United Sates
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R07-87/009
September 1987
Superfund
Record of Decision:
Conservation Chemical, MO

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.
. TECHNICAL REPOAT DATA
'P(taJI 'tad '1IrtfUCl101lf 011 lilt ,t.t"llHf~t co,.,,,ltlt1lf'

12. IJ "ECI~IE'" r 5 "CCESS,~" "0


5. "E~OlllT OATE
September 30, 1987

4. ~E""O'lIOoIIl"'C O"G"""ZATlO'" COOE
,. IIII'OIllT NO.
EPA/ROD/R07-87/009
...1'11'1.1 ANO SIJITITI.&
SUPERFUND RECORD OF DECISION
Conservation Chemical, MO
First Remedial Action - Final
7. AIJ1"10401111151
.
,. ~'IIIIIOIII""I"'G OlllCANIZAT,ON "1'OlllT "'0
19. 'IIIIIIOI'I""ING Ol'lGANIZATION NA"'" ANO AOOI'IISS
10. ~I'IOGI'IA."" &I..I""INT "<0
I 1 <;~N--rlIfAc:-T/GIIIA"'T NO
12. 5"ON501ll1NO AOINCY NA"'" ANO AOOI'I.S5
U.S. Environmental Protection Agency
401 M'Street, S.W.
Washington, D.C. 20460
IJ. TY'! Oil IIII"Ol'lT A"'O ~''''IOO CO\lE"IO
. Final ROD Report

1.. 5"ON50l'lINO ACIINC;Y COOl
800/00
15. SU'-\.I!""'NTAIIIY NOTI5
I.. A"T"ACT
The six-acre Conservation Chemical Company (CCC) site is situated on the flood plain
of the Missouri River near the confluence of the Missouri and Blue Rivers within the
city limits of Kansas City, Missouri. CCC initiated its activities at the site in 186D7
beginning with construction of chemical treatment basins, the process area and a roadway
ramp. Waste disposal operations began at the site soon after site construction was
initiated and continued until approximately 1980. The exact nature and quantities of
chemicals and wastes handled during the site's active operating period are unknown.
Many site operating records are reported to have been destroyed in a 1970 fire.
Operating records which are available indicate the primary materials accepted at the CCC
site include: organics, solvents, acids~ caustics, metal hydroxides and cyanide
compounds. Reports also indicate that pesticides, herbicides, waste oils, organic
solvents, halogenated compounds, arsenic and elemental phosphorous were handled at the
site. In addition, there are reports and some evidence that pressurized cylinders and
other metal containers were placed in the lagoons. The facility handled liquids,
sludges and solids. The above totals include 48,000,000 gallons of liquids and sludges
and 1,144 tons of solids. Because the records are incomplete, these figures are
believed to understate the total quantity of materials brought to the site. Most of the
materials brought to the site reportedly were disposed of onsite, with or without
(See Attached Sheet)
17.
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O.IC"'"OIllS
KI" .0"08 AHO OOCU"''''T ANAL,Y'lt
b.IO''''TII''II'I'/O-'''' INOIO TII'IMS
C. COSATI F..ldJC,O\I~
Record of Decision
Conservation Chemical, MO
First Remedial Action - Final
Contaminated Media: gw, soil
Key contaminants: dioxin, VOCs,
inorganics, metals
organics,
". OIST"lluTION STATU,IINT
l' SICV"'I TY CI.""SS , nus Rtpor'l
None
121 "'0 0" ~"GIS
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EPA/ROD/R07-87/009
Conservation Chemical, MO
First Remedial Action - Final
16.
ABSTRACT (continued)
treatment. CCC employed a variety of waste handling practices. Residual materials from
the various treatment ~rocesses were generally disposed of onsite in the basins~
Approximately 93,000 yd3 of materials, including drums, bulk liquids, sludges and'
solids were buried at the site. In 1975, the Missouri Department of Natural Resources,
Solid Waste Management Program (DNR/SWMP) investigated the site and found it to be
operating as a solid waste disposal area. In 1977, the Missouri Clean Water Commission
ordered the site closed and covered. At present, the site contains miscellaneous
surface structures, such as tanks and bUildings, and the six basins used for the
storage, treatment, and disposal of a variety of chemicals, liquid wastes and sludges,
which are presently covered. Soil and ground water are contaminated with 23
contaminants which include inorganics, organics, VOCs, metals and dioxin.
The selected remedial action for this site includes: surface cleanup including
demolition and disposal of existing building and other tanks and debris; installation of
a protective surface cap; ground water pump and treatment using sulfide precipitation
with discharge to the Missouri River; and offsite ground water monitoring. The
estimated capital cost for this remedial action is $8,626,000 with estimated present
worth O&M of $12,774,111.
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. ~ '", ".. , . ':' .:' '. ";",.,' ';":"':_-"".~
> ..,:' '.}";',~-:.::; .~.~.:: :":
. RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Conservation Chemical Company
Kansas City, Missour1
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'~':'~'-'" --"'''''''':''.:~''.;;:-
I am basing my decision concerning the appropriate
remedial alternative for the Conservation Chemical
Company (CCC) site on EPA staff and expert consultant
recommendatjons, information provided and analyses
performed by the public, including parties potentially
responsible for the CCC site and review of the
following documents, describing the analysis of the
remedial alternatives and the factors in the National
Contingency Plan. A substantial number of additional
documents are included in the administrative record as
well.
Among the documents that have been
documents and advice considered ar~:
reviewed
and
1.
Remedial Investigation Report on Conservation
Chemical Company Site, Kansas City, Missouri, by
Burns & McDonnell Engineering Company, 1984.

Focus Feasibility Study for the Conservation
Chemical Company (CCC) site, Final Draft Report,
February 1985, prepared by M. John Cullinane Jr.
and James D. Crabtree, U. S. Army Engineer ~
Waterways Experiment StatiQn (WES).
2..
3.
Endangerment Assessment: Conservation Chemical
Company, Kansas City, Missouri, May 1985, prepared
by Clement Associates, 1985.

Addendum to the Focus Feasibility study for the
CCC Site, March 1987, prepared by John Cullinane,
u.s. Army Engineer Waterway Experiment station.
4.
5.
Alternative Remedial Action for the CCC site,
Final Draft Report March 1987, prepared by Jacobs
~nginec.ring Group, Inc.

Numerical Simulation of Pumping and/or Inj ection
Alternatives for Remedial Action at the CCC site,
Final Draft, February 1987, .prepared by Geo Trans;
Inc.
6.
7.
Public Comments.
8.
The Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, 42 U.S.C.
Section 9601 et seq., as amended by the Superfund
Amendments and Reauthorization Act of 1986.
9.
The
National
Substances
oil
and
Hazardous
1
'-- -=:',' _.~ ~~";-;:-:.-, . :;--:-'00\,'-' ~.O:..~ ' , ~ 0;, ::,-,<;---; .::;--';,:=- ~'7',' :,,-..;0.'''''':., ;-=-;;:". ,.-.--.: "-,cf';-,;;...O~" .:'~~ ::~ '~~-"". :.
~ . F'=>Y'. -:;;;-:-~:i:.::.-,~':.'77"',;7.'..<'-:-.~-,~. E: '.,>," ~ ':,/,':.:.~;:-";,~"~~~~~)~:~,~'~-:c'.~':: .'...r;.-;~S~;:S;~'F~:='--.>;',~~'.
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.'. ..
. _.. .. 1.. . .
Pollution Contingency Plan,
November 20, 1985.
40 C.F.R.
Part 300,
DESCRIPTION OF SELECTED REMEDY
The selected remedy consists of:
Surface cleanup and preparation including dem-
olition and disposal of existing building and
other tanks and debris. .
Installation uf a protective surface cap which
will provide a two-layer cap over the existing
fill and consist of geotechnically stable loess
and top soil. .

Installation of a withdrawal well system to
achieve an inward groundwater gradient to be
measured by piezometer pairs along the perimeter
of the site.
Installation of a groundwater treatment system
that will include sulfide precipitation.
Enforceable operating rules will be established
and any discharge must be protective of public
heal th and meet all applicable and relevant or
appropriate requirements, including any effluent
limits that would be applicable under a NPDES
pend t .
Perform. offsite groundwater quality and water
level monitoring to permit an assessment of
changes in groundwater quality in the vicinity of
the CCC site outside of the remedial action area.
DECLARATION
I have determined that remedial alternative selected
for the CCC Site, is cost-effective, consistent with a
permanent remedy, attains applicable or relevant and
appropriate requirements, and provides adequate
protection of public health and welfare and the
environment and is consistent with the Comprehensive
Environmental Response, Compensation, and Liability Act
of 1980 (CERCLA) , as amended by the Superfund
Amendments and Reauthorization act of 1986 (SARA), and
National oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 C.F.R. Part 300;

I have determined that the action being taken applies
permanent solutions and alternative treatment
2
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technologies to the maximum extent practicable. The
state of Missouri has been consulted on the selected
remedy.

This remedial action will require operation and
maintenance acti vi ties. . to ensure continued
effectiveness of the remedial alternative as well as to
assure that the performance meets applicable federal
and state surface and groundwater quality criteria.
Da~ 30, /'1~7
. <::;:r/-
Attachment
.1.
Summary 0 f
Conservation
. Missouri
Remedial
Chemical
Alternative Selection
Company, Kansas ci ty ,
2.
Index of Documents in the Record.
3
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SUMMARY OF _~DIAL ALTE~ATIVE SELECTION
CONSERVATION CHEMICAL ~OMPANY
KANSAS CITY, JACKSON COUNTY, MISSOURI
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION VII
KANSAS CITY, KANSAS
. -,.-. ," .,_.~.~ -," ~r_.', '.r "-co c.' ., .'1'.
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4.
TABLE OP' CONTENTS
1.
Site Location and Description
a. Site Location
b.
2.
b.
c.
d.
e.
Site
a.
Topography

Hydrogeology

Hydrology. .

