record of decision ordot landfill superfund ...the governor of guam designated ordot as guam's...

SFUND RECORDS CTR103394

FINALRECORD OF DECISIONORDOT LANDFILLSUPERFUND SITE

GUAM

SEPTEMBER 1988

U.S. ENVIRONMENTAL PROTECTION AGENCYREGION 9

DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Ordot Landfill, Guam

STATEMENT OF PURPOSE AND BASIS

This decision document represents the decision to take noaction under CERCLA but to defer clean-up of site threats tothe Clean Water Act as a more appropriate authority for the OrdotLandfill in Guam. The decision was developed in accordance withCERCLA as amended by SARA, and to the extent practicable, theNational Contingency Plan. This decision is based on theadministrative record for this site. The attached index identifiesthe items which comprise the administrative record.

DESCRIPTION OF THE SELECTED REMEDY

EPA has determined, based on the available information, thatremedial action at the Ordot Landfill site under the ComprehensiveEnvironmental Response, Compensation, and Liability Act (CERCLAor Superfund) 42 U.S.C. Section 9601 et seq. is inappropriateat this time.

This determination is based on several facts: 1) OrdotLandfill is an operating municipal landfill; 2) all but approxi-mately 4-7 acres of the 47 acre site are active waste disposalareas; 3) the 4-7 inactive acres are downgradient of the activewaste disposal areas or are immediately adjacent to activewaste disposal areas; 4) any remedy for the inactive areaswill likely be affected by activities at the active waste disposalareas or continued surface flows through the landfill; 5) thebulk of any environmental impacts from the landfill will resultfrom activities at the active waste disposal area; 6) the landfill,by applying standard operation practices to control landfillleachate, can effectively reduce or eliminate the surface flow ofleachate to receiving waters; 7) EPA has issued an order underthe Clean Water Act, 33 U.S.C. Section 1251 et seq., that requiresthe Guam Department of Public Works to cease discharge of leachatefrom Ordot Landfill to the Lonfit River; and 8) EPA data, althoughtoo limited for comprehensive conclusions, has not demonstratedany imminent and substantial endangerment to human health orwelfare or the environment.

EPA concludes that threats to human health and the environ-ment currently identified at the landfill are due to poor operationpractices and can best be mitigated through addressing operationsand maintenance of the landfill itself including improved leachate

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control measures consisting of capping and surface water control.EPA concludes that the appropriate mechanism for implementingthese controls is through enforcement of the Clean Water Act. Theresponsibility for implementing these controls lies with thelandfill operator, the Territory of Guam. Expenditures, fromthe Superfund for these purposes are not appropriate.

Further, EPA concludes that any remedial action to addressthe inactive portion of the landfill potentially appropriate forresponse under CERCLA would be jeopardized or nullified unless'operation practices at the active disposal areas are jrnproved toreduce leachate formation and to prevent discharge of leachate.The design for improved operations at the active disposal areasmust consider the inactive portion due to the nature of the siteand thus would make a separate CERCLA remedial action unnecessary.

Based on these considerations, EPA selects no action as thepreferred alternative under CERCLA. As part of the preferred alter-native, EPA will continue to gather additional data to identifyany adverse impacts on human health or welfare or the environmentattributable to the landfill not currently identified and remediatedby the improved landfill operation practices. As part of thiscontinued monitoring program at Ordot Landfill, EPA will monitorto detect as early as possible any migration of contaminants fromthe landfill toward the sole source aquifer. The design of thisprogram will be based upon further hydrogeological investigationsat the site and in the vicinity of the site to characterizegeologic and hydrologic features necessary to define themonitoring program.

In choosing the no action alternative EPA reserves itsauthority to perform additional response actions should the newinformation warrant such a decision.

DECLARATION

This decision document represents the selected alternativefor this site developed in accordance with CERCLA, as amended bySARA, and the National Contingency Plan.

The Territory of Guam has concurred on the selected remedy.

Date Daniel W. McGovernRegional Administrator

Record of DecisionTable of Contents

SECTION

I. Site Location and DescriptionII. Site History

III. Enforcement ActivitiesIV. Community InvolvementV. Remedial Investigation

A. Initial Site Characterization (ISC)B. Site GeologyC. Site HydrologyD. Water Quality AnalysisE. Air Sampling

VI. Endangerment AssessmentVII. Selected Alternative

PAGE

11233

357912

1213

FIGURES/TABLES

Figure 1-1Figure 1-2Table 3-2Table 3-3

Location of Ordot LandfillSite Location MapSurface Water/Leachate ResultsGround Water Results

FOLLOWING PAGE

11

1010

APPENDICES

APPENDIX AAPPENDIX BAPPENDIX C

Index of Administrative RecordResponsiveness SummaryConcurrence Letter From GUAM

DECISION SUMMARY

ORDOT LANDFILL, GUAM

I. SITE LOCATION AND DESCRIPTION

Ordot Landfill (Ordot) is an operating municipal landfilllocated on the island of Guam (Figure 1-1), and is the only majormunicipal landfill on the island. It is currently operated bythe government of Guam through the Department of Public Works.The site has been receiving uncontrolled municipal (and perhapshazardous) wastes since before World War II.

The Japanese and United States military occupational forcesused the landfill during World War II, but the nature of thewaste placed in the landfill at that time is unknown. AfterWorld War II and with the expansion of the highway system in themore populated areas of northern Guam, Ordot Landfill became theprimary repository of municipal waste for the island and is usedby both the civilian population and the United States military.The landfill is presently managed and operated by the Guam Depart-ment of Public Works. Although Ordot Landfill primarily receivedmunicipal waste, because it is the only major public wastedisposal site on Guam, the Guam Environmental Protection Agency(Guam EPA) feels that it has received hazardous waste during itshistory, including spent industrial and commerical chemicals, PCScontaminated oils from transformers, and perhaps munitions.Unfortunately, records have never been kept as to the nature andquantity of hazardous wastes disposed of at Ordot Landfill.

Ordot Landfill is located in the volcanic upland near thedivide between the southern volcanic and northern limestonegeologic provinces which comprise the island of Guam (Figure1-2). The primary concern is that a suspected fault near thelandfill may provide a hydrologic connection between the contaminantsat Ordot Landfill and Guam's major drinking water aquifer locatedin the limestone province. A second basis of concern regardsleachate runoff impacts on the adjacent Lonfit River, which flowsinto Pago River, and ultimately Pago Bay. The source of leachateflow was suspected to be a perennial stream fed by a springburied beneath the landfill and originating in the fault.

