74
FINAL REMEDIAL ACTION MASTER PLAN INDUSTRIAL WASTE CONTROL SITE 01.6V37.0 March 21, 1984 000986
FINALREMEDIAL ACTION MASTER PLANINDUSTRIAL WASTE CONTROL SITE
01. 6 V 3 7 . 0March 21, 1984
000986
CH2M88 HILL
engineersplannerseconomistsscientists
March 20, 1 9 8 4
W66137.00
Mr. David PriceSite Project OfficerEnvironmental Protection AgencyRegion VI1201 Elm Stcsat, 28th FloorDallas, Texas 75270
Dear Mr. Price;
Subject; Copies oc the Final "Remedial Action MasterPlan-""Irduatrial Waste Control Site,"March 20, 1984EPA No, 01 .6V37.0
In accordance with Task 9 of EPA Contract 01-6V28.0, we aresubmitting the final RAMP for the Industrial Waste Controlhaza. 'JS waste site. Eight copies are included for Pe-gion V A , and additional copies have been distributee as in-dicated below.
PiGAfla call if you have any questions.
Respectfully submitted,
^3 -
Richard E. Moos, Ph.D.Site Project Manager
DE/IWC/vw027EnclosuresCG! Nancy Willia/U.S. EPA, Washington, D . C .
Russell Bartley/U.S. EPA, Region VIDave Peters/U.S. EPA, Region VIDiane Shoup/CH2M HILL, MAR/WDC&Qb Davia/CH2M HILL, DRHHifce Harri8/CH2H HILL, PMOBob Schillinq/CH2M HILL, SEAJeff Randall/ CH2H HILL, PDXGreg Hooney/CH2M HILL, MGMOuanc Whiting/CH2M HILL, SLC
Racfly MoualJin RegionJl OirK-eCMMIUH.ai»il(6HB-PO ao> 22508 OcnwrCoio^do.U22.; M^ HiaOB
(3 copiesi
000987
TA3LE OF CONTENTSINDUSTRIAL WASTE CONTROL SITE
01-6V37
1 . 0 EXECUTIVE SUMMARY1 . 1 Purpose1 . 2 Site Location1 . 3 Problem Statement1 . 4 General Approach1 . 5 Limitations
1.5.11.5.2 Data Limitations
Study Limitations1 . 6 Community Relations1 . 7 Initial Remedial Measures (IRM)1 . 8 Remedial Investigation/Feasibility Study1 . 9 Source Control Remedial Actions1.10 Off site Remedial Actions1 . 1 1 Cost Estimate and Schedule
2.0 DATA EVALUATION2 . 1 Objective2 . 2 Background
2.2 .12.2 .2
Site DescriptionSite History
2 . 3 Hazardous Waste Assessment2. 4 Environmental Setting
2 .4 .12 .4 .22 . 4 . 32 . 4 . 42.4.52 . 4 . 62 .4 .7
PhysiographyGeologySurface HydrologyGeohydrologyAir Quality dnd ClimateEcologySocioeconomics
TABLE OP CONTENTS
000988
2.5 Assessment or Potential Impacts2 , 5 . 1 Public Health and Safety2*5.2 Environment2 . 5 . 3 Socioeconomics
2*6 Assessment of Community Relations2.7 Data LimitationsREMEDIAL ACTIVITIJqS3 . 1 Remedial Action Plan
3 . 1 . 1 Overall Approach fcu Site3 . 1 . 2 Master Site Schedule3 . 2 Initial Remedial Measures3 . 3 Remedial Investigation
3 . 3 . 1 Objectives3 . 3 . 2 Scope of Work3 . 3 . 3 Remedial Investigation Scheduleand Cost EstimateF'eafit^*' i «- -3 - 4 ^ibiliky Study
1 . -3 . 4 . 1 Objective3 . 4 . 2 Scope of Work3 . 4 . 3 Feasibility Study Schedule andCost Estimate
3 . 5 Source Control Remedial Actions3 . 5 . 1 Objective3 . 5 . 2 Remedial Action Alternatives3 . 5 . 3 Cost Estimate/Schedule
3 . 6 Off site Remedial Actions3 . 6 . 1 Objective3 . 6 . 2 Remedial Action Alternatives3 . 6 . 3 Cost Estimates/Schedule
TABLE OF CONTENTS•2-
000989
TABLESTitle
Cost Estimates for Initial RemedialMeasures, Remedial Investigations, andFeasibility Study
•Types of Wastes Disposed of at theIWC Site
Maximum Concentration Found in SiteSoils Versus the Emission Level Goals
Analytical Parameters " Organics andInorganicsCost Estimates for Remedial Investigations
000990
1-22-12-2
2-3
3-13-2
3-33-4
DE/IWC/036
FIGURESTitle
Approach for Remedial Action Master PlanMaster Remedial Action Site ScheduleSite LocationIndustrial Waste Control SiteFort Smith, ARExtent of Underground Coal Mines i.\ theArea Near Jenny Lind, ArkansasMaster Remedial Action Site ScheduleProposed Location of Borings andMonitoring WellsRemedial Investigation ScheduleFeasibility Study Schedule
TABLE OF CONTENTS-4.-
2-14
3-23-11
3-263-33
000991
Section 1EXECUTIVE SUMMARY
This document is a Remedial Action Master Plan (RAMP) forthe Industrial Waste Control (IWC) Site southeast of FortSmith/ Arkansas. A RAMP is a plan for undertaking remedialinvestigation activities and remedial actions in response toa hazardous substance release, or a substantial threat ofrelease, into the environment. It is based on the NationalOil and Hazardous Substances Contingency Plan (NCP) promul-gated by the U.S. Environmental Protection Agency (EPA) onJuly 16, 1982 (47 FR 3 1 1 8 0 - 3 1 2 4 3 ) .
1 . 1 PURPOSE
The purpose of this RAMP is to identify and define the scopeand sequence of practical remedial investigation activitiesand remedial actions at the IWC Site. The RAMP is preparedfrom existing information and data only; no new data havebeen generated. It provides preliminary cost estimates onproposed activities or actions and addresses data limitations,community-relations strategies, and possible problems duringproject implementation.
This RAW precedes a work plan that will be developed forthe site prior to conducting any remedial (site) investiga-tions (RI) or the feasibility study (PS). The work planwill present more specific details on the actions plannedfor the site and will be prepared in cooperation with theEPA, by the contractors selected to perform the RI and F£.The work plan will incorporate additional information thatcan be obtained from public information and from state andlocal agencies and will reflect decisions made by the EPAafter completing the RAMP. Furthermore, the work plan willdescribe the exact nature of the RI and FS activities andwill present budgets for completing the RI and FS.
1 . 2 SITE LOCATION
The IWC Site is a closed and covered industrial landfillabout 8 miles south-southeast of Fort Smith, Arkansas. Thelandfill site, in an abandoned strip coal mine, covers ap-proximately 8 ctcreq in the southwest quarter of Section Jl,Township 7 North/ Range 31 West/ Sebastian County.
The IWC Site is located about one mile west of Jenny Lind,Arkansas, and is on th« north side of Long Ridge, one ofseveral prominent east-west oriented ridges in the region.The hillside south cf the IWC Site slopes steeply ap to theridge top. North of the site, the slope is more gradual(8 to 15 degrees) and fairly uniform between the site an'iPrairie Creek, about 1/2 mile away. The vertical relief
000992
from Prairie Creek to the top of Long Ridge is about 250 feet,Backbone Ridge to the souU'. of Long Ridge is 100 feet higher.
The area was extensively mined for coal during the late 1800 ' sand early 1900 's . Entryway'-^ into the numerous mines w^relocated all along the bass of Long Ridge from Jenny Li'.idwest to Bonanza. The mine?; followed the slightly dippingcoal seams northward for a P^IG or more until the sear.i becametoo deep to mine. Later, sometime about World War II, coalwas removed from narrow s^rip mines where the coal outcoppedat, the surface. The remnants of many of these old stripnines are evident today, extending east-west along Long Ridge.
1.3 PROBLEM STATEMENT
A landfill operation began in the western end of an aban-doned coal strip mine in the late 1960 ' s . Mr. J. A. Willisleased the coal strip mine in February 1970, presumably forexpanding an industrial waste landfill. In November 1 9 7 1 ,Mr. Willis* engineering consultant filed for an industriallandfill permit and in correspondence regarding that permitindicated that Mr. Willis was upgrading a landfill that hadbeen operating for several years. Temporary approval wasgranted to Mr. Willis in .1971, and a permit was granted inMay 1974 . In August 1974 , the lease was reassigned to GNJ,Xnc. The industrial waste facility accepted wastes from awide variety of industries in Fort Smith from 1974 through1978 . During those years, the facility operated under threedifferent companies: The Willis Landfill, GKJ, Inc., andIWC. However, the president of GNJ, Mr. Grady Shipley, wasalso the president of IWC.
Xn late 1 9 7 5 or early 1976, evaporation ponds were constructedat the site, and IWC began accepting and collecting bulkliquids from several area industries. Liquids and semiliquidsfrom different industries were apparently dumped into thesame pond. Although the Arkansas Department of PollutionControl and Ecology (ADPCE) noted that the ponds were con-structed in clay and underlain by shale (both assumed tooccur naturally at the site), Mr. Shipley stated in latercourt testimony that there had been no ground preparationprior to starting waste disposal operations at the sifce.
Over a 3-day period in late March 1977 , about 4 inches ofrain fell in the site area, and one or more liquid waste im-poundments overflowed. Adjacent landowners filed complaintswhen they noted that a stock-watering pond and pastures hadbeen contaminated. Water san.ples taken from a farm ponddirectly north (downalope) of the IWC Site contained signif-icant levels of phenols and cyanide. Substantial ar..ounts ofoil and grease and lead contamination were also found insurface water and soil samples from properties adjacent tothe landfill. Two property owners ncrfch of the IWC Site
1-2
000993
000994
subsequently claimed that they had lost or were forced tosell several dozen head of cattle. Mr, Perry Henson, ' .heproperty owner immediately north of the site, finally re-»aoved all of his cattle from the pasture and filed a legalsuit against IWC.
During the summer and fall of 1977, ADPCE inspections at theIWC Site revealed several problems including uncontrolledaccess, water ponding onsite, poor drainage/ and leaching ofliquid wastes, further analyses of soil and water samplesfrom adjacent property revealed that several heavy metalswere present in higher-than-normal levels, but were not nec-essarily toxic to plants. Analyses also indicated that the"ontaminants found on adjacent property most likely camefrom a waste containment pond on the IWC Site that containedoils with significant amounts of lead and phenols.
The IWC Site was closed in mid-1978. Sporadic sampling oc-curred from 1978 through early 1983 . In May 198.3, soil andwater samples and geophysical investigations revealed that alarge number of drums or ferromagnetic material was buriedat the IWC Site, and the site contained high levels of de-greasing solvent contamination.
1^4 GENERAL APPROACH
Pigure 1-1 presents a general flow schematic of the remedialaction planning approach being followed for the IWC Site.The approach is based on three types of remedial actions:
o Initialo Onsiteo Offsite
Initial remedial actions are generally carried out beforeremoving hazardous substances and/or contaminated materialsfrom a site and prior to remedial actions. The essentialcriterion for determining the need for initial remedial ac-tions is the existence of an actual or potential significantthreat to public health or the environment. Such actionsmust be cost-effective.
Onsite remedial actions are those responses taken at or nearthe original source of the hazardous substances and/or con-taminated materials whenever inadequate natural or manmadebarriers exist to retard migration. If substances have mi-grated away from the original source, off site remedial ac-tions may be appropriate in addition to or -<n place of onsifceremedial actions.
Before either onsite or offsifee remedial actions can be car-ried out, sufficient data and information must exist? to allowdevelopment, screening, selection, design, and construction/
1-3
000995
implementation of the remedial actions. The RAMP processoutlines a program for the collection and generation of thenecessary data and information through remedial investigationactivities.
1 .5 -LIMITATIONS
Several types of limitations apply to the RAMP process.Those that foUow are considered particularly relevant tothe IWC Site.1.5.1 Data Limitations
1 . No detailed survey or map exists of the site andimmediate vicinity.2 . The type and quantity of wastes that remain buriedon 8 its are unknown.3. The number of homes using private wells in theiaiHnediate vicinity of the site (nu.nimum 1-mileradius) is not known*4 . Little site-specific information exists concerningsubsurface conditions or Stratigraphy in the areadownslope (downdip) of the site and the characterof the material directly underlying the landfill,5« The location of mine shafts or adits, subsidencefeatures, and potential direct or indirect connec-tions between the underground mines and the oldsurface strip mine (the IWC Sitel has not beendetermined.6 . Ho information waa available concerning the qualityof groundwater at the site, the direction of thegroundwater flow, and the permeability of underly-ing strata. Areas of groundwater discharge in thevicinity of the site, especially springs and seepsbetween the site and Prairie Creek, are not known.7. Fish and ber.thic invertebrate populations upstreamand downstream of the site are unknown/ as is thecause for the dead trees just north of the site.8. Flow data for Prairie Creek and other naturalstreams wera not available prior to writing the
RAMP.
000996
1 . 5 . 2 _Study Limitations1. The RAMP does not provide specific remedial actionsdue to a lack of information necessary to conductan FS.2. Costs are included for RI's only and are based onexperience in hazardous waste working conditions,The nature of the site and the necessary healthand safety issues make comparison with conventionalinvestigations unreliable. Accordingly, a highand low estimate of cost is given based on conser-vative unit costs and a range of suspected workscopes,3. The RAMP is basically a planning document withtasks and oubtaaka suggested as minimum efforts toaccomplish its objectives.4. The RAMP budget and development achadule did notpermit a complete and exhaustive consideration ofall remedial planning activitioa.
1,A COMMUNITY RELATIONSThe ccmunity relations effort and development of the Com-munity Relations Plan ace being handled aeparately from thisRAMP by EPA Region VI, and the Plan will be aubmitted aa a•aparate document.1 . 7 INITIAL REMEDIAL MEASURES (IRH)No initial remedial meaaurefi are proposed for the IWC Sitebecause no imminent threats to public health or the environ-ment ware judged to ex-afc at the aite. The facility is acloaed and covered landfill, does not pose an immediate riskto the existing land uaeB, and haa existed in if presentunguarded condition for several yeara.1 8 REMEDIAL INVgSTIGATIOH/FEASIBXLITY STUDYAn F5 will be required to identify, acreen, and evaluateremedial action alternatives. However, the available tech-nical data and nontechnical information on the site are in-sufficient bo fully characterize the contamination presentand to develop viable remedial action alternatives. There-fore, an RX comprised of selected additional data gatheringand field atudiea if required prior to cor,4ucting the feasi-bility atudy.The propoaed RI ahould include eight activities, each eon-•isting of several dsfinad taakfl. Theaa activities aref
000997
00000000
Project startup/work plansSite definition activitiesPhase I site investigationsPhase II site investigationsPreliminary remedial technologiesSite investigation analysesA remedial investigation reportManagement activities
Phase IX site investigation work will depend on the resultsobtained in Phase X. If the results from Phase X indicatethat the site posee a significant public health or environ"nental nazard or the results aro inadequate to evaluate re-medial action alternatives, a more detailed field study andtesting program would be conducted in Phase T:, if Phase IXactivities are deemed not necessary, efforts would be shiftedfrom Phase I directly to conducting the PS.