Climate

History

Waste Disposal Practices

,..
Current Site Conditions
,..
Endangerment Assessment
Development of Alternatives
Detailed Evaluation of Alternatives
a. Reliability
b. Implementability
c. Technical Effectiveness
:3 .
5.
d.
f.

g.
h.
e.
Environmental Concerns
Safety
Regulatory Requirements
Public Acceptance
Cost
i. Operation and Maintenance
Recommended Alternative
a. Surface Cleanup/Surface Preparation
b. Protective Surface Cap.
c. Withdrawal Well System
d. Groundwater Treatment System
e. Off site Groundwater Quality Monitoring
System
Operation and Maintenance Program
6.
f.
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7.
8.
9.
10.
11.
Applicable or Relevant and Appropriate
Requirements
a. Groundwater Contamination
b~ Discharge to the Missouri River
c. Soil Contamination
d. Conclusion
Schedule
Community Relations
Enf~rcement Analysis
Responsiveness Summary
I'
I'
.' : ::~.;:';?"":.. .,: . .,;'~~ ',-:~;.':;~:'~:3T;:;-~:~.:.~':;::::.;p2~:7::Cg;;~::r: ,':.:::7'J.0"~;:,;:}:?\t:~:~.~;~f;':;.i~:~~Y7:i~~~;'~. .:~;:~~E;~~:~:t:fG~(~0~1~A[;t¥;,F~{;ji~:\?:~:',;:;~,7"f~~~~:-'
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"Figure 1.
Figure 2.
Figure 3.
Figure 4.
Table 1.
Table 2.
Table 3.
Table 4.
Table 5.
Table 6.
Table 7.
Table 8.
Table 9.
Attachment 1.
LIST OF FIGURES
General Map Showing Location of CCC Site
Location Map showing CCC Site
General Schematic of CCC Waste Disposal
Operation

Well and Piezometer Locations for Selected
Remedy
LIST OF TABLES
contaminants of Primary Concern at the CCC
Site
Technologies Considered in FFS

Technologies Excluded from Detailed
Development in FFS
. "
Description of Remedial Alternatives
Evaluated in FFS
Technologies considered in FFS Addendum
Technologies excluded from detailed
development in FFS Addendum

Descriptions of Remedial Alternatives
Evaluated in FFS Addendum
Comparison of Costs for Alternative 4, lOA,
and 11
Applicable or Relevant and Appropriate Re-
quirements (ARARs) for Contaminants of Con-
cern at the CCC Site
LIST OF A'rl'ACHMENTS
The State of Missouri's Preliminary
Applicable Effluent Limitation and
State ARARs
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1.
SITE LOCATION AND DESCRIPTION
a.
site Location
The Conservation Chemical Company (CCC) site is
located at 8900 Front Street, within the city
limi ts of Kansas City, Missouri. The site is
located approximately 1.75 miles east of
Interstate 435, along the Levee Road in Jackson
County, Missouri, as shown on Figures 1 and 2.
The site is approximately 6 acres in size and is
situated on the floodplain of the Missouri River
near the confluence of the Missouri and Blue
Rivers, on the river side of the levee. The only
access to the site is from the Levee Road.
The area in which the site is located is
industrially zoned. Mobay Chemical Company (HCC)
operates an agricultural chemical manufacturing
plant southwest of the site and owns property
northeast and east of the si te, which is
undeveloped, but a portion of which has in the
past been used for agricultural purposes. Kansas~
City Power and Light (KCPL) operates the Hawthorne
Power Plant to the northwest of the site and owns
undeveloped land to the north and west of the
site.
b.
TODocrraDhv
The site was undeveloped prior to startup of CCC's
operation, and the initial site topography was
that of the naturally occuring flood plain. As
the site was developed, its topography was
altered. Throughout the period of active opera-
tion, the process area had the highest elevation.
By 1963, the area around basins 1 and 6 (Figure 3)
had been built up to an elevation of approximately
739 feet above mean sea level (msl), the area
around basin 4 was at elevation 735, and the
~ortheastern portion of the site remained at
elevation 730.
Beginning. in approximately 1978, CCC initiated a
site closure process which involved an attempt to
stabilize the upper layer of waste materials in
the basins, which was followed by placement of a
soil cover over the basins. This process raised
the surface elevation of the site to approximately
1
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current levels. A topographic map prepared from
aerial photographs taken in March 1984 depicts the
current topography (Figure 4). The surface of the
site slopes generally from the southwest .to
northeast. However, slight irregularities in the
surface resul t in depressions which collect
precipitation. The area surrounding the site
currently slopes to the northeast, northwest, and
southeast, so that surface drainage trom the site
is in these three directions.
c.
Hvdroaeoloav
A detailed description of site hydrogeology is
found in reports enti tled "Hydrogeologic
Characterization Conservation Chemical Company
site" by Crabtree and Malone (1984) and
"Endangerment Assessment: Conservation Chemical
company" by Clement Associates (1985) (hereinafter
the "Endangerment Assessment"). A brief summary of
site hydrogeology is presented below.

Generally, the site is underlain by the Missouri
River alluvium which is composed of silt, sand,'
and gravel. This aquifer is used as a source of
drinking water by both private residents and
public water supply companies. The water table is
encountered below the site at depths ranging from
5 to 13 feet below' the ground. surtace. The
alluvium generally ranges in depth trom about 70
to 110 feet. Recent investigations indicate the
depth north of the site ranges up to 160 feet.
The bedrock underlying the alluvium is comprised
of interbedded shale, limestone, and sandstone.
Generally, the water table slopes towards the
Missouri River and exhibits a low hydraulic
gradient. During this condition, the groundwater
in the upper layers of the aquifer provides
recharge to the Missouri River. The water table
gradient and groundwater tlow direction can be
altered during high stages ot the Missouri' River.
Wastes at the site can become saturated by the
water table.
d.
Hvdroloav
The CCC site is southwest of the confluence of the
Blue River and the Missouri River. The average
annual discharge of the Missouri River, based on a
2
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78-year average, is about 55,000 cubic feet/second
(cfs) with extremes of 573,000 cfs and 1,500 cfs.
Annual extremes are generally much less with a low
flow occurring in late fall and winter and a high
flow in the spring. The 7-day, 10-year low flow
in the river is approximately 8,447 cfs.

U.S. Geological Survey records indicate that flow
in the Blue River is generally 100 to 1,000 times
less than that in the Missouri River. The Blue
River responds more rapidly to precipitation than
th 3 Missouri River and under some conditions the
flow in the Blue River may approach 10% of the
flow in the Missouri River. Flow in the Blue
River near its confluence with the Missouri River
may range from less than 500 cfs to over 40,000
. cfs.
The areas adjacent to the site flood with an
annual probability of .7% or less. The lOa-year
floodplain has an elevation of 739.93 feet above
msl. However, urban design in this area is for a
500-year flood having an elevation of 743.91 tee~.
above msl. This has resulted in ~onstruction of
the East Bottoms Levee unit to an elevation of
746.8 feet.
e.
Climate
The following climatological data were recorded at
the Downtown Airport in Kansas city, Missouri and
are considered to be representative of the CCC
site and surrounding area. These data were obtain-
ed from the National Oceanic and Atmospheric
Administration (NOAA 1983) and represent a period
of record from 1951 to 1980.
o
Average annual normal monthly temperature is
56.30F;

Highest temperature on record is 1090F;
o
o
Lowest temperature on record is -14°F;

Annual average normal precipitation is 29.27
inches:
o
3
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2.
SITE HISTORY
a~
Waste DisDosal Practices
CCC initiated its activities at the site in 1960,
beginning with construction of chemical treatment'
basins, the process area and a roadway ramp. The
u. S. Army Corps of Engineers, Kansas City
District, issued a permi t to CCC pertaining to
this site.. The permit was expressly limited to
issues related to the public rights of navigation.

Waste disposal operations began at the site soon
after site construction was initiated and
continued until approximately 1980. . The exact
nature and quantities of chemicals and wastes
handled during the site's active operating period
are unknown.. Many site operating records are
reported to have been destroyed in a tire in 1970
Operating records which are available indicate
that the primary materials accepted at' the CCO
site included organics, solvents, acids, caustics,
metal hydroxides, and cyanide compounds. Reports
also indicate that pesticides, herbicides, waste
oils, organic solvents, halogenated compounds,
arsenic and elemental phosphorus were handled at
,the site. In addition, there are reports and some
evidence that pressurized cylinders and other
metal containers were placed in the lagoons. The
facility handled liquidsJ sludges, and solids.
Based upon the available site operating records,
it has been estimated that the following quantit-
ies of material~ were brought to the site:
Acid metal-finishing
wastes:
32.6 million
gallons
Alkaline metal-finishing
'wastes:
10.3 million
gallons
cyanides:
0.4 million
gallons +
38.44 tons
4
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Solvents/organics:
1.7 million
gallons
. .
Miscellaneous wast~s:
0.7 million
gallons +
314 tons
Refinery wastes:
2.5 million
gallons +
719 tons
Arsenic/phosphorus
wastes:
2540 tons
The above totals include 48 million gallons of
liquids and sludges and 1,144 tons of solids,
i.e., roughly 300,000 tons in total. Because the
records are incomplete, these figures are believed
to understate the total quantity of materials
brought to the site.

Most of the materials brought to the site
reportedly were disposed of on site, with or
without treatment. According to the site operator,
the principal exceptions are the cyanides, some of
which reportedly were converted to HeN and
released or burned, and solvents, most of which
reportedly were either incinerated or reclaimed.
However, there is evidence from inventories that
substantial quantities of organic solvents may
have been disposed pf on site.
eee employed a variety of waste handling
practices, including but not limited to solvent
incineration, solvent resale, pickle liquor
neutralization, cyanide complexation, chromic acid
reduction, and ferric' chloride/ferric sulfate
recovery. Residual- materials from the various
treatment processes were generally disposed of .on
site in the basins. Drums, bulk liquids, sludges,
and solids were buried at the site. Some wastes,
such as drummed cyanide wastes and arsenic and
phosphorus containing wastes, were disposed of on
site without treatment.
Estimates based upon the surface areas of the
lagoons (approximately 139,500 sq. ft.) and
reported lagoon depths (up to 18 ft. below the
surface of the site) indicate that approximately
93,000 cubic yards of materials are buried on
5
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-
site. Native materials beneath and adjacent to
the disposal areas were probably contaminated by
the. waste disposal operations.