II. SITE HISTORY

Ordot Landfill is an operating facility and has been incontinuous operation for approximately 40 years. It continues to

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be operated more as an open dump than as an engineered landfill.Ordot Landfill was established in a ravine which slopes steeply tothe Lonfit River. Current operations at the facility utilize almostthe entire historic 47 acre waste disposal area with only approxi-mately 4-7 acres of the oldest portion of the landfill notcurrently in use. The unused portions of the historic wastedisposal area are downgradient or adjacent to current operations.One inactive area forms the steeply sloping toe of the landfill.The current depth of disposed wastes is approximately 100 feet.The toe of the landfill is approximately 1000 feet from theLonfit River and leachate streams emanate-from points along thecontact of the landfill toe and the clay soils which comprise thebanks of the Lonfit River.

The Governor of Guam designated Ordot as Guam's highestpriority site for Superfund clean-up. It was included on theinitial National Priorities List (NPL) which was finalized onSeptember 8, 1983.

On March 26, 1986, EPA found Ordot Landfill in violation ofthe Clean Water Act for discharging landfill leachate to theLonfit River without a National Pollutant Discharge EliminationSystem (NPDES) permit. EPA ordered Ordot Landfill to ceasedischarge. Ordot Landfill remains in violation of the EPA order.

III. ENFORCEMENT ACTIVITIES

A potentially responsible party (PRP) search has beenperformed to identify responsibility for the contamination atOrdot Landfill. The PRP search included a title search of theOrdot Landfill, a trip to Guam to interview individuals andagencies that have or may have interfaced with the landfill andits operations, file reviews of federal and Guam governmentagencies, contacts with consultants and other firms that may beknowledgeable of Ordot Landfill or activities related to it, anda field survey of the site to review operating practices.

The field survey was also performed to identify and locateindustrial properties surrounding the landfill that may havecontributed to the local groundwater contamination. During thefield survey, visual evidence of any type of industrial operationor storage facility was used as the criterion to identify PRPs.The result of the field survey found no industries or othersuspected practices in the vicinity of the landfill.

Results of the PRP search indicate that several PRPs canpossibly be identified based upon the information obtained: U.S.Navy, Government of Guam, and the Department of Public Works.Other agencies or businesses that are known to have disposed of

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waste in the landfill include the Agana Sewage Treatment Plant.

Guam EPA reported that private disposal companies and localhospitals have also disposed of waste at Ordot. Those cited wereGuam Memorial Hospital and Commercial Sanitation Systems, Inc,but others may be active on the island.

IV. COMMUNITY RELATIONS.————-——————-————.————————————————————— j*» —

Community involvement was solicited at the conclusion ofEPA's Phase I Remedial Investigation. The notice of availabilityof the Proposed Remedial Action Plan with supporting documentation,which identified EPA's and Guam EPA's preferred remedial alter-native of no action for this site, was published on June 27,1988. The Proposed Remedial Actipn Plan and supporting documentationwas released to the information repositories on July 12, 1988.The public comment period, initiated on this date, solicitedpublic comment through August 12, 1988. A public meeting washeld July 26, 1988.

EPA prepared the attached Responsiveness Summary to addressthe specific concerns raised during the public comment period,including comments made at the public meeting. A transcript ofthe public meeting is available at the information repositoriesat EPA, Region 9 offices, and Guam EPA.

V. REMEDIAL INVESTIGATION

A. INITIAL SITE CHARACTERIZATION (ISC)

An initial hazardous waste characterization study performedby Black and Veatch Engineers — Architects (1983) was inconclusivewith regard to documenting the nature and extent of the threatactually posed by contaminants from Ordot Landfill. EPA contractedwith Camp, Dresser and McKee, Inc. (COM) to perform an InitialSite Characterization (ISC) to determine: 1) the quality andquantity of contaminants at or produced by the landfill; 2)pathways by which these contaminants may leave the site; and 3)the potential impacts of the contaminants.

CDM made a initial site visit on October 17-18, 1985 anddeveloped a workplan for the site characterization which wasfinalized on June 2, 1986. Sampling of ground waters, surfacewaters and landfill leachate was performed March 10-16, 1987.Additionally, reconnaisance level air quality monitoring, and ageologic reconnaisance were performed. The Final Initial SiteCharacterization report was submitted September 18, 1987.

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The September 18, 1987 ISC report concluded that:0 Surface flow through the landfill was the source of leachateflows with the uncompacted landfill allowing for retentionof rain and surface inflow to produce the perennial leachateflow. There was no indication of a spring.

0 The geologic reconnaisance indicated that the landfill isunderlain by fine grained volcanic deposits of very lowpermeability, with an absence of any carbonate deposits.On this basis and corroborated by the ground water studies,the site appears to be hydrologically isolated from thelimestone aquifer. Groundwater flow is expected to bealong the bedding planes toward the Lonfit River and awayfrom the suspected fault. There was no indication ofpresence of a fault at the site. Follow-up monitoring toconfirm the hydrologic isolation of the site from Guam'ssole source drinking water aquifer is recommended due todata limitations from the geologic reconnaisance.

0 The water quality sampling was performed only during Guam'sdry season and was limited in number of samples. The samplesindicated a general absence of organic contaminants at thetime of sampling. The contract detection limit for vinylchloride was not sufficiently low to ascertain compliancewith the MCL. Two organic contaminants were -detected at levelsbelow the contract detection limits but above the instrumentdetection limits indicating the presence of some organicsat low levels. The samples indicated an increase in inorganicconstituents downgradient of the landfill which, however,did not exceed MCLs for any inorganic constituent. SecondaryMCLs were exceeded only for Iron and Manganese, and noadverse health effects would be expected. Several metalswere present in the landfill leachate and downgradiantgroundwater samples in excess of EPA ambient water qualitycriteria (AWQC). However, based upon the observed relativeflow of leachate and the Lonfit River, adequate dilutionis expected to be available. No significant impact on theLonfit River was observed under conditions at the time ofsampling. Groundwater in the site vicinity is not usedfor drinking or other purposes.

0 The air quality reconnaisance indicated the presence ofminor amounts of methane, predominantly in the olderlandfill portions. No other air quality problems wereobserved.

— 5~

The ISC report made clear recommendations for a remedialprogram to improve landfill operation practices to prevent orminimize any threats to human health and the environment posed bydisposal practices at Ordot. The remedial program includes:

0 implementation of perimeter control of surface flow run-onto prevent current flow through the landfill;

0 capping unused portions of the landfill; and0 continued monitoring to demonstrate the effectiveness ofthe improved practices and substantiate the conclusionsof the ISC.

B. SITE GEOLOGY

B.I. REGIONAL GEOLOGY

Guam is the largest and southernmost island in the MarianaIsland Chain. The island chain is located atop a large submarineridge known as the Mariana Island Arc System, which is the boundarybetween subducting tectonic plates. The Mariana Trench is locatedeast and south of the arc. Guam has two major physiographicdivisions (Figure 1-1). The southern half of the island is theoldest and is characterized primarily by a dissected and relativelyrugged volcanic upland, on which limestones were sometimesdeposited. Ordot Landfill is located in the northern part ofthis physiographic area.

