V
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            United States         Office of
            Environmental Protection   Emergency and
            Agency            Remedial Response
 c/EPA    Superfund
            Record of Decision

            Vertac, AR
 SEP 191934
EPA/ROD/R06-93/080
June 1993

PB94-964201

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VSj!77
            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                            REGION 6
                     1445 ROSS AVENUE, SUITE 1200
                        DALLAS, TX 75202-2733
              DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Vertac, Incorporated
Jacksonville, Arkansas

STATEMENT OF BASIS AND PURPOSE

This decision document  presents the selected remedial  action for
the Vertac,  Incorporated site,  Jacksonville, Arkansas, which was
chosen in accordance with CERCLA, as amended by SARA,  and,  to the
extent practicable, the  National Contingency Plan.   This  decision
is based on the Administrative  Record  for this  site.

The State of Arkansas concurs with the selected remedy.

ASSESSMENT OP THE SITE

Actual or  threatened releases  of hazardous substances from this
site, if not addressed by implementing the response action selected
in this  Record of  Decision  (ROD),  may present an imminent and
substantial  endangerment  to   public   health,   welfare,   or  the
environment.

DESCRIPTION OF THE REMEDY

This ROD is for the Vertac Onsite Operable  Unit 1,  which  includes
most  of  the  above-ground  media,   such  as buildings,   process
equipment,  process  vessel  contents,   spent   activated   carbon,
miscellaneous  drummed wastes   (including  Remedial  Investigation
wastes), shredded trash  and pallets, and PCB transformer  oils.

The major components of  the selected remedy include:

     •    Onsite incineration of F-listed process vessel contents,
          shredded  trash and pallets,  and miscellaneous  drummed
          wastes (except Remedial Investigation  (RI) wastes such as
          used personal  protective clothing and trash).

     •    Off-site incineration of transformer  PCB oils.

     •    Onsite  incineration  and/or  reactivation  and reuse of
          spent carbon.

     •    If feasible, off-site treatment,  disposal,  or reuse of
          demonstrated non-F-listed process vessel contents  (such
          as spent caustic, hydrochloric acid,  kerosene/fuel oil,
          etc.) or onsite incineration.
                                                       I.'"*' Printed on Recycled Paper

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     •    Off-site   recycle/reuse   of   decontaminated   process
          equipment (such as tanks,  structural steel, pumps, etc.),
          to the maximum extent practicable.

     •    Onsite  consolidation/containment   of  debris  resulting
          from demolition  of  buildings (except the  supervisor's
          office  building, bagged soil  storage  building,  and
          wastewater treatment plant building that would be left
          intact for continued use), and process equipment that is
          not  practicable  to  be  recycled/reused,   and  some
          containerized materials (RI wastes) in a RCRA Subtitle C
          landfill.

     •    Treatment residues - Incinerator ash and  salt disposal
          shall be  consistent  with the disposal of  ash and salt
          generated  by  onsite  incineration of  drummed  wastes
          currently in progress. The United  States  Environmental
          Protection Agency (EPA) is in the process  of developing
          and selecting  a  disposal option for  the  ash  and salt
          being generated at the Vertac facility.

     •    Decontamination residues - Onsite  incineration of used
          solvents,  filter spools, etc.    Onsite treatment  and
          discharge of contaminated water.


STATUTORY DETERMINATIONS

The  selected  remedy  is  protective   of  human  health  and  the
environment, complies with  Federal  and  State  requirements that are
legally applicable or relevant  and  appropriate to  the remedial
action, and is  cost  effective.   This remedy utilizes permanent
solutions   and  alternative   treatment  (or   resource  recovery)
technologies to the maximum extent practicable  and  satisfies the
statutory  preference  for  remedies  that employ  treatment that
reduces   toxicity,   mobility,  or    volume  as   a   principal
element.Because  this  remedy   results  in hazardous  substances,
pollutants, or contaminants remaining at the site above  levels that
allow for unlimited use and unrestricted exposure,  EPA shall review
the remedial action  no  less  often than  every five  years after
initiation  of the selected remedial action.
Date               *0& D*
                          Regional Administrator

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                       VERTAC, INCORPORATED
Record Of Concurrences  For Onsite Operable Unit 1 ROD
M'. S. Ramesh, Remedial Project Manager
Superfund Enforcement - Ar/La Section (6H-EA)
Verne McFarland,Chief
Information Management Section  (6H-MC)
For Peer Review Committee
Bill Luthans, Chief
Superfund Enforcement - Ar/La Section  (6H-EA)
        )
Sam Becker, Chief
Superfund Enforcement Branc
Mel McFarland, Attorney           \
Waste Enforcement, ALON Section  (6C-WA)
Pamela Phillips, Acting Chief
Waste Enforcement Branch  (6C-W)
George R. Alexander, Jr.
Regional Counsel (6C)
Allyn M. Davis, Director
Hazardous Waste Management Division (6H)

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     THE DECISION SUMMARY




VERTAC ONSITE OPERABLE UNIT 1

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                        TABLE OF CONTENTS

Section   Title                                             Page

1         Site Name, Location, and Description              1
               1.1  Site Name and Location                  1
               1.2  Description                             1

2         Site History and Enforcement Activities           5
               2.1  Site History                            5
               2.2  Site Investigations                     7
               2.3  Enforcement History                     9

3         Highlights of Community Participation             11

4         Scope and Role of Operable Unit                   12

5         Summary of Site Characteristics                   13
               5.1  Land Use/Population                     13
               5.2  Geology                                 14
               5.3  Ground Water                            18
               5.4  Surface Water                           18
               5.5  Remedial Investigation Findings         19

6         Summary of Site Risks                             34

7         Description of Alternatives                       39
               7.1  Alternatives                            39
               7.2  ARARs                                   57

8         Summary of Comparative Analysis of Alternatives   72
               8.1  Threshold Criteria                      72
               8.2  Primary Balancing Criteria              74
               8.3  Modifying Criteria                      77

9         The Selected Remedy                               77

10        Statutory Determinations                          84

11        Documentation of Significant Changes              89

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                         LIST OF FIGURES





Figure No^     Title                                        Page



1-1            Site Location Map                            2



1-2            Site Map                                     3



1-3            Site Process Areas                           4



5-1            Land Use Zoning Map                          15



5-2            Geologic Map of the Site                     17



5-3            Location of Buildings                        27



7-1            Conceptual Layout of Alternative 2           42



7-2            Storage Building Conceptual Design           43



7-3            Clay-Lined Consolidation Unit                45



7-4            Double-Lined Consolidation Unit              47



7-5            Conceptual Layout of Alternative 3           52



7-6            Conceptual Layout of Alternative 4           56



7-7            Conceptual Layout of Alternative 5           58

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                         LIST  OF TABLES


Table No. Title                                             Page

5-1       Site Geologic Formations                          16

5-2       F-Listed Process Vessel Contents Analytical       21
          Summary

5-3       Non-F-Listed Process Vessel Contents Analytical   22
          Summary

5-4       Unknown Process Vessel Contents Analytical        23
          Summary

5-5       Spent Carbon Analytical Summary                   25

5-6       French Drain Leachate Analytical Summary          26

5-7       Building Wipes Analytical Summary                 28

5-8       Building Dust Analytical Summary                  29

5-9       Process Equipment Wipes Analytical Summary        31

5-10      Process Vessel Rinsate Analytical Summary         32

5-11      Containerized Soil Analytical Summary             33

5-12      Shredded Trash Analytical Summary                 35

5-13      Shredded Pallets Analytical Summary               36

5-14      Transformer Oil Analytical Results                37

7-1       Estimated Capital and O&M Costs                   49

7-2       Potential Operable Unit 1 ARARs                   61

7-3       National Ambient Air Quality Standards            69

8-1       Individual Evaluation of Alternatives             78

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                      THE DECISION SUMMARY

                  VERTAC ONSITE OPERABLE UNIT 1

1.   SITE NAME, LOCATION, AND DESCRIPTION

1.1  SITE NAME AND LOCATION

The Vertac,  Incorporated Superfund Site  (the "site") is located in
Jacksonville, Pulaski County,  Arkansas.  The site is approximately
15 miles northeast of Little Rock. The approximate location of the
site is shown on Figure 1-1 (United States Geological Survey (USGS)
Cabot, Olmstead,  Jacksonville, and  McAlmont,  Arkansas,  7.5 minute
quadrangle map).

1.2  DESCRIPTION

Cultural features on the site and  in the site area are  shown in
Figure 1-2.   The site is bounded by Marshall  Road to the east and
the  Union-Pacific Railroad to  the west.   Further  west of  the
railroad  tracks,  the   land   is  used  for  industrial/commercial
purposes.  The Little Rock Air Force Base occupies land farther to
the north.   Residential areas are immediately  to the south and east
of the site.

Land  comprising  the site  consists  of  two  parcels  (Figure  1-2,
Parcel  1  and Parcel 2)  that were  acquired  at  different times.
Parcel 1, which contains the central process area, is approximately
93 acres and has  been in nearly continuous  industrial  use since
1948. Parcel 2, which is approximately 100 additional acres to the
north, was purchased by Vertac in 1978.   In 1979,  the 2,4,5-T waste
storage shed was built.  The storage shed was built adjacent to the
Regina Paint Building, which today is believed to  contain the empty
Vertac 2,4,5-T waste drums.  Parcel 2 does not contain production
facilities.   The  central process  area is wholly   enclosed within a
chain link fence that surrounds most of Parcels 1 and 2.

Topographically,  the land has moderate relief,  sloping from about
310 feet above mean sea level (MSL)  in the north to approximately
260 feet near the  southwestern corner.  The central process area is
located on a flat-topped, south plunging topographic nose bounded
by Rocky Branch Creek on the  west and  Marshall Road on the east.
Land on the west side of Rocky Branch Creek has not been used for
manufacture or disposal  and is generally isolated from the central
process area by the  creek.  Land  in the northern  parts of the site
has not been used  for manufacture and is generally upslope  from the
central process area.

The central process area is separated into 11 sub-areas according
to where operations took place while the plant was active (Figure
1-3).  The sub-areas and their former uses include:

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                                 ^
                    =^    Little Rock  »-
                       '  \§:Air ForceBase
               LOCATION
Source U S Geological Survey
      75 Minute Series
      Olmstead. AR(1987)
      Cabot AR (1987)
      Jacksonville, AR (1987)
                                                            ••^•^^^^^^^•^^^^^••

                                                             Scale in Feet
Jacksonville, A  (198
McAlmont AR(1975)
             FIGURE 1-1 SITE LOCATION MAP, VERT AC SITE
                         JACKSONVILLE, ARKANSAS

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     •    Maintenance Area - Used for equipment repairs and storage
          of equipment,  parts,  and some process  raw materials.

     •    Formulations Area  -  Used  for the storage  of raw  and
          finished  product   (large  warehouse  and  some  process
          vessels).

     •    Former  Chlorination   Plant  Area   -   Used  in   the
          manufacturing of  2,4-D.

     •    Existing Chlorination Plant  Area  -  Built in  the  early
          1980s and replaced the former Chlorination plant.

     •    Esterification Plant  - Used to add alcohols to increase
          the solubility of  the herbicide in water.

     •    Dalapon (1,1, l-trichloropropionic acid) Production Area -
          Used in the manufacturing of Dalapon.

     •    Recycle Liquor Storage  Area - Currently used  to  store
          drums generated by ongoing site activities.

     •    Recovery Plant - Used in the treatment of process wastes.
          2,4-D wastes were recovered  and drums  containing  2,4-D
          wastes were washed.

     •    2,4,5-T Production Area - Used in the manufacturing of
          2,4,5-T.

     •    Waste water Treatment Plant  -  Formerly used  to  treat
          process waste water,  and currently used to treat ground
          water and surface water from the central process area.

     •    Acid Plant - Chlorophenols were reacted with acetic and
          monochloroacetic   acid   to  form  phenoxyacetic   acid
          herbicides.

The Regina Paint Building,  located in Parcel 2,  is the only study
unit located outside of the Central Process Area that is included
in Onsite Operable Unit 1.

2j_   SITE HISTORY AND ENFORCEMENT ACTIVITIES

2.1  SITE HISTORY

The first facilities  on the site were  constructed by the United
States Department of Defense (DOD) in the 1930s and 1940s.  These
facilities were part  of  a munitions complex that extended beyond
the present site boundaries.  In  1948,  the Reasor-Hill Company
purchased the property and converted the operations to manufacture
insecticides such as DDT, aldrin, dieldrin,  and toxaphene. During
the  1950s,   Reasor-Hill manufactured  herbicides  such  as  2,4-

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dichlorophenoxyacetic  acid  (2,4-D),  2,4,5-trichlorophenoxyacetic
acid  (2,4,5-T),  and 2,4,5-tricholrophenoxypropionic acid  (2,4,5-
TP) ,  which  is also  called  Silvex.  Drums of  organic wastes were
stacked in an  open  field  immediately southwest of the production
area, and untreated process water was discharged from the western
end of the plant to Rocky Branch Creek.

Hercules  Powder  Company,  now known  as  Hercules  Incorporated
(Hercules), purchased  the Reasor-Hill  property and plant in 1961
and continued to manufacture and formulate herbicides. The drums of
organic wastes that were in  the open  area southwest of the central
process area were buried  in the 1960s  by Hercules in what is now
referred  to  as  the  Reasor-Hill  Landfill.  From  1964   to 1968,
Hercules  produced the  herbicide  Agent  Orange,  a  2,4-D/2,4,5-T
mixture for DOD. Hercules discontinued operations at the site in
1971.

From 1971 to 1976,  Hercules  leased the  plant to Transvaal, Inc., a
predecessor  company  of  Vertac Chemical  Corporation   (Vertac).
Transvaal resumed production of 2,4-D and intermittently produced
2,4,5-T.  Organic wastes  from  these  manufacturing processes were
stored and then buried onsite in the  1970s by Transvaal in what is
now referred  to  as the North  Landfill or  the Hercules/Transvaal
Landfill.  Transvaal purchased  the property and plant  from Hercules
in 1976.   In  1978,  Transvaal  underwent  a Chapter  XI bankruptcy
reorganization, and  ownership  of the site  was transferred to the
new company, Vertac, which is the present owner.

Arkansas  Department of  Pollution  Control  and Ecology  (ADPC&E)
issued  an order  in  1979 that required Vertac  to  improve  its
hazardous  waste  practices,  and  in  1980,   the  United  States
Environmental Protection Agency (EPA) and ADPC&E jointly filed suit
in federal district court against Vertac and Hercules.  A Consent
Decree entered into  by EPA, ADPC&E, Vertac,  and Hercules in January
1982, required that an independent consultant assess the conditions
of onsite wastes  and develop  a proposed disposal method for the
wastes.  The proposal,  called  the "Vertac  Remedy,"  was  deemed by
EPA to  be unsatisfactory.   The court decided  in  favor  of  the
proposed remedy,  which was implemented in  summer 1984  and completed
in July  1986.   As part of  the remedy, the Vertac  plant cooling
water pond was closed,  and sediment from this unit was removed and
placed   in   an   above-ground   vault.      The  Reasor-Hill   and
Hercules/Transvaal Landfills were capped,  and a french  drain and
leachate  collection  system were  installed  around  the  burial
(landfills)  area.     Ground water   monitoring  wells  were  also
installed, and a ground water monitoring program was initiated.

Vertac operated  the plant until 1986.   In January  1987,  Vertac
abandoned the site,  leaving about 29,000 drums  of 2,4-D and 2,4,5,-
T wastes.  Many of these drums were leaking.  EPA and Hercules then
took over management of the site. This  management has included the
maintenance and overpacking  (placing  a leaking drum in a larger new

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plastic drum) of nearly 29,000 drums of  organic  material by EPA.
Hercules has operated the treatment plant that treats ground water
collected  in french  drains,  which  were  constructed by  Vertac
downgradient of the landfills as a part of the Vertac Remedy, and
surface water runoff  collected in ditches that drain to sumps.  The
water treatment plant treats surface water runoff and ground water
by  phase-separation  followed  by  adsorption  through  granular
activated carbon.  Additionally,  a series of drainage ditches and
sumps, which surround the central process  area,  collects surface
runoff and  pumps it  to the water  treatment plant.   The treated
water is piped to the West Waste water Treatment Plant,  owned and
operated by the City of Jacksonville,  and is then discharged into
Bayou Meto.

Currently, there are no manufacturing operations at the site.  At
the time operations were shut down, Vertac "mothballed" the plant.
Mothballing involved flushing process  lines  and  draining many of
the process vessels.  However, many vessels and tanks still contain
residues. Continuing activities at the site  include  operation of
the water treatment plant by Hercules.

The Vertac, Incorporated site was added to the National Priorities
List  (NPL)  of hazardous waste  sites  in 1982.  Once  the  site was
placed on the NPL, Superfund money became  available  to  study the
contamination problems at Vertac and find ways to correct them to
protect public health and the environment,  pursuant to CERCLA.

2.2  SITE INVESTIGATIONS

Previous investigations performed at the  site began in April 1978,
when Vertac participated in a nationwide survey of potential dioxin
sites.    Three  recent activities  that  are  of  importance  in
formulating the site characterization activities are:

1. Beginning in March 1987 and continuing through April 1988, EPA
performed  an inventory of  the process  vessels  (storage tanks,
chemical reaction vessels,  etc.)  in the central process area.  The
inventory consisted of:

          Vessel identification.
          Geometric shape.
          Volume.
          Content level, volume, phase.
          Content visual description.
          Analytical data (specific vessels).

This inventory revealed that approximately 213 vessels were onsite.
Of  the  total, 73  of the process vessels  were determined  to be
empty. Of  the 140 process vessels that were not  empty,  96 were
sampled  and  analyzed for  2,4-D, 2,4,5-T,   and/or   2,3,7,8-TCDD
(TCDD). The remaining 44 process vessels were not sampled because
they  contained material associated with  a  known process, such as

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manufacture of 2,4,5-T, water treatment, etc.  Because sampling was
performed as  a general assessment,  not every vessel  onsite was
sampled.

Of  the  96  vessels  sampled,  46  vessels contained  TCDD  at  a
concentration  greater  than the detection  limit  of 0.3  part per
billion  (ppb).  TCDD concentrations ranged from non detect to 960
ppb. Concentrations of 2,4-D ranged up to a maximum concentration
of 200,000 parts per million (ppm).

Samples  of  insulation from the  outside of 52 insulated process
vessels were  collected  for asbestos analysis.   Asbestos was not
found in any of these samples.

Samples  were   also  collected from  selected  buildings,  building
components,  and roofing materials for asbestos analysis.   A total
of six  bulk samples were  analyzed  for asbestos and  five tested
positive.  The locations and the reported results are:

     •    Boiler feed water pump =>3% Amosite.
     •    No.  3 boiler =>2% Chrysotile.
     •    Dalapon Pad Area =>20% Chrysotile.
     •    Formulations   Building   roof   tile   =>!!%
          Chrysotile.
     •    Formulations   Building   wall   tile   =>ll%
          Chrysotile.

Since  February 1,  1987,   U.S.  EPA  has managed  onsite wastes,
including trash and pallets.  The trash included floor sweepings,
scrap metal, packaging material, personal protective clothing, and
other wastes  typically generated in an industrial setting.  EPA
shredded the trash and placed it into 1.7-cubic-yard polyethylene-
lined,  nylon  bags.  An  estimated 643  bags  were generated.   No
previous analytical data characterizing the trash were available.
The  trash was  considered to  have  been  homogenized  during  the
shredding process, which cut the trash into small pieces.  During
shredding, the trash  was  staged in  a  common area,  shredded,  and
later transferred into the bags.

EPA also shredded 9,906 pallets and placed them into an estimated
675 polyethylene-lined, nylon  bags  with a capacity of  1.7  cubic
yards.  The  bags of shredded pallets were generated with the trash.
No previous analytical  data characterizing the shredded pallets
were  available.    After  shredding,  the pieces  of the  shredded
pallets were  staged  in  a  common area  and  later were  transferred
into the bags.