In 1975, the Missouri ~epartment of Natural
Resources, Solid Waste Management Program
(DNR/SWMP) investigated the site and found it to
be operating as a solid waste disposal area. On
December 15, 1975 DNR/SWMP requested that' CCC
cease the disposal of solid wastes at the site and
that remedial actions be taken to clean up the
site.
In 1977 the Missouri Clean Water Commission
ordered the site closed and covered. A plan for
closure of the CCC site was submitted in June 1979
which called for the addi tion of absorbents and
cementing materials to the waste in the uppermost
5 ft of each basin. Waste acids, predominantly
pickle liquor, and fly ash were mixed with the
upper layer of waste materials in the basins.
Tests conducted on samples of the "stabilized"
wastes in 1985 indicated that the desired
pozzolonic cement-like properties had not formed. ~
Also, there are indications that this material has
deteriorated and will continue to deteriorate.
At present, the CCC site contains miscellaneous
surface structures, such as tanks and buildings,
and the six basins that were used for the storage,
treatment, and disposal of a variety of chemicals,
liquid wastes, and sludges, which are presently
covered. .
b.
CUrrent Site Conditions
The U. S. Army Engineers Waterways Experiment
Station (WES) completed a report entitled "Focus
Feasibility Study for Conservation Chemical
Company Site" in 1985 and, in 1987, prepared a
report entitled "Addendum to the Focus Feasibility
Study" (hereinafter the "FFS" and "FFS Addendum",
respectively). Data collected in previous studies,
including. investigations conducted by EPA, by
Ecology & Environment, Inc. (E&E) under contract
to . EPA, WES, and a remedial investigation
conducted by International Business Machines
Corporation, AT&T Technologies, Inc., Armco Inc.,
and FMC corporation (the Original Generator
Defendants) were used to describe the nature and
extent of contamination. Contamination sources,
6
...
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contaminant migration pathways, potential recep-
tors, and potential risks posed by the contam-
inants are described in the FFS and the FFS
Addendum. The following is a brief summary of the
types and concentrations of conta:.ninants at the
site.
Among the potentially hazardous substances detect-
ed in groundwater beneath and near the CCC site,
21 substances have been detected at concentrations
substantially in excess of applicable criteria or
standards for water quality. Th!se include six
metals, cyanide, four phenolic cot",pounds, and ten
volatile organic compounds (VOCs). In addition,
aluminum and total phenolics (including compounds
other than the four compounds specifically listed)
have been detected at levels sufficiently high to
cause concern for aquatic life. These 23
substances are listed in Table 1, along with the
highest concentrations for each compound reported
in groundwater at or near the site. Trans-1,2-
dichloroethylene has been detected at high
concentrations (up to 47,100 ug/liter). These high
concentrations may be of concern because of the
chemical similarity between this substance and
trichloroethylene, 1,1-dichloroethylene, and vinyl
chloride.
Finally, 2, 3, 7, a-tetrachlorodibenzo-p-dioxin
(2,3,7,a-TCDD or dioxin) has been detected in.
several samples recovered from on site borings
with concentrations up to 29 parts per billion
being reported. The high toxicity of this
compound is well established. A level of 1 ppb has
been recommended as a guideline for permissible
concentrations in soil at some sites where direct
contact with dioxin contaminated soil is likely.

A number of other inorganic and organic compounds
have been detected in soil and qroundwater at or
near the CCC site. The 23 contaminants listed in
Table 1, together with trans-1,2-dichloroethylene
and 2,3,7,a-TCDD, are the primary contaminants of
concern at this site.
7
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3 .
ENDANGERMENT ASSESSMENT
An assessment of the risks presented by the CCC
site is presented in the Endangerment Assessment,
which is an attachment to the FFS. This
assessment indicates that the greatest exposure
pathway is associated with the wastes buried at
the site which are in contact with the aquifer.
These wastes serve as a source for continued
release of contaminants into the aquifier where
they may migrate into and under the Missouri
River, thereby threatening water suppl i.es and
inhibiting future aquifer development. The
aquifer on the north side of the Missouri River
currently is used as a residential drinking water
source. Further development of or increased
withdrawal from this aquifer may draw contaminants
into municipal well fields downstream of the site.

The next greatest risk is presented by
contaminated' surface soils, which are a source of
contamination that may be transported. by
precipitation runoff into surface water bodies o~
the groundwater. Contaminated soils also present
hazards from direct contact and wind dispersion of
particulates. Debris and machinery on the site
surface also are potential contamination sources.
8
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4.
DEVELOPMENT OF ALTERNATIVES
The remedial alternatives for the CCC site were
developed and evaluated in compliance with the
Comprehensive Environmental Response, Compensa-
tion, and Liability Act as amended by the
Superfund Amendments and Reauthorization Act of
1986 (CERCLA), 42 U.S.C. 9601 n ~., and the
National Oil and Hazardous Substance Pollution
Contingency Plan 40 C.F.R. Part 300 (the "NCP").
Section 121 (b) of CERCLA provides that a remedy
shall be selected that is protective of human
health and the environment, that is cost
effective, and that utilizes permanent solutions
and alternative treatment technologies or resource
recovery technologies to the maximum extent
practicable. section 121(b) also establishes
certain preferences when considering remedial
actions, including the following:

a. Remedial actions' in which treatment which
permanently and significantly reduces the volume,
toxici ty or mobility of the hazardous substances,~
pollutants, and contaminants is a principal
element over remedial actions not involving such
treatment..
b. The offsite transport and disposal of
hazardous substances or contaminated materials
without treatment is the least favored alternative
remedial action where practicable treatment
technologies are available. As described below,
these preferences were considered when evaluating
various remedial alternatives.
o
Alternatives specifying on- and-off site
storage, destruction, treatment, or secure
disposal of hazardous substances at a
facility approved under the Resource
Conservation and Recovery Act (RCRA). Such a
facility must also be in compliance with
all other applicable EPA standards (e.g. Sate
Drinking Water Act, Clean Water Act, Clean
~ir Act, Toxic substances Control Act, etc.).

Alternatives that meet all applicable or
relevant federal. public health or environ-
mental standards, guidance, and advisories.
o
9
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o
Alternatives that exceed all applicable or
relevant federai public health or environ-
mental standards, guidance, and advisories.
o
Alternatives that meet CERCLA goals but do
not attain all applicable or relevant federal
public health or environmental standards,
guidance, and advisories.

No action alternatives.
o
Technoloaies Considered in FFS
Prior to the development of alternatives, an
evaluation of general response actions and
technology screening for the CCC site was
performed. The general response actions considered
are based on the findings of the Remedial Invest-
igation, including the analysis of potential con-
taminant exposure pathways. The technology screen-
. ing process considered the waste-limiting (waste~
characteristics that limit the effectiveness or
feasibility of a technology) and site-limiting
(site characteristics, such as soil permeability,
depth to groundwater and to bedrock and location
relative to the ~iver, that preclude the use of a
technology) factors unique to the site, and the
level of technical development adequate for each
technology. The screening of the various tech-
nologies in the FFS was based on the following
criteria which were in effect prior to the
enactment of SARA:
1.
The technology must be reliable, based
either on successful implementation at
other hazardous waste sites, or in
comparable applications:

The technology must be technically
feasible, reliable, and applicable to
site conditions and waste character-
istics at the site, based on
engineering judgement; and
2.
3.
The. technology must be capable, either
by itself, or in conjunction with
10
-:;--~~~t:.OC. T~\-';-'- ,'." ';;~,-
,"""c
-------
other technologies or alternatives, of
addressing the objectives and the
stated environmental goals.