Th« proposed PS scope should consist of the following eightactivities:
o Develop potential remedial alternativeso Screen alternativeso Recommend and conduct additional engineering
etudieao Technically access and evaluate the albornafiveso Prepare a preliminary reporto Prepare « conceptual designo Prepare a final reporto Management activities
1 . 9 SOURCS CONTROL REMEDIAL ACTIONS
Source control (onsite) remedial actiona are thoaa responsestaken at or near the original source of contamination/ wher-ever inadequate natural or manmade barriers exix& to retardmigration. Becauee of the lack of data, only general con-cepts can be presented for this site.
Appropriate remedial actions may vary froa nocompleito cutoff eyatem that isolates the siteFounding environment. Other alternatives maycutoff syafceme, removal of wasces to a secureplace treauaent/ or continued monitoring w^th
1 . 1 0 OFFSITK RENEDUi- ACTIONS
action to fifrom tne aur"involve partiallandfill, in-no ofchitf action r
Offaite remedial actions ar« aeacuren bo mitigate the sffactsof hazardous wasbas that have migrated beyond the site boun-daries. Dafca indicate that contaminated surface water andgrouJidwater have probably migrated from the site,
000998
Offsite remedial actions thafc may be feasible for this siter&nge from abandonment of downgradient private wells to re~moval and treatment of the contaminated groundwater.
1 . 1 1 COST ESTIMATE AND SCHEDULE1-T~girr~'" . I ••^l—f- •• Ill^ha^fci H *—• JJilM—^ir^—ihUiifcMItiTrBBin——mi i r i " - -
Cost estimates for conducting the RI/FS activities recommendedin this RAMP are presented in Table 1 -1 . A preliminaryschedule for conducting the above-mentioned activities i'ipresented in Figure 1-2.
DE/IWC/028
1-8
000999
Table l-lJ-UU-fce -"' 'A
COST ESTIMATES FOR INITIAL REMEDIAL HEASURES, REMEDIALINVESTIGATIONS, AND FEASIBILITY STUDY,
INDUSTRIAL WASTE CONTROL SITB, POST SMITH, ARKANSAS
MHECIAL aVESnGATKWS
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7. PAMAODtOff ACTlVITIiLC
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"This scfiedule assumes Phase I activities revealed significanthazards at the IWC Sito and Phase II Investigations were reQuired.
Figure 1-2Master Remedial Action Site Schedule
Industrial Wast® Control Sde
001001
Section 2DATA EVALUATION
2 .1 OBJECTIVE
This section summarizes background information and technicaldata for the XWC Site where an industrial waste disposallandfill was formally operated. These data will be used toassess the impacts of industrial waste contamination at thesite itself and adjacent land areas. The assessment willalso include an evaluation of impacts of contaminants on thelocal surface and groundwater systems. These data will beused subsequently as a basis for formulating and evaluatingproposed remedial activities.
2.2 BACKGROUND
2 .2 .1 Site Degcnpt Ion
The IWC Site is located in Sebastian County, Arkansas in thesouthwest quarter of Section 3 1 , Township 7 North, Range 31West. The aite is in the west-central portion of the elate,approximately 8 miles south-southeast of Fort Smith, Arkansas(Figure 2 - 1 ) . The landfill site. An an abandoned strip coalmina/ covers an area of approximately 8 acres. Waste mate-rials and fill dirt, including mine spoil material, weredumped into the pit left by mining activities. The site isnow closed, covered, and graded to the natural contour.
The IWC Site is situated on the north side of Long Ridgeabout one mile wee of Jenny Lind. The site today appearsas a natural sloping hillside because the strip mine hasbeen completely filled in and covered. A dirt country roadborders the site on three sides/ and a narrow line of treesand underbrush separates the road along the south side ofthe site from the abandoned landfill (Figure 2-2). Somesurface evidence of the old evaporation ponds is still pres-ent, but the site has a fairly uniform slope to the north.The site area is open except for a barbed wire fence alongthe north side of the landfill. The IWC Site includes sev-eral acres formerly leased from Ms. Minnie dark and nowowned by Ms. Goldie Duncan (Figure 2-2).
2 . 2 . 2 Site .History
Information on site history was obtained primarily fron* doc-uments on file with the SPA and the ADPCE,
On November IS, 1 9 7 1 , James Willis applied to the ArkansasPollution Control Commission for approval to operate an in-dustrial landfill facility in Sebastian County at the siteknown today aa the IWC Site. A landfill operation had
001002
FORT SMITH 8 MILES FORT CHAFFEE MtLtTARY RESERVATION
FORT SMfTM
SEBASTIAN COUNTY
A R K A N S A
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Figure 2-1Site Location
- ^ n 1 R.'FQfEatrtal Waste Control flWC) Sfte
001003
FORMERSTOCK
POND
PERRYHENSON
PROPERTY
001004
existed at the site prior to 1 9 7 1 , but had not been approvedfor industrial wastes. Willis was given temporary approvalin 1 9 7 1 , and a final permit was granted on May 24, 1984 . Atleast one local firm began disposing of solid waste at thefacility in January of 1984 .
Grady Shipley, President of GNJ, Inc. (subsequently renamedIndustrial Waste Control, Inc. in 1 9 7 6 ) , notified the ADPCEthat GNJ had taken over the operation of James Willis' land-fill in August of 1974.
On February 23, 1976, ADPCE noted during a site inspectionthat IWC had constructed two evaporation ponds and was plac-ing unknown quantities and types of liquids and semiliquidsinto these ponds. However, ADPCE also noted that the pondswere constructed in clay and underlain by shale so that pondleakage was expected to be n.inimal. The quarterly inspectionreports prepared by ADPCE for the IWC Site in late 1976 andearly 197'; noted that site conditions were satisfactory ex-cept for litter control.
During late March 1977, approximately 4 inches of rain fellat the IWC Site/ and one or more liquid waste impoundmentsoverflowed. Neighboring citizens subsequently complained ofloss of cattle, forage, and fish resulting from contaminatedrunoff. As a result of these complaints, numerous analyseswere performed on soil, water, and cattle in an attempt toassess the type and extent of contamination that had occurredto the adjacent property owners.
Mr. Perry Henson, owner of property north (downgradient) ofthe XWC Site, reported that all of the fish in a farm pondon the northwest corner of his property were killed by theMarch runoff from the IWC Site. Also, the grass in the pas-ture was coated with an oily or greasy substance. A sub-sequent water sample from the farm pond indicated that phe-nols and/or cyanide probably killed the aquatic life. Thewater sample contained 12,600 micrograms per liter (pg/Ll ofphenol and 860 ug/£- of cyanide in contrast to limits of2,560 ug/L and 3.5 ug/L, respectively, for the protection offreshwater aquatic life act by EPA ( 1 9 8 0 ) . The EPA informedMr. Henson that the cyanide would degrade biologically overa period of time, but the phenols could persist for a longtime.
M&Clelland Consulting Engineers/ Inc., conducted soil andwater sampling in November 1977 on the IWC Site and the Hen-son property. They reported that two contaminants of sig-nificance were still present in the farm pond/ namely lead(500 ug/U and oil and grease, McClelland also concludedthat the main source of offsite contamination was one of theevaporation ponds on the IWC Site that contained mainly oilswith significant amounts of lead and phenolic compounds.
2-4i >r an>i in •i ni rhi i'iirffflrffir--iii'i' i' 'i"
001005
The November 1977 soil samples, analyzed by the CooperativeExtension Service at the University of Arkansas/ revealedthat some soil samples from Henson's property contained lev-els of calcium, copper, nickel, zinc/ lead, and cadmium thatwere excessive compared to normal ranges. However, theseexcessive levels would not necessarily be toxic to plants oranimals, because other factors such as soil pH influence theavailability of these metals to plants.The University of Arkansas Agricultural Experiment Stationreviewed the analyses of the water and soil samples collectedin November 1977 from Henaon's farm and also data from soiland forage samples collected in 1978. The conclusion wasmade that major soil contamination was confined to areasclose to the landfill and that the majority of the elementstested for were within the range of normal soil values.Forage analyses indicated that nickel and possibly cadmiumlevels were higher than deeired, but the forage was not toxicto cattle due to excessive heavy metals concentrations.In early April 1977, ADPCE notified IWC that a lev^e con-structed by them at tho landfill acted like a dam and allowedwator to pond on the landfill. The ADPCE requested thataction be taken immediately to construct berma and ditchesthat would carry rainfall runoff from landfill areas beforeit soaked In and divert surface runoff away from the land"fill. Late in April, IWC myt with representatives of theArkansas Air, Water, and Solid Waste Divisions and with afew of the local waste generators to discuss waste disposalproblems at the IWC Site. IWC was requested to submit aproposal for proper short- and long-term storage and dis-posal of all wastes by May 15, 1977. The recommendation wasmade that volatile liquids be recycled or incinerated in thelong term and contracted to a third party in the short term.In June 1977, IWC informed the ADPCE that IWC would not ac-cept any liquid waste material containing hydrocarbons whilethey investigated disposal alternatives of reclamation andincineration. However, the company would continue to acceptsemisolid nonhazardous sludge material from wastevater treat-ment plant ficilities.During inspection in July 1977, the ADPCE noted that fluidfrom the containment ponda was seeping from the ponds andonto the landfill. They informed IWC that the inspection ofthe landfill also showed that little or no attempt had beenmade to correct previously notad deficiencies including un-controlled access, unsatisfactory containment ^onds, drainageproblems, and leaching of liquid wastes..During 1977, Mr. Henson filed a suit for damages againstIWC, and the court proceeding continued through the summerof 1977. Grady Shipley, president of IWC, completed written
001006
responses to Interrogatories in that case (Henson v. Indus-trial Waste Control, Case No. CIV-77-51) during August 1977.In response to questions on site operations, Mr. Shipleystated that there had been no ground preparation prior tostarting the solid waste disposal operations at the IWC Site.Written responses to Interrogatories were also filed by sev-eral of the industrial firms that used the IWC Site.
In September 1977, an engineering consulting firm for IWCwrote the ADPCE, stating that improvements had been made tothe landfill including: (1 ) access control, (2) cover ofoverflow area from previous spills with clay, (3) diversionof surface drainage away from containment ponds and fillarea, and (4) filling of a low area with clay material inpreparation for final cover. The ADPCE later replied thatseveral unsatisfactory conditions still existed at the land-fill. At that time, the ADPCE recommended that proposedplans for closing the containment ponds be acted upon imme-diately and that efforts be made to improve landfill opera"tions.
On August 8, 1978, IWC notified the ADPCE that the IWC land-fill had been closed. IWC stated that a more-than-adequafcecover had been placed and compacted over the industrial land-fill. The cover had been graded to ensure good drainagewith no ponding, and native grasses and weeds were growingwell. IWC stated that the only remaining open pond presentedno hazard but that it would be drained and filled in thenear future. That pond was subsequently filled,
The ADPCE inspected the IWC landfill on Hay 1 1 , 1979 andfound that a serious leachate problem existed at the site.
On March 24, 1 9 8 1 , the Field Investigations Team (FIT) forEPA inspected the IWC Site. Although IWC denied permissionfor the investigators to enter the site, off site samples ofgroundwafcer, surface seeps, and seep sediments were collectedfor analyses. Based on customer records, the investigatorslisted lead chromate, lead molybdate, phenolics, toluene,fcrichloroefchylene, methyl ethyl ketone, and oily wastes asbeing substances of greatest con^m. About 2 months afterthe field investigation, FIT notified EPA that a potentialfor groundwater contamination existed at the site due toinfiltration of watar into and through the buried materials.FIT also recommended that a shallow boring program be inifci-ated.
ADFCE contacted Perry Henson and the owners and operators ofthe IWC landfill and of the former Willis Landfill during1982 to request estimates on the number of drums buried on-site and the number of drums hauled offsite. Henson statedthat at least 1,000 drums were buried onsite, and he was notaware of any drums leaving the site. Mr. Shipley, President
2-6
001007
of IWC, did not know how manyMs-. Willis stated that duringfill drums containing liquidsatid then reused.
drums were buried onsite,the time he operated the land-were emptied into onsite ponds
In early February 1983, the ADPCE conducted a hydrogeologicstudy of the IWC Site. The study concluded that the sitewas situated in the recharge area for the regional ground-water system, with groundwater movement to the north (ADPCE,1 9 8 3 ) . A comprehensive we31 water sampling program was pro-posed,- but that study was apparently never made. An addi-tional hydrogeologic study performed by Wayne Van Buren andFloyd Durham at the ADPCE concluded that one or more under-ground ccal mine entryways could exist along the north wallof the former disposal pit at the IWC Site (Van Buren andDurham, date unknown). If such entryways were not properlysealed, they could provide pathways for leachate from thelandfill to enter a fairly extensive network of intercon-nected mine tunnels.
On May 10 and 1 1 , 1983 , the FXT team collected surface soil,seep, and water samples and conducted magnetometer and elec-tromagnetic terrain conductivity surveys at the IWC Site.The site investigation revealed areas of significant magneticand conductive anomalies that suggest the presence of burieddrums or ferromagnetic materials in pockets or piles alongthe rorth side and scattered over the western end o£ thesite (Ecology and Er.vironment, 1983 ) . Sample analyses in-dicated that the surface of the site contained high levelsof degreasing solvent contamination at all stations sampled,and the sampling team suspected that contaminant levels wouldbe higher underground. The FIT also noted that informationprovided by the Arkansas Geological Commission indicatedthat entryways to the underground coal mines may not existon the IWC site itself, but one or more enfcryways are some-where in the immediate vicinity of the site.
2.3 HAZARDOUS WASTE ASSESSMENT1.1 • MI-II i———J'I-JQ. -_irJ_m-gi._ 1 1 ••"• ri—• IF • ••—li "^-s—'^——————————————I-M-I —~ irr- -i •i—I
No detailed records exist of the types and quantities ofwastes disposed of onsite. However, Ta^'le 2-1 presents alist of the general categories of wastes that were reportedto be disposed of at the site. This information wasoriginally presented as part of the written responses toInterrogatories by IWC in the case of Henson v. IWC, CaseNo. CIV-77-51.
The disposal activities onsifce are not well riocumented ei-ther, Bulk liquid wastes were apparently dumped withoutregard to compatibility into the abandoned fftrip mine oronsite disposal ponds, and drums and other solid wastes were
001008
Table 2-1TYPES OF WASTES DISPOSED OF
AT THE IWC SITE1 . Acetone2. Chromium sulfate3. Methylene chloride4. Sodium hydroxide5. Stannous octuate6 . Trichloroethylene7. Alkaline flotation agents8. Kerosene9 . Paint
10. Paint anc^ lacquer thinner11. Phosphate sludge12. Procelain filter sludge13. Solid wastes14. Solvent-base and water-base ink15. Waste hydraulic oil (fluid)1 6 . Water-soluble oil17. Trichloroethene
Mote7 From Hay 9, 1983, letter from Rose, Kinsey & Cromwellto EPA.
buried in various areas across the site. Preliminary geo-physical work has identified several areas where drums orother metallic wastes are buried (Ecology and Environment,1 9 8 3 ) .
The types and quantities of chemicals onsifce are, as statedabove, not well documented. However, some 3oils and seepshave been sampled onsite and on the Henson property afterthe 1977 spill occurred. These samples had elevated concen-trations of several inorganic compounds, including arsenic,cadmium, chromium, lead, nickel, zinc and copper; and organiccompounds such as halogenated solvents, nonnalogenafced sol-vents, polynuclear aromatics ( P N A ' s l , phthalates, nitrosamines,pentachlorophenol, herbicides, and pesticides. TCDD hasalso been detected onsite by preliminary analyses but hasnoc been confirmed by mass spectroscopy.