The northern half of the island is characterized by a broadand gently undulating limestone plateau which slopes from MountSanta Rosa (elevation 858 feet) on the northeast toward the AganaSwamp area (near sea level) on the southwest (Figure 1-1). TheLimestone Plateau ends abruptly in near vertical cliffs alongmost of the coast line of nothern Gu'am. Volcanic rocks areexposed at the ground surface near the tops of Mount Santa Rosaand Mataguac Hill and form the surface expressions of the volcanicbackbone on which the thick sequences of limestone were desposited.The rocks of the northern province probably formed from volcanicevents that are both separate and younger than those in the south.

Limestone sequences grew on the submerged volcanic surfaces asthey were uplifted, and eventually connected with the southernhalf of the island. The two physiographic provinces may beseparated by a major northwest-southeast trending fault, locatednortheast of Ordot Landfill.

At this time, the island appears to be in a period of relativequiesence, with active fringing reefs being formed around thecoast of the Northern Plateau. However, because tectonic activity

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is still on-going in the region of the Mariana Trench, uplift ofthe island arc and Guam is expected to continue into the geologicfuture.

B.II.' GEOLOGIC MATERIALS BENEATH THE SITE

The geologic materials which underlie the site consist ofthinly bedded, tuffaceous shales and sandstones, with grain sizesranging from clay to medium-grained sand (Tracey, et. al., 1963).Bedding ranges from a few millimeters to several meters in thick-ness. Typically, these deposits range in color from gray tolight orange in fresh exposures and gray-green to dark red inweathered exposures. Gray-green beds are usually indicative ofthe coarser-grained tuffaceous sandstones, with the darker coloredbeds associated with the higher silica content of the matrixmaterial.

Most of the rocks observed at the site exhibited varyingdegrees of weathering. In most unweathered exposures, the tuffsare fairly hard, but show chemical altering around individualangular grains. With weathering, the fine-grained matrix materialbreaks down to clay and the grains continue to weather, eventuallyto clay with little evidence of the original clastic texture.Weathering is prominent in most of the rocks exposed in the uppertwo to three feet of the surface. Rocks with little sign ofweathering are exposed in the area used by the landfill operatorsas a source of cover material and in road cuts in and near thesite. These unweathered rocks originally existed over ten feetbelow the ground surface. The weathered rocks, because of theirhigh clay content, appear to have extremely low permeabilities.Unweathered rocks, because of their fine-grained matrix andpartially altered clastic texture, also appear to have lowpermeabilities.

B.III. STRUCTURAL GEOLOGY

The rocks beneath the site are moderately folded andfractured. Bedding is folded into an anticline with an east-westaxis. The north limb of the anticline dips 15 to 50 degrees.The south limb dips between 40 and 60 degrees. Folding iscommon within beds and appears to be due to depositional features.Fracturing was commonly observed in the rocks. However, most ofthe fractures are closed and, as such, may inhibit groundwatermovement.

Major faulting was not observed in the beds exposed in oradjacent to the site area. Tracey, et. al. (1964) indicated amajor northwest-southeast trending fault which passes just northof the Ordot site. This fault is thought to divide the northernlimestones and the southern vocanics. Reconnaissance of the areadid not substantiate the existence or absence of this fault. Thesteep terrain north of the site could be explained as either amajor block fault or as a terrace (erosional) feature. A springwas thought to issue from the fault zone and subsequently flow

through the site. However, on closer examination of the area,topography of the area appears to concentrate surface runoff andchannel it into the site.

B.IV. RESULTS OF GEOLOGIC RECONNAISSANCE

The results of the geologic reconnaissance indicate that thelandfill is underlain by fine-grained volcanic deposits. Thesedeposits appear to be of very low permeability, based on observa-tions of the surficial material.

There does not appear to be any of the carbonate depositspresent in the immediate site vicinity, based on available outcropinformation. One of the initial concerns about the Ordot landfillsite was the potential for leachate contaminating the limestoneaquifer through a fault suspected to be in the vicinity. However,the site appears to be hydrologically isolated from the limestoneaquifer based on the observations associated with the geologicreconnaissance. Furthermore, any groundwater on site wouldprobably flow along bedding planes or along the contact betweenthe landfill material and the bedrock deposits, both of which dipto the south away from the island's major limestone aquifertoward the Lonfit River. Therefore, there does not appear to bea pathway for groundwater contamination to affect the limestoneaquifer. Because the geologic reconnaisance was limited in scope,confirmatory monitoring to further substantiate the isolation ofthe site from the sole source aquifer is appropriate. The designof this monitoring program will be based upon further hydrogeologicstudies at the site and in the vicinity of the site necessary todefine the program.

C. SITE HYDROLOGY

C.I. PRECIPITATION

The rainfall record indicates two distinct seasons in Guam.The dry season runs from January through June, during which timeshowers produce most of the little rain that falls. The seasonalaverage rainfall during the dry season is approximately 5 inchesper month.

The wet season, runs from July through December. The wetseason rainfall is produced from major regional storm systems,during which the seasonal average rainfall is about 12 inches permonth. The maximum monthly rainfall for the season generallyoccurs in August and September and has historically ranged to.over 30 inches per month, but averages about 14 inches per month.During typhoons, rainfall intensities are extreme and can be asmuch as eight inches in two hours, 18 inches in 12 hours, and 24inches in 24 hours (Tracey, et al; 1964). However, the long-term

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records show that monthly and annual rainfall are rather consistenton Guam, with the exception of high intensity rain generatedduring the occasional strong typhoons.

Unlike southern Guam, northern Guam does not have a wellestablished, incised drainage system because the limestones areso permeable that rainfall almost immediately infiltrates uponreaching the ground. In developed areas of the interior, run-offover streets is usually diverted to open trenches, or to dry wells.Upon reaching storm water retention areas, the run-off infiltrates.In southern Guam, the volcanics weather to a relatively thick,impermeable soil zone. As a result, most of the rainfall ends upas surface runoff which eventually flows to the ocean in wellestablished drainage courses, such as the Lonfit and Pago Rivers.

C.2. GROUNDWATER PRODUCTION __

The water supply of northern Guam comes almost exclusivelyfrom the limestone aquifers of the Northern Plateau. Except fora few privately owned wells in northern Guam, the production fromthe groundwater system is managed by the Public Utility Agency ofGuam (PUAG), the Air Force, and the Navy. There are presentlyover 70 municipal wells and one infiltration tunnel in operationin northern Guam. These facilities have a maximum capacity toyield about 21 million gallons per day (MGD).

Only a few low-yielding wells have been drilled in southernGuam. Water wells have not been drilled in the volcanics nearOrdot Landfill.