2. The removal project performed by Hercules  in the fall of 1988,
under the terms  of an Administrative  Order on Consent,  involved
excavating residential surface soils contaminated with TCDD at a
concentration  > 1  ppb.   Approximately 2,700 cubic yards of soil
were  excavated and stored  in  approximately 1,630  polyethylene-

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lined, nylon bags (1.7-cubic-yard capacity).   TCDD concentrations
for most residential soils  ranged  from 1 to 10 ppb.   Other site
soils were also  excavated  and placed in bags.  These  soils came
from onsite surface drainage  areas that  were  excavated,  and from
the  excavation  for  surface  drainage  collection sumps.    TCDD
concentrations in these onsite soils ranged from  100  to 200 ppb.
The  soils  were  collected   in a common  staging  area and  later
transferred to the 1.7-cubic-yard bags.  The excavating,  staging,
and transferring resulted in thorough mixing of soils.   The soils
are considered homogenized and the TCDD  concentrations are expected
to be similar  among  bags.   These bags are currently  stored in a
warehouse built  by Hercules,  located near the boiler  house,  and
were sampled during Operable Unit I Remedial Investigation.

3. In July 1989, Hercules  signed an  Administrative Order (AO)  On
Consent with EPA to  conduct a Remedial Investigation/Feasibility
Study (RI/FS)  for the Vertac onsite areas. Since the contamination
problems at the Vertac onsite areas are complex,  the onsite RI/FS
was  divided  into  two  operable  units.  Onsite Operable Unit  1
consists  of  above-ground  media,   such  as  buildings,   process
equipment,  etc.  Onsite Operable Unit 2 addresses soils and ground
water. RI/FS  for Onsite Operable Unit 1 was completed  in March
1991. The findings of this  investigation  are detailed in Section 5
(Summary of Site Characteristics)  of this ROD.

2.3  ENFORCEMENT HISTORY

A  Potentially  Responsible  Party  (PRP)  search was not conducted
since the Agency knew the identities of former owners, operators,
and  some generators  of waste at  the  Vertac site,  and  since
litigation was  already going  on  prior to  CERCLA  activities.
However, CERCLA  Section 104(e)  information request  letters were
mailed in March 1990  and later to several companies, some of which
had  "tolling   agreements"  with the  Vertac Chemical  Corporation
and/or Hercules Inc.

The following  is  a chronology of enforcement activity at the Vertac
site:

  1. Litigation was filed in 1980 under RCRA Section 7003 and other
     statutes  by the  United  States  and the  State of  Arkansas
     against   Vertac   Chemical  Corp.   and  Hercules   Inc.  (the
     "Parties").  In January  1982, EPA and the State  of Arkansas
     entered into a Consent Decree with Vertac Chemical Corp. and
     Hercules Inc.  in the litigation for developing a remedial plan
     for certain onsite and  off-site  areas.   After  EPA invoked
     dispute resolution and a hearing on the remedy,  the court
     ordered the implementation of  the  "Vertac Remedy"  in July
     1984.    (See  Site History  for  a discussion of  the action
     taken.)

  2. In July 1986, pursuant to an agreement between the  parties and

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    entered by the court, Vertac established a Trust Fund, as part
    of a bankruptcy agreement. Vertac placed $6,700,000 in this
    fund  to  be  used  to remediate  portions  of the  plant.  A
    $4,000,000 letter  of credit was later added to this  Trust
    Fund.  Both EPA  and the  State of Arkansas have access to this
    fund, and it is being used to incinerate the 29,000 drums.

 3. In August 1986,  EPA issued a Unilateral Administrative Order
    to all  PRPs to  require posting  of warning signs and  the
    fencing of portions  of  the West Waste  water Treatment Plant
    and  certain  areas  of  Rocky Branch  Creek.   This  work  was
    performed by Hercules.

 4. In January 1987, EPA issued a notice letter to Vertac Chemical
    Corp.  that  required  Vertac  Chemical  Corp.  to   continue
    operation and maintenance of leachate collection and treatment
    system.

 5. In June 1988, EPA  signed an Administrative Order on Consent
    with  Hercules  to   allow  Hercules  to   implement  fine  grid
    sampling for off-site areas.

 6. In September 1988,  EPA signed an  Administrative  Order  on
    Consent  with Hercules  that  required  Hercules  to  remove
    contaminated soils from residential  yards.

 7. In July 1989, EPA  signed an Administrative Order on Consent
    with Hercules that required  Hercules  to  conduct the  onsite
    Remedial Investigation/Feasibility Study (RI/FS).

 8. In March  1990,  EPA  sent  CERCLA  Section  104(e)  information
    request letters  to several companies which had been involved
    in business  deals  with Vertac Chemical Corp. and  Hercules
    Inc., including "tolling agreements".

 9. In July  1990, EPA sent General Notice letters to  the PRPs
    regarding the proposed off-site remedial plan and other site
    actions.

10. In February 1991, the District Court entered a Consent Decree
    between the United  States and the "Phoenix Parties," which are
    companies related to Vertac Chemical Corp., and which carried
    on the remaining business of Vertac under their  names  after
    Vertac abandoned the site.   Hercules  appealed entry of  the
    Consent Decree to the Eighth Circuit Court of Appeals,  which
    upheld entry of  the Consent Decree in April 1992.   Under the
    terms  of  the   Consent  Decree,  the  Phoenix  Parties  have
    contributed  $1,840,000  to the  RCRA  Closure  Trust  Fund,  and
    will contribute  a percentage of pre-tax profits for 12 years,
    in return for a  release from liability.

11. Hercules Inc. had opposed the United States' efforts to select

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     a remedy for the  off-site  area at Vertac.  This  opposition
     included a motion  filed  in September 1992, to enforce  1982
     RCRA Consent Decree.  The parties were ultimately unable to
     resolve their  differences  regarding this  motion.   In  June
     1992,  the  trial court  entered an  order denying  Hercules'
     motion to enforce the Consent Decree,  and allowed  EPA to use
     CERCLA procedures to select remedies for  Vertac.

 12. The United  States added CERCLA section  107  cost  recovery
     claims against Hercules, The Dow Chemical Company and Uniroyal
     Chemical Limited  of  Canada in  a  complaint filed  in  March,
     1992.    By  order  of  the  trial court  in June  1992,  this
     complaint was administratively closed,  and the claims asserted
     against Hercules,  Dow and Uniroyal were consolidated with the
     existing litigation.    Other  parties,   including  BASF  AG,
     Standard Chlorine and  Velsicol,  have  been  added  to  the
     litigation  as  third-party defendants,

 13. Special notice  letters  for Remedial Design/Remedial  Action
     (RD/RA)  for the  off-site areas were sent to the PRPs in August
     1992.   No good  faith offers were received in response to this
     letter.    A subsequent  special notice letter was sent  in
     December 1992,  to  the PRPs after EPA revised the  scope of
     remedial work  at the off-site areas.  Negotiations regarding
     this work did  not result in an RD/RA Consent  Decree.

 14. Discovery in the liability phase of the ongoing litigation has
     been  completed.   Pre-trial  motions   and  negotiations  are
     underway.  The  case has  been set  for trial on the issue of
     liability beginning  on November  1, 1993.   Following  this
     trial, phases II and III will deal with the government's costs
     and  apportionment  of   liability  among  the  defendants,
     respectively.

 15. Although it  is not  specifically enforcement-related,  two
     separate citizens'  suits have  been filed  seeking to  halt
     incineration of dioxin still  bottom wastes  stored  at  the
     Vertac Site.   The  first suit,  filed in 1990 by the National
     Toxics Campaign and others, resulted in denial of plaintiffs'
     request for a  preliminary  injunction  against  incineration.
     The second  suit, filed in October 1992, by the Arkansas Peace
     Center and  others,  resulted in both a temporary injunction and
     a  preliminary  injunction   prohibiting  incineration  being
     issued.  The preliminary injunction  is being appealed to the
     Eighth Circuit  Court of Appeals, which has issued a stay of
     the preliminary injunction.

li   HIGHLIGHTS OF  COMMUNITY PARTICIPATION

A Community Relations  Plan  for  the Vertac  site was completed in
1983.  This plan lists contacts  and interested parties  throughout
government  and  the  local  community.     It  also   establishes

                                11

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communication pathways to ensure timely dissemination of pertinent
information.  Numerous fact sheets,  open houses and workshops have
been conducted on the Vertac site. A satellite community relations
office was established in Jacksonville in July 1990 to provide easy
access to  documents and  information.   The Vertac  Site Remedial
Investigation  and Focused Feasibility Study For  Operable  Unit 1
was released to the public in March 1991.  This document was made
available  at  five  local  repositories  (Jacksonville  City Hall,
Public Library, Police Courts Building, Air Force Base Library, and
ADPC&E  in  Little Rock).   The Administrative Record for  this
operable unit is maintained at EPA in Dallas, the Jacksonville City
Hall and the Arkansas Department of Pollution Control and Ecology
in Little Rock.

A Technical Assistance Grant (TAG) was awarded by  EPA in 1989 to a
citizens  group called  Jacksonville People With  Pride Clean  Up
Coalition  (JPWPCUC). This award was challenged by citizens groups
that competed for the grant, who alleged that JPWPCUC was funded by
the  Potentially  Responsible   Parties (PRPs)  for  Vertac.  Upon
investigation  by  EPA,  the grant  was  annulled after  it  was
determined that the JPWPCUC TAG application listed their source of
matching funds as a bank account shared with their larger "parent"
group, the  Jacksonville  People  With Pride.  This parent group had
indeed accepted monetary contributions from Vertac PRPs, and since
these funds were not distinct from those of JPWPCUC, EPA determined
that a  possible conflict  of interest could exist, resulting  in
annulment of the TAG in December 1991.

TAG availability was  again advertised in  January 1992, and the
grant was  awarded to  the  Concerned Citizens Coalition  (CCC)  in
April  1993  after  considerable  effort   by  EPA  to  facilitate
consolidation of four competing citizen groups. CCC is currently in
the process of soliciting for a Technical Advisor.

The proposed plan for this operable unit  was released on February
13, 1993.   A public comment period was held from February 22  to
April 23,  1993.   In addition,  an open house was held  on February
13, 1993 and a public meeting was held on April 13, 1993 to present
the results of the Remedial Investigation/Focused Feasibility Study
and the proposed plan.  All comments received by EPA prior to the
end  of  the  public  comment period,  including   those  expressed
verbally at the public meeting,  are addressed in the Responsiveness
Summary  section  of   this  Record   of   Decision.  Thus,   public
participation requirements of CERCLA Sections 113 (K) (2) (B) (i-v) and
117 have been satisfied.

4j_   SCOPE AND ROLE OF ONSITE OPERABLE UNIT 1 WITHIN SITE STRATEGY

Since the Vertac Superfund  Site is very large and complex, the site
is divided into the following operable units:

Vertac Remedy - As required by  the 1984 Consent Decree,  the Vertac

                                12

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plant cooling water pond was closed and  sediments  from this unit
were removed and placed  in an above-ground sediment vault.   The
burial  areas   (landfills)  were  capped  and  a  french  drain  and
leachate collection system  were installed around the burial areas.
Ground water monitoring  wells were also  installed and  a ground
water monitoring program was initiated.

Vertac Off-Site  -  This Record of  Decision,  signed  in September
1990, addresses  the  clean-up  of  the off-site  areas  that  were
contaminated as a result of untreated and partially treated surface
and underground (city sewer) discharges of waste water and other
releases from the plant. EPA has issued a Unilateral Administrative
Order (UAO) to the PRPs for  conducting  RD/RA for this  operable
unit.

Drummed Wastes Incineration - When Vertac abandoned  the  plant in
1987, approximately 29,000 drums  of 2,4-D and 2,4,5-T wastes were
left  onsite.  In 1989,  ADPC&E signed a  contract  to  have  these
drummed  wastes incinerated onsite.    EPA provided  incineration
support,  and  has  performed an  engineering  evaluation/cost
analysis  (EE/CA)  for incineration support.   Incineration of these
wastes began in fall 1990.  EPA  also signed an action memorandum in
September 1992,  selecting  incineration of these drummed wastes.
ADPC&E terminated  the incineration contract in  early  June 1993.
EPA has taken over this drum incineration project.

Onsite Operable Unit 1 -  In July  1989, Hercules Inc.(a Potentially
Responsible Party)  signed an Administrative Order on Consent, with
EPA to  conduct a Remedial  Investigation/Feasibility Study
(RI/FS)   for  above-ground  items,   such  as  buildings,   process
equipment, tanks and  their contents,  shredded  trash  and pallets,
and bagged  soils  (removed from  dioxin  contaminated residential
yards).   This RI/FS was completed in March 1991.

Onsite Operable Unit 2 - This operable unit addresses surface and
subsurface soils, underground storage tanks and piping and ground
water.   Hercules  is  conducting  an  RI/FS for  this operable unit
under the terms of  the  above-mentioned  Administrative  Order on
Consent  and this RI/FS is scheduled  for completion  by September
1994. This operable unit is expected to be further divided into
two operable units  (soils and ground water operable units).

The Onsite Operable Unit 1, the subject of this ROD, addresses the
onsite above-ground units.  The contaminated media (tank contents,
spent carbon,  drummed wastes,  buildings and equipment,  etc.) in
this  operable  unit poses  principal and  low level threats.   The
purpose of this response  is to address risks posed by this operable
unit's media.

5_._   SUMMARY OF SITE CHARACTERISTICS

5.1  LAND USE/POPULATION

                               13

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The Vertac site is zoned industrial and is located within the City
of Jacksonville.  Land use zoning near the Vertac plant is shown on
Figure  5-1.   The  portion  just south of the Vertac plant site,
between Marshall  Road  and the Missouri-Pacific railroad tracks,
south to West Main Street, is residential, a combination of single-
family homes and apartments.  The section immediately west of the
railroad tracks and north of West Main Street is undeveloped.  The
area between West Main  Street and South Redmond Road is commercial
and  light  industrial.    Just south  of  South Redmond  Road  is
undeveloped, uninhabited land that includes the Jacksonville Sewage
Treatment Plant,  DuPree  Park,  and  Lake  DuPree.  The rest  of the
area is either farmland, mainly irrigated rice fields in the area
south of Jacksonville and Bayou Meto, woodlands,  or residential.
There is substantial suburban residential development on the strip
of higher ground along Highway 161 and in the area north of Bayou
Meto.

The population growth of  Jacksonville  has been as follows:  1950 -
2,474; 1960 - 14,488, 1965 - 18,078; 1970 - 19,832; 1980 - 26,788;
and 1990 - 29,101.

5.2  GEOLOGY

The site lies in the transition zone between the Coastal Plain and
the  interior Highlands  Physiographic Provinces.  The  surficial
geology of the Coastal Plain Province in the region surrounding the
site is dominated  by a westward thinning wedge of unconsolidated
sediment consisting  of  the  Tertiary Age Claiborne  Group,  Wilcox
Group, and Midway Formation.

The Claiborne Group and the Wilcox Group are undifferentiated along
the fall line that  occurs in the site area.  The wedge  onlaps the
rocks  of   the  Pennsylvanian  Age  lower  Atoka  Formation,  which
dominates the geology  of the interior Highlands Province  in the
region  surrounding  the  site.  Quaternary  alluvium  and  terrace
deposits occur locally along  drainages in both provinces and are
more common in the Coastal Plain Province. A generalized summary of
the geologic formations surrounding the site is presented in Table
5-1. A map of the site  geology is  presented in Figure 5-2.

The   contact   between   the   Tertiary  Age   sediments   and   the
Pennsylvanian Age rocks occurs along a regional trend of northeast
to southwest and  is present in the area of the site. On a local
scale, the trend of  the  contact depends  on the current  erosional
surface and the paleotopographic surface of  the Atoka  Formation.
The strike of the Wilcox Group sediments  and  the Midway Formation
tends toward the northeast/southwest.  The dip of the sediments is
low and oriented  toward  the southeast.  The Midway  Formation was
deposited onto  the irregular and  weathered surface of  the Atoka
Formation, which was folded and fractured during the late stages of
the Alleghenian orogeny.  The Atoka Formation was  later uplifted and
weathered. In the area  of the site, the strike of the beds in the

                               14

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                              Land Use Zoning Map
                              Vertac Operable Unit 1
         15

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Atoka  Formation  trends N70°W and  dip is about  35°NE.  The Atoka
Formation outcrops along Rocky Branch Creek  on the western side of
the site.

5.3  GROUND WATER

This ROD does not  address  the ground water  contamination issues.
Onsite  Operable  Unit  2  ROD, scheduled  for December  1994,  will
address ground water contamination.  Ground water investigation has
indicated that contamination has  not migrated  to off-site areas.
The city of Jacksonville does not use ground water as a source of
drinking water, but receives water from Little Rock.

The ground water in the region surrounding the site occurs in both
the overburden  and the underlaying bedrock.  The  overburden and
bedrock are generally  not  considered important  sources of ground
water supply near the site. Ground water supplies in the region are
obtained from the unconsolidated sands and gravels in the Tertiary
and younger  Quaternary sediments. Most ground water  is produced
from wells  completed  in sands within the Wilcox Group and basal
sands  and  gravels  within  the  Pleistocene  alluvium  and  terrace
deposits. Yields from these deposits can range up to 2,000 gallons
per minute.  Ground  water in the unconsolidated sediments is present
in the primary intergranular pore space. Some domestic ground water
supplies are obtained from  Atoka Formation.  Yields can range up to
10 gallons per minute. Ground water in the  bedrock is present in
the fractures and partings within the rock. A summary of the water-
yielding characteristics is presented in Table 5-2.

The hydrogeology  in the area of  the  site  is  influenced  by the
location of  Rocky  Branch  Creek,  the  french  drain,  the  central
ditch,  and  the hydraulic  characteristics of  the  overburden,
weathered rock, and bedrock.

5.4  SURFACE WATER

This ROD does not  address  the surface contamination issues.  Off-
site ROD, issued in September 1990,  addressed the  surface water
contamination problems and proposed a remedy.

There are two major drainageways  in the  area, Rocky Branch Creek
and Bayou Meto. Minor  drainageways  are intermittent streams that
flow into Rocky Branch  Creek and Bayou Meto in the spring or during
periods of heavy rainfall.

Rocky Branch originates near the northern boundary of Jacksonville
and flows generally south,  traversing the  Vertac  plant property
along the west side. About  two miles south of the plant it empties
into  Bayou   Meto.   Being   a  young  stream,  Rocky   Branch  is
characterized by low sinuosity,  low  levels of suspended sediments,
and a high bed-load potential. Channel deposits are predominantly
silt and clay.

                                18

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Bayou Meto begins  in  the Atoka Formation approximately  one  mile
northwest  of   Jacksonville.   About   130   miles  southeast   of
Jacksonville,  Bayou Meto empties into the Arkansas River.

5.5  REMEDIAL INVESTIGATION FINDINGS

Onsite Operable  Unit I  consists of  the following  above-ground
materials:

     •    Contents and residues that are in process vessels.

     •    Miscellaneous containerized (drummed or bagged) materials
          that are currently stored onsite, including spent carbon,
          french  drain  oily  leachate,  shredded  plant  trash,
          shredded pallets, excavated soil, and other containerized
          disposables (this does not include those drummed wastes
          currently being incinerated).

     •    Process buildings and structures.

     •    Process equipment (i.e., storage tanks, reactors, piping,
          pumps, etc.).

     •    Materials used to  construct,  add to, and  maintain the
          chemical processing units and buildings (i.e.,  asbestos
          siding and insulation, and PCBs in electrical equipment) .


Contents of Process Vessels

During the process vessel inventory in 1989,  a total of 270 vessels
were found.  Of the 270  vessels,  175 were empty  (based on readings
from a nonintrusive level detector). 95 process vessels that were
not empty were categorized  into vessels  containing F-listed wastes
(based on historical  information  and  labels on vessels)  (46) ,
vessels containing non-F-listed wastes  (31),  vessels  containing
unknown wastes  (6), and vessels  in  active  use (12).  The Resource
Conservation and Recovery  Act  (RCRA)  lists  hazardous wastes fron
non-specific   sources  (such  as  waste   halogenated   solvents,
herbicides manufacturing wastes,  etc.) as  F-wastes.  The process
vessel inventory  is presented in Appendix  A of  the Vertac Site
Remedial  Investigation  and Focused Feasibility Study  for Onsite
Operable Unit 1.

