record of decision - remedial alternative … · kpd cg1 001693 5 9 0006 during the ... water...
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NPD C01 001693
5 9 0001
RECORD OF DECISION
Remedial Alternative Selection
tat 9 10
WiSV'
SITE; Newport Dump SiteCampbell County, Wilder, Kentucky
DOCUMENTS REVIEVED;
- Newport Dump Jteraedial Investigation
- Newport Dmp Feasibility Study
- Newport Dump Didatgerment Assessment
- Responsiveness Summary
DESCRIPTION Of SELECTED REMEDY!
- Multimedia Hanitoring Program
- Reiteration and extension of leachate collection Bvstem
- Restoration, regrading and revegetation or existing clay cap
0016945 9 0002
Declarations;
The selected remedy is consistent with the Conprehensive EnvironmentalResponse, Compensation, and Liability Act of 1980 (CERCLA), SuperfurrfAmendments and Reauthorization Act (SARA)(PL 99-499, October 17, 1986)and the National Contingency Plan (40 CFR Part 300). I have determinedthat the monitoring, regrading, revegetation and leachate collection atthe Newport Djnp site is a cost-effective remedy and provides adequateprotection of public health, welfare, and the environment. The Stateof Kentucky Department of Environmental Protection has been consultedand agrees that the approved remedy meet applicable relevant andappropriate State standards and requirements. Future operations andmaintenance activities to ensure continued effectivess of the remedy,will be considered part of the approved action and portions there ofmay be eligible for Trust Fund monies for a period of up to one year.
I have also determined that the action being taken is appropriate whenbalanced against the availability of Trust Fund monies at other sites.In addition, the monitoring, regrading and Icnchate collection is morecost-effective than other remedial actions and is necessary to protectpublic health, welfare and the environment.
tf.Date Jack E.
Regional Adminlstra1-
•'80 9
Npu CO! 001695
5 9 0003SITE LOCATION AND DESCRIPTION
The 39-acre fonrer municipal landfill is located at latitude 30" land longitude 84° 30' 17" in the City of Wilder (population 633) inCanpbell County, Kentucky (see Figure 1). The City of Wilder is located•bout three miles south of the City of Newport, a suburb of Cincinnati, Ohio.
The main road leading to the site is State Road 9. Access to the site isby way of Banklick Road, which terminates at the entrance of the landfill.The site is bounded on the west by the Licking River, a tributary of theChio River: on the north by a small industrial Park? on the east bysteep outcrops and State Road 9; and on the south by an unnamed stream(see Figure 2).
The Newport Dump site is located on the Licking River, a tributary of theOhio River. Approximately 250 feet'downstream of the site on the oppositebank of the river is the main raw water intake for the Kenton CountyTaylor Mill water treatinent plant. The water plant withdraws up to 18•u'llion gallons per day (H3D) from the Licking River and serves about75,000 consumers in Kenton and Boone Counties. An unnamed stream forms.the southern boundary of the landfill and drains to the Licking River.Flow in the stream is intermittent, with the greatest flow during periodsof high runoff.
The site is underlain by unconsolidated alluvial deposits. The alluviurrconsists primarily of clay, silt, Band, and gravel in a downward coarseningsequence. The thickness of the unconsolidated material ranges from 36feet at the eastern end of the landfill to about 110 feet at Licking River.Below the alluvial deposits is a shale and limestone bedrc... reported tobe up to 250 feet thick.
The topography of the site consists of two distinct areas. The lowerriver terrace occupies the areas adjacent to the river and is frequentlyflooded. The second level is separated from the lower terrace by an areaof steep slopes and includes the landfilled portion of the site.
SITE HISTORY
The site was o-iginally purchased by the City of Newport in the late1940's and war used by the City for the disposal of residential andcommercial wastes f.-or. its opening u-til its closure in 1979. Trenchingand area fillu-j of the waste were tl.e most corumn methods used to disposeof waste at the site.
In 1568, the Comranwealth of Kentucky instituted permitting requirementsfor landfills; and after being in violation, the City finally received apermit in late 1969 to operate the site as a municipal sanitary landfill.The site war; closed in 1979 and ownership was transferred to the NorthernKentucky Port Authority (NKPA) the same year.
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" P O C 0 1 001696
NEWPORTDUMP C Z
•CALE
• 0 100
REGIONAL INDEX MAPNEWPORT DUMP SITECAMPBELL COUNTY, KENTUCKY
FIGURE 1
NUSA HaHiburton Compan;
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C01 001697 5 9 0005
KINTONCOUNTYWATMINTAKI,
ILICTRICTHANSMIMION
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• COt '»•COW»NT
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INBUtTdlALPARK
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LlOfkOAPfMOXIHATItITI 10UMOAMT
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NEWPORT DUMP SITECAMPBELL COUNTY, KENTUCKY FIGURE
A Hailitxjrton Compar
K P D CG1 001693 5 9 0006During the life of the landfill, the City of Newport was cited on numerousoccasions by the Kentucky Department of National Resources and Environm?-1-^Protection (KDNREP) and other state agencies for permit violations. T>most frequent violations included: open burning at the landfill, abservof daily cover, onsite ponding of water, uncovered refuse, inadequatesecurity, presence of leachate, lack of proper seeding, and erosion•problems due to lack of vegetation. In addition to being cited foroperational violations, the City has also been cited for handling hazardouswaste without a permit.
Due to the inadequate management of the landfill, an Agreed Order betweenthe City of Newport and the Kentucky Natural Resources and EnvironmentalProtection Cabinet (Cabinet) to prepare a final closure plan for the sitewas issued on September 26, 1978. The final closure plan, however, wasnever fully implemented and ownership of the landfill was transferred onDecember 28, 1979 to the NKPA with the understanding that the NKPA wouldremediate the site. Due to the transfer of ownership, the NKPA wasobligated to prepare a final closure plan. An Agreed Order between theKentucky Cabinet and NKPA was issued on July 9, 1980, formally retiringth NKPA to properly close the former Newport waste disposal facility. Inan effort to comply with the Agreed Order, the NKPA installed a leachateoolletion system, regraded f-rtions of the site, installed a clay capover the waste, and seeded the area with grass.
Lack of adequate funding, however, resulted in the NKPA not being able tofully implement the July 9, 1980 Agreed Order. Cited violations againstthe NKPA since the Agreed Order include: lack of maintenance of theleachate collection system and collection tank, lack of vegetation anderosion of parts of the landfill, failure to install a methane g*- ventsystem, and failure to conduct a leachate monitoring program. Siteinspections by Kentucky DNREP personnel during the partial closure of thelandfill have noted the occurrence of several leachate breakouts leadingtoward the Licking River.
Since the NKPA did not fully implement the Agreed Order, a new AgreedOrder was entered into by the Kentucky Cabinet and the NKPA on October 30,1984. In accordance with the requirements established under CERCLA, theNewport Dump Site was evaluated by ETA in 1962 utilizing the Hazard RankingSystem (HRS). Ttie HRS was used to evaluate the relative risk or dangerfactors existing at the Newport Dump Site, taking into account the populationat risk, the hazardous potential of the substances at the facility, thepotential for contaro_,Mtic i of drinking water supplies, and for destructionof sensitive ecosysters ad other approprK ite factors.
The Newport Dump site overall HRS score was 37.69, which ranked the sitenumber 359 in Group 8 on the National Priorities List (NPL). The sitereceived this ranking due to the close proximity of the Kenton CountyDistrict One raw water intake located approximately 250 feet downstreamfrcm the site on the Licking River, the observed release of leachate toLickir*3 River, ar*d the presence of elevated concentrations of lead,chromium, and PCT.-, in leachate samples.
N P D C01 0016905 9 0 0 0 7
The Ranedial Action Master Plan (RAMP) was developed by Camp, Dresser,and HcKee, Inc., et al., in 1983 and NUS begtn the RI/FS in 1985.
NUS completed the RI site investigation in March 1986, and submi;draft RI/FS report in November 1986. The RI assessed the nature andextent of onsite and offsite contamination, and evaluated hazards to humanhealth and the environment. The goals of the data collection activites were:
• Location of approximate fill boundaries through the application ofgeophysical techniques
0 Assessment of the levels of groundwater contaminants and potentialpathways in the alluvial aquifer
• Determination of levels of contaminants in surface and subsurface soils
• Determination of levels of contaminants in the Licking River andan unnamed stream south of the site and the potential for contaminationof surface water at the raw water intake
0 Evaluation of he effect of leachate on aquatic organisms
The major concern at the site was leachate migration to nearby surfacewater bodies. These surface water bodies include the unnarned streamforming the southern border of the site and the Licking River, a tributaryof the Ohio River, bordering the western edge of the site. The surfacewater contaminant migration pathway was examined by collecting surfacewater and sediment samples at six locations in the unnameo stream andfive nearshore locations in the Licking River. Many of these sanplingpoints were also paired with shallow groundwater sampling points toevaluate the potential groundwater contribution to surface water. Detailsof the remedial site investigation bnd laboratory analyses are documentedin the RI report.
CURRENT SITE STATUS
The approximate boundary of waste .-aterials encompasses an area of 32.2of the 39 acrei that form the site. Based on disposal practices, thisarea has been r°per ted into an eastern and western section, broken by thelocation of the cu.; /et-t traversing t' e site. Since the majority of thelandfilling operations are conducted in the western section, the bulk ofthe wastes and contaminated soil lies within this area.
Jtough estimates of the volume of contaninated material suggest thatapproximately 1,078,000 cubic yards of waste may exist and that 60 percentof this material is construction rubble, scrap metal, and tires.
ons conducted during the RI indicated that the natural materialslandfill consist predominantly of low-permeability clays.
-3-
beneath th
col001700 5 9 0 0 0 8
Calculations based on data collected during the RI suggest that theHorizontal groundwater flow velocity is 4.4 feet per year, while t1vertical flow velocity is only 0.05 feet per year.
The thickness of the alluvial aquifer at the site varies between 37 and68 feet and thins toward the valley walls. Samples of the deepergroundwater, collected during the RI from monitoring wells set directlyabove bedrock, contained no significant levels of contamination. Samplesof the shallow groundwater beneath the site contained metals, solvents,and PAHs. The shallow groundwater is expected to be released as leachate
eps or as groundwater discharge to Licking River.
The presence of leachate seeps has been noted throughout the life of thelandfill. Early attempts to control the discharge of leachate to LickingRiver and the unnamed stream resulted in the construction of collectiontrenches or berms on the west and south landfill slopes. Most of theeffects of the past release of leachate have been eliminated as a resultof the regrading and capping performed by the NKPA during closure; butthe early collection trench along Licking River remains.