C.3. GROUNDWATER MOVEMENT BENEATH THE SITE

The site appears to be geologically isolated from the lime-stones of the Northern Lens Aquifer. The high clay content ofthe tuffaceous shales and sandstones appears to restrict infil-tration of rainfall or surface inflow. As such, most of the waterthat enters the area, either as rainfall or as surface inflow,will flow south along the original ground topographic surfaceinto the Lonfit River. However, rainfall at the site may resultin a significant amount of infiltration into the landfill debrisdue to the inadequate cover utilized at the site.

The background monitoring well in the northern part of thesite contained only a small amount of water, indicating extremelylow permeabilities for the rocks underlying the site. Theapparently small amount of groundwater which flows through thesite area probably follows the solid waste bedrock contact, whichdips in a southerly direction beneath most of the site toward theLonfit River. Groundwater beneath the southern portion of thesite appears to be related to the alluvium associated with theLonfit River. The groundwater gradient in the alluvium probably

follows the topography and, as such, flows parallel to the LonfitRiver and eventually enters Pago Bay on the eastern shore of theisland.

D. WATER QUALITY ANALYSIS

COM performed field sampling March 10-16, 1987 to determinequality of surface water, ground water and leachate in the vicinityof the site or potentially impacted by the site. This samplingeffort was for purposes of making an initial site characterizationand therefore limited numbers of samples were taken. The sampleswere collected during Guam's dry season where average monthlyrainfall is 5 inches versus a 12 inch per month average (withshort intense storms) during the rainy season. Although samplingduring the dry season may represent worst-case with respect tocontaminant loading, this assumption could be incorrect ifchanneling of flows within the landfill occurs during low flowconditions. Additional sampling would be required to fullycharacterize the site with respect to seasonal variation in flowsand concentrations, and to expand the current data base.

As detailed in the following analysis of results, the samplingresults indicated that although the landfill leachate and down-gradient groundwater are generally poor quality with respect toinorganic constituents, essentially no volatiles, semi-volatiles,or pesticides/PCBs were detected in any samples. Analysis ofdowngradient groundwater samples indicated the, presence of barium,iron, manganese, zinc, vanadium and aluminum. Leachate samplescontained these metals and additionally chromium, cobalt, copper,cyanide, potassium and lead. Although no samples exceeded theinorganic primary maximum contaminant levels (MCLS), secondaryMCLs were exceeded for iron and manganese in leachate samples anddowngradiant groundwater. Comparison of concentrations of metalsin groundwater and leachate to Ambient Water1 Quality Criteria ^(AWQC) for freshwater aquatic life show some concentrations arein excess of these criteria. However, based upon the observedrelative flow of leachate and the Lonfit River, adequate dilutionis expected to be available. No significant impact on the LonfitRiver was observed under conditions at the time of sampling. TheEndangerment Assessment addresses the potential impacts of thesecontaminants on human health and the environment.

D.I. ANALYTICAL DATA

All of the surface water, groundwater and leachate samplescollected during the sampling effort were analyzed for RoutineAnalytical Services Hazardous Substances List (RAS HSL) volatile,semi-volatile, pesticide/PCB, and inorganic constituents. Alldata were validated by Region 9 using standard review protocolsand the data quality was considered in analysis of the data and inreaching the decision.

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The following samples were taken and the results of thelaboratory analysis are reported in Table 3-2 (from the ISC) forsurface water and Table 3-3 (from the ISC) for groundwater:

SampleNumber Description

SampleNumber

SW-01 Lonfit River, upstream oflandfill

SW-02 Lonfit River, downstreamof landfill

SW-05 Leachate spring, southside of landfill

SW-07 Leachate pond area, southside of landfill

SW-10 Leachate stream, west

Description

GW-01 Municipal Well A-ll

GW-03 Municipal Well A-12

GW-04 WERI BackgroundMonitoring Well

GW-05 WERI DowngradientMonitoring Well

GW-06 WERI Well #4Downgradient

Duplicate sample pairs are as follows: GW-01 and GW-02; SW-02 and SW-13; and GW-06 and GW-07.

D.2 ANALYSIS OF DATA

Inspection of the data indicate that water quality of theleachate is generally poor, particularly considering the highconcentrations of the inorganic constituents. However, none ofthe inorganic constituents exceed the USEPA maximum contaminantlimits (MCLs), although iron and manganese generally exceed thesecondary maximum contaminant limits (SMCLs) for all of theleachate samples. With regard to organic constituents, onlytrace levels of carbon disulfide and chlorobenzene were detectedin sample SW-7, and phenol was detected in SW-10. Each ofthese constituents were detected in amounts below the ContractRecommended Detection Limit (CRDL) and are qualified as such.All of the other organic constituents analyzed under the CLP RASprogram were either undetected or detected in the method blank,indicating laboratory contamination. The CRDL for vinyl chloride(10 ug/1) is not low enough to determine compliance with theMCL for vinyl chloride (2 ug/1).

Samples were also collected from the Lonfit River to determinethe potential impact of the landfill on the water quality of theriver. Sample SW-01 was collected from the Lonfit River upgradientof the landfill, whereas sample SW-02 was collected downgradient.Sample SW-13 represents a duplicate of SW-02.

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11-

Examination of the data for the Lonfit River indicate thatthe water quality is generally better than the leachate quality.This is particularly true for the inorganic constituents, which inmany cases are an order of magnitude less than the inorganicconstituent concentrations detected in the leachate samples. Inaddition, none of the constituent concentrations detected in theLonfit River exceeded the MCLs or SMCLs, and none of the organicconstituents were detected in any of the samples. Finally,comparison of the data for the downgradient sample (SW-02) withthe data from the upgradient sample (SW-01) indicates that theleachate discharging to the Lonfit River had little impact on theriver water quality at the time of the sampling effort. Forexample, a comparison between many of the major ions in thesamples indicate that there was little to no change in the waterquality. However, based upon observed practices at the landfill,an impact on the river may occur due to improper disposal ofhighly contaminated wastes resulting in a more highly contaminatedleachate discharge to the river over a short time period.

Samples GW-01 and GW-03 were collected from municipal wellslocated in the vicinity of the landfill. Sample GW-02 representsa duplicate of GW-01. Samples GW-04, GW-05, and GW-06 werecollected from monitoring wells located within the site boundary.Samples GW-07 represents a duplicate of GW-06. Sample GW-04 wascollected from the upgradient monitoring well.

The samples collected from the on-site downgradient monitoringwells (GW-05 and GW-06) show a general degradation in waterquality when compared to the sample collected from the upgradientwell (GW-04). For the most part, every major inorganic constituentincreased in concentration downgradient. In some cases, therewas an order of magnitude increase in concentration (e.g., sodium,zinc). Furthermore, iron and manganese in both of the downgradientgroundwater samples exceeded the SMCLs. Organic constituents werenot detected in any of the on-site monitoring wells, with theexception of a phthalate in the upgradient well. The presence ofphthalate indicates the possible presence of plasticides.

