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Fourth Five-Year Review Report for
Arkansas City Dump Site Arkansas City, Kansas
USE?/ June 2012
Prepared By: United States Environmental Protection Agency
Region 7 Superfund Division Kansas City, Kansas
Cecilia Tapia, Director Date Superfund Division U.S. EPA Region 7
Table of Contents
List of Abbreviations iii Executive Summary iv Five-Year Summary Form v
I. Introduction 1
II. Site Chronology 2
III. Background 3 Physical Characteristics 3 Land and Resource Use 3 History of Contamination 3 Initial Response 4 Basis for Taking Action 4
IV. Remedial Actions 4 Remedy Selection 4 Remedy Implementation 5 System Operation/Operation and Maintenance 5
V. Progress Since Last Five-year Review 5
VI. Five-year Review Process 6 Administrative Component 6 Document Review 6 Data Review 7 Interviews 7 Site Inspection 7 Community Involvement '. 9
VII. Technical Assessment 9 Technical Evaluation Question A: Is the remedy functioning as intended by the
decision documents? 11 Question B: Are the exposure assumptions, toxicity data, ->
cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy still valid? 12
Question C: Has any other information come to light that could call into question the protectiveness of the remedy? 12
Technical Assessment Summary 12
VIII. Issues 12 IX. Recommendations and Follow-up Actions 12 X. Protectiveness Statement 12 XI. Next Review 13 XII Photographs 14
Appendix 1 - Site location maps Appendix 2 - Deed Notice ICs Appendix 3 - Cowley County property records Appendix 4 - Site Inspection Checklist Appendix 5 - RA AsBuilts FluorDaniel Appendix 6 - Public Notice
List of Abbreviations:
CERCLA Comprehensive Environmental Response, Compensation and Liability Act EPA U.S. Environmental Protection Agency ESD Explanation of Significant Difference FY Fiscal Year KDHE/BER Kansas Department of Health and Environment/Bureau of Environmental
Remediation NCP National Oil and Hazardous Substances Pollution Contingency Plan NPL National Priority List OU Operable Unit pH Power of hydrogen (negative log base 10 of the hydronium ion concentration) RA Remedial Action RAOs Remedial Action Objectives RCRA Resource Conservation and Recovery Act ROD Record of Decision SARA Superfund Amendment Reauthorization Act SSC State Superfund Contract
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 7
11201 Renner Boulevard Lenexa, Kansas 66219
JUL 1 2 2013
SUBJECT: Arkansas City Dump'Foikth Five-year Review Clarification
Craig W. Smith/p.E./_4 / V Senior Enginee,
TO: Arkansas City Dump Site File
This memorandum is to clarify the Arkansas City Dump Fourth Five-year Review dated June 29, 2012. Subsequent to the completion of the June 2012 document, I met with and requested review and comment on the ACD FYR from the EPA Region 7 Environmental Services Division and Regional Counsel.
Written comments were received from ENSV on December 26, 2012. Of those comments, the human health and ecological risk reviewers had no substantive comments. The hydrogeological reviewer suggested additional groundwater samples be collected every two years. The hydrogeologist comment was discussed with Bill Pedicino on January 28, 2013. Considering that: (1) the 2007 sample results were nondetect for all nonpetroleum related analytes and pH was normal for ambient groundwater, (2) the Kansas Department of Health and Environment has recommended no further action including no additional groundwater monitoring, and (3) the site inspection and detailed technical review yielded no physical changes to the site which would affect groundwater, it was agreed that no additional groundwater monitoring is needed for a protectiveness determination at present. Also, since the waste at this site was the result of the operation of the former Milliken Oil Refinery, almost all of the waste left on-site is subject to the CERCLA petroleum exclusion. Nonetheless, the primary purpose of the ACD Superfund remedial action that was implemented in the 1990s was to neutralize the residual acidic petroleum sludge left on-site after the refinery stopped operation and abandoned the waste. Excess lime was provided to ensure complete neutralization and buffering, therefore, the only nonpetroleum residual constituent was placed by the EPA, and it is monitored by analyzing the pH. The lime would not be considered a hazardous substance unless it failed RCRA characteristic of corrosivity (that is pH greater than 12.5, only in its original, technical-grade product form). Cement kiln dust was also added by the EPA to stiffen the waste, but it is not a hazardous constituent. Based on the 2007 and previous sampling, the groundwater pH is normal, representative of unaffected ambient groundwater.