The NKPA also installed a leachate collection system on the west andsouth banks of the lane-ill during the closure activities. However, thissysten is not working properly either due to clogging or collapse as aresult of subsidence of the waste material. In addition, the NKPAclosure activities did not address the steep banks along the north slopeof the landfill just east of the Ceramic Coating Company. This area isheavily vegetated, with erosion gullies and numerous active leachate seeps.
Siallow groundwater, not released as leachate seeps, is exp, .ied todischarge directly to the Licking River. As part of the RI, the groundwaterdilution rate in the Licking River was calculated to be over 40,000 to 1even under the lowest flow rate available for the river. Since a surfacewater intake for the Kenton County Water District is located 250 feetdownstream of the site, surface water and sediment samples were collectedfrcm the unnamed stream and the Licking River as well as two water samplesfrom the intake.
The results of the chemical analyses indicated that the levels ofcontaminants in the water withdrawn frcm the intake were below all accepteddrinking water criteria, and that sir.e contaminants did not appear tohave any affect on ihe quality of the water in Licking River.
The main recepto 3 for contaminant releases from the site are the 75,000residents served by Lne Kenton County water intake. Approximately, 1,200individuals live within a one-roile radius of the site, but no private orpublic drinking water wells were found within this area. The potentialreceptors include those eating fish caught for recreation from the LickingRiver. Public access to the site is currently uncontrolled; however,there does not appear to be any recreational use of the site.
The public health evaluation n -'ormed dv.ring the RI found no evidence ofany current oublic health or environnental concerns associated with theNewport !Xr> .",ite.
-4-
IB IS
N P D 001 001701 5 9 0009
The contaminant levels in the surface soils and in surface water an^sediment downstream of the site were below all accepted health criwhile dilution of shallow groundwater contaminants as a result of .qeto the Licking River is expected to reduce these contaminants to negligiblelevels.
FLOOD POTENTIAL
Following major floods, the Army Corps of Engineers Treasures the eleva-tions of high water marks at various points along the river. Interpolatingfrom known elevations, the projected high water marks on the Licking River,dating to at least 1875, are as follows (Army Corps of Engineers, 1986b):
Flood
January 1937March 1964April 1948May 1961
Elevation(ft amsll
511500.5495491
Channel velocities during floods are on the order of five feet per second,with local velocities of eight feet per second. Raving never inspectedthe study areas, and because the potential for erosion is site-specific,the Army Corps of engineers offers no reconrendaitons concerning theerosion potential of the riverbank near the site.
Flooding near the study area is increased by backwater flooding frcn theOhio River. Therefore, the site benefits from flood reductions on theOhio River due to operation of 52 flood control reservoirs on the OhioRiver tributaries upstream frcm the Licking River.
Flooding of the Licking River is also reduced by operation of the CaveRun Flood Control Lake, completed in 1975, which regulates a drainagebasin of 826 square miles. The Army Corps of Engineers (1986) floodelevations were used to illustrate the areas of the site expectedto be inundated by the 500-, 100-, 50-, and 10-year floodwaters. Theseareas are shown in Figures 3 throuqt. 6, respectively.
NATURE AND EXTCJ7 0V i'rJC PROBLEM
As specified ir. the National Contingency Plan (NCP), the RI was designed todefine the nature and extent of the threat to public health and theenvironment presented by the release of hazardous substances at or nearthe Newport Dorp Site. To accomplish this goal, waste and soil samplesvere collected from several locations on or near the landfill. Allsamples were analyzed for the hazardous substance list (HSL) of contaminants,hov-ver, only the specific compounds detected at least once in theirrespective m :Iia are presented in t!ie tables. Based on the results ofthese analyser., an attempt was made to characterize the types and levelsof conta-iirc-;1:- in the waste and Ii?ach3te to determine whether migrationof si to-linked contaminants har. occurred cr is likely to occur.
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001702 5 9 0 0 1 0 FINN WAFT
S.EQESDARIA IHUK»AT:O BY•OO-YIAK FLOOP
o *c too
500-YEAR FLOOD LEVEL (5 «0 FEET)NEWPORT DU?^P SITECAMPBELL COUNTY, KENTUCKY
FIGUREpswusL_ pJHPORATOM
A HaHiburton Company
in mi O i i
NPD C01 001703 5 9 0 0 1 1
AHt* IKUNDATtD «V100- T£*v
•O tOO 410' *OC°
100 -YE/ n FLOODNEWPORr DUMP SITE
; .•:. COUNTY, f
(503.8 FEET)F!QU;
A HaNitxirton Compan
NPD00170-5
A M f A i^UuOAiiu ml•0-VIAM FLOOD
50-YEAR rLOOD LEVEL 1500 FEET)NEWPORT DUMP SITECAMPBELL COUNTY, KENTUCKY RZCJS
CORPCRATDTA Hafc&urton Compar
I U '
001 001705
INUNDATIO IVFLOOD
10-YEAR FLOOD LEVEL (41)2 FEET)NEWPORT DUMP SITECAMPBELL COUNTY, KENTUCKY
FIG' :.E
A HaHiburtor Compan
to ~>n(V <_ u
NPO 00170o 5 9 0014
The results of the chemical analyses of waste and soil samples are presentedin this seciton. Sample code desciptions and field measurement •*-•-• 'OH,specific conductance, and temperature) for all samples collect jthe investigation may be found in Appendix D of the RI/FS dccvr
SOURCE
During the Rl, sarples of the waste material were collected and analyzedto determine the chemical characteristics of the waste. The waste materialimmediately beneath the clay cap and the subsurface soil below the waste*ere sampled at four borehole locations within t)ie landfill. The fourccisite and one offsite borehole locations are shown on Figure 1, andthe chemical characteristics of the waste are shown in Tables 2 and 3.
Data have been combined with the data from previous studies and the wastethickness at each location is shown on Figure 8. The available wastethickness shown in Figure 8 support the current understanding that thedepth of fill is extremely varied throughout the site. Since an approximatevolume of waste is necessary for costing purposes, the known depths ofwaste were used to provide an average waste thickness for each section ofthe landfill. The estimated total waste volume is 1,078,000, based on118,000 cubic yards in the eastern section plus 960,000 cubic yards inthe western section. This volume of waste should be considered as onlyan approximation since the actual waste volume at the site is unknown.
WiSTE COMPOSITION
The waste samples collected beneath the cap (SS-2A, SS-3A and SS-4A)contained a wide variety of inorganic and organic contaminants. The rnostcommon constituents consisted of metals, PAHs, various solvents, andPCBs. The highest concentrations were found in samples collected fromboreholes SS-3 and SS-4, west of the culvert. PCBs and DOO were the onlychlorinate hydrocarbons detected in the waste material, and they wereonly observed in the waste sanple (SS-3A) collected just west of theculvert. Borehole satrples taken below the waste material evidenced nosignificant levls of contamination. It is reasonable to assume that verylittle downward migration of cortsninants has occured.
Additionall>, r.o significant contaminant levels «ere detected in theoffsite subs.;rf>"- ;> soils but a lov level of toluene was detected near theCeramic Coat ng .jonpany. This inc.cates that the site contaminants havenot migrated significantly in the subsurface soils.
GRCUNDVZATER CONTAMINATION
A subsurface investigaiton was designed and implemented as part of the RTfor the Newport Dump Site. The design of the investigation included thecompletion of 14 soil borip"<; with the installation of 8 monitoring wellsand 3 piezometers in seme of the boreholes (see Figure 9).
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NPD C01 00170
KtMTONC O U K T T• ATI*IMTAU/
LEGENDX •AMU.INO LOCATION!
e no MO «»e tee'i^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^V.'ASTE AND SUBSURFACESOIL SAMPLING LOCATIONSNEWPORT DUMP SITECAMPBELL COUNTY,KENTUCKY
FIGURE 7
A Ha*borton Company
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NPD C0100170S 5 9 0016
• - •OMENOLI7 - W A S T E THICKNESS IN MIT
WASTE THICKNESSNEWPORT DUMP SITECAMPBELL COUNTY. KENTUCKY
FIGURE 8
MUSCORPORATOfM
A Halliburton Company
NPD COi 001709 5 9 0 0 1 7
LEQENT•$- MONITORING W E L L L O C A T I O N+ r i tZOMlT IH L O C A T I O NA tOIL lOftlNO LOCATION
e fte' »oo «»e' »oe'
SOIL BORING LOCATIONSNEWPORT DUMP SITECAMPBELL COUNTY, KENTUCKY
FIGURE ^
nswysi A Hallitxjrton Company
TABLE 2IMOKAMIC K8SDLT5 OF SOBStTKTftCB SOIL SAMPLES
OKSITR WITBIH WXSTR MATERIALNBrPOM OOKf SITR
CAMPBELL COOMTY, KENTUCKYOo
rARAKBTER (It3/*C)
SILVERARSENICDOPONBARIUMBERYLLIUMCADMIUMCOBALTCHROMIUMCOPPERMOLYBDENUMNICKELLEADANTIMONYSELENIUMTINSTRONTIUMTELLURIUMTITANIUMTHALLIUMVANADIUMYTTRIUMII!1CIIRCOmUMHF.^CURYAI.'MINimKA«i"..».NESECV -UM
OSS-1A5 FEET11/85
14JNA200J1.7
*U
7.028NA6115R—RNANANAH43NA97NAR20.00048 OJ21,000
ffalte ooncro,SS-IB10 FEET11/85
11JNA881.4
If1819NA •3315R
RNANANAR27NA71NAR14,000580J19,000
L
S3- 1C15 FEET11/85
9JNA130J
"_
R22JNA26J18J
UKHAMA.HA
NANAR22JNA70JNA
12.000JR15,OOOJ
SS-2Ac rest11/85
12JNA140
5—
2722JNA19140JR
31JNMAHA
NANA
20NA160JNA0.29J13,00070024.000
SS-3A8 FEET11/85
NA39 OJ
--_100NA57340JRR72JNANANA
NA540JNA0.76J17,000610J5,500
SS-4AC FRET11/85
10JNNA740
9-150620JNA1202,800R-140JNNANANA
NA1.200JUAnn3.9J10,00087076,000
S3-5A11 FBBT11/85
NA
—*~••
NA462URR—NANANA
T!AI
16J.1,000790J
0CJK*•<!K ••O
cnvo
CDCD
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6 L O O 6 S
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NPD 001 001712 5 9 0 0 2 0
PARAMETER (M3/KG)
TABLE 3ORGANIC RESULTS Of SUBSURFACE SOIL SAMPLES
ONSITE WITHIN rfASTE MATERIALNEWPORT EXMk> SITE
CAMPBELL COUNT*, KENTUCKY
Offsite Control____ ________Onsite Haste_______SS-1A————SS^lB SS-1C SS-2A SS-3A SS-4A SS-5A5 FEET 10 FEET 15 FEET 6 FEET 8 FEET 6 FEET 11 FEl11/85 11/85 11/85 11/85 11/85 11/85 11/B5
EXTRACTABLE AND MISCELLANEOUSCOMPOUNDS
1; 2,4 -TRICHLOR06ENZ END
2-ftETHYLNAPHTHALENE
ACENAPHENE
ALKANOIC ACID
"' YL ACKB/NO.