The water quality data for the samples collected from theoff-site municipal wells are similar to the data for the upgradientmonitoring well, when considering the concentration of some ofthe major metals such as sodium and magnesium. In that the waterquality is similar to the upgradient well and there does notappear to be a degradation in water quality similar to thatobserved in the downgradient monitoring wells, it appears thatthe off-site municipal wells are unaffected by the landfill.

Phenol was detected at a concentration of 5.0 ug/1 in sampleGW-03. However, this value was qualified since it was detectedbelow the CRDL. The source of the phenol is not known. No otherorganic constituents were detected in the off-site municipalwells sampled.

-12-

E. AIR SAMPLING

A reconnaisance air sampling effort was conducted at OrdotLandfill using portable field instruments.

The results of the reconnaissance-level air quality surveyindicate that air emissions from the landfill do not present amajor problem. For example, the average response of most of theinstruments along the transects were either zero or not abovebackground levels. The exceptions were the responses observedfor the Organic Vapor Analyzer (OVA). In general, the OVAconsistently maintained readings on the order of 2 to 7 ppm abovebackground over the entire transect. In addition, at severallocations along the transects, elevated readings on the OVA wereobserved, particularly along the southern portions of the land-fill. The OVA readings obtained at these locations ranged from 2to 100 ppm, although the upper levels generally represented shortspikes which were not sustained for extended periods of time.

The type of instrument responses observed at the landfillsuggest that small amounts of methane are being produced andemitted from the landfill. For example, the HNu, which does notrespond to methane gas, did not respond while conducting thetransects. However, the OVA, which does detect methane gas,generally responded above background along the entire course ofthe transects. These instruments would not detect emissions ofchlorinated hydrocarbons and if future sampling indicates presenceof chlorinated hydrocarbons at the landfill, additional monitoringto screen for air emissions is recommended.

The reconnaissance-level air sampling data collected indicatesthat methane is being produced from the southern portion ofthe landfill. This portion of the landfill is the oldest and,consequently, the waste has had the most opportunity to degrade.However, other portions of the landfill are presently not genera-ting much methane. Furthermore, the instrument responses at thesouthern portions of the landfill were not sustainable at thehigher levels, indicating that the methane production was notsustainable. Given these aspects, it appears that the landfilldoes not represent an air quality problem.

VI. ENDANGERMENT ASSESSMENT . __

ICF/Clements was tasked to write an Endangerment Assessment(EA) report to evaluate the magnitude and probability of actualor potential threat to public health or welfare and the environ-ment posed by the hazardous substances present at the site. TheEA, based on the limited data from the Initial Site Characteriza-tion, supports the conclusion that current conditions at thelandfill do not demonstrate a significant and substantial endanger-ment to human health or the environment with regard to hazardouscontaminant impact appropriate for response under CERCLAauthorizations.

-13-

VII. SELECTED ALTERNATIVE

The Superfund law requires that each remedy selected for asite must be protective of human health and the environment, costeffective, and in accordance with statutory requirements.Permanent solutions to toxic waste contamination problems are tobe achieved wherever possible. According to the NationalContingency Plan under which the Superfund program operates,specifically 40 CFR Part 300.68(j), the cost-effective remedy isthe lowest cost alternative that is technically feasible andreliable and which effectively mitigates and minimizes damages toand provides adequate protection of public health, welfare, andthe environment.

EPA has determined, based on the available information, thatremedial action at the Ordot Landfill site under the ComprehensiveEnvironmental Response, Compensation, and Liability Act (CERCLAor Superfund) 42 U.S.C. Section 9605 et seq. is inappropriate atthis time.

This determination is based on several facts: 1) OrdotLandfill is an operating municipal landfill? 2) all but approxi-mately 4-7 acres of the 47 acre site are active waste disposalareas? 3) the 4-7 inactive acres are downgradient or adjacentto the active waste disposal areas? 4) any remedy for theseinactive areas likely will be affected by activities at theactive waste disposal areas or continued surface flow through thelandfill? 5) the bulk of any environmental impacts from thelandfill will result from activities at the active waste disposalareas? 6) the landfill, by applying standard operation practicesto control landfill leachate, can effectively reduce or eliminatethe release of leachate to receiving waters? 7) EPA has issued anorder under the Clean Water Act, 33 U.S.C. Section 1251 et seq.,that requires the Guam Department of Public Works to ceasedischarge of leachate from Ordot Landfill to the Lonfit River?and 8) EPA data, although too limited for comprehensive conclusions,has not demonstrated an imminent and substantial endangerment tohuman health or welfare or the environment.

EPA concludes that threats to human health and the environmentcurrently identified at the landfill are due to poor operationpractices and can best be accomplished through addressing operationsand maintenance of the landfill itself including improved leachatecontrol measures consisting of capping and surface water control.EPA concludes that the appropriate mechanism for implementingthese controls is through enforcement of the Clean Water Act. Theresponsibility for implementing these controls lies with thelandfill operator, the Territory of Guam. Expenditures from theSuperfund are not appropriate for these purposes.

Further, EPA concludes that any remedial action to addressthe inactive portions of the landfill potentially appropriatefor CERCLA response would be jeopardized or nullified unlessoperation practices at the active disposal areas are improvedto reduce leachate formation and to prevent discharge of leachate.The design for improved operations at the active disposal areasmust consider the inactive portions due to the nature of thesite and thus would make a separate CERCLA action unnecessary.

Based on these considerations, EPA is choosing no actionas the preferred alternative. As part of the preferred alter-native, EPA will continue to gather additional data to identify anyadverse impacts on human health or the environment attributableto the landfill not currently identified and remediated by theimproved landfill operation practices. As part of this continuedmonitoring program at Ordot Landfill, EPA will monitor to detectas early as possible any migration of contaminants from thelandfill toward the sole source aquifer. The design of thisprogram will be based upon further hydrogeological investigationsat the site and in the vicinity of the site to characterizegeologic and hydrologic features necessary to define the monitoringprogram.

In choosing the no further action alternative EPA reservesits authority to perform additional response actions should thenew information warrant such a decision.

1*0 SEP

ORDOT LANDFILLGUAM

RESPONSIVENESS SUMMARY

This responsiveness summary is required by Superfund policyfor the purpose of providing EPA and the public with a summary ofcitizen comments and concerns about the site, as raised duringthe public comment period, and EPA's responses to those concerns.All comments received are factored into EPA's final decision fora site.

