges from thewastewater collection and treatment system, flood plains. RockyBranch Creek, and Bayou Meto. Most samples were collected in1984. In 1 9 8 7 , Hercules Inc. sponsored a sampling effortdesigned to be comparable to the 1985 RI data. The 1987 effortconsisted of grab samples collected from approximately the samelocations and depths as in 1984. Soils/sediments were sampledat three-inch intervals down to 30 inches.
'' Sampling techniques changed considerably in 1988. Herculessponsored another sampling effort, and IT Corporation
38
1984 TCDD LEVELS (ppb) INCW SEWAGE COLLECTION UN
J/U^ vertac ott-s"e ps
W W T r Jacksonville. Arkansas
(Hercules' contractor) sampled soils and sediments using grid sampling. In the grid sampling, aliquots of soil or sediment ^were collected from locations spaced 10 feet apart within a "^defined area (grid) not larger than 5,000 square feet. Theindividual aliquots were then composited for analysis. Soiland sediment samples were taken from 0 to 3 inches deep. Creekbanks were sampled at distances of 6 , 3 6 , and 60 inches fromthe water line. Stream sediment was collected midstream innearly dry creek beds. Sediment samples were collected at thesediment/water interface and at the interface between sedimentand the clay bottom of the aeration basin and oxidation ponds.
000
In November 1988 EPA conducted fine-grid sampling of soil alongthe west side of the west leg of Rocky Branch Creek south ofthe Vertac property. Additional grid sampling was performednear the Vertac property line in January 1 9 8 9 .
Comparability of Data
The 1984 and 1987 TCDD sampling data are directly comparable,and comparison of these two data sets may identify trends, ifany. The 1988 grid-sampling data are not directly comparableto the earlier findings; however, general comparisons can bemade in some cases. Individual grab samples may eitheroverestimate or underestimate contaminant concentrationspresent in a given area. Grid sampling gives a better estimateof representative concentrations, but does not identify "hotspots" (areas of severe contamination). Some of the grid-sampling data cannot be compared to earlier data because thoselocations were not previously investigated.
Historical Trends
The TCDD concentrations found in soil/sediment in the varioussampling efforts between 1984 and 1988 are compared in Table3 . (This table presents only the data that can be compared.Data summary tables for each of the off-site areas can be foundin the 1990 Feasibility Study report.) Once the source ofcontamination, i . e . releases from the plant site, is removedor reduced, TCDD levels in the environment are expected todecrease due to the combined actions of dispersion by wind andwater, downstream transport of contaminated soil/sediment,dilution by mixing and covering with clean material,biotransformation, and physical/chemical transformation.
TCDD levels tended to decrease between 1984 and 1987. A totalof 59 samples are directly comparable be-tween the 1984 and 1987sampling events (that i s , sample aliquots were collected at thesame location and depth and analyzed individually). These 59sa-rrples compare as follows:
40
TABLE 3
SAMPLING DATA COMPARISON TABLE FOR 2,3,7,8-TCDD (ppb)
SAMPLING AREA
SAMPLINGLOCATION
SAMPLE
DEPTH 1984 DATA 1987 DATA - -d DATA-
BACKGROUND VANBERG BLVD
OXIDATION POND NW QUAD
NE QUAD
SW QUAD
SE QUAD
ABCD
A
D
SIN
A
A
DF
SIN
A
D
SINA
A
A
C
GJ
SIN
30.7
3.6
1.80.980.51
1.98
0.34
0.92
0.2
1.30.570.44
0.15
ND-0.023
1.20.4
1.5
1.8ND-0.01
0.025
0.41
0.0061
1.30.022SP
1 . 1
0.0059
ND-0.0290.015
0.29 [4]NA (ND-0.3) [4]
0.97 [4]NA(ND-0.3)DU [4]
NA (ND-0.3) [4]NA (ND-0.3) [4]
NA (ND-0.3) [4]NA (ND-0.3) [4]
A = 0-3 inch
B = 3-6 inchC = 6-9 inchD = 9-12 inch
E= 1 2 - 1 5 inch
F= 15-18 inch
G - 18-21 inchH = 21-24 inchI = 24-27 incn
J = 27-30 inch
S = surface sample
IN = interface smpi b/w bottom sedmnt & linerX = deep bottom samples
NA = not analyzed lor 2,3.7,8-TCDD when TCDD < 1( ) = non-isomer-specitc TCDD concentrationND = non-detectable at given detection concentration
DU = duplicate associated with sample; highest value shownSP = split sample; hignest value shown
* Highest value of sampling gnd used
'* samples taken at 6.36, and 60 inches
[ ] = number of grabs (surface samples) or cores (interface samples)taken in the sampling gnd
s^
SAMPLING AREA
OXIDATION POND
OUTFALL
N BANK LEFT
AERATION BASIN
SW QUAD
SE QUAD
BAYOU METO
1 - 88 mi below
outfall
NBANK
88-2.4 mi below
outfallDRY CREEK
MIDSTREAM (Irni)
1
\MPLING DATA COMF
SAMPLINGLOCATION
DELTA
NBANK
NW QUAD
NE QUAD
MIDSTREAM
NBANK
CONFLUENCE
S DUPREE PRK
SOYBEAN FLD.
•ABLE 3
•ARISON T
SAMPLE
DEPTH
A
SA»•
A
B
C•*
SIN
A
EF
SINA
E
SIN
A
GSIN
A
A
A
DA
A
A
A
A
A
ABLE FOR 2,3
1984 DATA
0.74
2
3.51.1
2.1
NA(ND-0.3)DU [26]
37.9
6.5
16.2
2.08
2.83 DU (6)
NA(ND-0 3)DU [6]
0.27
0.47
0.53
0.74
0.22
0.06
0.9
0.37
0.1
1.7,8-TCDD (ppb)
1987 DATA
0.45
1.2SP
0.5SP0.6SP
0.68
2.9
1.5DU1.7
2.7
0.8DU/SP
7.6
1.9SP
0.024SP
0.036SP
0.29
ND-0.0065
0.8SP
0.36DU
0.068DU0.46SP
1
1.03
(^v<0
. 00
1988 DATA*
NA(ND-0.3)DU(10]
NA(ND-0.3)DU [26]
NA (ND-0.3) (6]NA (ND-0.3) (6]
1.41(6]NA (ND-0.3) (6]
NA (0.71) (6]NA (ND-0.3) [6]
N BANK CTm) NA (ND-0 3) [50]
s
SAMPLING AREA
S BANK (1 mi)
BAY MOUTH
NBANK
RR TRACKN BANK (2mi)
S BANK (2mi)
N BANK (2.4mi)
S BANK (2.4mi)
HWY 161
2.4-3.23 mi below
outfall
3.23-4 09 mi
below outfall
ROCKY BRANCH FLOODPLAIN
WEST LANE
HINESST
(end of st.)
W LEG(0-250ft
frm junct.of
W and E legs)
Ji
AMPLING DATA COMP/
SAMPLING
LOCATION
WOODLAND
MIDSTREAM
MIDSTREAM(2.25mi)
SBANK
IRRIGATION
RUNOFF DITCH
WOODED PENN.
0-20«.frm crk
20-40n (cm crk
40-60ft.frm crk
^BLE 3PRISON T
SAMPLE
DEPTH
A
BC•*
A
A
CAA
AB
B
CA
A••
••
AA
0••
*•
A
A
C
A
A
C
A
C
S
S
S
ABLE FOR 2,3,
1984 DATA
0.81
1.21.1
NA (ND-0.3) [38]0.86
1.58
1.10.54
1.52
0.78
1.7SP0.390.34
NA (ND-0.3) (50]NA (ND-0.3) [50]
0.25
0.31
NA (ND-0 3) [50]
NA (ND-0 3) [42]0.79
1 08
0.09
0.84
0.01
7.58
2.88 [150]
1 9 8 [150]
NA (0869 ' [150 ]
,7,8-TCDD (ppb)
1987 DATA
0.34
0.12SP
0.33
0.41SP
0.0980.0046SP
0.490.53
0.85SP0.75SP
0.64
0.22
0.25
0.180.18
0.0029
0.14SP
0.22DU
0.54DU/SP
ND-0.0055DU/SP
0.120.011SP
6.81.3SP
^^
^CD00
1988 DATA'
TABLE 3
SAMPLING DATA COMPARISON TABLE FOR 2,3.7,8-TCOD (ppb)
SAMPLEDEPTH 1984 DATA 1987 DATASAMPLING AREA
W.LEG(250-500ft.frm junct.ofW and Elegs)
E.LEG(0-250ft.frm junct.ofW and Elegs)
SAMPLING SAMPLLOCATION DEP^
0-20ft.frm crk S20-40n.frm crk S40-60tt.(rm crk SSO-eOft.frm crk S80-IOOft.frm cik S100-120ft. frm crk S
0-20ft.frm crk S
^^
T-l
000
1988 DATA*
2.73 [150]2.02(150]1.74(150]1.45(150]
1.34(150]NA (0.96) [150
NA (N0-0.3) (150]
E.LEG(250-500tt.frm junct.ot
W and E legs)
E.LEG(500-750tt.(nn junct.ofW and Elegs)
0-20ft.frm crk
0-20ft.frm crk
S
S NA(ND-0.3) [150I
ROCKY BRANCH IN THEVICINITY OF STP
DRY CREEKWBANK
MIDSTREAM
DRY CREEK
W BANK DELTA
BEND MIDDLEMIDSTREAM
AA
SA
A
S
CAA
AA
1.7
0.05
0.17
1.50.11
0.15
0.160.41
0.97SP
0.0049
0.098SP0.64
0.85SP
0.630.46SP
0.860.52
NA (0.569)DU [50)
NA (ND-0.3) [25]
OLD STP AREA
PERIMETER S
SLUDGE DRY BED S
A ND-0.01
1.01 [66]
2.79DU [73]
TABLE 3
SAMPLING DATA COMPARISON TABLE FOR 2,3,7,8-TCDD (ppb)
SAMPLING AREA
SAMPLINGLOCATION
CLARIRERS
SAMPLEDEPTH
A
B
B
A
A
1984 DATA 1987 DATA
0.77
6.59
0.58
1.62
0.23
1988 DATA'
CLARIFIER AREA S NA (0.307) [39]
SLUDGE DIGESTER BB
SLUDGE COLLCT.ARE A
A
E
EX
X
5.312.46
ND-0.76
ND-0.05
ND-0.21
0.42ND-0.48
1 . 1 9
i>^T
o In 1987, 47 samples (80 percent) were lower than in 01984, with 32 samples ( 5 3 percent) at least 50 0percent lower. The largest decrease was from 3 7 . 9 0ppb in 1984 to 2 . 9 ppb in 1987 in the aerationbasin.
o In 1987, 11 samples ( 1 9 percent) were higher thanin 1984, and 5 samples ( 8 . 5 percent) were more than50 percent higher. The greatest increase was from0 . 9 2 ppb in 1984 to 1.3'ppb in 1987 in the oxidationpond.
o In 1987, one sample ( 2 percent) was exactly the sameas in 1984.
It should be noted that this is not a statistical treatment ofthe data ( e . g . , lower than does not imply a statisticallysignificant difference) , but simply a mathematical comparison.TCDD levels at nearly half of the 1987 sampling stations werewithin plus or minus 50 percent of their 1984 concentration.
The elevated levels detected in aeration basin samples of 1984( 3 7 . 9 and 1 6 . 2 ppb) and 1987 ( 7 . 6 ppb) were not found in latersamples. This decrease may stem from the sampling methods used( e . g . , grab sampling of a hot spot versus dilution viacomposite sampling) or may reflect biodegradation or anotherattenuation process. In any case, the 1988 fine-grid samplingfound TCDD levels of less than 5 . 0 ppb in the aeration basinand less than 1 . 0 ppb in the oxidation ponds.
46
VI. SUMMARY OF SITE RISKS
1986 Endanqerment Assessment
An endangerment assessment (EA) was conducted to support theJune 1986 FS. The objective of the EA was to evaluate thepotential health and environmental effects if no remedialaction is taken at the Vertac site. It defined the current orpotential future exposures and risks attributable tocontaminants at the site, primarily TCDD.
The EA is based upon the 1 9 8 4 data and included a discussionof this RI data and how they are used, including soil,sediment, and fish sampling data. In some cases, chlorophenoxyherbicides, chlorinated benzenes, and chlorinated phenols wereanalyzed in addition to TCDD.
A discussion of the potential for migration of TCDD from thesewer system, Rocky Branch Creek, and Bayou Meto was included.The EA concluded that TCDD has the potential to migrate out ofthe sewage treatment plant, adsorb onto soils and sediments,and be transported in the creek beds and flood plains.
Potential exposure pathways to contaminated media wereidentified and included direct dermal contact or ingestion ofsediments or soils originating from the sever system. RockyBranch Creek, Bayou Heto, or the flood plains; inhalation ofvolatilized organics, if any, from contaminants in the sewersystem, creek, or flood plain sediments or soils; ingestion offish and other aquatic organisms from Rocky Branch' Creek orBayou Meto; and ingestion of agricultural products that havebeen grown in contaminated soils.
From the estimate of intakes, and considering various exposurescenarios, risks were quantified. A range of risks werecalculated based on the range of TCDD concentrations found inthe media. A summary of the calculated risks in the 1 9 8 6 EAis presented in Table 4.
Revised Risk Assessment
-^ The 1 9 8 6 EA was updated to reestimax-e off-site risks based onthe most recent TCDD data and current EPA exposure and riskassessment guidelines. While the 1 9 8 6 EA addressed severaliredia and both TCDD and non-TCDD compounds, this Update fOCUSeSspecifically on ingestion of TCDD-contaminated soils andsediments. Since ingestion of TCDD contaminated soil andsediments presents the dominant risk, this exposure scenariowas used to calculate baseline risk. in calculating the risksdue to exposure to the various components of the study area
47
Table 4 1986 Endangerment AssessmentSummary of Site Problems and Associated Risk (sheet 1 of 2)
Contaminated Media
Sewer System Sediments
Rocky Branch Sediments
Pathway
Direct/Ingestion
Dermal
Inhalation
Indirect/Ingestion,Dermal, Inhalation
Migrating to creeks
Direct/Ingestion
Dermal
Indirect/SecondaryContact (pets, etc.)
Aquatic Uptake
Assessment
Risk ranges from 103 to 10^ using occupational settings. Contactwith sediments in the system on a daily basis is unlikely.
Was not quantified, may act to increase total risk. This is themost likely pathway for worker exposure to sediments within thesewer system.
Was not quantified, may act to increase total risk. Inhalation ofvolatiles is a possibility. Quantification of volatiles was not donein the RI.
Was not quantified. Could occur through overflow, backflow,exfiltration, etc. However, it is anticipated to he a minor risk.
Was not quantified. Anticipated to present a substantial risk toenvironment.
Risks range from 103 to 10"4 using the residential scenario andKimbrough estimates of childhood soil intake. Risk ranges from106 to 107 using the recreational scenario, 0-3" sediment depthand any age group.
Pathway was not quantified. May act to increase the total risk.
Pathways not quantified. Limited risk anticipated.
Pathway not quantified. Data not available to determine risk toaquatic life.
000118CVOK195/11951
Tab le 4 1986 Endangerment AssessmentSummary of Site Problems and Associated Risk (sheet 2 of 2)
Contaminated Media
Bayou Meto Sediments
•
Fish
Flood plains
Pathway
Direct/Ingestion
Dermal
Indirect/SecondaryContact (pets, etc.)
Direct/Ingestion
Dermal
Direct/Ingestion
Dermal
Inhalation
Indircct/L cachingto Groundwater
Assessment
Risk ranges from 105 to 10 7 using the recreational scenario, 0-3"sediment depth and any age group. Risk is about the same for allsediment depths.
Pathway was not quantified. May act to increase the total risk.
Pathways not quantified. Limited risk anticipated.
Risk ranges from 103 to 10^ using the adult consumption setting.Risk is lower using TCDD concentrations in fish below 2 5 milesdownstream of the confluence with Rocky Branch Creek
Pathway not quantified. Limited risk anticipated.
Risk ranges from 103 to 105 using the residential scenario andKimbrough estimates of childhood soil intake. Risk ranges fromId 6 to 108 using the recreational scenario, 0-3" sediment depthand any age group. Risk is slightly higher for the 6-9" .soil deplhdue to one maximum concentration (105).
Pathway was not quantified. May act to increase the total risk.
Pathway was not quantified, anticipated to be minor increase tototal risk. Dust entrainment of soils in the flood plain notanticipated to he high due to dense vegetative cover.
Not quantified. Considered not a major risk due to mobility ofTCDD. No data available to assess pathway.
000130( V( )K19S/ | |<>< i l
( e . g . floodplains, West STP, e t c . ) , exposure to theconcentrations-found in each component was assumed. For each ycomponent, either a residential or occupational exposure <y?scenario was assumed, based upon the zoned use for the area. ^A zoning map is shown on Figure 3 . Q
0The exposure parameters used to estimate cancer risks in both Qthe 1986 and revised EA's are: fraction of the year thatexposure occurs; fraction of the chemical that is absorbed inthe gut; and lifetime average soil ingestion rate ( L A S I ) . Theexposure fractions used in 1986 and the revised EA are thesame since no new information is available that would changethem. The exposure fraction for the occupational setting is0 . 3 9 and is based upon time spent at work. The exposurefraction for the residential setting was based upon weatherconditions (from meteorological data) that typically prohibitoutdoor activities and was set at 0 . 5 8 . No new information isavailable to change the absorption factor. Therefore, the samewas used in both the 1986 and revised EA for both theoccupational and residential settings and was 0 . 3 . No newinformation on the LASI for the occupational setting isavailable and the same was used in 1986 and the revised EA.It was .0008 g/Kg/day. The LASI for the residential settingin 1986 was 0.028 g/Kg/day. However, new information isavailable which suggests that children ingest less soil thanwas used to calculate the LASI in 1 9 8 6 . Therefore, the revisedEA used a LASI for the residential setting which was re-calculated, according to EPA's 1989 risk assessment guidance,at 0.0022 g/Kg/day.
The cancer potency factor used in the 1986 EA was 156,000(mg/Kg/day) ' . This continues to be the cancer potency factorused in EPA risk assessments for 2 , 3 , 7 , 8 - T C D D ( E P A , 1 9 8 9 ) .
The following subsections present revised exposure and riskestimates for each of the off-site areas.
Sewage Collection Lines
The sewer collection lines have not been sampled since the 1984RI sampling, where the maximum concentration was found to be200 ppb TCDD. The occupational exposure setting used in 1984has not changed and, therefore, the risk estimates for thecollection lines remain at 10 J to 1 0 " ' .
Old STP
As part of the 1988 fine-grid sampling conducted by Hercules,73 surface ( 0 to 3-inch) samples were composited and analyzedfrom the sludge drying beds. The TCDD concentration in thiscomposite sample was 2 . 7 9 ppb. Using the same occupational
50
exposure parameters used in the 1986 EA, the risks associated C^with ingestion of sludge from the drying beds would be Gs?4 x l0'5^ based on the 1988 data.
000
The only other areas of the Old STP where post-RI data areavailable are the perimeter of the sludge drying beds and thesoil surrounding the clarifiers (available from 1988 fine-grid sampling). Neither of these specific areas were sampledduring the 1985 RI. Sixty-six samples were composited from theperimeter of the sludge beds and 39 from the clarifier area.The concentrations in these composite samples were 1.01 and0.307 ppb TCDD, respectively. The risks associated with theseareas, using the occupational exposure setting, would be 1.5x 10'5 and 4.5 x 10'6, respectively.
WWTP
The 1984 RI data showed maximum and average concentrationsfrom the aeration basin of 37 .9 and 2 0 . 2 ppb TCDD,respectively. In 1988 , composite samples were taken in eachof the four quads of the aeration basin. Each compositeconsisted of six samples. The highest composite sample was2 .83 ppb TCDD. Using the occupational exposure parameters anda 2 . 8 3 ppb TCDD concentration, the risks associated withaeration basin sediments would be 4.1 x 10 5.
The north oxidation pond showed maximum and averageconcentrations of 3 . 6 and 2 . 8 ppb TCDD, respectively, in 1984.In 1988, two composite samples were taken f rom the north pond.The highest composite sample showed a TCDD concentration of0 . 9 7 ppb. The risk associated with this concentration, usingthe occupational exposure setting, would be 1.4 x 10'\
The maximum and average concentrations from the south pond in1984 were 1.3 and 1.2 ppb TCDD, respectively. In 1988, bothcomposite samples showed nondetectable concentrations. At thedetection limit of 0 . 3 ppb TCDD, the risk would be 4 . 3 x 10"'.
Rocky Branch Creek Flood Plain
In 1988 and 1989, EPA sponsored sampling of the flood plainsoils along the west leg of Rocky Branch Creek. Samples werecomposited f rom grids that were approximately 20 feet by 250feet . The highest composite sample showed a concentration of9 . 6 ppb TCDD. The r isk associated with this concentration,using the revised residential LASI , is 5 . 7 x 10 ' .
51
Rocky Branch Creek: and Bavou Meto sediments
Assuming a continued and effective State advisory discouragingingestion of fish, the TCDD levels in the sediments should notpose an unacceptable health risk (see Appendix A ) .
TARGET CLEANUP AREAS AND ACTION LEVELS
In 1 9 8 6 , the ATSDR reviewed the Vertac off-site RI report andassessed the human health significance of the contamination andthe need for off-site cleanup. Based on this evaluation, ATSDRdeveloped guidelines and criteria for remediation of TCDD-contaminated materials in the Vertac off-site area. Thefollowing levels were derived from ATSDR recommendations (theATSDR memorandum is included as Appendix B ) .
o Wastewater Collection System. Sewer lines indicatedin the RI to have TCDD concentrations equal to orgreater than 1 . 0 ppb require remediation. Thisaction level was chosen because the contaminants inthe sewer line could migrate downstream andcontaminate the wastewater treatment facilities,Bayou Meto, and nearby flood plains.
o Old Sewage Treatment Plant. TCDD-contaminatedsludges, wastes, soils, and sediments in theabandoned facilities would be remediated so that anaction level of 5 . 0 ppb TCDD is not exceeded. TheATSDR recommended an action level of 5 to 7 ppb TCDDfor soils in and around the abandoned sewagetreatment facilities if the following conditionswere imposed:
The site must not be developed foragricultural or residential use
The use and activities of the site mustnot become associated with theproduction, preparation, handling,consumption, or storage of food, otherconsumable items, or food-packagingmaterials
The site soils must be protected fromerosion that would uncover or transportTCDD that could cause unacceptable humanexposure at a future date
o West Wastewater Treatment Plant. An action levelof 5 to 7 ppb was recommended for the aerationbasin, oxidation ponds, outfall ditch, and
52
^peripheral land zoned for manufacturing. This (7Qaction level is subject to the same conditions -r-tlisted above for the Old STP. 0
0o Flood Plain—Residential and Agricultural. \n 0
action level of 1 . 0 ppb TCDD would be adopted orresidential and agricultural areas.
o Flood Plain—Nonresidential and Nonagricultural.Nonresidential and nonagricultural areas in theflood plain (such as woodlands, industrial, andcommercial areas) that are not subject to erosionand transport processes would have an action levelof 5 ppb TCDD. If the areas are subject to erosionand transport processes (lack sufficient groundcover to inhibit erosion), the action level wouldbe 1 . 0 ppb.
On several occasions in late 1988 and early 1 9 8 9 ,representatives of EPA and ATSDR discussed the mostrecent sediment data and its potential risk to humanhealth. The results of these discussions is thefollowing conclusion regarding Rocky Branch Creek andBayou Meto sediments. The basis for this conclusion isoutlined in a memo in Appendix A . Assuming a continuedand effective State advisory discouraging ingestion offish, the TCDD levels in the sediment in Rocky BranchCreek and Bayou Meto should not pose an unacceptablehealth threat.
53
VII. DESCRIPTION OF ALTERNATIVES I.*?03
The Vertac off-site area is complex in the number and variety of T^target cleanup areas; however, the number of potential remedial ®actions is constrained by the limited number of treatment/disposal processes that are implement able and proven effective for TCDD waste. Table 5 lists area-specific potential remedial actions,along with the maximum TCDD levels detected in the most recentsampling event, the TCDD action levels established for the site,and the reason for concern. Table 6 lists quantities ofcontaminated material that were considered for remediation. Thesequantities were based upon the most recent data available and uponarea specific action levels.
A range of remedial action alternatives was assembled for the siteas a whole using the area-specific potential remedial actionslisted in Table 5 . The assembled alternatives are briefly outlinedin Figure 16 and described in detail below.
ALTERNATIVE 1
The no-action alternative consists of taking no further action toprevent human exposure to contaminated materials, prevent migrationof contaminants, or protect the environment. However, thecurrently existing conditions, institutional controls, and studieswould continue. These include:
o The fences that restrict access from the developedresidential area to contaminated sections of Rocky BranchCreek.
o The access and use restrictions at the undevelopedresidential area along the east side of the west leg ofRocky Branch Creek owned by Hercules Inc. This land isfenced and has signs to restrict access.
o The access and use restrictions at the Old STP and WestWWTP. These facilities are only partially fenced.
ALTERNATIVE 2
Figure 17 is a flow diagram of Alternative 2.
^ Alternative 2--Collection Lines
The sewer collection lines under consideration include twointerceptor lines running parallel to Rocky Branch Creek (Figure1 5 ) . The westernmost Rocky Branch Creek interceptor was abandonedin 1978 when the eastern most interceptor was constructed. In thisalternative, only the active sewer lines would be cleaned; the
54
Table 5Identification of Potential Remedial Actions (sheet 1 of 2)
Area
Collection Lines
Old STP
Sludge Digester
Sludge Drying Beds
Primary Clarifiers
Trickling Fillers
Secondary danders
Maximum TCDDConcentration
(ppb)/Year
> 200/1984(existing line)
12.5/1984
2.8/1988
1.6/1984
Nut Sampled
Not Sampled
TCDDAction 1-evel
(Ppb)"
1.0
5.0
5.0
5.0
5.0
5.0
Concern
Migration,Exposure (overflows)
Exposure
Exposure (gardening)
Exposure
Exposure
Exposure
Potential Remedial Action
No Action ,Remove Sediments and IncinerateInstall Pipe Liners (Active Lines)Grout (Abandoned Lines)Remove Lines
No ActionRestrict Access and UseRemove Sludge and ConsolidateRemove Sludge and Incinerate
No ActionRestrict Access and Use and CapRemove and ConsolidateRemove and Incinerate
No ActionRestrict Access and UseRemove Sediment and IncineruleDemolish. Consoli(l;nc, and Cap
No ActionDemolish, Consolidate, and CapRestrict Access and Use-
No ActionDemolish, Consolidate, and CapRestrict Access and U.sc
Table 5Identiricution of I'olentlul Remedial Actions (sheet 2 of 2)
Area
West WWTP
Aeralion Basin
Oxidation Funds
Rocky Branch Creek and Bayou Meto Flood Hum
Developed Residential Areas
Undeveloped Rcsideniial Areas
N<mrcsidcrHial/NonagricuHufal Areas
Rocky llrunch Creek and Bayou Melo Sediments
"'Bused on ATSDR recommend actions (see Appendix B).''Based on EPA memorandum to ATSDR (see Appendix A).
Maximum TCDI)Concentration
(ppb)/Year
2.8/1988
0.97/1988
1.135/1988
9.7/1988
1.1)3/1987
2.3/1989
TCDDAction I^evel
(Ppb)"
5.0
5.0
1.0
f"o5.0
2.3h
Concern
MigralionExposure
Migration
Exposure (contact,ingcsiion)
Exposure (eontaet,ingcsiion)
Potential Remedial Action
No ActionRestrict Access and UseRood ProtectDewaicr and CapRemove Sediments and Incinerate
No ActionRestrict Access and UseRood ProtectDewaicr and Cap
No Action
Restrict Access and UseRemove Soil and Incinerate
Remove Soil and Consolidate
No ActionAdvisory Against Fish IngeslionConlinue Fish and Wood DuckMonitoring
( V()KI'<'i/l IK'il
Table 61990 FS Estimated Volumes of Material Considered For Kemedlulion (sheet 1 of 2)
Area
Sewage Collection Lines
Sediment in active lines
Soil surrounding active lines
Abandoned Rocky Branchinterceptor and surrounding soil
old sir
Sludge in sludge digester
Soil in sludge drying beds andsurrounding soil
Sediment in primary clarificrs
Water in primary clarificrs
West WWI !• '
Sediment in aeration basin
Water in aeration basin
Sediment in oxidation ponds
Water in oxidation ponds
Volume
10 cy
7,7(X) cy
3,2(X) cy
890 cy
1,500 cy
90 cy
126,000 gallons
8,000 cy
6.8 million gallons
208,000 cy
30 million gallons
Basis
Volume estimate from sewer lamping studyresults for the 10,350-fi active sewer lines
Assumed 4-ft-by-4-fl contaminated crosssection; 25% bulking factor
4,350-fl length; assumed 4-fl hy-4-flcontaminated cross section; 25% bulking factor
Previous volume estimate; 40-fl diameter;assumed 19-ft sludge depth
267-fi-by-120-ft sampling area E-l; assumed 1-ft contaminated depth; 25% bulking factor
Two 40-ft diameter basins; assumed 1-flsediment depth
Assumed 7-fl water depth
Previous volume estimate; 3-acre basin;assumed 1.65-ft average sediment depth
Previous volume estimate; assumed 17-ftaverage water depth
Previous volume estimate; two 22-acre ponds;assumed 3-fl average sediment depth
Previous volume cslimaic; assumed 2-fl averagewater depth
Information Source
1985 Rl. Vol. 1
1986 FS, Vol. 1 (p. 67)
Hercules Inc., 1988 (p. 67)
1986 FS. Vol. 1 (p. 67)
1986 FS, Vol. 1 (p. 6-7)
1986 FS. Vol. I (p. 67)
1986 FS, Vol. 1 (p. 6-7)
000128
Table 61990 FS Estimated Volumes of Material Considered For Remcdiallon (sheet 2 of 2)
Area
Rocky Branch Flood Plain
Soil in undeveloped residential areaowned by Hercules Inc. (1.0 ppb<TCDD < 5.0 ppb)
Soil in undeveloped residential areawcsi of W. Rock)' Branch andimmedialcly south of Vqriac property(TCDD >5.() pph)
Soil in undeveloped residential areawest of W. Rocky Branch (1.0 ppb<TCDU < 5.0 ppb)
Volume
2,ll)0cy
400 cy
1,600 cy
Basis
Approximately 45,000 sf; assumed 1-ftcontaminated depth; 25% bulking factor
Approximately 8,600 sf; assumed 1-flcontaminated depth; 25% bulking factor
Approximately 35,000 sf; assumed 1-ftcontaminated depth; 25% bulking factor
Information Source
1988 Fine-Grid SamplingReport
i
1988 EPA Region 6sampling results
1988 EPA Region 6sampling results
000129(VOKDVm Sl
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FIGURE 17
ALTERNATIVE 2FLOW DIAGRAMVCfllM. ()lt 'ric I'tJQt h»oriv41«. A>lri"Mi'-
000131
<?labandoned interceptor would be left in place. The collection lines coto be cleaned include the trunk line running diagonally through T-Ithe residential area from the Vertac Plant site and the active 0Rocky Branch Creek interceptor. 0
0Damaged manholes along the active sewer lines would be r ---'airedor, if necessary, replaced. The 1985 RI evaluation of - inholestructural integrity found that most of the defects occurre on theVertac Plant site and along the abandoned Rocky Brancn Creekinterceptor, neither of which are part of the active sewagecollection system. The 1985 RI findings indicate that defects inmanholes along the active lines are minor and could be repairedusing an epoxy grout lining. Other possible rehabilitationmeasures include preformed polyethylene liners, formed-in-placeresin liners, or manhole replacement. It is assumed that groutingwould be sufficient to rehabilitate most of the manholes but a moreextensive restoration method would be employed if necessary.