79J
5,0003
BEN70 (E) P«Ri>IE
BENZO (OH) PERVLENE
BENZOCAJAKTHRACENE
BENZO(A)PYR£NE
BEN20<B AND/OR K) FLUORANTHENE
BEZYL BUTYL PHTHALATE
BIS(2-ETHYLHEXYL) Pffli.'MAT"
eUTYL 2-M^THYLPRDPYL MHWLATE
CAREfJE
CIS ALKEJC 92 ISGMERS)
C3 AUCY1BEN2ENE
190J
160J
260J
210J
490
290J
540
2,400 2,500
FCHRXSENE
2,OOOJN -
2COJN
5JUJN
430
* u L.
NPD 001 001713 5 9 0021
rORQVNIC RESULTS Of SUBSURFACE SOIL SAMPLESONSITE WlrfTIN WASTE MATERIALNEWPORT DtWP SITE CAMPBELL COUNT*, KENTUCKYPAGE TWO
Offsite Control Onsite Waste SS-1A
PARAfCTER (M3/KG)
DIBENZOFURAN
FLUORANTHENE
FLUORENE
HEXANOIC ACID
IDENO (1,2,3-CD) Pyrene
ISOPHCRCNE
MrTHYLANTHRACENE
INAPIHALQEPETROLEIM PRXltCr
PHENATTTHKENE
P^RENE
UNIDENnFIED /NO.
SS-1B SS-1C SS-2A SS-3A5 FEET 10 FEET 15 FEET 6 FEET11/85 11/85 11/85 11/85
_ — — —
- 480
- -
- 4.00QJ
_
_
-
- 110J
- - N
- 310J
- -
l,200J/2 -
SS-4A SS-5A8 FEET 6 FEET 11 i11/85 11/85 11/1
190J
1,100J 2,OOJN
240J
-
1600 - .
— —
-
440
N
1,600
1,300
400,OOOJ/2
i oca
N P D C01 0017145 9 0022
ABLE 3ORGANIC RESULTS Of SUBSURFACE SOIL SAMPLESCNSITE WIHTIN HASTE MATERIALNEWPORT JXMP SITE CAMPBELL COUOTY, KENTUCKYPAGE THREE
Offsite Control Onsite Waste SS-LA
PARAMETER (M3/KG)
SS-IA SS-1B SS-1C SS-2A SS-3A SS-4A SS-5 FEET 10 FEEf 15 FEET 6 FEET 8 FEET 6 FEET 1111/85 11/85 11/85 11/85 11/85 11/85 ll/
PURGEAdLE AND MISCELLANEOUSCCKPCXKQB
1 , 1 , 1 -TMCHLORDETHANE
1 , 1 , 2 , 2 -TETRACHLOROETHANE
ACETOtC
BENZENE
CARBON OISULFIDe/"'
JDRCBEKZE^E
ETHYLBEfHENE
ISO-OCTANE
*ME " ' BOTYL KETONE
STYRENE
TOLUENE
TOTAL XYLENES
UNIDE-VTIPIED/MO.
14J
14
1,OOOJ
5.4
35
200J/2
700J
46
1,300 -
6,900 -
1,600 -
9,300 -
N P D C01 001715 5 9 0 0 2 3
£LE 3ORGUJIC RESULTS OF SUBSURFACE SOIL SAMPLESONSITE WIHTIN WASTE MATERIALNEWPORT DUMP SITE CAMPBELL COUNTY, KEWTLCK*PAGE FOUR
Onsitc Waste SS-1A
PARAMETER (K5/KG)
____Offsite Control ________________________SS-iA SS-1B SS-1C SS-2A SS-1S SS-4ASS 3 !5 FEET 10 FEET 15 FEET 6 PEET 8 FEET 6 FEET 11 f11/85 11/85 11/85 11/85 11/85 11/85 11/B
CHLORINATED PESTICIDES, PCBs,AND OTHER CHLORINATEDCOMPOUNDS
4,4'-ODO
4,4'-QD£
4,4'-ODT
DIELORIN
(AROCLOR 1242)
(AROCLOR 1248)
PCB-12S4 (AROCLOR 1254)
PCB-1260 (AROCLOR 1260)
22
730
290
- Material was nalyzed tor out not detected above the mini.Tvjra quantitation limitJ Estimated valueN Presunptive evidence of presence ot materialR Data unuseable
NPD C015 9 0024
Nine Temporary well points were installed outside the waste boundary ofthe landfill. The well points were prijnarily located along the LickingRiver and the unnamed stream with an additional two well points locatednorth of the landfill, as shown in Figure 10. Well points were desigrv.to detect leachate production in shallow groundwater along the bank ofthe Licking River.
In general, the alluvium at the site can be described as predominantly asilty clay with sand occurring at greater depths and ranging in color fromyellowish-brown to gray. The thickness of the alluvium varies frcn 36 to110 feet and thins toward the valley walls where bedrock eventually outcrops.Note Figure 11 for a typical cross-section of the subsurface environmentand Figure 12 for the groundwater flow of the alluvial acquifer (HorizontalGroundwater Velocity -4.4 ft/yr., Vertical Groundwater Velocity • .05ft/yr, Licking River Dilution Rate - 40,000 to 1).
NATURE AND EXTENT OF GROUNDKATER CONTAMINATION
The distribution and concentrations of groundwater contaminants wereevaluated to determine the nature and extent of groundwater contaminationat the site. The distribution of these contaminants is shown in Figure 13Sumary of the contajninatioi is presented in Tables 4 and 5. (Pleasenote, the table list concentrations of the indicator chemicals only.) Ingeneral, the deeper groundwater at the site has shown only low levels ofsite related contaminants, primarily near the culvert. No significantlevels of contaminants were detected in the deeper groundwater offsite inthe floodplain. However, the shallow onsite groundwater both immediatelybelow the waste and at the banks of the Licking River and unnamed streamcontained significant levels of inorganic contaminants.
Shallow groundwater samples collected from four wellpoints installedalong the west bank of the site adjacent to the Licking River wereevaluated to determine the potential leachate contribution to the river.Additionally, one wellpoint was installed along the north bank of thelandfill in order to monitor potential leachate migration to the floodplainnorth of the site. Numerous inorganic contaminanta were observedin all shallow groundwater samples (WP-8, WP-2, WP-3, and WP-4) with thesample from WP-3 near the center of the landfill containing the greatestnumber and the highest concentrations, rto contaminants were detected inthe shallow groundwav.er sarple (WP-1) from the wellpoint north of the site.
NATURE AND EXTENT OP 31R ACfc WATER AND SEE' *EOT CONTAMINATION
The distribution and concentrations of surface water and sedimentcontaminants were evaluated to determine the nature and extent of surfacewater and sediment contamination at the site. Individual sanjples wereccrpared to the appropriate control sanples to determine where concentrationswere elevated for specific site-related contaminants. The distributionof these contaminants is shown in Figure 14 and a summary of thecon tarn i; .at ion is presented in Tables 4, 5 and 6.
183
' ^^WS
^ ^ • • • • ^ • • •• •••• •• ^
NPD COl 001717 5 9 0 0 2 5 / ' ' .-- -.
WELL POINT LOCATIONSNEWPORT DUMP SITECAMPBELL COUNTY, KENTUCKY
FIGURE
A HaJWxjrton Company
CROSS SECTION DW-6 TO DW-41F.VVPORT DUMP SITE
COUNTY, KENTUCKY
WPD C01 001713 5 9 0027
K I M T O M
,-$- TO* OF BJDR3CK MONITOMIN* V/ILL
UO^J*) AMI WATER TAILt ILIVATION-.——— aMOUNDWATIM FLOW DIRECTION
— 4tO—tOUI fOTINTIAL LINIS
e ' no' toe' «te' «bo'
GROUNDWATER CONTOURSALLUVIAL AQUIFER (12-4-85)NEWPORT DUMP SITECAMPBELS, COUNTY, KENTUCKY
FIQURF
A Hafcburton Comparry
col 0017^05 9 0 0 2 8
TIH^OMAIIV -TBL1. POINT*
PIKMANIMT MONITOMINQ WILLS
HHMANINT riI2OMITIMSIOU.I
0 tO MO «•« •»'
DISTRIBUTION OFGROUNDWATER CONTAMINANTSNEWPORT DUMP SITECAMPBELL COUNTY, KENTUCKY
FIGURE
MUSCORPORATOrS!
A HaHitXKlon Company
18-35 1 /
LLICTMICTM/1N8MIMION
UN!
• A N K I I C K R O A D
S-8i.Cr.Pb.DOTB4,Tn1utnt
S'Al.Cu.NIPb.Zn U M H A H I O
STRIAM
VIM! >TB||T
• UMPACI V.TIJ AND •IDIUENT• AUPLINC .OC.VTIONt
W A T I N CONTAMINANT!• I D I M t N T C O N T A M I N A N T S
DISTRIBUTION OF SURFACE WATERAND SEDIMENT CONTAMINANTSNEWPORT DUMP SITECAMPBELL COUNTY, KENTUCKY
FIGURE >
HNLTA Hallibufion Company
IB3S
NPD CO!' 0017225 9 0 0 3 0
TABLE 4BACKGROUND CONCENTRATIONS
NEWPORT DUMP SITECAMFBELL COUNTY, KENTUCKY
IndicatorChemical
Arsenic
Barium
Ouroniun (total)
Nickel
Benzo(A)Pyrene
Toluene
PCBG
Surface water(103/1)
ND
ND-0.079
ND
ND
ND
ND
ND
Ground water(mg/1)
ND-0.095
ND-1.04U
ND-0.254
ND-0.450
ND
ND-0.028
ND
Soil(ragAg)
ND-14J
89-200J
7.0-24
36-61
ND
ND-0.014
ND
Sediment(TCjAg)
ND
ND-68
ND-10
ND-33
ND
ND
ND
ND Not detectedJ Estimated value
001 0017235 9 0031
TABLE 5MEAN AND MAXIMLM OBSERVED CONCENTRATIONS
SURFACE WATER AND GROUNDWATERNEWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
IndicatorChqiucal (mg/1)
Arsenic
Barion
Qircmiun (total)
Nickel
Benzo(A)Pyrene
Toluene
PCBS
Surface Water GroundwaterMean
ND
0.05
ND
ND
ND
0.0004
ND
Maximum .