For the Ordot Landfill site, community involvement wassolicited at the conclusion of EPA's Phase I Remedial.Investi-gation (the Initial Site Characterization). A notice of theavailability of EPA's Proposed Remedial Action Plan (PRAP) withsupporting documentation was published on June 27, 1988 in Guam'sPacific Daily News. The notice identified EPA's and Guam EPA'spreferred alternative of no action for this site under CERCLA.A public comment period was conducted from July 12, 1988 throughAugust 12, 1988. EPA held a public meeting on July 26, 1988at Guam EPA's offices in Harmon, Guam. Press releases andnotification to the Commissioner of Ordot/Chalan Pago, the nearestvillage to the landfill, and to Senator Sam Agustin of the Guamlegislature's Committee on Health were prepared and made by GuamEPA to further assure notification of the affected community andtheir representatives.

EPA received no comments from the community at the publicmeeting and no written comments were received during the publiccomment period. On that basis EPA is unaware of any communityconcerns that have not been addressed by the preferred alternativeof no action at the Ordot Landfill site under CERCLA.

ORDOT LANDFILL SUPERFUND SITEOrdot, Guam

ADMINISTRATIVE RECORD INDEX(Indexed by Date)

This Index Was Compiled July 1, 1988 and Includes Documents 1-75


ADMINISTRATIVE RECORD INDEX(Indexed by Date)

This Administrative Record Index lists the documents contained in the AdministrativeRecord for the Ordot Landfill Superfund Site in Ordot, Guam. The Index presentsthe documents in ascending chronological order, which is consistent with the arrangementof the documents in the Administrative Record itself.

The documents contained in the Administrative Record were used by the U.S.Environmental Protection Agency in identifying remedial activities appropriate foruse at the Ordot Landfill Superfund Site.

Page No. 107/01/68

ORDOT LANDFILL SUPERFUND SITEORDOT, GUAM

Administrative Record File Index

DOC. i DATE FROM/ORGANIZ. TO/ORGANIZ. DESCRIPTION/SUBJECT PAGES

37 11/18/80

60 06/24/81

50 08/06/81

49 08/27/81

Dan W. Crytser, Tom Jones, EPAGuam EPA Region IX

Dan Crytser, Guam US EPAEPA

Dr. JakeMacKenzie, EPARegion IX


Ricardo C.Duenas,Administrator,Guam EPA


Cover Itr. withattached progressreport for the OrdotLandfill engineeringplan (Re: GMPAssoc.)

Notification ofHazardous Waste Site,Ordot Landfill

Ltr: Seeking EPAGuam verification ofOrdot Landfill aspriority site

Ltr: Trans»ittal ofNOTIS printoutshowing hazardouswaste TSD sites inGuam

10

30 10/08/81 Ricardo C.Duenas,Administrator,Guam EPA


Ltr: With attachedMitre modelcomponents and Mitremodel (Superfund)verification

43

48 10/26/81

29 12/24/81

47 01/25/82

33 01/26/82


William Flores,Public Works,Guam


Howard Harris,NOAA, OMPA


Carl Aguan, Dir.of Public Works,Guam

Sonia F. Crow,Administrator,EPA Region IX

Ltr: Re: Hazardouswaste pollutionthreat at OrdotLandfill

Memo: Ordot Landfillrequirements (Re:12/18/81 inspection)

Ltr: Transaittal ofattached verificationdocuments for Mitrehazardous waste siteranking model

Keith A. Takata, ROC: Harris calledEPA Region IX Takata Re: Interim

Priority List sites

32

Page No.07/01/88

ORDOT LANDFILL SUPERFUND SITEORDOT. GUAM


DOC. t DATE FROM/ORGANIZ. TO/ORGANIZ. DESCRIPTION/SUBJECT PAGES

45 02/26/82

44 05/03/82

David S. Mowday,EPA Region IX

William N.Hedeman, Jr., USEPA


Rita M. Lavelle,US EPA

43 06/01/82 Sonia F. Crow,Administrator,EPA Region IX

57 07/10/82 Daily News Staff

31 07/28/82

42 07/29/82

41 08/24/82

56 08/30/82

Sonia F. Crow,EPA Region IX,WilliamMcAlister, EPAGuam, and Paul H.Calvo, Governor,Guam

Norman L.Lovelace, EPARegion IX


James B. Branch,Administrator,Guam EPA

Paul M. Calvo,Governor, Guam

NewspapersReaders

Public Record

Ltr: Update oncurrent Superfundactivities, includingOrdot Landfill

Memo: Requestingauthorization toundertake remedialplanning at foursites, includingOrdot Landfill

Ltr: Approval ofGuam's request forCERCLA remedialaction at ORDOTLandfill

News: "EPA teamcoming to Guam forhazardous wastestudy"

Agreement between theTerritory of Guam andRegion IX of the USEPA for FY-83

Nachaa Siren, Ltr: Transaittal ofEnvironmental draft RI statement ofProtection Board, workTrust Territories



Ltr: Transmittal ofRI comprehensive WorkPlan

Ltr: Response to EPARegion IX request todocument Guam EPAactivities to involvepublic in RI andaction

Page No. 307/01/88




32 10/22/82

40 10/27/82


David S. Monday,EPA Region IX

26 11/01/82 Keith A. Takata,EPA Region IX

39 11/03/82

75 12/01/82

Keith A. Takata,EPA Region IX

CDM & Barret,Harris & Assoc.

34 01/13/83

74 05/20/83

Kathleen G.Shimmin, EPARegion IX

Vernon M. Reid,Black & Veatch

Joseph Egan, Ltr: Response toWorld Information 10/18/82 letterSystems requesting Pacific

Basin hazardous wasteinformation


Ltr: CurrentSuperfund actionsregarding hazardouswaste in InsularTerritories(Including OrdotLandfill)

Stephen Caldwell, Memo: HRS scores for 15US EPA

Stanley L.Carlock, P.E.,U.S. Army Corpsof Engineers

Guam EPA

EPA Region IX

Nancy Willis,EPA

US

Region IX sites -documentation forInsular Territories(10/25/82 HRS packagefor Ordot attached)

Ltr: Discussion ofCorps role in RI/FSproject

Final Rpt: "NorthernGuam Lens Study,GroundwaterManagement Program,Aquifer Yield Report"

Issue: What is thestatus of the sitesof the InsularTerritories underCERCLA?