The volume of sediment in the active collection lines is estimatedto be 10 cubic yards ( c y ) . This volume is based on the results ofthe 1985 RI sewer lamping study. It is assumed that upstreamlaterals and servic" lines tying into the Rocky Branch interceptordo not contain ntamina1 3d sediments and do not requireremediation.
In this alternative, 10,350 feet of collection lines would becleaned of contaminated sediments and debris by hydraulic flushingcombined with vacuum pumping. The pipe-cleaning procedure isillustrated in Figure 1 8 . An obstruction is placed in the pipeimmediately downstream from a manhole. A hose, fitted with anozzle that directs flow backwards, is fed through the manhole intothe upstream pipe. The hydraulic force of the water jet is allowedto carry the nozzle upstream to the adjacent manhole. The flushinghose is then slowly retrieved to hydraulically flush the entirelength of pipe with a pressurized stream of water. The water andsediment are simultaneously pumped through a hose at the downstreammanhole into a tank truck. The obstruction is then removed and theprocedure repeated in downstream segments. Additional vacuumingwould be employed as needed to remove sediments from m?-holes.
The RI reported that the primary obstructions in the •-'r lineswere grease, roots, dirt, and gravel. Bricks and co: te frommanholes have also fallen into sewer lines. The 1- to becleaned would be inspected with video cameras L locateobstructions. Some sections ( 5 percent of the total ac'. .'e pipelenath is assumed) may require supplemental mechanical clfc .ing -toremove major obstructions.
It is likely that damaged sections of pipeline would have to berepaired to allow hydraulic cleaning. Based on the lamping studyconducted during the R I . it is assumed that three percent of thesewer lines, excluding the abandoned Rocky Branch Creek inter-
61
KL I URN WAFERAND SEDIMENTPUMPED TOTANK TRUCK
RQURE 18
HYDRAULIC CLEANINGPROCEDURE FOR SEWER LINEVerloc Off-Site FSJocksonvJIle, Arkonsos
000133
ceptor, would require repair. Atsurrounding damaged pipe and (250 cy)repair and incinerated because ofcontamination.
^CO
least one foot of soil 'would be excavated during Qthe likelihood of TCDD Q
The poor structural characteristics of the 4,350-foot abandonedRocky Branch Creek interceptor, described in the 1985 RI, indicatethat it cannot be hydraulically cleaned. It is plugged withconcrete at both ends and there are no known interconnections,including exfiltration/infiltration, between the abandoned andactive Rocky Branch Creek interceptors. As long as the abandonedinterceptor remains undisturbed in the ground, there is no directroute for human exposure. Therefore, in this alternative, theabandoned Rocky Branch Creek interceptor would be left in place.
There are two main advantages of hydraulic cleaning: essentiallyall the sediment can be flushed to manholes and removed from thesewers, and there is Little or no disruption of service. Duringthe hydraulic cleaning, sanitary flow would be pumped to adjacentmanholes.
Hydraulic flushing generates large quantities of water (estimatedat seven gallons per foot of sewer). Further contamination of theaeration basin would be prevented by collecting the flushing wateras each segment is cleaned. This water would be treated bysedimentation, filtration, and carbon adsorption (see "WastewaterTreatment" later in this section).
Sediments can be effectively removed from the water bysedimentation and dewatering (see "Solids Dewatering" later in thissection). It is assumed that the 10 cy of sediment separated fromthe bulk liquid would contain 20 percent solids. This materialwould be dewatered to 6 . 7 cy at 30 percent solids. Because thesediments in the collection lines have been found to contain TCDDconcentrations in excess of 200 ppb ( 1 9 8 4 d a t a ) , the dewateredsolids would be incinerated.
Inspection of the sewers after cleaning would involve:
o Television inspection to determine the adequacy of thecleaning and required repairs and to detect anyunauthorized connections
o Smoke testing to identify points ofexfiItration and unauthorized inflow
inf i itration/
if television inspection indicated remaining obstructions,additional cleaning (probably mechanical followed by hydraulicflushing) would be required. It is assumed that the inspectionwould indicate that no additional cleaning and repair would berequired.
63
After completion of sewer cleaning, the equipment involved (trucks,hoses, pumps) would be decontaminated. Decontamination procedures would include hydroc lean ing, with water from the procedure captured for treatment. When the decontamination procedure is completed, wthe equipment would be wipe-tested and the wipe cloths analyzed for TCDD to assure that no contamination remained on the equipment. wThe equipment would be impounded until the test results indicated w-decontamination was complete.
Alternative 2—Old STP
Sludge would be removed from the sludge digester using a vacuumpumping system. The estimated 890 cy of digested biological sludgeassumed to be 5 percent solids would be dewatered (as describedunder "Solids Dewatering" later in this section) to approximately300 cy at 15 percent solids. The dewatered sludge would beconsolidated on the Vertac Plant site and capped. This and otherconsolidated material would be covered with a multilayered capconsistent with RCRA requirements. Onsite consolidation andcapping of waste materials is described in more detail under"Alternative 2--Rocky Branch Creek and Bayou Meto Flood Plain"later in this section.
The empty sludge digester would be cleaned with a hot, pressurized,biodegradable cleaning mixture. All other equipment would bedecontaminated by hydrocleaning. The leachate from sludgedewatering and the used washing and decontamination solutions wouldbe treated by sedimentation/filtration and carbon adsorption (see"Wastewater Treatment" later in this section).
No action would be taken on the remaining treatment units. Thegrounds of the Old STP would be fenced ( 1 , 5 0 0 linear feet) andsigns posted every 100 feet to restrict access to contaminatedareas of the plant.
Alternative 2--West WWTP
The oxidation ponds and aeration basin would be fenced( 7 , 5 0 0 linear feet) and signs posted to restrict access to thosefactlities.
Alternative 2--Rocky Branch Creek and Bayou Meto Flood Plain
In developed residential areas, all soils with greater than 1 . 0 ppbof TCDD have already been excavated and are temporarily stored inplastic bags on the Vertac Plant site. The 1 , 6 2 3 bags contain2,400 cubic yards of soil including: a ) soil from the residentialareas immediately east of the west leg of Rocky Branch Creek,b ) soil from the residential area just south of the Vertac propertyline and west of the east leg of Rocky Branch creek, and c ) soilfrom a drainage area on the Vertac Plant site just north of the
64
0Vertac property line and adjacent to ( b ) (see Figure 8 ) . These " °stored soils will be addressed as part of the onsite FS. ^
0Soils from undeveloped residential areas with TCDD levels greater Qthan 5 . 0 ppb (see Figure 8 ) would be removed with backhoes to adepth of one foot. This category includes two sampling grids-Numbers 17 and 18 from EPA's 1988 sampling effort—just west of thewest leg of Rocky Branch Creek and just south of the Vertacproperty line, and would result in 400 cubic yards of soil(assuming a 25 percent bulking factor). This soil would be con-solidated on the Vertac Plant site and capped as part ofAlternative 2. The excavated areas would be backfilled with cleansoil and seeded with grass.
Residentially zoned, but undeveloped areas that contain 1-5 ppbTCDD (see Figure 8 ) would not be excavated. Rather, the zoning ofthese areas, which include privately owned land (approximately 0. 8acres) west of the west leg of Rocky Branch Creek and land ownedby Hercules (approximately one acre) east of the west leg of RockyBranch Creek would be changed to a commercial/industrial use.
The total of 700 cy of material to be consolidated in Alternative 2includes 300 cy of dewatered sludge from the digester and 400 cyof soil. Since this material consists largely of contaminatednative soil, it is assumed that it would be compactable and thatcompaction would reduce the volume of soil by 25 percent. Forconsolidation, the material would be placed on the plant site andcompacted into a mound.
A multilayer cap would then be placed over the contaminatedmaterial. The cap would be consistent with federal and state RCRArequirements for landfill closures. The overall surface arearequired for consolidation would be roughly 0 . 3 acre. The nativematerials required for construction of the cap would be 162 cy oftopsoil and sand; 475 cy of native soil; and 650 cy of clay. Basedon soil type descriptions in the Jacksonville area, it is expectedthat materials suitable for cap construction are available locally.
Alternative 2—Rocky Branch Creek and Bayou Meto Sediments
The remedy for Rocky Branch Creek and Bayou Meto sediments is basedon the recommendations contained in the 1989 memorandum from EPAto ATSDR (see Appendix A ) . These recommendations include acontinued advisory against ingestion of fish taken from RockyBranch Creek and Bayou Meto. The memorandum states that the levelsof TCDD found in the sediments should not pose an unacceptablehuman health threat if this advisory is continued and iseffective. This remedy also includes continued monitoring of fish.
65
ALTERNATIVE 3 £s»<-o
Figure 19 is a flow diagram of Alternative 3. yi(0
Alternative 3—Collection Lines 00
The collection lines would be cleaned by hydraulic flushing asdescribed in Alternative 2. Only the active lines would becleaned; the abandoned Rocky Branch Creek interceptor would be leftin place. Sediments removed from the sewer lines would bedewatered and the solids incinerated. The flushing water and thewater from the solids dewatering would be treated by the wastewatertreatment system.
Damaged manholes along the active sewer lines would be repaired asdescribed in Alternative 2.
The hydraulically cleaned collection lines would be lined with aresin-type lining system. One such system employs a liquidthermosetting resin that is hardened in place to conform to theinterior contours of the existing pipe. Installation of this typeof pipe liner is illustrated in Figure 20. A resin-impregnatedfelt "sock" is fed into the pipe and filled with water to press theresin-coated side firmly against the pipe walls. Hot water iscirculated to cure the resin. The sock is then removed, the resinpipe ends cut o f f , and the lateral connections reopened using aremote-controlled cutting device.
Rehabil i tat ing the manholes and sewer lines would greatly reducethe probability of contaminant migration to the new WWTP. Soilsurrounding the sewer lines may have been contaminated byexf i l t ra t ion over the years that waste was conveyed from the VertacPlant site. The liners would virtually eliminate infiltration ofcontaminated soil and water. Also, the resin-type liners can bemade thick enough to provide structural integrity.
The main sewer line running through the residential area south ofthe Venae Plant site consists of clay pipe installed in 1941.This pipe is approaching the end of its service l i fe , and wouldsoon require replacement if not rehabilitated. Excavation of thisline in the future could constitute a hazard due to exposure toTCDD-contaminated soil. Rehabilitation of the active sewer lineswi th resin-type liners should provide sufficient structuralintegrity to preclude the need to replace those lines in the nearfuture.
Alternative 3--01d STP
The sludge digester would be emptied and cleaned as inAlternative 2; however, in this alternative the 300 cubic yards ofdewatered biological sludge from the digester would be incineratedra ther than consolidated onsite. The digester sludge had a maximum
66
< ( t i l 1 t . l lON I IN| l,
HOt.KT HRANCM AND BAYOU MF 10 FLOOO f'l AIN
IIAYOII MrTO AND HOCKY nRANCH '.itniMI NIS
Vr'loi pio"l iilc «nt(«
t> Vuturne inrfutfe^ /*»< hultung t«ic<oi
*- (jliif poirnt'oi osh d-spoaol oplio"» (o) nn ir roti-.»f<dot>o'i(d) "lunic.po' liindf>ll (it ilcfi^lerf)
FIGURE 1&
AUEHNAWE 3FLOW DIAGRAM
0001S8
1 . ATTACH SOCK TO II ^INSTALLATION ELBOW ^V^
Installationtube andelbow
Manhole
2. HYDRAULICALLY rEEDSOCK INTO PIPE
3. THERMALLY CURE RESIN BYCIRCULATING HOT WATER
Returnwater
4. REMOVE SOCK, CUT P1PEENDSJNSPECT WITH CAMERAAND REOPEN LATERAL CONNEdTIONS
-Closec :ircuitTV cc~ero
J \INOUSDEN69071\F:G2.0WG
PPE UNS INSTALLATICVertac Off-Site f"SJacksonville, Arkansas
031
TCDD concentration of 12.4 ppb in 1984. Incineration would destroyT-<this contamination, as opposed to consolidating it as inOAlternative 2. 0
0The sludge drying beds and surrounding soils would be capped withasphalt. Sampling in 1988 found TCDD levels of 2.30 and 1.01 ppbin composite samples of the drying beds and surrounding soils,respectively (see Figure 1 0 ) . Although these concentrations areless than the ATSDR 5 . 0 ppb action level for TCDD in nonresidentialand nonagricultural areas, the sludge beds have been used forvegetable and flower gardening in the past. Paving this area witha hard asphalt cap would prevent gardening and direct human contactin the future.
The area to be paved would be prepared by demolishing the concrete% curbs surrounding the sludge-drying beds and then grading. A small
bulldozer and, if necessary, a light grader would be employed forthese tasks. A geotextile would be rolled over the preparedsubgrade. A layer of four to six inches of crushed gravel wouldbe spread over the geotextile and compacted. The compacted gravelbase would be covered with a two-inch layer of dense gradedasphalt-concrete pavement. The pavement mixture would be designedwith a high asphalt content to retard oxidation and subsequentthermal cracking. All equipment used to move or grade contaminatedsoil would be decontaminated.
No action would be taken at the other STP units. Fencing andposting signs would further deter access to or use of the Old STPgrounds.
Alternative 3--West WWTP
The highest TCDD concentrations found in the 1988 grid sampling ofthe West '/.'WTP facilities were 2 . 8 ppb in the aeration basin and0 . 9 7 ppb in the oxidation ponds. Both of these values are belowthe ATSDR/EPA site-specific action level of 5 . 0 ppb fornonresidential and nonagricultural areas, and there is no knowndirect human use of these areas. However, this action levelincludes the condition that contaminated sediments be preventedfrom migrating and allowing exposure to humans.
The primary concern for the West WWTP is that sludge and sedimentfrom the bottom of the oxidation ponds may be scoured during aflood event and transported to relatively uncontaminated areas.Information from the USGS indicates that the 100-year floodelevation in this area is 250.8 feet above mean sea level ( m s l ) .The walls of the aeration basin are higher than 253 feet above msl,placing that facility out of the 100-year flood plain. However,the oxidation ponds, with walls approximately 246 feet above msl,are in the five-year flood plain. In this alternative, theoxidation ponds would be protected against inundation during a 100-
6 9
year flood by constructing earthen berms around their perimeter( 5 , 8 0 0 f t ) .
^Sft•rt000
The berms would be constructed using a low permeability soil suchas the local silts and clays and would feature a 252.8 footelevation ( m s l ) berm, vegetative cover, except for a crushed gravelroad surface, and an exterior perimeter drainage ditch. Roughly141,800 cy of material would be required to construct berms aroundthe oxidation ponds (this number assumes an average ground surfaceelevation of 242 feet above msl and is an overestimate because itwas not reduced by the volume of material in the existing berms,which would be incorporated into the new ones).
The West WWTP facilities (oxidation ponds and aeration basin) wouldbe fenced and signs posted to restrict public access and use inAlternative 3.
Alternative 3--Rocky Branch Creek and Bayou Meto Flood Plain
As in Alternative 2 , soils containing above 5 ppb TCDD would beexcavated, and those areas would be backfilled and seeded.However, in this alternative, these soils (approximately 400 cubicyards) would be incinerated (see "Incineration" later in thissection).
As in Alternative 2 , zoning changes would be sought for undevelopedresidential areas with soil TCDD levels between 1 . 0 and 5 . 0 ppb.A zoning change to nonresidential/nonagricuitural would helpprevent long-term direct human contact with contamination in thoseareas.
Alternative 3--Rocky Branch Creek and Bayou Meto Sediments
The remedy for this area is identical to Alternative 2 .
ALTERNATIVE 4
Figure 21 is a flow diagram of Alternative 4.
Alternative 4—Collection Lines
The active sewer lines would be cleaned by hydraulic flushing andthe cleaned pipes would be lined, as described in Alternatives 2and 3 , respectively.
The abandoned Rocky Branch Creek interceptor (see Figure 15) con-tained TCDD levels as high as 70.5 ppb in 1984. In thisalternative, mechanical trenching and excavation equipment, suchas backhoes, would remove the 4,350-foot abandoned, along withcontaminated sediments within the pipe, and a minimum of two feetof potentially contaminated soil surrounding the pipe ( 4 feet x 4^ e e t ) . These materials (approximately 3,200 cubic yards,
70
o( f) fir^
WSI WWTP
ROCKY BRANCH AND BAYOU ME TO Fl 000 PI *IN
Al I AKI AS
OAyou METO AND ROCKY BRANCH StOlMENIS
FIGURE 21
ALTERNATIVE 4FLOW DIAGRAMv-loc OH-!»felSJock«on«ilt«. Atkof^os
000142
considering a 25 percent bulking factor) would be dewatered andPOincinerated (see "Solids Dewatering" and "Incineration" later in"^this section). The resulting trench would be backfilled with clearfsoil. All flushing and decontamination liquids would be treated®by the onsite wastewater treatment system. 0
0Alternative 4—Old STP
Backhoes would excavate to a depth of one foot the sludge dryingbeds and surrounding soil. Approximately 1,500 cubic yards ofexcavated material (assuming 25 percent bulking) would beincinerated. As in Alternative 3 , the sludge would be pumped fromthe sludge digester, dewatered, and incinerated. No action wouldbe taken at the other STP units. The Old STP grounds would befenced and warning signs posted to restrict access.
Alternative 4--West WWTP
The 6 . 8 million gallons of water in the three-acre aeration basinwould be drained and pumped into the oxidation ponds and theaeration basin would be allowed to dry. After dewatering anddrying, the aeration basin would be capped. The purpose of thecap would be to provide a barrier against migration of contaminatedbasin sediments. The cap would consist of compacted native soil,six to 12 inches of topsoil, and a vegetative layer. The cap wouldbe designed to grade naturally with the surrounding soil. Assumingan average depth of 10 feet in the aeration basin, the cap wouldrequire 46,000 cy of native soil and 2,400 cy of topsoil (compactedvolumes).
As described in Alternative 3 , berms would be constructed toprotect the oxidation ponds against inundation during a 100-yearflood. Water accumulating in the oxidation ponds fromprecipitation would be allowed to flow to Bayou Meto via an outfalldesigned to prevent sediment entrainment.
The West WWTP facilities would be fenced and warning signs posted.
Alternative 4--Rocky Branch Creek and Bayou Meto Flood Plain
Soil would be excavated from all residential areas (developed orundeveloped) with TCDD concentrations greater than 1.0 ppb.Removal of this soil would remove the risk associated withpotential future development in areas zoned residential with TCDDconcentrations greater than the 1.0-ppb action level forresidential areas. These lands would be backfilled with clean soiland revegetated following excavation. The excavated soil( 4 , 1 0 0 cubic yards, including a 25 percent bulking factor) wouldbe incinerated.
72
•h.
Alternative 4—Rocky Branch Creek and Bayou Meto Sediments
' Same as Alternatives 2 and 3.
ALTERNATIVE 5
Figure 22 is a flow diagram of Alternative 5 .
Alternative 5—Collection Lines
In this alternative, all 14,700 feet of active and inactive sewerlines and all manholes would be mechanically removed, as would atleast two feet of soil surrounding the pipes. The contaminatedsediments and debris (approximately 10,900 cubic yards) would bedewatered. Solids would be incinerated, and liquids would betreated by the wastewater treatment system. Removal of thecontaminated collection lines and installation of new lines wouldpreclude contamination of the new WWTP.
Wastewater collection must continue during the removal of thecontaminated sewer lines; therefore, a new sewerage system, runningfrom the residential area south of the Vertac property to the newwastewater treatment plant, must be installed before excavating theexisting lines. For this alternative as well as the others, thetiming of various actions is critical for providing continuouswastewater collection and preventing contamination of the newwastewater treatment facility. Remedial actions that must betemporally coordinated include:
o Disconnection of sewer lines from the Vertac Plant sitewastewater treatment system
o Cleaning, removal, and replacement of existing collectionlines
o Connection of cleaned, new lines to the new WWTP
o Closeout of the West WWTP
Alternative 5--01d STP
As in Alternative 4 , the sludge digester would be eir. ied andcleaned and the sludge drying beds excavated and ba filled.Material from both the digester and drying beds ^. -lid beincinerated.
Other facilities that comprise the Old STP include two -imaryclarifiers, two trickling filters, and two secondary clar-fiers.All are inactive.
The water and sediments would be removed from the primaryclarifiers. The water ( 1 2 6 , 0 0 0 gallons) would be treated by
73
I 011 f (. IION I IN! S
01 U 'ill'
WTSI WWTP
HOCKY BRANCH ANO BAYOU ME TO 1 1 000 PIAIN
Oth»< pol*ntio< OTCirrfOlion options (o) otf-»it«. (b) nit'VTIQC plon( ••(• wo«(«
b Volume «nclud«l ?5» buUlm; foctcw
c Olh«( polTiliol ofth disposol Option* (o) On«'l« co"»"l>dolion.(h) mynttipo) londfill (it d*li»t«d)
HArol) klf 10 AND HOCKT nRANCH S» flIMI N I S
JFIGURE 22ALTERNATIVESFLOW DIAGRAMVKK Oil S.lc I SJ<cfc«OrtW««. ti«n!l«l
600145
0
"srifiltration and carbon adsorption and the sediments ( 9 0 cubic yards) dewatered and incinerated. No action would be taken on the two 0trickling filters and two secondary clarifiers. $3
The Old STP grounds would be fenced and warning signs posted.
Alternative 5—West WWTP
Roughly 8,000 cubic yards of contaminated sludge estimated to beon the bottom of the aeration basin would be removed, dewatered,and incinerated. The sludge could be removed from the bottom usinga pontoon-mounted, floating pumping system. The 37 million gallonsof water would be pumped from the aeration basin and oxidationponds to the onsite wastewater treatment system (see "WastewaterTreatment" later in this section). After dewatering, the oxidationponds would be allowed to dry and then covered with a soil/vegetative cap. It is assumed that the bottom sediments would drysufficiently to allow capping/compaction. The cap would consistof native compacted soil covered with six inches of topsoil and avegetative layer, constructed so that its surface grades naturallywith the surrounding soil. Assuming an average depth of three feetin the oxidation ponds, the cap will require 178,000 cy of nativesoil and 36,000 cy of topsoil (compacted volumes). Also, theoutfall ditch from the oxidation ponds would be filled with cleannative soil, and seeded. Fences and warning signs would beconstructed around the West WWTP facilities.
Alternative 5--Rocky Branch Creek and Bayou Meto Flood Plain
Soils with TCDD concentrations greater than 1 . 0 ppb would beremoved and incinerated as described in Alternative 4 .
Alternative 5--Rocky Branch Creek and Bayou Meto Sediments
Same as Alternatives 2 , 3 , and 4 .
ALTERNATIVES 6A AND 6B
Figure 23 is a flow diagram of Alternatives 6a and 6 b .
Alternatives 6a and 6b--Collection Lines
The active sewer lines would be cleaned by hydraulic flushing asdescribed in Alternative 2. Sediments removed from the activelines would be dewatered and incinerated onsite. Water from thecollection lines would be treated through sedimentation, filtra-tion, and carbon adsorption. Pipeliners would be installed in theclean active line as described in Alternative 3 .
In Alternatives 6a and 6 b , the abandoned section of the RockyBranch Creek Interceptor will be filled with grout to reduce themigration of contaminants in the line.
75
COIl fCIION LINtS
WIST WWTP
ROCKY ORANCH AND BAYOU MCTO f I 000 PI AIN
nAYOU ME70 AND ROCKY BRANCH SFDIMFNTS
0 Other polenttdt incine'otion optionf (o) ol( «i1«. (b) -ilhVC(|QL piiinl •>(• •o»ltt
b Volume tnclud** 25X bulkinq roctor
*• Oirie* pol«n|ioi o»h diipoiat option* (a) on«i|« corrohdol'(b) muntCipal landMI (" (Misled)
FIGURE 23ALTERNA11VE 6a AND 6bFLOW DIAGRAMv—iflc Off Si(« rsJtMlroifJf, Arkonm*
000147
co•^T-l000The grout will be placed in the old interceptor directly from a
ready-mix truck. Grouting will begin at the manhole on the lowestend of the line (near the treatment plant). The grout will bepoured into the manhole, and a concrete vibrator will be used toforce the grout into the interceptor. Pouring will be discontinuedwhen the level is just above the interceptor, and no additionalgrout can be forced into the line. The operation will then moveto the next manhole up the line, and continue until the end of theabandoned line is reached.
The new interceptor was installed in close proximity to the oldinterceptor. In several locations, the lines cross each other,and lateral lines pass through the old interceptor beforeconnecting to the new interceptor. Care must be exercised toensure that the new interceptor and the lateral lines are notaffected by the grouting operation. The Jacksonville SewageTreatment Authority should be consulted to safeguard the opera-tion.
Alternatives 6a and 6b--01d STP
In both Alternatives 6a and 6 b , the sludge in the digester wouldbe pumped out, dewatered, and incinerated as in Alternative 5 .Water contained in the trickling filters and clarifiers would bepumped out and treated through a filtration and carbon adsorptionprocess. Clean water would be discharged to Rocky Branch Creek andthe carbon and filter solids would be incinerated.
The old sewage treatment plant units will be demolished, and buriedonsite. The primary clarifiers, sludge digester, tricklingfilters, and curbs from the sludge drying beds, along with the pumphouse and associated structures will be torn down, usingconventional construction techniques, and the rubble reduced todebris suitable for burial. The secondary clarifiers, which arebelow grade, will be filled with demolition debris. Remainingdebris, including filter media from the trickling filters, will beconsolidated in an area over the secondary clarifiers, andcompacted for stability. The fill area will be covered with aminimum of one foot of clean soil. The sludge drying beds willalso be covered with one foot of clean soil.
The irregular nature of the demolition debris may cause settlementof the soil cover over time. Seeding of the cover soil will berequired to reduce erosion. Periodic inspection and maintenancewill be required, including addition of soil and seeding to repairthe cover.
Deed notices will be sought to warn against access and developmentof the old STP area.
77
Alternatives 6 a and 6b—West WWTP
The aeration basin would be dewatered, the water treated, and thecarbon and filter solids incinerated as in Alternative 4. Thedikes of the aeration basin would be demolished by mechanicallypushing the dike soils into the basin. The entire basin would thenbe covered by one foot of clean soil.
Notices would be placed in the deeds to restrict access and use ofthe West WWTP.
Alternative 6 a—Rocky Branch Creek and Bayou Meto Flood Plain
This alternative would be identical to Alternative 5 : All soilswith greater than 1 ppb TCDD would be excavated and incinerated.
Alternative 6b--Rocky Branch creek and Bayou Meto Flood Plain
In Alternative 6 b , all floodplain soils with greater than 1 ppbTCDD would be excavated. However, in this alternative, theexcavated soils would be consolidated onsite and capped.Approximately 4,100 cy of soil would require consolidation. Sincethe material consists largely of contaminated native soil, it isassumed that it would be compactable and that compaction wouldreduce the volume of soil by 25 percent. For consolidation, thematerial would be placed on the plant site and compacted into amound.
A multilayer cap would then be placed over the contaminatedmaterials. The cap would be consistent with federal and state RCRArequirements for landfill closure. The overall surface arearequired for consolidation would be roughly one acre. The nativematerials required for construction of the cap would be 800 cy oftopsoil and sand; 2,400 cy of native soil; and 3,250 cy of clay.Based on soil descriptions in the Jacksonville area, it is expectedthat materials suitable for cap construction are available locally.
Alternatives 6a and 6b--Rocky Branch Creek and Bayou Meto Sediment
Alternatives 6a and 6b would be identical to the previousalternatives: no action with a continued advisory against fishingestion and further monitoring of fish.
COMMON REMEDIAL ACTIVITIES
Incineration, solids dewatering, and wastewater treatment are reme-dial activities that are common to more than one remedial actionalternative. To reduce repetition, these activities are discussedunder separate headings below.
78
Incineration0tfi
This section discusses onsite incineration and related issues for Alternatives 2 through 6 . Each of these alternatives includesonsite incineration with an assumed "mobile" or "transportable"rotary kiln incinerator. The use of the rotary kiln process wasselected for detailed development and evaluation because of itsversatility in treating a range of wastes, its successful use atseveral hazardous waste sites, and its success in destroying TCDDwastes.
00
There is a range of trailer-mounted rotary kiln incinerationequipment available from several incineration vendors. Three basicsystem sizes currently available on the market include:
o Small mobile system. Approximately 5,000,000 to10,000,000 Btu per hour; one or two standardsemitrailers; maximum processing rate of 0 . 5 to one tonper hour of low Btu content, low moisture contentcontaminated soils.
o Large mobile system. Approximately 30,000,000 Btu perhour; three to 10 standard semitrailers; maximumprocessing rate of four to five tons per hour of low Btucontent, low moisture content contaminated soils.
o Transportable system. Approximately 60,000,000 Btu perhour; approximately 50 to 70 standard semitrailers(complete modularized ancillary support facilities, highdegree of system redundancy); maximum processing rate of15 to 25 tons per hour of low Btu content, low moisturecontent contaminated soils.
The trailer-mounted incineration technology has been developingrapidly in recent years. Several vendors are currently developingmore efficient systems that minimize combustion air and allowhigher waste throughput. Improvements in waste feed systems,process operation for wastewater minimization, and air emissioncontrol systems are also under development.
The actual size and type of incinerator would be determined bycompetitive bidding and would depend on waste volumes, wastecharacteristics, site location constraints, utility supportrequirements, and final performance specifications forincineration.
Potential alternative-specific incineration scenarios for theVertac off-site wastes are shown in Table 7 .
79
AO•00
Alternative
2
3
4
5
6'
"Based on 70 percent operating factor (17 hours per day).
Table 7Alternative-Specific Rotary Kiln Incineration Scenarios
Assumed WasteVolume forIncineration
Tons
260
3,400
11.900
22,000
4,650
Probably RotaryKiln System
Small mobilwsystem
Small to largemobile system
Large mobile ortransportablesystem
Large mobile ortransportablesystem
Small to largemobile system
ApproximateFootprint
Size (acres)
0.25 to 0.5 '
0.5 to 1.0
1.0 to 2.0
1.0 to 10
.75 to 1.25
ApproximateIncineration
Rate(tons/hour)
0.3 to 1
1 to3
3 to 15
3 to 15
2 to 4
IncineratorOperatinx
Tuae(months)'
0.5 to 1.5
2lo7
2 to 8
3»o 14
2 to 7
ca«5
Basic Incineration System Description T"?0
A generic rotary kiln process flow diagram is shown in Figure 24. w>
Onsite rotary kiln incineration systems for Alternatives 2 through s"6 would include:
o Feed storage. Feed storage would include a minimum one-week inventory of solid wastes to allow for continuousoperations. An enclosed feed building would likely beneeded for control of fugitive paniculate emissions.Conveyor systems or other feed systems would be enclosed.
o Feed preparation. The waste feed may require some wastesize classification and/or size reduction processingprior to incineration. Any large rocks or heavy objectsgreater than four to six inches in diameter would requirewaste feed preparation. Depending on the quantity andnature of the objects they may be processed throughshredders or crushers and fed to the incinerator orseparated out, decontaminated, and sent to a RCRA or, ifpossible, a sanitary landfill.
o Primary and secondary combustion chambers. Organicwastes are destroyed by combustion in the primary andsecondary combustion chambers. The efficiency ofcombustion is dependent on temperature, residence time,and contacting of fuel, combustion air, and wastematerials. In accordance with the January 1989 Title 40Code of Federal Regulations (CFR) Part 264 Subpart 0,incinerators at Superfund sites must provide99.9999 percent destruction and removal efficiency (sixnines DRE) for F-listed hazardous wastes. Typicaloperating temperatures to achieve such DRE's are 1,800°Ffor primary combustion chambers and 2,200°F for secondarycombustion chambers.
o Air pollution control system. Air emissions fromincineration depend on several factors, including:
Waste composition- Feed rate and method
Combustion designCombustion air rate
- Air emission control systems
The first four factors determine the type and rateof air pollutants generated, and the f i f thdetermines the percentage of these pollutantsdischarged into the atmosphere. Typical airemissions control systems include a combination ofquench towers, scrubbers, demisters, electrostatic
81
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W
1 l.A', ' , 1 1 / 1 AM
l'R( PARf/ FCEO
sionAr.r
i......