ND
0.18
ND
ND
ND
0.0031
ND
Mean
0.02
1.03
0.16
0.29
ND
0.0008
ND
Maxurajn
0.064
7.4
1.5
2.4
ND
0.017
ND
KD Not detected
1835I l
C01 0017245 9 0 0 5 2
Indicator
r
TABLE 6H.5AN AND MAXIMLM OBSERVED CONCENTRATIONS
SOIL AND SEDIMENTNEWPORT DUMP SITE
CAMPBELL COUNTS, KENTUCKY
Surface Soil Subsurface Soil SedimentChemical (rag/kg)
Arsenic
Bariun
Chromium (total)
Nickel
Benzo{A,)Pyrene
Toluene
PCBs
Mean
5.8
1.7
14
29
ND
ND
0.007
Maximum
10
97
16
42
ND
ND
52
Mean
6.9
173
25.2
43.9
0.15
0.128
0.06
Maximum
15
800
ISO
120
2.3
1.6
1,020
Mean
1.6
66
3.6
24
ND
ND
ND
Maxiraj
8
120
14
37
ND
ND
ND
ND Hot detected
NPD 001723 5 9 0033
In general, only low levels of inorganic contaminants were detected intne surface water and sediment samples collected from the unnamed strewn;however, toluene was detected in the surtace water at the discharithe culvert and FAHs were detected in the sediment at the mouth otstream. No site-related contaminants were detected in the sedimen- „..the mouth of the stream. tt> site-related contaminants were detected inthe surtace veter in Licking River and the water intake; and low levelsof arsenic and copper in samples collected at the downstream boundary otthe site were the only site-related contaminants in the sediments.
NATURE AND EXTENT OF SOIL CONTAMINATION
The distribution and concentrations ot soil contaminants were evaluatedto determine the nature and extent of soil contamination at the site.Individual soil sample analyses were compared to the appropriate backgroundor control analyses to determine where concentrations were elevated forspecific site-related contaminants. The distribution of these contaminantsis shown in Figure 15 and results presented in Tables 4 and 6. In general,it appears that the surface soil at the western bank along the LickingRiver and at the steep northern bank near the ravine are the only surfacesoil areas containing r^x^oentration of site-related contaminants.
BIOTA INVESTIGATION SUWAR*
A limited acute and chronic static bioassay was conducted during the RIusing water collected form the drainage culvert that bisects the site.The test organisms were the tath&ad minnow and daphnia. The water wasnot found to be acutely toxic to either test organism and r....-oductionwas not impaired in the daphnia.
No species on the federally endangered or threatened species list navebeen Deserved at the site.
PUBLIC HEALTH AND ENVIRDtWENTAL ASSESSMENT
Through a selection process outlined in tne draft Supertund PuMic HealtnEvaluation Kanual, several indicate) chemicals were chosenfrom the sample analysis results to represent the chemicals posing thegreatest health concern. This selection process was intended to simplifythe data evaluate v^ Jxxit seriously crroproraising the validity ot thoconclusions whic. were drawn. Ihe procedures employed in the indicatorchemical selection pvocess are described in Appendix L of the RI Reportand the resulting indicator chemicals include the following contaminants:
• Arsenic0 Bariun
* Oiromivjn
-6-
-
N P D 001723 5 9 0 0 3 4
KINTOMCOUNTYWATINIMTAKI/
ILICTMICTNANIMI I t lON
LINI
COUPOIITI tunrACi SOIL• A U F L I M Q IOC*.TIONt
• UBCURPACI 90)1.• A M F L I M O L O C A V I O N S
O M A I SUMFACI SOILS A W P L I N O L O C A T I O N
«00'
DISTRIBUTION OF SOIL CONTAMINANTSNEWPORT DUMP SITECAMPBELL COUNTY, KENTUCKY
FIGURE 15
R3USCCFFORATCTM
i A HaHtourton Company
N P D G01 0317275 9 0 0 3 5
• Nickel
• Benzol a Jpyrene
• Toluene
• Polychlorinated biphenyls
TRANSPORT MEDIA
Contaminant migration is dependent on the physiochemical characteristicsof the contaminant combined with the specific migration pathways existingat the site. The evaluation of contaminant transport in each medium,based on the data collected during the RJ, identified the migrationpathways and formed the basis for the evaluation of potential routes ofhuman exposure.
The waste material aampled beneath the clay cap at the Newport Dump sitecontained a wide array of chemical contaminants. The chemical groupsincluded metals, organic solvents, polycyclic aromatic hydrocarbons andchlorinated hydrocarbon';.
The chlorinated hydrocarbons found in the waste material (SS-3A) includedPC&-1242, PCB-1260, and 4,4'-DOO. These contaminants would be expectedto remain in place with little potential for migration due primarily totheir hydrophobic nature and adsorption to the subsurface soils or wastematerial. Also, they would be expected to remain essentially unaffectedby biodegradation. During the RI, no PCfis or 4,4'-DOO were detected inthe subsurface soil beneath the fill material or groundwater herreath thesite. The wide variety of PAHs found in the waste material, primarily inthe area west of the culvert (SS-3A), nave varying physical characteristicswhich affect their environmental fate. The lower molecular weight PAHs(less aromatic rings) such as naphtnalene and pyrene, have higher vaporpressures, higher water solubilities, and are subject to greaterbiodegradation than the heavier PAHs (benzol«)pyrene and benzofghi)pyrene).In general, metals such as arsenic, barium, chromium, and nickel wouldnot be expected to migrate significant distances in predominately claysubsurface soils. However, the silty clay soils at the site have lowcation exchange capacity (CEC) values which are not conducive forattenuating these metals. Therefore, the metals would be expected tomigrate, to sera, degree, with the groundwater. Since the predominantgroundwater flo- die-.Ttion at the site is horizontal rather than vertical,the majority of -nesj contaminants alv. ild be evident in the shallowgroundwater and leac-jte breakouts. As would be expected at the site,elevated metal levels were observed in shallow groundwater and in leachatesamples. The deeper groundwater, however, showed only sporadic increasesin metal levels.
Compounds such as benzene and toluene which were found in the wastematerial (SS-3A and SS-4A), are very volatile, soluble, and can bebiodeqraded. Under the conditions at the site, they would be expected tomigrate in tne groundwater ana in the subsurface soils.
-9-
NP 001 001723 5 9 0 0 3 6
Toluene was detected during tne RI in the subsurface soils Beneath thewaste (SS-4B) and in offsite subsurface soils (SS-i, SS-6, and SS-7).Additionally, toluene was detected in both the shallow and deep ground.within the landfill (SW-2 and OH-2, respectively), and in the upgradier:i_groundwater (DW-1).
PCBs were only found in the surface soil at one location at the site.Both PCB-1248 and PCB-1254 were detected at the surface sample S-2 in aold trench used for leachate collection. However, none was found in theculvert outflow, the unnamed stream, or the Licking River.
EXPOSURE POIWTS
The Newport Dump is located in a mixed land-use area with uncultivatedfarmland and an industrial development to the north, a snail farm to theeast, and natural vegetation associated with an named tributary of theLicking River to the south.
The nearest dwelling is approximately 360 feet southeast of the site onState Jtoad 9. Other residences are located along Banklick ffoad to thenorth and Vine Street to trv south, conprising an estimated totalpopulation of 50 in the immediate vicinity of the site.
Because of its ready availability, the region relies to a great extent onthe Ohio River and its major tributaries for its water supply. Residentof Kenton and toone Counties are served by the Kenton County MsterDistrict. The district, which regularly serves a population ot 75,000operates two water treatment plants: the Ft. Thomas plant, wnick Irawsfron the Ohio River, and the Tayior Hill plant which has its intake onthe Licking River 2bO feet downstream from the site. Residents in theinr>ediate vicinity of the site are served n<p the Csnpoell County WaterDistrict.
In contrast to surface water use, groundwater use in the site vicinity,if it exists, is extremely limited. Discussions with local waterauthorities, county extension agents, and other local officials, failedto identify a single user of groundwater within a one-mile radius of thesite. A door-to-dcor survey of residents north and south of the siteconfirmed that residents either utilize municipal sources or utilizecistams. Jtost resid^ntr? utilise municipal sources.
Because no ground JBtei users could be ident. fied, the principal humanexposure point associated -rith the site is the withdrawal of surfacewater £rcm the intake on the Licking River. This intake could be affectedby entering the river either through groundwater discharge or via surfacerunoff. Such an eventuality would place the customer bases of the Kentonand Campbell County Vteter Districts, or 90,000 individuals, at risk.Rjssicle exposure route to subsurface soil contaminants may includeingestion, inhalation, and dermal contact. Irvgestion may taka the formof direct exposure through drinking or eating materials which are con.ami-nated; Direct inhalation exposure results fron breathing air which hasbecone contaminated through volatilization, release ot gas phased conta-minants, or entrainnent ot airborne particulates.
-10-
18'-13
C01 0017295 9 0037
Dermal Exposure may result from direct contact with, soil or other material,or may involve indirect contact such as the transfer of contaminants toclothing and furniture, and subsequent skin contact.
SURFACE WATER CONSUMPflON
The Licking River is one of two sources of drinking water for theapproximately 75,000 citizens of Kenton and Boone Counties served by theKenton County Water District.
At present, no data exist which demonstrate a relationship betweencontaroinants detected onsite and contaminants detected in the District'swater intake or in the Licking River. Of the seven indicator chemicals,only toluene v»as detected in the raw water sample collected at the TaylorHill filtration plant. Thus, while exposure to hazardous materialsassociated with the site via consumption of surface water is a potentiallyconplete exposure pathway, it remains as yet an undemonstrated publichealtli concern.
GBOUNDKATER CONSUMPTION
Although traces of five of the seven indicator chemicals were detected inthe groundwater from one or more of the permanent monitoring wellsinstalled as part of the RI, no active domestic or industrial wells couldbe located within a one mile radius of the site. Thus, consumption ofcontaminated groundwater does not appear to represent a complete exposurepathway.
