PRELIMINARY CLOSE OUT REPORT

POP

ROGERS ROAD MUNICIPAL LANDFILL 8UPERPUND SITE

PULASKI COUNTY, ARKANSAS

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

SEPTEMBER 1995

001971
ROGERS ROAD MUNICIPAL LANDFILL BUPBRPUND SITE

PRELIMINARY CLOSE OUT REPORT

Pulaski County, Arkansas

I« INTRODUCTION

This Preliminary 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 a Site

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

contractors and the city of Jacksonville had substantially

completed the construction activities in accordance with the

Remedial Action (RA) work plans and specifications. During this

inspection, EPA determined that all remedial activities were

complete and that the only remaining activities at the Site prior

to final site close out would be Operation and Maintenance (O&M)

and ground water monitoring.

II. SUMMARY 07 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 tine

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

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SCALE (FEETt ^""^ SWAMP/MARSH GRASS IN SOLD

SITE DETAILS

ROGERS ROAD LANDFILL, JACKSONVILLE. AR

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001974
on 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 .

Remedial Planning Activities

EPA reviewed the results of the July 1990 Remedial

Investigation/Feasibility Study (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 ROD selected excavation, soil cover, and off site

treatment and disposal as the remedy for the Site. The remedy

included:

• Excavation of contaminated soil and debris containing

greater than 10 part 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

• Institutional controls such as fence maintenance and

land-use restrictions; and

• Ground water monitoring.

4

001975
On June 20, 1994, a Consent Decree (CD) between EPA and the

City of Jacksonville regarding the Site was entered in Federal

District Court. Under the agreement, EPA performed the work that

involved handling the hazardous substances, including picking-up

the hot spots, 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 walls, ground water sampling and analysis, and institution

of any land-use controls. This CD and the CD for the nearby

Jacksonville Site were the first in the country between a

municipality and EPA that utilized this type of mixed work and

mixed funding settlement.

Ramodial'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

as contaminated personal protective equipment, was transported to

the Vertac incinerator for treatment. 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 >1.0 and ^10 ppb and

dieldrin >37 ppb) which would later be covered with clean soil.

A total of 93 soil samples was 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.

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 RA activities performed by EPA and its

contractors.

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001976
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

its 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) FROM CLEANUP ACTIVITIES

Because of the simplicity of the action at the Site, one

work plan was submitted which encompassed the Remedial Design

(RD) and RA Activities consistent with the ROD and CD

requirements. The QASP for the RA detailed strict sampling and

analytical program. All procedures and protocol for confirmatory

sample analysis are included in this document. 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 for the Rogers Road Municipal Landfill.

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 complied with adequately. This

enabled EPA to make the determination that all analytical results

reported are accurate to the degree needed to assure satisfactory

execution of the remedial action, consistent with the ROD and the

RD/RA work plan.

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001977
IV. ACTIVITIES AND SCHEDULE FOR SITE COMPLETION

The following are tasks which will be performed in order to

complete the remedial process at the Site:

TASK

Ground Water Monitoring

Receive 10/15/95 Ground Water Data

Complete Analysis of Data

Final Operable Unit Inspection

Operable Unit Completion/Remedial

Action Report

Closeout Report

Revegetation

(must occur in rainy season)

Ground water monitoring

Ground water monitoring

Ground water monitoring

Five-Year Review

O&M activities

ESTIMATED

COMPLETION

10/15/95

01/15/96

02/29/96

03/15/96

03/31/96

03/31/96

04/30/96

10/15/96

10/15/97

10/15/98

08/04/99

TBA

RESPONSIBLE

ORGANIZATION

ADPC&E/City

ADPC&E

EPA

EPA/ADPC&E

EPA

EPA

City

ADPC&E/City

ADPC&E/City

ADPC&E/City

EPA

City

The City, with the assistance of ADPC&E, will conduct at

least four more annual ground water monitoring sampling events

prior to the Site five-year review. EPA and ADPC&E will evaluate

this data and determine whether or not additional monitoring is

necessary. Sample results from both the RI and the November 1994

and May 1995 sampling events show that the ground water in the

area surrounding the Site is not contaminated. If enough data is

collected prior to the fifth year of ground water monitoring to

show a statistically significant trend of non-contamination, EPA

may notify the City that additional sampling is not necessary.

Site O&M activities will include routine inspections of Site

conditions like drainage, maintenance of perimeter fencing, and

annual ground water monitoring. The Site has been cleaned to

001978
residential clean-up standards; however, ground water monitoring

will be conducted to ensure that the ground water is not

contaminated. Under the CD, the City of Jacksonville has assumed

all responsibility for O&M at the Site. The City will also

remain in control of Site access.

The remedial construction and remedial action activities

achieved the cleanup criteria and performance standards required

by the ROD for this activity.

^1TTMrY of Five-Year review Status

Because the Site was cleaned to residential levels through

excavation and capping of low concentration materials with clean

soil, the residual risk at the Site is not above health-based

levels. However, until additional ground water data is

acquired, there is a possibility that hazardous materials, above

health-based levels, could be found in the ground water. If so,

the use of the ground water must be restricted.

A five-year review will be conducted five years from the

date on which the first contract for remedy implementation was

awarded. E&E was tasked through an August 4, 1994, Technical

Directive Memorandum to perform the RD/RA. Therefore, EPA will

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 available at the time.

^9^^ Q, /^v^^^

Myron 0. Knudson, P.E.

Director, Superfund Division

8

Date

001979