1 ^^
n
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r ""!) ^[ )IUEI Oil. CAUSTICSIOHAGF sronAr.i
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ro
'
1 1 4 1WA
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IDIION CONIROl SYS11
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1 IJ llfl A (Ml N 1 1
L<-1
FIGURE 24
ONSnE INCINERATIONPROCESS SCHEMATICwlQr Oil Silnl'..)«llksii*(w(l«. Atfcn"s«l',
Sll1 It
1
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r~^—"*•'————fci f l
INI)U(TI)DIIAI 1 1 AN
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1 XIIAU',1
000153
precipitators, and fabric filters. For this study,the assumed air emission control systems includequench towers, wet scrubbers, and demisters.
Table 8 lists general air contaminants and pertinent {Qair regulations and standards.
o Wastewater processing and treatment system.Typically, onsite rotary kiln incineration systemsgenerate scrubber blowdown brine that must betreated before discharge. Scrubber water istypically recycled within the system to minimizeblowdown. In this study, it is assumed thatblowdown brine would be treated with a pHadjustment/precipitation system with filtration andsolids dewatering. Dewatered solids would bemanaged as RCRA-listed wastes and probably wouldrequire disposal at a RCRA landfill. The TCDDconcentration in the extract from the dewateredsolids must be less than 1 ppb to meet land disposalrestrictions ( L D R ) , as determined by the toxicitycharacteristic leaching procedure. Treatedwastewater would be managed as RCRA-listed wastesand probably would be discharged to surface waterunder National Pollutant Discharge EliminationSystem (NPDES) discharge criteria. Alternately, itmay be possible to evaporate/concentrate theblowdown brine to form solid wastes that wouldlikely require disposal at a RCRA landfill (subjectto L D R ) .
o Ash storage. A one-week enclosed ash storagestockpile facility is assumed in this study. Theash would presumably be tested in batches forresidual TCDD and other toxics and would betransported and disposed at a RCRA landfill.
o Ancillary support facilities. Ancillary supportfacilities would presumably include fuel storage,onsite analytical facilities, and site personnel,decontamination, and administration trailers.
Other Incineration Options
There are currently no incineration facilities off the site withpermits to burn dioxin wastes.
At least one facility off the site currently has an approved RCRAPart B permit, is permitted to burn PCB wastes, and has applied fora permit to burn dioxin wastes. Even with the approval to burndioxin wastes, incineration off the site would likely not be cost-
83
A
Air Contaminant
Paniculate Matter (PM)
SuUur Dioxide (SO;)
Carbon Monoxide (CO)
Nitrogen Dioride (NO;)
Lead(Pb)
Ozone
Hydrochloric Add (HC1)
*PM-10 = Paniculate matter less than lO-.nucrons (respirable paniculaies).^uperfund incinerators must meet RCRA requirements as outlined in Title 40 Code of Federalregulations Pan 264. Subpan 0.^AAQS = Primary Ambient Air Quality-Standards (criteria pollutants).''Not to be exceeded more than once per.ycar.
TalJr Contaminants, Re
Pertinent AirRegulation
PM-10*
40CFR2643401'
PAAQy
40 CFR 264.340
PAAQS'
PAAQS0
PAAQS'
PAAQSC
40 CFR 264340
Me 8lulattons, and Standards
Emission Standard
50 <uig/m3 annual arithmetic mean (AAM)150 Mg/m3 (24-hour max)'1
0.08 grain&Alscf
80 Hg/m3 or 0.02 ppm (AAM)365 Mg/m3 or 0.114 ppm (24-hour max)*1
10,000 fJig/m3 or 9 ppm (8-hour max)'1
40,000 ftf/m3 or 35 ppm (1-hour max)'1
100 ppm 1-hour rolling avenge)500 ppm (10-minute rolling avenge)
10,000 ftg/va3 or 9 ppm (8-hour max)4
100 /Ag/m3 (max. calendar quarter arithmeticmean)
U ftg/m2 (max. calendar quarter arithmeticmean)
235 g/m3
Less than 4 Ib/hr or 99 percent control efficiency
%f9tn>T"<000
CVORI95/115.51
weffective, even for the relatively small volume in Alternative 2. Incineration off the site probably would require: T^
0o Drum purchase ^
o Handling and drumming of TCDD wastes
o Transport of drummed wastes several hundred miles
o Incineration at premium prices (costs would likely be•». significantly greater than the approximate $2,000 per ton
rate to incinerate drummed PCB wastes)
Solids Dewatering
A mobile plate-and-frame filter press would be employed fordewatering sludge and sediment under Alternatives 2 through 5.Approximately 900 cy of material would be dewatered inAlternatives 2 through 4 , and 6 , whereas approximately 9,000 cy ofmaterial would be dewatered under Alternative 5. Table 9 lists thematerials to be dewatered, their volumes, and assumed solidscontents.
The mobile plate-and-frame filter presses available typically havecapacities of 2.0 to 2 . 5 cy per cycle. Cycle times vary dependingon the material being treated, but 1 . 5 hour is a representativeduration. One of those dewatering units would be adequate forimplementing Alternatives 2 , 3 , 4 , or 6 , while multiple units wouldbe employed if Alternative 5 were implemented.
Wastewater Treatment
Use of a mobile water treatment system is assumed for treatingmiscellaneous wastewater in Alternatives 2 through 6 . Table 10lists wastewater information for these alternatives.
Figure 25 shows a wastewater treatment schematic for the mobiletreatment processes conceptualized in these alternatives. The useof carbon adsorption treatment is consistent with s currentonsite treatment of leachate collected in the French c n system.
All discharges would comply with the NPDES require ents andtreatment standards. All solid residuals (filter spoc ^ , spentcarbon, e t c . ) resulting from treatment would be incinerated.
ARARS FOR THE VERTAC OFF-SITE AREA
CHEMICAL-SPECIFIC ARARs FOR THE VERTAC OFF-SITE AREA
The scope of this study includes only 2,3,7,8-TCDD as thecontaminant of concern. Currently, there are no chemical-specificARAR'S for 2,3,7,8-TCDD. There are, however, a number of health
85
s>10^000
Table 9Solids Dewatering Data
Alternative
2-4, and 6
5
Material
Collection line sedi-ment
Digester sludge
Digester sludge
Primary clarifier sedi-ment
Aeration basin sedi-ment
Estimated InitialVolume (cy) Assumed
Solids Content
10 (20%)
890 (5%)
890 (5%)
90 (5%)
8,000 (5%)
Estimated FinalVolume (cy) Assumed
Solids Content
6.7 (30%)
300 (15%)
300 (15%)
30 (15%)
2,700 (15%)
Table 10Volume and Disposition of Wastewater
From Alternatives 2 Through 6
Alternative
2,3,4,6
5
Note: Scrubber blowdown discussed under general discussion of incineration.NPDES permit not required but must meet substantive requirements.
Description
Filtrate from dewateringsewer sediments afterhydraulic flushing
Filtrate from dewateringsludge digester sludge
Decontamination andmiscellaneous liquids
Pump water fromaeration basin
Wastewater from primaryclarifiers
Wastewater fromoxidation ponds andaeration basin
Decontamination liquidsand miscellaneouscollected wastewater
EstimatedVolume (gallons)
72,000
130,000
50,000
6,800,000
126,000
37,000,000
50,000
Disposition
Treat in mobile system;NPDES discharge
Treat in mobile system;NPDES discharge
Treat in mobile system;NPDES discharge
Discharge to oxidationponds
Discharge to oxidationponds
Treat in mobile system;NPDES discharge
Discharge to oxidationponds
POIYMER
MQBIL WATER TREATMENT UNIT
^
FLOCCULATOR
DEWATERED SOLIDSTO INCINERATION
r~ t^
I TO NPDESDISCHARGE
JADDITIONALTREATMENT(IF REQUIRED)
RECYCLE THROUGH^ WATER TREA1MEN r
NOTE: MEDIA FILTER BACKWASHSYSTEM NOT SHOWN
J. \ll«>W\peN69071\FICU«E- ? OWC
FIQURE 25WASTEWATER •mEATMBfTPROCESS SCHEMATICVertoc Off-Site ftA fl '4 ! <^Jock««nvill«. ArlUlUAl 1. 0 V
0I' <0
advisories and suggested cleanup criteria that could be TBC's for ^the Vertac off-site remedial action. ^
0The most important TBC is in the April 24, 1986, memo from the 'oAgency for Toxic Substances and Disease Registry (ATSDR) to EPARegion 6 (see Appendix B ) . This memo recommends cleanup levelsspecific to the Vertac off-site area. Another important TBC is theJanuary 26, 1989, memo from EPA to ATSDR stating that the highestconcentration of TCDD found in the Rocky Branch Creek and BayouMeto sediments does not pose an unacceptable health threat(Appendix A ) .
o
The EPA l-ppb action level previously employed at other TCDD-contaminated sites (EPA, 1987) is also an important TBC. Thatlevel was based on a Centers for Disease Control (CDC)recommendation developed primarily for long-term direct contactwith TCDD-contaminated soils in residential areas (Kimbrough et al.1 9 8 4 ) .
Other TBC*s that could be of use include proposed advisories onprotection of human health and aquatic life developed under theClean Water Act. The advisories for aquatic life are specific toindividual fish species, and may have to be adjusted for conditionsin Rocky Branch Creek. These criteria should be consulted todetermine design goals for the wastewater treatment system includedin Alternatives 2 through 6.
LOCATION-SPECIFIC ARAR's FOR THE VERTAC OFF-SITE AREA
Location-specific ARAR's have been evaluated for the Vertac off-site area as a whole. Table 11 includes the location-specificrequirements identified as ARAR's.
The federal regulations that form the list of potential location-specific ARAR's include the Resource Conservation and Recovery Act(RCRA). the National Archaeological and Historic Preservation Act,the National Historic Preservation Act, the Endangered Species Act,the Clean Water Act, the Wilderness Act, the Fish and WildlifeCoordination Act, the Scenic Rivers Act, the Coastal ZoneManagement Act, the Marine Protection Resources and Sanctuary Act,and the Executive Orders on the Protection of Wetlands and theProtection of Flood Plains. No State of Arkansas regula "?ns wereidentified that addressed other location-specific requir ents orthat were more strict than federal regulations.
Location-specific ARAR's that will be applicable or relev nt andappropriate to the Vertac off-site area include floo< plainrequirements and requirements under the Fish and ^.^.IdlifeCoordination Act.
Flood Plain Requirements. Under RCRA, any hazardous wastetreatment, storage, or disposal facility constructed within a
89
Table 1 1Idenlllkallon of Potential Locallon-fpecUlc ARAR*
For Vertoc Off-site Area (a—e 1 of 2)
Location
1 . Wilhin 61 meters (200 feel)of • bull iliipliccd in1 Moccnc lime
2. Wilhin 100 year flood plain
3. Within flood plain
4. Wilhin sail dome tonnalion,underground mine, or cave
5. Wilhin area where iciionmay cause irreparable harm,lou. or destruction ofsignificant artifacts
». Historic project owned orcontrolled by federal agency
7. Cnlical habitat upon whichendangered species orthreatened species depends
8. Wetland
Rearlreraeol
New Irealmcnl, (loragc, or disposalof hazardous waste prohibited
Facility mil be designed.constructed, operated, andmaintained to avoid washoul
Action to avoid advene effect*,minimize potential harm, restoreand preserve natural and beneficialvalues
Placcmcnl of noncontaincrizcd orbulk liquid hazardous wasteprohibited
Action to recover and preserve•nitacis
Action to preserve historicproperties; planning of action tominimize harm to National HistoricLandmarks
Action to conserve endangeredspecies or threatened species,including consultation with theDepanoient of the Interior
Action to minimize the destruction,loss, or degradation of wetlands
Action to prohibit discharge ofdredged or nil material into wetlandwithout permit
Prerequisites)
RCRA hazardous waste;treatment, storage, or dispoul
RCRA hazardous waste;Irealmcnl, storage, or disposal
Action that will occur in a floodplain, ie.. lowlands, and relativelyflat areas adjoining inland andcoastal waters and other floodprone areas
RCRA hazardous waste; placementof nonconlainerized or bulk liquidhazardous waste
Alteration of temin thai threatenssigniflcant scientific, prehislorical,historical, or archaeological data
Properly included in or eligible forthe National Register of HistoricPlaces
Delerminalion of endangeredspecies or threatened species
Wetland as defined by ExecutiveOrder 11990 Section 7
CICUoa
40 CFR 264.18(a)
40 CFR 264.18(b)
Executive Order 119«8.Protection of Flood Plain*.(40 CFR 6. Appendix A)
40 CFR 264.18(c)
National Archaeological andHistorical Preservalkm Act(16 USC Section 469); 36CFR Part 65
National HistoricPreservation Act Section 106(16 USC 470 etteq.); 36CFR Part 800
Endangered Specie* Act of1973 (16 USC 1531 ctseq.);50 CFR Pan 200, SdTFRPan 402
Executive Order 11990,Protection of Wetland*. (40CFR 6. Appendix A)
Clean Water Act Section 404;40 CFR Pins 230.231
ARAR
NotARAR
AppUc—ble
Applicable
NolARAR
NotARAR
NotARAR
Pending
NolARAR
NolARAR
Comment.
No Holocene faults arc known toerisi wilhin 61 meters of theVertac off-site area
These requirements would belp(i(icab(e lo the construction andoperation of new RCRA •nil*wilhin (he 100-year flood plain
These requirements would be
whhin the flood plain
No salt domes, undergroundnunea, or caves will be used forplacement of hazardous wanes
No known scientific or historicanifacts within the boundaries ofthe Venae off-site area
No historic landmark* are locatedwilhin the boundaries of (beVenae off-site area
N0 endangered or threatenedspecie* are known lo exist on thedie. Awaiting confirmation of•lie status
No remedial actions are plannedfor areas that could be classifiedr wetlands
No remedial actions are plannedfor wcas thai cuuU be classified—wetlands
000161
Location
9. Wilderness area
10 Wildlife refuge
1 1 . Area affecting stream orriver
12. Wilhin area affectingNational wild, scenic, orrccrcalional river
13. Wilhin coastal zone
14. Oceans or waters of ihcUnited Slates
Requirement
Area must be idminislercd in such amanner as will leave il unimpairedas wilderness and lo preserve itswilderness characier
Only aclions allowed under (heprovisions o( 16 USC Seclion 668dd(c) may be undertaken in areasthai arc part of the NationalWildlife Refuge System
Action lo proiecl fish or wildlife
Avoid laking or assisting in actionthat will have direct adverse effecton scenic nver
Conduct activities in mannerconsistent with approved Slalcmanagement programs
Action to dispose of dredge and fillmaterial inio ocean walen isprohibited without a permit
Table 1 1Idenllncallon of Potential Locallo
For Vcrtac Ofr-all* Area (pfe 2 ol
Premiulslte(s)
Federally owned area designated aswilderness area
Area designated a* pan ofNational Wildlife Refuge System
Diversion, channeling, or otheractivity that modifies a stream orriver and affects fish or wildlife
Activities that affect or may affectany of the rivers specified inSection 1276(a)
Activities affecting the coastil zoneincluding lands thereunder andadjacent shorelands
Oceans and waters of the UnitedStales
o-apccllk ARARs
ri)
Citation
Wilderness Act (16 USC1 1 3 1 el scq); 50 CFR 35.1 el
*£3
16 USC 668 dd el sea.; 50CFR Pan 27
Fish and WildlifeCoordination Act (16 USC661 el scq.); 40 CFR 6.302
Scenic Riven Act (16 USC1271 el seq. Section 7(a); 40CFR63S?(e)
Coastal Zone ManagementAct (16 USC Section 1451 elscq.)
Clean Water Act Section 40440 CFR 125 Subpan M:Marine Protection Resourcesand Sanctuary Act Section103
ARAR
NotARAR
NotARAR
Applicable
NotARAR
NotARAR
Not ARAR
Comment.
No( i wilderness area
Not a wildlife refuge
Any remedial actions thai mayadversely affect Kocky Branch orBayou Mcto must be discussedwith the Department of Fish andWildlife
Rocky Branch and Bayou Meto•re ool classified as wild andscenic rivers
The «ile is not within a coastalzone
No dredge disposal in oceans orwaters of Ihc United Stales isincluded in (he remedialalternatives for the Venae off-sitearea
000163
, CO100-year flood plain must be designed, constructed, operated, and/ maintained in a manner that will avoid washout of hazardous waste ""1
during a 100-year flood (40 CFR 264.18(b) ) . For any activity that °occurs in a flood plain. Executive Order 11988, Protection of Flood °Plains, requires action to avoid adverse effects, minimize °potential harm, and restore and preserve natural and beneficialvalues.
Since the Vertac off-site area is within a flood plain,Alternatives 2 through 6 must comply with the requirements listedabove. For Alternatives 2 and 6b, the RCRA requirements would beespecially important for onsite consolidation. Construction oftreatment facilities in Alternatives 2 through 6 would also besubject to the RCRA requirements.
Fish and Wildlife Coordination Act. Any action that might modifyor adversely affect a river or stream is subject to review by thestate fish and wildlife agency under the Fish and WildlifeCoordination Act. This act requires protection of fish andwildlife in riparian areas. Discharge of treated wastewatereffluent and continued discharge of water from the oxidation pondswould require coordination with ADPC&E.
ACTION-SPECIFIC ARAR'S FOR THE VERTAC OFF-SITE AREA
Appendix D identifies potential action-specific ARAR's. Action-specific ARAR's are discussed further in the analysis of thealternatives and, in particular, in the analysis of the commonelements of the alternatives.
RCRA ARAR'S
EPA has made several determinations regarding RCRA ARAR's at theVertac off-site areas. These are presented below and discussed ingreater detail in Appendix D.
•
Wastes that are part of a permitted discharge to a publicly-ownedtreatment works (POTW), are regulated under the Clean Water Act,and are exempt from regulation under RCRA as long as the wastesremain in place. Therefore, RCRA hazardous waste managementrequirements are not applicable to wastes in the collection lines,Old STP. or West WWTP. For the collection lines, EPA hasdetermined that RCRA may be relevant but not appropriate due todepth of the lines (three to 15 feet) and the absence of a directexposure route. Similarly, for the Old STP and West WWTP, RCRA isrelevant but not appropriate because of the low TCDDconcentrations, which are below ATSDR action levels (except forsludge digester). EPA has determined that material removed fromthe collection lines or sludge digester must meet RCRA hazardouswaste management requirements.
92
- »The Rocky Branch Creek and Bayou Meto flood plain soils do not represent a RCRA unit and, therefore, RCRA is not applicable.^However, if soils or sediments are excavated, they must be managed®in accordance with RCRA hazardous waste management requirements. °
0Another important RCRA determination addresses the ash generatedfrom incineration in each of the alternatives. The status of ashfrom incineration depends on the material being burned:
o Ash from incineration of dioxin wastes must meet atreatment standard (less than 1 ppb of dioxin inextract from TCLP test) before it can be disposedof in land-based RCRA-hazardous-waste disposalunits.
o The ash generated by incinerating FOZO-listedhazardous waste is classified as a hazardous waste( F 0 2 8 ) .
o The ash from incinerating wastes and soils notclassified as hazardous is not classified as ahazardous waste.
o If the hazardous and nonhazardous ash are mixed,the mixture is a listed waste.
93
AO
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES °
EPA uses nine criteria to evaluate relative performance of each"v alternative. The nine criteria are categorized into three
groups: Threshold criteria (overall protection of human health• and the environment and compliance with ARAR's), primary
balancing criteria (long-term effectiveness and permanence,reduction of toxicity, mobility, and volume through treatment,short-term effectiveness, implementability, and cost), andmodifying criteria (State and community acceptance). Thethreshold criteria must be satisfied in order for analternative to be eligible for selection. The primarybalancing criteria are used to weigh major tradeoffs amongalternatives. The modifying criteria are taken into accountafter public comment is received on the proposed plan.
Table 12 provides a comparative analysis of alternatives.
Overall Protection of Human Health and The Environment. Allof the alternatives, with the exception of the "no action"alternative, would provide a certain level of protection ofhuman health and the environment by eliminating, reducing, orcontrolling risks through treatment, capping, or deed and landuse restrictions. Alternative 5 is the most protective actionalternative since human health and environmental risksassociated with exposure and migration of contaminated materialin and around the active and abandoned sewer lines, sludge inthe digester, contaminated soil in drying beds and Rocky Branchflood plain and contaminated sediments in the primaryclarifiers, aeration basin, and oxidation ponds would beeliminated. Alternatives 4 , 6a and 6b provide the same degreeof overall protection relative to each other by eliminating orreducing risks associated with the contaminated sediments inthe sewer lines, sludges and sediments in the sewage treatmentplants and the contaminated soils in the residentially zonedareas. Alternative 3 is less protective than Alternatives 4 ,5 , 6a and 6b because contaminated soil with TCDD >5 ppb wouldremain in the Rocky Branch flood plain. Alternative 2 is theleast protective action alternative because very few areaswould be remediated in this alternative.
In addition to the protection of the environment provided bythe action alternatives noted above, all of the actionalternatives provide that the commercial fishing ban willremain in effect, that the advisory against ingestion of fishtaken from Rocky Branch Creek and Bayou Meto will continue andthat fish and wildlife will continue to be monitored. However,no TCDD-contaminated sediments will be removed from RockyBranch creek or Bayou Meto. The specified remedy for the creekand bayou sediments is the most protective remedy of thealternatives available. Any removal of contaminated sediments
94
0
UARON CHIIERfA
"" MI rxoitcnvmss
, 11 HU 1 1 ( 1 ( 11'vl N1 •>'.r'l UMArn Nf(
ALTERNATIVE I
NO Acnon
onaoolfif •<it< cuntc Tiii<i)«Jff>atc'ioi> in«1( «.l* OKO
Uor* mil irdur* plitr"l>i)t fniqioliO" olranlu<n-nanl«
by Ihp Mo A<lHin olt«inftl.wc
Nol llfifir .H.H-
ALTERNATIVE 2
COLLECTION LINES HydroultcoNy cl«onactnx tin«J ond tnclft«rot« ••dwnir
OLD SIP Rwnov •ludo* from dlqniMand can»ol)d«t« dwotwd •qtid* on«i1«F»nc* ground* and pott •ian«
».on»
ROCKY BRANCH ffOOO PLAINRfnaw •oJ •l(h 7CDD > 5 0 ppt>fiom undttvetopcd rb«Jd«n(»i( OTCQI andconulklolc It orisilc.Pftrlct <J«« of und«vtop»d fidonllolar«o« with TCOO b«l«««n 1 0 t 50 ppb
POCKY BRANCH AND BAYOU MEtOSlOlUfNTS No action Condnu* frhadviiory and rnontloring
»f4im*nl« In •cli— —•«• •w». ftludf m«ia«tl«i. nockir Bench Ao«d plain •oil •«l"tcto> s o ppb
[limmolf pal*nl>ol mtqfotion ofCo"l«fnin«rd —dun«nl in (K||— •«««r hn»•IwdOtf ft diOHtW, Hacbr Branch nood plow.0- -.ih tCDO > 5 0 ppb
l«oil pfol«cli<»c oti'on olleinalxrc
and ••cawtXwd How) plow »Sn rnoi*og»d p*'MCHA M—li AISOR '•c«mm«ndol«n» tor«NI»l«n lKr». old SIP. Wwt WHP Cow notmeet ntWt reronr>iTicn(IOt>«ni for flood ptnin«o<r trt——f 1 0 * h 0 ppb
thf cunlortimolwd nialf-ol*
• SotI •ullountfnQ f«»0l)« COtttClirf •'"•*
• Sail In ludg* iSiyng b«d*
• 'itijifTrni In pr|mui)r fiodftii o<call«nbo-n. ond (rWatian pond*
• Horhy flianch hood plain •oil -.in •(.00I——IB b*r«*n ) 0 and •> 0 ppb
rurimlirfulinq nnd coppinq fducti >*h|
dH)*ilw i>nd RO(.*'I (tiu"c1 floufiplo.n io'( -.tr. fC( t > ^ 0 fipbbul ILOO cniaxit
K(HA (ap I.I moinlamrd) •ill 'rliQbly tonlaml.unl0riiinul«d inoltiutf H> on«,l*(OAtattdalionU«« and orc««« '•(t'tellof no— i»n<i«<)•((•ciluwd ond flkihllily
ALTERNATIVE 3
COLLECTION LINES' Hydroutlcoly citoooctiv !)»•• ond inc(n«rot« ••dtm«nt«.m«tall pip* llnw
OLO SIP R«mov •tudg« Iram dIntTand incm«rat« d««a(«<«d •olid* Co««r•)u4g«-rfry«ng b«d« •i(h ofiholt CUpr«nc« ground! and poll •lgn«
IrAS* 1WTP P'olcd o»dollon pondifrom 100-yeoi Hood by berming r«nc«focllt— and po«t •lqn«
ftOCKY BRANCH FLOOD PLAIN R«mo««DrwucMJsly ••co«g(«d •oH ftimaV andond incinTOl* •otf mlh TCOO > 5 0 ppb(rorn undeveloped rfldwntlal area*fteatfict UJ« of undevctoped mtifonllot
^^"BRANWWBrYAyM^yo0 ppbSCOlMtNTS No action Continu* tl«hodvofyond momlofir^
Allfnalw 2 ptu* fh of ••aa»Jc 19Con|o(T»n«t«d •a'l •n lud f d'fuiq b«4«flwluc— (rh al •upoiuc lo •ifl •wnounduiqgctiv« ««D«r tfi—
(l'mtffot»» rnnrai>tm«nlo* '>•*•* •ft nAll—noli— ?, plui pol*nl'«l m.ofollMt •(canlafriMfiMd •o4 •ut>*u"dir acliw •«•—hn« and •orf •n 1uda« drfinq bwtaRwduc— polwnllol miyalion ol contoflnalMl•«dim«(it« w (fdotion pirndi
• Soil In o^d o«ouna at>ond4Mi»d Hochr BroochInr'Cwplw
• S«dtm«nl in pi ifniu y cWI<V 9
9 »*oc)>rH.i»"[n liaod piom •on •llh ICODl»v*l» b«lwn 1 0 and I 0 Ppb
I tnmq P*U*B r«ducw nfk avsoclalwl «ri(ftconlorninolvd •oil •u(ioun4<ng ocllw ••••f
Copp'nq icrtuc** lith axsociafd •<IAtanlom-taled •o-l in Uudq* ri'fnq bedl
Be'niinq icouiel iif a««acio<ca ">lhcontotntnord Wdimcnii .n o>i4oti0n pOfldi
Alpholt top ••ill '•l.ablr toMof. conlo'ninofd•oi m •<utlq« <»rmq b«d« «ntf *—t'>cl ••• u»Hood-control b—T.« •m r«llabl« pr——nlmlgtol(on ol <:<inlomno1«d ••dm«nl| Inoridodon pond* (fo« up la 100 —oi-Hood(>0r«)floth cap and 6e"n« -in i-fqu'ff mo^lt"Wte
pllri (••«»r«* on«f ir' ob'iilr
ALTERNATIVE 4
COU.ECT10N ltNES:Hyritoulkolly cleanocth« lln— gno Inelnwol* ••obn«ntrln«tQ« pf llnw. Awnov abon4on«dRocky Branch tnt«rc«ptor.
OLD SIP R-nov iludgw Irom d(g««t«rond •oil from •ludy dtytnfl b.d»o"dinc(nTol« •alld* r«nc« ground* andp0»l •tOHB
WEST WW1P. Covr dewater«d. drl«doTotiwi bafn •4th « ««N/i«o«iothwcop. PfAfct •iJtfallon pond* from atOb- war HtfOd br b-wtng r«nc»locmd— and poit •tgni.ROCKY BRAMCM H. OOP PLAIN ft«mowond InchiTal* •«N with TCOO > 1 0ppb from OH ftdw*ttnf ar«a«
ROCKY BRANCH AND BAYOU MC10SCOlUCNTS: No action Conlmu* fithodvlioryond monllwinq
«i Al|wn«|iw 3, •KM •——w««/ina««ti0n rdr——ocwt«d —th Aachy »<*A«h ftoatf irfam •oil•ilh 1COO > 1 0 W. conlaminol«d Md^>«nlki •wllan baain, «nd coxlominacd mol—talin and around •MndonMl Nochy BrunchInOfpIt
flimlnolf •nwannnfilol iirir oil •nAllfnollW A, •)«• pftl—lliOl (niOrgdon «lRocky BfriCh i«*d plwi •Oil •ilh fCDU >1 0 ppo and •odMWtl* «• —flion b—inRwduc— polwnltal rnlgral'an of conlammaUd•»d<nMnl In —looilwn pondi
CoJl*cl<an ltn«f •*dtp«nla. ond •o>rrnwawd •«• HCNA Dwtif «iwdq«. dff^b«d Mud—, •nd «*od plat •orf« manned pr>dCRA U—l« ATSOR r«Cwnm«n<fo1«n« lo*oNormr
DM* »•! >«duc« "»•> ••ivcialfd •><hcanl«fnm«|«d ••dmieni <n p<cnory c^ifxf
I |nln( »|p— f»due— rlli rrfoctalwd •ithC»n(«mlnal»d •ol •u'fwi dnq acllw ••••((WfCopf>u rrducf »•*>• ••ia««>l«d •tth(«nlaniinol«d ••diti«nl« ift uiolion bu«>n
Bfming («tfucM !<«•• e» c'«nfo»T'>no<«»(f•tairrteni k* ooldatlfi por'tti
So<</—q«toli'- cap •ill ••iioblrcanlomcpniafnmalwd ••4ifn«A| in ««rBtcn (Mr'nriwd c*ftlfol bwrnB •ft (•iloblr^wWmlqcilon Ol conlomlnaicd ••dxnwir ktaxdgtion pondi ('0» up to 100 *««• t>oa4no—)eolh cop •nd btfw •ll ir«u»e nioln(eno"t«
r no) •••«n|i0l bTmf • onl«m>fial««molrfl •ilh trfflT > f 0 nfrfi •"' tf '«mo«vif
i
ALTERNATIVE 5
COLLCCnON LXS ttfnow oD •«w«rlinw ond ktclnwot* •oil, •»d>m«nt. anddtebrti. Construct n— ——r Uh—OLD STP R«mo«« «lwtfM from dtg««t«r.•o* from Uudg* *«*ng^«4& and••dlm«nl from fx-lriww ctorHtor*.Inclnwat* •oWfl «n4 fr«a* ——t«w«l«r.F«nc« ground* ana P—t •kp*.
aflralian bwin •nd Meinwl* wKtf*
with ull/««ui(ath« COD. Tr«at wo«C-w«l«r r«IC«ftKM«llKind p—t •Iqftft
SnV-i .M.aos8%i«:>Rttol»ROCKY BRANCH AND BAYOU METOSCDtMCNTS No oclion. C«n|tnu» flihOdwwy Ond monilormg
Cflmtarf Ituman n«alfN rt«h» — InAllin«(iw 4. ytw fifth •I ••pc«uf« locantonimair —J ——ae<«il«d «-(>> •N
In widation pond*Moit profc<'«4 OClit Otf-natf—
Elimmalei «n>if0nm«nlol »•*•• 91 mAff«"<ati— 4 (riw« pwCftl—t migrlion ofC«nl«n*Mot«d ••diwnf M —««Lt«n p«ndtt
Moil pcKcflwtf OCti«n gttfWM
&o«*« •• Mi«inollw «
Caap»nM r««wf "••>• ••—cried withcan(om«* *d •««»*«»)• w • •lign pandt.but InhwftI tn—d •f •«•!« fmwri ttnaUB fh •••Mflfd ••Ih •M mwlwhitaknown or ••?•((•« (• tr ion4omin«t«d •fthtct» > t 0 p«alla* lowl fiduot rl«h o( «• ItwnoIfwJ
Sorf/wqMioCw cop (<1 fnanlowd) •« rflttablrcBrtto-n conl—ftWH>l«a —d«n«nl in ••Nto((«iAp^f*
rfl«cli««n«»« a* u— «"d ocCCH r*«lrictwn«>l fol *«t«nlia4 bwow— {Oiit*TrnolcJ•norxl ••Ih KOO > 1 0 ppb —« b« >fw—<J
TABLE 12COMPARATIVE ANVfloc OH.'fic tiiJi>LkM)f*<Mtte. Atkansai
ALTERNATIVE 60 ond 6b
COLlCCTtON LINES Hydr«uNcoMy cfonOClhw llrMr and Inckwar Mdim«nf.bMt«M pip* (Inf. Cfaut abandoned HnwOLD SIP: Rwnow •Iwdo* lr«m dlqextf.and Irtdnwof tf»—lw5 ludai.Covw•lud4*-dr«tng b«d» with Mil captamBltett.Wfb ond c«p OLO STP•trwcluf. r»n<i» ground* onfl po*( •tgn*
MCST WWTP; Cowr dwatwd. drWd•w«l»0n b««in wilh a wl cop r«n««foctttiW «n4 p««t •(«»«.