Three domestic wells in the vicinity of the site have beensampled and tested. No contamination was detected, but thesewells are believed to be upgradient from the site, and theanalyses were only for metals.
The onsite sampling has been limited primarily to soil sam-ples with a few eurface water and seep samples. Consequent-ly, very little is known about the quality of the ground-
2-8
001009
water. See Section 2 .4 .4 of this report for more informationon the groundwater in the area and its utilization. Thequality of drinking water is controlled by the National In-terim Primary Drinking Water Standards, which were developedto protect the public health of water users of a communitywater system and are enforceable by Federal and state waterquality agencies on public water systems (EPA, 1 9 7 6 ) . Pri-vate domestic wells/ however, that serve an individual house-hold are generally not controlled by these regulations.
The National Secondary Drinking Water Standards establishadditional criteria for drinking water compounds that mayadversely affect the aesthetic quality of drinking water,such as tastes, odor, color, and appearance, and which there-by say deter public acceptance of drinking water provided bypublic water systems. These secondary regulations are notfederally enforceable but are intended as guidelines forstate water quality agencies (EPA, 1979) .
Unfortunately, no encompassing regulations presently existcontrolling contamination in the soil. The EPA has publishedMultimedia Environmental Goals (MEG's) that are estimates ofdesirable ambient and emission levels of various compounds.These Emission Level Goals are, in part, based on such ambi-ent factors as:
Minimum Acute Toxicity Effluents (MATE'S)—In undilutedemission streams, concentrations of pollutants thatwill not adversely affect those persons or ecologicalsystems exposed for short periods of time.
Ambient Level Goals, that is. Estimated PermissibleConcentrations (EPC's)-—Concentrafcions of pollutants inemission streams that/ after dispersion, will not causethe level of contamination in the ambient media to ex-ceed a safe continuous exposure concentration.
Elimination of Discharge (EOD) "Concentrations of pol-lutants in emission streams that, after dilution, willnot cause the level of contamination to exceed levelsmeasured as "natural background."
Table 2-2 presents a comparison of the maximum concentrationof selected organic compounds found in the soils onsite andtheir Emission Level Goals. Only those compounds that werequantitatively reported in the 1 9 & 3 Preliminary FIT raport,(Ecology and Environment/ 1963) aii'? are iddreased in theMEG'S, are included. No inorganic compounds in this set ofsamples were significantly higher than in the reported back-ground (that is, the EOD levels).
001010
Compound
Mechylene Chloride
Phchlace escers
Ethyl benzene
Toluene
Kylene
Te t rahyd ro f .iran
MAXIMUM CONCEfrVERSUS T!-
MaximumSoil Concentration
2.700
3.470°24
282
3.330
470
Table 2-2ORATION FOUNDIE EMISSION LEV
(vg/l)
MATE3
Based onHealth Effects
7.800
152
13,000
11,000
13,000
18.000
IN SITE S03rEL GOALS
i
Based onEcological
Effects
20
0.003
'£.
2
2
—
ELS
ALG6
Based onHealth Effects
7.2
0.14
12
10
12
16
F
3
Based onEcological
Effect
10
0.0006 1|'•
0.5
0.5
0.5
—
BE
>
a,*Mln<twJin acute coxiclcy effluents.iAmbiftnt level goals (i.e., estimated periBalsslbIe concentrations)b
'Bis (2-&thyl hexyl) phthalate.
001011
Soine compounds reportedly disposed of at the IWC Site warrantfurther discussion because of their acute toxicifcy or carcino"geRity. TCDD has been detected (but not confirmed by massspectroscopyi in the soils in a seep area onsite. TCDD isof prime importance because of the potential acute fcoxicityof the 2, 3, ?, 8 TCDD isomer. Other compounds detectedonsite such as benzo(a)pyrene, methylene chloride, polynucleararomatics, bis(2-ethyl hexyl) phthalate, and ferichloroethyl-ene, are reported as carcinogenic* The exact concentrationsof these carcinogenic compounds at the IWC Site are stillbeing investigated.
2.4 _ EHVIRONMENTAL SETTING
2^4.1 Physiography
The IWC Site is located in the Arkansas Valley Section ofthe Ouachita physiographic province. The rocks in t-^e areahave been subject to intense deformation and are highlyfolded and faulted. The folds take the form of a series ofeast-west trending anticlines and synclines that are cut bynumerous faults (Haley and Hendricks, 1 9 6 8 ) .
The topography of the project area is characterized by aseries of ridges and valleys that are the curficial expres-sion of the folds described above. The IWC Site is locatedon the northern flank of Long Ridge (just north and parallelwith Backbone Ridge) at an average elevation of approximately520 feet mean sea level. The overall slope of the site isto the north. The original topography has been modified bystrip mining and landfilling operations. The IWC landfillis located in the old strip-mined portion of the site. Momajor creeks cross the site; however, the channel of PrairieCreek lies approximately 1 /2 mile north of the site.
To the north of the XWC Site, the topography is gently roll-ing flafc~topped hills and stream valleys grading into therelatively flat and fertile Arkansas River Valley. Alti-tudes range from a few hundred to several hundred feet. Tothe south of the site, the topography is more mountainous,consisting of a series of east-trending ridges and narrowvalleya grading into steep stony mountains. Altitudes rangefrom several hundred feet to nearly 2,700 feet at the top ofPoteau Mountain at the south end of the county. Many of thesyncUnal ridges have altitudes around 1,000 feet.
2.4, 2_Geplogy
The IWC Site is located on the northern limb of the east-trending Backbone Anticline. Several sedimentary formationsof Pennaylvanian age are exposed along this anticline, allof which dip to the north beneath the site. These are, inascending order, the Atoka Formation, the Hartshorns
001012
Sandstone, and the McAlester Formation. The interbeddedsandstone shale and coal underneath the site are reported todip northward at 8 to 30 degrees (ADPCE, 1983; Van Buren andDurham, dats unknown)* Apparently the dip becomes steepercloser to Long Ridge and Backbone Ridge.
The Atoka Formation is approximately 6 ,000 feet thick in theproject area. The Atoka Formation consists primarily ofdark, silty shales, siltstones, and very fine-grained sand-stones. Two distinct lithologic zones that are unique withinthe Atoka have been identified. These are "Zone P" and"Zone W" (Haley and Hendricks, 1968).
Zone P occurs near the middle of the formation and consistsof coarse-grained quartz sandstone. Zone P occurs beneaththe southern boundary of the project site. Zone W occurs inthe upper portion of the formation and consists of sandstoneand siltstone facies. Zone W has been mapped along the crestof the Backbone Anticline.
The Hartshorne sandstone unconformably overlies the AtokaFormation and reaches a maximum thickness of approximately200 feet. This formation consists predominantly of light-colored, fine-grained sandstones. In addition, siltsfconesand shales also occur. The Hartshorne sandstone occurs be-neath the southern portion of the IWC Site.
The McAlesfcer Formation conformably overlies the HartshorneSandstone and ranges in thickness from approximately 1,400to 2,000 feet. This unit consists of shales, siltstones,sandstones, and at least four economically important coalseams. The most economically and widely occurring coal isthe Lower Hartshorne coal that occurs near the base of theformation and is the coal bed probably strip mined st thesite and removed from the underground mines north of thesite. This coal bed is approximately 60 inches thick in theproject area.
Numerous underground coal mines are in the area, and theWestern Coal and Mining Company No. 17 Mine immediately northof the site (the Graham-Henson Coal Company mine abandonedin 1932) was reported to be one of the largest in Arkansas.These mines went <?own to about 250 feet where the coal de-posits leveled out along the axis of the Central Sycline.Abandoned mine workings honeycomb the area from Bonanza allalong Backbone Ridge, extending east of Jenny Und. Thesemine workings exfcenc northward under Prairie Creek. Fig-ure 2-3 shows the boundary or outer limits of the undergroundmines in the vicinity of the IWC Site. The northern boundaryis erratic but runs basically parallel to the axis of theCentral Syncline, while the southern boundary is straighterand runs along Backbone Ridge. Note that the southern
2-12
001013
001014
boundary coincides closely with the remnant surface stripmines in the area.
Geologic maps of the area indicate that originally much ofthe site was covered by a mantle of stream-terrace deposits.The deposits consist of clays, silts, sands, gravels, andcobbles in varying combination. The exact thickness anddistribution of these deposits over the site are unknown,
Structurally/ the site is on the northern limb of the Back-bone Anticline, an east-trending structure that has beenextensively faulted. The most prominent fault is the Back-bone Fault Zone that runs east-west the length of the anti-cline. This fault zone consists of two to five major faultsand ranges from 300 to 4,000 feet wide. Most of the faultsdip to the south from angles near vertical at the surface toles5 than 15 degrees in the subsurface. Maximum throw forfche fault zone is approximately 12 ,800 feet. The IWC Sitelies adjacent to the northern mapped extent of the zone. Inaddition, a normal fault of unknown dip is inferred to runacross the northwest corner of the site (Van Buren and Dur-ham/ date unknown).
2"_ 4 ._3 Surface .Hydrology
The IWC Site is located on the north side of Long Ridge wherethe steeper slope of the ridge begins to level out into theCentral Syncline. The land surface drops to the north to-ward Prairie Creek, located in the synclinal valley. Thevertical relief from ridge top to creek is about 250 feet,with elevations along the ridge top around 750 feet. Prai-rie Creek flows eastward, meeting Bear Creek just north ofJenny Lind (Figure 2 -1 ) , and subsequently flows into VacheGrasse Creek and the Arkansas River.
Prairie Creek is a perennial stream about 30 to 50 feet wideand typically only a few feet deep. Much of the stream bot-tom is bedrock, apparently shales of the McAlester Formation,partially covered by broken shale, sand, and gravel. Thecreek is classified as a raw-water source for public watersupplies by the ADPCE (according to the Arkansas Water Qaal-ity Standards of 1975) and is regarded as suitable for warm-water fish and secondary contact recreation. Records ofunderground mining activities in the area indicate that creekwater flowing into underground fractures prevented coal min-ing in a few specific locations (Van Buren and Durham, dateunknown).
In the Arkansas Valley region, the close relationship betweenstreamflow and precipitation-evapotranspiration suggeststhat streams are supplied mainly by groundwater dischargeduring dry periods (Cordova, 1 9 6 3 1 . Therefore, maximum flows
001015
occur in the winter and spring when precipitation is highestand the evapotranspiration rate is lowest.
The closed IWC Site has been graded so the land surface slopesfairly uniformly from south to north. Along the east-westaxis, very little relief exists, so surface waters from pre-cipitation run off the site primarily as laminar sheet flowsto the north. However/ some localized surface flow patternsbegin to develop in minor depressions and in a few placeswhere landfill leachate comes to the surface during wetperiods of the year. Most of the site is covered with nativegrasses and weeds, but since much of this is clumped orbunch-type growth, the cover is subject to erosion. No topsoiland very little if any soil development exist on the site.The ground cover over the old filled evaporation ponds isbare, so this particular area/ of an acre or more, is verysusceptible to erosion.
^ ' 4 ' i_ .P^fi.by^yQiogyConsolidated rocks of the Pennsylvanian to Ordovician ageare the principal sources of groundwater in the region, out-side of the alluvial area of the Arkansas River (Ccrdova,1 9 6 3 ) . In the vicinity of the site, the consolidated rocksare represented primarily by the McAlester Shale, HartshorneSandstone, and Atoka Formation. Most wells in the area yieldless than 60 gallons per minute (gpm), and the rural homes,farms, and small communities generally use wells 50 to200 feet deep. The depth of wells in this region is limitedby the depth to saline water, which in most places is about1 / 0 0 0 feet (Cordova, 1 9 6 3 ) . Alluvial deposits of tributarystreams can satisfy rural"domestic needs in many areas/ butthese deposits cannot be used as major groundwater sourcesbecause of their low permeability and limited areal extent.
Groundwafcer from consolidated rocks generally has a dissolved-solids content of less than 500 parts per million (ppm), butwaters from the Atoka Formation and McAlester Shale are roostlikely to exceed that level. The predominate anion is bi-carbonate in the Afcoka and McAlester Shale units, while theHartshorne Sandstone contains both bicarbonafces and sulfafces.Sodium is the predominate anion in the Afcoka Formation andMcAlester Shale, while the Hartshorne Sandstone has equalquantities of calcium, sodium, and magnesium. Groundwaterin the area generally contains legs than 2 ppm iron, butwaters from the Atoka Formation and the Hartshorne Sandstonegenerally exceed this value (Cordova, 1 9 6 3 ) .
The IWC Site is located along the edge of the east-trendingCentral Syncline/ and the water table of this syncline isroughly 40 feet below the land surface (ADPCE, 1 9 8 3 ) . Back-bone Ridge and Long Ridge, immediately south of the site/serve as the principal recharge zone for the Central Syncline
2-15
001016
grcundwater. The groundwater in the synclinal valley isconfined on the north and south by the syncline structure/but east-west flows may be largely unrestricted. Water movesprimarily along bedding planes, extensional fractures, faults,and old underground coal mines (Cordova, 1 9 7 6 ; VanBuren andDurham, date unknown; ADPCE, 1 9 8 3 ) . At the IWC Site, theinterbedded sandstone, shale, and coal strata dip from 8 to12 degrees to the north. The depth to the water table atthe site itself fluctuates considerably through the year.During the wet season, the dep' .1 to water is reported to becn^y 2 to 4 feet below the land surface along the northernboundary of the site (EPA, 1981) .The area has been extensively mined for coal, and the land-fill operation at the XWC site used one of the abandonedstrip mines. Remnants of several strip mines are found inthe aref, including one iniynediately east of the IWC Sitethat was probably a continuation of the strip pit filled bythe IWC operations. During the late 1800*s and early 1900's/underground mines operated throughout the area. Then duringthe 1940*5, coal was strip mined from the surface outcropsdown to depths of 30 to 50 feet because World War II in-creased the need and value of coal. Strip mines in somecases were excavated over entryways into the undergroundmines. An ADPCE inspector observed that situation in a strippit near Jenny Lind (presumably not the IWC Site) in 1977(ADPCE, 1 9 8 3 ) . Although direct connections between stripmines and underground mines may be common or rare, indirectconnections apparently are common because of the geology andproximity of the underground and strip mines in the samecoal seam (ADPCE, 1 9 8 3 ) . Water flowing into the strip pitsprobably moves easily into the groundwafcer system and theold underground mines following bedding planes and fractures.ADPCE personnel noted that none of the unreclaimed stripmines in the area contained standing water (AOPCE, 1 9 8 3 ) /which supports the theory that the strip pits allow water toenter quickly into the groundwater system.During a field investigation of the area north-northwest ofthe IWC Site, ADPCE found water flowing from a 4-inch pipeprotruding from the ground just south of Bonanza Road. Theflow was e&timated at less than 5 gpm, and the water hsd asulfur odor. The pipe probably served as a conduit for alee"fcrical cables running down into an underground mine. Thisflowing pipe, and other geologic and hydrogeologic evidence,indicates that the aquifer under Prairie Creek Val'.^y 137 beartesian and recharged along the flanks of the valley, in-cluding Long Ridge and Backbone Ridge. The £>rtesi,xr. pres-sure is reported to be sufficient to create a head of 200 to250 feet. Therefore, any contaminants reaching undergroundcoal mines in the area could have a direcx iKpact on thewater in fche mines and an indirect effect or. the entiregroundwater and surface water systems.
