FINAL CLOSE OUT REPORT

FOR

ROGERS ROAD MUNICIPAL LANDFILL 8UPERFUND SITE

PULASKI COUNTY, ARKANSAS

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY,

APRIL 1996

001982
ROGERS ROAD MUNICIPAL LANDFILL SUPERFUND SITE

FINAL CLOSE OUT REPORT

Pulaski County, Arkansas

I. INTRODUCTION

This Final Close Out Report documents that the United States

Environmental Protection Agency (EPA) has completed construction

activities for the Rogers Road Municipal Landfill Superfund site

(Site) in accordance with OSWER Directive 9320.2-3C. EPA, the

Arkansas Department of Pollution Control and Ecology (ADPC&E),

and the city of Jacksonville, conducted an inspection of the site

on September 20, 1995, and determined that the EPA contractors

and the city of Jacksonville had substantially completed the

construction and remedial action activities in accordance with

the Record of Decision (ROD) and the Remedial Design (RD) work

plans and specifications. During this inspection EPA determined

that all remedial activities were complete and that the only

remaining activities were Operation and Maintenance (O&M)

including ground water monitoring.

II. SUMMARY OF SITE CONDITIONS

Background

The Site encompasses about 10 acres in Pulaski County,

outside the city limits of Jacksonville, Arkansas, approximately

12 miles northeast of Little Rock, Arkansas. (See Figures 1 and

2 . ) An estimated 10,000 people live within three miles of the

Site and draw drinking water from public and private wells.

Less than one-half mile west of the Rogers Road Municipal

Landfill Superfund Site is the Jacksonville Municipal Landfill

Superfund Site. Because of the proximity of the sites and the

similarities in their features and characteristics, the siterelated activities for these sites were carried out concurrently.

The city of Jacksonville operated the landfill from the time

it purchased the land in 1953 until 1974. Open burning and

trenching were the primary methods of waste disposal used at the

Site. The landfill was closed in July 1973 when ADPC&E refused

to grant a landfill permit because of the high water table and

poor drainage in the area.

Specific waste types and quantities were not recorded by the

Site owner/operators; however, in addition to municipal waste,

several drums of industrial waste from a local herbicide

manufacturer, Vertac Chemical Corporation (Vertac), were disposed

001983
001984
SITE DETAILS

ROGERS ROAD LANDFILL. JACKSONVILLE. AR

0 50 100

SCALE (FEET)

001985
of in the landfill. On-site soil and about 30 decaying drums

were found to be contaminated with dioxin (2,3,7,8-tetrachlorodibenzo (P ) dioxin expressed as 2,3,7,8-TCDD equivalents), the

herbicides 2,4-D and 2,4,5-T , and the pesticide dieldrin.

In early 1986, the city of Jacksonville fenced the Site to

prevent public access. Although the city of Jacksonville

maintains the fence around the Site perimeter, the Site is still

used recreationally for hunting by local residents.

The Site was added to the National Priorities List on

July 22, 1987, with a score of 29.64 .

Record of Decision Findings

The Remedial Investigation (RI) for the Site, which

described the nature and extent of contamination, was released to

the public in July 1990. The Feasibility Study (FS) was also

released at this time. A 60-day public comment period began on

July 9 , 1990, and ended on September 7, 1990. In addition, a

public meeting was held on July 18, 1990, to present the results

of the RI/FS and to accept public comment.

EPA reviewed the results of the July 1990 RI/FS conducted by

the EPA contractor. Peer Consultants, and all public comments

received. On September 27, 1990, a Record of Decision (ROD) for

the Site was issued. The selected remedy included:

• Excavation of contaminated soil and debris containing

greater than 10 parts per billion (ppb) equivalent

2,3,7,8-TCDD and backfilling the excavated area;

• Transportation of the excavated material to the Vertac

Chemical Corporation Superfund Site in Jacksonville,

Arkansas;

• Incineration of the excavated contaminated material and

disposal of residuals at Vertac;

• Steam-cleaning and disposal of large items of refuse

removed from contaminated areas at the Rogers Road

Site;

• Covering soil, debris and water meeting the criteria

stated below with twelve inches of soil:

1) 2,3,7,8-TCDD concentrations >1.0 and ^10 ppb,

2) Cumulative Hazard Index >. 7 for

2,4,5-T ; 2,4, 5 TP; and dieldrin; or

3) Dieldrin >37 ppb

001986
• Institutional controls such as fence maintenance and

land-use restrictions; and

• Ground water monitoring for at least 5 years.

On June 20, 1994, a Consent Decree (CD) between EPA and the

city of Jacksonville regarding the Site was entered in Federal

District Court. This CD and the CD for the nearby Jacksonville

Landfill Site were the first in the country between a

municipality and EPA that utilized this type of mixed work

settlement. Under the agreement, EPA performed the work that

involved handling the hazardous substances, including picking-up

the hot spots of contamination, transporting the material to

Vertac, incineration, and decontamination. The city performed

the non-hazardous work, including fencing, backfilling, grading,

re-vegetating, inspection and maintenance, installation of

additional ground water wells, ground water sampling and

analysis, and land-use controls.