•OCKY BRANCH FLOOO PLAIN E«c««ol«ond tncinfof (flol or conMhdal* omit*(6b) •Ol •rilh TCOO > 1.0 PpbROCKY BRANCH AND BAYOU ME TOSEDIMENTS HO action Continue ti«hod«i*0fy ond fnoniloring
|hfronal« human h«ot(n ri»fc* a* m All«*n«ln«3. pi—— '<•»• •( «^OKJ>« (• CW|«min«l«t SfP•trtrttw* ((•duc«« fni——l—n •nd ••pokf
rl«h« OB«ochll«d ••th Mochv l)ion«.lt HaodpH»4) •M -Uh ILftt » 0 p(«
rifninalf enwn^ncBtot iifh* ai MIAltwnBltw J. plw pal«nlial m>q>ol«n »am•><ndo»>«« Hnf and Rocky (lt«ich fl«o4 plom»• with 1COO fciler lh«n 1 0 ppb
CattfciMn t(H« n-fl*w*tt». ifqrfirr iriu«f. ond11—4 pl«tf> •wr fnanaqri »•« MHHAM—f "ISM r«camn>f«tf«tian« far oil ——<i»
Own«>i(*on orwt capping •I (XO &»' IflmrniWAHB rwtfucn Ih« p»l«nliat !• —potifh«m Ih—— unill Craulw** f«dwc*« r'*k Ho***mi——tlwt (twa> i •bandaortbnMllninq pip— fcofue— rN* In •clw fmfCcpping r««uc«« *i«h •llh •—wn«nl« inwro*lon ba«b*tdmtnolH fl-i ••««««l«d •ith uH n.a1«"att•——Ctw} loTi LtniKHiinulft ••11> KtXl > * 0ppb In Mood pln<n
Soil cop «« re(iob*y rontaM contomln<ife*f••dtrntnl in ofriltlon tM(«n on4 Oil) Ml1
|H«ctHcnw« nf tfuulina r u'lwluri uinlo>«<(rll ln.-rn-.-T
ALYSIS OP ALTERNATIVES
0001o<
TABLE 12COMPARATIVE ANALYSIS OP ALTERNATIVES
0001C6
LVALUARON CRITERIA
itluuuiuN m lonciiT.hiiifiiitit on VOLIIMCIHHOUr.U iHfAIMrNI
A.i.imrl |)fiiciv»i| of ticatwd
Hritui I'W o< loudly M«b«ilr. 0>Vt»'H'"»
lyw< anil Uuanlilv ol Hfidualittf—ioinfq Atli tmimmt
'.HWI IfUM IflLC'lVlUFSS
ALTERNATIVE 1
None
Non«
Not OOplMOU*
Nol ap(ilicorri«
N«| upiri>cot>l« •
NB| appiH.oTMc
Nut u|i|iliciittr
ALTERNATIVE 2
incMfoliwi d—trf •t ———of rCOO ki
• 10 er Of —dknwil In •«tl«« »—«f lln«B
• 2SO Cr a* KM| •urrguntf'r atll«« ——«fIff
RB*ICM MIV •t WdknwM* In c«N«cllf> IT«>N*«wc«« *n«*Mly •t dftiM 1ud«« and11«^ ft»» •(•'- <5 0 ppb '
Incmfalton •* lrrcwr«lbf wo»tB«oCrlfo(m«nl cowpl«« ••Ih incwrrolian olf-duM >• i>mw*l«
Afi ('•m Inclnwtian or 7«0 Cy ftt •«J/—«im«nt ffnwn«
lmftw*>«Ht«tlw CCM— »»t«Mltol tw(Wtwnlnwl lr«M»«| k*f (•Iwta, —ro*c«»>••. •r rum— (dwrinf ——«r ciMnirtf) *•<tar bw——4 Arl yrtucltan |*fln«««a«allw» •>i« ewnlrucllm) Bth <-h» cwift* «'««ll|r f4w««« bp appf—'«1« mUMl"wM99W99
Pcfclion o«at*rl tfwmat contact •n«initat»lw •I duri f>4 —pw « fw*4*,'«>« *« i <a« tli«H—
Incinwollon wM m—t •mriton •lonflafdaP«l«Hlial lor canCmiHant mifl—n Va <••*•(wm«r(w f»»n»H. •r Maa«——t«r •*er——*itfu*inq ••c«—li«n
) la & r«a>>
ALTERNATIVE 3
fAClfolian ilwlfr CWton*ln«tlM •• (IB|*«In AtlWMliw 2, p(w — nn« •t (COO In
• 400 cy »1 flocfcv ftrAncft ffood»l«ln •a«
flxAicw MtV •I *«««t«r •IU«OM. caHMIfw lin«w4f»«Af. •n4 11—4 •« —It Ihrouqhinclirration
Sottr o« Allfnatiw 1
A«h frfn inc«wtian •( ««0 cy •f •a*/•«d<m«nt/Mudg« r«*noM«
ftMr lo comfnunHy wklu^r t11* •amc — •HhAtlwfrli— 2
Sw*f o* Alfrnaiw 2. ••c«pt Ihfli laryw
|nwfonm«n|o> ImpacC or* |h« ••m* <r •rilhAllinall— 7, •BCM>> |t*«l mw molwMI (•Inclnfol—
1 lo 4 yolft
ALTERNATIVE 4
in Allw'iriN i1 ffi •S'——M •f TCOO h
••C*r Brontfi Itawd •Mm Mi
• 3.300 ey •I m«frt«l fci and Wwnd•bw««A«4 H*cky BfW** MtC'cfl*'
• 1,300 cy •I wtf In «u««« *)«*« Mtf»
••«•«•• M fv •f C—CIMH -— •«•>. «»(••— —*A**II. *——tw •n4 »»>»*«» b*« •kHta*.•«« •—4 plwn •••!• th.* Incir——llo**
S«m« — Af(«rnatH« J
Aiftfr«m kckflkn •f f.400 cy •t •M/
llttfr *• can*mMAMf •wwitMlw (*<• «wn« —h M«rn«IK— 2 w4 1, —e*»l tftt
Swrw — Al(wn»t»W 3. —«•»( lhal ta>9W
Cn«lcnm«t|al ImpocC or* ftf fm« en frithAlt—irtI— 3, ••«•»! t'wl "W nwlfrtM (•
J r 4 fw»
ALTERNATIVE 5
lAciHfitan «—fr syfyj'yUn.gJyx(n A(twn«ft«« 4. u« — MM4 •f TCOO tt
• 7.440 cy •I m«l«r*« M •ntf •r«W*« •cU—
• t0 C)r •f —dm*nt Ml primarir Cfrrtw
• •.000 Cy •I tMMfWl hi •WIMH »—ln
Tr—C J7 mIMon •——»• •f ewil«m*>Mtrtw—rwiwrfrwn ^bfwy ctarM*—. —r«t(—t
Sftintt — A*l«rn«l»— 4. 1w MtV f«uC«4 tar•CIW IM«. priwry ct>»li>f». •n4 Mr««lwitaBin 1(wu(h IfXiwtll
Sam* •• Alfnath« 2
A«h k«m (nelnwDw* •I r.MO *f •I Ml/
(Ml —*•* ^ IM» «11Mll«»N1^ •MMlwtCtf •Mh tfw4 1«4uCtt4H )•
••|«n«««
Sw — Altwn«lt— 4. ••Cfl It—* C'««rWwinw •I mrtwW w •«<«IMJ
Cn«JrofMn—*t«l Imycf f ttw ••*n« — wtthAifn«lt«« 4. —n»l lhal mw m«lwM te••c«w««4 •n« kwtofl«d
J to 4 y.«
ALTERNATIVE 60 and 6b
• 10<rf—*T>—lh«clh«ll——• KOo'ltM •<»•>«« «elb.
• •M cir •f Nu<*9« m •rrif
• 4100 C|r of Hocftr •(•nch Hood ?!•** M«
MJV——^M h MUlOrtta ——k«^
f'lifSlSiifS'ifi tiSKi SrfiSS!i'S!"<!SSFtak M— l'r—1- lUlllWfMW
Sfm — Ml«in«>n I
m M«r«tw fta. ••H Ifm MCIHWIIMI •f
t*)KaArc s<'itt"'%s"CT.«««".
I—— — Mrnlh* 3
Six — «l<m«,M 1
Sfn< — JUInnolM 1
l r 4 )««*•
TABLE I* („«(„„.,,)
COMPARATIVE ANALYSIS OF ALTERNATIVESvcc oo-Sii* rsJKkwn»l«. ArMA——
000167
EVALUATION CRITERIA
', iMPifUfNiAOHiry
'"""""" '•••"-"•"»
A^r"' ll/0l.,» 1 •triblllty
/ 1 (IM
..,„,...,..,.•n,,.,|)l ()*U (nil
10 y»ir p'r«rnl KitiJf ((«•!
(•i^ <ll!«. tl>t*.l •>ir)
ALTERNATIVE t
rf"' "i'r1" "'•'»
N»I uiipiit otir
>"
tn
»"
ALTERNATIVE 2
O**^ con»t'utt'oo. an4 opfollon in«•liiMhIlf-tf ••Cfil hi ini.lnflian. •hrf.h!• •U«»Kl 10 UO—lB WVt IftOHOftonuo •tlwcth-n—— ^ roMf tf«l«rnit—4bir •ub«M)uwi( ••malinq •HJ «d4t*lon« •titwt<m b* •o«M^ tmpCm«n)«tf » nwc——orr
NfUtS pfrnll nal fqulrwtf lo dl«.horo« (fafil•««l«*or' •fffwnt lo •uffac* MCr frotfrUutI cawdfrf —th Jodi«an«4ir «OBI«W«|I«•u(fW>fnand H^fof——inc '•OOrtfiA* ff—tfulof «««( WW11P, •wr lm« ffantnq andr«»i»)«> wlh —r WWTFUu«l co<irdmol« —th •tal« •b qualitt «q«ncrfOW«nf lncln«rot0f Wnknion* Uu«{ •howthai lncl(i—«llon •airflf RCM* cquk*m«nl«to •O Ufl ;•« 340 - ?fl4 »1UM flrlc1)on« ftwl b« cwwtfinord IrvouqhCllr of J«Cl««Onirfll« for
• Slutfg* »»<"» b«d>• Und«—)OP*d frttenttol o'«o« of Rocl.r
B>unch flood plain
AniWottlily of mo6H« Inclnftatw on4 titifP'n'—J ««»«nd« an currant ««mond«tt otn«r r«qulr«d •ou'»m«n) antf ——we**•nouid b« ft<«ilab>«
1MOOOO
(llfl y^w) J&OOQ
(oft» »»•» )—x) 3-1.000
* OOOT100
ALTtRNATIVE 3
S"—*' lo Ali.'.x,).^ ?
"iimioi )• Ait—nativ J ••<.•»>
• U— (••t'klian* a'* noi (•gu)>*d 1«*«kJd9« dr^ng b«d«
• Mfl «ooi01nol« •ilh RCHA landflHouihoflfJ r«a«id'na tfcpofo1 a'nt.in«'olo> o>'>
• U^ A'mvCOE STi'on «Q4 pJtrnllrrqfl'fif 1" coiBtlucliun in a fload pl«ln
lot d4MCB«l ol Incinfalor o)*' «'« •lltilnSOO mil«« of (n« •ilc Uotfiar aw«i>obi« (o*on«il« 4fpo««*
(nay b« iltll'cull lo iit.lnin liiiallr
/ B(X)OOU
(tim yar) 6) 000
(o(t«> frti r««r) <s.ooo(oddiiia«ol ••«ry 5|h y<i>) 10000
a ooo ooo
ALTERNATIVE 4
Smio' lo Ail—nativ ?
Som« OB Allwftfw 3. ••<•()< ia u—c»lfk1ton«
Sonr a« AlfrfiQll'r JAlltnwii— 4 r«^uw« <n« lorq«tt nrt-m» of•ob tor borfnln||. copplnq. ona ttiicfc llii<nq•iica««(«tf «««•
/U 000.000
(fWt y«f) 1 1 0 DOO
(alCf Ifl yo*) 66.000
21.000000
ALTERNATIVE 5
Simla, lo AH«'n«f<— 2
S«m« o* Ml«rn*(t<>« *
LOfaf fnaufit of m«l«r>ai r«qurMf lo' roping"•r b« d-Kwwil la •bl«in l«rollr
Jo.000 000
(ir«i y-) 300.000<oft«> ft yM') '50.000
40.000.000
ALTERNATIVE 60 and fib
SlmJ«r lo AlCrnat.** ? •iKBdt a'out»« a*COUiCiMn lint !• 4—w>tf«Ml •n lh« IW o*«*IWW<Mn •I (h« T^«»
Sanf o« A)l—n«l>— J
Sanr «• Ai|«rn«flw J
6a - (3,400000 6b )0«OOMJO(ikii vw) 60 &r.ooo
— 77.000
(ofl- (let y*w) 6« • U.OOOftb • U.ODQ
•« <*,000.000 H. llOii'l.r -
TABLE 12Vfloc Oir Sit« i sJflLli MiwIlr. Afh(ir<v<
l'.\lf*(HI'.l\l)(NC>10fl\IAl|'» W (I'M.
000168
' ' ' / »from the creek or bayou could resuspend the sediments and -release contaminated sediments downstream, resulting in —|exposing the environment, in particular fish, to additional QTCDD exposure. Such removal of sediments would also very Qlikely result in loss or destruction of fish habitat and more ooverall destruction of the environment than leaving thesediments in place. The U. S. Fish and Wildlife Service hasrecommended that the sediments in the creek and bayou not bedisturbed for these reasons. Therefore, the remedy for thecreek and bayou sediments is more protective of the environmentthan any removal of the sediments, even though it may resultin fish and other biota being exposed to low levels of TCDD.
Compliance with Applicable or Relevant and AppropriateRequirements (ARARs). The "no action" alternative does notcomply with ARAR's since contaminated soils/sludges withconcentrations exceeding the ATSDR-recommended action levelwould be left. Alternatives 2 and 3 also would not comply withARAR'S, unless the zoning of the undeveloped residential areasouth of Vertac is changed from residential tocommercial/industrial. Alternatives 4, 5 , 6a and 6b meet orexceed the ARAR's and remedial action goals.
Long-Term Effectiveness and Permanence. Alternative 5 has thelowest residual risks of all the alternatives, since a largevolume of contaminated material would be destroyed.Alternatives 2 and 3 have the highest residual risk of theaction alternatives, since soils having a dioxin concentrationhigher than 1 ppb would remain in the Rocky Branch flood plainsouth of the plant and very little contaminated materials aredestroyed. Alternative 4 provides more long-term protectionand permanence than Alternatives 2 , 3 , 6a and 6b because morecontaminated material is destroyed. Alternatives 6a and 6b aremore protective and permanent than Alternatives 2 and 3.Alternative 6a is more protective and permanent because thecontaminated floodplain soils are incinerated rather thanconsolidated onsite.
Reduction of Toxicitv. Mobility, or Volume of Contaminantsthrough Treatment. Alternative 1 does not reduce toxicity,mobility, or volume of contaminants present in the off-siteareas. In Alternatives, 2 , 3 , 4 , 5 , 6a and 6 b , approximately260, 1 . 5 5 0 , 9 , 9 5 0 , 25,480, 5 , 2 5 0 , and 1,150 cubic yards ofcontaminated soils/sludges/sediments would be treated byincineration, respectively. However, in Alternatives 4 and 5 ,buried sewer lines (abandoned line in alternative 4 and both
'•• abandoned and active lines in Alternative 5 ) would be excavatedand incinerated. Excavation and incineration of the sewer
; lines is considered unnecessary for protection of publichealth.
98
0Short-Term Effectiveness. This criterion is not applicable to i>"Alternative 1 , because no action will be taken. Alternatives ^2 and 3 provide the greatest short-term effectiveness, assuming access to the contaminated areas is effective, and because they include the smallest amount of construction activities .that :sscould cause short-term adverse impacts on workers and thecommunity. However, since land use controls are difficult toenforce and must be negotiated with landowners, the short-term effectiveness of these is questionable. Alternatives 4and 5 offer the lowest degree of short-term effectivenessbecause they involve the largest amounts of constructionactivities and thus would result in the greatest impact toworkers and the community. Alternatives 6a and 6b provide a
- moderate amount of short-term effectiveness because threats areaddressed, yet the construction will cause a moderate amount
; of impacts to workers and the community.
Implement ability. Alternative 1 is no action and thereforeeasily implementable. The remaining alternatives areimplement able. Implementing Alternatives 2 and 3 requirechanging the zoning of undeveloped residential area south ofthe Vertac plant site from residential tocommercial/industrial. This change in zoning may be difficultto accomplish because it would require negotiating thesechanges with landowners, particularly the owners of the westernfloodplain of the west fork of Rocky Branch Creek. ForAlternatives 3 , 4 and 5 , the large amounts of material requiredfor berming and/or capping oxidation ponds may be difficult toobtain locally. Alternatives 6a and 6b would be the easiestto implement among the action alternatives because no changein zoning would be required, and no large amounts of materialwould be required for berming and/or capping of oxidationponds.
Cost. The cost of and time to implement each alternative isshown below:
Annual O&M 30-YearAfter Present YearsFirst Value Cost to
Alter- Capital First Year (5% Dis- Imple-native Cost Year (2-30 Yrs) count Rate ment
1 -0- -0- -0- -0- -0-2 3,90 0 , 0 0 0 35,000 33 000 4 000 000 43 7,600,000 61,000 45 000 8 000 000 44 20,000,000 110,000 6 6 000 21 000 000 55 38,000,000 200,000 150 000 40 000 000 56a 13,400,000 57,000 46 000 14 000 000 46b 10,400,000 72,000 58 000 11 000 000 4
99
State Acceptance. The State of Arkansas is in general ^agreement with the proposed remedy. However, the State has _Jrequested EPA to carefully evaluate the advantages of Qexcavating the contaminated soil in the Rocky Branch flood -Qplain against the resulting ecological damage and cost from Qexcavation, before selecting the remedy. The State alsorecommends that, since it has been some time since the severlines, sewage treatment plants and floodplains have beensampled, these areas be resampled prior to being remediated.
Community Acceptance. The community response was generallyfavorable to the proposed remedy, except that several citizensare opposed to onsite incineration. Specific responses topublic comments are addressed in the responsiveness summary.
100
IX. THE SELECTED REMEDY
The remediation goals for the Vertac off-site area are: —
1. Residential and agricultural areas should be remedi? cedto 1 ppb TCDD.
2. For nonresidential/nonagricultural areas (Old STP, WestWWTP), prevent direct public contact with contaminatedsoils containing TCDD concentrations above 1.0 ppbTCDD. For the Old STP and West WWTP, this action levelis 1.0 rather than 5 to 7 ppb TCDD as recommended byATSDR, because levels above 1 ppb still represent a lowlevel risk to the public that can be eliminated throughcost-effective measures such as soil capping. Publicaccess to these areas was demonstrated when personsused the sludge drying beds for gardening.
3. Prevent migration of TCDD-contaminated soils into thewaterways and surrounding flood plains.
4. Prevent migration of TCDD-contaminated sedimentsthrough the sewage collection lines to the newJacksonville sewage treatment facility.
The selected remedy is Alternative 6 a , with some minormodification to address comments by the State of Arkansas. Themajor components of the selected remedy include:
o Sewage Collection Lines — Sediments would beremoved from the active sewage collection linesbetween the Vertac plant site and the WestWastewater Treatment Plant and incinerated onsite.Pipe liners would be installed in the cleaned sewerlines. Cleaning the line and installing the pipeliner will allow the interceptor to be routed to thenew Jacksonville sewage treatment facility, withoutcontaminating the new facility. The abandoned linewould be filled with grout to reduce the migrationof contaminants in the line.
o Old Sewage Treatment Plant — The sludge would beremoved from the sludge digester and incineratedonsite. The sludge drying beds would be capped withone foot of clean soil. Accumulated water in thetreatment units would be removed, treated anddischarged, and the treatment units would bedemolished and capped with one foot of clean soil.EPA will negotiate with the City of Jacksonville toplace a notice in the deed recommending that the Old
101
STP 'site zoning remain commercial/industrial and $»^access be restricted, s.
ylo West Wastewater Treatment Plant — The aeration o
basin would be drained, the dikes demolished, and .0the entire basin capped with one foot of clean soil. 0A notice would be placed in the deed recommendingthat the West WWTP site zoning remaincommercial/industrial and access be restricted.
o Rocky Branch and Bayou Meto Flood Plain — In orderto minimize ecological damage to the floodplain andto the downstream areas, the floodplain areas thatare currently residentially zoned will be resampledand only those areas with actual 2 ,3 ,7 ,8tetrachloro-dibenzo-p-dioxin (2 ,3 ,7 ,8 TCDD) levelsgreater than 1 .0 ppb will be removed and incineratedonsite.
o Rocky Branch Creek and Bayou Meto — Monitor fishin these streams for dioxin and continue ban oncommercial fishing and advisory discouraging sportfishing as long as fish tissue dioxin levels areabove Food and Drug Administration alert level.
The implementation of the selected remedy will result in thereduction of carcinogenic risk from being as high as 10'3 dueto the sewer line sediments to the 10'5 to 10'6 range, dependingon the point of exposure.
102
I>X. THE STATUTORY DETERMINATIONS ^
0The remedy selected must satisfy the requirements of Section 121°Of CERCLA to: -"
o Protect human health and the environment;
o Comply with ARAR*s (or justify a waiver);
o Be cost-effective;
o Utilize permanent solutions and alternativetreatment technologies or resource recoverytechnologies to the maximum extent practicable; and
o Satisfy the preference for treatment as a principalelement or justify not meeting the preference.
A discussion of how the selected remedy satisfies these statutoryrequirements is presented below:
Protection of Human Health and The Environment. Implementation ofthe selected remedy would eliminate the risk of exposure ormigration associated with contaminated sediments in the activesewer lines, sludge in the digester, and Rocky Branch Creek floodplain soils containing greater than 1 ppb TCDD. The removedsediments, sludge, and excavated contaminated soil would beincinerated. The grouting of the abandoned Rocky Branchinterceptor will minimize the potential for further contaminantmigration in those lines. Demolition of the old STP structures,burial onsite, and capping will reduce the potential for futureexposure to these contaminated materials. Capping of sludge dryingbeds will eliminate the risk of agricultural use of the drying bedsand the potential for migration of contaminated soil. Dewateringand capping of the aeration basin in the West Wastewater TreatmentPlant will reduce the risk of exposure to contaminated sedimentsand eliminates the potential for migration.
Compliance with ARAR's. The selected remedy will comply with allARAR's. The selected remedy addresses contamination in the activesewer lines, sludge digester, and Rocky Branch Creek flood plainsoils to the levels recommended by ATSDR for each area. Sedimentsfrom active sewer lines, sludge from the digester, and Rocky branchCreek contaminated floodplain scils would be incinerated. RCRAhazardous waste management requirements would be applicab a forremoval and treatment of these wastes.
Solids dewatering prepares solid wastes for treatment in the onsiteincinerator. The RCRA hazardous waste management requirements arerelevant and appropriate to the dewatering process and management
103
of residuals. (See Appendix D for RCRA requirements for container storage, tank storage, and treatment.) xs"
'^9
Onsite incineration would treat (destroy) dioxin in contaminated materials, and would satisfy RCRA hazardous waste disposal requirements. (See Appendix D for RCRA requirements for ssincineration, treatment, and tank storage.)
The flushing water from collection lines, liquid from solidsdewatering, liquid decontamination wastes, and scrubber blowdownwater from incineration would be treated by an onsite filtrationand carbon adsorption treatment system. Wastewater treatmentstandards for liquids contaminated by dioxin are not specified byRCRA. However, treated effluent would meet the substantiverequirements of the National Pollutant Discharge Elimination System(NPDES). Effluents regulated by the Clean Water Act are nothazardous wastes, by definition. However, the RCRA hazardous wastemanagement requirements would be applicable to management of theresiduals from the treatment process. (See Appendix D forrequirements for container storage, direct discharge of effluent,tank storage, and treatment.)
^ RCRA hazardous waste management requirements are consideredrelevant to the contamination in and around the abandonedcollection lines, but not appropriate because there is little risk
' of exposure. Therefore, although there is no ARAR requiringgrouting, this remedy component provides a cost-effective means ofminimizing further contaminant migration through the collectionlines.
Cost Effectiveness. The 30-year present value cost for theselected remedy is estimated to be $14,000,000 and is moderate whencompared to the most expensive alternative, which would cost$40,000.000 (30-year present worth). The selected remedy providesa similar degree of protectiveness as the most expensivealternative but is much less expensive. The less costlyalternatives do not afford adequate protection of human health andthe environment and they are not considered appropriate.
Utilization of Permanent Solutions and Alternative TreatmentTechnologies or Resource Recovery Technologist to the MaximumExtent Practicable ( " M E P " ) . The selected remedy meets thestatutory requirement to utilize permanent solutions and treatmenttechnologies, to the maximum extent practicable, becauseapproximately 5250 cubic yards of contaminated materials would bepermanently destroyed. Alternative 6a was selected because thisalternative is protective of human health and the environment,complies with all ARAR's, reduces the toxicity, mobility, andvolume of the contaminants to the maximum extent practicable, isimplementable and is the most cost-effective. Alternatives 4, 5 ,6 a , and 6b provide similar degrees of protectiveness, but the costsfor Alternatives 4 and 5 are much higher ( 1 . 5 times to about three
104
0I>
times higher than the cost for the selected remedy) . These two alternatives involve tasks not considered necessary for protection °of human health, such as excavation and incineration of sewer °lines. Alternatives 6a and 6b are identical, except that in —Alternative 6a the soils excavated from the Rocky Branch Creekflood plain would be incinerated, whereas in Alternative 6b theexcavated soil would be consolidated onsite and capped.Alternative 6a was chosen because this alternative utilizes a morepermanent solution and treatment technology to a greater extentthan Alternative 6b.
Preference for Treatment As A Principal Element. By treating thedioxin contaminated soils/sludges/sediments in a thermal treatmentunit, the selected remedy addresses the principal threats posed bythe site through the use of treatment technologies. Therefore, thestatutory preference for remedies that employ treatment as aprincipal element is satisfied.
105
XI. DOCUMENTATION OF SIGNIFICANT CHANGES £*I>
The proposed Plan for the Vertac site was released for public "^comment in July 1990. The Proposed Plan identified Alternative 6a, wincineration of removed soils/sediments/sludges, capping of drying (wbeds, demolished STP structures, aeration basin, etc . , as thepreferred alternative. EPA reviewed all written and verbalcomments submitted during the public comment period. Upon reviewof these comments, it was determined that no significant changesto the remedy, as it was originally identified in the ProposedPlan, were necessary.
106
!
XII. RESPONSIVENESS SUMMARY
The following is a summary of the questions and comments receivedat the public meeting and during the public comment period. Manyof the comments received relate to the Vertac site. in general, andnot specifically to the proposed plan for the Vertac off-siteareas. Most of the questions and comments received regardingincineration were made with respect to the State of Arkansasincineration of the 28,500 drums of dioxin waste on the Vertacplant site. The responses to these questions are meant as aresponse to both the incinerator currently onsite and anyincinerator to be built onsite for destruction of the contaminationfrom the Vertac off-site areas. Comments received from Hercules,Inc., a potentially responsible party, are summarized separatelyin this Responsiveness Summary.
TOXICOLOGY AND HEALTH CONCERNS
COMMENT #1 : What is the basis for the Toxicological Profile ondioxin which was distributed at the meeting?
RESPONSE: The Toxicological Profile was based on a review of allof the literature on dioxin. The profile was compiled by SyracuseResearch corporation for the Agency for Toxic Substances andDisease Registry and EPA.
COMMENT #2: What is the airborne standard for dioxin which isconsidered to be dangerous?
RESPONSE: The action level set by the Center for Disease Controlfor airborne dioxin is 5 .5 picograms per cubic meter. This is thelevel which is considered safe. EPA has set a working action levelof 3.0 picograms per cubic meter, which includes additional safetyfactors.
COMMENT #3: Why are silvex, xylene, chlordane, mirex, heptachlor,toluene, aldrin, dieldrin, DDT, lindane, and toxaphene notdiscussed with respect to the site?
RESPONSE: Dioxin is used as an indicator compound for the abovelisted compounds. Dioxin is considered to be much more toxic andif the soils are cleaned up to the dioxin cleanup levels, the othercompounds will also be cleaned up. In addition, many of thecompounds lis-ted above are highly volatile or biodegradable, andtherefore, are not likely to currently exist at levels of concern.
COMMENT tt4: Why will a health study not be done until 1991? IsEPA not giving the citizens of Jacksonville a fair health studybecause Vertac produced Agent Orange for the Government?
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i ' 09RESPONSE: Trie Arkansas Department of Health has established a-^rcommunity panel so that the citizens of Jacksonville will have input on what they would like to see in a health study relating to-othe Vertac site. The Agency for Toxic Substances and DiseaseoRegistry will support the study by providing help on the final-ostudy design and review.
COMMENT #5: Will the results of the National Dioxin Study be usedas a basis for the health assessment?
RESPONSE: The National Dioxin Study focused on levels of dioxinin the environment (i.e.,in the soil, water, and fish tissue) noton health effects from dioxin. However, there is a registry ofworkers exposed to dioxin, which is kept by the National Instituteof Occupational Safety and Health. The institute monitors thehealth of these workers and their families. A series of initialreports are due to be published over the next six months.
COMMENT #6: Why is the cleanup level of 1 ppb dioxin being usedwhen more recently published data indicates a higher value of 100ppb for a cleanup level?
RESPONSE: The 1 .0 ppb clean-up level for dioxin is used forresidential areas by EPA because it is within the acceptable riskrange set by the National Contingency Plan and is recommended bythe Agency for Toxic Substances and Disease Registry. It has beenused at numerous other dioxin sites. According to the EPA acceptedmethodology for calculating risks, a 100 ppb clean-up level wouldleave a residual risk in excess of 10'3, which is far above theaccepted risk range of 10' to 10' .