001017
The use of private wells as a primary source of domesticwater in the area around the IWC Site has been diminishingover the past 15 years. Also, apparently no groundwaterwells are used for irrigating crops in the area. The SouthSebastian Water Supply Association began installing water-lines in the area in 1965 and completed its basic system inlate 1968 (record of communication between Mr. Perdue, EPA;and Mr. Booth, South Sebastian Water Association/ March 30,1 9 8 3 ) . Additional houses have continued to be linked to thebasic system since 1968.
However, several hom^s in the immediate vicinity of the IWCSite still use private wells as their main water source, andmany homes in the area have wells that are still used forwatering lawns. Recent estimates by EPA indicate that sev-eral hundred people in thti area may still be using wells;these are generriUy 50 to ;00 feet deep. None of the privatewells immediately downgradient have been tested for contami-nation.
2 . 4 . 5 Air Quality and Climate
Air quality data in the State of Arkansas are collected andsummarized annually by the ADPCE. The air quality in thePort Srr.ich area is quite good due to the area's relativelysmall population and industrial activity. For this reason,the Department monitors only air particulafces ir. Fort Smith.The ADPCJt:; classifies Fort Smith, about 10 miles north of theTWC Site, as an air quality compliance area for all pollu-tants of concern, including particulates.
The climate of the Fort Smith area (and the I>?C Site area)is characterised by warm summers and moderate winters. Onaverage, the '^rea experiences temperatures of 90°F or greaterabout 72 days per year. The highest recorded temperaturewas U3°F. The arsa experiences temperatures of freezing orbelow about 80 days per year, and the lowest recorded tem-perature was -15°F. The Boston Mountains north of SebastianCounty provide a natural barrier that keeps the winters rel-atively mild. As a result of this, the Fort Smith and IWCSite area has a growing season averaging 223 days (Cox,et ai., 1 9 7 5 ) .
The average precipitation in the Fort Smith area is 42 inchesper year, with approximately 5 inches per year of snow.Most of the precipitation occurs during the months of Marchthrough July. Precipitation is generally in the form ofshowers, and amounts are measurable on the average of 100 daysannually. However, more than 7 inches occasionally falU ina single storm. Severe weather disturbances are not frequent,but tornadoes are occasionally reported. Winter (Novemberthrough February) is the driest time of the year, but evapo-transpiration rates are typically high in the summer,
2-17
001018
offsetting the benefits of higher precipitation. Annually,the water loss due to evapotranspiration is about equal tothe water gain by precipitation (EPA, 1 9 8 1 ) .
2 . 4 . 6 ..Ecology
Originally, Sebastian County was mainly wooded with a fewscattered prairie areas. Now trees cover about 40 percentof the county, primarily on the steeper slopes of ridges andhills and in the Ouachita National Forest (Cox, et al., 1 9 7 5 ) .Extensive wooded areas are also present along most of thecreeks and rivers in the area. In the vicinity of the IWCSite, the vegetation ranges from heavily wooded hillsidesalong Long Ridge and Backbone Ridge to the south and pas-tures and meadows to the north. Trees with understory brushand tall grasses are common around the perimeter of the pas-tures an<? along Prairie Creek* The area is predominantlyrural, with some cultivated fields along Prairie Creek. Aresidential area exists northeast of the site with mosthouses on one" or 2-acre lots.
The forested hillsides of Long Ridge contain mixed hardwoodswith some evergreens/ such as shortleaf and loblolly pineand redcedar. Along the lower reaches of Long Ridge/ in-cluding the IWC Site and around the pastures, the commontrees are oak, hickory, beech, and maple* The understorybrush in these areas includes dogwood, persimmon, blackberry,primrose, and honeysuckle. In the pastures north of the IWCSite and along Bonanza Road and Prairie Creek, the commongrasses are bahiagrass, bermudagrass, tall fescue, whiteclover, ryegrass, and several types of lespedeza. A fewsmall wet lowland areas are present in the pasture north ofthe site, such as around the farm ponds and in a few lowdepressions. In these areas, rushes and sedges are foundalong with wild millet, smartweed, and persimmon.
The rural setting around the IWC Site. especially fche woodedhillsides/ provides a good area for wildlife. Birds, smallanimals, and snakes are abundant in the area. Birds andsmall animals, typical of those found in open pastures andoigricultural-rural areas include doves, meadowlarks, fieldsparrows, quail, deer mice and white-footed mice, easternwood rats, cottontail rabbits s raccoons, skunks, and foxes.
Many of the birds and animals found in the pastures and tree-lined fields are also found along the wooded hillsides.However, birds such as thrushes, woodpeckers, and vireoa arerelatively more abundant in fche wooded areas. Animals suchas fox and gray squirrels, raccoons, and deer are more commonin the forested areas than in the open pastures and farmfields. Wild turkeys are also found in the wooded country-side.
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001019
Prairie Creek flows along the valley north of the IWC Siteand is about 1 /2 mile downsiope from the Site. It potential-ly could be impacted by surface water flows from the sitearea and by the artesian groundwater system that is rechargedby precipitation in the site area (that is/ along Long andBackbone Ridge). This perennial stream apparently supportsa good warm-water fish population and provides an excellenthabitat for turtles, frogs/ and snakes. During a site in-spection in June 1983 , many fish were observed in the creek,including sport fish such as sunfish, and wildlife were abun-dant in and along the creek. Prairie Creek is classified asa warm-water fishing stream and is suitable for secondarycontact recreation (EPA, 1 9 8 1 ) .
2 .^ .,7 SQcxpeconomics
Sebastian County, in western Arkansas, is primarily a ruralarea bounded on the north by the Arkansas River and on thewest by Oklahoma. In the early 1970 ' s , about 78 percent ofthe land area was in farms. However, Fort Smith is the prin"cipal trading center for west-central Arkansas and east-central Oklahoma. It is the main employment center for thepeople of Sebastian County. Most of the people in the coun-ty, including more than half of the farmer?, work in indus-tries and businesses within the Fort Smith area {Cox/ etal., 1 9 7 5 ) . Additionally, the Fort Chaffee Military Reser-vation is located just southeast of Fort Smith.
The area economy is based on farming and industry. Corn,cotton, soybeans, and sorghum are important field crops; buttruck farming, dairying, and livestock raising are also im-portant agricultural activities (Cox, et al., 1 9 7 5 1 . Theindustry is centered around Fort Smith and includes manufac-turing, food preparation, packaging, mining, natural gasdrilling, and sand and gravel businesses.
Sebastian County covers approximately 535 square miles andhas a population of 95 /3 .72 (1980 census, U.S. Department ofCommerce, 1 9 8 2 ) . Fort Smith, the largest city in the countyand the second largest city in Arkansas accounts for 75 per-cent of that 1980 population. At the time of the 1980 cen-sus, about 90,000 people lived in the Fort Smith uroan area.The second largest city in Sebastian County is Greenwoodwith a population of 3 ,317 , Greenwood is a second countyseat and is located about 6 miles southeast of the IWC Site.Between 1970 and 1980, the urban population in the countyincreased by 21 percent in contrast to a 15-percent increasein the rural population.
Several manufacturing and industrial firms are located inthe Fort Smith .^rea, and the economy of the area has beenenhanced by continued development along the Arkansas Biver.The Arkansas Rivee is a navigable waterway and a major barge
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transportation route from the Gulf Coast through Arkansasand into Oklahoma. Some major industries in the Fort Smitharea include Whirlpool Corporation, General Electric.. Rheem/Rudd Air Conditioning, Crain Industries, Georgia Pacific,Champion Packaging, and Gerber (baby food) Products Company.
The mineral resources of the region include coal, naturalgas, sand and gravel, and shale* Although coal mining inthe area peaked in the late l800*s and early 1900's, thereis some renewed interest in the area now. Also, mining ofshale, used for manufacturing brick and tile, is importantin Sebastian County along with sand and gravel operations.Natural gas has been obtained from ten different counties inthe area, and several gas fields exist in Sebastian County.Natural gas reserves in the Arkansas Valley region of Arkansashave been estimated at more than 900 trillion cubic feet(Cordova, 1963).
2 , 5 ASSESSMENT OF POTENTIAL IHPACTff
2 - 5 « 1 Public Health and Safety
The extensive underground coal mining in the IWC Site areahas left the area honeycombed with abandoned tunnels andmine shafts. Since the IWC disposal pit is an old stripmine pit, a potential exists for the contaminants to enterthe underground mines along bedding planes and fractures orthrough a mine opening(a) that may underlie the site. Oncein these mines, the contaminants could migrat'a into thegroundwaters of the area.
Some of the farmhouses and rural residences in the area stillobtain water from private wells, although many homes in thearea now get their water from the South Sebastian Water Asso-ciation lines. A few wells south (upgradient) of the IWCSite have been tested by ADPCE for select heavy metals andvolatiles, and these wells did not indicate contamination.However, wells to the north (downgradient) or east and wastof the site have not been tested. The economic impact ofcontaminated wells may be relatively small in this area be-cause municipal waterlines are not far away, but the healthand safety aspects could be critical.
The wastes onsite are buried for the most part; however,several contaminated seeps have been reported. With no sitesecurity, the potential exists for public exposure to *-oxicsubstances. Other potential exposure hazards are posed byshallow-buried, corroded drume that might collapse underfoot or vher. any equipment is driven over them.
2.5 ,_2 Env i ronment
The potential environmental impacts in the vicinity of theIWC Site are apparently limited, but additional field infor-mation is required before a complete assessment can be made,
„.,- — - 2-20
001021
Due to the topography of the site and the occurrence of seepsfrcm the old landfill during wet periods of the year, a po-tential exists for runoff to impact the vegetation on thenorthern part of the site itself and on adjacent property tothe north. Contamination of the vegetation adjacent to thesite could increase erosion potential and prevent full usageof pastureland. Presently several dead fcre^s are adjacentto the site, but the cause at this time is unknown.
Prairie Creek is nearly 1 /2 mile from the site and mightappear to be buffered from potential impacts by distance.However, a strong possibility exists of water interchangebetween the groundwater system and the creek. Also, artesianwells upgradient from the creek may provide a contaminatedsurface water source flowing into the creek. Therefore/ thewater quality of the creek and thereby the fish and wildlifealong the creek could potentially be impacted.
2 .5 .3 _ SocipecQnpmics
Since the landfill has been closed for several years, futureaction on the site will not adversely impact any of the com-panies in the area. The companies that formerly used thesite have long since selected alternative disposal sites ormethods. The potential for impacts to adjacent propertyowners, however/ still romains. During the spring when thegroundwater system gains water, some seeps develop on thesite, and this water drains downhill onto adjacent pasfcure-land. The intrusion of this contaminated water onto thepastureland limits the full use of these pastures by adjacentproperty owners.
2 . 6 ASSESSMENT Or COMMUNITY RELATIONS
Community relations is being addressed by EPA, Region VI.
2._ 1 _ JPATA LIMITATIONS
A significant body of regional geologic, hydrogeolie, andsoils information is available for Sebastian County. How-ever, site-specific data in these areas are virtually nonex-istent, except for general descriptions of site conditionsand limited sampling and testing conducted during priorstudies of the IWC Site and adjacent properties. Also, thereare only limited records of generators or inventories of thetype and quantities of wastes on the site. Although thedisposal of drums and other liquid wastes, poor landfillpractices, and unsuitable site conditions all point to ahazardous waste problem, the present or future health andsafety hazard is not known. This is primarily due to thelack of adequate data. The data limitations listed belowshould be addressed in the remedial investigation process.
001022
1 . No detailed survey or map exists of the site andimmediate vicinity.2. The type and quantity of wastes that are buriedonsite are unknown.3.
4.
5.
The number of homes using private wells in theimmediate vicinity of the site (minimum one-mileradius) is not known/ and private wells downgradi-ent from the site have not been tested.Little site-specific information exists concerningsubsurface conditions or stratigraphy in the areadownslope (downdip) of the site, and the characterof the material directly underlying the landfill.The location of mine shafts or adits, subsidencefeatures, and potential direct or indirect connec-tions between the underground mines and the surfacestrip mine (the XWC Site) has not been determined.No information was found concerning the quality ofthe groundwater at the site, the direction of thegroundwater flow, and the permeability of underly-ing strata. The areas of groundwater discharge inthe vicinity of the site, especially apri':ig8 andseeps between the site and Prairie Creek, are nocknown.Fish and benthic invertebrate populations upstreamand downstream of the site are unknown, as is thecause for the dead trees just north of the site.Flow data for Prairie Creek and other naturalstreams were not available prior to writing theRAMP.
9. The suspected presence of TCDD at the IWCmust be confirmed or ruled cut. lite
DE/IWC/030
001023
Section 3REMEDIAL ACTIVITIES
3 . 1 REMEDIAL ACTION PLAN
3 . 1 . 1 Ove r all App roa ch to S i fce
Available data indicate that quantities of hazardous wastesare present at the IWC Site and that these known and possiblyother unknown wastes pose a hazard to public health and safe-ty and to the environment. However/ the extent of the totalhazard is unknown due to inadequate site data. Remedialefforts are required to define the total hazard, protectpublic health and safety, and eliminate or mitigate the en-vironmental impact.
This RAMP has been prepared to assess available XWC Sitedata and to identify, define, and schedule a sequence ofremedial actions appropriate for the site. Because thisRAMP has been based on available data, it may require revi-sions as new data and information are obtained; and a workplan that will be prepared prior to site investigations willcontain a more definitive and accurate scope of work thanthis RAMP. Preliminary cost estimates are presented foractivities that can be rc.-adily defined within the scope ofthis RAMP, but these costs may also require revisions as newdata become available.
The remedial action plan for the IWC Site encompasses thefollowing general activities:
1 . Phased ' •" 's to further define the nature and extentof the E. ^blems at the site and to collect thedate-. ;ec asary to develop and ev&luate remedialalternatives (Section 3 .3 ) .
2. An FS to develop and evaluate the remedial alterna-tives and recommend the most appropriate alterna-tive based on costs, potential environmental impact,and engineering feasibility (Section 3 . 4 ) .
3. Source control (onsitel remedial actions to reduceor remove hazards on the site (Section 3 .5) .
4. Off site remedial actions to reduce or remove haz-ards posed by the migration of contaminants fromthe source(a) (Section 3 . ? ) .
3 . 1 . 2 Master Site Schedule
Figure 3-1 presents a master site schedule for the RI's, theF'a, and remedial actions. This schedule is developed with
3-1
001024
6
Months from Rl/FSWork Assignment
8 9 10 11 ^2 13 14 15 16 17 18 19 S?0
Work Plans and Project Startup
Phase I Remedial Investigations
Phase I Report
Phase It Remedial (n vest iga lions'
Remedtar investigations Report
Feasibility Study
Preliminary FS Report
EPA Review
Conceptual Design
Finaf FS ReportRemedial Action Designand Implementation
•iiftiiiiinii^
Community Relations Program and Management Activities
'This schedule assumes Phase 1 activities revealed significanthazards at the IWC Site and Phase (I Investigations were required.