Rpt: 'RemedialInvestigation,Insular TerritoryHazardous WasteSites, Draft Report"

219

113

Page No.07/01/88



DOC. i DATE FROM/ORGANIZ. TO/ORGANIZ. DESCRIPTION/SUBJECT PAGES

38 06/08/83

55 06/08/83

53 06/22/83

54 06/29/83

Antonio B. WonPat, Member ofU.S. Congress


MargaretSizemore, DailyNews Staff

MargaretSizemore, DailyNews Staff

William D.Ruckelshaus,Administrator,EPA

Ltr: Informationrequest Re: Toxicwaste disposal inGuam (with attached6/29/83 ROC Re: WonPat letter)

Herman D. Sablan, Ltr: Transmittal ofAdministrator, "RemedialGuam EPA investigation of the

Insular Territoryhazardous wastesites*

Newspaper Readers News: "Ordot dumpsamples declarednon-toxic"

Newspaper Readers News: "Waste cleanuphinges on EPA"

52 07/21/83

51 09/07/83

58 09/30/83


James B. Branch,Administrator,Guam EPA

HarrySeraydarian, EPARegion IX

Herman D. Sablan, Ltr: With attachedAdministrator, suggested languageGuam EPA for ROD public

comment periodnotification


Ltr: Re: Publiccomment on DraftRemedialInvestigation

Herman D. Sablan, Notice Itr:Administrator, Violation of 40 CRFGuam EPA Part 265 - Interim

Status Standards forhazardous waste TSDfacilities

59 10/18/84 James B. Branch,Administrator,Guam EPA

Francis K.Y. Mau, Ltr: Comments onEnvironmental Scope of Work forBranch, Dept. of confirmation of IASthe Navy sites on U.S. Navy

properties in Guam(Re: 10/2/84 Itr.)

Page No. 507/01/88



DOC. i DATE FROM/ORGANIZ. TO/ORGANI2. DESCRIPTION/SUBJECT PAGES

36 03/27/85

35 05/16/85

22 08/13/85

73 09/10/85

24 11/06/85

64 06/02/86

18 06/25/86

Janes B. Branch,Administrator,Guaa EPA

Doris Lee-Betuel, Cover Itr. withEPA Region IX attached project

synopsis for WERI'sOrdot LandfillLeachate Study

13

Marvin Young, EPA Jerry Clifford,Region IX EPA Region IX

Memo: Quarterlyreport - OrdotLandfill, Guam - Jan1985-Mar 1985

James L. Canto,Guam EPA

Doris Lee-Betuel, Ltr: Transmittal ofEPA Region IX Guam Water and Energy

Research Instituteproject forinvestigationssurface andgroundwatercontamination

James A.Goodrich, CDM

James A.Goodrich, CDM

72 11/20/85 CDM

Keith A. Takataand Thomas A.Mix, EPA RegionIX

Thomas A. Mix,EPA Region IX

EPA Region IX

James A. EPA Region IXGoodrich, CDM

Terry L. Stumph, Keith A. Takata,EPA Region IX EPA Region IX

71 07/24/86 CDM EPA Region IX

Rot: 'Work PlanMemorandum for OrdotLandfill, Guam'

Memo: Ordot Landfillinitial siteinspection

Rpt: "Revised WorkPlan Memorandum forOrdot Landfill, Guam"

Rpt: Ordot Landfill,Guam RI, Work PlanVol. I - "TechnicalScope of Work"

Memo: Review ofOrdot Landfill sampleplan

Rpt: "QualityAssurance ProjectPlan, RemedialInvestigation, OrdotLandfill Site, Guam"

25

26

61

95

Page No.07/01/88




10 08/13/86

68 08/14/86

17 08/18/86

69 08/20/86

67 09/25/86

70 11/06/86

11 12/01/86

7 12/12/86

13 01/26/87

HarrySeraydarian,Region IX

James B. Branch,EPA Guam EPA

Peter Rubenstein, Thomas A. Mix,EPA Region IX EPA Region IX

James B. Branch,Guan EPA

Terry L. Stuaph,EPA Region IX

Janes A.Goodrich, CDM

Terry L. Stunph,EPA Region IX

Carl Aguan, Dir.of Public Works,Guam


EPA Region IX

PatriciaConnaughton,Region IX

EPA

PatriciaSanderson Port,U.S. Dept. ofInterior

Jeff Zelikson,EPA Region IX



Bruce Blanchard,U.S. Dept. ofInterior

Notification ofproposed selection ofOrdot Landfill as aSuperfund site

Memo: Review ofOrdot Landfillsampling and analysisplan dated 7/18/86(plan foundinadequate)

Notice of violationRe: Uncontrolledscavenging at OrdotLandfill

Memo: Discussion ofOrdot Landfill QAPP(7/24/86 revision)review

Rpt: "Final QualityAssurance ProjectPlan, RemedialInvestigation, OrdotLandfill Site, Guam*

Memo: Discussion ofRose Fong's review ofthe Quality AssuranceProject Plan

Memo: Evaluation ofOrdot sample plans

Memo: Preliminarynatural resourcessurvey report

CAPT Donald Ltr: CERCLA 104O'Shea, U.S. Navy information request

Re: U.S. Navyresponsibility atOrdot Landfill

99

Page No.07/01/88




63 02/02/87

8 02/03/87

12 02/04/87

9 02/09/87

66 02/10/87

3 05/04/87

5 05/27/87

62 06/08/87

James A.Goodrich, COM

EPA Region IX

Jeff Zelikson,EPA Region IX

Lawrence J.Caplan,CommercialSanitationSystems, Inc.,Tomuning, Guam

Peter Rubenstein, Stewart Simpson,EPA Region IX EPA Region IX

Patricia Thomas A. Mix,Connaughton, EPA EPA Region IXRegion IX

Rpt: 'Final Samplingand Analysis Plan,Phase I RemedialInvestigation, OrdotLandfill, Guam"

Ltr: Re: Involvementwith Ordot Landfill

250

Neil E. Botts,COM

James A.Goodrich, Camp,Dresser & McKee(COM)

Nancy Lindsay,EPA Region IX


Kent M. Thomas A. Mix,Kitchingman, EPA EPA Region IXRegion IX

James A.Goodrich, COM

EPA Region IX

Memo: Transmittaland approval ofproposed OrdotLandfill air samplingplan

Memo: Ordot Landfillsampling and analysisplan review

Rpt: 'Final QualityAssurance ProjectPlan, RemedialInvestigation, OrdotLandfill Site, Guam*

Ltr: Revisedschedule, Phases I &II RemedialInvestigation, OrdotLandfill, Guam

Review of analyticaldata - samplesMY0195, MY2095-2100,MY0789-0791, MY0187(13 waters)

Rpt: "Addendum toFinal Sampling andAnalysis Plan forSecond Quarter ofSampling for theRemedialInvestigation forOrdot Landfill, Guam"

300

57

Page No.07/01/88



DOC. I DATE FROM/ORGANIZ. TO/ORGANIZ. DESCRIPTION/SUBJECT PAGES

2 06/16/87

61 02/11/88

21

46

Debra L. Bogen,LockheedEngineering,ManagementServices

25 11/18/87 COM

Kent M.Kitchingman, EPARegion IX

EPA Region IX

Kent M.Kitchingman, EPARegion IX


EPA Region IX

Organic analysisscreen withtransaittal letter

Rpt: Final initialsite characterizationreport, OrdotLandfill - Island ofGuam

Memo: Review ofanalytical data,samples Y4953 to¥4962, ¥4964, ¥4965,¥4795, ¥B196, ¥B199 &¥B200

Briefing document:Description of OrdotLandfill site

Comprehensiveremedial responsefact sheet. InsularTerritories

58

14

SUPPLEMENT No. 1


ADMINISTRATIVE RECORD WITH INDEX(Indexed by Date)

This Supplement Was Compiled September 22, 1988 and Includes Documents 76-96

SUPPLEMENT No. 1


ADMINISTRATIVE RECORD WITH INDEX(Indexed by Date)

This Administrative Record Index lists the documents contained in the attachedAdministrative Record Supplement No. 1 to the Administrative Record for theOrdot Landfill Superfund Site in Ordot, Guam. The Index presents the documentsin ascending chronological order, which is consistent with the arrangement of thedocuments in the Supplement itself.