COMMENT #7: If the contamination has not caused any healthproblems or migrated in the last 40 years, why can't the materialsit there for another 40 years?
RESPONSE: The off site contamination does not appear to have causedany health problems, but uncertainties in this assessment do existand the offsi te contamination does pose a risk to human health andthe environment and, thus, should be remediated. Dioxin has beenseen to migrate downstream through the sediments and has beendetected in fish tissue. Even though a decrease in dioxinconcentrations in the stream sediments and the fish tissue has beenobserved, the removal of the contaminated materials in thefloodplain will expedite the cleansing of the system.
INCINERATION
COMMENT #1 : Will paniculate matter and contamination be spreadout over Jacksonville during incineration?
RESPONSE: No. The particulates are limited by the air standards,which are required to be met by the particulate removal system on
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. . . 0any hazardous waste incinerator. The removal system on the QQincinerator that is currently constructed onsite is designed to cremove the particulates down to 1/6 of the air standard. With Qrespect to contamination, any incinerator used to destroy dioxin Qcontaminated waste at the Vertac site will be designed and required Qto destroy or capture 9 9 . 9 9 9 9 % of the contamination in thematerial. In addition, EPA will be monitoring air quality at thesite regularly.
COMMENT #2: How will EPA monitor the performance of theincinerator?
RESPONSE: The performance of the incinerator currently builtonsite and of any future incinerator built onsite will be monitoredthrough the operating parameters which will be set during the testburn. The purpose of the test burn is to define the specific modeof operation needed to operate at the 9 9 . 9 9 9 9 % destruction removalefficiency level. Once these parameters are established, they mustbe met at all times during incinerator operation. In addition, EPAwill be monitoring the air quality around the site during theoperation of the incinerator.
COMMENT #3: Who will be responsible for shutting down theincinerator if there is a problem?
RESPONSE: During the State incineration of the drums, the Stateand their contractor will be responsible for shutting down theincinerator if there is a problem. EPA will be monitoring theperformance and will coordinate closely with the State during theincineration of the drums. During the incineration of the off-site material, EPA will be responsible for shutting down theincinerator if there is a problem.
COMMENT ft4: What is the danger to people living next to the sitefrom the incineration, especially the children?
RESPONSE: There is no danger from the incineration to the people,including the children, living next to the site during incinera-tion. The incineration performance regulations require a minimumdestruction and removal efficiency of 9 9 . 9 9 9 9 % for dioxin wastes.These standards were set based on analyses of potential risks tothe health or the environment and the levels of performance thathave been measured for properly operated and well designedincinerators. Although the 9 9 . 9 9 % destruction and removalefficiency is protective of public health and the environment, amore stringent standard of 9 9 . 9 9 9 9 % destruction and r-.-'iovalefficiency was set for wastes containing dioxin because of £PA'sand the public's concern about this particularly toxic chemical.
COMMENT #5: How can the residents of Jacksonville be assured thatthe incinerator at Vertac will not be used to commercially burnhazardous wastes or to burn wastes from other Superfund sites,
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other than from the Jacksonville and Rogers Road landfills, after T"<the Vertac wastes are incinerated? 00
T-»RESPONSE: In order to commercially burn hazardous waste at an 0incinerator, a permit under the Resource Conservation and Recovery 0Act would be required. This permitting process requires public 0comment prior to issuance of any type of permit, with respect towaste from other Superfund sites being brought to Vertac forincineration. Federal regulations only allow waste from oneSuperfund site to be brought to another site when sites aregeographically close and contain similar wastes.
COMMENT #6: Why doesn't EPA know exactly how much soil needs tobe incinerated at this time?
RESPONSE: The purpose of the Feasibility Study, which isculminated by the issuance of the Record of Decision, is to developthe conceptual remedy for the site. Not until the design andactual remediation process, which includes testing to verify thecomplete extent of the contamination, is the exact amount of soil,which needs to be incinerated, known.
COMMENT #7: How can EPA incinerate this material without acompleted health assessment or environmental impact study?
RESPONSE: EPA has determined that the preparation of anEnvironmental Impact Statement is not required in connection witha Superfund cleanup because of the functional equivalency of theRemedial Investigation/Feasibility Study process. Since theprocedures in the Superfund Remedial Investigation/FeasibilityStudy process result in a rigorous review of environmental andhealth considerations, the health and safety of the community andthe environment can be ensured without a separate environmentalimpact statement.
COMMENT #8: Has an incinerator been used to burn dioxin waste ina residential neighborhood anywhere in the country before?
RESPONSE: The incineration of hazardous material has beenoccurring for many years. There are numerous facilities inoperation throughout the country which incinerate many differenttypes of hazardous wastes on an ongoing basis. Only a smallfraction of the incinerators of this type are operated under theauthority of Superfund. Instead, most are private or commercialfacilities regulated under other Federal Laws such as the ResourceConservation and Recovery Act, the Hazardous and Solid WasteAmendments, and the Toxic Substances Control Act, among others.Additionally, there are other agencies besides EPA which overseethe operations of these facilities, for example, the Department ofEnergy and the Department of Defense.
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Although there are known instances of hazardous waste ( i . e . , 01dioxin) incineration being conducted in or adjacent to cities and 00towns, information detailing the specific location of incinerators relative to population density within a known proximity is not 0readily available. However, it is known that dioxin contaminated 0soil was incinerated, in a residential area in Gulfport, ®Mississippi.
COMMENT #9: What will the incinerator be doing during times whenthere is no burning going on?
RESPONSE: If it will be a long time before the next time soil willbe burned, the incinerator will be shut down. If incineration willbegin again soon, the incinerator will continue to be heated.
COMMENT #10: Is it possible that the MRK incinerator will not bethe incinerator used at Vertac after the drums have beenincinerated?
RESPONSE: At present, it is not known what incineration contractorwill be used to incinerate the off-site waste. If EPA performs theoff-site cleanup action, EPA will follow the Federal procurementregulations and the competitive bidding process. If a potentiallyresponsible party performs the off-site cleanup action, the
"*• potentially responsible party can contract with any qualifiedincineration contractor, with oversight by EPA.
COMMENT #11: How can EPA bypass a city ordinance which allows thatonly the 28,500 barrels be burned at Vertac?
RESPONSE: CERCLA mandates that Superfund response actions complywith all Applicable or Relevant and Appropriate Requirements( A R A R ' s ) . ARAR's consist of all Federal or State environmentallyprotective requirements that either address specific circumstancesrelated to Superfund sites, or situations sufficiently similar tothose encountered at the CERCLA site that their use is well suitedto the particular site. Compliance with the substantiverequirements of State regulations is required only when theregulation is uniformly applied on a State-wide basis. Localordinances would not qualify under this criteria because they arenot applied consistently across the state. Another reason thatcompliance with standards other than Federal and State regulations( i . e . , local ordinances) is not required is that they might undulyrestrict or otherwise encumber timely remedial response atSuperfund sites.
COMMENT #12: If the destruction efficiency is 9 9 . 9 9 9 9 % , whathappens to the 0.0001% that is left?
RESPONSE: The remaining 0.0001% is allowed to be discharged fromthe stack into the air. This standard was set based on theanalyses of potential risks to health and the environment and the
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, f^levels of performance that have been measured for properly operated ^and well designed incinerators. 100% destruction is only ~theoretical and is not possible in reality. _ '
<"'•&COMMENT #13: Can the incinerator at Vertac withstand an earthquake, since one is predicted for the New Madrid fault?
RESPONSE: It is not possible to plan for all natural disasters,but EPA and the State are attempting to mitigate the effect of anynatural disaster by destroying the waste now so that a naturaldisaster will not create a risk from the contamination as it sitstoday.
SAFETY
COMMENT #1: During the excavation of the Creek and Bayoufloodplains, what precautions will be taken to ensure that theexcavated material will not be blown, washed, or tracked into thecommunity?
RESPONSE: The precautions to be taken to ensure that the excavatedmaterial will not be blown, washed, or tracked into the communitywill be thoroughly developed during the design phase of theproject. These design elements are standard procedures in modernhazardous waste management projects.
COMMENT #2: Is there an evacuation plan for Jacksonville and whois responsible for implementing it?
RESPONSE; The City of Jacksonville is responsible for theevacuation plan. More information concerning the evacuation plancan be obtained from the Jacksonville Fire Department.
ROCKY BRANCH CREEK AND BAYOU METO
COMMENT #1: As part of the off site remediation, can EPA post andidentify Rocky Branch Creek with signs so that people are aware ofwhere it is located?
RESPONSE: EPA and the State of Arkansas searched for signs alongRocky Branch Creek. Fourteen signs were found to already exist andthe State o'f Arkansas posted several additional signs.
COMMENT #2: Is the contamination so extensive in Rocky BranchCreek to warrant the excavation of the Creek and Bayou? This couldcause excessive damage to the ecological habitat.
RESPONSE: EPA believes that it is not necessary to excavate theCreek and Bayou sediment because the level of contamination doesnot pose an unacceptable risk to human health. However, EPAbelieves that it is necessary to excavate residentially-zonedareas, including floodplain, which are above the residential action
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level of 1 ppb. This will ensure the safety of area residents ^exposed to the floodplain. In order to minimize ecological damage Q0due to excavation, retesting of the floodplain areas prior to excavation will be required to ensure that only those areas with ,'°concentrations greater than 1 ppb will be excavated. In addition, /CTthe remedial design will require that great care be taken tominimize damage and tree removal during excavation and that grassesand tree saplings be planted in the excavated areas to minimizeerosion.
COMMENT #3: The State of Arkansas commented that carefulconsideration should be given to the advantages of excavating thevery low TCDD concentrations in the Rocky Branch Creek floodplainversus the ecological damage resulting from that action.
RESPONSE: EPA is very sensitive to this "trade o f f . " EPA believesthat the large area that contains greater than 1 . 0 ppb TCDD shouldbe excavated, but that every effort should be made to minimizedisruption to the area ecology. With this in mind, the remedyrequires that all areas be resampled prior to excavation. Onlythose areas above 1 . 0 ppb will be excavated. Furthermore, thedesign will require that excavation procedures be used to minimizethe removal of trees, and that the excavated areas be seeded withgrasses and tree saplings planted.
COMMENT #4: Why hasn't there been a study to assess the impact ofthe contamination on the food chain?
RESPONSE: EPA has recently entered into an interagency agreementwith the United States Fish and Wildlife Service for the Fish andWildlife Service to conduct a study to assess the availability ofdioxin to the food chain. The study is scheduled to begin in thewinter of 1990 and to be completed in 1992.
WASTEWATER TREATMENT PLANT
COMMENT #1: How extensive was the EPA remedial investigation ofthe sewer system? Was the entire city investigated or just thesystem around and near Vertac? Is it possible that thecontamination could have spread throughout the Jackson ille sewersystem?
RESPONSE: Only the portions of the sewer system which se 'iced theVertac plant were investigated. There is no evidence tc Indicatethat any other parts of the system were impacted by the pl^nt, and,therefore, were not investigated.
COMMENT #2: After the remediation, will the Vertac site Jontinueto discharge from outfall 002 into the West Wastewater TreatmentPlant? Jacksonville Wastewater Utility wants to close the WestWastewater Treatment Plant after completion of the offsiteremediation. The Wastewater Utility also requests that all unused
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t s^building sewers be sealed off at the Vertac property line and that QQall active sewer lines on the plant be either replaced or lined before any water on the Rocky Branch interceptor is diverted to the onew Johnson Wastewater Plant. 0
0RESPONSE: After the remediation, outfall 002 will dischargedirectly to Rocky Branch Creek or Bayou Meto or discharge via thewastewater treatment plant. The exact details of this dischargewill be determined during the remedial design/remedial actionphase. All unused building sewers will be addressed in theremedial design. The selected remedy states that all active sewerlines will be replaced or lined before any wastewater in the RockyBranch interceptor is diverted to the new treatment plant.
COMMENT #3: Will one foot of soil over the top of the oldstructures at the sewage treatment plant be enough considering soilerosion?
RESPONSE: Yes. The soil cover will be designed, seeded, andmaintained to prevent soil erosion.
FURTHER INVESTIGATIONS AND ANALYSES
COMMENT #1: Request by Kelly Denise Jones to test her property.
RESPONSE: The sampling was conducted by EPA on August 20-21, 1990,and results from the sampling are expected in early October. 1990.
COMMENT #2: Request by Mr. Roy Hawks to test the propertysurrounding his house.
RESPONSE: The sampling was conducted by EPA on August 20-21, 1990,and results from the sampling are expected in early October, 1990.
COMMENT #3: Request for EPA to collect samples at PinewoodElementary School.
RESPONSE: The sampling was conducted by EPA on August 20-21, 1990,and results from the sampling are expected in early October, 1990.
COMMENT #4: Request for EPA to test sewers across Marshall Road•»> from the Vertac plant.
RESPONSE: While there is no reason to believe that Vertac couldhave discharged to these sewers, EPA will sample these sewers toallay community concerns. Results are expected in late October,1990.
COMMENT #5: How can EPA and the public determine if a lab isqualified to test for dioxin?
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RESPONSE: When EPA does sampling for dioxin, either the EPAc0Houston laboratory does the analysis or the sample is sent to a T"*qualified contract lab that has met certification requirements for °the EPA. These laboratories must meet stringent certification0requirements and must adhere to very specific quality control ®procedures. The public can contact the EPA Region 6 Office ofQuality Assurance to check on the qualifications of a laboratory.
i, COMMENT #6: Is it normal to have analyses done at locallaboratories?
! - RESPONSE: Local laboratories can be used if they are qualified.
MISCELLANEOUS
COMMENT #1: How long will it take to complete the off site project?
RESPONSE: It will likely be a number of years before constructionis completed. After the Record of Decision is signed in September199 0 , the design will begin. The design phase of the project willtake at least 18 months. After that the construction can begin.However, there may be advantages to coordinating the onsiteconstruction with the off-site construction, which could delay theoff-site construction.
COMMENT #2: How long will it take to complete the onsite project,besides the drummed wastes?
RESPONSE: A remedy is scheduled to be selected for the aboveground material, located onsite, in mid-1991. The remedy for thesoils and the below ground contamination onsite, will be selectedin 1 9 9 2 . Since the extent of these remedies is unknown at thistime, the timeframes to complete the remedies are unknown.
COMMENT #3: In 19 8 1 , Vertac applied for a water discharge permit,requesting to discharge 30,000 pounds per day of 2,4-D and 15,000pounds per day of 2 , 4 , 5 - T into Rocky Branch Creek.
RESPONSE: The 30,000 pounds per day of 2,4-D and the 15,000 poundsper day of 2 , 4 , 5 - T which were shown in the Vertac permitapplication were not discharge limits requested, but were theproduction rates of each compound at the Vertac facility, at thattime. The water permit was issued to Vertac in 1984 and containedvery stringent discharge limits for these substances.
COMMENT #4: What were the results from the broken water pipe atVertac?
RESPONSE: The pipe was repaired and drinking water samples werecollected from several homes of area residents. No dioxin wasfound in any of the samples.
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£•»COMMENT #5: Is there creosote on the Vertac site? °0
-r-lRESPONSE: No, there is no creosote on the Vertac site. ®
0COMMENT #6: Is Rebel Drive on the Reasor-Hill landfill? °
RESPONSE: No, Rebel Drive is not located on the Reasor-Hilllandfill.
COMMENT #7: Has there ever been a surface or ground water studydone for the Vertac site? Why wasn't the ground water study forthe Vertac site not initiated earlier?
RESPONSE: The surface water samples from Rocky Branch Creek andBayou Meto and the fish tissue samples from the Creek and Bayou doshow the presence of dioxin. The ground water study is beingconducted as part of the onsite investigation. The first priorityof each of the operable units being addressed at the Vertac siteis the removal of the largest amount of contamination first.Therefore, incineration of the drums and the off-site removal weremoved to the forefront. The onsite investigation and ground waterstudy were sequenced after the drums and the off-site study, andare ongoing.
The following is a summary of written comments received fromHercules, Inc. , a Potentially Responsible Party at the Vertac site.Some of the Hercules comments contained general objections or weresomewhat vague. EPA has, in the responses below, addressed allcomments and has given specific responses where specific commentswere made. However, EPA has not speculated regarding the exactmeaning of Herculesr comments which were not clear.
^ COMMENT #1: According to the 1990 Feasibility Study, the areasproposed for remediation, other than the sewage collection lines,pose a risk of l0'4 to l0'6. Since the 1990 National ContingencyPlan (NCP) states that for known or suspected carcinogens,acceptable exposure levels are generally between l0'4 and l0'6.Since the calculated risk for the sewage lines is overlyconservative, there are no health or environmentally based reasonsfor the proposed remedy.
RESPONSE: The areas proposed for remediation pose a threat to bothhuman health and the environment. The NCP states that anacceptable level of lifetime cancer risk is the l0'4 to l0'6 range.It also states that other factors, such as ARAR's and protectionof the environment , should also be considered in remedy selection.The 1990 Feasibility Study states that the risk posed by the sewagecollection lines is on the order of l0'3 and that the risk posed bythe residentially zoned floodplains is 5 .7 x l0'4. Both of theserisks exceed the range considered acceptable by the NCP, andwarrant the selected remediation. The selected remedy is also
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^ necessary to protect the environment. Fish tissue samples show the 0presence of dioxin and a commercial fishing ban is in effect for 0the Bayou Meto and a sports fishing advisory is in place. The 0
' selected remedy is designed to minimize the migration of anyadditional contamination from the floodplain, sewage lines andsewage treatment plants, into the Creek and Bayou.
COMMENT #2: Hercules, Inc. suggests that higher dioxin actionlevels for both residential and industrial areas may be moreappropriate (ChemRisk™ paper). According to the ChemRisk paper,28 ppb TCDD should be the residential action level, compared to 1ppb used by EPA, and 113 to 209 ppb should be the industrial actionlevel compared to 10 ppb used by EPA.
RESPONSE: Hercules, Inc. submitted a report prepared by ChemRisk,which calculates alternative cleanup goals for dioxin, The reportcalculates these alternative cleanup goals using calculations andassumptions that are contrary to EPA guidance. The resultantcleanup levels are, therefore, much higher than those used by EPA.The paragraphs below discuss some of the assumptions andcalculations advocated in the report that are contrary to EPApolicy. All section references in the paragraphs below refer tothe ChemRisk report.
A cancer potency factor for 2,3,7,8-tetrachloro-dibenzo-p-dioxin( 2 ,3 ,7 ,8 -TC DD) of 9,700 (mg/kg-day)'1 is presented in Section 2(Dose-Response Assessment for Dioxin) . This cancer potency factoror slope factor has not been verified by the EPA Carcinogenic RiskAssessment Verification Endeavor (CRAVE) workgroup and is not inaccordance with EPA policy. The CRAVE workgroup is responsible forreviewing and verifying cancer slope factors for EPA. Review byCRAVE is the mechanism by which EPA ensures consistency in theslope factors used by EPA and others, such as PotentiallyResponsible Parties. The EPA slope factor for 2 ,3 ,7 ,8 -TCDD is 1.56x 10s (mg/kg-day) '1 .
Several exposure parameters used in Section 4 (Recommended ActionLevels for TCDD-Contaminated Soil) are not in accordance with EPAguidance. The Hercules, Inc. submission used a soil contact rateor adherence factor of 0 .5 mg/cm2, which underestimates by afactor of 3 to 6 the quantity of soil adhering to the S K - n , whichresults in an underestimate of dermal absorption. This, in turn,results in the calculation of higher allowable coi"aminantconcentrations.
The Hercules, Inc. submission used soil ingestion rate- of 10mg/day for children aged 0 to 1 years, 50 lug/day for child n aged1 to 5 years, and 10 mg/day for older children and adult-.. EPAguidance (OSWER Directive 9 8 5 0 . 4 ) recommends soil ingestion ratesof 200 mg/day for children aged 1 to 6 years, and 100 mg/day forolder children and adults. Use of lower ingestion rates as done
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in the ChemRlsk report results in the calculation of higherallowable contaminant concentrations. 09
00The Hercules, Inc. submission used fish consumption rates of OT"Ig/day, 0 . 4 9 g/day, and 1.48 g/day for ages 0 to 1 years, 1 to 120years, and 12 to 70 years, respectively. The EPA guidanceOrecommends fish consumption rates of 38 g/day for the 50th®percent!Ie daily intake. This rate represents per capitaconsumption and may underestimate the risk for recreationalfishermen who consume larger amounts of fish than the generalpopulation.
The National Contingency Plan states that the acceptable risk rangeis one excess cancer case in ten thousand individuals (10" 4) to one-excess cancer case in a million individuals ( 1 0 ' 6 ) . Using the EPArisk assessment approach, the cleanup levels advocated by theChemRisk report would result in a residual risk, in theresidentially zoned floodplain areas, in excess of 10' 3, whichgreatly exceeds the acceptable risk according to the NCP.
COMMENT #3: The EPA Endangerment Assessment, which assumesexposure to the highest concentration, is too conservative, andexposure to an area's average concentration is more appropriate.
RESPONSE: The risk Assessment Guidance for Superfund Volume IHuman Health Evaluation Manual states that actions at Superfundsites should be based on the reasonable maximum exposure (R M E ) .Because of the uncertainty associated with sampling, the 95 percentupper confidence limit on the arithmetic average is often beingused as a conservative estimate of the exposure concentrationcontacted over time. The use of the highest concentration in theEPA Endangerment Assessment is more appropriate than the use of theaverage concentration. The use of the average concentration doesnot account for the uncertainty associated with sampling.
COMMENT #4: The presentation of data in Table 2-2 of the 1990Feasibility Study ( F S ) is misleading because there is nodistinction made on the depth of the 1988 "surface sampling" ascompared to the 1984 data collected at a depth of 0 - 3 " .
RESPONSE: The 1988 sampling was conducted by collecting twospoonfuls of soil from the top 3" with a stainless steel tablespoon. Therefore it was assumed that the data would be comparablewith the 0-3" collection method cited for the 1984 data.
COMMENT #5: There is no indication on Figure 2-6 of the 1990 FSthat. the west side of the east leg of Rocky Branch was sampled.
RESPONSE: This area is identified on Figure 2-6 with a lightlyshaded marking. The legend identifies this marking as ND which isnot detected with the method detection limit of 0 . 3 ppb.
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• 0COMMENT #6: While not discussed in the 1990 FS, sampling was also 09done by Hercules in 1988 in areas surrounding manholes which are T-<part of the sewer collection system. 0
0RESPONSE: If true, these data were not available to EPA at the 0time the 1990 Feasibility Study was prepared. In addition, sincethese samples were taken from areas surrounding manholes, they donot impact the selection of the remedy for the sewer system.
COMMENT #7: There is no indication in the 1990 FS that ATSDR hasreviewed post-1985 RI data for the off-site areas or that they haveconcurred with the EPA proposed plan.
RESPONSE: EPA summarized the post-1985 RI data and discussed theproposed plan with ATSDR during a meeting held on May 3 , 1990.ATSDR concurred with the EPA proposed plan by letter dated June 11,1990 (Appendix C to this ROD).
COMMENT #8: EPA Region 6 has not followed ATSDR recommendationsfor the Vertac off-site areas or TCDD cleanup levels at sites inother EPA regions. The remedy proposed for the Vertac off-siteareas is also not consistent with the proposed remedy for thelandfills in Jacksonville.
RESPONSE: The proposed plan is consistent with the ATSDR actionlevels for the off-site areas. See responses to comment number 10,regarding residential action levels, comment number 12, regardingthe Old Sewage Treatment Plant, and comment number 1 3 , regardingthe West Wastewater Treatment Plant. Regarding the cleaning of thesewer lines, the proposed remedy at Vertac (remove contaminatedsediments and incinerate sediments) is the same as that employedfor sewer lines at Love Canal site in EPA Region 2. Regardingconsistency with the landfills, the residentially zoned floodplainareas that contain above 1 ppb TCDD should not be capped with cleansoil, as proposed at the landfills where TCDD is between 1 and 10ppb, because this residentially zoned area is subject to erosion..and any capping could be washed out, allowing contaminantmigrations.
COMMENT # 9 : ATSDR action levels are overly conservative and recentinformation about TCDD supports a soil cleanup level for TCDD thatis greater than 1 ppb for residential and greater than 7 ppb forindustrial areas. ATSDR should have been consulted on whether thel ppb was still appropriate for residential areas.RESPONSE: See response to Hercules comment #2. In addition,ATSDRwas consulted and has concurred on the remedy. In addition,according to ATSDR, it is unlikely that these action levels willbe changed in the near future.
COMMENT #10: The undeveloped residentially-zoned areas south ofthe Vertac plant are not readily accessible, less than 10% of the
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area has TCDD' concentrations greater than l ppb and one acre is v-ifenced. This area has an average concentration below l ppb and 09need not be remediated. T"4
0RESPONSE: The 1 ppb TCDD action level for residential areas is a 0well-established and widely-accepted level. Over two acres of ®floodplains along Rocky Branch Creek contain more than 1 ppb TCDD,some areas contain as much as 9 . 6 ppb TCDD. This large area, whileundeveloped, is zoned residential, and still poses a direct contactthreat to nearby residents. Since this area is zoned residential,it is possible that it could be used as such. If this were thecase, then under the residential use scenario, the residents wouldbe exposed to these concentrations in their yards, not an averageconcentration for the entire two-acre area, as suggested byHercules. Therefore, it is inappropriate to use an averageconcentration, under this scenario, for the entire two-acre area.In addition, this large area of contamination still acts as asource of contamination to Rocky Branch Creek, Bayou Meto, and thealready contaminated fish in the Creek and Bayou, and thus posesa risk to the environment. By removing these contaminated soilsin the floodplains, a source of contamination to the aquatic lifewill be removed, possibly expediting the removal of the ban andadvisory against fishing in the Bayou.
COMMENT #11: The undeveloped, residentially zoned area south ofthe Vertac plant should be re-zoned as non-residential, thusremoving the need to remediate the area.
RESPONSE: According to the NCP, institutional controls may be usedonly as a supplement to engineering controls and should not besubstituted for active response measures as the sole remedy, unlessactive response measures are not practicable. Since excavation offloodplain soils in the undeveloped resident!ally-zoned areas ispracticable and desirable to prevent migration of thesecontaminated soils into the waterways, EPA is not in favor ofchanging the zoning in order to leave the contaminated soils.
COMMENT #12: ATSDR has recommended a cleanup level of 5-7 ppb TCDDfor the Old Sewage Treatment Plant and the Region had selected 5ppb in 1 9 8 6 . Despite this recommendation and precedent, an actionlevel of 1 ppb has been selected in the 1990 FS and the proposedplan.
RESPONSE: The sludge in the digester contained 12.4 ppb TCDD,which is above the ATSDR action level. Therefore, the sludge willbe removed and incinerated. The ATSDR recommendation also includedthat migration of contaminants via surface runoff be prevented.The drying beds will be capped with one foot of clean soil toprevent contaminant migration. This would prevent unexpectedexposure by humans to these contaminants and would protect theenvironment by preventing migration into the environment. Theother treatment units, such as clarifiers and trickling filters,
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pose a safety problem and contain small amounts of contaminated Ctsediments. Because of the safety concerns and the SARA requirement OSthat the selected remedy utilize permanent solutions, the treatment units would be demolished and covered with a foot of clean soil. -0This additional measure is considered to be a cost-effective way '0to further reduce the risks posed by the area. 0
COMMENT #13: In 1 9 8 6 , ATSDR recommended a cleanup level of 5-7 ppbfor the West Wastewater Treatment Plant, but the 1990 FS and theproposed plan select an action level of 1 ppb TCDD.
RESPONSE: The ATSDR action level of 5-7 ppb includes thestipulation that contaminants be prevented from migrating from theplant. Grab sampling in 1984 showed that the aeration basinsediments contained TCDD as high as 3 7 . 9 ppb. 1988 grid samplingshowed the aeration basin sediments to contain TCDD as high as 2.8ppb. While the 1984 samples were grab samples, which can identifyhot spots, and the 1988 samples were composites from a grid, whichtend to average the concentrations over the area sampled, such alarge reduction in sediment concentration indicates that the TCDDcontaminated sediments may be flushing into the environment. Inorder to prevent further degradation of the environment, closureof the aeration basin is considered necessary. The two oxidationponds contain sediments with less than 1 ppb TCDD and, therefore,will not be remediated.
COMMENT #14: CDC approved capping an area that contained 51 ppbTCDD in an industrial area in Midland, Michigan and an area with20 ppb TCDD at Times Beach, Missouri.
RESPONSE: CDC/ATSDR provided site-specific cleanup levels for theVertac off-site areas and also concurred with the EPA proposedremedy for the Vertac off-site areas. The selected remedyincorporates the ATSDR recommendations for Vertac off-site areas.
COMMENT #15: The assumption that a sewer worker would ingest 0 . 1grams of the sediment each day during his/her working years indeveloping the risk for excess lifetime cancer for sewagecollection lines is overly conservative. The risks of disease,e . g . , from viral hepatitis, are greater than from the infrequentexposure that might occur from the TCDD in the sewer line.
RESPONSE: The cancer risk estimate for sewage collection lines isbased on a worst-case scenario. However, this risk estimate is notthe basis for the remediation. Rather, prevention of migration ofcontaminated sediments to the new STP and into the environment, ingeneral, require that these actions be taken.
121
V XIONaddY
f ^m^ ^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCYS^W^/ • WASHINGTON. 0 C. 20460
January 26, 1989
MEMORANDUM
SUBJECT: Remediation of Dioxin-Contaminated Sediments Near theVrtac MPLSitJB
FROM: J. Wins^bh Porter, Assistant AdministratorOffice of Solid Waste and Emergency Response (WH-562)
THRU: Renate Kinbrough, M.D. /2u^6. ^^>^ W^ , ^•^.Office of the Administrator (A-101) v
TO: Barry Johnson, DirectorAgency for Toxic Substances and Disease Registry
Sediments in and along the West Leg of Rocky Branch Creek andBayou Meto downstream from the Vertac NPL site are contaminatedwith 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) . This memorandumis intended to provide the rationale used by EPA in determiningappropriate remedial actions regarding these sediments. Yourcomments are requested.
A limited number of channel sediment samples from Rocky BranchCreek and Bayou Meto were analyzed in 1984. Additional samplingwas conducted in 1987 and again in 1988. TCDD concentrations inthese channel sediments reportedly ranged from <0.3 ppb to 2.3ppb. Rocky Branch Creek bank sediments were sampled in September,1988. TCDD concentrations in ten composited samples reportedlyranged from 0.50 ppb to 2.30 ppb.
EPA has previously employed 1 ppb as an action level forremediation of TCDD in creek sediments (EPA, 1987) . The use of 1ppb as an action level is based on a Centers for Disease Control(CDC) recommendation developed primarily for direct contact withTCDD-contaninated soils in residential areas. The CDCrecommendation is derived from Kimbrough et al. (1984), whichdescribed 1 ppb as "...a reasonable level at which to .beginconsideration of action to limit human exposure to contaminatedsoil." It also stated, "Environmental situations may ve-.ry widely,and whether a certain level of TCDD in soil will give rise toconcern has to be evaluated on a case-by-case basis." As thisstatement indicates, the 1 ppb action level was not intended tobe interpreted or applied as an all-encompassing standard.
Rather, the assumptions and uncertainties underlying itsdevelopment need to be understood and compared to site-specificcircumstances* It should also be noted that 1 ppb does notrepresent a fine line between safe and unsafe conditions as thetern "action level" implies. Rather, it was intended to representa level of concern. In addition, soil ingestion data developedsubsequent to publication of the Kimbrough et al. (1984) articleshould also be considered.