Community Relations Activities

Because of the high community interest in the nearby Vertac

Corporation Superfund Site, a community relations office, staffed

by an EPA contractor, was established in 1990. The purpose of

this office is to disseminate information to citizens and the

press and to give citizens a focal point for their questions.

An active campaign to notify local residents and receive

input prior to the Site excavation and transportation was

conducted. Landowners adjacent to the Site were visited and

transportation was coordinated with local authorities and

representatives of the Little Rock Air Force Base which is

located near the transportation route. A community open house

meeting was held on August 22, 1994, to discuss the remedial

action and receive citizen input.

A Site close-out open house and ribbon-cutting ceremony were

held on September 25, 1995.

Remedial Construction Activities

On August 22, 1995, Ecology and Environment (E&E) , the EPA

Technical Assistance Team (TAT) and the Emergency Response Cleanup Service (ERCS) contractor, Riedel-Peterson, mobilized to begin

remedial operations at the Site. After preliminary road work was

completed, excavation of contaminated soil was initiated.

During the action, Riedel-Peterson recontainerized

contaminated material that was in decaying drums and excavated

soil. This material, along with investigation-derived waste such

001987
as contaminated personal protective equipment, was transported to

the Vertac site for treatment at the incinerator. Confirmation

soil samples were collected after this initial excavation to

verify the degree of contaminant removal and to determine the

areas of moderate contamination (2,3,7,8-TCDD concentrations >l. O

and ^10 ppb and dieldrin >37 ppb) which would later be covered

with clean soil.

A total of 200 cubic yards of contaminated soil and 76 drums

of hazardous materials (including 19 drums of investigationderived wastes) were transported to Vertac and incinerated. This

is a higher volume than the 130 cubic yards estimated in the ROD.

Despite this increase in volume, remedial activities went

smoothly. Incineration at Vertac began on October 20, 1994, and

ended on December 4 , 1994. The January 20, 1995, Technical

Assistance Report for the Rogers Road Municipal Landfill written

by E&E, details the Remedial Action (RA) activities performed by

EPA and its contractors.

The total cost for the RA was $129,070.00 for the excavation, preliminary sampling, and transportation of the waste

and $1.07 million for the confirmatory sampling and incineration

at Vertac.

During the fall of 1994, the city of Jacksonville continued

regrading activities and installed the three additional ground

water monitoring wells between the Jacksonville Landfill and the

Rogers Road Landfill as required by the ROD and CD. The city

demobilized in late October when heavy rains in the area made

passage through the Site difficult, city activities recommenced

in July 1995 when the Site was sufficiently dry for vehicles to

pass. The city regrading activities were completed in September

1995. A list of all site activities undertaken by the city is

included in the weekly activity reports in the Site file.

III. DEMONSTRATION OF QUALITY ASSURANCE/QUALITY CONTROL

(QA/QC) FOR CLEANUP ACTIVITIES

Because of the simplicity of this action, one work plan was

submitted which encompassed the Remedial Design (RD) and RA

activities at the Site, consistent with the ROD and the CD. The

Quality Assurance Project Plan for the RA detailed the strict

sampling and analytical program. All procedures and protocol for

confirmatory sample analysis included in this document were in

accordance with EPA procedures. The selection of the locations

for confirmatory sampling and a graphical presentation of the

concentrations of contaminants at these locations are documented

in the January 20, 1995, Technical Assistance Report (the

Remedial Action Completion Report) for the Rogers Road Municipal

Landfill.

6

001988
A total of 93 soil samples were taken during the RA to

confirm attainment of clean-up standards. Samples were collected

from points on a 14 x 14 foot grid pattern extending outside of

the boundary of contamination as established during the Remedial

Investigation. Eighty-six of these samples were analyzed for

dioxin and related compounds and 13 were analyzed for dieldrin,

in accordance with the Quality Assurance Sampling Plan (QASP)

prepared for the Remedial Action by the TAT.

EPA provided direct oversight of the excavation and

confirmatory soil sampling activities. The Jacksonville

Community Relations Office maintained administrative support for

the project five days a week.

The QA/QC program utilized throughout the remedial action

was sufficiently rigorous and was adequately complied with to

enable EPA to determine that all analytical results are accurate

to the degree needed to assure satisfactory execution of the

remedial action consistent with the ROD and the RD/RA work plan.

IV. MONITORING RESULTS

The Quality Assurance Sampling Plan explained the confirmatory sampling and analytical program for the remedial

action. The implementation of this plan was detailed in the

Technical Assistance Report. Initially the confirmatory sampling

involved a 14 x 14 grid around all the areas that were visibly

contaminated or shown to be contaminated during the remedial

investigation. Sample locations that did not meet remedial

action goals and all the adjacent grid locations were then reexcavated, and the entire re-excavated area was resampled. This

process was continued until all grid locations met remedial

action goals.