AIR AND SUBSURFACE GAS INHALATION
Since volatile contaminants were not detectod in the arrbient air or inoffsite boreholes using filed monitoring equipment during the RI, itappears that the entrapped gases beneath the cap are not being released ormigrating offsite. Certain remedial action alternatives may, however,disturb the soil and create emissions of contaminated dust or free previouslytrapped gases. The population at greatest risk of exposure would beworkers and observers onsite during the r»* edial action if adequate safetymeasures were not observed.
DIRECT CONTAC t
No quantitative data are available on the size of the population potentiallyexposed to site-related contaminants via direct contact with contaminatedsediment or soil. However, because access to the site is not restrictedand because seme of the contaminants which were detected, notably PCBs,have known dermal penetration properties, accidental exposure couldoccur.
-11-
•V/S4S'
N P D C01 0017305 9 O C 3 8
FEDERAL AND STATE APPLICABLE OR RELEVANT AND APPFOPRIATE REQUIREMENTS
The applicable standards and criteria are shown in Table 7. Most of tindicator chemicals were detected in the shallow groundwater at the si
Exposure to groundwater contaminants would have to be through groundwaterdischarge to surface water and withdrawal of that water at the TaylorMill filtration plant. Therefore, in compliance with SARA Section 121(d)(2)(A)(ii) alternate concentration limits (ACL's) have been presented inTable 8. These limits are based on actual groundwater contamination andensure a safe baseline limit in deciding if any future remedial actionwould be necessary.
As stated previously, the dilution rate for groundwater discharge to theLicking Paver was over 40,000 to 1. Since land use controls could beimplemented to prohibit the installation of onsite drinking water supplywells, it would be considered conservative if the alternate concentrationlimits of contaminants in groundwater were set at ten times that whichwould protect drinking water supplies as shown in the table. FinallySubtitle D, RCRA; Managing Solid Waste will be the appropriate standardgoverning the closure of this facility subsequent to the implementationof the Remedial Action.
As discussed previously, the possibility of direct contact with thesurface soil or sediment cannot be precluded. Sine* long-term contactis not expected on a regular basis, conservative acceptable levels ofcontaminants could be set at background levels. Since benzo(a)pyrene andPCBs were not detected in offsite background samples, conservative acceptablelevels can be set based on the potential but unlikely ingestion of soilor sediment. The acceptable levels of contaminants for surface ««il orsediment are shown in Table 9. These levels were based on maximon observedconcentration in offsite background soil and sediment samples and 10~&risk level of cancer for benro(a)pyrcne and PCB.
ENFORCEMENT ANALYSIS
Currently the only viable parties for sane type of enforcement action arethe City of Newport and the North Kentucky Port Authority. Both partieshad acquired ownership of the site befcre the remedial investigationensued. North Kentucky Port Authority is the current owner of the site.To date potential responsible party research indicates there are notransactional r»corr«« f-ut identify users of the site. Since there wasno charge to &m? a', th-j site, then no dap tickets, Invoices, etc., weredeveloped. Parting stickers may provide the only record of who hadauthority to access the site. Research indicates that aH Newport cityindustry during the term of operation of the Newport dump would have usedthe site to dispose of their waste. Due to the uncontrolled nature ofthe site as evidenced by lax enforcement of the resident-only use policyprior to 1972, it also is possible that other non-resident users existed.With the onset of a stricter enforcement posture in 1972, it is possiblethat previously unstickcred site i—?-s would have obtained such stickersin 1972.
-12-
6 2 0 0
M I?'II \\\13 ?;iJP T|f**• ?li4VI
3!
J f-.a
rr 0 0
?•
I i I I C I I §
5o3i i i i
8 * ?:
'?
I
2 C g s a
5 - i- J 38 r-i. a - * • . e i <*
TOO
TABLE 7AQUATIC ire CRITERIA
NEWPORT DUMP SITECAMTUUL COUNTY, KENTUCKY
ooo
Toluene
CLEAN WATCH ACT KEKTL _.;Y ADMNBTRAT1VE MCUtATlONS
V•
t-clcator
A,-tj'.!c »J
B«rlun
Chrwniuot *i
Nickel (c)
ten (vt/v
e.n 21X 1,100
<««/0
MdotclAt)
lOO(toulCr)
0.01%
I7.X10
0.001*
-JEa-)ro
(«1 '?r,f«r 9*H«r criteria citabllrfMd undrr provlilont el lt« Ck*n W«tw Actor 1177 (PL 1J-2I71.t^,.lrfwd in Fc4««l Re^itlw mU-W7». Nevemtw 21. ino.
''-) Kentucky A4mlr4ttr*tlr« McfuUtloni, Title Ml, CtMptCf ), «n«bll*«d under provliiani ofR«viM4 Jtatuin 72«.020 «nd 22I.OM.
.xu «|ui«*l<n1 to X) ntf/l CiCOj.
en
vo
oCD-F^O
NHP c-01 0017335 9 0 0 4 1
TABLE 8
ACTUAL AND PHOJBCTEDCONCENTRATION LEVELS
Indicator Newport Sited) Proposed(2) Health Base(3) Projected DiluteeJiemicals Groindwater Concentration Alternate Concentration Criteria rag/1 Concentration ir
mg/1 Limits tng/1 Licking River m;
ARSENIC
BARILM
CHfOULM
NICKEL
BEN20(a)PYRENE
TOLUENE
PCA
.064
7.4
1.5
2.4
-
.017
-
.64
74
15
24
-
.17
-
.05(MCL)
KMCL)
.05(MCL)
.013(WQC)
-
.014(WQC)
-
1.6 x 10-
1.85 x 10-
3.75 x 10-
6 X 10-
-
4.2 x 10-
-
(1) Actual concentrations ooserved in the groundwater discharge to the Licking River.
(2) These concentrations are ten tunes those presen«-«J in Column (1).
(3)' »" •<»• s listed in Table 7.
(4) Projected Concentrations based on 40,000 to 1 dilution of values listed in column ( 2 ) .
NPD C01 001?34
5 9 0 0 4 2
TABLE 9ACCEPTABLE LEVELS OF CONTAMINANTS
SURFACE SOIL AND SEDIMENTNiWPORT DUMP SITE
CAMPBELL COUNTY, KENTUCKY
IndicatorCnemical
Arsenic
Bariun
Chroiuun (total)
Nickel
Benzol A JPyrene
Toluene
PCBs
Acceptable Level ofContaminants (mg/kg)
14
200
24
61
1.00
0.014
2.7
Basis
BKGD
BKGD
BKGD
BKGD
Irgestion
BKGD
Ingestion
BKGD Maximum observed concentration in off site background soil orsedunent samples.
Ingestion Concentration calculated based on 10"6 risk of cancer frotiingestion of soil. See Appendix M.
NPD C01 0017335 9 0 0 4 3
It also is apparent that fonner site operators may recall the identity ofspecific unauthorized site users. The other city officials interviewedindicate previous site operators that would be aware of the identity frany such users.
ALTERATIVE EVALUATION
The purpose of the remedial action is to mitigate contamination at theNewport Dump site in order to remove potential risks to human health andthe environment.
Each remedial alternative developed for use at the Newport Dump site wassubjected to an analysis to determine its effectiveness in addressingsite problems. This analysis also included an evaluation of the publichealth and environmental risks both during and after implementation.
Table 10 and 11 presents the six remedial action alternatives evaluated forthis site. Each of the six alternatives were evaluated based upon technicalconsideration, institutional issues, environmental issues, public healthimpacts and cost criteria. The results of the final evaluation are givenbelow.
Alternative Is No Action
If this alternative were selected, no additional remedial activites or•onitoring would be undertaken at the Newport Dump Site. This alternativewould not require any operation and maintenance or th« acquisition ofpersonnel and materials. The inplementation of this alternate wxildnot address any impacts resulting from the site contaminants. Contaminantmigration could occur unnoticed and without means of control. Groundwaterdischarge of contaminants above health based standards from the shallowacquifer into the Licking River has been documented. This option doesnot satisfy any currently applicable or relevant State or Federal (RCRA)standartds for the closure of a site. Based upon the above considerationof public health, this no action alternative has been rejected.
Alternative 2: No Action - Monitoring
All aspects of this alternative are the same as those described underAlternative 1, wit. *hc exception of periodic sampling, analysis andreport preparation unoming groundwater quality, surface water and soilcontamination. Sasrplirr- analysis, and report preparation would be performedserai-annually. Sampling and site visits would mean that the site andgroundwater will be monitored and not go unnotice. Similar to alternative1, no remedial action provides no additional protection to the publichealth and environment. Based upon consideration, this no actionalternative has been rejected.
-••3-
Du
NPD C01 Q0173G
h**?
li
aj»>•cc
1S['il> ft
11
•si
if,in8 • t < ":"111 *-5j]^| illih§ i i i
I IJ- *i e -I
5 9M* '-I- |ip i 5 2 * 2 3til lil Is
0 0 4 4
ui•-,1
•3
M if4 * 1 * S R ? | »J S • T 3 " - • -v
I?! Ill 111
] I
|r {jrH lil!* JM'ii •i.Is! }^•i] in
15i
-i!
iii ijif? H fII « 1^rl fj J,Hi i! ^|£5 |5 Jr.
TABLE //COST SUMMARY OF REMEDIAL ACTION ALTERNATIVES
NEWPORT DUMP SITECAMPBELL COUNTY, KENTUCKY o
o
Time to
1. No Action
2. No AcHoo-Monitorlng
;.'oni' :>ring, Leachate Collection,and Degrading and Revegetation
$. Monitoring, Leachate Col "ret ion,degrading and Revegetation,Capping, ana ii«s collection
5. Monitoring, Excavation, andSolidification/Stabilization
6. Excavation and Offsite Disposal
4 weeks
10 weeks
1.3 yean
3.2 years
3.2 years
DesignLife
30 years
30 years*
30 years
(1) Time reflects the me of a unit crew.
(2) Costs are shown In present worth dollars for comparison.
0
7,000
316,000
15,727,000
30 years 39,0*8,000
30 years 178,836,000
0 A MCost
0
26*,000
398,000
ToulCost
0
271,000
914,000
1,448,000 17,175,000
150,000 39,198,000
178,836,000
OOK*-aCO-.1
Cn
MD
CDCD
en
NPD C01001733 5 9 0 0 4 6
Alternative 4: Monitoring, Leachate Collection, Regrading andReveoetation, Capping,- and Gas Collection
This alternative involves the placement of a multilayered cap c _-.eentire 39 acre site, repairing the leachate collection system and a gascollection and treatment system which would control gas migration andits related hazards. Implementation of this alternative would serve toclose the landfill in compliance with the requirements under RCRA 40 CFR264. This alternative has been rejected because the installation of aRCRA clay cap would not be cost effective ($17,175,000). The amount ofsurface contamination is minimal and a decrease in grtxndwater dischargeto surface waters can be affected by other means. The same affect forminimization of leachate generation can be accomplished with regradingand revegettticn and repair of the leachte collection system.
