The Arkansas Department of Environmental Quality released its final Remedial Action Decision Document (RADD) for Corrective Action on Friday (Dec. 27) that requires Whirlpool to spend at least $6 million to clean up pollution at its shuttered Fort Smith plant.
ADEQ’s plan also informs Whirlpool and residents affected by the company's spill of potentially cancer-causing trichloroethylene (TCE) of the final cleanup plan that has been the subject of public discussion for much of 2013.
The final RADD document does not vary in remediation approach from the draft RADD document first made public in October, implementing a three-pronged approach to remediation — asphalting the Whirlpool site, using chemical injection wells to dilute the TCE and implementing institutional controls. Several members of the Fort Smith Board of Directors opposed the remediation plan when it was proposed in October.
TCE EXPOSURE RISKS
ADEQ begins by outlining near the beginning of the document how TCE, a degreaser Whirlpool used until the 1980s at its now-shuttered plant on the south side of Fort Smith, could pose danger to individuals impacted by the plume, which extends from the former Whirlpool manufacturing facility to the north, across Ingersol Road.
The state agency tasked with environmental protection and cleanup said three types of individuals are at risk for TCE exposure on the Whirlpool site itself — routine workers, maintenance workers, and construction workers.
"Exposure routes for on-site routine workers from COCs in surface soil include ingestion, dermal contact, inhalation of soil-derived vapors and airborne particulates in outdoor air, and inhalation of soil-derived vapors that migrate through building foundations to indoor air," the document reads.
The ingestion route is very similar to what has already been discussed when Whirlpool lobbied the Fort Smith Board of Directors for a ban on the drilling of new groundwater wells both on the Whirlpool site and in the TCE-contaminated neighborhood directly north of the facility. The request for the ban was defeated.
ADEQ also addressed exposure routes for residents living over the TCE plume, stating that soil-derived and groundwater-derived vapors are exposure routes for anyone living in the affected area as well as "community workers" in the area.
Even with the concern, ADEQ advises that "vapor intrusion pathway from chemicals in soil does not result in an unacceptable exposure in the workplace for on-site routine workers," adding that there are no cancer risks based on measurements taken and compared to EPA-recommended guidelines.
REQUIRED REMEDIATION STEPS
As previously outlined in a draft RADD document, ADEQ said in the final RADD that the entire impacted area "will be covered with asphalt and an impermeable coating. The cover is designed to prevent the water from migrating through the contaminated soils."
In addition to the asphalt cover, a deed will be placed on the property to "prevent unauthorized excavation of the on-site impacted soils." Whirlpool will also be required to implement a soil gas monitoring program at the site for five years. The cost of the asphalting and soil gas monitoring will total $600,000.
In addition to the asphalting, ADEQ is requiring Whirlpool to invest $5.4 million in chemical treatment of the TCE contamination at three different sites, both on the Whirlpool site and elsewhere within the plume.
"Injection points may be added or removed depending upon the hydraulic conductivity and lithology identified during the pre-design phase of work and resulting design. Based on subsequent monitoring results it may be necessary to expand the treatment areas and/or re-treat these areas until a satisfactory trend in TCE concentrations is achieved."
Some of the design work is already taking place at the site, according to Katherine Benenati, ADEQ's public outreach and assistance division chief.
"Whirlpool’s consultants are in the field doing pre-design testing of the soils in preparation for implementing the RADD after the first of the year," she said in a Dec. 18 e-mail.
The final action will be a deed notification on the Whirlpool site.
"The deed notification would identify the kinds of contaminants present, and describe activities that should not be conducted at the facility and grant site access to ADEQ," the RADD states, further adding that the deed restriction must be in place within 60 days of the RADD's effective date.
The RADD states that Whirlpool must begin remediation within 60 days of the effective date (Dec. 27) of the RADD and file quarterly reports every February 15, May 15, August 15, and November 15 as well as annual progress reports on January 15.
City of Fort Smith Communications Manager Tracy Winchell said the final RADD document arrived late in the day and city staff did not have an opportunity to evaluate its contents and recommendations during regular office hours.
Link here for a PDF of the ADEQ final RADD.