To achieve these objectives, several technologies
were evaluated for the removal, containment and
treatment of wastes and contaminated soils and the
, containment" collection, treatment and discharge
of . contaminated groundwater. Technologies were
screened as required by 40 C.F.R. Part 300.68(g)
to ~liminate those technologies of greater cost
that would not provide substantially greater pro-
tection, that were not feasible or reliable and
that would not effectively contribute to the
protection of the public health and welfare and
the environment.
The technologies that were reviewed in the FFS are
listed in Table :2. The technologies that were
eliminated from further consideration and the
reason for their elimination are specified in
Table 3. The remaining technologies were assembled
into alternative remedies and analyzed in detail
in the FFS. These technologies were reconsidered
in the FFS Addendum.
.'
The source removal technologies considered in the
evaluation included excavation, chemical solidifi-
cation/stabilization and treatment following
excavation in conjunction with various on- and
off-site disposal options. Source isolation
technologies evaluated included surface treatment
(capping, revegetation, floodproofing), vertical
impermeable barriers and on site (interior)
withdrawal wells. Technologies for enabling plume
capture, such as downgradient withdrawal wells and
subsurface drains, also were considered. Treatment
of groundwater recovered by the withdrawal well
would be required. The contaminants of concern are
primarily' heavy metals and organic compounds.
Cyanide also is a potential problem. Heavy metals
would be removed by precipitation and organics
would be removed by biological treatment and
activated carbon. Cyanide removal, if required,
would be accomplished by using alkaline chlor-
ination.
11
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. '.'" ...... .
5.
DETAILED EVALUATIO~ OF ALTERNATIVES
Alternatives developed from combinations of the
available technologies were initially screened in
tbe FFS along with a no action alternative. This
initial screening of alternatives provided the
basis for selecting alternatives for further
detailed analysis. The nine remaining alternatives
are presen~ed in Table 4. Detailed discussion of
all nine alternatives is presented in the FFS.
In mid-19~5, the Government adopted Alternative, 4
(circumferential containment with interior pump-
ing) of the FFS as the remedial action for the CCC
Site. Additional geotechnical investigations per-
formed in 1986, however" revealed that the depth
to bedrock'at the CCC Site ranged up to 160 feet,
such that the construction of a circumferential
impermeable barrier could be more difficult than
originally believed. Furthermore, in late 1985 the
NCP was revised and in 1986 the Superfund
Amendments and Reauthorization Act (SARA) was
enacted. Both of the regulatory changes affected
EPA's review of r-m~niA' alternatives. In lighi
of these changes, aftrt+~i rrl'u,' eval.ua.tions were
undertaken by the EPA to reassess potential
remedies at the CCC site.
To address the changes, especially SARA, addi t-
ional alternative technologies and remedies were
evaluated in the 1987 FFS Addendum. The addition-
al technologies considered are listed in Table 5.
The technologies excluded from detailed develop-
ment in the FFS Addendum are listed in Table 6 and
the additional remedial alte~atives carried
through for full evaluation in the FFS Addendum
are listed in Table 7.
The FFS Addendum provides a comparative analysis
of the following three alternative remedies:
o
Alternative 4. Circumferential containment
with on-site groundwater withdrawal and
treatment of the extracted groundwater
(original 1985 selected alternative)
o
Alternative lOA. On-site containment of
contaminants by on-site pumping: and
o
Alternative 11,
,
treatment.
Excavation followed by soil
12
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The alternatives selected for detailed comparative
analysis were evaluated in the FFS Addendum
according to the following criteria:
Reliability
Implementability
Technical Effectiveness
Environmental Concerns
Safety
Regulatory Requirements
Public Acceptance
Cost
Operation and Maintenance
a.
Reliabilitv
Alternative 4: The major advantage of Alternative
4 is the apparent structural containment of the
waste materials within the circumferential barrier
wall and the relative ease with which the
effectiveness of this remedial action could be
monitored. On the other hand,. there are a number
of uncertainties associated with the design and
construction of such a wall at this site. These
uncertainties are associated with the particular
geology of the CCC site. However, because the
interior withdrawal well system provides
protection to the environment against leakage,
these uncertainties primarily affect the cost of
implementing this alternative rather than its
reliability.

Alternative lOA: Alternative lOA relies on hy-
draulic, rather than structural, containment to
prevent migration of contaminants from the site.
Potential difficulties associated with the imple-
mentation of this alternative include reliance
upon well-maintained water elevation instrumen-
tation to monitor system performance, hydro-
geologic uncertainties which may affect pumping
rates and well locations, and the impact of the
Missouri River on the withdrawal wells. Moreover,
Alternative lOA is dependent on the long-term
13
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-.-..~ ..
" ro-.'
implementation of water treatment technologies to
remove the contaminants from the groundwater
pumped 'from beneath the site. On the other hand,
it is anticipated that problems associated with
this system can be resolved from an engineering
standpoint by. installing additional pumping and
trea~ment capacity.
Alternative 11: The technology employed by
Alternative 11 is relatively new and has not been
tried on a large scale such as would be required.
at the CCC site. Extensi're laboratory and pilot
scale studies would be necess~ry to verify that
this alternative could be successfully imple-
mented. Assuming successful resolution of the
technical issues associated with implementability,
which are discussed below, during such studies, a
reliable Alternative 11 could be constructed.
Conclusion: Both Alternative 4 and Alternative
lOA could be implemented with a high degree of
reliability. While it is believed that Alterna-
ti ve 11 could be implemented , extensive testing,
and studies would be necessary to verify this
prior to implementation.
b.
ImDlementabilitv
Al ternative 4. While' geologic conditions at the
site may make Alterntive 4 more difficult to
construct than was believed in 1985, it is a
technically feasible and constructable remedial
alternative. Because the interior withdrawal well
provides protection should leakage occur, the
issue is one of cost rather than overall technical
implementability.

Alternative lOA. Construction of extraction wells
and a groundwater treatment plant are within the
state of current practice. The major difficulty
with implementation of Alternative lOA is the
development of an adequate monitoring proqram to
ensure that the containment goals are aChieved.
Monitoring of groundwater elevations around the
perimeter of the 5i te to verify constant inward
flow is the most appropriate manner for evaluat-
ing performance of such a system. Specification
of precise pumping rates as a control measure is
inappropriate because the geologic and hydro-
geologic uncertainties at the site make
calculation of precise pumping rates necessary to
14
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- "" ':; r"::-~:l' ~':.-:,-::~5'-7': ~'.:::..:-<'~'_::~:~'-::-~;' ,
ensure adequate capture impossible. Construction
and operation of treatment facilities for
recovered groundwater as required for implementa-
tion of this al ternati ve are wi thin the current
state of commercially available technology.

Alternative 11. Alternative 11 is implementable
at the CCC site assuming that the following
problems are satisfactorily resolved:
1.
Development of a safe methodology for excav-
ation of the waste and contaminated soils.
2.
Development of an appropriate method of soil
washing that will remove all the contami-
nants.
3.
Development of a scheme for disposal of the
treatment fluids and other residuals produced
by the treatment process.
4.
Obtaining additional land adjacent to the
site for construction of the treatment
facilities.
Conclusion: Al ternatives 4 and lOA are im-
plementable based on existing technology. Al-
though there are known technical problems with
each, these problems can be resolved through app-
lication of well known engineering principles. On
the other hand, Alternative 11 applies a new
technology and, as a result, there are substantial
uncertainties associated with implementation of.
this alternative which may take considerable time
to resolve before this alternative could be
implemented.
15
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c.
Technical Effectiveness
Alternative 4. Alternative 4 is technically
feasible and, in combination with the interior.
withdrawal well, would result in physical
containment of the waste materials on site. Wastes
remaining on site would probably tend to
concentrate somewhat; however, the interior with-
drawal well system should protect the slurry wall
from degradation by these chemicals. Alternative
4 could be modified to include a permeable cap
that would allow infiltration to assist in the
:leanup process. This modification would enhance
the flushing process that would remove higher
volume of contaminated groundwater from the site.
There is no methodology available to estimate the
length of time required for cleanup. The on-site
cleanup would include the discharge of treated
wastes containing acceptable levels of
contaminants remaining in the groundwater after
treatment to surface waters and the generation of
solid wastes from the groundwater treatment
processes. contaminants that have already migrated
beyond the containment barrier generally would not
be captured by this alternative.

Alternative lOA. Alternative lOA is technically
feasible, and should result in containment of the
waste materials on-site. Although des'igned'
primarily for containing the on-site contaminants,
Alternative lOA would also clean up a portion of
the off site contamination, including some
contaminants not contained under Al ternati ve 4.
However, while the treatment technologies that
will be employed provide high levels of treatment,
they do not remove 100 percent of the
contaminants. .Thus, discharges to the Missouri
River from the treatment plant would be greater
than with Alternative 4. Alternative lOA includes
a permeable cap that would allow infiltration to
assist in the cleanup process. Theoretically, this
conta-inment would result in eventual cleanup of
the on-site and some portions of the off-site
. contamination, although this cleanup process could
,take a substantial time period.
Groundwater modeling was performed to estimate the
parameters necessary to capture the groundwater
which originates in or passes through the space
beneath the CCC site such as withdrawal well
locations and pumping rates. Also, groundwater
16
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.: ":':;..;:.: ". :,1,. . ~--: '. <" J'-~ ;:""?:~'-'~-=:'-'-7~'-"": ,-"'::"~~ . ',-;.' .-:'~ c
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treatment processes were analyzed to provide a
conceptual design for a treatment system and to
assess anticipated levels of discharge into
surface waters.
There is no methodology available to estimate the
length of time required for cleanup. One could
speculate that Alternative °lOA, which allows con-
tinued migration of the groundwater through the
site, . might result in cleanup at a faster rate
than Alternative 4, however there is no present
methodoJogy to predict how fast either alternative
would remediate the site. This cleanup would
include the discharge of acceptable levels of
contaminants remaining in the groundwater after
treatment to surface waters and the need to
dispose of solid wastes resulting from the
groundwater treatment processes.
Alternative 11. The technical effectiveness of
this alternative would depend upon the successful
resolution of the problems discussed above under
Implementability. Theoretically, if coupled with ~
. qroundwater treatment proqram, both the on-site
wastes and contaminated soils could be .renovated,
and a portion of the contaminated groundwater off-
site could be remediated. However, the technical
effectiveness of this alternative is not .yet
known.
Conclusion: Technically effective remedial
actions based on the concepts contained in Alter-
natives 4 and lOA, could be constructed. There
are still unresolved uncertainties associated with
the technical effectiveness of Alternative 11.
d.
Environmental Concerns
Alternative 4. Whereas technical effective-
ness concerns the primary goal of contaminant con-
tainment, environmental concerns relate to the
secondary impacts of a remedial al ternatve.
Alternative 4, although offering positive contain-
ment of the on site contaminants, results in
several environmental concerns, including:
17
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~, ; ", >;;'~' 'r;;' ~ < 'J.' ':>'~.. ;-'.-." --:'~ ',' ,.':" "c..'-:;;~,,~ -;--:' .t
o
Extraction of a large quantity of
contaminated material during construction
of the containment barrier, which would
probably require disposal in accordance with
RCRA requir~ments.
o
- Discharge of treated groundwater.

Generation of sludges in the groundwater
treatment processes that may require disposal
in accordance with RCRA requirements.
o
Alternative lOA. Alternative lOA. also poses
environmental concerns similar to those associated
with Alternative 4. However, under Alternative
lOA, since the only construction into contaminated
materials would be the on-site extraction wells,
there would not be large amounts of contaminated
material requiring disposal. This factor is
offset by the greater discharges of extracted
groundwater into surface waters .and greater
volumes of sludges generated by the water
treatment.processes.