Additionally both the City of Newport and the Kentucky Port Authority doplan sere type of reclamation and construction work on the 39 acre site.The RCRA cap is composed of artificial membranes that are not amenableto the proposed land renovation planned by the local authorities. Thecap would not tolerate any type of heavy construction and its integrity,design life and usefulness would be threatened to a substantial degree.Also due to the min'-al levels of organic vapor venting from the subsur-face, a gas collect ion system is not warranted and premature at thisjuncture of the rerodial process.
Alternative 5: Monitoring, Excavation, and Solidification/Stabilization
Implementation of this alternative wxild require extensi'~ excavation andthe use of a silicate-based solidification stabilization process. As artsult of these two procedures, separation of the waste material, backfilling,and regrading and revegetation would also be necessary. A monitoringprogram, would be instituted for the collection and analyses of groundwatersarrples to determine the long-term effectiveness of the solidificaiton/stabilization process.
The Newport Dump site covers an area of 39 acres and is estimated to havea total volume of 1,078,000 cubic yards of waste and contaminated soil.Based on lithologic logs of site boreholes and historical photographs,approximately 1,509,000 cubic yaids would have to be excavated. Thedifference ir vclumes is accounted for by the cover that presently existsat the site. The -tepth of excavation would vary widely at tho site,ranging from '.' fe- t in portions of :he eastern section to 40 feet in thewestern section or the landfill. The actual depth of excavation would bedetermined visually with confirmation sarplirsg at the bass of the excavation.
Though SARA dictates permanent on-site detoxification of hazardouswaste, the large amount of soil to detoxify would require extensive andunwarranted waste handling practices during clean-up. The Implementationof this alternative would have the potential to significantly impact~jblic ho-.lth. During the excavation procedures, the opportunity foroffsite rr, qration of contouii>ant3 would be greatly increased. Pathwaysfor this r-igration would include airborne particulates, gas emisssion,and sur!!.. .• runoff.
IBS
N P D 001 001730 5 9 0 0 4 7
Receptors in the area of the site would be susceptible to ir -, orgas as well as contaminant-laden participates, the ingestion -iculates,and direct contact with wastes.
Anotner tactor that could potentially impact puolic health would be theonsite storage of the waste material prior to the solidification/stabilizationprocess. Storing the waste would increase the cnance of contaminant lossdue to volatilization and surface runotf .
Implementation of this alternative should, in the long-teen, eliminatethe public health concerns associated with the landfill. This would beachieved by solidification and stabilization of the hazardous materials.However, there could be potential adverse health effects associated withthe possible leaching of contaminants from the solidified and stabilizedwastes. Tne low levels of contaminants prssentiy in the groundwater wouldcontinue to migrate off site until the site had been self-purged. Adcli-tionally this remedy would cost 540 million dollars to implement. Thisexpenditure cannot be justified based on the low level potential healththreat the site poses to the ccramunity. Based on these considerationsthis alternative _s rejected.
Alternative 6: Excavation and Offsite Disposal
The components of Alternative 6 would be excavation with separation ofthe waste and disposal in an offsite landfill, backfilling, regrading,and revegetation. The alternative would retire disposal of the wastematerial in an offsite EGA-approved RCRA landfill. This would be carriedout concurrently with excavation, separation and
Implementation of this alternative would result in the excavation ofapproximately 1,509,000 cubic yards of waste and contaminated soil. Theexcavated material would be separated, and the 788,000 cicic yards ofhazardous waste and contaminated soil would be transported offsite to anEEA approved RCRA landfill.
There are presently tvo oftsite comraerical landfills in Region IV incompliance with RCRA requirements. These landfills are in Bnele, Alabamaand Pine Wood, South Carolina. Transportation would be accomplishedusing 20-cubic yard trucks and would require 39,400 loads for completion.The site <oulti be backfilled with the separated nonhazardous material andoffsite so '. C.-J he regraded and revegetated .
Disposal in an offsite landfill is a permanent remedial action and wouldprovide a very high Iwel of environment and public health protection.Bowever, the alternative directly contradicts the intent of the new SARAmandates. SARA calls for the Agency to prefer remedies that use on sitetreatment to permanently and significantly reduce the toxicity, mobility,or voluroe ot wastes over remedies that do not use such treatment. Inaddition, SARA requires that the Agency select a remedy that utilizespenaarv-nt solutions and »' ".Trr-ativcs treatment technologies, or resourcerecovery technologies, to the maximm extent practicable. Excavation arvl
^ disposal do not comply with the intent of the new Superfund
-15-
.'854
NPO CQl 001740 5 9 0 0 4 8
Additionally due to the minimal extent of contamination at tlx? ^ite suchan expensive remedial action (179 Million oollars) cannot be --_!.Based on these considerations this alternative has been rejec
Alternative 3: Monitoring, Leachate Collection,tegrading and Revegetation
This alternative has been selected as the recoranended alternative actionfor the Newport Dump Site. This alternative selection does not fullycomply with certain portions of SARA S 121. SARA emphasizes remediesthat must utilize permanent solutions and alternative technologies orresource recovery technologies to the maxi""" extent practicable. Since1) Minimal contamination has been found in the surface soil and groundwaterdischarge to the surface water, and 2) one million cubic yards of solidand hazardous waste is buried at the site, then this remedial actionselected is adequate to the "maximun extent practicable" for this site.The selected remedy is protective and cost-effective, attains ARARs andis a practicable solution which substantially reduces the public healthand environmental threat to negligible levels. This alternative wouldinclude the folio.ing remedial action components:
f
16)
1) ECNITOMNG
Ihe primary health concern at the Newport Dump Site is that site contaminantsmay migrate to t^e Licking Ri«»r end en<-er the raw water intaXe 250 feetfrom the site. Since various confaminants were detected during the RemedialInvestigation (RI) in Uie groundwater and surface soil near the LickingRiver bank, there is a potential for these contaminants to discharge intothe Licking River. As a result of this concern, both groundwater andsurface water would be monitored.
Six of the groundwater monitoring wells installed during the RI would besampled to determine the levels of contaminants being released (see FigureThe groundwater samples from location CW-1 and EW-3 would be used tomonitor the groundwater quality upgradient of the site. The samples fromDW-3 would also provide data on possible contamination migrating underthe site from the non-ferrous ~uto parts landfill. Groundwater samplesf rcm locations SW-2/DW-2 and SW-5/DW-5 would provide information ongroundwatt- ^vj*.1 ity at two depths beneath the landtill. The samplingprogram for grv ndwater would ir^lude quarterly monitoring at the fourlocations tor tnree years to establish baseline conditions and then theprogram would be reevaluated for changes in analyses and sampling frequency.
Surface water would be monitored at three locations adjacent to the riverbank shown on Figure 16 to determine the effects, if any, of contaminantsentering the Licking River. The surface water at location LR-1 and LR-2would be used to monitor water quality at the Kenton County wafer TreatmentPlant intake. The sampling program for surface water would include quarterlymcnitcrirg for three yc^\> ^rri then the program would be reevaluated forchanges in analyses and sampling frequency. Initially, the surface watowould " .- analyzed for the complete Hazardous sunstance list.
-16-
.'#55
N P D CO! 001741 5 9 0 0 4 9
KINTONOUNTY
WATIdIMTAU/
tLICTHICTRkN«MIS«ION
LINI
L I I Q E K DVATtR
• •«• HOHITOHIH* WILL^- aKOUMDWATIM KOHITOHIKO VfILL
OCATIOK
o mo' MO* «M' *oo'
MONITORING LOCATIONSALTERNATIVES 2 AND 3NEWPORT DUMP SITECAMPBELL COUNTY. KENTUCKY
FIGURE ft
A Haftburton Company
•v <i T •*«»»'! *•*
NPD 001 001742 5 9 0 0 5 0
A monitoring system to detect gas migration would be instituted "•*->•onitoring wells would be installed along the site's northern .to supply gas migration information potentially affecting the _ i a lpark and residential area located north of the landfill. Since critmajority of waste was reportedly deposited in the western portion of thelandfill, a gas monitoring well along this border would provide infonntionconcerning the landfill potential for gas generation. An additional gas•onitoring well vould be placed on the site's eastern boundary to detectany migration toward the residence located adjacent to the landfill (seeFigure 16).
Gas monitoring along the site's southern boundary was not considered dueto the buffer zone supplied by the unnamed stream as well as the absenceof receptors. The sampling program for gas would include quarterlymonitoring for three years at which time the program would be reevaluatedfor changes in analyses and sampling frequency.
Annually, the quarterly results of the sampling and analysis program wouldbe averaged and compared to the acceptable levels of contaminants establishedfor groundwater and surface water in the public health evaluation. Ifany of the indicate.- chemicals exceed these acceptaDle concentrations onan average ar^nual basis, the proposed remedial action at the site would bereevaluated by the EPA. If any volatile gases are detected in samplesfrom the gas monitoring wells, the need for monitoring ambient air wouldthen De evaluated. The time and procedure for these evaluations shall bedone in accordance with the statutory mandates of SARA.
2) LEACHATE COLLECTION
Trie effectiveness of the present systera which was completed in 1980, hasbeen of concern. This concern has been generated fron the inability ofthe system to f i l l the holding tank located in the southwest corner ofthe site (see Figure 17). It is also believed that a portion of theleachate may be entering breaks in the 60-inch culvert that runs from thenatural drainage area north of the site to the unnamed stream along thesite's southern border.
Therefore under this alternative a properly operating system for thecollection cf leachate would be provided. This would i-ivolve the repairor replaoatu't c* the existing system and the construction of additionalcollection 1: ,»es along the norther t border of the site. Figure 17 showsthe location of -he existing system and the proposed expansion. Thiscollection system would prevent the migration of contaminated leachate tothe unnamed stream. Licking River, and the area nort/i or the site.Included as part of the leachate collection system would be the installationof a collection basin and punp to remove water from the natural drainagearea located northeast of the site. Removal of this water would greatlyreduce infiltration into the northeast face of the landfill and ~ubsegue. •:leact^tr,' formation. In addition, it is likely that subsidence or clogginghas irajx.-c.xJ U>e ability ut. aic IcachaLe collection systan to functionproperly. To bring the present system to standard, it would be acc^sr-edarc! f lu . .«d using high pressure, jet-cleaning equiurent. To excess _.-.osystem, permanent manholes •n'.'.lcl bo installed at SOC-feet intervals.