W&H3WT Qvar Nat* SietfOute d«pw«t<f an tunwiy rnpOfttt* *.a m* e«Nntfef ubo««ran««
Figure 3-TMaster Remedial Action Site Schedule
Industrial Waste Control Site
001025
best estimates of the time required for each major activity/-however, actual project developments may cause elements ofthe schedule to shift chronologically or alter..the.activityduration.
fibiioho
3.2 INITIAL REMEDIAL MEASURES
No initial remedial measures are proposed for the XWC Sitebecause no imminent threats to public health or the environ-menx i-'ere judged to exist at the site. The facility is aclosed and covered landfill, does not pose an immediate riskto t:he existing land uses, and has existed in its presentunguarded condition for several years. ; 's
At the initiation of site investigations, appropriate measureswil^. be taken to limit site access and protect the publicfroe: any hazardous materials exposed during onsite studies.3.3 REMEDIAL INVESTIGATION
3« 3 . 1 Objectives . ,
The d.\ta an^. information available, on the IWC Site at: ^histime are insufficient to fully characterize the contamina-tion present, to develop viable rem^di'.al action alternatives,and for conceptual design activities following selection ofa preferxed alternative. Therefo^a, RI studies are requiredprior to conducting the FS.
Site-specific objectives for the RI are described more com-pletely in Section 3 .3 .2 , In general, the objectives wouldinclude, but not be limited to, studies of surface water,^rour.dwater, soils (or fill material), and geology to do, thefollowing: ^
Identify specific contaminants posing acute orchronic hazards to public health.
o
Determine the physical characteristics of fehaSite. ~\
0
Determine the type and extent of soil and ground-water contamination at the IWC Site.
0
Determine the type and extent of soil, groundwater/and surface water contanunation that may have mi-grated from the IWC Site. -„... - IB^
0
Define pathways of surface and groundwa&ar trsna.-port of contaminants. //. ; . ,_ . . • -.^;:
0
Determine if the IWC Site contamination has ad-versely affected the area eao-logy. .. ^ .
0
•k 1 ',iv:
:-ig<ti<l liores
^^W^ •c^11 l\'-^tuld'' °' imed^' ^- -st'^ spe•vyingy; iks3 f tr' and) , y .
^reamr'^",~TI shm E:ofthi;
fQ tl• pr<
'f^.y ' s^ .a•sswof (
-^^- [ th&th !-•mate
'"•"wv - •y.-"'' i tfic!^^•^l EP2*
Back§ , avuld
3-3 3-4
001026
o Determine and describe physical site features thatcould affect migration of contaminants, methods ofcontainment, or methods of cleanup (for example,mine shafts, faults).
3 . 3 . _ 2 _ _Scope pf_WorkThe scope of work proposed for the RI should consist of thefollowing activities;
o Project Startup/Work Planso Si^e Definition Activitieso Phase I Site Investigationso Phase XI Site Investigationso Preliminary Remedial Technologieso Remedial Investigation Reporto Management Activities
Activity I—Project Startup/Work PlansActivity I should include a series of tasks to refine thescope of work for the remedial investigation discussed inthis RAMP. This activity should also develop a schedule andwork plan to implement the remedial investigation activities.Unless otherwise noted under specific tasks, the cost esti-mates are based on the following assumptions. The low costestimates assume that the tasks can be accomplished withlittle difficulty and limited travel. The high cost esti-mates assume more difficulty and usually additional travel.Ta s k 1 -1. As sembIe Project Tea_m. Upon receipt of the workauthorization, a project team should be assembled. A kickoffmeeting should be held between EPA Region VI, ADPCE person-nel/ and appropriate members of the project team. The fol-lowing are the objectives of this meeting:
o Introduce respective team memberso Discuss the overall project objectives and approacho Obtain relevant datao Discuss sensitive issueso Establish channels of communications and reporting
The low cost estimate assumes that two project team membersattend the kickoff meeting with ADPCE and EPA in Little Rock,Arkansas. The high cost estimate assumes that three projectteam members are involved and that meetings are held withADPCE in Little Rock and with EPA and the FIT contractor inDallas^ Texas.Task 1-2. Gather and Review Background Data. During andfollowing the kickoff meeting, available background data notcollected during the RAMP should be obtained from the files
3-4
001027
of the EPA, FIT contractor, state, county, local and regionalorganizations, and other pertinent sources.All new data obtained should be reviewed on a preliminarybasis due to the limited time available for preparation ofthe work plan for Task 1-6. RI tasks recommended in thisRAMP should be revised as appropriate. Further data reviewwill be accomplished during Task 2-2, Data Collection/Literature Ssarch, and Task 2-5, Work Plan Update and Report.The low cost estimate assumes that 2 man-days are spent dur-ing the kickoff meeting trip to gather background data inLittle Rock and that additional data from EPA and the FITcontractor are delivered to Denver. The high cost estimateassumes that 6 man-days and a visit to Fort Smith (coincid-ing with the kickoff meeting trip) are required to gatherbackground data in Little Rock, Fort Smith, and Dallas. Thelow and high estimates assume 2 and 4 man-days, respectively,to review and assess the additional data.Task 1 " 3 . Prepare Quality Assurance Project Plan. A site-specific quality assurance project plan (QAPP) should bedeveloped that incorporates, by reference, the appropriateportions of the REM/FIT general quality assurance plan. Theplan should include any other needs specific to the workassigned or requested by EPA as a result of extraordinaryproject requirements A copy of the QAPP should be providedto appropriate EPA and ADPCE project personnel.The plan should be consistent with requirements of EPA'sContract Laboratory Program. It should also address thefollowing:
o QA objectives for measurement datao Sampling procedures and sample custodyo Instrument calibration procedureso QA performance audits and reportingo Preventive maintenanceo Corrective acti --n procedures and documentation
Task 1-4. Prepare Site Health and Safety Plan. A site healthand safety plan should be developed for the remedial inves-tigation activities. The plan should include a. health andsafety assessment to determine hazardous chemical exposurelevels in the surface water, groundwater.. and soils at theIWC Site. Such information will be useful during the imple-mentation of R I ' s . The assessment will also provide localresidents and investigation teams with adequate warnings andsafeguards, and address safe procedures for geologic, surfacematerial, and water sampling.The health and safety assessment should include, at least,the following generalized items:
3-5
001028
a. The risks should be assessed in terms of the envi-ronmental fate of the metals and chemicals knownto be onsite, potential human exposure (ingestion;dermal contact), and the type of toxicologicalaffects (acute, subacute, or chronic).
b. The restrictions that may apply to work at and inthe vicinity of the site should be delineated.
c. Safe work proced.ires should be defined.
The low cost estimate assumes that a one-day trip is requiredto Fort Smith. The high cost estimate assumes that a 3"daysite trip is required with stops in Fort Smith, Arkansas,and Dallas, Texas.
Task 1-5. Identify Preliminary Goals and Objectives. Theproject team should identify preliminary cleanup goals andassociated alternative remedial actions to assist in target-ing the scope of investigations to be described in the workplan. These goals and options should be based on discus-sions with EPA and ADPCE personnel. They should includeobservations from site visits, conclusions drawn from thereadily available background data, and experience from othersites. The preliminary goals and alternative remedial ac-tions should be reviewed with EPA and ADPCE personnel.
The low cost estimate assumes no travel. The high costestimate assumes that a meeting is held in Little Rock,Arkansas.
Task 1«6. Prepare Work Plan. Based on the informatr'on ob-tained in Tasks 1-1 through 1-5, a draft work plan should beprepared and submitted for EPA and ADPCE review. The finalwork plan should be submitted after receipt of written agencycomments on the draf t plan. However, the work plan shouldbe a flexible document and be revised as the data base isenlarged and as new information might change the directionof the investigation.
Both low and high cost estimates assume no travel.
Task 1-7. Develop a Community Relations Plan. The activ-ities for developing ^Community Relations Plan are beingconducted by EPA Region VI and will be addressed in a reportseparate from this RAMP.
Activity 2—Site Definition Activities
This activity should define the basic physical characteris-tics of the site and establish onsite health and safety fa-cilities for use by all field personnel,
001029
Unless otherwise noted under specific tasks, the low costestimate assumes that the tasks can be accomplished withlittle difficulty and limited travel, and the high cost esti-mate assumes more difficulty and additional travel,
Task 2-1. _Site VjFit, A site visit should be conducted bya limited number of project team members to gather first-handinformation on site features, access routes, potential siteboundaries, and site safety requirements. Yearn members shouldalso meet with appropriate local agencies to establish propercontacts for the investigation work and collect informationfor subsequent tasks.
The low cost estimate assumessite visit are required. Thethat three people for a 2-day
that two people for a 2-dayhigh cost estimate assumessite visit are required.
Task 2-2. Data Collection/Literature Search. A concertedeffort should be made to compile existing literature anddata on the site to supplement that gathered during prepara-tion of this RAMP and during Activity 1 , Project Startup/Work Plans. This information will be useful for furtherdocumenting site history and for providing additional knowl-edge about the operation of the site. The information willalso preclude duplicating studies or surveys that might havebeen done previously.The type of information to be collected and reviewed wouldconsist of general site information, such as air photos,stream flow and classification data, mine workings, and lo-cal water supply information? specific waste type and char-acter information from generators; the landfill history andoperation from the operator and/or county records; and a^yother site information available from state, county, localgovernments, and the EPA.The low cost estimate assumes that ten agenc'ies or firms
-.<ply with the request to supply data voluntarily and thatall agencies support the effort by providing some manpowerfor searching files and copying appropriate data. The highcos',- estimate assumes that 15 agencies provide literatureand data but that most of the search and copying is done bythe field investigation group. The low and high cost esti-mates assume 3 and 6 man-days, respectively, to review thedata and incorporate it into appropriate reports,T^g^2"^. Prepare Topographic Site Map. A site map shouldbe prepared showing topograpnic features, streams and drain-ages, buildings and utilities, roads, and other pertinentfeatures. Such information is necessary for developing,screening, and selecting remedial actions as well as for t:ieactual design and contracting of the remedial actions. Dur-ing the site survey work, a benchmark should be established
001030
onsitle or in the immediate vicinity of the site for laterc[roun!dwafcer and geological studies,
Two topographic maps should be prepared, one showing prin'LSLr-ily the IWC Site itself and one showing the site and thesurroiunding area. The site-specific base map should be at ascale, of one inch = 50 feet and show 2-foot contour inter-vals. The e rea map should include Prairie Creek north ofthe site, at least part of Long Ridge to the south, and amile or more of the countryside east and west of the site.The ayea map might have a scale of one inch = 200 feet andshow '5- or 10-foot contour intervals.
The legal description of the permitted IWC Site boundariesand adjacent properties should be researched and verified inthe field. The intent is not to perform a property boundarysurvey but to confirm boundaries so that subsequent Rl' s andremedial measures will not carry over into neighboring prop-erties without appropriate oermission. Since part of thelandfill was leased and is currently not under IWC ownership,the legal issues concerning remedial actions on that proper-ty should be carefully defined before Rl studies begin.
The low cost estimate assumes EPA will prepare the topo-graphic maps from existing aerial photographs and providethis service at no charge to the project, A few man-days oftime will be required to coordinate project requirementswith EPA. The high cost estimate assumes that the contractorprepares the topographic maps from existing aerial photo-graphs and 2 days of field survey work arfi required.
Task 2-4. _Sifce Safety Facilities. The objective of thistask is to identify and provide site safety and deconfcamina-fcion facilities for the RI/FS activities.
A combination decontamination and office trailer should besupplied for site use by all field personnel, as requiredand identified in the health and safety plan. The facilityshould be supplied on a rental basis. Detailed specifica-tions should be developed for space requirements, decontam-inatioh equipment, furnishings/ and utilities (power, water,and waste). The facility should include a secure waste ma-terial storage area for temporary storage of wastes generatedduring\onsite work.
Task 2-5, Work Plan Update and Report. Based on the datacollected in Tasks 2-1 through 2-4 / the work plan preparedin Task 1-6 should be reviewed and revised aa needed.
A summary report should be prepared at the conclusion of theSite Definition Activities, including the results of Task 2-1through 2-4 and the work plan update. A copy should be pro-vided t.o appropriate EPA and ADPCE project personnel.
001031
Activity 3--Phase I Site Investigations
Phase I site investigations should be conducted to assist incharacterizing the site and in defining actual or potentialpublic health and environmental hazards. Because of thelack of detailed information concerning the IWC Site> thesite investigations should be conducted using a two-phasedapproach.
Phase I is designed to gather basic site data and to deter-mine physical site and waste characteristics and, in a gen-eral sense, if migration of contaminants from the site hasor potentially can occur. The results of these investiga-tions should be used to define the nature and general extentof the problem at the IWC Site and to determine whether ornot conditions at the site pose significant public health orenvironmental hazards.
Information gathered during Phase I should be used to deter-mine whether or not Phase II investigations are needed and,if needed, what the Phase II scope of work should include.If Phase II activities are not deemed necessary at the endof Phase I, efforts may be shifted to the feasibility study.
Phase II investigations would include more detailed fieldstudies and testing programs and would be designed to corn"plete the data base required for developing and evaluatingremedial action alternatives. These studies would be moreintensive and maybe more extensive than Phase I studies andwould provide a-.'^quate information for development of reme-dial action alternatives/ cost estimates, and conceptualdesign.
The Community Relations (CR) Program developed by EPA Re-gion VI should be initiated prior to implementing any siteactivities. Also, Advisory Notices should be distributed asa part of the CR program prior to site studies and at appro-priate major stages of the RI/FS work.
Task 3'*!. Geological Investigations. This task consists ofseveral subtasks that should gather basic information cur-rently unavailable on the physical characteristics of thesite. The information gathered should aid in determiningwhat problems or potential hazards are posed by the site andin defining aajor pathways that may exist for offsite migra-tion of contaminants. The subtasks have been separated ac-cording to purpose or goal to enhance understanding of thescope of work.
Subtask 3"1-1. Subsurface Investigation.
Little information exists concerning the physical character-istics of the materials underlying the IWC site. A
3-9
001032
subsurface investigation should be performed to determinethe thickness, depth, occurrence, and properties of materialsbelow the site. The information generated by this studywould be used to develop a general understanding of sitecharacteristics, to determine the presence of aquicludes orimpervious layers, to define the structural characteristicsof the subsurface surafca, and to aid in determining if po-tential subsurface pathways for migration of contaminantsexist.The Phase I investigation would consist of both shallow anddeep borings drilled around the perimeter of the site. Theshallow borings should be drilled to depths of approximately§0 feet and should be located primarily along the northernboundary (downgr^dient) of the site. One shallow boringshould be drilled upgradient of the site. Two deep boringsshould be drilled to a depth of approximately 150 feet andshould be located both upgradient and downgradient of thesite.In alt the borings/ unconsolidated or overburden materialsshould be sampled at regular intervals using conventionalsoil sampling techniques. These soil or fill samples shouldbe tested for degree of contamination (if applicable) and todetermine engineering properties of the materials sampled.The remainder of each boring should be continuously coredthrough the underlying sedimentary rock to final depth/ usingan HX or NX size core barrel. The rock core should bi2 sare"fully logged and used to define subsurface stratigraphy,structure of the rock, rock quality designation ( R Q D ) , andgeneral engineering characteristics of the rock. Core sam-ples could also be used for permeability and other rock test-ing, if required, in later phases of investigation.All of the samples recovered during t e subsurface investiga-tion should be field scanned using the HNU photoionizer forpresence of volatile contaminants. Drilling should be donein compliance with EPA and other applicable regulations,with drilling equipment being decontaminated between borings.All borings should be designed and developed for monitoringwells (see Subtask 3-2-2).The low cost estimate for this task assumes that four shal-low borings and two deep borings will be completed using ro-tary techniques. In addition, the low cost estimate assumesthat 4 samples will be tested for contaminants and that12 samples will be fcested for engineering properties. Thehigh cost estimAte assumes that six shallow borings and twodeep borings will be completed. The high cost estimate alsoassumes that 8 samples will ue tested for contaminants andthat 20 samples will be tested for engineering properties.Figure 3-2 shows suggested locations for Phase I borings.