As per the ROD and the CD, areas where 2,3,7,8-TCDD

equivalent concentrations were greater than or equal to 10 ppb

were excavated and the material was transported to Vertac for

incineration. In several areas, this involved excavation deeper

than the one foot projected from previous Site studies. A total

of 200 cubic yards of waste material was removed. Final

confirmatory sampling showed that removal of this quantity of

material was sufficient to meet remedial action goals. The

complete results of the confirmatory sampling are given in the

Technical Assistance Report for the Rogers Road Municipal

Landfill. The data contained in this report demonstrate that

cleanup levels specified in the ROD were achieved.

Ground water samples taken in November 1994, June 1995 , and

December 1995 did not show dioxin contamination, nor did they

show concentrations of organic materials or inorganic (metals)

materials above acceptable health-based levels.

001989
V. SUMMARY OF OPERATION AND MAINTENANCE

Site O&M activities which will be performed by the city of

Jacksonville include routine site inspections to ensure that

positive drainage (as defined in the CD Statement of Work) is

occurring and maintenance of perimeter fencing. These activities

will maintain the protectiveness of the remedy. The city of

Jacksonville, as agreed upon in the CD and accompanying Statement

of Work and as detailed in the RA Work Plan, has assumed all

responsibility for O&M at the Site. In addition, under the CD,

the city agreed to perform the ground water monitoring for at

least five years as required by EPA to ensure that the remedy was

effective and operating properly. Plans for O&M are in place and

are sufficient to maintain the protectiveness of the remedy. The

city is fulfilling its obligation to perform the O&M.

The site is fenced and the city of Jacksonville is

controlling access to the site ground water, so the institutional

controls are in place.

VI. PROTECTIVENESS

This site meets all the site completion requirements as

specified in OSWER Directive 9320.2-3C, Procedures for Completion

and Deletion of National Priorities List Sites and Update.

Specifically, confirmatory sampling verifies that the site has

achieved the ROD cleanup standards: all contaminated soil and

debris containing greater than 10 part per billion (ppb)

equivalent 2,3,7,8-TCDD were excavated and all soil and debris

with 2,3,7,8-TCDD concentrations >1.0 and ^10 ppb, or with a

Cumulative Hazard Index >. 7 for 2,4,5-T ; 2,4, 5 TP and dieldrin

were either excavated or covered with one foot of clean soil.

In addition, no soil was left onsite with a dieldrin

concentration above 37 ppb. Confirmatory ground water sampling

and backfilling the site with clean soil provide further

assurance that the site will no longer pose a threat to human

health or the environment. The only remaining activities to be

performed are O&M activities, including ground water monitoring,

both of which the city of Jacksonville has guaranteed.

A bibliography of all reports relevant to the completion of

this site under the Superfund program is attached.

VII. FIVE YEAR REVIEW

Prior to site cleanup, contamination at the Rogers Road

Landfill was very localized. The majority of the landfill was

never contaminated above health-based cleanup levels. At this

time, the Rogers Road Municipal Landfill Superfund Site has been

cleaned-up to residential standards and, therefore, from a

health-risk standpoint, the landfill has no land-use

restrictions. Because the site is located in an area

8

001990
historically used for trash dumping, however, physical hazards

caused by items made of glass and metal may still exist. The

ultimate use of the site land will be at the discretion of the

owners of the land, one of which is the city of Jacksonville.

Because the ROD calls for institutional controls limiting

ground water use on and immediately downgradient of the site, a

five-year review is necessary. A five-year review is usually

conducted five years from the date on which the first contract is

awarded for work to install, construct, or implement the remedy.

A contract was awarded to E&E on August 4 , 1994 for the RA.

Therefore, EPA expects to complete the first Five-Year Review on

or before August 4, 1999 . Further five-year reviews will be

conducted pursuant to OSWER Directive 9355.7-02, "Structure and

Components of Five-Year Reviews" or other guidance where it

exists.

9

APR 3 0 1996"

Date

001991
VIII. BIBLIOGRAPHY

1. U.S . Environmental Protection Agency, Record of Decision,

Rogers Road Municipal Landfill Superfund Site, September

1990.

2. City of Jacksonville, Remedial Action Work Plan, September

1994.

3. Ecology and Environment, Technical Assistance Report (includes Remedial Action Sampling and Analysis Plan, Quality

Assurance Project Plan, Health and Safety Plan, and Remedial

Action Closeout Report), January 1995.

4. U.S . Environmental Protection Agency, Report on the First

Annual Ground Water Sampling Event Under the Consent Decree

Between EPA and the City of Jacksonville, April 1995.

5. U.S . Environmental Protection Agency, Report on the Resampling of the Jacksonville and Rogers Ground Water Monitoring

Wells, September 1995.

6 . U.S . Environmental Protection Agency, Pre-final Inspection

Report, September 22, 1995.

7. U.S . Environmental Protection Agency, Preliminary Closeout

Report, September 25, 1995.

10

001992