The documents contained in Supplement No. 1 to the Administrative Record wereused by the U.S. Environmental Protection Agency in identifying remedial activitiesappropriate for use at the Ordot Landfill Superfund Site.

Supplement No. 1 to the Administrative Record contains documents identified forinclusion in the Administrative Record following the initial compilation, which wasplaced near the site on July 11, 1988.

Page No. 109/21/88

ORDOT LANDFILL SUPERFUND SITEOrdot, Guaa

Administrative Record File IndexSuppleaent No. 1

DOC. t DATE FROM/ORGANIZ. TO/ORGANIZ. DESCRIPTION/SUBJECTNo. ofPAGES

76 03/26/86

77 01/01/88

78 01/01/88

79 03/15/88

80 06/22/88

81 06/24/88

82 06/29/68

Frank H.Covington, EPARegion IX

Kathy Diehl, EPARegion IX

Carl J. C. Aguon,Guaa Dept. ofPublic Works

Rick Sugarek, EPARegion IX

Arnold Den, EPARegion IX

EPA Region IX

Rick Sugarek, EPA FilesRegion IX


Jaaes L. Canto,Guaa EPA

Jaaes L. Canto,Guae EPA

Faye Vasapolli,Pacific DailyNews

Jaaes L. Canto,Guaa EPA


Cover Letter:Transaittal ofattached Finding ofViolation and Order

Memo: Coaaents onProposed RemedialAction Plan of 6/22/88(Docuaent dateassigned for indexing;actual date unknown)

Comments on SamplingPerformed at OrdotLandfill (Documentdate assigned forindexing;actual date unknown)

Memo: Response toComments RegardingOrdot Landfill PRAPand ISC by RegionalSenior Scientist

Cover Letter:Transnittal ofattached ProposedRemedial Action Plan(PRAP)

Letter: Publicationof Federal EPA'sNotice on the OrdotLandfill SuperfundSite froa theCalifornia NewspaperExchange

Letter: Comments on6/22/88 ProposedRemedial Action Plan

21

Page Mo.09/21/88

DOC. i DATE

ORDOT LANDFILL SUPERFUHD SITEOrdot, Guam

Administrative Record File IndexSupplement No. 1

FROM/ORGANIZ. TO/ORGANIZ. DESCRIPTION/SUBJECTNo. ofPAGES

83

84

85

86

87

88

89

07/06/88

07/06/88

Janes L. Canto,Guam EPA

Jane Hoppin, ICFClement

07/08/85 Norman L.Lovelace, DorisLee-Betuel, EPARegion IX

67/08/88 ICF/Clement

07/08/88 Jeff Zelikson,EPA Region IX

08/08/88

08/11/88

Gerald F. S.Hiatt, EPA RegionIX


Doris Lee-Betual,EPA Region IX


Files

CH2M Hill

David Howekamp,Harry Seraydarianet al


Nancy Boone, U.S.Dept. of Interior

08/13/88 Rick Sugarek, EPA FilesRegion IX

Memo: Comments on theEndangermentAssessment

Memo: PreliminaryDiscussion of Leachatefor Inclusion in theEndangermentAssessment for OrdotLandfill

Memo: ProposedDe-Listing of OrdotLandfill from the NPL

Report: PreliminaryEndangermentAssessment for theOrdot Landfill, Guam

Memo: Transmittal of6/22/88 ProposedRemedial Action Planto EPA Managers forComment

Memo: Comments onOrdot Risk Assessment

Letter: Discussion ofProposed Authorizationof *1.7 million forExpansion andimprovement at OrdotLandfill

Memo: Response toComments of RegionalToxicologist re: OrdotLandfill

60

Page No.09/21/88

DOC. t DATE


Administrative Record File IndexSupplement No. 1

FROM/ORGANIZ. TO/ORGANIZ. DESCRIPTION/SUBJECTNo. ofPAGES

91

92

93

94

95

08/17/88

08/29/88

Kelvin Okawa, EPARegion IX

Kent Kitchingman,EPA Region IX

Lead Reviewer,OGW


09/06/88 Harry Jeffrey Zelikson,Seraydarian, EPA EPA Region IXRegion IX

09/06/88 Rick Sugarek, EPA Kent Kitchingman,Region IX EPA Region IX

09/08/88 James L. Canto, Doris Lee-Betuel,Guam EPA EPA Region IX

96 09/20/88 EPA Region IX EPA and thePublic

Memo: Review of6/22/88 ProposedRemedial Action Plan

Memo: Comments onProposed RemedialAction Plan for OrdotLandfill, Guam

Memo: Comments onProposed RemedialAction Plan

Memo: Response toConcerns of 6/29/88memo Commenting on theProposed RemedialAction Plan

Cover Letter:Transmittal of Minutesof 7/26/88 PublicMeeting on the OrdotLandfill RemedialAction Plan

Responsiveness Summary

keg ^ 415 974*7361; 9-27-88 6: 1SPM ;

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147183084159747351;8 2

P. 02

GUAM ENVIRONMENTAL PROTECTION AGENCYAHENSIAN PRUTEKSION LINA'LA GUAHAN

POST OFFICE BOX 2999 AGANA, GUAM 96910 TELEPHONE: 646-8863/64/65

SEP 281988Mr. Daniel W. McGovernRegional AdministratorU.S. Environmental ProtectionAgency, Region IX

215 Fremont StreetSan Francisco, California 94105

Dear Mr. McGovern:

We have reviewed the final Record of Decision representing the selectedalternative for Ordot Landfill under CERCLA.

Please be advised that the Guam Environmental Protection Agency concurs withthe decision of no action as the preferred alternative under CERCLA at thistime, until Ordot Landfill operation practices are improved and additionalenvironmental monitoring data are gathered.

I look forward to working with you and your staff on this project in thefuture.

Sincerely yours,

CHARLES P. CRISQSTCMQ, M.P,H.Administrator

CC: Norm Lovelace

"ALL LIViNG THINGS OF THE EARTH ARE ONE'