001033
001034
Sub^ask 3-1-2. Air Photo Interpretation and GeologicReconnaissance,
Air photos providing st^reographic coverage of the IWC Siteshould be gathered and reviewed. These should include pho-tographs from past years {if. available), as well as recentphotos. These photos should be used to help determine sitegeology; the presence of major geologic features such asfaults and joint systems near or on the site, which may actas conduits for migration of contaminants; areas of ground-water discharge such as springs and seeps; and areas of sub-sidence or mine features related to the nearby abandonedunderground mines. This inforn.ation will be used to identifypotential pathways for offsite migration of hazardous mate-rials and to gain additional understanding of the site'sphysical setting.
A brief geologic field reconnaissance should be performedafter the photo interpretation work is completed. This wouldinclude field verifying features identified on the photos aswell as noting overall surficial geologic conditions.
The low cost estimate assumes that air photos are easilyavailable at little or no cost and that they will requirelittle; time to locate. In addition, it assumes that oneprofessional will conduct a 2~day photo interpretation andthat two professionals will conduct a 2-day field reconnais-sance. The high cost estimate assumes that the air photosrequire more time and effort to obtain and cost more. Italso assumes that one professional .'ill conduct a 3-day photointerpretation and that two professionals will conduct a4-day field reconnaissance.
Subtask 3-1-3. Mine Working Investigations.
The IWC Site is located in an area underlain by abandonedcoal mines. Features such as shafts, drifts, and subsidenceareas are usually associated with underground mines and, ifpresent near the site, may provide major pathways for migra-tion of contaminants offsite and for contamination of ground-water.
An investigation supplementing the work already done by FITshould be undertaken to determine if any such features arepresent in the vicinity of the site. Where possible/ thecondition of these features should also be determined. Inaddition to the air photo interpretation described above,the Phase I work would include additional literature andmine map reviews, an onsite reconnaissance, and, if possible,interviews with people familiar with the eld mine workings.Any features identified would be marked in the field andlocated by field survey.
001035
The low cost estimate assames that relevant litcr^.tur^ iseasily available at little or no cost and tbst it will re-quire little time to locate. In addition, it assumes thattwo professionals will conduct a 3-day field reconnaissanceand survey. The high cost estimate assumes that literaturerequires more time and effort tc locate and that it is morecostly. It also assumes that two professionals will conducta 5-day field reconnaissance and survey.Task 3-'2. Hydrogeologic Investigation. A hydrogeologicalstudy should be conducted to determine the current uses ofprivate wells in the area, to define groundwater occurrence,and to define the direction and rate of groundwater flow.In addition, the study should determine if there is any con-tamination of groundwater attributable to the site. Thespecific chemical contaminants and their concentrations inthe groundwater should be identified at each sampling loca-tion. This information should help in identifying possiblesources of contamination and patterns of concentration,Subtask 3-2-1. Survey of Nearby Wells.A survey of private wells within a one-mile radius should beconducted using existing public records and door-to-doorsurveys. This important task can be implemented early inthe RI. This survey should identify the location/ depth,type, and use of existing wells, as well as the number ofpeople who use wells for potable water. This informationwill identify potential health hazards. Several downgradientwells should be sampled later because only upgradient wellshave been tested so far.The low cost estimate assumes minimal time to search existingrecords and one day to complete the door-to-door survey.The high cost estimate a&sumes considerable time for checkingand identifying existing records, and a 3-day door-to-doorsearch.Subtask 3-2-2. Develop Monitoring Wells.Monitoring wells should be completed around the site usingthe core borings drilled for the subsurface geologic inves-tigation. These wells should be used to determine waterquality both upgradient and downgradient of the site, todetermine direction and rate of groundwater flow, and todetermine general aquifer characteristics. The borings shouldbe placed to have at least two upgradient and foar downgra-dient monitoring wells. The wells should be ccinpleted andsampled to satisfy at least minimum RCRA requirements. Theproposed locations for these monitoring wells are shown inFigure 3-2.
001036
After drilling, each core hole should be constructed as a2- or 4-inch-diameter monitoring well. Actual zones to bescreened and developed will be determined in the field basedon results of drilling. Wells will not be completed in moretha i one aquifer at a time. The wells should be developedby surging and pumping. The locations of the monitoringwells should be surveyed to gain horizontal and verticalcon-crol. Drilling and well completion should be in accor-dance with EPA and applicable state and local regulations.As stated earlier, all drilling equipment should be decon-ta<aJ.nated between r.e '. holes.
The low cost estimate assumes that four approximately 50-foot-deep wells and two 150-foot wells are completed as2-inch-diameter wells in rock. The high cost estimate as-sumes that six 50-foot wells and two 150-foot wells are com-pleted, and two of the eight wells are 4-inch-diameter wells.
Subtask 3-2-3. Groundwater Sampling and Sample Analysis.
After installation, development, and stabilization of themonitoring wells, a groundwater sample should be collectedfrom each well. Samples should also be taken from selectedexisting private wells that were identified during Sub-task 3-2-1.
Standard EPA sampling procedures using acceptable pumping orextraction techniques should be used. Prior to taking th-ssample, the static water level should be measured. Followinga presample well purge, the pH, temperature, and specificconductance of th^ groundwater sample should be measured inthe field.
Samples from each well should be tested (GCMS Scan» for pes-ticides, metals, and organic contaminants as listed in Ta-ble 3 -1 . This list of parameters may be revised after theevaluation of the first set of analytical results.
All sampling and testing should conform to guidelines in theUser's Guide to the U.S. EPA Contract Laboratory Program(CLP) prepared by the Sample Management Office of CLP andpublished in August 1982, All samples should be low-concentration samples according to the CLP criteria.
If significant impact or hazard is revealed during the Phase Ihydrogeologic investigations, then the field sampling programshould be shifted to Phase II. If hazardous levels of con-taminants are not detected, then these wells could be usedas long-term monitoring wells for the IWC Site. For planningpurposes, it was assumed that moderately hazardous conditionswere detected during Phase X sampling and that Phase £1 in-vestigations are initiated.
001037
Table 3-1ANALYTICAL PARAMETERS—ORGANICS AND INORGANICS
Pesticides
AldrinAlpha BtiCBeta BHCGamma EKCDelta BHCChlordane4,4-DDO4,4-DDE4,4-DDTDieldrinAlpha EndosulfanBeta EndosuUanEndosulfan SuXfateEndrinEndrin AldehyAeHepfcachlorHeptachlor ExpoxideFCB 1016PCS 1?21FCB 1232PCB 1242PCB 1248PCB 1254PCB 1260Toxaphene
Acid ExtractlbleOrganics
2~Cholorophenol2/4-Dlchlorophenol2,4-Dl»ethylphenol4,6-Dlnitro-O-Cresol2,4-Dinitrophenol2-Kitroplienol4-NitrophenolP-C-hloro-H-CresolPentachloroghenolPhenol2,4,6-'*'fichlorophenol
Base-Neutral_^<tractible Grganlcs
AcenaphtheneAcenaphthyleneAnthraceneBeiizidineBenzo(alanthraceneBenzotalpyreneBenzo(b)fluorantheneEenzotghOperyleneBenzo(k)fluorantheneBis(2-Chloroethoxyl) KethaneBis(2-Chloroethyl» EtherBis(2-Chloroisopropyl.) EtherBls(2-Ethylhexyl) Phthalate4-Bromophenyl Phenyl Ether2"Ch1oronaph tha1eneChrysene4-Chlorophenyl Phenyl Ether1,2,5/6-Dlbenzanthracene1.2-Dlchlorobenzene1.3-Dichlorobenzene1.4-Dichlorobcnzene3,3-Dlchlorobenz tdineDiethyl PhthalateDimethyl PhthplateDi-N-Butyl Phthalata2,4-Dinitrotoluene2,6-DinltrotolueneDi-M-Octyl Phthalate1,2-Diphenylhydrazin6FluorantheneFluoreneHexach1oroben ze neHexachlorobutadieneHexachlorocyclopentadieneHexachloroethaneIndeno(1,2,3-CD)py reneIsophoroneMapthaleneN-Butyl Benzyl PhthalateKitrobenzeneN-HitrosAdiaefchylaaineM-MUrosodi-N-PropylaBineH-NlfcrosodiphenylaainePhenanthrenaPyreneTCDD1,2,4 Trichlorobenzene
yolatile j)rganics
Aero leinAcrylonitr:.leBenzeneCarbon TetrachlorideChiorobenzene
2-Dicho1 roe thane1,1-Trlct.loroethane1-Dichloroethane1.2-Trichloroethane1,2,2-Tetrachloroethane
Chloroethane2-Chloroethylvinyl etherChloroform1.1-DichloroefcheneTrans-li2-Dtchloroet.hene1.2-DichloropropaneTrans-l,3-DtchloropropeneCls-l,3-DichloropropeneEthylbdizeneHethylene ChlorideChloroaethaneBroaioBe thaneBroaofo^Broaor nioroaethaneFluor ichloroaethaneDichli. - t>d i f luorcae thaneCnlorodibro;nome thaneTetiachioroetheneToluaneTrichloroetheneVinyl Chloride
InorQanics
AluaiinucAffitnoniaAntiBonyArsenicBariuinBerylliumBoronCadniiL-ChroaiuaCobiltCopperCyanideIronLeadManganeseMercuryHickelSelcr.iuBSilverSulfideThalliuBTinVanadiuiZinc
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The low cost estimate for this task assumes that three ex-isting private wells and six onsite monitoring wells will besaapled once and the samples analyzed by an EPA contractlaboratory. The high cost estimate assumes that five exist-ing private wells and eight monitoring wells are sampledtwice and the samples analyzed by an EPA contract laboratory.Both estimates assume that after initial sampling and analy-sis, the field program will be shifted to Phase II.
Task 3*3, Hazardous Waste Characterization. The types ofwastes buried at the IWC landfill are not well defined.Therefore, a sampling program should be conducted to deter-mine what contaminants are contained within the aifce andcould be migrating away from the site.
The soil 01 fill near the bottom of the disposal pit shouldbe sampled. Because of the uncertainty of the types of mate-rial and the methods used in backfilling the pit, and thepresence of the buried drummed wastes, a sampling methodcannot be specified a this time. During the initial sitevisit, an evaluation of the fill material followed by a com-prehensive review of the existing site information should beconducted to select a sampling method. Special attentionshould be focused on the May 1 9 8 3 magnetometer and electron-magnetic conductivity surveys because the results of thesestudies at this time are preliminary. The sampling programshould also consider health and safety factors, such as rup-turing buried drums, and the capability of each samplingmethod to obtain a representative soil sample at depth acrossthe site. At this time, it appears that pushing or drivingshelby tubes or splitbarrel samplers/ backhoe excavation, ora bucket auger process should be considered as possiblesampling techniques.
At least two areas on the site should be sampled, and thesample for each area should be composited from three soilborings (holes). These samples should be analyzed for theorganic and inorganic compounds listed in Table 3-1.
Task 3-4. Surface Water and Sediment Investigations. Sur-face water resources in the area are limited primarily toPrairie Creek, several farm ponds or filled gravel pits, andlocal drainages. The main objective of the surface waterinvestigations should be to determine if any of these waterbodies are contaminated, and if so, to identify the probablesources of contamination. Prairie Creek should be investi-gated because of the potential contamination from the ground-water system via seeps or artesian flows.
Sediments in the bottom of some water courses should be sam-pled to determine if hazardous substances have accumulatedin bottom sediments, and soil from seep areas should be sam-pled to determine what chemicals are carried in the leachate
3-16
001039
flowing to the surface. Soil samples from seep areas shouldalso be analyzed to confirm the presence or absence of TCDOat the IWC Site.The first part of this investigation should be the delinea-tion of surface drainage paths on the IWC Site itself and inthe area between the site and Prairie Creek. These flowpatterns ehould be illustrated on an accurate topographicmap. This task will require a thorough site reconnaissanceduring the early spring (or wet period) to identify all sur-face water flows including leachate seeps/ springs, artesianwells, drainage ditches, and ponds. A visual or field surveyestimate of flows should be recorded for major drainages andfor any artesian wells. Flow data for Prairie Creek shouldbe obtained from the U . S . Geological Survey or state agenciesWater quality and sediment (soil or fill material in satu-rated areas) samples should be collected and analyzed duringthe early spring field survey. The best locations for sam-pling the water quality (or sediments) of onsite surfaceseeps, major drainages from the site, springs, and artesianwe!la should be determined during the site reconnaissanceand mapping activity described above. For purposes of esti-mating effort and cost, eight water quality or sediment sam"pling locations are assumed; two in Prairie Creek, one inthe farm pond directly north of the site (both water andsediment), two at artesian wells (or springs) downgradientfrom the site, one in a main drainage ditch near the site(both water and sediment), one onsite sample from an activeleachate seep, and one sediment sample location in a lowwater-filled depression just north of the site. At leastone of the artesian wells sampled should have a confirmed orsuspected direct link with an underground mine.A limited water quality sampling program should also be con-ducted later in the year when onsite surface seeps and Isach-ate flows are not present. This program should document thesurface water quality during the dry season and assist inassessing the seasonal variation in contaminant dispersalfrom the site.Again, the best sampling locations should be determined byan area reconnaissance. For purposes of estimating effort,seven water quality sampling locations are assumed; two inPrairie Creek, one in the farm pond on Henson's property(both water and sediment), fcwo artesian wells, and two onsitesediment samples from seep areas.Water quality and sediment samples should be analyzed formetals, pesticides, and organics as shown in Table 3-1. EPAContract Laboratory Program (CLP) guidelines should be fol-lowed for sample collection, preservation, chain-of-custody.aid analytical procedures. Results from sample analyses
001040
should be used to assess the types and quantities of contam-inants leaving the site via surface water flows. Data shouldalso be used to evaluate the possibility of contaminatedgrcundwafcer surfacing downgradienfc of the site and contami-nating Prairie CreeK.. Water quality analyses should be usedto supplement evidence of significant onsite contaminationcollected by earlier studies (E&E, 1 9 8 3 ) .Ths low cost estimate assumes that seven water samples andthree sediment samples are collected and analyzed during thespring (wet-weather period) and that eight samples (fivewater and three sediment) are obtained during the dry-weatherseason. The low cost estimate also assumes that minimaltime is required to locate the artesian wells reported toexist north of the IWC Site. The high cost estimate assumesthat twelve water and si>s soil samples are collected andanalyzed during the spring and that eight water and foursoil samples are obtained during the dry-weather season. Italso assumes that 2 days are required to'locate and map theartesian wells in the area north of the site.Task 3-5. Ecological Investigation. A general survey shouldbe conducted on the landfill site and in the near vicinityof the site to determine the type and relative abundance ofplants and animals at the IWC Site. The survey should beconducted by two or three trained field biologists and shouldbe limited primarily to vegetation, small mammals (includingrodents), birds/ and the aquatic ecosystem of Prairie Creek.A general survey should be adequate to characterize the ter-restrial and aquatic ecosystems, determine if dumping opera-tions at the site have significantly impacted that ecosystem,and provide baseline information needed to evaluate the po-tential impacts of remedial action alternatives.The field effort should include walk-through surveys of eachhabitat type present in the site area to characterize thenatural and introduced vegetation in the area and documentvisible evidence of stressed vegetation. Special attentionshould be focused on the dead trees north of the IWC Siteboundary. Maps should be prepared based on available aerialphotographs and topographic maps to illustrate location andacreage covered by each habitat type/ areas of stressed veg-etation (if a n y ) , and general site features.To evaluate bird and animal populations in the site area,all observations of birds and animals and signs or theiractivity (such as tracks/ scats/ and nests) should be re-corded daring field investigations. Site surveys should beconducted to provide data for comparing the relative wild-life value of each major habitat type and assessing the im-pact on each habitat by dumping activities at the XWC Site.Also, members of the local Audubon Society, the U . 3 . Fishand Wildlife Service, and the Arkansas Game and Fish
3-18
001041
CoEnmission should be interviewed to determine whi^h mamma Isand birds are seasonally abundant in the area, fcc find outwhich mammals and birds are relatively rare in the area (andtherefore, may not be observed during site sur/eys), and todocument which species are rare and endangered.