-17-
1 U 3 I
4PD C01 001743 5 9 0051
Failed portions of the system would be excavated and new a collectionline retrofitted, to eliminate the potential loss of leachate to60-irch corrugated metal drainage pipe, the culvert would be sealoeacn end with a concrete bentonite mixture. The collection systemextension along the northeast border of the landfill would consist of1,000 feet ot line and an additional 5,000-galion fiberglass tank. Thesystem would be constructed by digging a trench 2-teet wide and 9-feetdeep and placing a 4-inch perforated polyvinyl chloride pipe on a 4-inchbed of sand. A 2-foot drainage layer of gravel would be placed over thepipe and covered by a 6-inch layer of graded sand. Finally, the trenchwould be backfilled to grade with canton fill (see Figure IB) .
The system would be placed along the 515 foot (amsl) contour at a slopeof 2 percent. te>th of the leachate collection tanks mentioned abovewould be equipped with purps to lift the leachate to a 20,UOO-gallon tanXlocated on the surface of the landfill. With this arrangement, inundationby Hood waters would be eliminated and access would be available yearround. If analyses results determine that leachate treatment is necessary,an appropriate treatment scheme would be determined by conducting a pilot-scale study. If treatment is not necessary, the leachate would be punpedto trucks and transport. <d to a nearby treatment plant.
Storm drainage would be controlled by installing a precast 1,000 gallonconcrete tank at the toe of the landfill's northeast face. If. necessary,minor grading would be done to promote drainage to this tank. A centrifugalpunp with a float control valve would be used to renove the water fromthis tank and transport it through a 6-inch pipe across the top of thelandfill with discharge to the unnamed stream.
3) R££RADIM3 AND REVEGETATION
In order to stabilize and prevent further erosion of the northeast landfillDank, regrading would be necessary. In addition, to provide protectionagainst infiltration into the bank, two feet of clay would De includedas part of the bank stabilization process.
Presently the terrain is extremely variable with sooe steep eroded areas.The final slope would be reduced to j constant 5 to 1 change in elevation.He vegetation would be required followirrj regrading in order to stabilizethe area. Alterations to the bank would be completed at the same timethat the extended le-r-.hate collection system lines, are being installed.
Local materials would be used for rough correction of the slope prior tothe application of the clay layer and to supply the final cover for theestablishment of vegetation. Figure 19 shows a cross section of theexisting grade and the amount of material that would be necessary toachieve the constant grade.
4) SUBTITLE D: Municipal Kasi"" landfill
Ftor the Newp->rc Dump site a distinct separation ot RCRA Subtitle C(Hazardous Waste) and Subtitle D (MunicipaJ Waste) is d i f f i c u l t to
-18-
i a DO
^ ^ ^ ^ ^ ^ ^ •i ^B^HB^B^ HB^ I
NPD C01 00174 5 9__005? - . ' , : . ; 'fi
EXISTING AND PROPOSEDLEACHATE COLLECTION SYSTEMNEWPORT DUMP SITECAMPBELL COUNTY, KENTUCKY
FIQUR n"1
——I IS i~ ^^f^ ^»"_J CORPCDRATCA HaKiburton Comp;
/ nr~ ni u 3
U C01 001743 5 9 0053
FINAL DMFT
COMMON ULLVAMIABLI
• AND
PGNFONATI* * ««AVIt
4* tAI
CROSS SECTION FOR DESIGN OFLEACHATE COLLECTION SYSTEMNEWPORT DUMP SITECAMPBELL COUNTY, KENTUCKY
FIGURE
A Haltourton Comfjany
00174:
• 90-1
• oo•o
5 9 0 0 5 4
ro eo 110 130
110
CROSS SECTION OF NORTHHAST BANKNEWPORT DUMP SITECAMPBELL COUNTY, KENTUCKY
,n\
IBS
NPO C01 001747 5 9 0 0 5 5
ascertain since the site contains both surface ?.nd sifcsurface soil c^-r —cnination which is similar to the contamination conrnonly found in m:waste (see Table 1). The regulatory framework established under Su:C (40 CFR Part 260-267) was designed to protect hunan health and theenvironment fron the effect of unpemitted disposal resulting in theimproper management of hazardous waste, However, due to the minimalamount of surface contamination and migration of hazardous waste offsiteand since the remedial alternative selection does ccmply with SARA S 121to the "maximum extent practicable" then any closure or post closurerequirement can be determined by Subtitle D "Criteria for Classificationof Solid Wsste Disposal Facilities and Practices", ccrnonly referred toas the "Sifctitle D Criteria" (40 CFR Part 257).
The Criteria are used as a (1) set of minimum technical standards withwhich all Federal and non-Federal solid waste disposal facilities mustcomply, and (2) a means of determining if a solid waste disposal facilityis an oprr dump. The criteria cover eight areas: Floodplains, Fndangeredspecies, surface water, groundwater, waste application limits for landused in the production of food chain crops, disease transmission, air,and safety. These criteria should be examined and implemented during andafter the completion of •.-« remedial action. The State of KentuckyDepartment of Environmental Protection has been delegated this responsibilityand should adhere to the regulations under 40 CFR Part 256.
PUBLIC KEALTO EVALUATION
• Implementaion Phase
There would be risks involved with the construction of the leachatecollection system and the regrading ot the northeast slope. The hazardswould include the potential inhalation of volatile contaminants duringconstruction of the leachate collection system and the ingestion of contaminateddust generated from surface regrading activities. Remedial personneldigging the trenches and installing the leachate collection system mightbe required to wear level B respiratory protection (selfcontained breathingapparatus). Surface contamination is expected to be minimal and would berestricted to relatively small, isolated portions of the landfill.Additionally, the period of exposure ~ould be restricted to the constructionphase, which is erpected to be only 10 weeks. During this period,workers could be .--ctorted from significant exposure through the u<e ofreadily available ; rsd ccopted control * :chnolcgies.
The potential for exposure by offsite public receptors would be minimal,since no material would be removed fron the landfill. Constructionequipment moving offsite would be decontaminated at the sr.te exit, therebyeliminating transport of contaminant material offsite by this raechanisn.
+• Residual Risk
In terms of if. residual effect ^,. the public health, implementation ofthis alternative would eliminate the risks associated with the discfargeof ieachato tc che Licking River and eventually to the raw water intakedownstream of tJ-.e site. This alt r-jtive vruld result in stabilizing a
-19-
'QC ~~'OOC
NPD C01 0017435 9 0 0 5 6
downstream of the site. This alternative would result in stabil'presently steep and eroding slope, while preventing the possibii:waste exposure and reducing infiltration.
Implementation of this alternative would also provide an early warningsystem (monitoring of gas and water) should site conditions change.
ENVIRQt«EWIAL EVALUATION0 Implementation Phase
The alternative would require minor excavation and surface activity, butany impact on the regional environment from this action should be negligibleif good work practices are employed.
• Residual Risk
A significant decreac 2 in the risk associated with the site would beachieved with the iraplaiientation of this alternative. Sensitive environ-mental receptors in the unnamed stream and Licking River would be relievedof the potential stress resulting from the discharge of leachate.
INSTITUTIONAL EVAUATION
The institutional requirements for monitoring are shown ir ^Sble 7 andACLs are shown in Table 8 and 9. Implementation of this alternative mightrequire that the leachate be pretreated prior to discharge to a localsewage treatment plant. There are federal and state guidelines ooncernirqmaximum slopes for landfill banks that would be met during the regradingprocess.
The City of Newport and the North Kentucky Port Authority do plan torenovate and construct on the site. Regrading and revegetation will beadaptable to any type of future work at the site as opposed to a RCRA capinstallation. However, at the sate time, heavy construction and earthmoving can and will reduce the design life of this remedial action afterthe implementiiicM phase. Therefore, future renovation activities will haveto be de!»y»<i tv»r "- vears. after the remedial action has been implemented.
After 3 years wnen monitoring does reveal innocuous levels of contamination,then some type of agreements, orders or covenants will have to be establishedanong the local and state governments, anc' EPA to establish and maintainlimits and standards to the type of land renovation the site can tolerateand remain stable. Alao the local authorities nust promulgate iranediatelya mandate on permanent land use restrictions i.e. prohibiting the drillingof any typo of groundwater well or sifcsurface equipment. The fentu=kyState Department of National o^sources and Environmental Protection shallbe responsiDle in ensuring that all municipalities comply with the 3 yearmoratorium on future land use atter remedial action is completed.
-20-
1853
NPD col 001740 5 9 0 0 5 7
COST EVALUATION
Capital costs for the installation ot the gas monitoring wells, c.:~- leacnatecollection system, and regrading and revegetation would t>e $516,uuu.Operation and maintenance costs vould include routine inspections of theleachate collection system, all landfill slopes, and the monitoring.This vould result in annual operation and maintenance costs for the first3 years of $63,000 and for years 4 througti 30 of $35,000.
The present worth value for the operation and maintenance costs for 30years at a 10 percent discount rate would be $398,000 while the totalcosts vould be $914,000. Costs necessary for personnel, equipment, andlaboratory analyses can be found in Appendix R of the RI Report. Thecapital costs for the leachate collection system would consist of materials,equipment and labor, engineering, and health and safety. A sensitivityanalysis was performed on the installation of tfte leachate collectionsystem with 20 percent variation in the materials and labor to upgradethe present system causing the capital costs to vary from $74,000 to$110,000. A sensitivity analyses was also performed on the volune ofmaterial required for rograding. A 10 percent variation in the volunewould cause the capi .il costs to vary from $375,000 to $459,000. Addingthese factors to the sensitivity analysis would cause the total presentworth costs to vary from $820,000 to $1,008,000. The costs and sensitivityanalysis are sururarized in Tables 12 and 13. However, these costs can bereduced it leachate collection, regrading and revegetation are accomplishedby the immediate removal section (EHCS contract) of Rag ion IV, EPA.
ALTERNATIVE SUGGESTED BY PIBLIC AT PUBLIC MEETINGS
The majority of the participants at the meeting deferred to the judgementof both the Federal, and local officials who were undecided. The alternativerecommended by several residents of Campbell County was Alternative 1.Alternative 1 is both environmentally and politically unacceptable becauseit would not meet the cleanup criteria established by the EPft or State ofKentucky.