F-Listed Vessel Contents

This category  includes  2,4-D  product and waste, 2,4,5-T products
and waste,  discarded raw materials  like chlorophenols,  toluene,
etc. and spent alcohols. Out of the  46  vessels believed to contain
F-listed wastes,  17 were sampled for physical and incinerability
characteristics of the material contained within the  vessels.  The
physical nature of the material varied  greatly; vessels  contained

                                19

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solids,  tar,  sludges,   organic   liquids,  and  aqueous  liquids.
Thirteen   vessels  contained   more  than   one   phase.      The
incinerability characteristics also varied widely; including BTU
(measure of heating value), ash,  and  moisture  content.  Table 5-2
lists the  ranges  and  median values of  analytical  results.  Total
volume  of  F-listed  vessel  contents was estimated  at  104,700
gallons.

Non-F-Listed Vessel Contents

This  category  includes materials  such  as  tetrachlorobenzene,
caustic soda,  hydrochloric acid, dimethyl amine, kerosene/fuel oil,
etc. Of the 31 vessels believed to contain non-F-listed wastes, 9
vessels were  sampled.   These vessels  contained material that was
typically  single  phase.   With the  exception of one  sample,  the
analytical  data  generally did   not  indicate  the  presence  of
trichlorophenol  or  2,3,7,8-TCDD,  which  supports  the  initial
characterization of the contents of these vessels as non-F-listed
materials.   Some  of the material contained high values for BTU and
chlorides. Table 5-3 is a summary of the  analytical  results for the
non-F-listed vessels.  Total volume of non-F-listed vessel contents
was estimated at 69,400 gallons.

Unknown Vessel Contents

This  category includes  materials of unknown  origin.  Of the  6
vessels containing materials of unknown origin,  only 5 were sampled
(because the sixth vessel contained material similar to one of the
vessel  sampled).  Three   of   the  vessels   contained  weathered
hydrocarbon residues, probably derived  from petroleum,  based on
infrared  (IR)  scans performed  on these  samples.   The  physical
nature of the materials varied greatly,  including aqueous liquid,
organic liquid, tar, and soil.   2,3,7,8-TCDD was detected in four
of the seven samples analyzed.  With the possible exception of one
(2.4  ppb  2,3,7,8-TCDD),  the  vessel  contents display  chemical
compositions  that would support  listing the  contents with  the
non-F-listed category.   The BTU and chloride values are similar to
those of  the  other vessel  contents.  The analytical  results are
summarized in Table 5-4. Total volume of  unknown vessel contents
was estimated at 23,110 gallons.

Spent Carbon

Spent carbon (generated  from treatment of aqueous phase of leachate
collected  in  the  french drains)  drums  inventoried totalled 502.
The physical  nature of  the spent carbon was a  solid,  although a
high moisture content was present.  The analytical data showed that
the spent  carbon  contained organic  compounds,  including toluene,
di- and  tri- chlorophenols, naphthalene,  2,4-D,   and  2,4,5-T at
concentrations over 1,000 ppm.  The analytical data  showed that the
spent carbon  is relatively homogeneous, even between  the drummed
and bulk carbon.   The spent carbon has  a  high heating value, above

                               20

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                         TABLE 5-2
     F-USTED PROCESS VESSEL CONTENTS ANALYTICAL SUMMARY
CONCENTRATION
RANGE (a)
METALS mo/ka
Arsenic ND-130
Barium ND - 82.8
Calcium ND - 22200
Chromium ND - 38.5
Lead ND • 35.7
Magnesium ND-818
Potassium ND - 221
Sodium ND - 53400
PHYSICAL PARAMETERS
Ultimate Analysis (Wt %)
-Carbon 0.41 - 73.4
-Hydrogen 0.46 - 5.97
-Oxygen 20.5 - 97.2
•Nitrogen 0.03 - 0.62
-Sulfur ND - 0.13
Melting Point (F) 195-1865
Percent Ash (Wt %) ND - 79.4
Percent Moisture (Wt %) ND - 95
Heating Value (Btu/lb) ND - 1 6000
Total Chlorides (mg/kg) 1 700 -420000
-Inorganic Chlorides 200 - 52000
-Organic Chlorides ND - 420000
NOTES:
MEDIAN
VALUE (b)
mg/kg
19
0.44
17.2
11.6
7.1
13
47.5
1350
62.4
4.18
32.2
0.13
0.06
204
1.3
45
6100
49000
800
158000

(a) Only those metals with detected concentrations greater than
1 mg/kg are included in this summary table.
(b) The median value for each analyte is determined using
detected concentrations only.
VOLUME BREAKDOWN

  VESSELS CONTAINING F-USTED MATERIAL * 46

  TOTAL F-USTED PROCESS VESSEL CONTENTS = 104700 gal.
    -TOTAL UQUIDS = 25400 gal
    -TOTAL SOUDS = 30800 gal
    -TOTAL UQ/SOL = 48500 gal
                       21

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                            TABLE 5-3
     NON-F-LISTED PROCESS VESSEL CONTENTS ANALYTICAL SUMMARY
                           CONCENTRATION
                              RANGE (a)
                          MEDIAN
                         JfALUE (b)
VOC»
Chloroform
Toluene
Ethylbenzene
Xylenes

BNAa
2,4-dichlorophenol
1,2,4-trichlorobenzene
Naphthalene
2,4,6-trichlorophenol
Pentachlorophenol
2-methylnaphthalene
Phenanthrene
Anthracene
Pyrene
Tetrachlorobenzene

HERBICIDES
2,4-D
2,4,5-T

DIOXIN
2.3,7.8-TCDD

METALS
Arsenic
Barium
Calcium
Chromium
Magnesium
Pota»*ium
Sodium
PHYSICAL PARAMETERS
Ultimate analytic (Wt %)
  -Carbon
  -Hydrogen
  -Oxygen
  -Nitrogen
  -Sulfur
Melting point (F)
Percent aah (Wt %)
Percent mowture (Wt %)
Heating value (Btu/Ib)
Total 'chloride*  (mg/kg)
  -Inorganic chloride*
  •Organic chloride*
  mg/kg
  ND-41
 NO-590
 NO-40000
ND-110000

  mg/kg
 NO-1000
 NO-5600
 NO -360
 NO-5000
 NO-8700
 NO-1800
 NO-560
 NO-560
 NO-200
  NA(C)

  mg/kg
 ND-400
  NO ^7

   ng/g
 ND-OJ21

  mg/kg
 NO-31.4
  NO -1.3
 NO-75.1
 NO-233
 NO-78.4
 NO-439
NO-687000
 0.52 - 78.3
 18.0-97.0
 0.02-1.96
 NO -0.53
321 -685 (d)
 NO -14.9
  NO -95
 ND- 18300
NO -660000
300-80000
ND- 660000
mg/kg
 0.24
 0.93
  2
  4.7

mg/kg
  7.5
 5600
  130
 0.37
 8700
 1800
  560
  560
  200
610000

mg/kg
  17
 0.079

 ng/g
 0.21

mg/ka
  18.9
  1.3
 24.7
  9.9
  4.8
  138
 78.5
 5.36
  5.1
 892
 0.07
 0.04
 321
  0.3
  80
 4500
 1400
 300
 1100
NOTES:
   (a) With the exception of dioxin, only thoee chemical parameter* with
     detected concentration* greater than 1 ppm are •ummarized above.
   (b) Only detected concentration* we ueed when determining the median value.
   (c) Only one aampfewa* analyzed for tetrachlorobenzene.
   (d) Value* lea* than 32 F are not Included.	
VOLUME BREAKDOWN
  VESSELS CONTAINING NON-F-USTED MATERIAL - 31
  TOTAL NON-F-USTED PROCESS VESSEL CONTENTS - 69400 gal
     -TOTAL LIQUIDS - 53420 gal
     -TOTALSOUDS - 5790 gal
     •TOTAL UQ/SOL * 10190 gal
                              22

-------
                           TABLE 5-4
      UNKNOWN PROCESS VESSEL CONTENTS ANALYTICAL SUMMARY
                          CONCENTRATION
                              RANGE (a)
                          MEDIAN
                         VALUE (b)
VOC«
 riethylene chloride
Acetone
Chloroform
Tetrachloroethane

BNAa
 Jen2oic acid

PESTICIDES/PCBa
Oieldrin
4,4'-DDE
Endrin
4,4'-DOD
4.4'-DOT

HERBICIDES
2,4,5-T

DIOXIN
2,3.7.8-TCDD

METALS
Arsenic
Jarium
Calcium
Chromium
Magneeium
9otM«ium
Sodium

PHYSICAL PARAMETERS
Ultimate analytic (Wt %)
   -Carbon
   -Hydrogen
   -Oxygen
   -Nitrogen
   -Sulfur
Melting point (F)
Percent a»h (Wt %)
Percent moisture (Wt %)
Heating value (Btu/lb)
Total chloridee  (mg/kg)
   -Inorganic chloridee
   -Organic  chloridee
  mg/kg
  ND-1
  NO-74
  ND - 3.5
  ND-5.1

  mg/kg
 ND-3600

  mg/kg
  ND-1.5
  ND-1.5
  ND-4.1
  ND-7.7
  ND-12

  mg/kg
  ND - 9.1

   ng/g
  ND - 2.4

  mg/kg
  ND - 26.3
  ND - 28.7
 22.8-2560
  ND-261
  18-244
  ND -215
 29.6-9810
 1.43-81.3
 0.78-4.62
 15.1-97.5
 0.05 -0.39
  ND-0.83
192-1432 (c)
  NO-85.3
   4-96
 ND-14800
 ND- 470000
  ND-4600
 ND-424000
mg/kg
  1
0.014
0.031
  5.1

mg/kg
 3600

mg/kg
0.017
0.014
  4.1
0.011
 0.12

mg/kg
  9.1

 ng/g
 0.51

mg/kg
 2Z9
  13.2
  353
  2.5
  61.7
  161
  62.8
  58.3
  2.96
  37.7
  021
  025
  1400
  12.1
   7
 11200
  1400
  400
  1000
NOTBS:
   (a) With the exception of dloxin, only thoee chemical parameter* with
     detected concentration* greater than 1 ppm are summarized above.
   (b) Only detected concentration* are used when determining the median value.
   (c) Value* leas than 32 F are not included.	
 VOLUME BREAKDOWN

   VESSELS CONTAINING UNKNOWN MATERIALS - 5

   TOTAL UNKNOWN PROCESS VESSEL CONTENTS - 23110 gal
     -TOTAL LIQUIDS - 7870 gal
     -TOTAL SOUDS - 15240 gal
                               23

-------
7,500 BTU/lb.  The ash content varied between the bulk and drummed
carbon samples.   The  bulk carbon exhibited a higher ash content,
probably  because  solids removal  (filtration)  prior to  carbon
treatment did not take place until 1987, when spent  carbon began to
be stored in  drums.   Because  the spent carbon generated prior to
1987 did not  experience  prefiltration,  it is believed to contain
higher grit and  iron concentrations, thus  having a higher ash
content.  Approximately 59,000 gallons of  spent  carbon  (bulk and
drummed)  were inventoried.  Analytical results are summarized in
Table 5-5.

Containerized Materials/French Drain Oily Leachate

377 drums  (55 gallons drums)  were inventoried.  The  majority of
these  drums  contained  various  materials  resulting  from  the
installation  and  maintenance of  the  french drain  system  for
leachate collection and  Remedial Investigation wastes (discarded
tyvak suits,  etc.).    The sample  (and  duplicate  sample)  of the
french drain oily leachate showed high levels of toluene (above 10
wt%),    2,3,7,8-TCDD,    di-    and    tri-chlorophenols,    and
chlorophenoxyherbicides.  Table  5-6  is a  summary  of  analytical
results for oily leachate.

Process Buildings

Figure 5-3  shows  the  locations of the buildings (administrative,
manufacturing, warehouse, machine shop, etc.) .  These buildings were
sampled for surface contamination (wipe samples)  and contaminated
dust. With  the  exception of the Dalapon boiler, all  of  the wipe
samples from  the interior and exterior surfaces  of  the  process
buildings showed 2,3,7,8-TCDD; the exterior levels were generally
lower than the interior levels.  The T-Product Storage Building and
the Change  House showed 2,3,7,8-TCDD concentrations  an  order of
magnitude higher than  the other  onsite  buildings sampled.   Also,
the Regina  Paint Building is  anticipated to be contaminated by
2,3,7,8-TCDD because  of  the many empty 2,4,5-T waste  drums being
stored inside the building.  2,3,7,8-TCDD was also found in all the
dust samples that were taken inside the process buildings. Tables
5-7 and 5-8 present the summary of analytical results of wipe and
dust samples.

An  estimated  1,100   empty  drums  are  within the Regina  Paint
Building.  2,3,7,8-TCDD was found in the wipe sample collected from
a drum located near the door.

The volume  of debris  resulting  from demolition of buildings is
estimated at 13,680 cubic yards.

Process Equipment

Process equipment includes process vessels (tanks, reactors, etc.),
piping, pumps, etc. 2,3,7,8-TCDD  (from wipe samples) was generally

                                24

-------
        TABLE 5-5
SPENT CARBON ANALYTICAL SUMMARY
CONCENTRATION RANGE (a) MEDIAN VALUE (b)
VOCt
Methylene chloride
Acetone
1,1-dichloroethene
Chloroform
Benzene
Toluene
Chlorobenzene
Xylenee
BNAj
Phenol
2-chlorophenol
1,4-dichlorobenzene
Benzyl alcohol
2-methylphenol
4-methylphenol
Benzole acid
2,4-dichlorophenol
1 ,2,4-trichlorobenzene
Naphthalene
4-chloro-3-methylphenol
2,4,6-trichlorophenol
2,4,5-trichlorophenol
HERBICIDES
2,4-D
2,4,5-TP
2,4,5-T
DIOXIN
2,3.7.8-TCDD
METALS
Arsenic
Barium
Cadmium
Calcium
Chromium
Lead
Magnesium
Potassium
Sodium
PHYSICAL PARAMETERS
Ultimate analysis (Wt %)
•Carbon »
-Hydrogen
-Oxygen
-Nitrogen
-Sulfur
Percent ash (Wt %)
Percent moisture (Wt %)
Heating value (Btu/lb)
Total chlorides (mg/kg)
-Inorganic chlorides
-Organic chlorides
NOTES:
mg\kg
NO -1.3
NO - 2.3
0.66-1
7.7-14
1.7-2.8
4100-5100
1-1.7
0.79-1.2
mg\kg
270-280
930-960
16-17
80-88
51-60
51-60
NO-38
13000-150000
68-85
1900-2000
ND-20
1500-1600
4800-5500
mg\kg
13000-140000
610-640
1900-2300
ng/g
1.9-2.6
mgVkg
NO -23.9
3.8-92.5
NO -1.1
190-2140
4.5-61.1
NO -30.4
74.2-175
NO -537
126-1970


60.6-64.8
3.12-423
29.8-34.8
0.96-1.12
0.01-0.08
3.5-28.9
10-42
7600-11400
26000-70000
400-4000
23600-69600

(a) With the exception of dioxin, onty those chemical
mg\kg
1.3
2.3
1
14
2.8
5100
1.7
1.2
mg\kg
280
960
17
88
60
60
38
150000
85
2000
20
1600
5500
mg\kg
140000
640
2300
ng/g
2.6
mg/kg
23.9
52
1.1
436
7.9
30.4
119
333
162


64.3
4.06
30.5
1.01
0.04
4.7
31
7800
27000
600
26400

parameters with
detected concentrations greater than 1 ppm are summarized above.
(b) Only detected concentrations are used when determining the median value.












VOLUME BREAKDOWN (a* of 06 October 1989

TOTAL QUANTITY OF SPENT CARBON - 59010 g

-BULK STORAGE - 21360 gal
-DRUM STORAGE - 37650 gal







































                         25

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              TABLE 5-6
FRENCH DRAIN LEACHATE ANALYTICAL RESULTS

VOCs (a)
Chloroform
Trichloroethene
Benzene
Tetrachloroethene
Toluene
Chloroberuene
Etnylbenzene
Xylenes
BNAs
2,4-dichlorophenol
1 ,2,4-trichlorobeazene
2,4,6-trichlorophenol
2,4, 5-trichlorophenol
PESTICIDES/PCBt
HERBICIDES
2,4-D
2,4,5-TP
2,4,5-T
DIOXIN
2,3,7,8-TCDD
METALS (b)
Barium
Beryllium
Calcium
Chromium (c,d)
Magnesium
Potassium
Sodium
PHYSICAL PARAMETERS
Ultimate analysis (Wt %)
' -Cartxxi
-Hydrogen
-Oxygen
-Nitrogen
-Sulfur
Melting point (F)
Percent ash (Wt %)
Percent moisture (Wt %)
Heating value (Btu/lb)
Total chlorides (mg/kg)
-Inorganic chlorides
-Organic chlorides
HE-FD-DC1-OLD-01
mg/kg
8.8 J
3.6
33J
45
100000
84
190
310
mg/kg
22000
8100 U
8100 U
40000 U
ND
mg/kg
6400
1100
3300
ng/g
21
mg/kg
74.8 J
0.26 J
524 J
73.1 J
37.2 J
305 J
536J


56.2
4.03
39.5
0.13
0.18
MA
1.8
2-4 (e)
10500
280000
200
280000
HE-FD-DC1-OLD-02
mg/kg
5J
2.8 J
19J
27
110000
52
110
190
mg/kg
22000
7100 J
9500
40000 J
ND
mg/kg
7200
1400
4000
ng/g
1200
mg/kg
67.4 J
0.26 J
281 J
69.6 J
43.2 J
522J
521 J


56.5
3.98
39.2
0.15
0.21
NA
1.2
2-4 (e)
10800
290000
300
290000
               26

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27

-------
           TABLE 5-7
BUILDING WIPES ANALYTICAL SUMMARY
2,3,7,8-TCDD RANGE
PROCESS BUILDING
Dalapon boiler
Product storage
Contractors building
T-product storage
Acid
Boiler house
Change house
Formulations
Maintenance shop
Parts storage
Laboratory area
Wastewater treatment plant
Chemical storage
Regina paint (residue)
Regina paint (drum wipe)
Maintenance garage
NOTES:
(a) Only detected concentrations are
value (no detection limits).
(ng/sq m)
ND-2.1
1.4-56
1.1-32
23-2360
13.8-260
37
1.3-1870
3-31.5
3-62
4.1 -430
75
9.8
1.3-4
91 mg/kg
121000
28
MEDIAN
VALUE (a)
0.3
4.2
13.6
480
62
37
930
12.5
35
76
75
9.8
4
91 mg/kg
121000
28
used in determining the median


            28

-------
                          TABLE 5-8

               BUILDING DUST ANALYTICAL RESULTS
                                                  2,3,7,8-TCDD
     SAMPLE ID	 BUILDING	(ng/g)
HE-PB-009-VAC-01          Maintenance Shop                18

HE-PB-009-VAC-02         Maintenance Shop                18

HE-PB-010-VAC-01            Parts Storage                   61J (a)

HE-PB-011-VAC-01            Administration                   88

HE-PB-013-VAC-01             Supervisors                   12

HE-PB-014-VAC-01        Glass/Instrument Shop               29
NOTES:
      (a)  HE-PB-010-VAC-Q1 was spiked in the laboratory.  The recovery
         was less than the QC limit in the spiked samples.  Therefore
         the reported result for the unspiked sample was qualified
         as estimated.
      J «= Estimated value.
                              29

-------
not detected on the exterior  surface  of  the  process vessels,  and
the levels on the interior surfaces varied, exceeding 100 ng/m* on
one sample.  The  analytical data  from the  process vessel rinsate
samples  varied.    Three  of  six  of  the  samples  showed low  or
nondetectable   levels    of    toluene,    chlorinated    phenols,
chlorophenoxyherbicides, and 2,3,7,8-TCDD, while  the other  three
samples  showed  these compounds  one or  two  orders of  magnitude
higher.  2,4-D was the only compound reported in all the samples.
Tables 5-9 and 5-10 present the summary of wipe and rinsate samples
analytical results.