Alternative 11. The environmental concerns
associated with Alternative 11 are similar to
those of Alternatives 4 and lOA. However, Alter-
native 11 would result in the greatest short-term
impacts because the wastes and contaminated soils
would be excavated, resulting in the potential for
release of contaminants through the air and sur-
face water pathways. Although the potential for
release can be minimizd through proper planning
and design, it cannot be eliminated. Alternative
11 would also involve the discharge of low levels
of contaminants and generation of treatment plant
sludges requiring disposal.
Conclusion: Each of the alternatives raises a
number of environmental concerns. Efforts should
be made during the remedial design to minimize
environmental consequences of the remedial action
selected.
e.
Safetv
Alternative 4. The construction operations assoc-
iated with Alternative 4 pose the potential for
contact with large quantities of contaminated
materials. Thi~ potential contact presents the
18
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'-?~):":~~:i:-",-';,\'';l.'Eo<~~': c:",:-~'"' t
-------
primary safety concern for this Alternative.
Proper planning and design can minimize these
concerns, but not eliminate them.
Alternative lOA. Alter~lative lOA involves some
potential contact with contaminated materials
during construction of the on-site extraction
wells and, to a lesser degree, the monitoring
wells. However, this potential for contact is much
less for Alternative lOA than for the other
alternatives. The handling and disposal of treat-
ment chemicals, and slucges, would involve poten-
tial exposure to cont~inants. The potential
exposures could be minimized through proper
planning and design. Also, potential hazards
. associated with the sulfide precipitation process
would be minimized by proper planning and design.

Alternative 11. Implementation of Alternative 11
may result -1n the greatest potential for safety
related problems because it invol ves the excav-
ation of wastes and contaminated materials. The
safety risks include direct exposure to toxic
materials, exposure of elemental phosphorus to air~
(causing cOmbustion), and rupture of pressurized
gas cylinders. The quantity and nature of
materials thought to be present on the CCC site
make excavation of the materials potentially
risky. Although detailed planning, design, and
implementation can minimize the potential safety
problems to on- and off-site personnel, they can-
not be totally eliminated.
Conclusion: Alternative 4 and
constructed with an adequate margin
both on- and off-site personnel.
safety risks for Alternative 11
greater.
lOA can be
of safety for
The potential
appear to be
f.
Reaulatorv Reauirements
Implementation of each of the three alternatives
involves consideration of a number of regulatory
requirements falling withiri the jurisdiction of a
variety of regulatory agencies. Specific require-
ments which are applicable or relevant and
appropriate to this remedial action are discussed
in Section 7, below.
19
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g.
Public AcceDtance
Alternative 4. Alternative' 4 would result in the
positive containment of the source of on-site
contamination and address the m~jor environmental
and health problems created by the CCC site.
Because existing off-site contamination including
any potential migration of non-aqeous-phase
liquids (NAPL), is not specifically addressed by
this alternative, the public may not view this
alternative alone as an acceptable remedy for the
site.
Alternative lOA. Alternative lOA would result in
the containment and some treatment of the primary
source of on-site contamination and the cleanup of
some contamination that has already migrated off-
site. There may be some concern by the public
regarding off-site contamination, but that level
of concern should be less than for Alternative 4.
Alternative 11. Because Alternative 11 would
result in the removal of the source o~
contamination and some cleanup of contamination'
that has migrated from the site, Alternative 11
probably would be viewed favorably by the public.
This favorable view may be offset by concerns over
the ability to excavate safely the waste materials
and contaminated soils and to treat them properly
prior to placement back on the site. The public
concern regarding off-site contamination is
expected to be comparable to that for Alternative
lOA.. .
Conclusion: No major public acceptance problems
have been identified or are expected with any of
the three alternatives. Thus, the alternatives
are generally equivalent based on anticipated
public acceptance.
h.
~
The 'estimated. capital and operation and
maintenance costs and present worth ot each of the
three alternatives is presented in Table 8. The
present worth was calculated over a thirty-year
time period using a discount rate of 10 percent.
This cost estimates are based on the best
engineering judgement using currently available
information. There are a number of uncertainties
associated with each of these alternative and are
20
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.-.-c':- 'f'"':.~':- :","'-:1::':::-'-~'<. ~~~.,;(.:.-;-~,~ .,.~;.1C ',; ~"':;~'~'.';"~~~':--;-' ,. p.c.>"~::::"~~':----=:,:::;,:'..;:~y-
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discussed in more detail below. The discount rate
of 10 percent was used, based on United states
Office of Management and budget (OMB) Circular No.
A-94 (revised) dated March 27, 1972.

Alternative 4. The present worth estimate for
this al ternati ve is $17.09 million. The cost of
Al ternative 4 cannot be .calculated at this time.
primary uncertainties which prevent such a
calculation include the cost of constructing the
containment barrier and the pumping rate which
would. be required to maintain an inward hydraulic
gradient, and the requisite cost of truating the
extracted groundwater prior to discharge. These
uncertainties could substantially impact the
actual cost of this al ternati ve. As shown in
Table 8, the estimated cost of Alternative 4 is
primarily for capital expenditures.
Alternative lOA. The present worth estimate for
this alternative is $21.4 million. The cost of
Alternative lOA cannot be calculated at this time.
Primary uncertainties which prevent such a
calculation include the required pumping rate to'
maintain an inward hydraulic gradient and the
requisite costs of treating the extracted
groundwater. These uncertainties could substant-
ially impact the cost of implementing this
alternative. As shown in Table 8, the estimated
cost of Alternative lOA is primarily for operation
and maintenance of the remedial action.
Alternative 11. The present worth estimate for
this alternative is $23.4 million. The cost of
Alternative 11 cannot be calculated at this time.
The primary uncertainty associated with
Alternative 11 is the cost of excavating the
contaminated soils and sludges and the cost of
handling residuals from the soil treatment
process. Furthermore, since this alternative
employs a relatively new technology which has not
been implemented on as large a scale as required
at the CCC site, the data base upon which this
estimate is based is much less complete than those
for Alternatives 4 and lOA. These uncertainties
could substantially impact the cost of implement-
ing this al ternati ve. As shown in Table 8, the
estimated cost of Alternative 11 is approximately
the same for capital expenditures and operation
and maintenance.
21
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Conclusion: The estimated costs for each of the
alternatives are similar. While there are a
number of uncertainties for each alternative, in
relative terms, the uncertainties are probably the
least for Al ternati ve lOA and the greatest fc.r
Alternative 11, with Alternative 4 lying somewhere
in between. .
i.
ODeration and Maintenance
This section addresses the skill levels a~d
potential time periods required for operation a1d
maintenance acti vi ties, rather than the cost of
operation and maintenance, which are addressed
above.
Alternative 4. Operation and maintenance activi-
ties associated with Alternative 4 involve
maintenance of the surface cap and containment
wall, and operation and maintenance of the
groundwater treatment system and groundwater
monitoring system. .With the possible exception of
maintenance of the barrier wall invol vinq repair~
of a breach in the wall, each of these activities
require skill levels which are generally
available. Repairing a breach in the barrier wall
would be a specialized process. Operation and
maintenance for this alternative would be required
until the wastes no longer need to be contained,
~ all applicable or relevant and appropriate
requirements ("ARARs") have been met.
Alternative 10. Operation and maintenance activi-
ties associated with Alternative lOA involve
maintenance of the surface cap and operation and
maintenance of the groundwater monitoring system.
Surface cap maintenance would require similar
skill levels to that required for maintenance of
the surface cap for Alternative 4. The operation
and maintenance requirements for the groundwater
monitoring system similarly would be much qreater
than that required for Alternative 4 because the
water level differentials being measured are much
.smaller and would therefore require much more
sensitive water level instrumentation than
required for Alternative 4. Since there would not
be a barrier wall to maintain, there would not be
a potential need to repair a breach in the wall.
The overall skill levels required for Alternative
lOA are generally available. Operation and
22
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maintenance for this alternative would be
necessary until all ARARs have been met. Since
this is an act~ve pumping system, the time period
to meet ARARs might be shorter than for
Alternative 4.
Alternative 11. Operation ~nd maintenance
activities associated with Alternative 11 include
excavation and t~eatment of contaminated soils and
sludges. These activities require significant
skill - levels during operation of the active
remediation process. The needed skill levels are
believed to be less readily available for this
alternative than for the others in that fewer
contractors have experience with this technology.
Long term operation and maintenance requirements
for Alternative 11 would be minimal.
Conclusion: Each of the alternatives considered
would require persons with some level of
specialized skills for operation and maintenance
activities. In relative terms, Alternative 4 and
Alternative lOA would require approximately the,
same level of skills. - Alternative 11 would"
require a higher skill level but over a shorter
time period.

Alternative 4 probably would require the longest
period for operation and maintenance. Alternative
lOA might require a somewhat shorter operation and
maintenance period than Alternative 4. Alterna-
tive 11, if feasible, should require a substan-
tially shorter period of operation and maintenance
than either Alternative 4 or Alternative lOA.
23
o A,~
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'.~~ .:; .' 7:""o'-:~,;-'::1 !;o':-:.-.~''-:.I:(-':''..i:.-''-'':O' ~~-:~',' -~',~:i~.\:'~:'. ~
6.
SELECTED ALTERNATIVE
Based ~pon the evaluation of remedial alternatives
described in section 5 and consideration of the
applicable or relevant and appropriate legal
requirements, described.__in section 7, below, an
active pumping containment system, which was
evaluated as Alternative lOA, is selected as the
remedial alternative for this site. This
alternative is consistent with the general
requirements of Section 121 (b) of CERCLA that a
remedial action shall be selected which is
"protecti ve of. human health and the environment,
that is cost effective, and that utilizes
permanent solutio~s and alternative treatment
technologies or resource recovery technologies to
the maximum extent practicable."
A remedy employing an active pumping system would
be protect;ve of human health and the environment.
Contaminants present at the site will be contained
at the site, thereby eliminating further
uncontrolled releases into the environment.-
Contaminants present in the groundwater extracted.
to achieve hydraulic containment will be properly
treated prior to discharge. Potential environ-
mental impacts of wastes generated during
construction of the remedial action are also less
than those presented by the other alternatives
considered. Finally, because an active pumping
system relies upon the use of currently available
technology, which can be constructed in the
shortest time frame, this al ternati ve would
provide expeditious implementation of the remedial
action with substantial certainty as to its
effectiveness in protecting public health and the
environment.
Furthermore, an active pumping system containment
system would provide a cost effective remedy for
the site. Given the uncertainties associated with
implementation of any remedy at the CCC si te,
Alternative lOA may prove to be the least costly
remedy that would meet the environmental goals and
requirements of CERCLA~ Treatment of hazardous
substances to reduce their volume, toxicity and
mobility by treating .the extracted groundwater is
the principal element of Alternative A.
Alternative 11 also involves treatment which
reduces the volume, toxicity and mobility of the
hazardous substance present at the site. However,
24
. - ~~;;'~g',~:-F':-'~~~t;7~~~';;::-z ?~;"r.-:ri'V< .
-------
the uncertainties of its technical feasibility at
this site raise substantial question as to its
practicability. Extensive research would be
necessary prior to its implementation to resolve
this question. For these reasons, Alternative lOA
offers treatment to the maximum extent
practicable.