Fish populations in Prairie Creek and the potential of thefisheries resource should be evaluated using existing dataand a qualitative stream survey by an aquatic ecologist.The survey should include visual observations of stream hab-itat, stream-bottom organisms, and fish, supplemented withsome limited qualitative sampling of fish and benthic inver-tebrates, Stream survey data for Prairie Creek should beobtained from the Arkansas Game and Fish Commission, andinterviews should be held with state and Federal agency per-sonnel or university staff members who have done field workin the area.
Phase I investigations should provide adequate informationto characterise the ecology of the area and assess the impactthe landfill has had on the environment. These Phase I in-vestigations should also provide the information necessaryto evaluate the potential environmental impact of the pro-posed remedial actions* Therefore, no Phase II ecologicalinvestigations are recommended at this time and should notbe required unless Phase I investigations indicate unusualcircumstances that- warrant more thorough site investigations.
The low cost estimate for Task 3-5 assumes a 2-day site visitby a team of two trained field biologists. The high costestimate assumes a 4-day site visit by a team of three train*ed field biologists.
Task 3-6. ._Data Analysis/Report. Data from Phase I siteinvestigations should be analyzed and presented in an interimreport describing the investigative methods, data obtained,results, and conclusions. The general objectives of theanalysis and report are the following:
o Provide a detailed characterization of the physicalsite features and surrounding environment-
0 Document the typesite contaminantsthe contaminantswater systems.
and general distribution of on-and the suspected movement of•n the surface water and ground
o
o
Describe the results of the sampling program onprivate existing wells.Provide baseline data for designing Phase IXstudies, or recommend starting the feasibilitystudy.
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001042
o Present a scope of work for Phase II site investi-gations, including schedule and cost estimates,for EPA review and approval; or recommend initia-tion of the feasibility study at the completion ofPhase I.
Activity 4—Phase II Site Investigations
Phase II investigations should be conducted if Phase I in-vestigations determine that the IWC Site poses significantpublic health or environmental hazards or if data from Phase Iinvestigations are inadequate for developing and evaluatingremedial action alternatives. The detailed scope of workfor Phase II investigations should be developed in thePhase I interim report and submitted to the EPA for approval.
Phase II investigations should consist of groundwater, sur-face water, and geological investigations that are more ex-tensive fcha.-i the Phase I activities. Phase II should includeadditional field studies, sample analyses, and monitoringprograms designed bo complete the data base required fordeveloping and evaluating remedial action alternatives. Inmost cases, the same chemical and physical analyses shouldbe made in Phase II as in Phase I. The principal differencebetween the two programs would probably be sampling differentlocations or fionitoring over a longer time period.
The following remedial site investigation tasks are proposedfor Phase II.
Task 4-1-"Geological InvestigationsTask 4-2--Hydrogeological InvestigationsTask 4-3—Surface Water and Sediment InvestigationsTask 4-4-"Hazardous Waste Characterization
Phase II activities cannot be realistically defined at fct-istime because the need, approach, and methodology all dependon study results from Phase I. Therefore, the followingtask descriptions and cost estimates are presented here onlyas an estimate of what might be required for Phas-^ II and asa means of emphasizing that studies at the IWC Site shouldproceed cautiously in a well-planned phased process. Thephased approach should be a cost-effective and safe way t-odetermine what action might be taken to remove or controlthe substantial quantities of buried wastes at the site.
Task 4 - 1 . GeologicalInvestigations. Phase II geologicalinvestigations, if required; should include additional bor-ings to further d& £ine subsurface conditions at. the itfC Site,with an emphasis o-. conditions relevant to development, eval-uation, ard possible design of remedial action alternatives.For planning purposes, it is assumed that two or three deepborings (about 150 feet) and four to eight shallow borings
001043
to a depth of approximately 50 feet will be required to sup-plement the data on subsurface conditions obtained duringPhase t,
Borings should be drilled and sampled following the sameprocedures as for Phase I borings. Samples should be testedfor basic engineering properties and for chemical properties/contaminants iif applicable) as for Phase I testing. Pro-posed boring locations and depths would be determined afterthe completion of Phase I investigations.
The low cost estimate assumes that two additional deep bor-ings and four additional sh.illow borings will be completedusing rotary techniques and that six samples are analyzedfor contaminants. The high cost estimate assumes that threeadditional deep borings and eight additional shallow boringsare required and that eleven samples are analyzed for contam-inants. Both estimates assume drilling and sampling by acontractor and sample analysis by an ERA contract laboratory.
Task 4~2' Hydrogeological Investigations, Phase II ground-water studies, it required, would include the installation,sampling, and testing of additional groundwater wells in-cluding wells located in the abandoned underground mines,where possible. These wells would be used to further delin-eate the level and extent of groundwafcer contamination andto define whether or not the underground mines are hydrau-lically connected to the deeper aquifers identified inPhase I. These data would be used for evaluation of remedialaction alternatives.
Phase II would include additional 2" and 4-inch-diametermonitoring wells to provide a more complete coverage ofgroundwater flows .nd quality than Phase I.
The locations of the wells would be based on Phase I findingsNew wells should be installed and developed following thesame procedures used in Phase I. Sampling procedures shouldalso be the same as in Phase I. The chemical parametersanalyzed for in Phase II should be selected based on Phase Tresults. Samples should be taken from each well after thewell has stabilized. All sampling and testing should con-form to the guidelines established for the ERA CLP.
The low cost estimate assumes that four Phase II wells arerequired and that chree existing private wells and fourPhase I monitoring wells are sampled again and analyzed forcontaminants. The high coat estimate assumes the installa-tion and testing of four additional 50-foot-aeep, 2-inchwells and three additional 4-inch, 150-foofc-deep wells. Thehigh cost estimate assumes that these seven new wells, fiveexisting wells, and six Phase I wells are sampled and
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001044
analyzed for contaminants. B^th high and low estimates as-sucae that the samples are analyzed by an EPA contract labo-ratory.
Task 4-3. Surface Water and Sediment Investigations.Phase II investigations, if required, should consist of ad-ditional sampling and analyses of surface waters and sedi-ments to determine the extent of offsite migration of con-taminants. Samples should be taken at locations of seepanear the landfill site, at selected stations located alongPrairie Creek, and in offsifce areas suspected of being con-taminated. The location of additional stations, the numberof stations, and the frequency of sampling should be assessedbased on the Phase I investigation results. For planningpurposes, it is assumed that the samples would be obtainedonce during spring when stream flows are highest and onceduring the dry aeayon in the fall.
Sampling and analysis procedures should conform to the guide"lines established for the EPA CLP. However, the analysisshould be narrowed, where possible/ to the contaminants iden-tified to have migrated offsite during the Phase I investi-gations.
The low cost eetimate assumes that one additional streamstation, three more offsite areas, and two leaehate stationsare sampled twice. The high cost estimate assumes that twostream stations, five offsite areas, and three leachate sta-tions are sampled twice. Both estimates assume that allsamples are analyzed for inorganics, 25 percent are analyzedfor organics, and no further tests for dioxins are necessary.Both estimates assume that samples are analyzed by an EPAcontract laboratory.
?a_sk ^-4, Waste_Cha_racteri2ation. Phase IX waste charac-terization studies should be conducted, if necessary, tosupply additional information for evaluating and designingremedial actions. Phase I Studies are designed primarily toprovide a better definition of what wastes are buried at theIWC Site. Therefore, Phase II studies might be directedmore at defining the extent and volume of hazardous wastes.
The scope of work and proper methodology for Phase IX activ-ities depends on Phase I results. For planning purposes, alow coat investigation is assumed to include five corings onsite and four back-hoe trenches along the east and west perim-eters of the site. The high cost estimate .xsumes eightonsite corings and eight trenches feo assist in defining theouter boundaries of buried material. Moat samples should beexamined visually in the field and logged, tested with anHNU or OVA, and field checked for heavy metals. Both thelow and high cost estimates assume only six samples are
3-22
001045
analyzed for organics,oxins*
ten for inorganics, and none for di-
Ac^ivity 5—Preliminary Remedial TechnologiesThis activity should be conducted prior to, during, and afterthe Site Investigations. Prior to site studies, projectstaff should review the potential remedial actions that couldbe taken at the IWC Site. This review should include anyprior responses taken or attempted by government agenciesand the operator. The object will be to identify the sourcecontrol and offsite measures that are reasonable for the IWCSite and to ensure that site investigations provide the datanecessary to develop and evaluate these alternatives.During site investigations, this activity will be primarilyfor quality assurance. Project team members should reviewstudy results as they become available to ensure that allreasonable and practical alternatives are considered and tofine-tune data collection activities, if required.Activity 6--Remedial Investigation ReportTeam members responsible for the tasks under Activities 2 ,3 , and 4--Site Investigations, should analyze the resultantdata and prepare report section0 describing their methods,results, and conclusions. Respective data sets should beanalyzed and described with the following report objectivesin mind:
o Identify (-he sources of contamination on the IWCSite.
o Determine extent of contamination.o Access the potential impacts and hazards of con-
tamination on public health and the environment.o Provide data for evaluation and selection of reme-
dial action alternatives.o Provide information for selecting source controls,
offsite measures, or an appropriate combination.Prior &o drafting the Remedial Investigation Report, teammembers should meet with the EPA to discusr the results ofsite Studies and review the report outline. At this time,viabl< remedial actions can be discussed and the proper levelof effort defined for the report. Xn addition, the teamshould address the level of effort and scope of the feasi-bility study.
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The Remedial Investigations Report should include the resultsand conclusions of Activities 1 through 5 , and incorporatebasic data. summaries in an appendix.Activity 7-"Management ActivitiesDuring the entire process of implementing the remedial ac-tions at the IWC Site, including initial planning and siteinvestigations, several management activities are required.Technical and financial progress/status reports should besubmitted monthly to the EPA. Technical progress reportsshould compare actual completions with the prior months'plans and explain any deviations. Difficulties encounteredand actions taken to rectify those problems should be pre-sented. The financial report should include graphic compar-ison of proposed versus actual expenditures and projectionsof cost to completion. Any variations in actual or projectedcosts should be explained.All field sampling activities should be documented on project-specific control forms and the required chain-of-custodyprocedures for samples should be followed. Safety, qualityassurance/quality control, and standard operating proceduresshould be monitored to maintain the standards set for theproject.Critical project communications should be documented by suchmeans as telephone memos, notes of conference, letters, andwork order requests and kept in a project file.3._3.3 Remedial Investigation Schedule and Cost EstimateTable 3-2 presents the preliminary cost estimates for theIWC Site remedial investigation activities. Figure 3-3 pre-sents a schedule for these activities.A cost range is provided on all cost estimates. The taskdescriptions for the remedial investigation study providethe basis for the associated cost range.The preliminary cost estimates for the Rl have beer. preparedfrom the information available at the time of the estimateand should be used for guidance in project evaluation andimplementation. The final costs of the RI will depend onactual labor and material costs, competitive market condi-tions, final project scope, implementation schedule/ andother variable factors. As a result/ the final RI costs mayvary from the estimates presented. Because of this expecteddiscrepancy, project feasibility and funding needs must becarefully reviewed before project funds are expended. Thisreview should help ensure that the project is accuratelyevaluated and funded.
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Table 3-2COST ESTIMATES FOR REMEDIAL INVESTIGATION:;
INDUSTRIAL WASTE CONTROL SITE, FORT SMITH, ARKANSAS
5C*'" TCr"— If'1 T l/T—TPC" -JtL. Ml.. i »1.. 1E3
1 . PROJECT aTARTUPAsse».3le Project 'eaa'istbsr/Reviaf D&taPrepare QA ?:anPsepaM ii&3 Plan:D 3odIfi/Cb;ect*»esPrepare Kork PlanCon—ity Relations
TC^AL ?OH ACTIVITY 1
2. SITE DETIKITIOHSita 7iaitLiterature; Pe»l,euPrepare Stt« HdpSite £afec.y facilitiesMark Plar. Opdata
TOTAL FOR ACUVm 2
3. PHASE I SITE INVEST; CAT I OttaGeological Inv««tl;auoa
SubsurfaceAl; Phcito/CeoI. X»coa.HIM Workings
HTdrogeo logical Inv«tig«ti«nSurvy Itoll*Crvlop MiiiiGrouMtvatT SAxpUng
ir«Jf CSiaracttriiaUoflSurfaol M«t«r. S«du*nt
InvestigationsEcological lavsti^aiLoniFhu* . Report
TOTAfc nA ACTIVITY 3
4. PHASE II SITE WVESTIGATIOHSCieologyHydrogeoiogy
TOTAL F0» ACTIVITY 4
;, PB&IP:MA^y BD<a;;Al, TBOt.