The volume of debris resulting from demolition of process equipment
is estimated at 10,080 cubic yards.

Asbestos Characterization

The asbestos characterization included the buildings, piping within
the buildings,  and the major outdoor pipe runs onsite.   Of the 12
buildings surveyed,  11  buildings  contained asbestos; the Dalapon
boiler building  did not.   Most  of  pipe and fitting  insulation
sampled  was found to  contain asbestos.   Siding  shingles,  roof
shingles  and  floor  tile  samples  also contained  asbestos.    The
outdoor asbestos characterization  focused on pipe runs and fittings
in the major process areas.  The general conclusion was that,  while
much of the outdoor  insulation  appeared to be fiberglass, asbestos
was present in the  pipe and  fitting insulation  throughout  the
central process area.

Containerized (bagged)  Soils

Contaminated soils removed from residential  yards  and  a drainage
ditch onsite are  bagged and stored onsite in a steel building.  The
analytical results for  the bagged soils  were within a  consistent
range  for  all  the  samples,  indicating a general  homogeneity.
Chlorinated    phenols,    chlorinated    benzenes,    and
chlorophenoxyherbicides  were   present at  nondetectable  to  low
levels.  2,3,7,8-TCDD was detected in all  samples at levels ranging
from 13 to 55 ppb.  The bagged  soils exhibited very low BTU values.
Table 5-11 presents the soil analytical summary.

The total volume was estimated at 2770 cubic  yards.

Shredded Trash and Pallets

After Vertac abandoned the site in 1987, EPA (under removal action)
collected  and  shredded  trash  and pallets  that  were  scattered
throughout the plant.  The shredded trash and pallets,  placed  in
plastic  bags, are stored on site under  a  tarpaulin cover.    The
analytical results for the shredded trash and pallet samples showed
variability over  several  orders of magnitude.  2,3,7,8-TCDD  was
reported in all samples at  levels ranging from 1.9 to  4100 ppb.
The pallet samples generally showed higher levels of 2,3,7,8-TCDD

                                30

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              TABLE 5-9
PROCESS EQUIPMENT WIPES ANALYTICAL RESULTS
SAMPLE 10 PROCESS VESSEL
INTERIOR
HE-PE-001-WPI-01
HE-PE-002-WPI-01 (a)
HE-PE-002-WPI-02 (a)
HE-PE-003-WPI-01 (a)
HE-PE-004-WPI-01 (a)
HE-PE-005-WPI-01 (a)
HE-PE-006-WPI-01 (a)
HE-PE-007-WPI-01 (a)
EXTERIOR
HE-PE-001-WPE-01
HE-PE-002-WPE-01
HE-PE-003-WPE-01
HE-PE-004-WPE-01
HE-PE-005-WPE-01
HE-PE-006-WPE-01 (b)
HE-PE-007-WPE-01
HE-PE-007-WPE-02
HE-PE-008-WPE-01 (b)
HE-PE-009-WPE-01
HE-PE-010-WPE-01

EPA-35
EPA-18
EPA-18
EPA-1
T-367
T-357
R-405
T-527

EPA-31
T-503
T-432
T-139
R-404
T-316
T-201
T-201
R-362
EPA-1 6
EPA-26
2,3,7,8-TCDD 2,3,7,8-TCDD
(ng) (ng/sq m)

5.5
0.54 U
1.4 U
1 J
1.3 U
29
2.8 J
19U

0.34 U
0.23 U
0.41 U
0.97 U
0.36 U
1.8 U
0.62 U
0.8 U
26J
0.84
0.6

22.0
2.2 U
5.6 U
4.0 J
5.2 U
116.0
11.2J
76.0 U

1.4 U
0.9 U
1.6 U
3.9 U
1.4 U
7.2 U
£5U
3.2 U
104.0J
3.4
2.4
                   31

-------
               TABLE 5-10




PROCESS VESSEL RINSATE ANALYTICAL SUMMARY


VOCs
Toluene
BNAs
2-chlorophenol
2,4-dichlorophenol
2,4,6-trichloropheno)
2,4,5-trichlorophenol
4-chlorophenol
2,6-dichlorophenol
2,3,6-trichlorophenol
HERBICIDES
2,4-D
2,4,5-TP
2,4,5-T
DIOXIN
2,3,7,8-TCDD
NOTES :
(a) Only detected
CONCENTRATION
RANGE
ug/L
ND-810
ug/L
ND-57
ND -5700
ND-1600
ND-2100
ND-280
ND-530
ND-43
ug/L
3.3 - 49000
ND-2800
ND - 4700
ng/L
ND-86
concentrations are used when determining the
MEDIAN
VALUE (a)
ug/L
1.8
ug/L
8
6
260
1300
13
80
43
ug/L
250
220
2.1
ng/L
0.51
median value.
                   32

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                           TABLE 5-11
              CONTAINERIZED SOIL ANALYTICAL SUMMARY
                          CONCENTRATION
                               RANGE
                         MEDIAN
                        VALUE (a)
CHLORINATED
BEf.-ZENES/PHENOLS
2,4-dichlorophenol
2,4,5-trichlorophenol
Tetrachlorobenzene

HERBICIDES
2,4-0
2,4,5-TP
2,4.5-T

DIOXIN
2,3,7,8-TCDD
PHYSICAL PARAMETERS
Percent a*h  (Wt %)
Percent moisture  (Wt %)
 mg/kg
NO • 0.39
ND • 0.41
 NO -5.6

 mg/kg
0.2S • 5.1
0.034-1.6
0.23 - 3.9

  ng/g
 13-55

 mg/kg
ND-14.4
 1.8-3.6
47.5-647
0.22-0.95
 ND-1.2
603-3490
7.5-25.1
3.5-152
 12-18.5
288-819
  2-6.1
 ND-573
ND-0.31
15.5-64.1
17.6-35.8
76.9 - 82.6
  10-17
mg/kg
 0.21
 0.18
 2.5

mg/kg
 0.46
 0.11
 0.54

 ng/g
 23

mg/kg
 5.8
 2.4
 55
 0.46
 0.77
 997
 8.3
 5.2
 14.3
 359
 4.4
 269
 021
 60.1
  21
 80.9
  14
NOTES:
   (a)  Only detected concentration* are uted when determining the median value.
VOLUME BREAKDOWN

   TOTAL aUANTTTY OF CONTAINERIZED SOIL - 2770 cubic yarde
                           33

-------
while  the  trash  samples  generally  showed  higher  levels  of
chlorophenoxyherbicides. Tables 5-12 and  5-13 present the shredded
trash and pallets analytical summary.

The total  volume of shredded  trash and pallets  is  estimated at
2,240 cubic yards.

Electrical Equipment

PCBs were detected in five of the eleven transformers sampled.  All
five of those transformers  are owned by  Arkansas Power and Light
Company (AP&L).   Of those five, PCBs were detected above 50 ppm in
four transformers, and  above 500 ppm in one transformer. Table 5-14
presents transformer oil analytical summary.

The volume of PCB oil is estimated at 1 cubic yard.

6_._   SUMMARY OF SITE RISKS

The National Oil and Hazardous Substances Contingency Plan (NCP),
promulgated on March 8, 1990,  states that EPA expects to:

1. Use treatment to address  the principal threats  posed by a site,
wherever practicable.

2. Use engineering controls, such as containment, for wastes that
pose  a  relatively  low long-term  threat or  where treatment  is
impracticable.

3.  Use  a  combination  of  methods,  as  appropriate,  to  achieve
protection of human health and the environment. In  appropriate site
situations, treatment  of principal  threats  posed by  a site,  with
priority placed on treating waste that is liquid, highly toxic or
mobile,   will be  combined  with  engineering controls   (such  as
containment)  and  institutional  controls  as  appropriate,   for
treatment residuals and untreated waste.

4.  Use  institutional  controls  such  as  water  use  and  deed
restrictions to supplement engineering controls as appropriate for
short-and  long-term management to  prevent  or limit  exposure  to
hazardous substances.

Principal threat wastes are those source materials considered to be
highly toxic or highly mobile that  generally cannot  be reliably
contained or would present  a  significant risk to human health or
the environment should exposure occur. They include liquids (such
as  liquid  waste contained  in drums  or  tanks)  and other  highly
mobile  materials  (such   as  surface   soil  containing   high
concentrations  of  contaminants  of concern that  are mobile  due to
wind entrainment, volatilization, or surface runoff)  or materials
having high concentrations of toxic  compounds   (such  as  buried
drummed non-liquid wastes or soils containing significant

                                34

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                           TABLE 5-12
               SHREDDED TRASH ANALYTICAL SUMMARY
                          CONCENTRATION
                               RANGE
                          MEDIAN
                         VALUE (a)
CHLORINATED
 ENZENES/PHENOLS
 -chlorophenol
 ,4-dichlorophenol
 ,4,6-tnchlorophenol
 ,4,5-trichlorophenol
4-chlorophenol
 ,6-dichlorophenol
 etrachlorobenzene

HERBICIDES
 !,4-D
 :.4.5-TP
 :,4,5-T

DIOXIN
 :,3,7.8-TCDD

METALS
Antimony
Arsenic
 larium
 leryllium
Cadmium
Calcium
Chromium
Copper
L«ad
Magneaium
Nickal
 'otaaaium
Sodium
Zinc

PHYSICAL PARAMETERS
 Percent aah (Wl %)
 Percent moiature (Wt %)
 Heating value (Btu/lb)
 Total chloridea (mg/kg)
   -Inorganic chloridea
   •Organic chloridea
  mg/kg
 NO - 5.8
NO-25000
NO-25000
NO -21000
  ND-11
 ND-150
60-100000

  mg/kg
 11-44000
  ND-75
 2.8-6500

   ng/g
 1.9-120

  mg/kg
 NO - 27.3
 NO - 0.64
 3.3-68.6
 NO-0.31
  NO-1.4
1030-37300
  3-31.5
  5.4-103
  1.6-58.1
 89.9-3350
  1.9-28.2
  NO-404
 369-4060
 21.1-418
  1.1-49.6
   3-61
 NO -10600
 NO -30000
 ND-12000
 NO-29800
mg/kg
 3.8
 170
  67
  49
  11
  14
 330

mg/kg
 6300
  18
  74

 ng/g
  5.1

mg/kg
  5.8
 0.41
  55
 0.19
 0.77
  997
  8.3
  12.1
  14.3
  359
  4.4
  113
  746
  32.5
   5.5
   37
  3200
  8800
   600
  7600
 NOTES:
   (a) Only detected concentration* are uaed when determining the median value.
 VOLUME  BREAKDOWN

    TOTAL QUANTITY OF SHREDDED TRASH - 1150 cubic y arda
                        35

-------
                           TABLE 5-13
               SHREDDED PALLETS ANALYTICAL SUMMARY
                          CONCENTRATION
                               RANGE
                         MEDIAN
                         VALUE (a)
CHLORINATED
BENZENES/PHENOLS
2-chlorophenol
2,4-dichloroph«nol
2,4,6-trichlorophenol
2,4.5-trichlorophenol
4-chlorophenol
2,6-dichlorophenol
2,3,6-trichloroph«nol
Tetrachlorobenzene
HERBICIDES
2,4-D
2,4,5-TP
2,4,5-T

DIOXIN
2,3,7,8-TCDD
PHYSICAL PARAMETERS
Percent a»h (Wt %)
Percent moieture (Wt %)
Heating value (Btu/lb)
Total chloridee (mg/kg)
  -Inorganic ehlorid**
  -Organic chloride*
  mg/kg
  ND-45
 NO-1000
 ND-290
  19-530
  ND-85
 NO-160
  NO-24
  12-170

  mg/kg
 NO-2200
  NO-65
 ND-560

   ng/g
 2.5-4100

  mg/kg
  NO • 5.3
 1.9-212
 105-1010
 0.53-1.7
 0.99 - 3.8
  ND - 5.8
 NO-296
  ND-1.9
 ND-0.89
 ND-0.67
23.7-2000
 6.6-20.1
  0.3-3
  15-50
4300-7700
ND-21000
 ND-700
ND-20300
mg/kg
 4.9
 210
 40
 75
 5.4
 27
 9.4
 27

mg/kg
 220
 29
 45

 ng/g
 27

mg/kg
 3.7
 52
 453
 0.8
 1.3
 1.3
 75.6
 12
 0.89
 0.67
 101
 9.9
  0.6
  36
 4800
 6800
  700
 6100
NOTES:
   (a) Only detected concentration* are ua«d when determining the median value.
VOLUME BREAKDOWN

   TOTAL QUANTITY OF SHREDDED PALLETS - 1090 cubic yarda
                        36

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           TABLE 5-14
TRANSFORMER OIL ANALYTICAL RESULTS
AROCLOR AROCLOR AROCLOR
TRANSFORMER 1016 1254 1260
OWNER (mg/kg) (mg/kg) (mg/kg)
HE-EE-001-OLD-01
HE-EE-001-OLD-02
HE-EE-002-OLD-01
HE-EE-003-OLD-01
HE-EE-004-OLD-01
HE-EE-005-OLD-01
HE-EE-006-OLD-01
HE-EE-007-OLD-01
HE-EE-008-OLD-01
HE-EE-009-OLD-01
HE-EE-010-OLD-01
HE-Eb-011-OLL»-01
AP&L
AP&L
AP&L
AP&L
AP&L
AP&L
AP&L
AP&L
Vertac
Vertac
Venae
Vertac
NOTES:
(a) Reanalyzed to obtain lower quantitation
120U
120 U
SOU
60 U
74
11 U
12 U
12 U
11 U(a)
11 U(a)
11 U(a)
11 U(a)
240 U
240 U
120 U
120 U
10
22U
24 U
24 U
22U(a)
22U(a)
22U(a)
22U(a)
limits. Refer to Section 2,2.2 for
560
570
360
210
48 U
22U
6
24 U
22U(a)
22U(a)
22U(a)
22U(a)
method.
              37

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concentrations of highly toxic materials). No "threshold level" of
toxicity/risk has been established to equate to "principal threat".
However, where toxicity and mobility of  source material combine to
pose  a potential  risk of  10"3  or  greater, generally  treatment
alternatives should be evaluated.

Low level threat wastes are those source materials that generally
can be contained and that would present  only a  low  risk in the
event  of release.  They  include source materials that exhibit low
toxicity (soil with concentrations not greatly above reference dose
levels or that present  an  excess cancer risk near the acceptable
risk  range),   low mobility  (such   as  surface   soil  containing
contaminants  that generally  are relatively immobile in  air  or
ground water)  in the  environment, or are near health based levels.

Some  of  Onsite  Operable  Unit  1 media, such  as liquids,  semi-
liquids/solids, and sludges contained in process vessels,  PCB oil
in transformers, oily leachate stored in drums,  spent carbon, and
shredded trash/pallets, fit into the category of principal threat
wastes and  since  treatment  is practicable,  they must be treated.
The contaminants of concern in this category of wastes are dioxins,
PCBs,  herbicides  (2,4-D  and  2,4,5-T),   chlorophenols,   and
tetrachlorobenzene.  The debris  resulting  from  the  demolition of
buildings,  process equipment, miscellaneous drummed wastes  (such as
used tyvak suits,  some RI wastes, etc.) are low level threat wastes
and therefore should be contained using engineering controls. The
primary  contaminant   of concern in  these  types of wastes  is
asbestos.

The baseline  risk assessment  is a  four-step process.  The first
step,  data collection  and evaluation, identifies  contaminants
present in the environmental media — soil,  ground water,  surface
water, air, fish,  etc.  — of  the site.  The  second step,  toxicity
assessment, uses the results  of  years of research and testing of
the effects of  chemicals  on the health of  people and animals  to
decide which of the contaminants found on site might pose a health
threat. The third  step, exposure assessment,  defines which pathways
(e.g., using the ground water  for drinking and showering or eating
the fish) might bring the  contaminants  into contact  with people.
The final step,  risk characterization, brings the  information from
the first three steps together to determine the potential severity
of health threats from the site.

The baseline risk assessment provides the basis  for  taking action
and indicates the  exposure pathways  that need to be  addressed by
the remedial  action.  It serves  as  the  baseline  indicating what
risks could exist if no action were taken at  the site. This section
of the ROD  reports the results of the risk assessment conducted for
this operable unit.

Because  this  operable  unit's  media are   contained  in  storage
vessels,  drums,  plastic bags,  etc.,  currently there is no exposure

                                38

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pathway for this operable unit's media to the public, and therefore
a  traditional baseline  risk  assessment  is not  feasible.    A
traditional baseline risk assessment will be performed for the site
as part of  Onsite Operable Unit 2,  which  includes surface soils and
ground water.  Human health and ecological risks associated with the
surface water,  off-site  soils, and other contaminated  off-site
media were  addressed in  the Vertac Off-site Record of Decision,
issued in September 1990.

Exposure to the public, however,  could  occur from  a  catastrophic
release. Therefore,  a  reasonable  maximum catastrophic  release
scenario was  developed to  assess  the potential risk from  such a
release and to assess the need  for remedial action.  Because the no
action alternative cannot ensure that the property could not be re-
zoned for residential or commercial purposes, uncontrolled human
contact with the Onsite Operable Unit I media  is possible. Based on
the 2,3,7,8-TCDD (dioxin)  concentrations found  in Onsite Operable
Unit 1 media,  human exposure to concentrations  in excess of those
considered  acceptable  (for example, the  acceptable  2,3,7,8-TCDD
concentration level  for soils in residential or recreational areas
is l ppb)  could occur.

To evaluate potential risk from the Site, a scenario was considered
whereby a catastrophic release of toxicants would occur from some
of the more heavily contaminated Onsite Operable Unit I media.  A
fire scenario was  selected  for  this  purpose based on the available
analytical  data for  Onsite Operable Unit I media.   The scenario
involves the burning of the trash and pallets  that are stored under
a black PVC tarp and within a  bermed area at the west  end of the
Formulations  Building.   Shredded  trash and  pallets contain high
concentrations of  2,3,7,8-TCDD,  herbicides, chlorophenols,  and
tetrachlorobenzene.   If  a  person   (receptor)  at the   fence  line
inhaled the smoke for  a  12-hour  period,  the calculated  excess
cancer risk from inhalation of 2,3,7,8-TCDD would be 1.9E-04 (1.9
excess  cases  in  10,000).  Similarly,  the risk  posed  by  2,4,6-
trichlorophenol during this 12-hour period would be equivalent to
5.4E-11  (5.4  excess  cases  per  100  billion people).    These risk
calculations  include only  the  inhalation  pathway;  risk resulting
from deposition of  contaminants on soils, in surface  waters,  or
entry  into the food chain were  not evaluated as part  of this
particular scenario.

It   DESCRIPTION OF ALTERNATIVES

7.1  ALTERNATIVES

The alternatives for Onsite Operable Unit I include:

     •    Alternative 1:  No action.
     •    Alternative 2: Onsite secure  storage  with  onsite lined
          consolidation/containment unit.
     •    Alternative 3: Off-site incineration  with  onsite lined

                                39

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          consolidation/containment unit.
     •    Alternative  4:  Onsite  incineration  with  onsite  lined
          consolidation/containment unit.
     •    Alternative   5:   Onsite  incineration   with  off-site
          disposal.

The majority of the alternatives present center around two remedial
components:  incineration and consolidation/containment.

ALTERNATIVE 1;  NO ACTION

The no action alternative for Onsite Operable Unit I media at the
Site provides a basis for comparing existing site conditions with
those  resulting  from  implementation   of   the  other  proposed
alternatives.   Under  the  no  action  alternative,  no  additional
measures would be used to remediate contaminant sources.  Access to
the site  would  be prohibited only by  the  existing site  fence.
Therefore, public access would  only be  passively restricted.   No
institutional controls, facility maintenance, or monitoring would
be implemented.

Implementing no  remedial activities for  the Onsite Operable Unit I
media at the Site allows the existing contaminant sources to remain
in  place.    The  potential  for exposure to  contaminants is  not
reduced in this alternative.