A more detailed' discussion of the applicable. or
relevant and appropriate legal requirements is
presented in section 7 below.
The selected remedy
following features:
would
incorporate
the
a.
Surface C1eanun/Surface Prenarat~on

The on-site building will be demolished and
its basement filled to grade.
o
o'
The septic system will be demolished or
grouted. All other depressions will be
properly graded in such a manner that the cap
integr.ity will be maintained.

All existing tanks and solid debris remaining
on site from of CCC's past operation the
facility either will be cut into pieces for
incorporation under the cap or decontam-
ination and disposed of off-site.
o
o
The existing surface of the CCC Site will be
regraded utilizing on-site soils to the
fullest extent practicable to fill in local-
ized depressions prior to installation of the
cap.
b.
Protective
Surface Can
A two-layer cap for the CCC Site will be
constructed as follows:
o
The lower layer of the cap will be construct-
ed over the existing fill and will consist of
at least 18 inches of geotechnically 'stable
loess, locally available.

The upper layer (vegetated top cover) will be
at least 6 inches of top soil, able to
support persistent vegetation, and will be'
o
25
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-------
planted. The cap will have ,a final slope not
less than 3% and will have a surface drainage
system capable of conducting runoff across
the cap without erosion rills.
o
provision will also be made for paved chutes,
flumes or rIgid downpipes to transport water
down the steep sided embankments. These
emb'ankments will have a slope not, greater
than 5:1 (horizontal:vertical).

The embankments of the cap and site will be
protected from floods with a layer of riprap.
o
o
At the end of the remedial action, a
permanent cap to meet the then-existing
regulatory requirements will be provided.
c.
withdrawal Well Svstem
An on-site groundwater withdrawal well system
designed to capture all of the qroundwater
emanating in or passinq throuqh the site will be~
installed. This system will be designed so that
its performance can be verified by determininq
differences in water levels at paired piezometers
surroundinq the site.
If the withdrawal wells installed are not capable
of meetinq the performance standards I then
additional wells will be installed to provide
sufficient pumpinq and treatment capacity as
needed to achieve the performance requirement as
soon as practicable.
d.
Ground Water Treatment Svstem
o
A system for treatinq water extracted by the
withdrawal well system will be constructed
and operated in such a way that the effluent
from the facility is discharqed at a level
that will meet any effluent limits establish-
ed under the Missouri Clean Water Law or the
Federal Water Pollution Control Act.
The treatment system will include, at a
minimum, such treatment processes as metals
precipitation (utilizing both hydroxide and
sulfide precipitation), filtration,
biological treatment, and carbon absorption.
Treatment processes that'provide an
26
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-------
equivalent level 6f performance may be
substituted for those listed above. The
metals precipitation units will be designed
and operated in a manner which seeks to
attain the following levels:
METAL
DESIGN VALUES. ua/l
o
Al 100
As 50
Cd 2
Cr 20
Fe 20
Pb 5
Ni 150
Zn 30

Additional studies will be performed of the
contaminated groundwater to determine whether
alkaline chlorination is capable of reducing
the level of cyanides at the site.

All State of Missouri requirements which are
applicable or relevant and appropriate,
including applicable Missouri effluent
limits, will be met.
o
All sludges generated by groundwater extract-
ion and treatment facility operatIons shall
be managed in accordance with all applicable
regulations.

Discharges of contaminants to the air by the
groundwater extraction and treatment facility
construction, operation, and maintenance will
be in accordance with the Clean Air Act and
all applicable regulations.
o
e.
Off-site
Svstem
Oualitv
Monitoring
Groundwater
o
A number of monitoring wells (approximately
12) will be installed to monitor water
quality and groundwater elevations. The
location of these wells will be determined
in the design phase.
o
The water quality and groundwater elevation
surveys will be conducted quarterly for the
first three years ~ith analysis for priority
27
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-------
"I,e, .?f.~~ 'j~::f;~-"1~,::~:,:::::~c;c~~-/ ~~~<)'"~-j~,~::-:~... "::--'
o
pollutants and other selected water quality
parameters.

After the first three years the groundwater
quality and ground~ater elevations will be
monitored according to the following
schedule:
Years 4-5
Quarterly
Years 6-20
Annual
Years 21-30
Biennial (every two years)

Complete reevaluation of
water monitoring program;
determination of need
for future.
Years 30
These schedules may be adjusted depending on the
data developed during the monitoring program. All
analyses of samples will be performed using EPA
approved protocols, handling, reporting and chain
of custody procedures, all of which will be
described in detail in a groundwater monitoring
plan, to be developed during the planning or
design phase of the remedial program.
f.
Ooeration and Maintenance Proaram
o
An Operation and Maintenance (O&M) Plan will
be developed and implemented for the CCC Site
which provides a schedule and description of
maintenance activities.
o
The O&M Pl~n will include provisions for the
cap, perimeter fence, monitoring wells, water
level recorders, wastewater treatment system,
sewer lines and any other structures con-
structed or installed pursuant to this
remedial program.
28
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.,;."."...,
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7 .
APPLICABLE OR RELEVANT AND APPROPRIATE
REOUIREMENTS
The discussion in the sections above and the data
and discussions presented in the Remedial
Investigation Report and the FFS and FFS Addendum
establish that substantial amounts of hazardous
substances currently are present on site, in the
groundwater and in the soil; that many of these
hazardous substances are present in high
concentrations; and that several of these
'hazardous substances are pot'ential carcinogens.
The presence of these hazardous substances at such
high concentrations potentially poses several
types of risks. First the groundwater is not
suitable for use as a drinking water source
because of the contamination. Second, the
contaminated soil may pose a risk through direct
contact. Third, the contaminated soil also poses
an indirect risk in that, if it is left
unremediated, the contaminants will continue to
migrate into the groundwater and prolong anq
exacerbate the groundwater contamination. This
contamination prevents the present use and will
prevent the future use of the groundwater as a
drinking water source. In short, the site in its
current condition presents a threat to human
he'al th and the environment in several ways.
The applicable or relevant and appropriate
requirements for these three areas are discussed
below.
a.
Groundwater Contamination
The goal of this remedial action is to restore
groundwater to drinking water quality for possible
use as a drinking water supply. The Agency has
considered seven sets of standards for groundwater
quality: maximum contaminant level goals (XCLGs),
maximum contaminant levels (XCLa), water quality
criteria, health advisories, the concentration
limi ts calculated from potency factors and
verified reference doses (RFD), and RCRA
groundwater protection standards.
Recommended
those seven
criteria:
cleanup levels were
categories according
selected
to four
from
basic
29
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". ,:.~'-<>r "'-'~ ""-."~ '-l~'.."'~- r...,- CC"'-~.";'-C';'.:~
- '.,~~': . "-: .; ':'.! <
1.
Where a chemical causes both carcinogenic and
noncarcinogen~c 7ffects, ~hetclea~up levels
.must be set w1th1n the 10 4 0 10 7
risk range.

Where two standards or criteria describe the
same effect for the same chemical, the more
recently derived standard (based on more
recent scientific information) was chosen.
2.
3.
MCLs and non-zero MCLGs were taken as the
~~int of departure for evaluating cleanup
levels.
4.
Total risk_from al!,carcinogens should be
between 10 to 10 .
Section 121 of SARA outlines the cleanup standards
for remedial actions at superfund sites. The
primary standard is that remedial actions must
assure protection of human heal th and the
environment. SARA further requires that a remedial
action meet applicable or relevant and appropriat~
standards, criteria, or limitations. SARA spec-
ifies that: "Such remedial action shall require a
level or standard of control which at least
attains Maximum contaminant Level Goals and water
quality criteria where such goals or criteria are
relevant and appropriate under. the circumstances
of the release or threatened release" (SARA
121(d) (2».
As noted above, seven groups of federal standards,
cri teria and other health-based levels might be
used for cleanup standards for groundwater at the
CCC Site. Potential cleanup standards include the
following:
Maximum Contaminant Level Goals (MCLG), estab-
lished .under the Safe Drinking Water Act. MCLGs
are nonenforceable heal th goals, set at levels
where no known or anticipated adverse health
effects will occur to exposed populations, and
which allow a margin of safety.
Maximum Contaminant Levels (MCL), established
under the Safe Drinking Water Act. These are the
maximum contaminant concentrations allowed in
regulated public water supplies. MCLs represent a
balance between the MCLGs and technical
limitations: they are based on a chemical's
30
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C:.L:;~~~~:':-~CC:-<. '~i--::.';;'-'~::-"\ . :'.'C~!,'-<'.V-',~ -~'"' "",':~. -~;~'7'::':~ .""~~-C-.---::~~f": ~.~. ,:;;:,-:-. ~'T'-';'~'~J":- :~ :"~";>-:-:'~;"'~'-':!',::.~''-
. ;:~, ~~-;,Ic. ;:::'~'-::""'~".":~ ~T -< -~~,~. . ' :.~ .
-------
toxicity, treatability, cost effectiveness and the
analytical limits of detection. All MCLs are set
for non-carcinogens at no adverse effects l~vels,
and for carcinogens within the 10-4 to 10-7 risk
range.