Evaluation of the risk assessment assumptions used to derive the1 ppb level in the context of site-specific exposure scenariosapplicable to Rocky Branch Creek and Bayou Meto sediaentsindicates that it is inappropriate to apply this directly as theaction level for these sediments.
There are two plausible scenarios by which humans may be exposedto TCOO contaminating Rocky Branch Creek and Bayou Metosediments. One is direct contact with the affected sediments(resulting in TCDO intake by ingestion, transdermal absorptionand/or inhalation). This scenario would be more applicable toexposed bank sediments than to the submerged channel sediments,as the latter are less accessible for direct contact.
The 1 ppb level was developed primarily for residential soils, asopposed to creek sediments. It was based on a cancer riskassessment which incorporated numerous conservative exposure andtoxicity assumptions. Prominent among these were assumptions thatyoung children would come into contact with the contaminatedsoils on a daily basis, and that young children ingest 10 gramsof soil per day. Since these two assumptions "drove" the riskassessment (Kimbrough, personal communication), their relevanceto the potential for contact with Rocky Branch Creek and BayouMeto sediments is of particular importance.
The daily contact assumption can be reasonable for residentialsoils, which would be readily accessible to children. Incontrast, the affected Rocky Branch Creek sediments are not asreadily accessible, and may be essentially inaccessible to youngchildren. It is also unlikely that children would come into dailycontact with Bayou Meto sediments since these are not in aresidential area. In addition, the assumption of 10 grams/daysoil ingestion has since become viewed as overly conservative;less than 1 gram/day is now viewed as a more reasonableassumption for soil ingestion by "typical" young children (Binderet a l . , 1986; Clausing et a l . , 1987; EPA, 1988; LaGoy, 1987). Inother words, both of the critical assumptions supporting 1 ppb asa level of concern appear overly conservative for application toRocky Branch Creek and Bayou Meto sediments.
Another pertinent assumption in Kimbrough et al. (1994) involvesthe distribution of TCOD -in the contaminated areas. Morespecifically, the 1 ppb designation was predicated on theassumption that 100« of the affected soils are contaminated atpeak levels ( i . e . , assuming uniform distribution of 1 ppb TCDDthroughout the area of potential soil contact). The sampling fromresidential areas near Rocky Branch Creek has shown a few areas(mostly near the creek) with average soil concentrations for TCODequivalents greater than 1 ppb. Removal of these contaminatedsoils is in progress. Upon completion of this removal action theaverage TCDO contamination in surface soil of this residentialarea will be substantially less than 1 ppb. While the bank ofRocky Branch Creek can be considered a portion of the residentialarea, it comprises less than 1 percent of the area. The nearlyvertical banks of the creek make access to the contaminated soildifficult for the young child. In addition, it is separated fromthe residential area by a fence. These factors combine to reducethe opportunity for the young child to have even the normalfrequency of exposure opportunities to these contaminated soils.Figure 2 in Kimbrough et al. (1984) shows that if 1 percent ofthe area is contaminated at the maximum concentration, theestimated lifetime excess cancer risk is two orders of magnitudeless than if the entire area is contaminated at a uniformconcentration. Thus, if the entire creek bank, which representsless than 1 percent of the residential area, is contaminated at amaximum concentration of 2.3 ppb, the estimated excess lifetimecancer risk is equivalent to that if the entire residential areawere contaminated to less than 0.023 ( 0 . 0 2 ) ppb.
The second plausible human exposure scenario leading to TCDDintake from the contaminated sediments is food-chain ingestion.
Based on concern regarding exposure to TCDD via this route, theState of Arkansas Department of Health has imposed an advisorydiscouraging consumption of fish taken from the affectedwaterways. For the same reason, ATSOR has previously recommendedthat an interim action level of less than 1 ppb be achieved inRocky Branch Creek and Bayou Meto sediments (ATSDR, 1 9 8 6 ) . ATSDRalso recommended monitoring of TCDD levels in edible fishportions, to assist in determining the need for continuation ofthe State advisory.
Kimbrough et al. (1984) provided no specific acceptable sedimentconcentrations pertaining to this exposure route. It was stated,however, that acceptable levels for soils which night contaminatewaterways ( i . e . , creek sediments) might have to be lower than 1ppb due to the potential for bioconcentration of TCDD in fishtissue. A potential for 20,000 fold or greater TCDD
- 4 -• S>
<s>bioconcentration in fish (National Research Council of Canada, <r-<
1981) was mentioned in support of this position. °0
Results of fish sampling conducted downstream from the Vertac '°site in 1984 are noteworthy in this regard. TCDD levels wereevaluated in fish sampled from sections of Bayou Meto in whichsediment TCDO concentrations were less than 1 ppb. TCOO levels inedible portions of those fish ranged from 136 ppt to 704 ppt,well in excess of the 25 ppt PDA concern level.
Both these data and the potential for TCDO bioconcentration wouldindicate that the ATSOR recommendation to achieve levels lessthan 1 ppb should not be interpreted as a recommendation toachieve l ppb or less. Rather, remediation to levelssubstantially lower than 1 ppb may be necessary to achieve TCDDlevels in edible fish tissue which meet the current PDA concernlevel of 25 ppt.
To date, neither EPA nor ATSOR have specified sediment TCOOconcentrations permissible for unlimited fish ingestion.Therefore, an action level for Rocky Branch Creek and Bayou Metosediments based on potential risks to human health posed by fishingestion cannot readily be designated. However, action levelscan be based on potential human health risks posed by directcontact with the sediments, in conjunction with continuation ofthe State of Arkansas Department of Health advisory againstconsumption of fish taken from the affected waterways. Inaddition, EPA will be conducting long-term monitoring of TCDDlevels in fish and other wildlife in Bayou Meto and Rocky BranchCreek, in accordance with the ATSOR recommendation.
The recommendation of 1 ppb as a level of concern was qualifiedwith, "The appropriate degree of concern for which managementdecisions are made should consider an evaluation of the specificcircumstances at each contaminated site." (Kimbrough et a l . ,1984). It is clear that the derivation of the 1 ppb concern levelwas based on soil exposure assumptions which were more thanseveral-fold greater than the exposures to sediments expected inand along Rocky Branch Creek and Bayou Meto. Therefore, assuminga continuing and effective State advisory discouraging ingestionof fish taken from the affected areas, the reported <0.3 ppb to2.3 ppb TCOO levels in these sediments should not pose anunacceptable health threat. Based on the above evaluation, EPAhas determined that no clean up of either the West Let, of RockyBranch Creek or Bayou Meto to protect human health is necessary.
REFERENCES
ATSDR, 1986. Memorandum dated April 24, 1986 from Jeffery A.Lybarger, ATSDR, to Carl Hickam, Public Health Advisor for U.S.EPA Region VI
Binder, S . , D. Sokal and D. Maughan. 1986. Estimating soilingestion: the use of tracer elements in estimating the amount ofsoil ingested by young children. Arch. Environ. Health 41:341-345
Clausing, P . , B. Brunekreef and J.H. van Wijnen. 1987. Afor estimating soil ingestion by children. Int. Arch.Environ. Health 59:73-82
methodOccup.
Kimbrough, R . D . , H. Falk, P.implications of 2 , 3 , 7 , 8contamination of residential14:47-93
Stehr, and G. Fries. 1984.•tetrachlorodibenzodioxinsoil. J. Toxicol. Environ.
Health(TCDD)Health
LaGoy, P.K. 1987. Estimated soil ingestion rates for use in riskassessment. Risk Analysis 7:355-359
National Research Council of Canada (NRCC). 1981. Polychlorinateddibenzo-p-dioxins. Publ. NRCC No. 18574 of the EnvironmentalSecretariat. Ottawa, Canada: National Research Council of Canada
U. S . EPA, 1987. Superfund Record of Decision: MinkerStout/Romaine Creek, HO. EPA/ROD/R07-87/007. September, 1987
U.S. EPA, 1988. Superfund Exposure Assessment Manual.88/001. April, 1988
EPA/540/1-
APPENDIX B
Miilc M—th Suv<« 0DEPARTMENT Qf HEALTH A HUMAN SERVICES Af-cy <sr T rt-.-ia-JCh
__________________________W D'MM»ff»e'«fy^g
DM' APR 2 4 1986
p^n, Aotinc DirectorOffioa of Health iaaeasaant
Subitet Htftlth Aaaaaauant, Off-alt* Remedial Zavaatlfatioa,Vertao Cnaaioal Corporation, Jacksonville, Arkaaaaa 52-8S-079
To Mr. Carl Biok—Publio a«alfcb AdTicorEPi X««ioa VI
Kgenrrvg siMmy
The Envlroaaental Protection Afocy (EFA), X«(ioo VZ Office, •ubaittod
data indloatiAf tbat Jlud««« and a«dla«at« la th« J«olc«onvill« w««t«vfr
tr««ta«at plant •yfa (VWTP). Kooky Branch, Bayou Meto, and aaaoolafd
floodplains are oontaainated with aeveral compounds including
tatraohloro-dibenzo-p-dioxina (TCTD). Becauae of tha potential for human
exposure to these compounds, and bha potential for a major release of
these compound* from the WWTP to downstream water and land reaouroes, tha
A«enoy for Toxio Substances and Disease Registry (AT30X) offers the
following; recommendations: ( 1 ) restriot general public aooaaa to tha
abandoned and existing WWTP) and to the channel and floodway soils of the
west leg of tha Rooky Branch in tha residential area Just south of Vertao;
(2) prevent additional aigration and flood release* of oontaainanta froa
the WVTP aystea, other environmental sinks in Rooky Branch, Bayou Meto,
and their floodways, and from Vertac; (3) residential land uses on tha
Vertac site would constitute an unacceptable health risk; (4) provide
additional characterization of both on-site and off-aita contamination to
deterolne the need for additional remediation; and (?) lapleaent a health
and skfety plan for all on- and off-site reaedial activities.
g7ATEMg??T nF PMBLgM
The ATSOR has been requested by the U.S. Environmental Protection Agency
(ERA), Region VI, to review and comment on the Draft Off•sits Remedial
Investigation (RI5 for tha Vertao Chemical Corporation plant,
Page 2 - Mr. Carl Hiokaa
Jacksonville, Arkanaaa* In addition, E?A baa aakad ua 60 addrooa the
following conoernai
1. The public health aignifioaaee of the oontaainaat
levela found la envirooaeatal pathway,
2. The aaed for off••if oleoaup.
3. Aaaiataaoa la developing guideliaea and orlfria
for off-clfce r«a«dixtioa of diozia«oont«ain«t«d
•oilA/aludf/rdlaenta to protect public h«*16h»
aTTg ggaeBTyrrnff tm flAercMnm
Th« 7«rtao Cheoiool Corporation p«Jfcioide plaat li«a on the iit« of ft
fora«r World Var II ordnance plant. Peatleidaa hav been produced on the
aite ainoe 1916 by three foraer ooapaniea. Xaaldential aubdivlaiona lie
issedl&tely south •sd ^w^ of the Tertae plaat aite* The land uae to the
north and weat la priaarily undeveloped or oomercial/li(ht Induatrial.
For additional background inforoation on the aite, pleaae refer to our
reporta to SPA Xecion 71 dated April 1 1 , 19fl3, and January 15, 1966, oa
the Vertao Site aad February 25, 1900* on fiah data«
LJ3T or pormfflirpa agyrgigp
1. Off-aita RCBedial Zoveaticatioa, Draft Report Toluae I-R«port &
Bibliography, Draft Report Toluae H- Tablea 6 Appendioea, Draft
Report Voluae 121- Mape & ricuree. Project Ho. CH313-<» Site
Ho. 98>6L04, prepared for the E?A uoder Contract lo* 68~01«(692 by
CB2M Hill, Ino* aad Eoolocy aad Environaent, Ino., July 12, 19fl5.
2. Supplement to the Off•cite Reoedial Znveati«atioa, Draft Xeport-
Oelineationa 4 Toluaea/A Workin* Paper, Project He* CH313-6, Site
Ifo* 98-6L01, prepared for the ERA under Contract Ho. 66-01-6692 by
CB2H Hill, Inc. aad Ecology and Environaent, Inc., July 19, 1985.
?tf 3 - Hr. Carl Hiekaa
3. Memorandum datad SepfabT 3, 1985, froa Mr. Larry P. Xexroat,
Super fund BnforceBent Section, ZFA Region VI, to Mr. Carl Blokaa,
Public Health Advisor, C8C/EPA Region 71.
4. ATSDR proj«ot fir.
LTST Qy MTfffT^r CfflrPAMTffi
The pplaary oon6«aln«nts of oonoern la off-tlte ar«u laoludci
2,3,7,8-TCTD. 2,4-dlchlorophenoxyacetic acid (2,4-0),
2,4,5-trichloroph»noxy»c»tio acid (2,4,5-T), silvex, omorlnafd ph«nol«
and benzanaa. Th« RI foouaaed on 2,3,7,8-TCDD, and ua«d tha caaarlo tarB
'•dioxin- for 2,3»7*8-TCDD (p. 1-1, Vol. I).
QPALTTY CQM-raOLfQC^
To date, only tha 1964 aaapling data have received QC, An aooaptable
•valuation of the QC for the 1984 data vaa provided la Appendix 10 (Vol.
III).
STTg TM3PECTTQg
On March 5 and 6, 1986, AT30R conducted a alta Inapeotlon and aat with
Mr. Larry Rexroat, Project Of floor, and Mr. Larry Hl»ht of B?A Region II,
and Richard Satardal of CH2M Hill. Pleaae refer to Attaohaent 1
aufflnarizioc ATSOR'a itinerary, infonaatlon obtained, and problaaa obaerved
during the site Inapeotlon. Photographs were taken of both the Tertao
alte and off-alte areaa.
gMVTaQNMWrit. SAMPLTM
In Qaaaaber 1983, ••venty-four •edlaeat and aoll aaaplaa were oolleoted In
the off-alte etudy area and analysed for "dioxin," 2,4-0, 2,4,5-T, allvax,
chlorinated benzenea, chlorinated phenola, and othar organlca. Forty of
the ••venty-four aaaplea contained "dioxin" (See Tablea 5-1 6 5*2, Vol.
II, and refer to Attaohaent 2).
?•<• 4 - Mr. Carl Hiokaa
la June 1984, twenty-one foil aaaplea vre collected la &r«a« within 500{••t of Bayou Meto that, Judged by vlaual iaapeotioa, had b—a frequentlyflooded* The«e aaaplea vre analyzed for "dioxin." Only one of theaeooatained aeaaurable levela (0.43 ppb) of "dioxia."
In Au«uat 1984i 229 field aaaplea of aoll and aediaenta wer« oolleoted for"dioxin" analyala; 29 additional aaaplea were oolleoted for baokfrouad aadquality control. Seventy-nine of the 229 field aaaplea containedaeaaurable aaounta of "dioxin" ran inc froa 1.0 ppb to •ore than 200 ppb.Until thia particular eaaplinc effort, the abandoned WTCf aad the exiatincWWT? aeration pond '...had never been aaapled..." (p* 5-7» Vol. I). Znaddition. Rooky Branch and Bayou. Keto had only been aaapled at road andrailway croaain«a; thia aaaplinc effort inoluded other aediaeat aaaplinclooationa in the atreaa cbanaela aa well aa aoila throughout the 2-yearaad 5-year floodplaina. Pleaae refer to Attaohaent 2 for a ausaary of the"dioxin" data«
The higheat 2,4-D level (20,000 ppa) and the hicheat 2,4,5-Tlevel (7,200 ppa) were found in a 1984 sludge aaaple froa WWTP manhole 77(Z016A), Thia aaffle aludge aaaple alao contained the hicheat "dioxia"level 0200 ppb) found durlne the 1984 aaapliac aad analyaia effort* Thehi»heat conoentrationa of ail vex were found la 1983 la aludfe aaaplea froaan abandoned interoeptor/aanhole •2 (67 ppa, 1-5) aad a newiafceroeptor/aaahole <19 «100 ppa, 1-4). Bexaehlorobeaxeae (300 ppa,1-3)• peataehloropbenol (300 ppa, 1-3), oalordaae (48.3 ppa, Z006A),aad 2,4,6-triohloropheaol (5.7 ppa, Z016A) were alao found la the VWT?colleotioa Jystea aludee. In the vioiaity of Hinea Cove alonf RookyBranch wt lee, 2.8 ppa PCS 1254, 1.5 Ppa 2,4-0, aad 2.7 ppa 2,4,5-T(N0301) were found in a 1984 floodplaia •oil •aaple (X030A).
Page 5 - Mr. Carl Hiokiffl
SMTFMNMgyTAL >ATHVA?S
>^ ^•^ BBfealf
Bioooaoeatration has be«a doouaented ia aquatio orgaaisas dowastreaa of
both the Vertao plant ia Rooky Branch and the Bayou Mto and the WPT
outfall la the Bayou K«to. nan aaaples collected as far as 15 ailee
downstreaa froa Bocky Braaoh contained I«T«I» of 2,3»7i8-TCTO ia the
edible portions that exceeded FDi'a Great Lakea advieory level. Vhole
fish •aaplee eolleoted in Bayou Hefco a« far aa 75 ailee dovnatrean (Bayou
Meto Vildlife Kana«eaent Area) of Rooky Branch have been found to be
ooataainated.
lip Tr«Mnort
Large ground surface areas are exposed on the site to water and vind
erosion. This raises the possibility of off-site ai«ration of
contaainants through the air. In addition, the potential for subsurfaoe
transport of volatile gas vapors fron the waste landfills should be
explored*
Surface Wft»/g«dinent Tranenort/
Sediment transport of 2,3,7,8-TCSO and other haxardoua substances froa the
site to Rocky Branoh, Bayou Heto, and the sewage treataent plant has been
observed. The Rooky Branoh and the Bayou Heto downstreaa of the Tertao
•ite flow adjacent to several resideotial subdivisions, individual boaes,
agrloulturBl landa, industrial and oomercial areas, and recreational
areaa such as Dupree Park.
Rocky Branch!In the Rocky Branch channel end floodplain, "dioxin" levela in tne 198^
eediaent aaaples ranged froa the detection liait (i.e., varies froa 0.02
to 0.70 ppb) to 7.58 ppb. The levels appear to deorease with distanoe
fvos the Vertae plant site to O.T1* ppb (questionable peeult) just above
If?
?&<• 6 - Hr. Carl Klekaa ^00
leg of Hooky Branch near the Vest Lane dead end (3,01 ppb, N026C) and near 9
the end of Hin«« Drive (7.58 ppb, if030C). These level* are of partioular
concern because of their proxialty to reaidenoes. Oeteotable "dioxin"
levels ranced froa 0*19 to 0.74 ppb for in'atreaa aedlaenta.
Whir ao 1984 •—plea ww oollaofcad froa th« eaat l«c of Kooky Branch.— *
•even locations vere aaapled in 1983 in the —At leg watershed. Three of
the aaaple locations (M-8, IT-12, & N•16) were below Vertao's/Eaat Ditoh~l
diacbarxe. The data reaulta indlaate the need for •AyifeiaM't ••mpi^c to
&J«ure that TCDO oonta^nation doea not exist la the realdentlal areaa
eaat and aouth of the Vertao plant.
Bayou Meto:Bayou Meto channel and floodplain aedia«at aaoplea in 1984 •howd
concentrations of "dioxin" ran«inx froa the detection llalt to 2.1 ppb.
The highest "dioxin" concentration* were found between the WVT? outfall
and a point about 2000 feet downatraan of the Highway l6l bridge. The
hixheefc "dioxia" level found in 1984 waa the eatlaated aaxiaun
concentration of |3.? ppb)(r047A) in a near-atrean. Bear-surface aediaent
saaple; thia waa found about 25 feet downatreaa of the WTP outfall ia
Bayou Meto and HO feet from the left bank* a water edge. The defotabia __
"dioxin" levela found in the 1984 in-atreaa aediaent aaaplea ranced
froa 0.10 to 0.39 Ppb in shallow •ediaenta •ad froa 0.10 to 1 . 1 0 ppb for
deeper •ediaenta*
Vaatewatar Treafent Plant (WTP) Syataa:
Sludge and •ediaent aaaplea in the WTF collection and treataent •ytea
revealed an average concentration of 21.5 ppb "dioxin" which included the
tnree higheat valuea (70.5, 1 1 9 * 4 , and >200 ppb). Saaplinx in 1984 of the
abandoned WWTP found[6.59 PP? "dioxin" in the aludge drying bedaandn2.46 ppb -diexin'' in the digeator. In the exiating WWTP faoilitiea,
1984 sludge saaplea in the/aeration lagoon were found to have oaxiaua
levels aa high aa~(37.9 ppb^ (3018A, invalid or questionable data)
?a«e 7 - Mr. Carl -Elalcia
and[l6.2 ppbl(S019*)« 31udc« •aapleaiathe oxidation ponds were found to
contain aaxina "diexin" values ofj 8.37 Pgblin 1979, and) 3.6 ppb)ia 19M.
Aecordiac to the XZ, aanhole #106 (200 ft south of Tertu property la
the mat !•( of ioelcy Brftaob between Bradea & Alfca. Cove) was noted during
tb« 1984/1985 ••WT •aBpllac invtigatioa (Table 4-<» Tol. ZZ) to
ovrflow. Th» RZ &l»o duoribod •«nhol«« «1198i »1202, f1206, aad f301 to
overflow. Th« oTTflov potential for othT unholM ia th« r««idantial
ar«a« iaaediafly •outh aod •ut of tha 7«rtaa •ite durlac a«4or •toru.
•bould be d6«orl6«d« Tn» iat«ro«ptbr vhiob •errw tb« r««id«ufci&l
•ubdiYiaion iBB«diat«ly •outh of 7ert»c w fouad to ooatain th« t6r««
hlfheat *dioxin" oooo«ntr«tlona («•• abov) ia a«vr •ludf/aedlaeata.
Upicultuni U»«« Ootnrtreaa:
Efforta h»v notbewde to identify •xiatiag or gon«d acrioultural
tr«aa along Bayou Mfto downatr^aa of the WWTP or Bocky Branoh to a point
up«tr»aa of South«*atom Avenue that nay hay bwn aff»ot«d by floodific
and eontaninafd ••diaanta. Of these acrioultural •r«—t f««dlot and
grazing ftreaa ia the floodplala •r« th« aost iaportaat •iace 2,3,T,8-TCSfi
accufflul&to in the tiaauea of crfttioc o«ttl« and rooting swine. Cattle
grazinc areaa and other agricultural aotiTitiea were ob»Tred during the
•ita inspection. Saotf of tneae area* aoould be •aBpled. Note that levels
of 2,3,7,8-TCDD in •oila froa 0.0062 to 0.079 ppb have been projected by
Siabrouch et »1.4 to produce maxiaua allowable residues of 2,3,7,8-TCDS
in foode (i.e., beef, pork, and «ille).
q»^m>n^ in the vicinity of three Bayou Meto aurftce water withdrawal
points aay be of public health concern for certain acrioultural uaea. We
note that site 25 (about 500 feet upstreea of Highway 67/167) withdraw
for waterfowl purposes, site 13 (near Ri«hway l6l) withdraws for 60-aores
of rioo, aod site n (about 0.3 ailes upstreaa of Southeastern Ave.)
withdraws for 280«ecres of rioe. While site 25 lies about 1000 feet
downstreaa of the sediaent seaplinf station containing the two highoet
P«C« 8 • Mr. Carl Hlokaa1>0C<1
•dioxin" vluaa (2«1 aad 3,5 ppb) found la tha Bayou Hato, tha Bayou Mata o
ohaaaal rdioant* aaxt to th« laxa at •it« 29 vara 006 found to oeatala
"dioxin*" TIM oollaotlen •ad aaalyaaa of a tw additional aadiaaat aad
bioloxlo aaapl— aay ba prudaate if ( 1 ) tha vatarftwl aay ba aoaauaad, or
(2) flooding aay tiara ooourrad aiaoa fcha laat a—pi Ing pariod, rha B&you
Mato aadiMata la tha Ttolaity of aita 13 appaar to baTa a hiatory of
axoaadlflg 1 ppb •dioxla«*
mamw piTWiT^
Ttia aoat lllcaly axpoaura pafcbwaya for looal raaidanta, City Baautifloatloa -
•aployaa, aad VWT? axployaaa to tha ooataalaaata of ooaoaro would ba by
diraot ooataofe with ooataalaatad aludcaa/aadlaanta/aoil aad lafialaiioa of
ooBtaainafc«d duat, Zf aaall ohildraa play ia ooataadaatad yarda or gardaa
aolla, la tha vaat lac of Xooky Braaeh juat aouth of tha Tartaa plant, op—
liTa ia tba 1—adiata araa, thay Bay ba aobjaat to axpoauraa threuea
diraot contact aad iacaation of ooata^natad aoil or dua6« Qthar probabia
axpoaura patbvaya iaoluda tba lacaatioa of food oropa cr«vB la
oontaalnatad aludxaa and aolla, incaatloa of looal fiah (aad poaaibly
othar looal vlldlifa), aad laKaatlon of fara aniaala tbat (raxa oa or ara
ooaflaad to laada oontaininc oontaainafcad aolla/aadlaaata« ~~~* *
BTIT.TH »ygera
For AT3DR*a diaouaaioa oa tha baalth affaota of 2,3i7,a-TCCD, 2»t=U;———
and 2,4,5-T, plaaaa pafar to our Haalth Aaaaaaaaat raport oa tha
JaokaoBTilla Landfill datad Ootobar 23, 1965.
Tba aaotioa of taa XI daallae with th« toxloolocio •ad oaralaacaia
affaota of TCOO axpoaora ia adaquata. Bowvr, tba •Huaan Iffaota*
aaatloa raoulraa aaTaral rTlxiooa, Firat of all, it ahould ba aot«d that
tha raproduotlYa data oollaot«d following th« Sav—o incident or* •till
baloi araluatad* Saooadly, tha aonoludinc atataaaata darirad fpoa tha
oaaa atudy of tha 55-yaar-old woaaa aaad to ba r axalaad. Tha
•Italnatioa half-Ufa for TCTC ia a variety of aaia&l •paoiaa raacaa
Paga 9 - Mr. Carl Bioxaa
froa 10 to 43 day. In addition, MoMulty reported the TCOO elisination
half-Ufa In fcb« fat of aonkaya vaa approxiaataly 365 day. For tha oaaa
la jluaatlon, 58 paroant of tha raoovarad TCTD vaa takaa froa adipoaa
tiaaua. It ia lapoaaibia, la tha abaaaoa of human data, to pradiet
wbathar twenty, aeveral, or BO balf-livea aay bava ooourrad ia tha seraa
aonth pariod. Tharafore, it ia inaccurate to daflaitiraly atata "...the
paopla iaoludad ia thia atudy aoouaulatad large aaounta of dioxla..."
Furtheraore, it IJ unaooaptabia to ooapara actual aaouata (ug, aaaa uaita)
of an abaorbed toxicant batvaen differing apaoiaa without BorBalizatioa to
factora auch aa body weight, aurfaoa araa, aatabolio rata, or life apaa.
If tha total amount of dioxin (60 uc) calculated for tha oaaa in queetioa,
ia noraalized to body vi ht (70 k<), the actual abaorbed
doae (0.57 ug/kg) ia not 1000 to 3000 tiaee higher than tba tolerable doae
calculated (LDjO" 0«6 ug/kg) uaing guinea pig acute toxicity data.
fffflM PTSgnSSTOIT
g^l.tlny •nrf ih^anad UtfTP.
Of apecial concern ia tha faot that the WVT?*a oxidation ponde would be
subject to inundation by floods equal to or greater than a 5-year flood
(p. 3-20. Vol. I; Table 4.1, Vol. II; Plates 4-1 i 4-2, Vol. HI}.
Beoauae a aaaa release fron the oxidation lagoona aa a result of Bajor
etora oould epread 2,3,7,8-TCTD-oontaBinated oateriala to u extenaive
area dovnatreaa, raaedial effort auat ba taken to reduce this potential
iapaot.
In inspecting the aite and the HZ exhibita (Plata Ho. 3-10, Vol. Ill) of
the "Old Sawaga Treatment plant," tha polioe ahooting range portraya
featurea that reraal tha poaaibia existence of aoae previous treata»nt
works that may have been covered after being; abandoned. Thia araa should
ba saapled if it was a part of the old treataent works.
Pace 10 - Mr. Carl Hiokaa
Rooky Branah/Bsvou MetOi
Multiple land uaee exist downatreaa of the 7ertao site and the existing
WTP. These include residential, induatrial, commercial, agricultural,
and unzoned areas, Claaaup levels for 2,3.7»8-TCTD In sediaents/soils in
dovnatr«aa land use areaa ahould depend upon the potential nuaan exposure
associated with theae land uses. The future developoent potential and
realisation of the undevalopad floodplain areas depend upon tao Flood
Daaa«« Prevention Ordinance dated September 15, 1977. 31ao« m»
floodplain ordinance doea perait ooutruotion of new atruotureg, olaanup
levela for currently undeveloped floodplain/floodvay land uaes anould
atill apply.
Exiatinff reaidenoeB alonf both the eaat and west leg of Xooky Branch Bay
be subject to a variety of flood eventa. Reaidenoea on Alta Cov«, Alt*
Lane, Hill Road, and the enda of Braden, Ve«t Lane, Hinea Lana, and Hin—
Cove, and at the Willow Bend Apartaenta off Marshall Road lie within
the 100-year floodplain, the designated floodway, or the 2-year or 5-year
floodplain. Many of the reeidential yarda incorporate the Rooky Branch
creek banks as part of the yard and lack any physical barrier between the
yard and the creek. Toya, play areas, and huoan patba were observed in
and next to the Rooky Branch channel and banks.
Currently, health advisory levels for 2,3,7i8-TCTD in fish have been
developed only for the Great Lake*. The AT3DX b&a previoualy reni—MileiT -
that FDA deteraine whether the Oreat Lakes health advisory for
2.3,7,8-TCTD in fish should be revised for the Jacksonville area* The
Juatifloation for a olaanup level for 2,3J,a-TCT>D in waterway •ediaenta,
and/or soils subject to eroaion, should depend upon the potential for
huaan exposure. If the existinc fish ban for the Jaokaonville area is
ineffective in preventiaf huaan exposure froa the affected food-chain,
additional reaedial efforts would be required. If soil aaaplin* of
aericultural land uaee alonf the Bayou Meto cbannel and floodway
downstream and subsequent biological sampling reveal unacceptable exposure
?•€• 1 1 • Hr. Carl Bicxaa
to tarn aniaala. additional reaedial aaaauraa would ba require.
The AT30X offara tha followiac reoomandationa to aafaxuard publio haclte
froa tha oontaaination of off-alta araaa and to better aaaaaa the public
health hazard aaaoaiatad with thia eontaalnation. Th— r««om«ndatioaa
ar« Bad* aaauaiac tba tara, •dioxia," that la uaad la tha RZ la aaaat to
ba aquiyalant to 2,3,7,8-TCTD. Thia ia atatad in tha BI (p. 1 - 1 , vol. Z).
1. Specify what dioxia iaoaara vere analyxad for ia tha RZ "dioxia* data*
2. Obtain total aad laoaar specific data for detaraiaial tha 2,3,7,8-TCTD
aquivalaata ia off-aita aoil/aadlaaat/aludfe aaaplaa*
3. Raatpiot caaaral public aecaaa, iaoludiac tha Jaakaoarilla Dapartaaat
of Baaufcifloatioa eaployaaa, to tha abaadoaad WT? faeilitiaa (i.a«,
aludga dryinx bada, adjacent aurfaca aoila, dUaator, tricleliac
filter(a), olarifiera, ••va«a intarcaptora, puap houaa, and poaaibia
other oontaadaatad faoilitiaa), tha axlatia« VWT? faoilltlaa
(diatribution/bypaaa pipalinaa and boxes, aaration lagoon, oxidation
la«oona), and adjaoant aoila at tha axiatin^ wr?.