There are no capital  or operation  and maintenance costs associated
with this alternative.

ALTERNATIVE  2;    ONSITE  SECURE  STORAGE  WITH   ONSITE   LINED
CONSOLIDATION/CONTAINMENT UNIT

The onsite secure storage alternative would involve interim storage
that complies with standards for the more hazardous contents of
process vessels  and drums onsite.  This storage would be an interim
remedy that would be used until more cost-effective and efficient
remedial technologies become  available.  The major components of
this alternative include:

     •    Construction of  a storage building capable of containing
          the process  vessel contents and drummed  onsite  wastes
          (spent carbon,  french  drain  oily  leachate,   and  other
          containerized materials).    PCB transformer oils  and
          compacted  Regina Paint  Building  drums  would also  be
          stored in this building.

     •    Construction  of  a permanent  (long-term)  above-ground,
          lined consolidation/containment unit,  and packing of the
          asbestos-containing materials and the demolition debris
          into the unit.

     •    Abatement  (removal  and  disposal)  of  friable asbestos-

                                40

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          containing materials (ACM) , including pipe insulation and
          possibly building shingles/tiles.

     •    Emptying  the  contents  of  the process vessels   into
          compatible containers.

     •    Demolition  of  the  buildings  and  process  equipment
          (including  emptied  process  vessels)   in the  central
          process area and the Regina Paint Building to the ground
          surface, with the exception of the bagged soil storage
          building and the bermed and tarped area containing bagged
          trash  and  pallets.   These  latter  facilities  would
          continue  to function  as interim  storage units.   The
          demolition debris and process equipment would be put  into
          the  consolidation/containment unit.   The active water
          treatment plant would not be demolished.

     •    Periodic inspection of the container storage building and
          the consolidation/containment unit.

Figure 7-1 presents a possible location and the major components of
Alternative 2.

Container Storage Building

The container  storage building to  be constructed onsite would be
for  interim  secure  storage  of  process  vessel   contents,  spent
carbon,  french drain  oily  leachate,  PCB transformer oil,  and
miscellaneous drummed wastes.  To store these materials, a 400-ft
x 100-ft facility has been conceptually designed.  The conceptual
design features are shown in Figure 7-2.

After  the  container  storage building  is  operational,  waste-
containing  drums  being stored within the central  process  area,
including  contents  transferred to   compatible  containers  from
vessels, would be  transported  to the container storage building.
Empty drums within the Regina Paint Building would be crushed and
overpacked  in  85-gallon drums.   Once all of the  drums have been
removed from the central process area,  the process vessel contents
would be recontainerized and stored.   Because of the wide range of
materials within  the  vessels,  ranging  from  liquids (aqueous and
organic)  to  crystalline  solids  and  soils,  numerous  removal
techniques would be required to collect the vessel contents, such
as digging,  shoveling,  gravity draining,  heating/slurrying,  and
pumping.    Safe  removal  of  vessel  contents may be  extremely
difficult because  of  limited  access  and the mixed,  multiphase
material in some vessels.   Once a vessel is emptied, the contents
would  be  transferred  to  a new  container for  loading into  the
container storage building.   Care would be taken to make sure that
the contents are placed into compatible containers  (i.e., stainless
steel,   polypropylene,  or glass  lined)  because  many of  these
materials are highly corrosive.

                               41

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42

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                          ACO Channel • Slop*
                            Pre-Cast Trench
                           Dram Constructed
                          of Polyester Concrete
                              or Equal
        6'Curb(Typ.)
                                      Plan • Not to Scale
                 Smoke Detector
                ' Warning Light
                                       Roof Ventilators
                                                          Steel Sandwich Panel Roof
                        \ Gravity Operated Louver Sized
                         For Roof Ventilator - Typ.
G73-566
                                                                6* Curb
Side View
                    FIGURE 7-2 CONTAINER STORAGE BUILDING
                                 CONCEPTUAL DESIGN

-------
PCB transformer oils would also be collected in drums and stored in
the container storage building.   The transformers that do contain
PCB-contaminated  oils     would   be    de-energized,   drained,
decontaminated (if possible), and refilled if they are planned to
remain in use.   After  refilling, the  transformer could be put back
in service, if needed. The new contents would be checked after an
equalization period to confirm the PCB concentration is less than
50 ppm.

The capacity of the storage building is approximately 4,000 drums
(assuming 4 rows of 36 pallets per row, stacked 2-high, containing
4 drums each, per bay).   The building consists of 4 bays.

Onsite Consolidation/Containment Unit

An above-ground,  lined,  consolidation/containment unit  would be
constructed and filled to provide long-term isolation of building
materials, process equipment, and containerized soils, trash, and
pallets.    The  lined consolidation/containment  unit  would  be
constructed onsite to contain approximately 30,000 cubic yards of
site debris,  including any asbestos-containing material.  Two types
of consolidation/containment units (single lined and double lined
units) are proposed in Alternative 2.

Single Liner Unit

The first  design  scenario for the  consolidation/containment unit
would  be  a  clay-lined/clay-capped  unit  similar to the  vault
constructed  onsite  in  1985.   This unit  has been  conceptually
designed as follows (Figure 7-3) :

     •    The unit would be constructed entirely aboveground.

     •    To accommodate the 30,000 cubic yards of debris  to be
          generated,  the foot print  of the  unit  would need to be
          approximately 300  ft x 300 ft.  The foot print would rest
          upon a 5-foot clay base.

     •    The unit would  be approximately 30 feet high, sloping
          upward at a maximum rate of 3:1.

     •    A leachate collection  system would rest above the single
          clay liner  and collect into a  sump.   The sump would be
          drained or pumped to the onsite treatment plant.

     •    Upon closure, a  3-foot  thick clay  cap  would be placed
          over the unit.   Venting of the unit through  the clay cap
          would   be   necessary   to  release  gases   from  the
          biodegradation of  organic  material, particularly wood.
          Emissions through the vents may require treatment.  Top
          soil would be placed on the cap to promote vegetation and
          to keep the cap intact.

                                44

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                                                 Q
                                                 IU
                                                 o
                                                 Ul
                                                 tc
                                            •
45

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Double Liner Unit

The second design scenario for the consolidation/containment unit
would  be  a  double-liner  system  with  leachate  collection  and
detection  systems.    This unit  would  comply with  RCRA  design
standards.  The conceptual design  of this unit is  similar to the
unit described above, with the following exceptions (Figure 7-4):

     •    The leachate collection liner system would consist of two
          liners, a  leachate  collection system,    and  a leachate
          detection system.  The top liner would  be a compatible,
          flexible membrane liner at least 60 mils  thick (minimum
          requirement).     The  conceptual  alternative  for  the
          consolidation/containment unit uses an 80-mil thick liner
          to provide a stronger,  more puncture-resistant barrier.
          The  bottom  liner   would be  a  composite  made  of  a
          compatible,  flexible membrane liner (80  mil) on top of
          3 feet of clay.

     •    The leachate collection system would rest above the top
          liner and the  leachate detection system would rest above
          the bottom liner.

Once constructed, the lined consolidation/containment unit would be
able to accept the demolition debris.

Asbestos Abatement

Asbestos  abatement  (removal  and disposal)  would be  performed as
part of  the  demolition. Based  on the  current National Emission
Standards for Hazardous Air Pollutants (NESHAPs) asbestos criteria,
asbestos-containing materials  (ACM) found onsite were  present in
friable  and  nonfriable  forms.   Friable asbestos was  present in
insulation on some piping and fittings,  and as vessel and breaching
insulation in the boiler house.  Nonfriable asbestos was present in
roofing  and  siding  shingles  and in floor tiles.   Some asbestos-
bearing insulation is present inside buildings.  Additional onsite
characterization may be  required  during remediation to delineate
ACM, where uncertainty exists, unless it is determined that all of
the insulation will be handled as ACM.

Demolition

Buildings, process equipment,  and piping within the  central process
area would be demolished to ground surface (foundation level) , with
the exception of the building containing  the bagged soil and the
area containing bagged trash and pallets, and the water treatment
plant.     The  materials  would   be  wetted  during  demolition.
Demolition would occur using conventional construction equipment.
The Regina Paint Building  outside the  central process area would
also be demolished and consolidated. The estimated volumes  (after
volume reduction) of the debris are as  follows:

                                46

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                                             i
                                             o
                                             s

                                             I
                                             CD
                                             i
                                             Ul
                                             cc

                                             i
47

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     •    Buildings and structures - 5,600 cubic yards
     •    Piping - 1,200 cubic yards.
     •    Process vessels/reactors - 7,700 cubic yards.
     •    Miscellaneous debris - 8,100 cubic yards.

The estimated  total volume of  debris generated from demolition
activities for  this alternative would be approximately 22,800 cubic
yards.   After  demolition,  the debris  would go through  a  volume
reduction step  where materials would be further cut and crushed to
increase the bulk density and  minimize any long-term settlement in
the consolidation/containment  unit.  Debris would then be hauled to
the lined consolidation/containment unit for packing.  Soils could
be used to fill  void spaces within the consolidation/containment
unit and minimize settlement.

Pretreatment

Pretreatment of  the  building  and equipment  surfaces  may  be
beneficial in reducing the amount of contaminants packed into the
consolidation/containment  unit  and in reducing the  amount  of
contaminated dust that could  be generated  during demolition.   If
implemented,  pretreatment may  include a scraping, dusting, wiping,
and vacuuming steps for the buildings and/or a steam-cleaning step
for the process equipment.   A solvent rinse/wipe may also be used
on a  limited basis,  if  areas of  visible staining are  present.
Pretreatment  is  not  required  to meet  the  risk-based  target
concentration levels  for 2,3,7,8-TCDD  (for industrial scenario),
but  may  be  useful  in  reducing  potential  cosolvents,   where
structural conditions permit.  Decontamination may be performed to
remove dust and particulates from exposed  surfaces.

Steam cleaning  may be used  to  decontaminate equipment with visible
organic staining. Steam cleaning would be  performed to remove dust
and soluble organic compounds from visible surfaces. Those pieces
of equipment exhibiting visible staining  may be solvent-wiped if
steam cleaning were unsuccessful in removing the staining.

Bagged Soils, Trash/ and Pallets

The final component of Alternative 2 would  be the continued storage
of the bagged soils and the bagged trash and pallets.   The bagged
soil  storage building was constructed in 1988 and  is in good
condition.  Because onsite  interim storage is the emphasis of this
alternative,  the bagged soils would remain  in their current storage
locations.   The same rationale would  hold true for  the bags of
trash and pallets that have been placed in a concrete bermed area
and covered with a PVC tarp.

The total  capital costs and  operation and maintenance  costs for
this and alternatives 3, 4, and 5 are summarized in Table 7-1.
                                48

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-------
EVALUATION OF ALTERNATIVE  3;   Off-site INCINERATION WITH  ONSITE
LINED CONSOLIDATION/CONTAINMENT UNIT

This alternative would involve the transport of those wastes that
could be considered a principal threat to  an off-site incinerator
permitted to treat  dioxin-contaminated materials.  Those materials
(low level  threat  wastes)  that could be  consolidated would  be
packed in a lined consolidation/containment unit on site.  The main
components of this  alternative include:

     •    Emptying  of process vessels, bulk storage containers, PCB
          transformers,   and re-containerizing  the  contents  in
          containers  suitable  for  transport  to   an  off-site
          facility.

     •    Compaction of the metal drums located inside  the  Regina
          Paint Building  and placement into 85-gallon  overpack
          containers.

     •    Loading of the above materials,  as well as the drummed
          materials (spent carbon,  french drain oily leachate, and
          other containerized materials),  for transport  on semi-
          trailers  to  an  off-site  hazardous waste  incineration
          facility.

     •    Construction of  a permanent  (long-term),  above-ground,
          lined consolidation/containment  unit  onsite and packing
          of  the  asbestos-containing  materials,  and  demolition
          debris,  into the unit.

     •    Asbestos    abatement   of   friable  asbestos-containing
          materials,   including  pipe  insulation   and  possibly
          building  shingles/tiles.

     •    Demolition of  the Central Process Area to  the  ground
          surface,  with the exception of the active water treatment
          plant.    The  Regina  Paint  Building  would  also  be
          demolished.

     •    Periodic   inspection  of  the  consolidation/containment
          unit.

     •    Shredded  trash and pallets and  containerized soils are
          evaluated    as    part    of    both    the    onsite
          consolidation/containment and the off-site incineration
          technologies.

               Option A:    The  shredded  trash and pallets  and
               containerized  soils  would  be   packed   into  the
               consolidation/containment  unit  along   with  the
               demolition  debris,  and any  asbestos-containing
               materials.

                                50

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          -    Option  B:    The  shredded trash  and pallets  and
               containerized  soils would  be  loaded onto  semi-
               trailers for transport  to  an  off-site  hazardous
               waste incineration facility.

          -    Option C:  The shredded trash and pallets would be
               packed into the consolidation/containment unit and
               the containerized soils would be loaded onto semi-
               trailers for transport  to  an  off-site  hazardous
               waste incineration facility.

Figure 7-5 illustrates a possible layout of the onsite components
within Alternative 3.

Materials to  be  transported to an off-site  incinerator  would be
carefully containerized and loaded onto semi-trailers for transport
to the incineration facility.  Transportation distances are unknown
at this time.  The onsite media  that  are candidates for off-site
incineration include:

     •    Vessel contents (approximately 900 tons, assuming 1,800
          Ibs/cubic yard).
     •    Spent  carbon  (approximately  140  tons,  assuming  900
          Ibs/cubic yard).
     •    French  drain oily  leachate  (approximately  15  tons,
          assuming 2,000 Ibs/cubic yard).
     •    PCB transformer oils  (approximately 1 ton,  assuming 2,000
          Ibs/cubic yard).
     •    Drummed materials  (approximately 165 tons,  assuming 1,500
          Ibs/cubic yard).
     •    Trash  (approximately 520 tons, assuming  900  Ibs/cubic
          yard).
     •    Pallets (approximately 660 tons, assuming 1,200 Ibs/cubic
          yard).
     •    Containerized soils (approximately 2,100 tons,  assuming
          1,500 Ibs/cubic yard).

A maximum  of approximately  4,500  tons of  contaminated  material
would  be  transported  off-site   for  treatment.     Assuming  a
semitrailer can haul 15 tons per load, it would require 300 trips
to transport the  above  materials to an off-site treatment facility
(Option B) .   If the trash, pallets, and soils are to  be packed into
the  lined  consolidation/containment  unit,  only 1,220  tons  of
contaminated material would be transported off-site for treatment
(Option A) .   This would  require only  80  trips to  the  off-site
treatment facility.   If the trash and pallets are to  be packed into
the  lined  consolidation/containment  unit,  only 3,300  tons  of
contaminated material would be transported off-site for treatment
(Option C) .   This would require 220 trips to the off-site treatment
facility.

PCB transformer oils would also be collected in drums.   The

                               51

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52

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transformers  that contain  PCB-contaminated  oils would  be  de-
energized, drained, and decontaminated.

The 1,100 empty metal drums currently  being  stored in the Regina
Paint Building would  be  compacted and placed in 85-gallon overpack
drums.  Compaction would be performed under wet conditions using a
drum crusher.  It is  assumed that 10 crushed 55-gallon metal drums
could fit into one 85-gallon overpack  drum.   This activity would
generate  approximately   110  drums  to  be shipped for  off-site
treatment.

After wastes to be incinerated off-site have been removed, onsite
remedial actions would begin.   Before demolition/consolidation of
buildings and equipment  in the central process area, as well as the
Regina    Paint    Building    to    the    north,    the    lined
consolidation/containment unit  would  be constructed  onsite  to
contain approximately 30,000 cubic yards of site debris, including
any  asbestos-containing material  and the  containerized  soils
onsite.  Two consolidation/containment  unit scenarios are proposed
for Alternative  3.   The first  scenario  would be  a  single clay-
lined/clay  capped  unit  with leachate  collection  similar  to  the
vault    constructed    earlier    onsite.        The    second
consolidation/containment unit scenario being considered would be
a  double-liner  system  with  leachate collection and  detection
systems.  This unit  would closely resemble  a RCRA-type facility.
Both of  these scenarios have  been  conceptually  described under
Alternative 2.

Once  the   consolidation/containment   unit   is   constructed  and
operational,   all   asbestos   abatement,   demolition,   packing,
pretreatment,  and  monitoring/inspection activities would begin.
These activities  have been described in detail under Alternative 2.

EVALUATION OF ALTERNATIVE 4; ONSITE INCINERATION WITH ONSITE LINED
CONSOLIDATION/CONTAINMENT UNIT

This alternative would involve onsite incineration of some of the
more hazardous materials (principal  threats)  and consolidation of
the   other   materials   (low    level   threats)    in   an   onsite
consolidation/containment  unit.    This  alternative  resembles
Alternative  3  except that  the incineration  would be  performed
onsite instead of off-site.  This alternative  would comply with the
CERCLA requirements for the treatment of principal threats (process
vessel contents,  spent  carbon, french drain oily leachate,  PCB
oils,  and shredded trash/pallets).  The major components  of this
alternative are:

     •    Onsite incineration of the process vessel contents, spent
          carbon, french drain oily leachate,  PCB transformer oils,
          shredded trash/pallets,  Regina Paint  Building  drums
          (empty), and other containerized materials.
                               53

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Asbestos  abatement  for   friable   asbestos-containing
materials. These materials would include pipe insulation
and possibly building shingles/tiles.

Demolition of the  buildings and equipment in the central
process area and the Regina Paint Building to the ground
surface.  This  includes buildings,  piping,  debris,  and
process equipment, except for the water treatment plant.

Construction of  a permanent (long-term) aboveground lined
consolidation/containment  unit,  and  packing  of  the
demolition debris, and asbestos-containing materials into
the unit.

Delisting of  the  incinerator residues and  packing  the
solids (salts) and ash into  the consolidation/containment
unit.

Periodic  inspection  of  the  consolidation/containment
unit.

Shredded trash  and pallets and  containerized soils  are
evaluated    as   part    of    both     the    onsite
consolidation/containment and incineration technologies.

     Option A:   The  shredded  trash and pallets   and
     containerized  soils  would  be  packed  into  the
     consolidation/containment  unit  along  with  the
     demolition    debris    and    asbestos-containing
     materials.

     Option  B:    The  shredded  trash  and  pallets  and
     containerized soils  would be incinerated  onsite
     along with the other incinerable media.

     Option C:  The shredded trash and pallets would be
     packed into the consolidation/  containment unit and
     the  containerized  soils  would   be  incinerated
     onsite.

     Option D:  The shredded trash and pallets would be
     incinerated onsite and the containerized soils would
     be packed  into the consolidation/containment unit.

     Option E:  The shredded trash and pallets would be
     incinerated onsite and the containerized soils would
     be removed from this operable unit.

     Option F:  The shredded trash and pallets would be
     consolidated  onsite   and the  containerized  soils
     would be removed from this operable unit.
                      54

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Figure 7-6 illustrates a possible layout of the components within
Alternative 4.

In Alternative 4A, materials including the process vessel contents,
spent carbon,  french drain oily leachate, PCB transformer oils, and
Regina Paint Building drums would be thermally treated in an onsite
incinerator.   In Alternative 4B,  shredded  trash  and pallets and
containerized  soils  would  also  be  incinerated  onsite.    In
Alternative 4C, the media in Alternative  4A  plus the containerized
soils would be incinerated onsite.  Materials would be removed from
the  vessels  and brought  to  the  incinerator staging  area  in
temporary   storage   containers   (drums   or   other  compatible
containers).   Materials  that are  already containerized  (spent
carbon, french drain oily leachate,  shredded  trash,  and shredded
pallets) would also be  brought to the staging area.   The Regina
Paint Building drums  would be  shredded  or  compacted  using a drum
compactor and brought to the incinerator staging area.

Buildings  and equipment  in  the  Central Process  Area would  be
demolished. The bags of shredded trash and shredded pallets would
be removed from their current location in preparation for packing
into the consolidation/containment unit  (Option A) or incineration
(Option   B) .   Asbestos   abatement   and   construction  of   the
consolidation/containment unit would occur during demolition.  The
bags of contaminated  soil will be removed  from their location in
preparation for packing in the consolidation/containment unit.

