engineersPlannersEconomists

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June 23, 1986

'K66237.BO

Anthony GardnerU.S. Environmental Protection Agency,Region VI1201 Elm Street, 28th FloorDallas, Texas 75270

Dear Mr. Gardner;

Enclosed are formal responses to comments submitted by thePotential Responsible Parties (PRP's) following their reviewof the Phase I RI Data Report, Final Work Plan, and RemedialAction Master Plan (RAMP) for the IWC Site. The PRP reviewcomments were presented in a letter of September 20, 1985from Mr. Steve Willis of Whirlpool to you. All of theconcerns expressed in that letter were considered whileplanning Phase II RI activities, and as the enclosedresponses indicate, their concerns were addressed durir,Phase II.

Where appropriate, the Final RI or Endangermenfc Assessmentreports have been referenced as the document providing anexplanation or elaboration to the responses provided in thissubmitfcal.

Please call if you have any questions or require additionalinformation on these responses.

Richard E. Moos, Ph.D.SPM/ IWC Site

DE/IWC3/072/si

cc: Mike Harris, CH2M HILL ...Clyde Hutchison, Black & Vea^ch

CH2M HiLi. INC. Rocky Mountain Offic@ CH2M HILL Surfc/lnQ/SWS S Sy/ocuaa Englewood. CO 303.771.0900P.O. Box 225Q8. Qenvsr Colorado 6G233

003264

Industrial Waste Control SiteFort Smith, ArkansasWA No. 6 9 . 6 L 3 7 . 0

Responses to PR? Review of Phase I Reports

The consultant for the PRP*s, Geraghty & Miller, Inc*, re-viewed the Phase I RI Data Report, the Remedial Action MasterPlan and the Work Plan, and provided comments in letter datedSeptember 20, 1986 * The Phase II remedial investigation andsubsequent report addressed their major concerns. Followingis a response to each specific item in the review letter bysection; , . . . . , , „ , . . . . , ' . . j . u . , ^ ^ . . - . . . . i . . ^ ; ^ . ' . " • • • • ' ; 1 ! ' • " ' " " ' 1

A. GENERAL OVERVIEW AND COMMENTS1. The Final Work Plan clearly indicated that the Remedial

Investigation (RI) at the IWC Site would be conductedin two phases, and that the first phase would only par-tially characterize the site. That is why the Phase IData Report does not completely define the ground watersystems. During Phase II, nested shallow and deep wellswere installed to establish the presence of shallow anddeep ground water systems, and determine head relation-ships between these two zones. An analysis of the groundwater systems at the IWC Site i& presented in Section5 , 2 of the Final RI Report.

2 . According to the planned two phased approach, additionalwells were installed during Phase II investigations onand adjacent to the IWC Site. The data obtained fromboth Phase I and Phase II studies provided a data basefor defining the area ground water systems.No wells were installed adjacent to Prarie Creek. Theelevation of Prarie Creek is apparently higher than thepotentiometric elevation of the artesian groundwatersystem that exists immediately north of the IWC Site,and extends northward beyond Prarie Creek. Section 5 . 2of the Final RI Report discusses the area groundwatersystems.

3. The nature and extent of contamination at the IWC Sitewas characterized in the RI report (Sections 5 . 2 , 5 , 3 ,and 5 * 4 ) . The degree of toxicifcy o£ contaminants wasevaluated in the Endangerment Assessment (EA) Report.Samples collected during the RI were analyzed by ERA'SContract Laboratory Program (CLP) for a standard set oforganic and inorganic chemicals. The organic compoundsincluded in this set are based on the hazardous sub-stances list developed for the CERCLA program. Thespecific list of organic compounds analyzed are pre-

003265

sented in the CLP Work Scope for Organic Analyses andin the IWC Site Sampling Plans. The hazardous natureof the site and the potential human health and environ-mental affects are assessed utilizing this standard setof chemicals.It would be economically unreasonable to develop analy-tical techniques to identify all organic compounds foundin samples from the site. This would require developinganalytical standards and GCMS libraries for hundreds ofnew chemicals, which may or may not help in the overallsite assessment process. Therefore, the analyticalresults of samples do contain a number of "unknown"organic chemicals, and their presence was assessed onlyin a general qualitative sense.Dioxin (TCDD) was reported "but not confirmed by MS" ina soil sample taken by FIT during their 1983 field exer-cise at IWC. EPA determined that some extract remainedat the lab from that sample and requested that the CLPreanalyze to confirm whether or not dioxin was present.Keith Bradley of EPA reported that dioxin was not pre-sent above detection limits (2 ppb) in the reanaiysis.A report documenting the results was reportedly preparedby FIT at EPA's request, but no copy of the documentwas made available for the project files.These effortsthe work plandioxin". Themeeting notes

satisfied the intent of the reference in"to determined the presence/absence ofattached Telephone communications anddocument the action taken*