4. Devalop a baalth and •lta safety plan for workers in aooordanoa vita
OSHA atandarda. Outline tha aotlTifciea aaaoolatad with ooBtaainatad
areaa in thia plan and require indiTiduala who eagaxe in thoaa
aotivitiaa to wear personal protaotiva saar/olothin«; in aooordanoa
with OSHA atandarda and HZOSH xuidalinaa.
5. Xaatriot all xoneral publio aooaaa to both tha ohannal aad tha
floodway of tha waat lac of Rooky Branch froa tha Vertae property Una
to Waat Main Road in tha raaidaatial area aouth of Yartao until
^p-fco-date aoil and sediment aaaplinc data ara Bada arallabla.
Par 12 - Mr. Carl Hiokaa
6« Inaure that ai«ration of oonfcaainanta via aurfaoe ruaoff 00 the 7ertae
•if to orf-alte area*, particularly Rooky Branch, ia no loacer
ooourrinf*
7. Inaure the adequacy of exiatiac control aeaaurea on the Tertao aite 60
avoid uaaooeptable releaaea, apilla, or diaoharfea of 2»3,7,8-TCDD and
other oontniaaaf of OOOOTC to the wry. Vh«r« •xistlac •M«ur«aar« defroiBcd ln»ffaotlv, iapleoent additional oa-aito r—dial
•«a«ur«a«
8. Prevent exiatinc pretreataeot •uapa on the Tertao aite froa bypaaain^
aifce oontaBinanta to Rooky Branob* Hooi&or diaobarcea froa 7«rtao
aita pariodioally.
9. Sample and analyze aediaenta for 2,3.7,8-TCTD and other ooofcaainanta
of concern on the Vertac aite in the Rocky Branch, fiaat Ditoh. South
Ditoh, the Central Oitoh, and other draiaace ditohea.
10. laveatigate the need for additional reaediation of certain on-aita
area* (!.••• portioaa of Rocky Branch and drainace ditohea that have
not reoeived any previous reaediatioa, or drainafe ditohea that appear
to bypaaa the pretreataent •yalea) before iapleaentiac off-aita
reBcdiatioa of oontaainated channel aediaenta or floodplain aoila
dowaatreaK.
1 1 . Requeat local authoritiea to prohibit reaideotial land uaea vithia the
Verfcao cite bouadary (Plate 5-2, T.ZZZ). Xequ—6 that aotAoa be tatem
to per«16 QO one to live on ttr aite* Zoolude aayoaa oiureatlyreaidinc on the Tertao aite in the State'a ezpoaure atody.
12. Saaple the aurfaoe soila in the iaaediate vioinity of the aobile boae
found on'aite and ita interior duata for 2,3,7,8-TCTO and ether
oontaainanta of concern. Zaaure that the aobile hoae reaideaee on the
PU« 13 - Mr. Carl Hiekaa
aite ia properly cleaned if it la found to be contaainated ud ooved
off-tit*.
13. Perfora aaaplioc and aaalyalc of aurfaoa aoila around —ahelea that
are down«radleat of the Tertao •it«, have a hlftory of overflow, or
bar* the potential to ovrflow.
14. Inv8ti«ate the pofntial for vaatevatar orTflov ia aay buildio^
floor draias that aay be eooaooted to a 2.3.7.8-TCDD-oontaninafd WVTP
intaroeptor bavinc a hiatory of •ureharxa*
15. Prevent the continued degradation of Bayou Meto and Rooky Branch by
the transport of oontaaiaanta of concern froa both oa-aifce and
off-aite aouroea of ooataaiaatioa*
16. FerforB detailed (fine grid) saaplio^ and analyaia of channel
aedioenta and floodplain soils for 2,3,7,8-TCDD and other oootaaiaaata
of concern in and alooc the veat leg and eaat lee of Rooky Branch
between the Vertao property line and the confluence point of both
Rooky Branch legs.
17. perfora fine {rid aaaplinc and analyaia of channel aediaenta and
floodplain aoila for 2,3,7,8-TCDD and poaaibly other ooataoinanta of
ooncern in depoaitional areaa of Rooky Branch, upatreaa of ita
confluence with Bayou Meto, and Bayou Meto betwn 6h« WWTP outfall
aad 2000 feet downatreaa of the Bifhvay l6l bridge. Conduct this
aaapling or additional aaaplin^ after reaediation of the upatreaa
areaa.
18. Perfora fine <rld aaaplinc and analyaea of aoila/aediaenta for
2,3,7,8-TCDD in the Bayou Meto floodplain adjaoent to and ia the
Woodhaven Mobile HOBO Park near Highway 1 6 1 .
Pftf itt - Mr. Carl Hiokaa
19* Perfora •upllAg and analyses of floodplain soils/sediaeots for
2,3»7,8-TCSD and other oontaainanta of concern la any paaturea,
feedlots, or faras upatreaa of the Southeastern avenue bride* ia the
Bayou Meto floodplain. Conduct •••pllac to a d«ptb xrutT tou that
whiot would b« di«turb«d by local fara •quip—Bt*
20. P«rfora aoaitorinc and analyra of •urfao* vafra for eoataalaanta of
concern and other priority pollutaaf in Rooky Branch and ia Bayou
Hafco adjacent to r«aid«ntial ar«aa. D«aignat»d ua«a and applicable
wafr quality atandarda •hould be disclosed for the affected wafcervaya
and compared with the Bonitorinx data,
21. Consider the following cuidanoe criteria for dioxin reoediation:
a. MiH.iftlp»l Va«tewater CallaBtiaB 9»»tm
(1) Prevent human exposure to aludces, Naatea, and aediaenta
oontaininx 2,3i7i8-TCTD and other oontaninants of concern in the
affected sanitary sewer and/or storaaewer collection syatea (abandoned
and exiatine).
(2) Prevent the above contaainanta froa oontaainatinc the future
aewace treataent plant and any new interoeptora.
b. Ahandanad WTP faallitiM
(1 ) Prevent expoaure of the general publio to oontaainated sludges,
wastes, soils, and eediaenta in the abandoned sewage treafcaent
faoilitiea.
(2) Prevent those oontaainated materials froa contaainating the future
sewage treataent plant and collection syatea via any subsurface sewer
connections or surface runoff.
Pace 15 - Kr. Curl .Hiekaa
(3) Consider requiring surface •oils in and around the abaadoatd
sewage trMtaeot faoUifciea to •••ft aa action level of not aor*
than 5-7 ppb 2,3,7,8-TCM «ffr resediation. CThi» la justified
because of the infrequent contact with aurfaoe •oil* by the general
public i and bwuae th« prwnt land w pr«otlo«« la the vicinity of
th« abftndoa«d VWT? do not ftppur to b« any Bor« iafn«iv than tb«
oeaaToi&l ar»M of the Zronbouad Oictriot a—r Niraric, lev J«r««y,
where EPA Region n ofcibliahed a •lail«r aotion leyelS.]
(4) Inpose the follovia^ oonditiona oa the aboTe 5-7 ppb action level:
•The uaea aad activitiea of the aite ouafc not beooaa
aaaooiated with the production, preparation, nandlinc,
consumption, or atorage of food or other oonauaabia iteo«,
and food packaging uteriala*
•Site aoila Buat be protected froa eroaion that would uaooTer
or transport 2,3i7»B-TCDD oauaing unacceptable huaan exposure
at a future date (refer to aeotion on EXPOSURE PATHWAIS for
poasible ezpoaure pathway).
(5) Reevaluate the applicability of the 5-7 ppb action level If
present land uae ia changed aad 2,3»7,8-TCDD ia left on the aite in
surface or subsurface aoili at levels greater than 1 ppb.
o. B*<«».I wrv y>fliiifcv
(1 ) prevent «xpo«ur« of the general public to ooDtaaiaated sludges,
wastes, sediaenfca, aad aeila.
(2) Prevent effluent discharges or surcharge releases of
2,3,7,8-TCSD-eontaninated materials and other eontaainanta of concern
ia the treatment •ytem to Bayou Heto and aake every poaaible effort
to achieve desired vastewater treataent in the interia until the
• iture WVT? is on-line in July 1987.
10Pu« 16 - Mr. Carl Hloku ^1
a^o
(3) Ifduo* th» pofotiAl for a aajor r«l«u« of °
2i3>7»8-TCBD-oonttala»t»d aat«rial« ud othor oontaolaant* of oona«ra
froa the oxiditioo luoou due to • aaJor flood er«at*
(9) Prwnt th« ooataalaat«d ut«rial« froa ooatulnfttlac tb« future
WT? •ad oollftotlea •yte—»
(5) Prwot tht •lud«u, ««dlanf, vu6e«, ud •oil* oontalala^
2t3f7*8-TCDO ud other ooataaiaaBt* of QOBOTB la tho 6r«atuBt •yt—
ud •djao«at •oils froa Bixratiac to ud ooatuiMtlBc •ddltioaal
off-«it« •r«m*
(6} CoafidT u«lac •a aotlon IT«I !••• fthaa 1 ppb 2»3»T»t-TCBS to
pr«T«n6 uaaoo«pt«bl« huoaa •xp<««ur« la tb« futurw for tbo—. luda la
ud vt of tto oxidation l«eoou that TO •oa«d ro«id«atlal, or
x^auutlBC lookl authorltif to inT««tl«&fc« tto fMiblLity of
r«xoalac luda ooatuln&tod with 2,3.7(t-TCOO to & leu •u .tiro lud
ua««
(7) ZBplwnfc r«—di«l a«aaur«« to •llaiaaf futuro r«l«u—
of 2,3,7,8-TCDD froa th« •it« ud avoid bioeeovulfttloa la th«
foodohAia, partloularly food fiah, ud prT«at adTorr laputc upon
other ••a«16ir« lud u««« dovutrw*
(8) ror ar«u OB fth« •xlatlnc WT? •lt« vtilah •r* «on«d for
•uufuturinc u ^ vhloh would b« protootod froa oroiloa by •urfuo
ruaoff or potutlal flood T»Bt», ooaKLdT UJUC t6« utioa IT«I ofao« aor« etiaa S-T PPb 2,3»T.8-TCBS «±teh «&• ooadltlaa* d-1 •nw«<l •b«v
ufldT 21«6.(3), («)»• (5).
d. ^pi a^^^ •Hd aaypM w>^ ffh.»n»l* «^ yioadnl.iM
(1) Insure that iJtln« r««ld«atlal yard* ooataia lT«la < thu 1 ppb
2,3»7»fl-TOm ia •urfu« •oil* ud —diaiif to •ialxif uauomtui*
bu—a •xpomuf*
0-r-|
?•<• 17 • Mr. Carl Hiok— ^00
C2) Xaoocaize that'"adcquaf olaaaup of realdaatlal •r«u, froa ft
public b««lth parapaatira, r quir a that the ooao«ntr&«loa of TCDO
left ia aurfaoe •oil b« !••• thaa on« ppb."5 [lota that tlBbreu<h •t
al,11 iad Dr. Varaen Houk 3(5 of CBC atatad ftbat IT«I« at or abov
1 ppb 2,3»T»8-TCSD la r«ald«Btial aolla oaaaot b« ooaaldtr aafa aad
•.••ooutituto aa uaaoo«ptabl« riak to hsaaa teal6h««]
(3) Por ourreafcly uad«r«lop«d laada aoaad for rwldaatial laad ua«,
ooaaidT ualac aa aotloa XT«I laaa thaa 1 ppb 2,3,T»<-TOm to pr«r«at
uaaoooptablo buaaa ipeaur* la tha fbtara, or x^quaatlac looal
authorltiaa to iaT«ati«at« the feasibility of rwaooiAc ooata^aatod
laada to a laaa ••aaitiTa laad ua««
(4) For floodplala ar«aa alone taa affaotad oaaaaal aad floodvara
vbioh ar« ua«d or xoaad for laduatrlal or opa—rotal uaaa,aad vhioa
would ba prot«ot«d froa •roaioa by aurfaoa ruaoff or potaatlal flood
•T«nta, ooaaldar uaiac aa aotloa I«T«I of not •ora thaa 5-7 ppb
2,3,7,8-TCDD with tha condition* diaouaaad abora uadar 21.b.(3),
(4).* (5).
(5) For a«rieul6ural ar«u in tha affaotad floodplalaa, aaka
•Ite-apeoifio r«qu««t» for a health aaaaaa««nt vbara Justified by
additional •oil •aapliac and aoil l«T«la of 2,3,T»8-TCDS •ad othar
ooat&ainant* of OOBOTB, or by biological data,
(6) To ainlAiz* tbi biououBul&fcloa potantial of 2,3,7,8-TCTD ia :lraouatio foodahain, ooaaldar aohlarlac aa iat«rla aotioa IT«I of l«aa
thaa 1 ppb 2,3,T»<-TCDD in ohaaaal aadl—nta aad floodplala aolla
•ubjaot to Toaion aad traaaport prooaaaaa* [Thia r«oo—adatioa ia
baaed on •xiatiac a—plinc data that r«T«ala that (a) all •dibia flah
•aaplw (136 ppt to 704 ppt 2.3,7,8-TCDD) oollaofd ia 1984 dovn«tr«te
of th« 7«rtaa •it« •ad tha WTP outfall to a point (BM3) 3 1/2 Bllaa
downatr*— oa Bayou K«to fro« ita oonfluanoa with Xoolcy Branch
JD»Pf 18 - Mr. Carl Ride— ^
00
•xoe«dad fDA'i Oraat Lakaa baalth adriaory (2; ppt) for 2,3,7,8-TC30 0
la fish, aad (b) in«atr«aa, aaar^aurfaoa aadlaaata oollaotod la 1994
wara •qual to or laaa thaa 0.39 PPb 2,3,7,8-TCDD IB th« Bayou Kftto
froa a point 200 f»<t upatrua of tha Hictefy 161 bride (« polat far
apatreaa of BM3)J« Coaduot futuro •valuatioaa of Bairou Mato •dibia
flah tiaaua portlou la aooordaBoa with n)A*a yrooadura* to aaalat
approprlata fltata authoritlaa datandaa tho aooaaaltr for •aiatalolnctha praaaat flah baa.
22. D«T«lop •ad ixpl—ot apaolal Toalon ooatrol orltaria aad a
oontl««aoy plaa for rwMdial oparatlooa to avoid 107 fUrtIrr traaaportof ooataalaaata dovaatfaa,
22. larlao tho Inuw-a affaota aootloa of ttea IZ to roflaot tha gimnta
•ado uadar BSALTB VTW9 aboro.
23* To obtala Ififorxation oa tba poaalbia diapoaltlon of prrfloualy
drodcod aadlaaataf ooataot tha 9«fl« Anay Corpa of Kaela—ra for
Ififorsatloa oa aoy p«raita for •alataBaaoa of ohaaaala oaar bridcaa
and ooaatruotloa of saw roada that •ay hara ba«a parfor—d la Kooky
Braaoh aad Bayou Mato.
naaao rafar to Attaohaaat 3.
Va appraolata tha opportunity to prorida raoo—aBdatloaa oa tala off-alta
rwadlatloa* Va thank you aad M»««r». Razroat, Xl«ht, ui<l Satardal for
thair aaalataaoa la our lupaotloa of tha aita*
^^ /a^^
Jaffray I. Lyfearcw, M.D.
Attaohaaata
ATTACHMENT 1: gy"? Tysi»?e?TC!t /„i ' w".
y(G^
IttnTaTY 0
March 5, 1986; §
1. Visitad Mr* Diolc Morris, oanagar of the City of Jaekaonvill*
Wastewater Utility, for general inforaatiea on bow the wastawater
collection aad tmtaaot syatea is affaotad by tha Vartso Plant.
Visited th« •xiatiac «ut«wafr treatsant plaat (WTP) vhieb raeai as
vaataa froB the TTtao Plafit. Ob—rvd tM« abandoned portion of ttw
old WVTP (olarifiars, trioklinc filtan, di aator, and aludf drylac
bada), aa vail aa those WWTP faoilitiaa (aerator, oxidation lifoona)
eurrantly ba u«ad.
2. flaw ovar tna Vartao Plant, adjaoant raaidantial araaa, downatreaa
floodplain areaa of Rooky Branch and Bayou Mato, and tha UVT?*
3. Drova on tha Vartac Plant aita to aaa drainace pathwaya and bow
affective past raaedial aaaauraa have been in containing on'aita
vastaa*
March 6, 1996i
1. Orova off the eita to aae potentially affected residential areas,
recreation areaa, and drainage pathways and their asaoeiation with
adjacent land uaea.
2. Visited Mr. Duana Reel, City EnEineer, for information on current and
projected land use zoning in areas around tha Vertao Plant and
downstream in the floodplain. Zoning maps and flood naps ware
obtained.
PpohlMg QhaarYad
1. Aooording to tfto City Engineer, tha WTP ia in violation of ita
discharga penult affluent liaitations but tha City has indioatad that
they ara unable to do anything about it baoauae of the dioxin
contamination in the WWTP ayataa. The oxidation lagoona are nearly
ATTACTKSSTS 1 Cqn't. -w9^<59i
full and have inadequate retention tiae left. The City is wilting for 0
SPA to take action cm cleaning up the existing WWTP syatao and ponds. °
The connection of the new Interceptor to the future WWT? (scheduled
for conpletlon In July 1987) vlll depend upon the approved oleaaup of
the WWT? interceptor ay•tea.
2. Poaaible evidence of air pollution exl«t around the ezlstlfig WTP
•orator. The City Biglneer pointed out nuaeroua dead trees on the
northwest aide of the aeration lagoon, and suggested that air\
pollution fror the aeration lagoon oay be reepoirible.
3. The publio ha* exeeea to the abandoned WWT? areas whion are
oontaainated* Both potential health and aafety hazards exl»t» The
City la uainc the oontaainated aludge dryinc bedo for {rowing (arden
vegetablea (i.e., tomtoea, cabbage, etc.) and other plaata. photoa
were taken. Levela of 2,3,7,8-TCTD aa high aa 7 PPb have been found
in the aludge drying beda. A potential health hazard eziata beoauae
of buaan contact, poaaible transport of contaminants to the boae —
eavironaent, aad iogeation of poaaible contaalnanta in and on
vegetableo. No record exists of past people who have reaoved aludge
for boae garden use.
4. The oxidation lagoons could be inundated by a 3-yw flood eveat. The
lagoons contain aany oontaoinanta including 2,3,7(S-TCDD.
5. Ho aaapliag has been done after oa-sita reaedial work in the upper
portions of Rooky Branon for either the eaat leg or veat leg.
6. Noxious odors were apparent both on the Vertao aite aad in downwind
areas in reaidential areas south and aaat of the Vertao Plant sits*
It could not be determined if fcheae odora were related to current
production activitias or wastes disposed or stored oo-eite.
7. Drainage (East Ditch, South Ditch, & Central Ditch) fron the Vertae
Plant does not receive proper pretreament because of susp bypass
ATTACHMENTS 1 Con't.
features and inadequate oapaoity during •tora periods. Photo* wr«
taken*
8. Portions of Rooky Bnaea exist on t6« Tertao •If taat were not
included la tha ea«eite r—dlal work.
9. Despite the newly inatalled trench drain, seeps were observed between
the new •lurry wall and Rocky Branch in the area of the on-aite burial
•ite. Aerial photoa were taken.
10. Evidence exists that children probably play in Rooky Branch
immediately downstreaa of the Vertac Plant property line. Toy and
numerous footpaths were found in and along Rooky Branch in the
subdivision ianedlately south of the Vertao Plant. Photos were taken.
1 1 . A aobile hoae residence was observed on the Vertao site (Plate 5-2,
Vol. Ill] about 800 to 1000 feet froa the highly contaninated
"T-wastes" (druna coatalninc 30 ppa 2,3,7,8-TCDD), and 1000 fat- -
froa 25,000 druBa containing "D-waates." The residenta of this aobile
hoae appear to bare access to the site by a locked baokgata. A dog
and toys were seen observed in the yard. Photoa were taken.
12. Sone residential yftrds ianediately downitrua of the Vertao Plantshare an intiaate aaaooiation with both the weat and eaat legs of
Rocky Branch.
13. Some Bayou Meto floodplaio areaa downstreaa of the Tertao Plant and
the WWTP are used for gracing, crop production (rice and soybeans),
and possibly other agrioultural purposes.
though a flood prevention ordinance exists, portions of the
. ... niain can atill be developed for residential purposes snd other
i-'WT ;F :::;1?{ .SVT.S FOL'S; lit C^-Sl'E fiREiiS, W.SCNVILLE, WAUSaS
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;it» er:3r ta tht ftl *r» lritt< Hut ts in*d«qmt» qmlity ea»tral.'fit 1933 oxiiitlan l»i;sn srti" •••'« t*t(n (r9« h<rd bottca »di«(flts.i^iult lociliops li» »ry "' v »" l"l'"" iiscsitlicn •ith residintiil *r»is.3<n not 3» «-if:fff BV Tibli 3-1 in Val. 1 1 »or th« M»t It); howr, 0.:7 MI feund it fit »*in I F.acily Irwcti.:':i;;i- -11 i;i»i ;i-E'-;ciIlr tnrsui-aut P.Ii hainv»r f. l-l,V.l itftfitHiK diBxin « 2,3,7,3-TSCS.'^'i::'r:-, :''f:'.'ir.- "••' a>i;i:*'.?» '.*'• '3t s* rttr'ffi !>.» to ".t sf the i.:l::ittl ;•:"; •—ItttriSl?.
ATTACHMENT 3i
WffVVVVfV^
I* U.S. Environaental Protection Agenoy, Rational Interia Priaary
Drinking Vatar Regulations, Appendix A Background Docuaent,
OA-570/9-76-003. 1976.
'2. Sax, H. Irving, Oangeroua Propartiea of loduatrlal Hafriala, flixtn
Edition. 1984.
3. Lattar datad July 8, 1984, froa Or. Vernoa Houk, CDC. ATSDK, to
Mr. Morria, U.S. BPA, Ragion 722.
4. Kinbrough, Senate 0., Falk, Henry, and Stehr, Paul of Center for
Environmental Health, COG, and Fries, George of Departaent of
Agriculture, Health Inplicationa of 2,3,7,8-TCDD Contamination of
Residential Soil, Journal of ToTieology and gnYironnental HMlth,
H(:<*7-93. W.
5. Letter dated July 9» 1981»» fron Dr. Vernon Houk, CDC, ATSDK, to
Mr. Dewling, Begional Adninatr&tor, U.S. EPA, Region 12.
6. Heaorandua dated October 26, 1984, froa Ha. Georgi Jones, Chief,
Superfund iBpleoent&tlon Group, CDC/ATSDR, to Mr. David P. Knorovski,
Public Health Advisor, EPA Region II.
APPENDIX C
DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service "*SB
eg?go-Agencv '01 Tox'c Substances"""
and Disease Registry •—r
Atlanta GA 30333 CT
June 11, 1990
Mr. Sam BackerChief, Superfund Enforcement Branch (6H-E)United States Environmental Protection AgencyRegion 61445 Ross Avenue, Suite 1200Dallas, Texas 75202-2733
Dear Mr. Backer:
I have received your letter of May 29, 1990 requesting the Agency forToxic Substances and Disease Registry (ATSDR) to approve, in terms ofpublic health protection, the remedial plans for the Vertac, JacksonvilleLandfill, and Rogers Road Landfill Superfund sites located inJacksonville, Arkansas.
On May 3 , 1990 a meeting was held in Atlanta to discuss, in depth, theproposed remediation at these Superfund sites. Present at the meetingwere members of your staff and representatives of the Centers for DiseaseControl and ATSDR. A brief synopsis of your proposed remedies follows:
VERTAC SITE
Sewer Lines and Manholes:
The 2 , 3 , 7 , 8 tetrachlorodibenzo-p-dioxin (TCOD) contaminated sediments fromthe active interceptor and manholes will be removed by hydraulic flushing,followed by remote TV camera inspection to assure that all sediments havebeen removed. Sediments will be dewatered and incinerated. A pipe linerwill be installed in the active interceptor to improve structuralstability and to avoid possible recontamination by inflow. The abandonedinterceptor will be filled with grout to immobilize any contaminatedsediments and to prevent flow into and out of the line.
Abandoned Trickling Filter Plant:
The accumulated water in the trickling filters and clarifiers will betreated in activated carbon columns prior to discharge, and the spentcarbon and filter spools will be incinerated. The digester sludge willalso be incinerated. All of the units in the trickling filter plant willbe demolished, and the debris covered with a foot of clean soil. Thesludge drying beds will also be covered with a foot of clean soil. Theabandoned trickling filter plant will continue to be fenced and accessrestricted.
Page 2 - Mr. Sam Becker
Active Vest Vastewacer Treatment Plant:
The aeration basin will be devatered, and the water treated with activatedcarbon prior to discharge. The dike* of the aeration basin will bedemolished, and the basin covered with a foot of clean soil. Theoxidation ponds will. most likely, be used for storage and release ofeffluent from the Vertac leachate collection and treatment system. Thevastewater treatment plant will continue to be fenced and accessrestricted.
Rocky Branch Creek and Bayou Meto Flood Plain:
In these flood plains, soil containing more than 1 ppb TCDD In undevelopedresidentlally zoned areas, vlll be excavated and hauled back to the Vertacsite for ultimate disposal.
Rocky Branch Creek and Bayou Meto Sediments:
The TCDD concentrations In the sediment are as high as 2.3 ppb In thecreek, and as high as 1.03 ppb In the Bayou. A fishing ban will remain Inplace.
JACKSONVILLE AND ROGERS ROAD LANDFILLS
All material with TCDD concentrations greater than 10 ppb will beexcavated for treatment and the dioxins vlll be destroyed to levels belov1 ppb. Residual contamination exceeding 1 ppb will be capped by a footor more of clean fill. The fence around these sites will be maintained bythe City and the deeds will Indicate that the sites are consideredunacceptable by EPA for residential use.
I believe that the above briefly but accurately summarizes your proposedremedies. The ATSDR in consultation vlth the Centers for Disease Controlbelieves that with the following clarifications the proposed cleanupstrategies for these Superfund sites will be protective of human health:
1 . Erosion controls are necessary to protect the additional soil used asclean cover.
2. Vith regard to the Rocky Creek and Bayou Meto sediments, the fishtissue concentrations muse be monitored for dioxin and the fishing banshould remain In effect until the fish are determined to be safe forunlimited human consumption.
0csSSl0
Page 3 - Mr. San Becker °
If you have any question* or require additional clarification please donot hesitate to contact me.
Sincerely yours,
Edwin Kent Gray -Chief, Eaergency Response
and Consultation BranchDivision of Health Assessment
and Consultation
APPENDIX D
Table C-lPRELIMINARY IDQmFICATION OF POTENTIAL ACTION-SPECIFIC ARARs
VERTAC OFF-SITE FS
Requirements Prerequisites Citation
Placement of a cap over waste(e.g., closing a landfill, orclosing a surface Impoundment
or waste pile as a landfill, orsimilar action) requires a
cover designed and constructed
to:
o Provide long-term rnlnlmlza-tlon of migration of liquidsthrough the capped area
o Function with minimum main-tenance
o Promote drainage and mini-mize erosion or abrasion of
the cover
Significant management (treat•ent, storage, or disposal) ofhazardous waste will Bake requirenents applicable; cappingwithout disturbance will notnake requirements applicable,but technical requirements arelikely to be relevant and appro-priate.
40 CFR 264.228 (a)(Surface Impound-ments)
40 CFR 264.2S8(b)(Haste Piles)40 CFR 264.310(a)
(Landfills)
o Accommodate settling andsubsidence so that thecover's Integrity Is main-tained, and
o Have a permeability lessthan or equal to the permea-bility of any bottom linersystem or natural sub-soilspresent.
Eliminate free liquids, sta-bilize wastes before capping(surface Impoundments).
"nde>
40 CFR 364.228 (a)
,!
_______Actions_________ ______Requirements_______ ______Prerequisites______ Citation
Capping (Continued) Restrict post-closure use of 40 CFR 264.117(c)property as necessary to pre-vent damage to the cover.
Prevent run-on and run-off from 40 CFR 264.228(b)damaging cover. 40 CFR 264.310(b)
Protect and maintain surveyed 40 CFR 264.310(b) --benchmarks used to locate wastecells (landfills, waste piles).
Clean Closure (Removal) General performance standard Disturbance of RCRA hazardous 40 CFR 264.111requires niniBization of need waste (listed or characterls-for further Baintenance and tic) and movement outside thecontrol; minimization or elimi- unit or area of contamination.nation of post-closure escapeof hazardous waste, hazardous Hay apply to surface Impound"constituents, leachate, contam- ment; contaminated soil, tn-inated runoff, or hazardous eluding soil from dredging orwaste decomposition products, soil disturbed In the course of
drilling, or excavation, andDisposal or deconlamination of returned to land. 40 CFR 264.111equipment, structures, andsoils.
Removal or decontarnination of Not applicable to undisturbed 40 CFR 264.228(a)(1)\ all waste residues, contami- material and
nated containment system corn- 40 CFR 264.258ponents (e.g., liners, dikes),contaminated subsoils, andstructures and equipment con- Disposal of RCRA hazardouslaminated with waste and leach- waste (listed or characteris-ate, and management of them as Lie) after disturbance andhazardous waste, movement outside the unit or
area of contamination*Meet health-based levels at 40 CFR 244.111unit.
action alternatives from ROD keyword Index. U U U W «W
____Actions________ _____Requirements______ Prerequlsitea______ Citation____Actions________ _____Requirements______ Prerequlsitea______ Citation
sure with Uaste in Place Eliminate free liquids by re- 40 CPR 264.228(a) (2)ipinq) moval or solidiflcation.
Stabllixation of remaining 40 CFR 264.228(a)(2)waste and waste residues to andsupport cover. 40 CFR 264.2 58 (b)
Installation of final cover to 40 CFR 264.310provide long-tent mininizationo( infiltration.
Post-closure care and ground- 40 CFR 264.310Mater monitoring.
Closure with Waste in Place Removal of Majority of contami- Proposed rule, not yet applicable 52 FR 8712(Hybrid Closure) nated materials. (March 19, 1987)
Application of cover and post- Proposed rule, not yet applicable 52 PR 8712closure monitoring based on (March 19, 1987)exposure pathway(a) of concern.
Consolidation Area free which Materials are Disposal by disturbance ot bai- See Closureremoved should be cleaned up. ardous waste (listed or charac-
teristic) and •oving It outsideunit or boundary of contaul-nated area.
Consolidation in storage piles/ See Containerstorage tanks will trigger Storage, Tankstorage requirements. Storage, Naste
Piles In thisExhibit.
Place>ent on or In land outside After November 8, 1968 40 CFR 268unit boundary or area of con- (Subpart D)lamination will trigger landdisposal requirements and re-
•ttlrt'"- 000230
- • • " • • I -- »--- 1>/W> <,„<„.,„.•,« <nnr>»
sure with Maste in Place Eliminate free liquids by re- 40 CFR 264.228(a)(2)ipinq) moval or solidiflcation.
Stabllixation of remaining 40 CFR 264.228(a)(2)waste and waste residues to andsupport cover. 40 CFR 264.2 58 (b)
Installation of final cover to 40 CFR 264.310provide long-ten minimizationo( infiltration.
Post-closure care and ground- 40 CFR 264.310water monitoring.
Closure with Waste in Place Removal of Majority of contami- Proposed rule, not yet applicable 52 FR 8712(Hybrid Closure) nated materials. (March 19, 1987)
Application of cover and post- Proposed rule, not yet applicable 52 PR 8712closure monitoring based on (March 19, 1987)exposure pathway(s) of concern.