". hEHOiiAi. :KVE£TIGAT;0« SEPOPT
-. 'wtAGtKnrr ACTIVI-IB-TrAI. mB REHEDIAL :»VEST:^TIC«£«
^Excludlitq Pfcaf ;: ACLtftt-l—
'erMC/o3<
CA^T
$ 2,2001^002.4002,0301,;003,640
0
S 13,120
S 2,4603,6601,1:02,320t.^Q
< 1 1 . 1 2 0
S (,4»04.2405.200
1,5;03^W)
960
3,120
6,0802,400
i6*»0
S 90,Q«0
-
•*r — -- m iru— <Ut<m
Juriac* 4iE«r/S(KlfenLJ — -•• — 19.7SS•w
< •• e «>« e •• 1 1 in q<o ? ,„ ^ - -? —— 9 3 «I iu / — - —
S 3,440
S 11,300
S 17.4M
$106.-W
Uw
&[Eensej
S 1,530300
3571530
9000
S 3,150
S 1,255290
0985
50
S 2.5CO
f 3,2702,1552,155
\w2,0501 . 1 7 S
600
2.5551,645bTTO
S 18,650
f
«*•*
S SO
S Jad^Wrf
• ^J 3
- ^.no
3"
C^ts<illh-OUU
Contract
$ 03000C0
S 0
S 100
6,2000
S 6,200
S 4<,900 5 54,6500 6,3950 ?,555
0 2.S9Sfl,130 ;3,9407.650 9.785
10.000 13.720
15,750 24,3850 4.0450 18^ MO
S 86,430 5155,160
$ — S
V&sf Cb4ract«rixa&lon — --* —' 16,500 — — — :'.:CC•»
10. X '
S O S
S ^ ;
S . I S
> 53.630 S3
"25
.Total
3 3.73C1,3002,4752,7951,2304,140
„ 0
S 16,270
S 3.7351,9701.1209.505If51Q
S 19,900
54,300
16,500
3,490
11,480 -. 15,440
l?,46tt
23.-8a
Labor
S 3,7604.0003,6903,7602,000'.920
2S :3,120
S 3.920S.ISO3,7604,9603,120
S 20,880
S 7,7208,5608,560
3,5205,2003,200
5.360
8,5606.320
23,60Q
$ 80,600
S
56.ail
S 5.'«0
- :S,576
*l74.376
Hic;h
Exgenses
S 2 ,4152 6IC
'loo995
1,085550
0
s 3,oec
? 1.8251.1001,0451.MO
100
S 5.960
f 4,42i3,1"53,575
1..9252,4202,660
1,150
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wwamw •va? fnduslriat Waste Control StEe ' i
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Figure 3-3Remediat Investtgations Schedule
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001049
Months from Rt/FS Work Assignment
13 15 17 18
Profed Startup
Develop ASternattvea
Screen Alternatives
Engineering Studies
Refine, Evaluate, and Rank Alternatives
PrettfNnary Report
EPA Review
Conceptual Design
Finat ReportDesign andImplementation
Management Activities
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WSfil 37/01,6VS7
Figure 3-4Feasibility Study Schedule
001050
3 . 4 FEASIBILITY STUDY
The FS is conducted primarily to develop and evaluate reme-dial action alternatives and is an integral part of che re-medial planning process.3 . 4 . 1 Objective
The objectives of the FS, based on the results of the RI,include:
o Develop remedial action alternatives to control oreliminate the source (s) of contamination at theIWC Site and the contaminants that may have mi-grated off the site.
o Evaluate remedial action alternatives consideringcosts, environmental effects, and engineering fea-sibility (cost-effectiveness).
o Recommend a most cost-effective remedial actionalternative. The lowest cost alternative (of thoseevaluated) that is technologically feasible andreliable and that adequately protects (or mitigatesdamage to) public health and the environment shouldbe considered the cost-effective alternative.
o Prepare a conceptual design of the recommendedremedial action alternative.
3 • 4 • 2 _Scope of WorkThe FS should develop and evaluate reasonable alternativesand then recommend the most cost-effective alternative tothe EPA. Following review and approval, a conceptual designshould be developed for the selected alternative and a finalreport prepared.Sufficient data are not availablea detailed site-specific scope ofstudy. However, the scope shouldgeneral activities:
for the IWC Site to presentwork for a feasibilityconsist of the following
Activity 1 -Activity 2-Activity 3-
Activity 4 -Activity 5-Activity 6-Activity 7'Activity 8-
•Develop Potential Remedial Alternatives•Screen Alternatives•Recommend and Conduct Additional EngineeringStudies•Technically Access and Evaluate the Alternatives•Prepare Preliminary Report•Prepare Conceptual Design"Prepare Final Report•Management Activities
3-27
001051
Activity I—Develop Potential Remedial Alternatives
Based on the work completed in the Rlbut realistic remedial actions shoulddevelopment of potential alternativessite objectives and existing remedialsider public health and environmental
s , a list or potentialbe developed. Theshould be based ontechnologies, and con-concerns.
The no-action alternative will be included in the evaluationof alternatives and may be a viable alternative ( 1 ) if theother remedial actions present a greater danger than thehazard itself, (2) if an appropriate engineering solution isnot available technically/ (3) if the site is determined tonot be a threat to the public or the environment/ or ( 4 ) ifthe cost of the remedy outweighs the benefits achieved.
Activity 2—-Screen Alternatives
Screening criteria should be developed to assess the remedialaction alternatives. The factors addressed in developingthe screening criteria should include;
o Economic. The estimated capital and long-termoperational and maintenance (O&M} costs and apresent-worth value.
Environmental Effects. The adverse impacts of thealternatives, the adequacy of source control, andthe acceptable mitigation of danger to public healthand welfare and the environment should be identified.Screening criteria should also include permit re-quirements and institutional issues (for example/implementability).
o
Engineering. The alternative must be technicallyfeasible regarding site location and conditions.It must be applicable to the project needs androust be a reliable method of solving the problem.
o
The remedial action alternatives developed during Activity 1should be screened according to the criteria described above,and a technical memorandum prepared summarizing the screeningprocess. Project staff, EPA, and representatives from ap-propriate Federal, state, and local agencies may participatein this screening process to eliminate inappropriate andinfeasible alternatives. The screening process should resultin a refined list of remedial a-i-ternatives.
Activity 3—Recommend and Conduce Additional EngineeringStudies
All remedial alternatives remaining after the screening pro-cess should be thoroughly evaluated. This evaluation should
3-28
001052
include review of the remedial investigation studies for allappropriate data. The project team should also recommendand conduct further data collection, laboratory studies, orbench tests that would be necessary to fully evaluate thealternatives. Further studies might be required to evaluatethe effectiveness or reliability of certain alternatives, oradequately compare the cost, constructability, applicability,and reliability of the alternatives.
Activity 4--Technically Assess and Evaluate the Alternatives
Based on the data from the RI's and the information gainedduring Activities 1 through 3 of this FS, all of the remedialaction alternatives identified from the screening processshould be refined and more fully developed.
A detailed written description of each alternative should beprepared to include: a basic component diagram, a descrip-tion of the required technologies, a list of major equipmentneeds and utility requirements, a conceptual site layoutdrawing, a description of operation and maintenance require-ments (including monitoring and regulatory compliance re-quirements) , a list of potential environmental impacts andsafety considerations, and an implementation schedule.
The remedial alternatives should then be assessed and com-pared, based on accepted engineering, economic, and environ*mental criteria. The comparative technical assessment shouldinclude, but not be limited to, the following factors:
1. Engineering
a. Reliabilityb. Established technologyc. Suitability to control the site-specific prob-
lem(s)d. Constructability ind operability under site
conditionse. Onsite and/or offsite disposal capacityf. Transportation
2. Environmental
a. Adverse impactsb. Effectiveness of mitigation measuresc. Adequacy of source control measuresd. Effectiveness of offsice control measurese. Institutional and legal constraints£. Health and safety requirements
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001053
a. Construction costb. Operation and maintenance costsc* Health and safety requirement costsd. Potential for cost escalatione. Present-worth analysis
The technical assessments and detailed descriptions shouldbe compiled and the alternatives ranked. The alternativesshould be ranked first within each assessment category andthen overall rankings should be developed. Rankings shouldbe based on all available data, professional judgment, andexperience with other hazardous waste sites. Meetings shouldbe held, if appropriate, to solicit input from EPA; Federal,state, and local agencies; or the public. A report shouldbe prepared summarizing the comparative rankings and describ-ing the advantages and disadvantages of each alternative.The result of Activity 4 should be the recommendation of -amost cost-effective alternative*
Activity 5—Prepare Preliminary Report
A draft report should be prepared summarizing data developedduring the evaluation of alternatives and documenting theassessment process. On the basis of the entire evaluationprocess, one alternative or a combination of alternativesmay be recommended for consideration in the conceptual de-sign. This draft report should be submitted to EPA,
The EPA should review the preliminary report and approve therecommended alternative or work with the project team todevelop a compromise alternative. EPA approval of the pre-ferred alternative is required prior to conceptual designactivities.
Activity 6—Conceptual Design
The conceptual design activity will be the mechanism by whichthe selected remedial alternative is) is defined. The scopeof work should provide the data needed to prepare a designconsistent with the objectives of the proposed remedial ac-tion(s), The work scope should also include data sufficientfor preparing an order-of-magnitude level cost estimate forthe remedial action(s).
The principal tasks during the conceptual design activitywould be to develop a detailed work plan for the activityand prepare the conceptual design. We recommend that theappropriate lead agency be included in the review of workplans and work products during conceptual design activities.
The following conceptual design elements should be developed,as required, for the remedial action(s) selected:
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001054
o A conceptual plan view drawing of the overall site/showing general locations for project actions andfacilities
o Conceptual layouts (plan and cross sectional viewswhere required) for the individual facilities,other items to be installed, or actions to be im-plemented
o Conceptual design criteria and rationale
o A description of types of equipment required, in-cluding approximate capacity, size, and materialsof construction
Process flow sheets and a description of the pro-cess
0
A description of structural concepts for facil-ities
0
Utility requirements and rationale
An inventory of the required environmental permitsand institutional requirements
Operation and maintenance requirements
Engineering approach and implementation schedule
/-"Prepare Final Report
A final report presenting the results or i;he feasibilitystudy and the conceptual design of the selected remedialalternative should be prepared. The final report shouldalso incorporate the review comments received from EPA onthe draft report and document the decision process used byEFA and the contractor for selecting the preferred alter-native.
Prior to drafting the report, selected project team membersshould meet with the EPA to discuss the results of the FS,input comments on the conceptual design, and review the re-port outline. At this time, the EPA may request close in-volvement and a review period prior to completing the finalreport.
Activity 8—Management Activities
This activity occurs - - • ^hc- the FS. General tasks includeestablishing project records; r'.tcending review meetings withEPA and state agencies; prep^ri*..'.' "icnthly reports; rricoflamend"ing and documenting changes in the scope of work, if
001055
appropriate; monitoring staffing, budgets/ and contractorperformance; and maintaining quality assurance programs.These management requirements are the same as those listedin Activity 7 of the RI 's .
3 . - t * 3 _Fgasij>ility Study Schedule and Cost Estimate
Table 1-1 presents a preliminary low and high cost estimatefor the IWC Site feasibility study activities. Only thefeot-al cost estimates are presented for the feasibility studybecause information on the site is insufficient at this pointto present estimates with any accuracy. The total costsprovided are based on experiences at other hazardous wastesites and should be a reasonable low and high cost range. Atypical schedule for feasibility study activities is shownin Figure 3-4.
1,5_ SOURCE CONTROL REMEDIAL ACTIONS
3.5.1 Objective
Source control remedial actions include measures to preventor eliminate contamination by containing or neutralizing thehazardous waste at the source of contamination or removingit from the site. Appropriate actions can be formulatedonly af ter sufficient data have been generated through theRI activities to determine the extent and nature of the con-tamination and to determine whether a significant publichealth hazard or environmental problem exists at the site.
3._5._2 Remedial Action Alternatives
Alternative source control remedial actions that may be ap-propriate for the IWC Site include:
1. Continued monitoring of the site with no removalor containment activities.
2. Containment c£ the contaminated mat^riaXft in-place,auch as using a grout curtain or slurry wall, andimpervious cap. A containment technique may alsoinclude a water collection system with groundwatertreatment.
3. In-place treatment to transform or neutralize thecontaminants at the source, or break the contami-nant into components that are no longer a hazard.It should be noted that treatment processes mayproduce waste streams that could requirement treat-ment or disposal.
4. Removal of contaminants from the site with subse-quent offsite treatment or disposal. This
001056
Figure 3-4www »w Feasibly Study Schedule
Months from Rl/FS Woric Assignment
12
Project Siariup
Develop Atle
Sere
13
matives
en AMemathfes
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14
Studies
Refine, Evaluate
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nl Activtties
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ew
ceptual De-sign
Fina
17
Report
18
Design andImptementatio
19
n •
001057
alternative would include transportation of thewaste to an approved treatment or disposal site.
3 . 5 . 3 Cost .EstJ-mate/Schedule
Sufficient data are not available to estimate the cost ofsource control remedial action alternatives at this point.Following the completion of the RI's and the FS outlined inthis RAMP/ cost estimates and tentative implementationschedules should be prepared for the suggested actions.
3.6 OFFSITE REMEDIAL ACTIONS
3 . 6 . 1 Objective
Offsite remedial actions include measures to mitigate theeffects of the hazardous waste contamination that may havemigrated beyond the contaminant source. Appropriate actionscan be formulated and analyzed only after sufficient datahave been generated through the remedial investigation ac-tivities to determine the extent and nature of the offsitecontamination and to determine whether or not a significantpublic health hazard or environmental problem exists offsite.Offsite control remedial actions may not be appropriate ifthe degree of offaite contamination does not pose a healthor safety hazard,
3 . 6 . 2 Remedial Action Alternatives
Depending on the results of the RI activities, the followingoffsike remedial actions may be appropriate for the IWC Site:
1 . Offsite monitoring with no other mitigative mea-sures
2. Removal and treatment of any contaminatec ground-water at carefully located wells immediately northof the IWC Site to interrupt the existing flowpatterns of contaminated groundwater.
3 . 6 . 3 Cost Estimates/Schedule
Sufficient data are not available co estimate thfc cost ofoffsite remedial action alternatives at this point. Follow-ing the completion of the RI*s and FS outlined in this RAHP,cost estimates and tentative implementation schedules shouldbe prepared for the suggested actions.
OE/IWC/032
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001058
LITERATURE CITED
ADPCE. 1983. Field Work Conducted at the Industrial WasteLandfill near Jenny Lind, Arkansas. Internal Memoran-dum of February 9, 1983.
Cordova, Robert M. 1 9 6 3 - Reconnaissance of the GroundwafcerResources of the Arkansas Valley Region, Arkansas.U.S. Geological Survey, Water-Supply Paper 1669-BB; incooperation with the Arkansas Geological and Conserva-tion Commission.
Cox, J. B., B. A. Garner, and F. M. Vodrazka. 1975. SoilSurvey of Sebastian County, Arkansas. U.S. Departmentof Agriculture, Soil Conservation Service and ForestService, in cooperation with Arkansas Agricultural Ex-periment Station.
Ecology and Environment, Inc. 1983. Preliminary Report onMay 1983 Geophysical and Sampling Investigations atIndustrial Waste Control, Fort Smith, Arkansas. Memo-randum of August 10, 1983, from Gordon Duncan (E&E) toDave Petera (EPA)-
EPA. 1976. National Interim Primary Drinking Water Regu-lations, FR40 and 4 1 , December 24, 1975, and July 9,1976.
EPA. 1979. National Secondary Drinking Water Regulations.EPA 570/9-76-000. July m9.
EPA. 1980. Water Quality Criteria Documents; Availability.Federal Register, Friday, November 28, 1980.
EPA. 1981 . Field Investigation Team (FIT) Site InspectionReport of March 24 , 1 9 8 1 . Inspection and Report com-pleted by Ecology and Environment.
Haley, B. R., and T. A. Hendricks. 1968. Geology of theGreenwood Quadrangle Arkansas-Oklahoma. U.S. Geolog-ica\ Survey Professional Paper 536-A.
U.S. Department of Commerce. 1982. 1980 Census of Popu-lation, Volume 1, Characteristics of the Population,Arkansas. Bureau of the Census Report PC80"l-A5"Ark.
VanBuren, Mayn® and Floyd G. Durham. (Date unknown) Hydro-geologic Study of Landfill Site Hear Jenny Line. &DPCEMimeographed Report.
DE/IWC/035
001059