Contaminants at the IWC site which exceeded backgroundlevels and/or presented a public health risk were iden-tified in the RI and EA.During Phase I, a monitoring well was planned for eachlocation where borings were planned, except for threeboreholes designed for rock coring/down-hole geophysics*This plan was followed during Phase I. It was expedientin some cases to obtain soil samples from one borehole,then establish the monitoring well in another holeimmediately adjacent to the first. During Phase II,all boreholes were developed into monitoring wells.MAJOR COMMENTS REFERENCED TO SPECIFIC REPORT PAGESFHJAL, WORK_ PLAN

This statement was based on the Henson versus IWCCourt proceeding documents concerning the allegedrelease of contaminants onto the Henson propertyduring a heavy rainstorm event, on written GQayauni-

003266

III-4

III-6

cations between Henson and various laboratoriesthat analyzed samples submitted by Mr. Hanson, andon field observations at the site.See the above responses to General Comments No.1 , 2, and 3. The phase II Rl filled these datagaps.Preliminary results of the conductivity/resistivity survey were considered during selec-tion of monitoring well locations for Phase X .While drilling the three Phase I monitoring wellsnorth of the site, very little watar was encoun-tered while drilling through soil and shallow rockstrata, and a decision was made to continue drill-ing and develop monitoring wells in the coal seamzone. Water was encountered at the deeper strata,around 50 or 60 feet below ground level, and thewells were developed to monitor that system.Shallow monitoring wellsPhase II to verify Phasethe low-yielding shallownorth of the site.

were installed duringI assumptions and sampleground water system just

The conductivity/resistivity survey results wereused in selecting well locations during Phase II,„ specifically at Stations 23, 40S, and 04.FINAL REMEDIAL ACTION MASTER PLAN1-5

I~6

I"7

2-6

2-8

See response to General Comment N0.4

The potential does exist for public exposure totoxic substances at the IWC Site. However, thethreat was not considered imminent. EPA decidedto initiate Phase I remedial investigations assoon as practical and install fences to limit siteaccess as an early RI Task, rather than interruptthe overall site schedule with an initial remedialmeasure.

Ground water migration should not have been includedin this statement at the time the RAMP was prepared.Phase II results, however, have substantiated thisstatement.

Methyl ©thyl ketone is typically listed as 2-Butanone.It was not included in the &AMP (Table 3-1) , butws one o£ the compounds analyzed during the RI.

See response to General Comment No. 4.

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Attempts were made during the RI to determine thedepth of this 4-inch pipe (with flowing water),but obstructions prevented sounding. Water stoppedflowing from this pipe prior to Phase I field work,but it was flowing during Phase II and was sampled.It was determined, based on Phase II RI results,that the artesian system associated with this 4"inchpipe (Station 34) was not connected to the artesiansystem directly downgradient of the IWC Site.Section 5 . 2 in the Final HI Report discusses theseground water systems.The topography of the IWC Site relative to PrarieCreek would allow rain falling on the site to flowoverland to Prarie Creek. During minor storm eventsit is likely infiltration would occur rather thanrunoff. However/ larger storm events would resultin runoff to Prarie Creek. Prediction of the levelof storm whi<;h would result in runoff from thesite reaching Prarie Creek was not considered neces"sary for development of the HI and FS reports*See also, the response to General Comment N o . 2 .This statement was based on the documents availablein the project files concerning the Henson versusIWC court proceedings, and personal communicationswith Mr. Henson. This conclusion was not retainedin the Final RI Report.Yes. A fence was constructed around the site,signs were placed on that fence, and EPA advisedlocal authorities and residents of the site natureand pending RI activities. Access to the site wasstrictly controlled during the field investigationactivities.See the response to General Comment Mo* 3. Thecontaminants of concern were identified in the RIand EA reports.See the response to General Comment No. 5. ThreePhase I holes, drilled to obtain rock cores andestablish lithology, were the only locations notused for monitoring wells.Prarie Creek was not investigated only because offcha potential impact from seeps or artesian flows.Prarie Croek is the major watershed in the sitevicinity and receives surface flows from the siteand surrounding areas during storms and snow meltconditions.