The construction of  the consolidation/containment unit would be the
same as described in the above alternative.   The design of the unit
(single-   or   double-lined)    would  determine   the  need   for
pretreatment.  If a  single, clay-lined unit is chosen,  pretreatment
of the materials (buildings,  process vessels,  piping, and debris)
prior to consolidation would proceed as described previously.  The
containerized soils would be consolidated with the other materials
without any pretreatment.

EVALUATION OF  ALTERNATIVE 5:  ONSITE INCINERATION WITH  OFF-SITE
DISPOSAL

This  alternative would  involve  incineration of  all  materials
characterized during  Onsite  Operable Unit  I and disposal  of the
delisted  incineration residues in  an off-site  landfill.    This
alternative offers  a  permanent remedial  solution  for each media,
although  implementation  and  cost   of  this   solution   may  be
prohibitive.   The major components of this  alternative are:

     •    Asbestos   abatement   of   friable  asbestos-containing
          materials.  These materials would include pipe insulation
          and possibly building shingle/tiles.

     •    Demolition of  the buildings and equipment in the central
          process area and the Regina Paint  Building to the ground

                               55

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          surface.  This  includes  buildings,  piping,  debris, and
          process equipment, except the water treatment plant.

     •    Onsite incineration of Onsite Operable Unit I materials.
          This includes process vessel contents, french drain oily
          leachate, spent carbon,  PCB transformer oils,  shredded
          trash,  shredded pallets, Regina Paint  Building drums,
          non-asbestos-containing  building   materials,   process
          equipment, process  piping,   containerized  soils,  other
          containerized materials,  and debris.

     •    Delisting of incinerator residues and disposal of these
          residues in an off-site landfill.

Figure 7-7 illustrates a possible layout of the components within
Alternative 5.

The building  and equipment central process  area and  the Regina
Paint Building would be demolished as described  previously.   The
shredded trash,  shredded  pallets,  and containerized  soils would
also  be  removed  from  their  current   storage  locations  to
incineration. Asbestos-bearing materials would be removed prior to
demolition for off-site disposal.

Materials will  be brought  to the incinerator staging area for
mixing and/or size  reduction.   Process vessel contents would be
removed from the vessels as described previously and brought to the
incinerator staging area in  temporary  storage containers (drums or
other  compatible  containers).    Materials   that   are  already
containerized (spent carbon,  french  drain oily  leachate,  trash,
pallets, and  containerized  soils)  would  also be brought  to the
staging area.   The Regina Paint Building  drums may  be compacted
using a drum compactor near the Regina  Paint Building or brought to
the staging area (for compaction or  shredding) .  The incinerator ash
and any other residue  would be delisted and  sent to  an off-site
landfill.    Once delisting is  complete, the  incinerator residues
would be able to be disposed at an off-site sanitary landfill.

7.2  ARARS

The Super fund Amendments and Reauthorization Act (SARA) of 1986 and
the  National Contingency  Plan  (NCP),  revised   March  8,  1990,
provides that the development  and  evaluation  of  remedial  actions
under the Comprehensive Environmental  Response, Compensation, and
Liability  Act  of 1980  (CERCLA  or   Superfund)   must  include  a
comparison of alternative  site responses to applicable or relevant
and appropriate Federal and state environmental and public health
requirements (ARARs).

Identification of ARARs must be done on a site-specific basis.  The
NCP  and  SARA  do not provide  across-the-board standards  for
determining whether a particular remedial action will produce an

                                57

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adequate  remedy  at a  particular  site.    Rather,  the  process
recognizes that  each site will have unique  characteristics that
must be  evaluated and compared to those  applicable  and relevant
requirements  that  apply  under  the  given  circumstances.    In
accordance with the  requirements  of the NCP,  the remedial action
selected  must meet all  ARARs  unless a waiver  from  specific
requirements can be granted.

For remedial actions performed under SARA, permits for compliance
with the Resource  Conservation  and Recovery  Act (RCRA),  National
Pollutant Discharge Elimination System (NPDES),  and Clean Air Act
(CAA) regulations  for  onsite remedial actions  are not  required.
However, CERCLA and SARA do require that the selected alternative
meet relevant and appropriate regulatory standards or performance
levels  where possible,  even though  a permit  is not  required.
Relevant and appropriate regulatory standards address problems or
situations sufficiently similar to those encountered at a CERCLA-
regulated  site.    Therefore,  their  use  is well-suited to  the
particular site of concern.  ARARs are defined as follows:

     •    Applicable  requirements are  those cleanup  standards,
          standards of control, and other substantive environmental
          protection  requirements,   criteria,   or   limitations
          promulgated   under   federal    environmental,    state
          environmental, or facility siting law, that specifically
          address a  hazardous  substance,  pollutant,  contaminant,
          remedial action,  location, or other  circumstance found at
          a CERCLA site.

     •    Relevant and appropriate requirements are those cleanup
          standards, standards of control, and  other substantive
          environmental  protection  requirements,   criteria,   or
          limitations promulgated  under federal  or state law that,
          while  not  "applicable"  to  a hazardous  substance,
          pollutant, contaminant, remedial action,  location,  or
          other circumstance at a  CERCLA site, address problems or
          situations sufficiently similar  to those encountered at
          a CERCLA site.

ARARs may be divided into the following categories:

     •    Chemical-specific requirements are health- or risk-based
          concentration limits or ranges in various environmental
          media for specific hazardous substances,  pollutants, or
          contaminants.   These limits may  take the form of action
          levels or discharge levels.

     •    Location-specific  requirements  are   restrictions   on
          activities that  are  based  on the characteristics of  a
          site or its immediate environment.   An example would be
          restrictions on wetlands development.
                               59

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     •    Action-specific requirements are controls or restrictions
          on particular types of activities in related areas such
          as hazardous waste management or waste water treatment.
          An example would be RCRA incineration standards.

The chemical-specific, location-specific, and action-specific ARARs
for Onsite Operable Unit I media at the site are listed in Table
7-2, and described  in more detail in the remainder of this section.


FEDERAL ARARs

Resource Conservation and Recovery Act fRCRAl

RCRA requirements may be applicable to the Vertac site because some
of  the  contaminated  materials  found  at  the Vertac  site  are
considered RCRA-listed wastes.  Regulations promulgated under RCRA
generally provide the basis  for  identification and  management of
hazardous waste  and establish technology-based  requirements for
active  or  proposed hazardous  waste facilities.   RCRA  facility
design standards may also be consulted if appropriate for wastes
other   than  RCRA   wastes  containing  significant   hazardous
constituents.

Chemical-Specific Requirements

Because of the range of chemicals detected at the site,  including
solvents, herbicides,  and 2,3,7,8-TCDD, numerous chemical-specific
requirements exist. According to 40 CFR § 261.31  (hazardous wastes
from non-specific sources), some  of  the wastes,  specifically the
contents of the F-listed  process  vessels,  would  be given the
hazardous waste numbers of F02X (F020,  F022, F023, F026, or F027).
These waste numbers are described and defined in 40  CFR § 261.31.

2,3,7,8-TCDD is produced as a byproduct during the manufacture of
herbicides. These potentially dioxin-containing F-listed wastes are
labeled  "acutely hazardous  wastes"  (40CFR  § §  261.30  (d)  and
261.31).

Some of the other materials characterized during this operable unit
investigation may also be characterized as listed or characteristic
RCRA wastes.  These wastes would be defined as follows:

     •    Materials that are F-listed, such as spent alcohols and
          solvents,  but  are  not   defined  by   the   F-listed
          classifications previously described.   These materials
          would be listed as F001-F005 wastes.

     •    Materials,  such  as  the contents  of the  non F-listed
          tanks, may be listed, as defined in 40 CFR § 261.33, as
          discarded commercial chemical products, of f-specif ication
          species,  container residues,  and spill  residue thereof.

                                60

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                              Table 7-2

       Potential Operable Unit I ARARs for the Vertac Site

CHEMICAL-SPECIFIC

          Resource Conservation and Recovery Act  (RCRA)
          Toxic Substances Control Act (TSCA)
          Safe Drinking Water Act (SDWA)
          Clean Water Act (CWA)
          Clean Air Act (CAA)
          Arkansas Water and Air Pollution Control Act
          Noncriteria Air Pollution Control Strategy

LOCATION-SPECIFIC

          Resource Conservation and Recovery Act  (RCRA)
          Arkansas Hazardous Waste Management Code
          Arkansas Solid Waste Management Code


ACTION-SPECIFIC

          Resource Conservation and Recovery Act  (RCRA)
          Toxic Substances Control Act (TSCA)
          Safe Drinking Water Act (SDWA)
          Clean Water Act (CWA)
          Clean Air Act (CAA)
          Arkansas Hazardous Waste Management Code
     -    Arkansas Solid Waste Management Code
          Arkansas Water and Air Pollution Control Act

TO-BE-CONSIDERED (TBC)

          City of Jacksonville Ordinances 604, 620, 684, and 877
                              61

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     •    Materials considered RCRA characteristic wastes.   RCRA
          characteristic wastes are defined in 40 CFR § 261 Subpart
          C   as   wastes   displaying  the   characteristics   of
          ignitability, corrosivity,  reactivity, or toxicity.

     •    Residues from the treatment of a  listed RCRA hazardous
          waste are themselves considered a  RCRA  hazardous waste
          unless   delisted.      Residues  resulting   from   the
          incineration of the F02X materials would  be considered F-
          028 wastes (40 CFR § 261.31).

The residues  of materials  in  containers  would  be  subject  to the
above criteria unless the container is empty (40 CFR § 261.7).

It is important to note that the definitions of the F023 and F026
listings  apply  to  the  wastes  only.     Therefore,   a  strict
interpretation  of these  definitions  indicates  the  vessel,  or
container, would not be a listed waste.

There are  other materials that  contain  small  concentrations of
dioxin that would  not be specifically listed as wastes under RCRA.
Furthermore,  some  materials investigated may not be  considered
hazardous, but due to the nature and public awareness of the site,
it  is unlikely  that  an off-site  facility  would accept  these
materials.

Although  some of   the  materials  onsite  may  be defined as  RCRA
hazardous  wastes,   the  regulations  pertaining to  the  dioxin-
containing F-listed wastes are more  stringent than for the other
wastes.  For example, 99.9999 percent  (six 9s) destruction removal
efficiency  (ORE)  is required for incineration of these dioxin-
containing  wastes,  while  only  99.99  percent  (four  9s)  DRE is
required for  most  other wastes.   Regulatory  requirements for the
land disposal of these materials are also more stringent than for
other wastes.

Location-Specific Requirements

Location-specific ARARs within RCRA may be applicable to the siting
of any onsite treatment or storage alternative.  RCRA states that
any  facility within  a  100-year  flood plain must be designed,
constructed, operated,  and maintained to prevent washout.  Washout
is described  as "the movement of  hazardous  waste from the active
portion  of the facility as a  result of flooding".    RCRA also
requires that the  treatment,  storage,  or disposal of a hazardous
waste must not be  conducted within 200 feet of a fault that has had
displacement within the Holocene time (40 CFR § 264.18).

Action-Specific Requirements

Because of the potential hazards associated with dioxins, action-
specific  ARARs  related to the  remediation  of  dioxin  wastes are

                                62

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especially stringent.  Action-specific ARARs are usually technology
or activity-based requirements or limitations on actions taken with
respect to hazardous wastes.  These requirements may be triggered
by the particular remedial  action  that is selected to accomplish
the  selected  alternative.    Because  there  is  more  than  one
alternative action for the Vertac site, many different requirements
may be applicable.

Corrective Action Provisions

The revised corrective  action-related regulations under subtitle C
of RCRA  (40  CFR § 260)  became  effective on April  19,  1993.  The
revised regulations  introduces  the concept  of corrective action
management units (CAMUs)  and temporary units for remediation wastes
to provide facilities with wider range of remediation alternatives,
while assuring reliable, protective, and cost-effective remedies.
The Vertac Superfund Site  is widely  contaminated and has  been
designated as and Area  of Contamination (AOC),  the equivalent of a
CAMU.        As    such,    contaminated   debris     amenable    to
consolidation/containment within  the  AOC  may be  pretreated  and
consolidated  without   incurring   placement   or   triggering  the
applicability of Land Disposal Restrictions.

Incineration

Incineration of a RCRA  hazardous waste is regulated under 40 CFR §
264 Subpart o.  These regulations call for an analysis of the waste
feed  (40  CFR § 264.341), and for  the disposal of  all  hazardous
wastes and residues, including  ash,  scrubber water,  and scrubber
sludge (40 CFR § 264.351).    In addition, the regulations set the
following  performance  standards  for  incineration  (40  CFR  §
264.343); including:

     •    For  dioxin   containing   wastes   (F-02X),  achieve   a
          destruction  and  removal efficiency  (ORE)  of  99.9999
          percent (six  9s)  for  each  principal organic  hazardous
          constituent (POHC) designated under 40  CFR § 264.342 in
          the permit.   DRE  for  dioxins is demonstrated  during a
          trial burn using a POHC more difficult to incinerate than
          dioxin.

     •    Reduce hydrogen chloride emissions  to  1.8  kg/hr or 1
          percent of the HC1 in the stack gas before entering any
          pollution control  device.

     •    Not release particulate matter in excess of 180 mg/dscm,
          corrected for the  amount of oxygen in the stack gas.

The  ability  to  meet  these  performance   standards   must   be
demonstrated  during the trial burn period.
                                63

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Furthermore, monitoring of various parameters during operation of
the incinerator is required  (40 CFR §  264.347).   These operating
parameters include:

     •    Combustion temperature.
     •    Waste feed rate.
     •    An indicator of combustion gas velocity.
     •    Carbon monoxide emissions.

Finally, fugitive  emissions  must  be controlled (40 CFR § 264.345)
either by:

     •    Keeping the combustion zone totally sealed.
     •    Or maintaining  a combustion  zone  pressure  lower  than
          atmospheric pressure.

Land Disposal Restrictions

There are presently  no regulations that specifically  govern the
destruction  efficiency  for  non-thermal  treatment  of  dioxin-
containing wastes.   A land  disposal  restriction  (land  ban)  was
enacted under RCRA effective on November 7,  1986 (40 CFR § 268.31) .
The land ban stipulates that no untreated dioxin-containing wastes
(as defined  in  40 CFR §  261.31) may be  land disposed.  Treatment
standards for hazardous debris,  effective on November 16, 1992 (40
CFR § 268.45), requires that hazardous debris  must be treated prior
to land disposal unless EPA determines under 40  CFR § 261.3(e)(2)
that the debris is no longer contaminated with hazardous waste or
the debris is treated to waste specific  treatment standard provided
in this  subpart  for  the  waste contaminating the debris.   Land
disposal restrictions are not applicable to  onsite debris, e.g.,
equipment, buildings, or other materials, consolidated within the
"area of  contamination"  (AOC) .    An AOC is defined  as  the areal
extent  of  contiguous contamination.    RCRA requires  that  the
treatment of wastes that  are subject to  the  ban  on land disposal
attain  levels   achievable by   the  best  demonstrated  available
technology  (BDAT).   A treated material is required  to have less
than 1 ppb TCDD,  as  measured by the  Toxicity Characteristic  (TC)
test, prior to disposal in a RCRA-permitted landfill.

The  land  disposal restrictions apply  to the storage  of certain
hazardous wastes  onsite.   These restrictions prohibit the onsite
storage  of  "banned"  wastes  for  longer  than 1  year  unless the
owner/operator can prove  that the extended storage is solely for
the purpose of accumulating enough waste for proper treatment.

Delisting

If the material  (i.e., residues from incineration)  can be delisted,
it would no longer be considered a RCRA hazardous waste, the land
ban  would not  apply,  and the  material could be placed  in any
permitted  solid  waste  landfill.   Metals  content  within  the

                                64

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incinerator ash  roust also be considered before  the  ash could be
placed into a solid waste landfill.  Metals content within the ash
would be measured by the TC test to determine if the ash would be
considered a RCRA  characteristic waste.   After delisting,  if the
ash leachate concentrations are less than TC standards, treatment
residues would be disposed in a solid waste landfill.

Hazardous Waste Landfills

Minimum technology requirements (MTR)  are not applicable within an
AOC, but may be relevant.  Therefore, technical requirements for a
consolidation unit may, but  are not required to, consider relevant
and appropriate certain design guidance (for covers/caps, drainage,
liners,  stability,  etc.) pertaining  to  RCRA facilities.  RCRA-
specific requirements for a  hazardous waste landfill are presented
in 40 CFR § 264.300  (Subpart N), which  could be considered relevant
and appropriate to  the  consolidation unit.   40 CFR § 264.301 states
that  a RCRA  landfill  must have  two or  more  liners that  are
designed, constructed,  and installed to prevent migration of wastes
out of  the  landfill to the  adjacent  soil or subsurface  soil or
ground water during the active life of the landfill.

Leachate  collection systems are required  above and  between  the
liners that are designed,  constructed, maintained, and operated to
collect and remove any leachate from the landfill.

Furthermore,  RCRA   presents requirements  for  dioxin-containing
wastes.   In  order to  place dioxin-containing wastes  into  a
landfill, the  landfill  must be operated in  accordance with  a
management plan for these wastes  that is approved by the Regional
Administrator (40 CFR § 264.317).  Approval of the management plan
would be based on the following factors:

     •    The volume, physical, and chemical characteristics of the
          waste, including migration potential.

     •    The  attenuative  properties  of  the  underlying  and
          surrounding soils.

     •    The effectiveness  of additional treatment,  design,  or
          monitoring requirements.

Finally,  RCRA  also  presents  monitoring,  inspection,  surveying,
record-keeping, closure, and post-closure care requirements (40 CFR
§ § 264.303-264.310).

Container storage

Because container  storage in a storage  facility is  a potential
alternative for the Vertac  site, RCRA requirements pertaining to
such a storage facility may be considered relevant and appropriate.
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The container storage regulations under RCRA  apply  to  owners and
operators of hazardous waste facilities that  store  containers of
hazardous waste.

According to these regulations, containers of RCRA hazardous waste
must be:

     •    Maintained in good condition (40 CFR § 264.171).
     •    Compatible with hazardous waste to  be  stored (40 CFR §
          264.172).
     •    Closed during storage  (except to add or remove waste)(40
          CFR § 264.173).

Container storage areas must be inspected weekly for deterioration
(40 CFR § 264.174) and have a containment system that is designed
and operated in  accordance  with  40 CFR § 264.175.   In addition,
containers of ignitable or reactive waste must be kept at least 50
feet  from  the property line  (40 CFR  §  264.176).   Furthermore,
incompatible materials must be  kept  separate and separated by a
dike or other barrier  (40 CFR § 264.177).  Finally,  at closure,
hazardous waste and residues must be  removed from the containment
system and containers and  liners must be decontaminated or removed
(40 CFR § 264.178).

Storage of dioxin must  be in  accordance with 40  CFR  § 268, Land
Disposal Restrictions.  When such storage occurs beyond  1 year, the
owner/operator has  the burden  of proving  that  such  storage is
solely for the  purpose of  accumulating sufficient  quantities to
allow  for  proper  recovery, treatment,  and disposal  (40  CFR  §
268.50) .

Toxic substances Control Act (TSCA)

The  Toxic  Substances  Contract  Act   (TSCA)  regulates  hazardous
chemical substances and mixtures deemed to present an unreasonable
risk  to  human  health and the  environment.    The  only identified
substances at the Vertac site that may be regulated under TSCA are
PCBs  and  asbestos.  The  asbestos regulations  are  identical to
NESHAPs regulations and are outlined  under the Clean Air Act.

The PCBs of concern at the site are within four active transformers
located throughout the site.  Under TSCA, as  of October 1, 1990,
the use of network PCB transformers with secondary voltages equal
to or greater than 480 volts, including 480/227 volt  systems,  in or
near  commercial  buildings is prohibited.   Also, the  use of any
retrofilled PCB transformer  is limited to use until October 1, 1990
(40 CFR § 761.30).