Since the 2012 site inspection determined that the cover is intact and well maintained and no other engineering or hydrogeological changes have occurred, it was agreed that there is no technical need to or basis for conducting additional groundwater sampling to make a protectiveness determination. However, as a precaution, Superfund will ask the state to consider voluntarily collecting limited groundwater sampling data coincident with future FYRs using available state authority and resources. Mr. Pedicino agreed that there were no significant hydrogeological or other environmental issues at this site, agreed
II 111 III Superfund
with this evaluation, and agreed to a suggestion to the state to consider voluntary state or local five-year sampling depending on site conditions and other factors. By copy of this memorandum, the agency is asking KDHE to consider that sampling.
A follow-up discussion was conducted with CNSL attorney Bob Richards on January 29, 2013. He confirmed the recommendation in the June 2012 FYR that the state upgrade the institutional control and found no know other legal issues with the site;that need any, action.
One of the other internal EPA reviewers had a question about the Operable Unit designations for this site. The acidic sludge stabilization work—which constituted the final remedy for the site—was conducted as OU2. In the original 1988 OU1 Record of Decision, a different treatment technology was selected for the Remedial Action. When that technology was found to be ineffective, an alternative treatment technology was adopted in the May 25,1990, ROD's Explanation of Significant Differences and implemented as OU2. That OU2 work addressed all the human health and environmental concerns at the site; additional work was not needed and OU2 became the final site-wide ROD. The June 2012 FYR incorrectly stated that the OU1 action was the final site-wide remedy and it should have stated OU2 was the final remedy, consistent with the CERCLIS database entries.
No public comments were received from the public availability of the FYR in the Arkansas City area. Superfund will work with the Office of Public Affairs to publish a notice of availability that the final FYR has been completed.
The remedy for the Arkansas City Dump site in Arkansas City, Kansas, called for neutralization and stabilization of acid waste, covering the treated waste with a vegetative cap, and using institutional controls to prevent future disturbance of the waste. The site achieved construction completion on September 8, 1992. The first Five-year Review (5YR) report was signed by the then EPA Superfund Division Director, Michael J. Sanderson, on August 22, 1997. The second 5YR was initiated for completion within five years of the first 5YR and signed by the EPA Superfund Division Director on September 24,2002. The third 5YR was prepared by the Kansas Department of Health and Environment's Bureau of Environmental Remediation, and was approved by Cecilia Tapia, Director, Superfund Division, on July 20, 2007.
The assessment of this fourth 5YR reached similar conclusions as the previous Five-year Reviews. That assessment is that the remedy was constructed in accordance with the requirements of the Record of Decision (ROD). A second ROD was issued to express the determination that the remedy expressed in the ROD for Operable Unit 1 (OU1) was sufficient to provide protectiveness for the entire site and no additional actions were required. Threats relative to CERCLA appear to have been remediated, although refinery-related hazardous waste has been left in place at the site. The site was removed from the National Priorities List (NPL). This document recommends that a fifth 5YR be completed in 2017.
Five-Year Review Summary Form
Site Name: Arkansas City Dump
EPA ID: KSD980500789
Region: 7 State: KS
NPL Status: Deleted
City/County: Arkansas City/Cowley
Multiple OUs? Yes
Has the site achieved construction completion? Yes
Lead agency: EPA If "Other Federal Agency" was selected above, enter Agency name: n/a
Author name (Federal or State Project Manager): Craig W. Smith, P.E.CIick here to enter text.
Author affiliation: USEPA Region 7 Superfund Division
Review period: 5/07 5/12 Click here to enter end date.
Date of site inspection: 6/13/12
Type of review: Statutory
Review number: 4