Consolidation Area froi which materials are Disposal by disturbance ot bai- See Closureremoved should be cleaned up. ardous waste (listed or charac-
teristic) and moving It outsideunit or boundary of contaul-nated area.
Consolidation in storage piles/ See Containerstorage tanks will trigger Storage, Tankstorage requirements. Storage, Naste
Piles In thisExhibit.
Placenent on or In land outside After November 8, 1968 40 CFR 268unit boundary or area of con- (Subpart D)lamination will trigger landdisposal requirements and re-
•ttlrt'"- 000230
- • • " • • I -- »--- 1>/W> <,„<„.,„.•,« <nnr>»
_______Actions_________ ______Requirements_______ ______Prerequisites______ ___Citdtion__________Actions_________ ______Requirements_______ ______Prerequisites______ ___Citdtion___
Container Storage (Onslte) Containers of hazardous waste RCRA hazardous waste (listed orBust be: characteristic) held for a tem-
porary period before treatment,o Maintained in good condition disposal, or storage elsewhere, 40 CFR 264.171
(40 CFR 264.10) in a containero Compatible with hazardous (i.e., any portable device In 40 CFR 264.172
waste to be stored which a Material is stored,transported, disposed of, or
o Closed during storage handled). 40 CFR 264.173'(except to add or removewaste)
^
Inspect container storage areas 40 CFR 264.174weekly for deterioration.
Place containers on a sloped, 40 CFR 264.175crack-free base, and protectfrom contact with accumulatedliquid. Provide containmentsystem with a capacity of10 percent of the volume ofcontainers of free liquids.Remove spilled or leaked wastein a timely manner to preventoverflow of the containmentsystem.
/' Keep containers of ignitable or 40 CFR 264.176reactive waste at least 50 feetfrom the facility's propertyline.
Keep Incompatible materials 40 CFR 264.177separate. Separate incompatl-
• ble materials stored near eachI other by a dike or other bar-
rier.
;——————— 000231Action alternatives from ROD keyword index.
Container Storage (Onsite) Containers of hazardous waste RCRA hazardous waste (listed ormust be: characteristic) held for a te»-
porary period before treatment,o Maintained in good condition disposal, or storage elsewhere, 40 CPR 264.171
(40 CFR 264.10) in a containero Compatible with hazardous (I.e., any portable device In 40 CFR 264.172
waste to be stored which a material Is stored,transported, disposed of, or
o Closed during storage handled). 40 CFR 264.173'(except to add or removewaste)
^
Inspect container storage areas 40 CFR 264.174weekly for deterioration.
Place containers on a sloped, 40 CFR 264.175crack-free base, and protectfrom contact with accumulatedliquid. Provide containmentsystem with a capacity of10 percent of the volume ofcontainers of free liquids.Remove spilled or leaked wastein a timely manner to preventoverflow of the containmentsystem.
/' Keep containers of Ignitable or 40 CFR 264.176reactive waste at least 50 feetfrom the facility's propertyline.
Keep Incompatible materials 40 CFR 264.177separate. Separate incompatl-
• ble materials stored near eachI other by a dike or other bar-
rier.
;——————— 000231Action alternatives from ROD keyword index.
..ctions Requirements Prerequisites Citation
container Storage (Onsile)(Continued)
Containment (Construction ofNew Landfill Onslte) (SeeClosure with Haste In Place.)
At closure, remove all haz-ardous waste and residues fromthe containment system, anddecontaminate or remove allcontainers, liners.
Install two liners or more, atop liner that prevents wastemigration into the liner, and abottom liner that preventswaste migration through theliner.
Install leachate collectionsystems above and between theliners.
Construct run-on and run-offcontrol systems capable ofhandling the peak discharge ofa 25-year storm.
40 CFR 264.178
RCRA hazardous waste (listed orcharacteristic) currently beingplaced in a landfill.
40 CFR 264.301
40 CFR 264.301
40 CFR 264.301
Control wind dispersal of par-ticulates.
40 CFR 264.301
Inspect liners and covers dur-ing and after installation.
Provide groundwater monitoringadequate to detect releasesfrom the unit.Inspect facility weekly andafter stoms to detect Malfunc-tion of control systems or thepresence of liquids In theleachate collection and leakdetection systems.
40 CFR 264.303
40 CFR 264Subpart F
40 CFR 264.303
Actions Requirements Prerequisites Cildlion
Containment (Construction ofNew Landfill Onslte) (SeeClosure wi th Waste In Place.)(Continued)
Maintain records of the exactlocation, dimensions, and con-tents of waste cells.
Close each cell with a finalcover after the last waste hasbeen received.
40 CFR 264.304
40 CFR 264.310
No bulk or non-containerizedliquid hazardous waste or haz-ardous waste containing freeliquids may be disposed of inlandfills.
40 CFR 264.314
Containers holding free liquidsmay not be placed in a landfillunless the liquid Is mixed wi than absorbent or solidified.
40 Cm 264.314
Treatment by Best DemonstratedAvailable Technology beforeplacement.
Placement, after November 6 ,1988, of RCRA hazardous wastesubject to land disposal re-strictions.
40 CFR 268(Subpart 0)
Containment (Construction ofNew Surface Impoundment Onslte)(See Closure wi th Waste InPlace and Clean Closuie.)
Use two liners, a top linerthat prevents waste migrationInto the liner and a bottomliner that prevents wastemigration through the linerthroughout the post-closureperiod.
Design liners to preventfailure due to pressuregradients, contact with thewaste, climatic conditions, andthe stress of Installation anddally operations
RCRA hazardous waste (listed orcharacteristic) currently beingplaced In a surfaceImpoundment.
40 CFR 264.220
40 CFR 264.221
Action alternatives from ROD keyword index.
( - • • ^ \ , I
a_____Actions_________ ______Requirements_______ ______Prerequisites______ ___Citation___
^•4
Containment (Construction of Provide leachate collection 40 CFR 264.221New Surface Impoundment Onsite) system between the two liners.(See Closure with Haste inPlace and Clean Closure.) Use leak detection system that 40 CFR 264.221(Continued) w i l l detect leaks at the
earliest possible time.
Provide groundwater monitoring 40 CFR 264adequate to detect releases Subpart Ffrom the unit.
Dike Stabilization Design and operate facility to Existing surface impoundments 40 CFR 264.221prevent overtopping due to containing hazardous waste oroverfilling; wind and wave creation of new surfaceaction; rainfall; run-on; mal- Impoundments.functions of level controllers,alarms, and other equipment;and human error.
Construct dikes with sufficient 40 CFR 264.221strength to prevent massivefailure.
Inspect liners and cover 40 CFR 264.226systems during and afterconstruction.
Inspect weekly for proper 40 CFR 264.226operation and integrity of thecontainment devices.
Provide groundwater monitoring 40 CFR 264* adequate to detect releases Subpart P
from the unit.
Remove surface Impoundment from 40 CFR 264.227operation If the dike leaks or ,,there Is a sudden drop In 000^34liquid level.
a t________Actions_________ ______Requirements_______ ______Prerequisites______ ___Citation___
a t________Actions_________ ______Requirements_______ ______Prerequisites______ ___Citation___
Dike Stabilization (Continued) At closure, remove or 40 CVR 264.228decontaminate all wasteresidues and contaminatedmaterials. Otherwise, freeliquids must be removed, theremaining wastes stabilized,and the facility closed in thesame manner as a landfill. "
Manage Ignltable or reactive 40 CFR 264.227waste so that It Is protectedfrom Materials or conditionsthat May cause It to Ignite orreact.
Direct discharge of treatnent Applicable federal Mater qual- Surface discharge of treated SO FR 30784system effluent Ity criteria for the protection effluent. (July 29, 1985)
of aquatic life Must be con-plied vlth when environmentalfactors are being considered.
Applicable federally approved Surface discharge of treated 40 CFR 122.44 andstate water quality standards effluent, state regulations•ust be complied with. These approved understandards way be In addition to 40 CFH 131or more stringent than otherfederal standards under theCMA.
The discharge •ust be consis-tent with the requirements of aHater Quality Management planapproved by EPA under Sec-tion 208(b) of the Clean MaterAct.
Action alternatives from ROD keyword Index. /» ft rt t:» 0 (*uUU«v«.l
rvpiK/mi-n
Dike Stabilization (Continued) At closure, remove or 40 CVR 264.228decontaminate all wasteresidues and contaminatedmaterials. Otherwise, freeliquids must be removed, theremaining wastes stabilized,and the facility closed In thesame manner as a landfill. "
Manage Ignltable or reactive 40 CFR 264.227waste so that It Is protectedfrom materials or conditionsthat may cause It to Ignite orreact.
Direct discharge of treatnent Applicable federal water qual- Surface discharge of treated SO FR 30784system effluent Ity criteria for the protection effluent. (July 29, 1985)
of aquatic life must be com-piled with when environmentalfactors are being considered.
Applicable federally approved Surface discharge of treated 40 CFR 122.44 andstate water quality standards effluent, state regulations•ust be complied with. These approved understandards may be In addition to 40 CFH 131or more stringent than otherfederal standards under theCMA.
The discharge must be consis-tent with the requirements of aMater Quality Management planapproved by EPA under Sec-tion 208(b) of the Clean MaterAct.
Action alternatives from ROD keyword index. /» ft rt t:» 0 (*uUU«v«.l
rvpiK/mi-n
)
| — ' / \ I
)
I — ' / \ I
'»^ _______Actions_________ ______Requirements_______ ______Prerequisites______ ___Citation___
Direct discharge of treatment Use of best available tech- Surface discharge of treated 40 CFR 122.44(a)system eff luent (Continued) nology (BAT) economically effluent
achievable Is required to con-trol toxic and nonconventlonalpollutants. Use of best con-ventional pollutant controltechnology (BCT) Is required tocontrol conventional pollu-tants. Technology-based limi-tations nay be determined on acase-by-case basis.
The discharge must conform to Surface water discharge affect- 40 CFR 122.44(d)(4»applicable water quality ing waters outside Coloradorequirements when the dischargeaffects a state other than thecertifying state.
Discharge limitations must be Surface discharge of treated 40 CFR 122.44(e)established for all toxic pol- effluentlutants that are or may be dis-charged at levels greater thanthose which can be achieved bytechnology-based standards.
Discharge must be monitored to Surface discharge of treated 40 CFR 122.44(1)assure compliance. Discharge effluentwi l l monitor:
o The mass of each pollutant
o The volume of effluent
o Frequency of discharge andother Measureients as
appropriate. 000236
Action alternatives from ROD keyword index.
'»
^ _______Actions_________ ______Requirements_______ ______Prerequisites______ ___Citation___
Direct discharge of treatment Use of best available tech- Surface discharge of treated 40 CPR 122.44(a)system eff luent (Continued) nology (BAT) economically effluent
achievable is required to con-trol toxic and nonconventlonalpollutants. Use of best con-ventional pollutant controltechnology (BCT) Is required tocontrol conventional pollu-tants. Technology-based limi-tations nay be determined on acase-by-case basis.
The discharge must conform to Surface water discharge affect- 40 CFR 122.44(d)(4»applicable water quality ing waters outside Coloradorequirements when the dischargeaffects a state other than thecertifying state.
Discharge limitations must be Surface discharge of treated 40 CFR 122.44(e)established for all toxic pol- effluentlutants that are or may be dis-charged at levels greater thanthose which can be achieved bytechnology-based standards.
Discharge must be monitored to Surface discharge of treated 40 CFR 122.44(1)assure compliance. Discharge effluentwi l l monitor:
o The mass of each pollutant
o The volume of effluent
o Frequency of discharge andother Measurements as
appropriate. 000236
Action alternatives from ROD keyword index.
______Actions_________ ______Requirements_______ ______Prerequisites______ Citation______Actions_________ ______Requirements_______ ______Prerequisites______ Citation
Direct discharge o( treatment Approved lest methods for wastesystem eff luent (Continued) constituents to be monitored
rust be followed. Detailedrequlrenents for analyticalprocedures and quality controlsare provided.
Permit application inforiRation 40 CFR 122.21must be subnitted Including adescription of activities,listing of environmentalpernlts, etc.
Monitor and report results as 40 CFR 122.44(1)required by permit (minimum ofat least annually)
Comply with additional permit 40 CFR 122.41(1)conditions such as:
o Duty to Bitlgate any adverseeffects of any discharge;and
o Proper operation and Main-tenance of treatmentsystems.
Develop and implement a Best Surface water discharge 40 CFR 125.100Management Practices (BMP) pro-gram and Incorporate In the
, NPOES peril t to prevent the re-lease of toxic constituents tosun ace waters.
The BMP program Bust; 40 CPU 125.104
— ' -- " - ^ - - - rit ML JL —^ *k «mA
'Action alternatives from ROD keyword Index. UUU5p^»
Direct discharge of treatment Approved lest methods for wastesystem eff luent (Continued) constituents to be monitored
rust be followed. Detailedrequlrenents for analyticalprocedures and quality controlsare provided.
PerMit application inforiRation 40 CFR 122.21must be submitted Including adescription of activities,listing of environmentalpermits, etc.
Monitor and report results as 40 CFR 122.44(1)required by perMit (MinlMUM ofat least annually)
Comply with additional permit 40 CFR 122.41(1)conditions such as:
o Duty to Bitlgate any adverseeffects of any discharge;and
o Proper operation and Main-tenance of treatmentsystems.
Develop and Implement a Best Surface water discharge 40 CFR 125.100Management Practices (BMP) pro-gram and Incorporate In the
, NPOES permit to prevent the re-lease of toxic constituents tosun ace waters.
The BMP program must; 40 CPU 125.104
— ' -- " - ^ - - - rit ML JL —^ *k «mA
'Action alternatives from ROD keyword Index. UUU5p^»
/
^""-- ' - I
/
^""-- ' - I
_____Actions_________ ______Requirements_______ ______Prerequisites______ ___Citation___
Direct discharge ot treatment o Establish specific proced-systeni eff luent (Continued) ures for the control of
toxic and hazardous pol-lutant spills.
o Include a prediction ofdirection, rate of f low, andtotal quantity of toxic pol-lutants where experience in-dicates a reasonable poten-tial for equipment failure.
o Assure proper management ofsolid and hazardous waste inaccordance with regulationspromulgated under RCRA
Sample preservation procedures. Surface water discharge 40 CFR 136.1-136.4container materials, andmaximum allowable holding timesare prescribed.
Discharge to POTM Pollutants that pass-through 40 CFR 403.5the POTH without treatnent, in-terfere with POTM operation, orcontaminate POTH sludge areprohibited.
Specific prohibitions precludethe discharge of pollutants toPOTHs that:
o Create a fire or explosionhazard in the POTW
o Are corrosive (pH<5.0)
________ 000238Action alternatives iron ROD keyword index.
' - ' •' "• * """ •< an t t-f «;»'W . . •OIIV» .... P
_____Actions_________ ______Requirements_______ ______Prerequisites______ ___Citation___
Direct discharge of treatment o Establish specific proced-system eff luent (Continued) ures for the control of
toxic and hazardous pol-lutant spills.
o Include a prediction ofdirection, rate of f low, andtotal quantity of toxic pol-lutants where experience in-dicates a reasonable poten-tial for equipment failure.
o Assure proper management ofsolid and hazardous waste inaccordance with regulationspromulgated under RCRA
Sample preservation procedures. Surface water discharge 40 CFR 136.1-136.4container materials, andmaximum allowable holding timesare prescribed.
Discharge to POTH Pollutants that pass-through 40 CFR 403.5the POTH without treatnent, in-terfere with POTM operation, orcontaminate POTW sludge areprohibited.
Specific prohibitions precludethe discharge of pollutants toPOTHs that:
o Create a fire or explosionhazard in the POTH
o Are corrosive (pH<5.0)
________ 000238Action alternatives iron ROD keyword index.
' - ' •' "• * """ •< an t t-f «S»'W . . •OIIV» .... P
i1Actions8________ ______Requirements_______ ______Prerequisites______ CitJtion
Discharge oi dredge and f i l l The four conditions that lust 40 CFR 230.10material to navigable waters be satisfied before dredge and 33 CFR 320-330
f i l l is an allowable alterna-tive ace:
o There must be no practicablealternative
o Discharge of dredged or fillmaterial must not cause a lviolation of State waterquality standards, violateany applicable toxic efflu-ent standards, jeopardize anendangered species, or in-jure a marine sanctuary
o No discharge shall be per-mitted that will cause orcontribute to significantdegradation of the water
o Appropriate steps to mini-mize adverse effects must betaken
Determine long- and short-termeffects on physical, chemical,and biological components ofthe aquatic ecosystem.
Dredging Removal of all contaminated Disposal by disturbance of See discussionssoil. haiardous waste and moving It under Clean
outside the unit or area of Closure, Consoli-contamlnation. datlon. Capping
Excavation Area from which materials are Disposal by disturbance of 40 CFH 2b4 DIs-excavated may require cleanup hazardous waste and noving It posal and Closureto levels established by outside the unit or ana of requirements
closure requirements contamination. f\ H fk 0 *> f^U U U » o <ff
a . , ,. . . ,., . . .
Actions8________ ______Requirements_______ ______Prerequisites______ CitJtion
Discharge of dredge and f i l l The four conditions that must 40 CFR 230.10material to navigable waters be satisfied before dredge and 33 CFR 320-330
f i l l is an allowable alterna-tive ace:
o There must be no practicablealternative
o Discharge of dredged or fillmaterial must not cause a lviolation of State waterquality standards, violateany applicable toxic efflu-ent standards, jeopardize anendangered species, or In-jure a marine sanctuary
o No discharge shall be per-mitted that will cause orcontribute to significantdegradation of the water
o Appropriate steps to mini-mize adverse effects must betaken
Determine long- and short-termeffects on physical, chemical,and biological components ofthe aquatic ecosystem.
Dredging Removal of all contaminated Disposal by disturbance of See discussionssoil. haiardous waste and moving It under Clean
outside the unit or area of Closure, Consoli-contamlnation. datlon. Capping
Excavation Area from which materials are Disposal by disturbance of 40 CFH 2b4 DIs-excavated may require cleanup hazardous waste and Moving It posal and Closureto levels established by outside the unit or ana of requirements
closure requirements contamination. f\ H fk 0 *> f^U U U » o w
a . , ,. . . ,., . . .
00
I I ' . . /• \ I0^
Actions________ _____Requirements______ ______Prerequisites______ Citation
Excavation (Continued) Movement of excavated materials Materials containing RCRA 40 CFR 2^8~ to a previously uncontaminated, haiardous wastes subject to (Subpart D)
onsite location, and placement land disposal restrictions.in or on land may trigger landdisposal restrictions.
Gas Collection Proposed standards for control Proposed standard; not yet 52 FR 3748of emissions of volatile ARAR. (February 5, 1987)
_ organlcs (CAA requirements tobe provided.)
Groundwater Diversion Excavation of soil for con- Disposal by disturbance of hai- See Consolidation,struction of slurry wall may ardous waste and loving It out- Excavation in thistrigger cleanup or land dis- side the unit or area of Exhibit.posal restrictions, contamination.
Incineration (Onsite) Analyze the waste feed. RCRA hazardous waste. 40 CFR 264.341
Dispose of all hazardous waste 40 CFR 264.351and residues, including ash,scrubber water, and scrubbersludge.
Action alternatives from ROD keyword index.
000240
I I ' . . /• \ I0^
Actions________ _____Requirements______ ______Prerequisites______ Citation
Excavation (Continued) Movement of excavated materials Materials containing RCRA 40 CFR 2^8~ to a previously uncontaminated, hazardous wastes subject to (Subpart D)
onsite location, and placement land disposal restrictions.in or on land may trigger landdisposal restrictions.
Gas Collection Proposed standards for control Proposed standard; not yet 52 FR 3748of emissions of volatile ARAR. (February 5, 1987)
_ organlcs (CAA requirements tobe provided.)
Groundwater Diversion Excavation of soil for con- Disposal by disturbance of hai- See Consolidation,struction of slurry wall may ardous waste and loving It out- Excavation in thistrigger cleanup or land dis- side the unit or area of Exhibit.posal restrictions, contamination.
Incineration (Onsite) Analyze the waste feed. RCRA hazardous waste. 40 CFR 264.341
Dispose of all hazardous waste 40 CFR 264.351and residues, including ash,scrubber water, and scrubbersludge.
Action alternatives from ROD keyword index.
000240
Actions Requirements Prerequisites
Incineration (Onsite)
(Continued)
No further requirements applyto incinerators that only burnwastes listed as hazardoussolely by virtue of the charac-teristic of ignitabillty, cor-rosivity, or both; or thecharacteristic of reactivity ifthe wastes will not be burnedwhen other hazardous wastes arepresent in the combustion zone;and if the waste analysis showsthat the wastes contain none ofthe hazardous con&Lituentslisted in Appendix VII I whichmight reasonably be expected tobe present.
Performance standards for in-cinerators:
40 CFR 264.340
Achieve a destruction andremoval efficiency of9 9 . 9 9 percent for each prin-cipal organic hazardous con-stituent in the waste feedand 99.9999 percent fordioxins
40 CVR 264.343
Reduce hydrogen chlorideemissions to 1.8 kg/hr or1 percent of the HC1 in thestack gases before enteringany pollution control de-vices
40 CFH 264.342
Action alternatives fro* ROD keyword index.
CVR134/032-15
' \ ,
l
a______Actions________ _____Requirements______ ______Prerequisites_____ ___Citation___
Incineration (Onsite) Monitoring of various para" 40 CFR 264.343(Continued) meters during operation of the
incinerator is required. Theseparameters include:
o Combustion temperature
o Waste feed rate .
o An indicator of combustiongas velocity
o Carbon monoxide
Special performance standard 40 CFR 761.70for incineration of PCBs.
Land Treatment Ensure that hazardous consti- RCRA hazardous vaste. 40 CFR 264.271tuents are degraded, trans-formed, or immobilized withinthe treatment zone.
Maximum depth of treatment zone 40 CFR 264.271must be no more than 1.5 meters(5 feet) from the initial soilsurface; and more than 1 meter(3 feet) above the seasonalhigh water table.
Demonstrate that hazardous con- • 40 CFR 264.272stituents for each waste can becompletely degraded, trans-formed, or immobilized in thetreatment zone.
Hinimice run-off of hazardous 40 CFR 264.273constituents.
________ 000242nn . naM ^roni keyk Inrte
Actions Requirements Prerequisites CUdUon
Land Treatment (Continued)
Operation and Maintenance (OCM)
Slurry Mall
Maintain run-on/run-off controland nanageaent systeii.
Special application conditionsIf food-chain crops grown In oron treatient zone.
Unsaturated zone Monitoring.
Provide groundwater •onltoringadequate to detect releasesfroi* the unit.
Special require«ents forIgnltable or reactive waste.
Special requlreBents for Incom-patible wastes.
Special requirements for RCRAhazardous wastes.
Design systeu to operate odorfree.
Post-closure care to ensurethat site Is Maintained andmonitored.
Excavation of soil for con-struction of slurry wall naytrigger cleanup or land dis-posal restrictions.
Disposal by disturbance of hax-ardous waste and Moving It out-side the unit or area of con-taainatlon.
40 CFK ^64.273
40 CFK 264.276
40 CFR264.278 —
40 CFR 264Subpart F
40 CFR 264.281
40 CFR 264.282
40 Cra 264.283
CAA Section 101and40 CFR 52°
40 CFR 264.1
See Consolidation,Excavation in thisExhibit.
Action alternatives froa ROD keyword index. f\f\f\C) A ^c u u u M ' ^All of the Clean Air Act ARARs that have been established by the federal govercent are covered by Batching state regulations. Tho litatehas the authority to •anage these progrars through the approval of Its l«ple»entatlon plans (40 CFR 52 Subpart G).
<<
( \ f •: I
a_______Actions_________ ______Requirements_______ ______Prerequisites______ ___Cttation___
Surface Hater Control Prevent run-on and control and Land-based treatment, storage, 40 CFR 264.251(c)(d)collect runoff from a 24-hour, or disposal units.25-year storm (waste piles, 40 CFR 2b4.273(c» (d»land treatment facilities,landfi l ls) . 40 CFR 264.301(c)(d»
Prevent over-topping of surface 40 CFR 264.221(c)Impoundment.
Tank Storage (Onslte) Tanks must have sufficient RCRA hazardous waste (listed or 40 CFR 264.191shell strength (thickness), characteristic) held terpor-and, for closed tanks, pressure arlly In a tank before treat-controls, to assure that they ment, disposal, or storagedo not collapse or rupture. (40 CFR 264.10).
Haste must not be Incompatible 40 CFR 264.192with the tank material unlessthe tank Is protected by aliner or by other means.
Tanks must be provided with 40 CFR 264.193secondary containment toprevent releases.
Tanks must be provided with 40 CFR 264.194controls to prevent ov. f i l l ingand sufficient freeboard main-tained In open tanks to preventovertopping by wave action orprecipitation.
aAction alternatives from ROD keyword Index.
000244
( \ f •: ia
_______Actions_________ ______Requirements_______ ______Prerequisites______ ___Citation___
Surface Hater Control Prevent run-on and control and Land-based treatment. Storage, 40 CFR 264.251(c)(d)collect runoff from a 24-hour, or disposal units.25-year storm (waste piles, 40 CFR 2b4.273(c»(d»land treatment facilities,landfi l ls) . 40 CFR 264.301(c)(d)
Prevent over-topping of surface 40 CFR 264.221(c)Impoundment.
Tank Storage (Onslte) Tanks must have sufficient RCRA hazardous waste (listed or 40 CFR 264.191shell strength (thickness), characteristic) held tempor-and, for closed tanks, pressure arlly In a tank before treat-controls, to assure that they ment, disposal, or storagedo not collapse or rupture. (40 CFR 264.10).
Haste must not be Incompatible 40 CFR 264.192with the tank material unlessthe tank Is protected by aliner or by other means.
Tanks must be provided with 40 CFR 264.193secondary containment toprevent releases.
Tanks must be provided with 40 CFR 264.194controls to prevent ov. f i l l ingand sufficient freeboard main-tained In open tanks to preventovertopping by wave action orprecipitation.
aAction alternatives from ROD keyword Index.
000244
Actions Requirements Prerequisites Li lot ion
Tank Storage (Onslte)
(Continued)
Inspect the following: over-filling control, control equip-ment, Monitoring data, wastelevel (for uncovered tanks),tank condition, above-groundportions of tanks (to assesstheir structural Integrity),and the area surrounding thetank (to Identify signs ofleakage).
Repair any corrosion, crack, orleak.
At closure, remove all hazard-ous waste and hazardous wasteresidues fron tanks, dischargecontrol equipment, and dis-charge conflnenent structures.
Store tgnltable and reactivewaste so as to prevent thewaste froR Igniting or react-ing. Ignltable or reactivewastes In covered tanks •ustcomply with buffer zone re-quIreBents In "Fla—able andConbustlble Liquids Code,"Tables 2-1 through 2-6(National Fire ProtectionAssociation, 1976 or 1981).
40 CFK 264.195
40 CPR 264.196
40 CFK 264.197
40 CPU 264.198
Action alternatives fro* ROD keyword Index.
CVR134/032-19
Actions Requirements Prerequisites Citation
Treatment Standards for miscellaneousunits (long-term retrievablestorage, thermal treatmentother than Incinerators, openburning, open detonation,chemical, physical, andbiological treatment unitsusing other than tanks, surfaceimpoundments, or land treatmentunits) require new miscellane-ous units to satisfy environ-mental performance standards byprotection of groundwater, sur-face water, and air quality,and by limiting surface andsubsurface migration.
Treatment of wastes subject toban on land disposal must at-tain levels achievable by bestdemonstrated available treat-ment technologies (BOAT) foreach hazardous constituent ineach listed waste.
Treatment of hazardous wastesin units not regulatedelsewhere under RCRA.
Effective date for CEBCLA ac-tions November 8, 1988, forF001-F005 razardous wastes,dioxin wastes, and certain"California List" wastes.Other restricted wastes willhave different effective datesas to be promulgated In40 CFR 268.
40 CFR 264(Subpart X)
40 CFR 268(Subpart D)
BOAT standards are based on oneof four technologies or combin-ations: for wastewaters(1) steam stripping, (2) bio-logical treatment, or (3) car-bon absorption (alone or Incombination with (1) or (2),and for all other wastes(4) Incineration. Any tech-nology may be used, however. IfIt will achieve the concentra-tion levels specified.
Actions8________ ______Requirements_______ ______Prerequisites______ Citation
Waste Pile Use liner and leachate collec- RCRA hazardous waste, non- 40 CFR .264.251tion and removal system, containerized acciwulation of
solid, nonfla—able hazardouswaste that is used for treat-Rent or storage.
action alternatives fron BOO keyword Index.i
CVR134/032
*
000247
^<»m -* H /oi t ti
APPENDIX E
\ STATE OF ARKANSASDEPARTMENT OF POLLUTION CONTROL AND ECOLOGY
•••1 NATIONAL DRIVE, P.O. BOX 9S93..LITTLE ROCK, ARKANSAS 72209
PHONE: (501) 5(2.7444 c-i C^ ' 0 pr', '; C5FAX: (501) 5C2.4C32 --•».-• « - ' • ' •
September 7, 1990 - -
Ms. Ellen GreeneyConununity Relations CoordinatorU.S. EPA, Region 6 (6H-MC)1445 Ross AvenueDallas, TX 75202-2733
RE: Vertac Off-Site Proposed Remedies
The Arkansas Department of Pollution Control and Ecology presentsthe following comments regarding the proposed plan for VertacOff-Site:
1. The extremely low concentration of TCDD in the RockyBranch Creek Flood Plain requires careful evaluation ofthe advantages of remedial action, verses the ecologicaldamage resulting from that action.
2. The analytical data for the sewer lines, sewer treatmentplant, and lagoons were derived from samples taken in1984. The flood plain was sampled over two years ago.All of these areas should be resampled prior to anyremedial action.
3. The cleanup levels in the flood plain are based on healthrisks associated with the residential soil contamination.Rezoning the flood plain area from residential tocommercial, in the flood plain areas where no developmenthas occurred, would eliminate the remedial action needsbased on a change in health risk scenario. It would serveto save millions of dollars and remain protective of humanhealth and the environment and be non-destructive to theexisting ecology. These issues should be seriouslyconsidered while finalizing a Record of Decision.
We concur with the balance of the proposed remedy as outlined byEPA in the proposed plan. We appreciate your consideration of theState's comments.
Sincerely,
Mike BatesChiefHazardous Waste Division
MB:cw
STATE OF ARKANSASDEPARTMENT OF POLLUTION CONTROL AND ECOLOGY
^001 NATIONAL DRIVE, P.O. BOX 9593LITTLE ROCK, ARKANSAS 72209
PHONE: (501) 562.7444FAX: (S01) 562.4«32
September 18, 1990
Garret Bondy"Chief, AR/IA Superfund Enforcement SectionU.S. EPA Region 61445 Ross Avenue, Suite 1200Dallas, TX 75202-2733
RE: Vertac Off-Site Proposed Remedy
Dear Mr. Bondy:
It has come to my attention that my September 7, 1990, letter toMs. Ellen Greeney regarding the Vertac off-site proposed remediesmay have been mis interpreted by EPA. The comments relative to theproposed remediation of the flood plain areas was not intended tosuggest our nonconcurrence. We understand the basis for selectionof the clean-up criteria and agree that application of saidcriteria (clean-up to 1 ppb TCDD) should be accomplished based onthis criteria.
Our comments were intended to point out the ability to use orprovide flexibility in the application of cleanup criteria duringthe decision making process. We urge EPA to exercise as muchflexibility as feasible in the application of the clean-up standard(and particularity in the design and implementation of the remedy) .
I hope this clarifies any questions EPA may have regarding ourposition on the Proposed Plan.
Sincerely,
Hike BatesChiefHazardous Waste Division
MB:cw