Regulations for the disposal of PCBs are also promulgated in 40 CFR
§ 761.  In  general, all PCBs of 500 ppm or greater must be disposed
of  by  incineration  in  incinerators  in  compliance  with  the
performance  standards  in 40  CFR §  761.70.  PCB concentrations

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between 50 and  500  ppm may be disposed of by incineration, high-
efficiency  boiler,   or  in a  chemical  waste  landfill.    Empty
transformers must be disposed of by incineration or chemical waste
landfill provided the transformer has been rinsed with a solvent.
Large  PCB-containing capacitors  (containing  more than 3  Ibs of
dielectric fluid) must also be disposed of by  incineration  (40 CFR
§ 761.60).   Storage of PCBs is also limited  to 1 year (40 CFR §
761.65) .

Clean Water Act  (CWA)

The Clean Water  Act (CWA)  requirements may  be applicable because
incineration or  pretreatment may  generate fluids  that need to be
treated and  discharged.   The CWA  applies to  point-source direct
discharges  into navigable  waters and  indirect discharges to  a
publicly owned  treatment works (POTW).   In the case of indirect
discharges to a POTW, the POTW sets forth  pretreatment standards.

Clean Air Act (CAA)

Because asbestos was found in building  and  insulation materials
onsite, remedial activities must be designed to  comply with the
NESHAPs regulations in the Clean Air Act  (CAA).   NESHAPs provides
procedures for controlling asbestos emissions during demolition (40
CFR § 61.147)  and during  disposal  (40 CFR § 61.156).  Highlights of
NESHAPs pertaining to asbestos (Subpart M) include:

     •    Discharge no visible  emissions  of  asbestos particulate
          material to the outside air.

     •    Friable asbestos is to be removed or contained prior to
          or during  demolition, unless unsafe structural conditions
          exist.

     •    When a facility component coated with friable asbestos is
          being  taken  out in  sections,  adequate  wetting  of  the
          material  must  be  performed  before  any  cutting  or
          disjoining occurs.

     •    An active, commercial waste disposal site is required to
          cover the  asbestos waste daily with 6 inches of compacted
          nonasbestos-containing material.

     •    Proposed amendments to the NESHAPs (54FR912; January 10,
          1989)   indicate that non-friable  asbestos  that  may  be
          broken during  demolition must  also  be removed prior to
          demolition,  except  where unsafe structural  conditions
          exist.

Remedial technologies that could result in air  emissions would have
to be designed so that emissions meet Federal or state air-emission
standards.    Currently,  NESHAPs  regulations  do not  specifically

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address emissions from hazardous waste sites.

National Ambient Air Quality Standards (40 CFR Part 50)  have also
been developed for particular pollutants under the Clean Air Act.
These standards are included in Table 7-3.

STATE ARAR3

Arkansas Hazardous Waste Management Code

The  Arkansas  Hazardous  Waste  Management Act  of  1979  and  the
Arkansas Resource Reclamation Act of 1979 are known together as the
Arkansas Hazardous Waste Management Code (the "Code").   This Code
resembles  the Federal  Hazardous  Waste Management  Regulations.
These  ARARs  are discussed  in  Subsection 4.1.    The  Arkansas
Hazardous  Waste  Management  Code  does  contain  siting  criteria
(Section 5) for  a hazardous waste management facility.   Such a
facility may not be sited in the following areas:

     •    An active fault zone.

     •    A  "regulatory  floodway"  as  adopted  by  communities
          participating in the National Flood Program.

     •    A 100-year flood plain.

     •    A recharge  zone of  a sole  source aquifer  designated
          pursuant to the SDWA.

     •    Wetland areas that are inundated or saturated by surface
          water or ground water.

In addition,  no  permit  shall  be  issued for  a hazardous  waste
landfill facility  or  surface  impoundment  if  such a facility is
located in the following areas:

     •    Areas of high earthquake potential.

     •    Areas having a soil that would be classified as vertisol.

     •    Areas in which a stratum  of limestone or similar rock of
          an average thickness of more than 1 meter lie within 30
          meters of the base of the proposed liner system.

     •    Areas in which the liner  bottom or in-place barrier soil
          is less than 10  feet above  the historically  high water
          table.
     •    Areas near a functioning private or public water supply
          that would constitute an  unacceptable risk to the public
          health or safety.
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                                 TABLE 7-3

                     NATIONAL AMBIENT AIR QUALITY STANDARDS
      POLLUTANT
    STANDARD
      AVERAGING
        PERIOD
     REGULATORY
      STATUS (a)
Sulfur oxides



Paniculate matter


Carbon monoxide


Ozone


Nitrogen oxides

Lead
Primary
Primary
Secondary

Prim. & Sec.
Prim. & Sec.

Prim. & Sec.
Prim. & Sec.

Primary
Secondary

Prim. & Sec.

Prim. & Sec.
12-month arith. mean
24-hour average (b)
2-hour average (b)

Annual arith. mean
24-hour average

8-hour average
1-hour average

Max daily 1-hour avg.
1-hour average

12-month arith. mean

Quarterly mean
    80 ug/cu. m (0.03 ppm)
   365 ug/cu. m (0.14 ppm)
   1300 ug/cu. m (0.5 ppm)

             50 ug/cu. m
            150 ug/cu. m

   9 ppm (10 mg/cu. m) (c)
  35 ppm (40 mg/cu. m) (c)

0.12 ppm (235 ug/cu. m) (d)
0.12 ppm (235 ug/cu. m) (d)

   100 ug/cu. m (0.05 ppm)

            1.5 ug/cu. m
NOTES:

(a)  National short -term standards are not to be exceeded more than once in a calendar year.
(b)  National standards are block averages rather than moving averages.
(c)  National secondary standards for carbon monoxide have been dropped
(d)  Maximum daily 1 -hour average: averaged over a 2-year period, the expected number of days above
    the standard must be less than or equal to one.
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     •    Areas one-half mile from any occupied dwelling,  church,
          school, hospital,  or similarly occupied structure.

     •    Areas where the active portion of the  facility  is  less
          than 200 feet from the facility's property line, and less
          than 300 feet from right-of-ways for roads and utilities.

Section 13 of the Code includes performance  standards in addition
to the provisions of 40 CFR 264, 265, and 270.  Within Section 13,
it states  that when it  is  technically feasible, destruction of
hazardous waste should be accomplished  by incineration utilizing
currently available technology.  No acutely  hazardous waste shall
be disposed in landfills in the State of Arkansas.

Arkansas Solid Waste Management Code

Section I of Appendix A of the Arkansas Solid Waste Management Code
pertains to friable asbestos  material.  The regulation states that
asbestos  material wastes  shall be  handled  in  accordance  with
NESHAPs Regulations in the removal,  containerizing,  storage,  and
transporting of materials.   Additionally, Arkansas Class  III  and
Class  IV  landfills  (facilities  for   the   disposal  of  inert
nonputrescible and approved process wastes only)  could not accept
asbestos material wastes.

The  State of  Arkansas  requires  the   following  permitting  and
operational  standards  when  planning/designing  a   solid  waste
landfill within the state:

     •    Testing - Geological characteristics would be required to
          indicate  soil  conditions,  ground  water elevation  and
          movement, and subsurface characteristics.

     •    Equipment - Verification of proper equipment available to
          properly operate the landfill facility.

     •    Geologic  Structure  -  The  subsoil  and   lithological
          structure  shall  be  such  that   there  is  reasonable
          assurance  that leachate  from the  landfill will  not
          contaminate the ground waters  or surface waters of the
          state.

     •    Sedimentation  and  Surface  Water  Control - The  surface
          contour  of the area shall be such  that surface runoff
          will not flow through/into the fill area.

     '-    Water Table -  Landfill operations will maintain a safe
          vertical  distance  between deposited   refuse  and  the
          maximum seasonal water table elevation and  shall include
          such measures necessary to prevent contamination of the
          ground water.


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     •    Flooding - Sites subjected to  flooding shall be avoided.

     •    Site Improvement -  The  following physical improvements
          shall  be made  before  a  landfill  site  is placed  in
          operation.

               The  site  shall be  adequately  fenced,  with  an
               entrance gate that can be locked and posted.

               All weather operational roads shall be provided.

               Arrangements  shall  be  made  for  fire-protection
               services.

     •    Operation - All operations  of the  landfill shall be in
          accordance with the approved plans and the Arkansas Solid
          Waste Management Code.

Arkansas Water and Air Pollution Control Act

Arkansas air and water  quality regulations resemble the national
standards set forth by the U.S. EPA under the Clean Air and Clean
Water Acts, but require preconstruction review by the state.   In
addition,  Section  5  of  the  Arkansas  Air  Pollution  Control
Regulations outlines specific limitations for particulate emissions
from new or modified sources.  These limits are based solely on the
amount of material being processed (Ib/hr).

Arkansas Noncriteria Air Pollutants Control Strategy

ADPC&E  has  also implemented  an evaluation  of  the  emissions  of
proposed emission of noncriteria air pollutants from  all sources in
order to determine if a permit should be issued or if an existing
source  should  be required  to retrofit  control  equipment.   The
Noncriteria Air Pollutants Control Strategy (NAPCS)  is based upon
Threshold Limit Values  (TLVs)  for  chemical substances adopted by
the  American Conference  of  Governmental Industrial  Hygienists
(ACGIH).

According to  NAPCS, the  predicted ambient air concentration  of
gases and vapors is considered acceptable if it is less than 1/100
of the ACGIH TLV.  The ambient concentration is determined by using
appropriate atmospheric dispersion models over a 24-hour average.
The spacing between receptors used in the model is 100 meters (in
the area of the highest concentration).   The NAPCS may consider 8
and 24-hour averages,  first highs, as well as annual averages for
use in assessing risk.

TLVs  have  been  established  for  the following   contaminants  of
concern:
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               Compound              TLV

               2,4-D               10 mg/m3
               2,4,5-T             10 mg/m3
               Toluene             375 mg/m3
               Phenol              19 mg/m3

As stated in the NAPCS, when the substance emitted is a particulate
compound  and  persistence  in  the  environment  is  expected,  the
predicted annual average concentration is considered acceptable if
it does not exceed the dosage mass of the LD50  (lethal dose for 50%)
expression divided by 10,000.

TO-BE-CONSIDERED (TBCs)

City of Jacksonville Ordinances 604, 620, 684. and 877

Existing operations at the Vertac site involve the pretreatment of
water collected in the french drain system and water collected in
the surface water diversion  ditch  system.  This treated water is
then combined  with sanitary waste water and discharged  to  the
Jacksonville West  Publicly Owned  Treatment  Works  (POTW).   POTW
influent must  meet pollutant  limitations on  metals,  chlorinated
phenols, chlorophenoxyherbicides,  and 2,3,7,8-TCDD as outlined in
City Ordinance 877.  POTW effluent must meet secondary taste and
odor standards before  being discharged to Bayou Meto.  Taste and
odor  standards  for   chlorophenols   range   from   0.1  ug/L  (4-
chlorophenol)  to 2.0 ug/L (2,4,6-trichlorophenol).

£i   SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

The nine criteria for evaluation of an alternative are categorized
into three groups:  threshold criteria (overall protection of human
health  and  environment  and  compliance  with  ARARs),  primary
balancing   criteria   (long-term  effectiveness  and  permanence,
reduction  of  toxicity,  mobility,   or volume  through treatment,
short-term  effectiveness,   implementability,  and   cost),   and
modifying criteria (state and community acceptance). The threshold
criteria  must  be  satisfied in order for an alternative  to be
eligible for selection. The primary balancing criteria are used to
weigh major tradeoffs  among alternatives. The modifying criteria
are taken into account  after  public comment is received  on the
proposed plan.

8.1  THRESHOLD CRITERIA

Overall Protection of Human Health and Environment

This evaluation  criterion  involves  consideration  of  the overall
protection  of  human  health  and  the  environment.    The overall
assessment  of  protection draws on  the assessments conducted for
other evaluation criteria,  especially  long-term effectiveness and

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permanence, short-term effectiveness, and compliance with ARARs.

Evaluation of the overall protectiveness of an alternative focuses
on  whether  a  specific  alternative  achieves  the  remediation
objectives and  describes how risks posed through each potential
exposure  route  addressed  in the  Focused  Feasibility  Study are
eliminated, reduced, or controlled through treatment, engineering,
or  institutional  controls.    This  evaluation  also allows for
consideration of  whether an alternative poses  any unacceptable
short-term impacts.

All of the alternatives,  except Alternative 1  (no action), provide
adequate  protection   of  human  health  and   the  environment.
Alternatives  3   and  4  provide  a  high  degree  of  overall
protectiveness because the principal threats are destroyed through
incineration, and  low level threats are contained  in a disposal
vault  that will  isolate  the low level threats  from exposure
pathways  and  ensure no migration from  the  unit.   Alternative 5
provides a high  degree of overall  protectiveness by  destruction of
all organic pollutants by incineration.   Alternative 2 provides
protection by isolating hazardous  material and keeping them out of
exposure  pathways.   However, Alternative 2   is  not a  permanent
solution and may eventually result in a release because some of the
wastes are corrosive liquids.

An  ambient  air  monitoring  program will be  implemented  to  help
ensure   overall  protectiveness,   including   the   short   term
effectiveness of waste handling and incineration that may result in
fugitive emissions.

Compliance With ARARs

This criterion is used to determine how each alternative complies
with applicable and relevant regulations that  include  chemical-
specific, location-specific, and action-specific ARARs.

Alternatives 3,  4, and 5 will comply with all ARARs provided they
are  properly implemented.    Alternatives  3,  4,  and  5  require
compliance  with  ARARs  such as  operating  requirements  for  an
incinerator   and   performance    requirements    during   remedy
implementation.   Upon completion of the remedies, Alternatives 3,
4, and 5  will also  comply with ARARs  for treatment standards and
for disposal  of treatment  residuals.    Alternative 2  would not
comply with RCRA storage ARARs if the material  is stored  for longer
than 1 year;  however,  it is  considered an interim remedy and could
qualify for a waiver  from ARARs.   Alternative  1 would not comply
with ARAl-^-  ,j.    hazardous  waste would be stored  on  site  in a
manner that  does  not meet  storage requirements.   Alternative 1
would not meet  EPA  policy of using 1 ppb of dioxin as  an action
level in areas of unrestricted public access and 20 ppb of dioxin
as an action level in industrial areas.
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8.2  PRIMARY BALANCING CRITERIA

Long-Term Effectiveness and Permanence

This evaluation criterion involves consideration of the long-term
effectiveness and performance of the alternative once it has been
implemented.  The evaluation focuses on the presence of receptors,
magnitude of the remaining risk from untreated waste or treatment
residues, adequacy, and reliability of controls  that are used to
manage treatment residuals or untreated waste.

Alternative 2 was not designed  as  a permanent solution and would
not be effective  in the long-term because the materials of most
concern remain onsite untreated.   These  materials contain liquid
and corrosive wastes which present a high probability for release
if left onsite indefinitely.

Alternatives 3 and 4 offer a high degree of long-term effectiveness
and permanence.  Both of these alternatives contain an incineration
component   and   a   consolidation/containment  component.     By
incinerating  principal  threats  (vessel  and  drum  contents),  the
source of additional contamination  is  destroyed.  The residuals of
incineration, salt and ash,  are dry,  inert,  and  contain very low
levels of contaminants.  The onsite consolidation/containment unit
would provide long-term effectiveness for the  low  level threats and
asbestos containing materials.  These wastes do not contain liquids
or high  concentrations of waste  and can be contained without
significant risk of migration.

Alternative 5 offers the highest degree of long-term effectiveness
and permanence  because  all  media  of  concern would  be thermally
treated to destroy contaminants. After treatment, materials would
have to be  delisted  and permanently disposed off-site in a solid
waste landfill.  If residuals can not be delisted, disposal would
need to be in a RCRA Subtitle C  hazardous waste landfill, provided
the treatment standards have been met.

Short-Term Effectiveness

This evaluation criterion  involves  consideration  of the short-term
effectiveness   of  the   alternative   during  construction  and
implementation.  The evaluation focuses  on the protection of the
community  and  the  onsite  personnel during implementation  of
remedial measures, potential environmental impacts,  and the time
required to achieve remedial response objectives.

Alternative  1  is  anticipated  to  have  the   greatest  short-term
effectiveness since  no  action is required.   Of  the alternatives
requiring action, Alternative 2 presents the  least amount of risk
to workers, the  community, and the  environment  because Onsite
Operable Unit I media are contained onsite with the least amount of
effort.   Some particulate emissions from construction/demolition

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activities are  anticipated  during implementation;  however, dust-
control methods would reduce this risk. Alternative  3 would involve
all  of the  short-term risks  of  Alternative  2,  plus  the risks
associated with transporting the more hazardous materials off-site.
Alternative 4 also includes all of the risks of Alternative 2 plus
the risks associated with onsite incineration.   The  short-term risk
to the neighboring community associated with Alternative 5 centers
around  incinerating all media within this operable unit.   This
would entail a long-term incineration project,  with  risk associated
with operation of the incinerator and materials handling for size
reduction  to  facilitate  feed  of  multiple  materials  to  the
incinerator.

Any  of  the  Alternatives   2,  3,  4,  and 5  will also  require
implementation of an ambient air monitoring program to detect and
protect  against the impact of fugitive emissions during  remedy
implementation.  Ambient air monitoring  and a site specific risk
assessment performed as part of the ongoing incineration of drummed
wastes at the Vertac Site indicate that onsite incineration can be
performed in a manner that does not pose unacceptable risk to the
community.


Reduction of Toxicitv.  Mobility, and Volume of Contaminants

Consideration of  this  evaluation criterion  is  a  result  of  the
statutory   preference   for  selecting  remedial  actions  that
permanently and significantly  reduce the toxicity, mobility,  and
volume of the contaminants and associated media.

The following factors are considered in this  evaluation:

          The treatment process and materials.
          The amount of hazardous materials.
          The degree of reduction in toxicity, mobility, or volume.
          The degree to which treatment will  be irreversible.
          The type  and quantity  of  materials that  remain after
          remediation.

Alternative 1 will not  reduce toxicity, mobility or volume of the
contaminants  at  the  Site  since  no  treatment  or  additional
containment is performed.

Alternative  2 would reduce the  mobility of the contaminants.
However,  this  reduction   would   be  through  containment,   not
treatment. Mobility may not  be  permanentlv reduce with Alternative
2 since  wastes are  liquid  and '     i:  *          eventually  be
released from the storage unit.   Pretreatment would  reduce toxicity
of some of the media being consolidated/contained onsite.

Alternatives  3,  4,  and  5  use thermal  treatment  to reduce  the
inherent hazards posed  by the contaminants  of concern at the site.

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Alternatives 3 and 4 would reduce toxicity,  mobility,  and volumes
for the principal threats.  Pretreatment would reduce the toxicity
of  the low  level threats  being consolidated/contained  onsite.
Alternative 5 would achieve the  greatest  reductions in toxicity,
mobility,  and  volume because  all media  would  be  incinerated.
Incineration yields salt and ash  as a treatment residue.  However,
the salt  and  ash occurs at a  lower  mass than the  organic waste
feed,   is  dry, not chemically reactive,  and contains  hazardous
constituents  at   concentrations much  lower  than   the  waste
incinerated.

Implementabilitv

This  criterion  establishes  the  technical  and  administrative
feasibility of  implementing an  alternative.   Technical  aspects
evaluated for each alternative  include: construction and operation
activities,  reliability of the  technologies  involved,  ease  of
undertaking  additional  remedial action,  and  monitoring  after
completion  of  activities.    Administrative   concerns  include
establishing  contact  with  appropriate  agencies  to  implement
remedial  actions   (e.g., obtaining permits  for construction  and
operation of  a treatment unit).   Availability of  materials  and
equipment needed  is  another  factor  that must be  considered when
evaluating implementability of an alternative.