Health Advisories (RA), developed .under the Safe
Drinking Water Act for contaminants not having a
MCL. Heal th Advisories may apply to short term
exposure, long term exposure or chronic exposure..
Water Qualitv Criteria (WQC), for Human Health
established under the Clean Water Act. The
original WQc assumed that people drank contam-
inated surface water and ate contaminated fish
that grew in that water.

The criteria for freshwater aquatic life are
relevant to this site since groundwater discharges
to surface water.
Verified Reference Doses (RFD) , developed by an
intrA agency EPA workgroup~ These values represen~
an acceptable daily intake of noncarcinogenic
chemicals (or, for a carcinogen, an acceptable
daily intake of that chemical considering its
noncarcinogenic toxicity). The corresponding
acceptable concentration of a contaminant in
drinking water is calculated by assuming that a
typical 70 kg person drinks 2 liters of water per
day.
potencv Factors (PF), developed by EPA to charac-
terize the potency of a given carcinogen. These
factors are used to estimate the incremental in-
crease in cancer in a large group of people due to
chronic exposure to a carcinogen at a given
concentration. The calculations assume that. a
typical person weighs 70' kg and drinks 2 liters of
contaminated water per day.

Groundwater Protection Standards Established
under the Resource .Conservation and Recovery Act
(RCRA) . These standards directly apply to the
groundwater at regulated facilities that treat,
store, or dispose of hazardous waste in surface
impoundments, waste piles, land treatment units,
or landfills after November 19, 1980. If contam-
inant concentrations exceed the standard, the
facility owner/operator must begin corrective
action.
31
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MCLs were the first set of standards considered
for cleanup levels. MCLs have been proposed for a
number of the contaminants of concern at the CCC
si te. MCLs represent safe contaminant con-
centrations in public 'later supplies. Most public
water supplies should be fairly clean, even before
treatment. In contrast, qroundwater at the CCC .
site contains many toxicants.
Ambient Water Quality criteris (AWQC),. were the
next set of standards considered, as specified in
SARA. These levels were calculated from the
criteria for exposure to both contaminated water
and fish listed in the 1980 water quality criteria
documents. EPA updated the water quality criteria
in i986. The 1986 Water Quality criteria states
that for the maximum protection of human health
from potential carcinoqenic effects, the ambient
water concentration of carcinoqens should be zero.
However, the document acknowledqes that the zero
level may not be achievable and presents a ranqe
of concentr.ations associated with tn increm"mtal
increase in cancer risk between 10- and 10- for
each carcinoqen. For contaminatfd qroundwater at
the Superfund sites, the 10- level is the
startinq point for evaluatinq risks. Table 9
lists the water6quality criteria for human health
for the 1 x 10- risk level.
For noncarcinogens, water quality criteria, Health
Advisories, and contaminant concentrations calcu-
lated from verified reference doses (RfD) may be
appropriate cleanup levels. For carcinoqens,
Health Advisories suggest concentration limits
that guard against noncarcinoqenic health effects.
For example, vinyl chloride is a known human
carcinoqen with a lonq term health advisory. of 46
uq/l. Vinyl chloride may cause liver damaqe and
other noncancerous disorders after lonq term
exposure. The health advisory of 46 uq/l should
prevent these effects, but will not preclude an
increase in cancer incidence in a population
exposed for a lifetime to vinyl chloride at that
level. The MCL for Vinyl Chloride is 2 uq/l.
Contaminant levels calculated from verified
reference doses also refer to noncarcinogenic
health effects after chronic exposure. For
example, methylene chloride is a probable human
carcinogen. The concentration limit calculated
.32
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-'---~.-o."- ::. "'. ,
-------
,- :' .,;>",:;~~-c~ ~ ~7:--<;:- '~, ":,.,~~"'~";'i-'~~:: ~;~'~:,.:-:;::~~? ~:~.-:~~ .\.J.; ~"', :"T-(-:~' ::-,"
from the RfD is 2100 ug/l. This limit represents
an acceptable daily intake from drinking water
which should prevent (noncarcinogenic) damage to
the central nervous system and the heart
associated with exposure to ".I1ethylene chloride.
However, lifetime exposure to 2100 ug/l methylene
chloride in drinking water may cause an increase
of 17 cases of c~cer in an exposed population of .
20,000 (8.4 X 10- ris~ level). '
Verified reference doses represent. a recent
consensus among EPA scientists on acceptable daily
intakes of toxic chemicals. Therefore, more
weight was given to reference doses than to the
older water quality criteria for human health and
Health Advisories when evaluating possible cleanup
levels. Of the few 'noncarcinogtens which have
nonorganoleptic criteria, the 1986 Water "Quality
Criteria specifies that RfDs should replace the
older water quality criteria for human health.
Groundwater protection standards set under RCRA
were the last set of standards considered for tha
site. These standards, which apply to hazardous'
waste treatment, storage or disposal facili ties,
do not legally apply to the site but may be
considered relevant and appropriate.

Portions of 40 C. F .R. Part 264, Su}:)part F, are
relevant and appropriate because they address
situations similar to the site, notably, situat-
ions where hazardous wastes are present in both
the soils and the groundwater. Su}:)part F provides
that groundwater must be cleaned up to background,
to MCLs, or to risk-based alternate concentration
limits (ACLs). The Agency thinks it appropriate
to restore the groundwater on-site, as well as the
groundwater off-site, to drinking water quality.
As noted above, this is an aquifer that is used as
a drinking water source now, and the use ot which
can be expanded by cleaning up this site to ensure
that all potentially usable groundwater is of
drinking water quality.
The Agency's Groundwater Protection Strateqy
(GWPS) promulgated by the Office of Groundwater
Protection in August 1984, provides guidance
concerning how different groundwaters throughout
the country should be classified and to what
extent cleaning up a particular groundwater is
appropriate, given where it fits in the
33
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classification scheme.
The GWPS provides that EPA's policy ,on groundwater
protection should consider the highest beneficial
use to which particular groundwater can presently
or potentially be put. It defines protection
policies (i.e., policies concerning ~evels of
protection and cleanup) for three classes of
groundwater, 'based on their respective value and
their vulnerability to contamination. Class I
groundwater is special groundwat~1:' that is
irreplaceable (i.e., no reasonable alternative
source of drinking water is available to
substantial populations) or' ecologically vital
(i. e., the aquifer provides the base flow for a
particularly 'sensitive ecological system that, if
polluted, would destroy a unique habitat). Class
II groundwaters include groundwaters that are
current or potential sources' of drinking water and
waters having other beneficial uses. Class III
groundwater is not considered to be a potential
source of drinking water and to be ot limiteq
beneficial use (i.e., groundwater that is heavily.
saline or is otherwise contaminated beyond levels
that could be cleaned up). To fit into Class III,
groundwater also cannot migrate to Class I or II
groundwater or have a discharge to surface water
that could cause degradation.

The groundwater that underlies the CCC site is
Class II groundwater. This groundwater is
considered to be a current drinking water source
since groundwater is used for drinking water
within a two mile radius of the site. The natural
condition of the groundwater makes it possible to
develop the area, including installation of
drinking water' wells in the future. This
groundwater also migrates to and is part of a
Class II groundwater aquifer that is being used. as
a drinking water source now.
Based upon 'the above considerations, until such
time as alternate concentration limits tor those
contaminants of concerns 'are established, EPA has
determined that the appropriate levels for
groundwater cleanup are those levels noted in
Column 2 of Table 9.
34
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b.
Discharqe to the Missouri River
The selected remedial alternative involves
discharging groundwater withdrawn from beneath and
adjacent to the CCC Site into t:he Mi.ssouri Ri'/er..
Therefore, appplicable or relevant and appropriate
requirements pertaining to this discharge must be
considered. Both the Federal Water Pollution
Control Act, 33 U.S.C. 1251 ~ ~., commonly
referred to as the Clean Water Act (CWA) , and the
Missouri Clean Water Law, RSMo Chapter 204, are
applicable or relevant and appropriate to such
discharges.

The state of Missouri has identified, on a
preliminary basis, applicable effluent limitations
for discharge into the Missouri River as part of
this remedial action. (See Attachment 1). The
final effluent limitations will be established
during the actual permit issuance process and will
be met. In addition, tile effluent limits set
forth in Attachment 1, at a minimum, will be
required for any discharge. The State of Missouri~
has been authorized. to administer the National
Pollutant Discharge Elimination System (NPDES)
permit program within its state boundaries. Thus,
the State is required to set effluent limitations
based upon effluent guidelines promulgated by EPA,
if applicable. In this instance, EPA has not
promulgated effluent guidelines for discharges
from hazardous waste sites and the preliminary
effluent limitations are based upon best
professional judgment, including consideration of
effluent guidelines for industries with. effluent
streams similar to the CCC Site. These effluent
limits will be reviewed and, if appropriate,
revised at least every five years.
In addition, to ensure adequate protection of
public health and ~e environment EPA has
determined that the use of sulfide precipitation
and filtration technologies are necessary for
maximum removal of certain metals from the
discharge. The expected discharge levels to be
achieved by the metals treatment processes are as
follows:
35
- "1.'. -.'. ~"'o;"'. r -~. --, '..-'-'",=-.,...,"'~ ,,~,- "Co.,'" .",.~, ."..,~ -'.1'-." '.'.~--'- --,~----~
"""-".';~:."":'~-=' ..._,-~_." --'
-------
METAL
DISCHARGE VALUES. ua/l
Al
As
Cd
Cr
Fe
Pb
Ni
Zn
100
50
2
20
20
5
150
30
The treatment levels required by the effluent
limitations and to be met using the treatment
technologies selected for this site are both
achievable and protective of public health and the
environment. This conclusion was reached after
analysis of the applicable literature and review
of other treatment plants currently in operation.
Also, this conclusion was reached after comparison
of cleanup levels to the levels of contamination
posing a threat' at the site as described in the
Endangerment Assessment.
c.
Soil contamination
Remedial action is necessary to prevent endanger-
ment posed by direct contact with contaminated
surface soils. RCRA closure requirements are re-
levant and appropriate for addressing such soil
contamination. (See 40 C.F.R. Part 265).