003268

3-18

3-22a

3-22b

The ecological study at XWC was a survey-type inves-tigation of limited extent* This survey was requestedby EPA, and the results were used to assess potentialcauses for the dead trees located north of thesite, identify ecosystem impacts observably bytrained biologists, determine if threatened orendangered species were present in the area, andestablish the information base required to assessthe potential environmental impacts o£ remedialaction alternatives.The scope of work, presented in the SAMP is asuggested scope of work based on limited data andsite information. The scope of work is developedfurther and refined in the site work plan* Theactual work performed at the site was better definedin the work plan and Phase Z and Phase II samplingplans. The precise intent or meaning of the phrase"field check for heavy metals" in the RAMP couldnot be clarified and was not incorporated into theRI methodology*With respect to dioxin analyses, see response toGeneral Comment No. 4.

DRAFT PHASE I RI DATA REPORT

4-9

5-2

5-7

6-la

6-lb

The project staff agree with this comment. Thepotential for migration of contaminated on-siteground water into the deeper artesian ground watersystem is discussed in Sections 3 . 4 . 3 (page 3-29)and 5 . 2 . 3 (page 5-63) of the Final RI report.Both permeability and head differences are discussed.This item is not addressed in the RI report.There are no sanitary sewers serving homes nearthe site and septic systems are the assumed methodof disposal for domestic wastes.The ground water systems at the IWC Site are dis-cussed in Section 5-2 of the Final Rl report.This discussion presents a more thorough assessmentof the ground water systems, and considers severalfactors in addition to water levels.Base maps with 2-foot contour intervals were usedduring field investigations to interpret drainagepatterns. The map used in thd report was designedto show a large area, so some contour definitionwas not shown.Ponds are not surface expressions of a shallowground water table. The ponds recharge the ground

003269

water. (This is not stated explicitly in the RIbut is implied in th<; discussion of the shallowground water system). See algo the response tocomment 2-19 on the RAMP,

The relationship of the site and Kennedy's pondwas reevaluat^d in the Phase II work. A groundwaterconnection between the IMC site and Kennedy's pondis unlikely. Thus, the referenced statement wasdeleted in the Final RI.

See the response to comment 2-39 on the RAMP.

The nature and extent of the contamination in PrarieCreek is discussed in Section 5 .2 .3 .5 of the RI.The use of the terminology "little evidence" wasused to reflect the inherent difficulty of determin-ing if inorganics are indeed above a natural back-ground level, and the fact that concentrations oforganic contaminants in the samples were low.

The RI report includes this same statement. Theecological survey did not document any evidence ofdeterioration of the off-site environment.

The interpretation of the BMP survey results wasrevised in the Final RI fco reflect the linitationsof the survey controls (Section 5 . 1 . 5 ) . No BMPprofiling was run upgradient (south) of the sitebecause of the steep topography and differences inupgradient and downgradient soil types and geology.E&iP survey transects (both east-west and north-south) far north of the site, however, were usedto assess background conditions. Vertical elec-trical soundings (VES) were also taken to assistin the interpretation of the BMP data.

The Final RI states that neither of the two con-ductive zones that occur immediately north of theXWC Site can be definitely ascribed to a contaminantplume. Section 5 .1 .5 ,2 discusses th^ possibilityof a contaminant plume as one interpretation ofthe EHP data.

Both the EMP and VES data identified a resistivelayer at the surface (over most but not all of thesurvet area), underlain by a relatively thick con-ductive section. The conductive layer underlyingthe resistive (soil overburden) layer probablyrepresents naturally occurring silty shales andclays. See Section 5.1.5 o£ the RI for furtherdiscussion.

003270

The Final RI states that the anomalously high con-ductivity area northwest of the site could be dueto a contaminant plume, leachate from the coalrefuse pile, or an unknown cause. The source ofthe conductivity cannot be determined based onjust the EM data. Surface and subsurface samplesfrom this area support the conclusion that contam-inants have migrated into this area from the site.The conclusions drawn with respect to the EMP sur-vey results are discussed, and appropriately qual-ified, in the Final RI report Section 5 . 1 . 5 .The Phase IX investigations augmented the groundwater sampling conducted during Phase 1. The re-sults of the total RI sampling effort are presentedin Section 5 . 2 - 4 of the Final RI report*Both organic and inorganic contaminants were iden-tified at the IKC Site, as contaminants of concernin the on-site groundwater. Leaching tests aremore applicable to inorganics than organics. Further-more, no single source of contamination was iden-tified and the chemical nature of the site is apparent-ly very heterogenous. Given these conditions, itwould be difficult to obtain a representative sampleset for leaching tests.See the response to General Coroinent No. 3 .The on-site contamination is discussed in Sections5 . 2 , 5 . 3 , and 5 . 4 of the RI. The referenced state-ment has been revised based on analysis of all theRI data.Additional ground water and soil samples werecollected on the site during Phase II. The con-clusions drawn with respect to the on-site shallowground water system are presented in Section 5 . 2 , 4of the RI report. The remedial investigations atthe IWC Site support the conclusion that both thesoil and groundwater media on site are contaminated.Shallow wells were installed during Phase II, todocument to occurrence of off-site migration ofcontaminants within the shallow ground water sys-tem. Contamination of the shallow system is dis-cussed in Section 5 . 2 . 4 of the Final RI.The Phase X and Phase II Sampling Plans indicatethat water samples were analyzed for total metals.Therefore, the samples were not. filtered.