CONSISTENCY WITH OTHER ENVIRONMENTS LAWS
It is EPft Poli^-y ':o give primary consideration to remedial actions thatattain or exctt ; >r.^licable or relevant Federal environmental or publichealth standarc i.
State and local standards should also be considered, however Statestandards that are more stringent than federal Standards may form basisfor the remedy only i£ the result is consistent with the cost effectiveremedy based on Federal standards. The State may also pay the additionalcost necessary to attain the State standard(s).
-21-
' " 'T•n:
A. Sensitivity Factor*
Alternative Components
Monitoring
Lcachate Collection
Regrading and Revtgeta»fon
TABLE I)SENSITIVITY ANALYSIS - ALTERNATIVE i j
NEWPORT DUMP SITECAMPBELL COUNTY, KENTUCKY
Sensitivity Factor
Number of sample*
Materials arvj laborto upyaoe system
Vohvneof soil
•.10%
»20%
3tatiflcatlon for Kange
Contamination may spreador lessen
Condition of existingsy»ie»n
Volume to achieve necessarygrade was estimated
oH*
O
K*•a
B. Co«t VarUtlon (Present Worth Costs)
Capital Coat* 0AM Cost* <S) ToUl Variation (5)Alternative Camponwita
Monitoring
Leachate Collection
Regradln| ar>d Revegetatlon
Total Alternative Variation
HIlK
7,
110,
»»,
57*.
000
00-"
000
ooo
ZJOU ————————Low
7,000
7»,000
37J.OOO
tx.ooo
Hlch
373,000
3J.OOO
t.OOO
•32,000
—— TKw
30)
55
*
X*
High
,000
,000
,000
.000
3SO
163
463
1,001
,000
,000
,000
,0f
Low
3I2,!
129,
379, >
•20,
.
0
9
0
3
(_n
<~)olCn
7366
"PD C01 Q017G2 5 9 0060The environmental or public health laws which nay be relevant or apolicableto the site are:
- Resource Conservation and Itecovery Act (FCRA)The RCRA requirements for groundwater cleanup levels wiu applyto final action at the site. Any requirements for soil removaland disposal are not applicable.
- Floodplain Management Executive Order 11988 (E.O. 11988)
The purpose of this chapter Is to implement Executive Order 11988, May 24,1977, 42 F.R. 26951 entitled Ploodplain Management.
This Order requires the evaluation of potential effects of actions takenin a floodplain to reduce the risk of flood loss, to minimize the inpactof floods on hunwn safety, health and welfare, and to restore and preservethe natural and beneficial values served by floodplains.
- Clean Water Act (CWA)
The action proposed at the site by this document will complywith the n^juiretnents of the act since there is no surface watercontamination attributable to this site.
- Occupational Safety and Health Administration (OSHA) requirements.
Any applicable OSHA requirements will be addressed during thedetailed design phase of the selected alternative. OSHArequirements address such concerns as on-site worker safety andhealth. All alternatives can be designed to bt m full corpliancewith OSHA requirements.
- Groundwater Protection Strategy (OJPS)
The GWPS is an applicable standard for this site. The levelsreconmended by the Region IV office of Groundwater Protection arefound in Table 8 of this report.
- Department of Transportation
DOT requirements for movanents of hazardous wastes, will address anyleo-hate collected above the alternate concentration limits listed in
? b
- Other Applicable Laws (see Table 7)
OPERATION AND MAINTENANCE (O4M)
This remedy will require at least 10 weeks to implement with a designlife of 30 years. This time limit depends on the design, and operationof the ooerable units and future activity at the site. The operatingccets wi.M be for the implc.. ,itation and the operation of the leachate
-22-
IUU
N P D 0017G3 5 9 0 0 6 1
collection, regrading, revegetating, and monitoring wells and maintenanceof these units. After the remedy is implemented (10 weeks) the cc 1-will be to maintain the restored site, and periodic monitoring tcthe permanence of the remedy.
As required by CERCLA, 104 (c)(l) amended by SARA (PL 99-499),
l*the State will pay or assure payment of ...(ii) 50 percent(or such greater amount as the President nay determineappropriate, taking into account the degree of responsibilityof the State or political subdivision for the release) of anysums expended in response to a release at a facility, thatwas operated by the State or a political subdivision...."]
Response has been defined in SARA as a "Remedial Action" as including allconstruction and implementation activities until site reraediation iscompleted. Activities required to maintain the effectiveness of the remedyfollowing completion of the remeaial action is considered operation andmaintenance (O6M). If surface water or groundwater treatment is part ofthe remedy, only the first ten years of such treatment will be considered asremedial action; the remaining period of treatment will be a part of otMactivities. The State is required to pay 100 percent of all 0&M followingcompletion of the remedial action. EPA and the State may enter into anagreement whereby EPA would fund 90 percent of OfcM costs, for a periodnot to exceed one year, during which the remedy is determined to beoperational and functional.
SCHEDULE
The planned schedule for completion of the cleanup at the Newport Dumpsite is as follows:
March 27, 1987Sept«*rber 30, 1987December 1, 1987
Record of DecisionRemedial Design CompletedRemedial Action (Xrrences
This schedule is contingent upon the simultaneous availability of bothFederal and State funding. At which time, 6 months will be required fordesign and to select a contractor, after which approximately 10 weeks ofactivity will rul-ninate in a full stabilization of the waste source andgroundwater omitar-I nation at the site.
ACTION
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NPD C01 001754 5 9 0 0 6 2
Relations
LXMP siftCanprxil I CountyWilder, KentucKy
Introduction
For tne public record, this sumnary doeunents <:juestions and coanents raiseodurinj the puolic neetinj and comnent period on th- ri-'won't Dunp RemedialAction/Keasiin lit/ Stuly. Concerns rjis^J Jurioj t;w con.nont k>=rir>J tronMarcn 3, to i-larc'i ii4, v««jr^ ri3s;x>nUed to liy the KeT\edial Project iAanajer ott.'io NJw;x>rt Dono Si to.
At the ''larch 3, Nowp-jrt public ineeti^} tiie Gvnpi>:Ll county residents Jtvjlocal aJninistrat'jrs w.-ro interesto.1 in tn-.> tinal results ot tne investijation.'Die intonnation re9L»'- itory v^as place<i at the Ca.npLDell County Puolic Liorary,:<Jowport, KY. S'.veral "otewortny Cdnnents 'nado 3t the puDlic 'Tieetin; were:
1. Oit; resident stated tnat tr-><\ ] • ) ! ( } to 1 t)7y topner <inployees at t.vjsite oOser-'c-J nun-rous trucks dunlin; sealed Darrel'? at the site onj rojular basis. TIV2 qu^r.tion was rais-i-l Wiethjr the invest ijat ionwas dXLonsii/ i- e. 'V^vij ' i to reaii7.v.' the mpl icat. ions tn.- Djrial ot drjis
have t i v e or ten years iienco.
The stOsurtace area in ^uestio>'i w.v; in th..' western section otthe site. S.'veral wellpjints were untied in tiiat area andany leacimv) 'naterial tron the deteriorating druus or stiaii-j-jacqjiter was pinfjoint^J in tne -jrounjwater sanple analysis.SiiDsequent rene^lial desyn worn will explore tnis area turtn-.-rusinj 171 survey equipnent and orillinj Doreholes.
2. Another resident naned a [»ssiole eyewitness to sone ot the iliejaidunoinj that transpired Detore the site was closed in ly^U (set1 CourtRepi'jrter 1'ranscript) .
J. Pdolic 3d:;.inistrators ot the City ot r^e^Drt and Northern KentuckyPort. A.J.I1O- . -y raise^J cooeor""^ over sone ot the nore e<;>j.nsive alter-natives e. sol iuit icat ion ^ vJ excavation that were recoanended inthe teasioi.ity study. llv?y indicatevl tnat any rnnedy costinj asmuch as one 'nil lion dollars would tx> impossiole to ineet considermi.tile present financial status or the municipalities.
NPD C01 0017035 9 0063
Aside tron tiw presentation give Dy tPA, the aoove cotvnents were tiu . . jon discussion du rmj the question and answer period. The comnent i>_'riocitor the site wont tron March J, l^i!7, thru flares 24, 1987, one letter wasreceived tron a concerned c i t i zen . Tliis letter has been copied and attachedto th is report.
Letters and Responses addressing Community Concerns
1. Fechter and Seller, Attorneys at Law res idinj in C i n c i n n a t i , Olio wrote aletter to the EPA concerned w i t h Corner enployoes ot the Newport LUnpSite observirvj the d unpin.} ot saaled barrels at the site rrcra 1976 to1979. Th^se incwiuua i s noted that the dunp in j occurred in the western[xsrtion ot the site how^wr they haj ivo knowledge as to the content oftiv» barrels. The author ot the letter, Mr. Lewis Seiler telt that theremedial inves t iga t ion made no atten^t to discover the location andettects of uie pDssiDle l e a k i n j ot de t e r io ra t ing druns oelow the surtdce.It is Mr. boiler's rv- inion that a solection ot an alternative would DCpr-jtiature at this p. .T, u n t i l a caretul invest igat ion is made ot areaswnore the allojed drjos were buried.
L U r i n j the invest i jat i 'n w o l l ^ j i n t - s were ,jlacec m die <u'_-a utiare tiiedruns were p r e sunaDly ojned in t:ie su^sur raco . A n y d i s ' ' r je t ron tn>.-ouriod . tutorial was observed d u r i o j the sanpl inj o: those wellpoints. .'on a r n r u l e t tec ts ot t ins leacnmj .na te r i a l was noted in the surrace wateror the Kenton County i n t a K e . Further i nves t i ga t i on and mon i to r i n j ottins area w i l l take place d u r i n j t i io remedial desi.jn and runedial actionphase.
Remain ing Concerns
Otlier issues involve the f u t u r e land use ot tiie s i te proposed by the C i t y oLr».'wp^rt aixi the N K P A , and K e n t u c k y Stito t u n d i n j tor the selected remedialai t ; rna t iv<? , Alternat ive »3. Tie m a i o concern is that any pro;X3sed landrenovation and r e c l a m a t i o n at the site csuld cur ta i l the design l i te ot ther.-noJi.il a l t e r n a L . / e t Hected and a t t ec t tlie s t ab i l i t y ot the site-. A publich e a l t h and cnviro1 ien;,al e v a l u a t i o n uou J be necessary at ter the remedialaction is implemented and lx;tore ar iy t u r t he r ci^nstruction and land renovationtakes place at the Newport Dump Site.