Alternatives 2,  3,  4,and 5 all contain technologies that  are proven
and commercially available.  Alternative 2 would be the easiest to
implement because  no  treatment would take place.   Alternative 3
would require locating an off-site facility permitted and willing
to treat dioxin-containing wastes.  Also,  difficulties may  arise in
transporting the materials to the off-site facility.  Alternatives
4  and  5  would  be   more  difficult  to  implement  compared  to
Alternative 2  because  of  facility requirements  for  the onsite
incineration component.  There is strong opposition to incineration
among some members of the community  that has resulted in several
lawsuits attempting to halt  incineration.  This ongoing litigation
will make onsite  incineration more  difficult to  implement than
Alternative 2.

Cost

A  remedial  program must be implemented  and operated  in  a cost-
effective manner  and must mitigate  the  environmental  and human
health concerns at the Site.  In considering the cost-effectiveness
of  the   various   alternatives,   the  following  categories  are
evaluated:

     •    Capital  Costs—These  costs  include  expenditures  for
          equipment,  labor,  and  materials  necessary  to  install
          remedial actions.   Indirect costs may  be incurred for
          engineering,  financial, or other  services not  directly
          involved with installation  of remedial alternatives, but

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          necessary for completion of this activity.

     •    Operating  and Maintenance  Costs—These  costs  include
          post-construction   expenditures   incurred   to   ensure
          effective implementation of the alternative.  Such costs
          may include,  but are not limited  to,  operating labor,
          maintenance  materials  and  labor,  rental  equipment,
          disposal of residues,  and administrative,  insurance, and
          licensing costs.

Cost  is assumed  to  be the  critical factor  in deciding  among
alternatives that are in compliance with ARARs or that are better
than risk-based health  standards.  Costs for Alternative  2 range
from $ 19.9 to $ 21.5 million.   Costs  for Alternative 3 range from
$ 24.2 to $  53.6 million. Costs for Alternative 4  range  from $ 20.8
to $ 38.7 million.   Alternative 4F had the lowest total cost, at
approximately $ 20.8 million.  Alternative  5 had the highest total
cost, at $ 169.2 million, due to the amount and type of materials
incinerated.

It should be noted that costs associated with Alternatives  3, 4 and
5 assume that incineration residuals are delisted and disposed in
the  consolidation  unit  onsite  or  off-site  as  solid  waste.
Additional  treatment at  additional  cost  would  be required  if
residuals cannot be delisted.

8.3  MODIFYING CRITERIA

State Acceptance

The  State  of Arkansas has commented  on the proposed  plan.   The
State is in general agreement with the proposed plan.

Community Acceptance

All  comments  received have been addressed  in the responsiveness
summary, which is attached to this Record of Decision.

Table 8-1 summarizes the evaluation of alternatives.

9j_   THE SELECTED REMEDY

Based  upon  consideration of  the  requirements   of CERCLA,  the
detailed analysis of the alternatives using  the nine  evaluation
criteria, consultation  with the Arkansas Department of Pollution
Control & Ecology, and public comments, the EPA has determined that
Alternative 4, Option E (w.i^h the Changes described below) is the
most appropriate remedy for the Vertac site Onsite Operable Unit 1.
The selected remedy  uses treatment to address principal  threats and
consolidation/containment  to  address  low level  threats posed by
this operable unit media. The treatment selected is incineration.
Incineration is the best demonstrated available technology for

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dioxin wastes. Onsite incineration (except for non-F-listed wastes)
was selected because of the CERCLA preference for onsite remedies
and the current estimates indicate that off-site incineration would
cost about $ 2000 more per ton of waste.  Consolidation/containment
of low level threat wastes will be within the area of contamination
defined by the site  boundaries. A  RCRA subtitle C landfill will be
constructed within  the  area of contamination. A RCRA  subtitle C
landfill is required  to minimize the potential  for  migration of
contaminants and to  improve long-term effectiveness of the remedy.
A subtitle C landfill is also required because some of the wastes
to be consolidated and contained on site  contain contaminant levels
above  the  best  demonstrated   available   technology  treatment
standards and the ground water table occurs at shallow depths. The
selected remedy consists of the following:

l. Contents and residues that are in process vessels - This media
is a principal threat and  therefore shall  be  treated.  The remedy
shall  be  onsite incineration  for F-listed wastes.  Incineration
shall  be  performed  by  an  incinerator with 99.9999% destruction
removal efficiency  (DRE)  based on  trial burn results. Demonstrated
non- F-listed wastes shall  be transported to a RCRA permitted off-
site   facility   for  treatment/disposal   (if   feasible)   and/or
incinerated onsite.  Demonstrated uncontaminated raw materials, such
as caustic, kerosene/fuel oil, etc., shall be shipped off-site for
recycle/reuse   or    treatment/disposal   (if   feasible)   and/or
incinerated  onsite.  This  flexibility in  treatment/disposal,
recycle/reuse   for   demonstrated   non-F-listed    wastes   and
uncontaminated raw materials in an off-site permitted facility is
built in to reduce remediation costs (since  non-F-listed wastes can
be incinerated  in  a commercial facility with 99.99% destruction
removal  efficiency).  Both  process  knowledge  and  analytical
confirmation that dioxin levels are below the detection limit shall
be the performance standards to demonstrate  that a particular waste
or raw material is non-F-listed.

2. Spent carbon - This  media is  a principal threat and therefore
shall be treated. The remedy shall  be  onsite  incineration and/or
onsite regeneration/reuse.  Regenerated carbon  shall be used solely
in the onsite leachate collection/treatment system and shall not be
shipped for off-site use.

3. Containerized (drummed)  wastes - Onsite  incineration of drummed
franch drain oily leachate,  spent Butyl-T,  recovery waste, 2,4-D
drum  wash waste,  and  used filters  (from Phase  2 waste  water
treatment, french  drain,  and  sumps),  since  these  materials are
principal threat wastes.  Consolidation of drummed RI waste  (such as
used cyva": suits, discarded glassware, and trash) in an onsite RCRA
Subtitle C landfill, since this waste poses a low level threat. A
remedy  for the  containerized mud  and   sediments  collected from
manholes, drains, leaf filter, and drilling  will be proposed during
the Onsite Operable Unit 2  remedy  selection process  (reasoning for
this deferment is provided under  the remedy for bagged soils)

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4. PCB  oils  in transformers -   This material poses  a principal
threat  and the TSCA regulations require  incineration.  Since the
estimated quantity of PCB oil is small (1 cubic yard)  and a trial
burn is required for a PCB incinerator, this media shall be shipped
to an off-site permitted facility for incineration.

5. Shredded  pallets -  This media  is a  principal threat  waste
because  the   sampling  results  indicate that   this  waste  is
contaminated with herbicides and dioxin (average concentration of
2,3,7,8-TCDD is about 549 ppb, with  a range  of  2.5 to 4100 ppb).
Therefore, shredded pallets shall be incinerated onsite.

6. Shredded trash - This media poses  a principal threat because of
high  concentrations  of  chlorophenols   (25,000   ppm  maximum),
tetrachlorobenzene (100,000 ppm maximum),  and herbicides (44,000
ppm 2,4-D  maximum)present in this  media. Therefore,  this  media
shall be incinerated onsite.

7. Buildings  -  This media poses a low level threat after removal of
friable asbestos.  The buildings mainly contain porous media (such
as asbestos siding, shingles, wood, sheetrock, etc.). For off-site
Recycle/reuse of building materials, the building materials must be
decontaminated  using  the treatment  standards set forth in  the
hazardous debris rule (40 CFR § 268.45). This rule requires removal
of at least 0.6 centimeters  of surface  layer and to further ensure
removal of contaminants that may be absorbed to depths beyond 0.6
centimeters,  the rule requires removal of virtually all staining
that could be  indicative  of the presence  of  toxic contaminants.
This decontamination process, if implemented, poses unacceptable
short-term risks.   Therefore, the buildings (except  the bagged soil
storage building,  which will continue  to  store  bagged soils,  the
supervisor's office building, which will continue to be used by the
site maintenance personnel,  and  the waste water  treatment  plant
building, which will continue to be used for treatment of leachate
collection system water) shall be demolished and the debris shall
be consolidated/contained in an onsite RCRA subtitle C landfill.

8.  Process  equipment  (including  drums  in  the  Regina  Paint
Building)-   After  the  removal of  process vessel  contents,  this
media poses  a  low level threat. Since this  media  is made  up of
mostly metal objects, it should be decontaminated and shipped off-
site for recycle/reuse.  Therefore,  the process equipment shall be
decontaminated utilizing treatment standards for hazardous debris
(40 CFR § 268.45),  to the maximum extent practicable,  and shipped
off site for recycle/reuse.  The treatment standards for hazardous
debris require the use  of abrasive  blasting,  high pressure  steam
an:? wat: r  sprays,   -aj.er/detergent  washing, liquid phase solvent
extraction, etc. to clean  the surface so that residual staining is
limited to no more  than  5% of each square  inch  of the surface area.
Debris  resulting   from  demolition  of  equipment  that cannot  be
decontaminated, utilizing the maximum extent practicable criteria
(determined,in  part,  by integrity,  degree of corrosion,  safety

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considerations, etc.)/ shall be consolidated/contained in an onsite
RCRA subtitle C landfill.

9.  Bagged  Soils  -  Since  the  bagged  soils  (excavated  from
residential yards  and  an onsite  drainage  ditch)  are  similar  to
onsite contaminated surface  soils that will be addressed  in the
Onsite  Operable Unit  2,  remedy  selection  for  this  media  is
deferred. A remedy for these bagged soils will be selected, along
with the  onsite soils,  during  the remedy selection  process for
Onsite Operable Unit 2.

10. Friable asbestos containing materials - After removal from the
buildings and process equipment following NESHAPs regulations, this
media shall be  consolidated/contained  in an onsite RCRA Subtitle C
landfill.

11.  Residues  from  decontamination activities  -  Spent  solvents
generated from decontamination activities shall be incinerated on
site. Waste water generated from decontamination activities shall
be treated onsite and discharged to the Rocky Branch Creek.

12.  Onsite  incinerator  ash and salt  -  EPA is in the  process  of
developing and  selecting  a  disposal option for the  ash  and salt
generated by onsite incineration of 29,000 plus drums. Disposal of
ash  and  salt that would  be  generated by onsite  incineration  of
Onsite Operable Unit 1 media shall be consistent with the remedy to
be  selected  for  the   ash   and  salt  from  the  current  onsite
incinerator.

The  remedy  shall also require  implementation of an  ambient air
monitoring program during remedial action  to  measure and protect
against excessive fugitive emissions that may pose a threat to the
community or the environment.

The  estimated  remedial  cost  for  the selected  remedy is  $ 28.5
million. The annual O&M  (inspection) cost is estimated at $ 15,000
per year. A better  estimate of the annual O&M cost will be provided
in the site O&M plan (developed during remedial design).

Since  all the  media  addressed in this operable  unit would  be
treated  onsite,   treated,   reused,   or  disposed  off-site,  or
consolidated in an  onsite RCRA Subtitle C landfill, the ARARs  (such
as RCRA regulations for incinerators,  landfills etc.) specify the
performance standards and cleanup  levels.

10.  STATUTORY DETERMINATIONS

Under  CERCLA  section  121,  EPA  must select  remedies that are
protective  of   human  health and  the  environment,  comply with
applicable  or  relevant  and appropriate  requirements  (unless  a
statutory waiver  is justified),  are  cost-effective,  and utilize
permanent  solutions  and  alternative  technologies  or  resource

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recovery  technologies  to  the  maximum  extent  practicable.  In
addition,  CERCLA  includes a preference for  remedies that employ
treatment  that  permanently and  significantly  reduce the volume,
toxicity,  or mobility  of  hazardous wastes  as their  principal
element. The  following  sections discuss  how  the selected remedy
meets these statutory requirements.

Protection of Human Health and the Environment

The  selected remedy  protects  human  health  and the environment
through  treatment  of principal threat  wastes  (process  vessel
contents, spent activated carbon, shredded trash and pallets, PCB
transformer  oils,  and   miscellaneous  drummed wastes),  through
containment of low level threat wastes (asbestos, debris resulting
from the demolition of buildings  and some equipment,etc.)  in a RCRA
Subtitle  C landfill,  and  through  decontamination  and off-site
recycle/reuse   of  process  equipment  to  the  maximum  extent
practicable.

Treatment  of  the highly  contaminated wastes  will  eliminate the
continued  threat  of exposure  to the most toxic contaminants of
concern  (dioxins, chlorophenols, tetrachlorobenzene,  herbicides
such as 2,4-D and 2,4,5-T,  toluene,  and PCBs)  via  direct contact
with or ingestion/inhalation of these wastes. Since the principal
threat wastes are  contained in tanks, plastic  bags, etc., the exact
risk to the public cannot be quantified. However, the cancer risk,
from just one release scenario, assuming that trash/pallets would
catch fire and a receptor at the fenceline would inhale smoke for
a  12-hour  period,  is  estimated  at  2xlO"4.   By treating  these
principal threat  wastes,  the  cancer risks from  exposure will be
reduced to  less than IxlO'6.  This  level  falls within  the  EPA's
acceptable risk range of IxlO"4 to IxlO"6.

Short-term  threats associated with the  selected  remedy can be
controlled by proper  design and implementation. In addition, no
adverse cross-media impacts are expected from  implementation of the
selected remedy.

Compliance with Applicable or Relevant and  Appropriate Requirements

The selected remedy of incineration, decontamination and off-site
recycle/reuse of process equipment,  and consolidation/containment
of this  operable  unit media will  comply  with all  applicable or
relevant and appropriate requirements (ARARs) ,  if properly designed
and implemented..  The ARARs for the selected remedy are presented
below.

Chemical Specific ARARs;

RCRA

     A. TSD able to accept material

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TSCA

     A. PCBs

CAA

     A. Asbestos

     B. NAAQS

Arkansas Water and Air Pollution Control Act

     A. Particulate emissions from new or modified sources

Arkansas Noncriteria Air Pollutants Control Strategy

     A. Ambient air criteria
          1. TLV/1000
          2. LD50/10,000 for particulates

Location Specific ARARs

RCRA

     A. Location stds. (40 CFR 264.18)
          1. Floodplains
          2. Seismic considerations

Arkansas Hazardous Management Code

     A. Hazardous waste management facility siting stds.
          1. Fault zone
          2. Regulatory floodway
          3. Floodplain
          4. Recharge zone of sole source aquifer
          5. Wetland areas

     B. Hazardous waste landfill siting stds.
          1. High earthquake potential
          2. Vertisol soil
          3. Limestone > 1 meter thick within 30 meter
          4. Bottom liner > 10 ft above historically high water
             table
          5. Near a functioning water supply that would pose an
             unacceptable risk
          6. Within 1/2 mile of occupied dwelling
          7. within 200 ft of facility boundary
          8. Within 300 ft of right-of-way

Arkansas Solid Waste Management Code

     A. Solid waste landfill design/planning

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          1. Proper geologic conditions
          2. Proper hydrogeologic conditions
          3. Floodplains

Action Specific ARARs

RCRA

     A. Incineration (40 CFR Subpart O)
          1. 99.9999 % ORE
          2. HCl emissions < 1.8 kg/hr
          3. Particulates emission < 180 tons/dscm
          4. Monitoring

     B. Landfills (40 CFR 264 Subpart N)
          1. Construction stds.
          2. Operating and monitoring stds.
          3. Closure requirements
          4. Post-closure requirements

     C. Land Disposal Restrictions (40 CFR § 268)
          1. Alternative treatment standards for hazardous debris

CWA

     A. Treatment Standards and Effluent Limitations for Direct
        Discharge
     B. Pretreatment Standards for Discharge to a POTW

TSCA (40 CFR 761)

     A. Treatment/storage/disposal of PCBs

CAA

     A. Demolition
          1. Asbestos release

     B. Disposal requirements for asbestos

Arkansas Hazardous Waste Management Code

     A. Destruction of hazardous wastes by incineration where
        feasible

     B. No acutely hazardous wastes in landfills

Arkansas Solid Waste Management Code

     A. Solid waste landfill design/planning
          1. Proper geologic conditions
          2. Availability of proper equipment

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          3. Sedimentation and surface water control
          4. Site improvements (roads, fencing,  etc.)
          5. Operation in accordance with approved plan

Arkansas Water and Air Pollution Control Act

     A. Preconstruction review

To Be Considered fTBCs)

City of Jacksonville Ordinances 604, 620, 854,  877

     A. POTW influent limitations on metals, chlorinated phenols,
        chlorophenoxyherbicides and TCDD

     B. Secondary taste and odor stds. for POTW effluent

Cost Effectiveness

EPA believes this remedy will eliminate the risks to human health
at  an estimated  cost of  $  28.5  million.  The  selected  remedy
provides an overall effectiveness proportionate to its costs, such
that it represents  a  reasonable  value for  the money that will be
spent.

The selected remedy assures a much higher degree of certainty that
the  remedy will be effective  in  the  long-term  because  of  the
significant reduction of  the toxicity, mobility, and volume of the
wastes  achieved through  treatment of  wastes,  recycle/reuse  of
process after decontamination, and consolidation and containment of
debris resulting from demolition of buildings and some equipment in
a RCRA Subtitle C landfill.

utilization  of  Permanent  Solutions   and  Alternative  Treatment
Technologies  (or Resource Recovery Technologies) to  the Maximum
Extent Practicable

EPA has determined that the selected remedy represents the maximum
extent to which permanent solutions  and treatment technologies can
be utilized in a cost-effective manner for this operable unit. Of
those alternatives (alternatives 3,4,  and 5) that are protective of
human health and the environment and  comply with APxARs,  EPA has
determined that this selected remedy provides the best balance of
trade-offs  in  terms  of  long-term  effectiveness  and permanence,
reduction  in  toxicity,   mobility,  or volume  achieved  through
treatment, short-term effectiveness, implementability, cost, while
also  considering the statutory preference for  treatment as  a
principal element and considering state and community acceptance.

The  selected remedy  treats the principal threats posed  by  the
highly  contaminated wastes,  achieving significant 2,3,7,8-TCDD,
chlorophenols,  tetrachlorobenzene,  2,4-D,   2,4,5-T,  toluene,  and

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PCBs  reductions.  This  remedy  provides  the  most effective  and
implementable treatment of any of the alternatives considered. The
selection  of  treatment  of  the  highly contaminated wastes  is
consistent with  program  expectations  that indicate  that highly
toxic and mobile wastes are  principal  threats and a priority for
treatment and often necessary to ensure long-term effectiveness of
a remedy.

Preference for Treatment as a Principal Element

By treating  the  process vessel contents,  spent  carbon,  shredded
trash and pallets,  miscellaneous drummed wastes, and PCB oils, the
selected remedy addresses the principal threats posed by the site
through the use of treatment technologies.  By utilizing treatment
as a significant portion of  the remedy,  the statutory preference
for  remedies that  employ treatment  as a  principal  element  is
satisfied.

11.  DOCUMENTATION OF SIGNIFICANT CHANGES

A proposed plan was released for public comment in February 1993.
The  proposed  plan  identified  onsite  incineration  of  vessel
contents,  spent   activated   carbon   (with   option   for  onsite
regeneration and  reuse), miscellaneous drummed  wastes,  shredded
trash and  pallets,  and PCB  oils,  and onsite consolidation  and
containment of the  debris  resulting from demolition of buildings
and  equipment.  EPA reviewed  all  written and  verbal  comments
submitted during the public  comment period. Upon review of these
comments, it was determined that provisions  should be made for off-
site  treatment/disposal  and  recycle/reuse   of  some   of  the
demonstrated non-F-listed vessel contents (non-F-listed wastes such
as  dalapon  wastes,  and uncontaminated raw  materials  such  as
hydrochloric acid,  sodium  hydroxide, kerosene/fuel  oil,  etc.)  to
reduce remediation  costs,  to  decontaminate  process  equipment for
off-site recycle/reuse  to the maximum extent practicable,  since
recycle/reuse benefits the environment, and for consolidation and
containment of  some  drummed (containerized)  RI  wastes  (such as used
personal protective clothing,  trash,  etc.)  in  the  onsite RCRA
Subtitle C landfill,  since this type  of waste poses  a low level
threat.  These changes are  a  logical outcome of the  discussion of
EPA's goals for site remediation in the proposed plan.
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RESPONSIVENESS SUMMARY



 VERTAC ONS1TE OU 1 ROD

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