003271

9-12

C

The mobility and potential transport mechanismsfor many contaminants of concern are addressed inChapter 2 of the EA report.

MISCELLANEOUS COMMENTS

FJNAL WORK ,PLAN

III-2 The site maps referenced in Subtask RI 2 . 3 . 3 wereprepared. Large blue-line maps were utilized inthe field and appropriate maps, and figures usingthese maps as a base, were used in the RI and FSreports.

IIX-3 The perimeter fence was installed at thebeginning of Phase I field work.

IIX-9 The monitoring wells were sampled once duringPhase I. These Phase I wells were resampled dur-ing Phase II.

FINAL RAMP

2-8b

2-11

3-5

3-8

3-13

Acetone was inadvertently left off Table 3-1 inthe RAMP. RI samples were analyzed for acetone.Items 6 and 17 in Table 2-1 are the same chemical.It was not possible to document if the wells men-tioned on page 2-20 of the RAMP were the same ordifferent from the three domestic wells reportedlyanalyzed just for metals.The exact concentrations of potentially carcino-genic contaminants at the IWC Site are presentedin both the Final RI and EA reports. The Endanger-ment Assessment discusses these carcinogens, andestimates the risks associated with the concentra-tions observed at the IWC Site*Quality assurance project plans were prepared forboth Phase I and Phase II RI activities,Yes, the referenced topographic maps were preparedSee the response for comment IIX".2 on the FinalWork Plan.Data on well depths for residential wells in thearea are presc ,ited in Table 5-5 of the Final RIreport. Table 5-6 presents well constructiondetails, including depth, for Phase I and Phase IImonitoring wells.

003272

3-15 Table 3-1 in the RAMP was developed in early 1984and represents the suggested list of analyticalparameters. The list of analytical parameters wasrefined and updated prior to field operations, andTable 9-2 represents the standard analyses conductedby CLP during the Phase I study.

DRAFT _PHAgg.._I_,g-I_tJATA REPORT

5-7

5-10

7-17-7

9-59-7

E-3

An Arkansas registered surveyor provided surveyservices during Phase II. The work included aproperty survey, a stadia survey to located moni-toring wells and near site sampling locations, andan elevation survey of both the Phase I and Phase, II monitoring wells.The Phase 1 elevation survey provided interim ele-vations of well casings which were useful in eval-uating the Phase I data. The Phase I measurementsand water elevations were adjusted when the moreaccurate Phase II elevation survey was completed.The adjusted results are reported in Section 5 . 2 . 3of the RI.

Data provided from the Phase II investigationssupplement the Phase I data. The ground watersystems are described in Section 5 . 2 . 3 of the RIreport.

See response to comment 3-18 on the Final Ramp.This was strictly a visual observation of the soilsin the drainage paths entering Prairie Creek.See the response to comment 3-15 on the Final Ramp.Borings at Stations .TWO 1 2 , IWC-13, and IWC-14were made using a portable auger. Heterogenousfill material was observed at these stations.Yes, the questions as to whether VOA data had beenreported as parts per million or parts per billionwas resolved. Data Tables in Appendix B of theFinal RI report include the correct data.The pH measurements taken during Phase I were, insome cases, made with litmus paper rather than apH meter. The pH data in thoses cases were reportedto the nearest one-half unit. All Phase I pH datawere obtained with meters and reported to the nearestO . I unit,

003273

The results of physical measurements of groundwater are discussed in Section 5 . 2 . 4 of the RIreport. The Final RX report also discusses thepotential influence o£ laboratory contaminants,which may include methylene chloride, on analyt-ical results. Field blanks (control simples) wereroutinely taken during both Phase I and ^hase IXstudies to monitor the potential impact of chemicalsintroduced during laboratory analyses.

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