Remediation of surface soil contamination will be
approached in two phases.. During the course of
the pump and treat phase of the remedial action, a
permeable cap will be in place over the site.
This permeable cap will protect against direct
contact with the contaminants while allowing
infiltration through the surface. This infiltra-
tion will inc.:rease leaching of contaminants from
the soils, thereby allowing capture and treatment
of the released contaminants. Upon completion of
the pump and treat program, ~ completion of
groundwater cleanup, the si te will be capped in
accordance with the RCRA closure requirements in
effect at that time.
36
, "c;:,;' -c..>;::'l.H_'-~,-.7""'C.'" '-i~c:"<"'- -'"
~'~'~2i::--,-;tJ.~",,"'~;~:' ~ ,-.
. ..-,..~'c-", ~~. - ,-' "'.' "j'" . r;' ":;' . . r-
[' --,-.. -;-. ~ -;'-"",'-"0':0 .,~, o...~ . ~ " . "0' -.
. .' 'r.'~ c' -,' .~.-.>., ",'
-------
d.
Conclusion
The soil and groundwater at the CCC Site contain
high concentrations of a wide variety of hazardous
substances. Because these hazardous substances
are present, the' site poses a threat to human
heal th and the environment. The remedy selected
by EPA minimizes the risks posed by direct contact
with the contaminants by limiting site access and
capping the site. Furthermore, the selected
remedy minimizes the actual or potential
endangerment posed to human. heal th by ingesting
contaminated groundwater or to aquatic life by
movement of contaminated groundwater into the
Missouri River by containing the contaminated
groundwater on the site and allowing a discharge
to surface waters only after proper treatment.
Since all TCDD containing samples were obtained
from sludge and surface soil samples, the waste
containment strategy and surface cap will minimize
possible contact with TCDD.
37
~'1 ".'~",-'~' .',' ~'''., .-., ;,-~---".r .., r':'-~_~'.--=-=--..':;.~i~" ..-
. ~.!,'-l'" '
" "l'''," '.r_',' "_..-']">--" '~"'~"--' -, '~ . - ".' .," J' ..',.;" -==-.--,", ",,""---Y,C.)O- "
--;'''"~-- I~-,"-- , "C-:-' ".:;-,-," '-'r" ',~"-,~ --. _.' '.",".'10-:-
-------
SCHEDULE

EPA anticipates that the remedial design and
remedial action will be completed according to the
following time frame.
8.
1.0
Remedial Desian:
A.
B.
C.
Final design Plans and specifications
for Surface Cleanup and Surface
Protection Cap will be completed in
seven months.
Final design plans and specifications
for withdrawal well and groundwater mon-
itoring system will be completed in
eight months.

Final design plans and specifications
for water treatment facility will be
completed in twelve months.
2.0, Remedial Actions:
A.
B.
Surface Cleanup and installation of the
Protective Cap will be completed in
seven months.
Installation of withdrawal well,
monitoring system and water treatment
plant will be completed in ten months.
38
", .~'C-'~-.-::~ ':; ::~;:.-. ',~' '- ~~;~":"~\~o'~':;;;'~', -: :~~<'':,'.',---':.~ ',::,._.."...\-~,.,:, .c.c'~ ~,';.'.:' :'~ ---::J~-:.Z':::':.'.'~" ~77:,;~<;'-:,},:"T:.",~ ;',::~~'~'~~<',J:'L~.;;""~~~C\~,,"-' "-';,~-',;~< ~~ '~~~:,'.:':?:'~;i<;~:::':_' ~ ,:,' -;--:'~~ ',. ~;.',",::::' I~,::r.:~o.:; ~";.:;7:- .,.' ~o'-~':=-':
-------
. - . " ..,
'."" -. "
~' .. . ..., , '
9.
COMMUNITY RELATIONS

The public .has been informed of the status of
EPA's activities regarding this site on several
occasions. Generally, few comments have been
received in response to the various public notices'
and press releases issued regarding the site,
which indicates a low level of community concern.
No 'major public concerns have been received at
this time. Specific community relations ativities
are summarized as follows.
On April 23, 1985, EPA issued a public notice
requesting comments from the public on the draft
Remedial Investigation Report prepared by the
Original generator Defendants and a draft Focus
FeasibilLty Study prepared on behalf of the EPA.
On August 2, 1985, EPA issued a press release
announcing that an agreement had been reached with
the Original Generator Defendants whereby those
parties would implement the remedial action.

On October 8, 1985, EPA issued a public notice.
announcing that a hearing open to the public,
would be held before the U. s. District Court
Judge presiding over the litigation concerning the
CCC site. The issue considered was the approval
by th$ Court of the Preliminary Agreement reached
by the government and the Original Generator
Defendants.
On March 26, 1987, EPA issued a public notice as
to the availability of the FFS Addendum and other
documents relevant to selection of a remedy and
requested public comment on remedial alternatives.
The public comment period, which was originally
scheduled to close on May 4, 1987, was extended as
the result of requests received during the comment
period. The public was advised of this extension
during the comment period. Written comments were
received from three persons, which comments are a
part of the record con~idered in selecting a
remedial action for this site. The nature of
these comments and EPA' s response to them are
presented in Section 11 of this document.
On April 10, 1987,
announcing that EPA
meeting to receive
alternatives for the
a public notice was issued
was going to hold, a public
comments regarding remedial
si~e. A public meeting was
39
-., -;'-'-~~";>"-'''.~''- '''-''--
'-I"', '--".'l -,--;-=<~~:;;-,..--:-c_"..o,,--' '~-".~-,,-
-------
held on April 23, 1987, during which one person
offered comments. This comment and EPA's response
thereto are presented in Section 11 of this
docUment. .
~
40
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10.
ENFORCEMENT ANALYSIS
Remediation of this site has been the subject of
ongoing litigation since September 1980, when the
united States first sued Conservation Chemical
Company. In November 1982, a'separate complaint
was filed against not o.nly Conservation .Chemical
Company but also its President, a related
corporation, and four companies believed to be the
largest contributors of the contaminants of
greatest concern at the site. The 1980 complaint
was subsequently dismissed.

In 1984, 'approximately 250 third party defendant
generators, insurance companies and government
agencies were brought into the lawsuit by the'
original defendants. Most of the claims involving
third party defendants have now been settled. A
settlement agreement between the United States and
the parties it sued is currently under considera-
tion.
41
;'~.}--'-:' ; '.~ ~~.~~~:;:.; u.';' y" ;:-~7' :.~, . '~:.:.t,:';~;.':.C:-:'~ ~-;'-;_:~' ~~~;~-~ ">~::::::~~:r~,i2~~r:~ ~'~.\:'~':.:_-:~-.:- .~::_o, - ",C
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11.
RESPONSIVENESS SUMMARY

A public hearing was held regarding the remedy
selected in 1985 and a public meeting was held on
Apr~l 23, 1987. The FFS Addendum was released to
the public for review and comment on March 26,
1987, with the-comment period extending to May 8
1987, and a public meeting was held on April 23,
1987 to receive comments. One oral comment and
three written comments on remedial al ternati ves
for the CCC site were received by EPA Region VII
during this comment period. The fOl-lowing is a
summary of the comments and EPA's responses. (The
comments have been edited and, in some cases,
paraphrased to summarize the major points of each
commenter.) The transcript of the public meeting
and the original texts of written comments are a
part of the administrative record.
Oral comment by Dan DeCarlo of Coalition for the
Environment, Kansas City, MO: The Coal-ition for
the Environment requests clarification of the
kinds of environmental impacts the barrier wall~
alternative would have. Specifically, to clarify
if the remedy would involve pumping and treatment
of groundwater and return of the treated water to
the river and whether the soil washing alternative
would return the treated soil to the site or would
it be moved elsewhere. For the groundwater pump
and treat alternatives, what would the groundwater
withdrawal rate be and how long would it continue.
Finally, what is the extent of both the aquifer
and the area of water contamination.
EPA ReSDonse: The groundwater would be treated
and discharged into the Missouri River in a manner
which is protective of the public health and the
environment and the treated water would meet the
applicable or relevant and appropriate require-
ments for such discharges. The soil washing al-
ternative would return the treated soils to the
original excavation. Groundwater pumping would
occur in several of the alternatives considered by
the EPA, al though the rate of wi thdrawal would
depend upon the means of hydraulic isolation used.
The interconnection between the Missouri River and
the alluvial aquifer underlying the CCC site would
resul t in 1 i ttle, if any, change in groundwater
availability under any of the groundwater pumping
scenarios envisioned for a CCC remedy. The length
of time necessary to achieve the desired cleanup
42
:.':;~1:~~.{;'~'~~ : '~."~ :.,.. ".~ 'd"~:''::.~<,-'~,,:..
-------
t.... ...
. .. . - I .
under the active pump and treat alternative cannot
be determined precisely. A thirty year time period
was used for purposes of cost estimation only.
Regarding the boundaries of the aquifer and the
contamination, it is known that both extend off
site. Monitoring wells have been installed off
the site and several of the remedies considered
for CCC site, including the selected alternative,
would address 'at least some of the off-site
contamination.
Writ. ten comment by counsel for Original Genel'ator
Defbndants: In accordance with the order entered
April 28, 1987, by Judge Scott o. Wright in the
civil action entitled United States of America v.
Conservation Chemical Comoanv. et ale , they
maintain that the administrative proceedures which
EPA is purporting to follow 'are extra-legal,
redundant, and inappropriate for remedy selection
under the circumstances of the CCC litigation.
Moreover, an administrative proceeding deprives
the potentially responsible parties of due process
of law.
EPA Resoonse: The administrative process for
selection of a remedy is both appropriate legally
required under CERCLA and the NCP.

Written comment by William C. Ford, P.E.,
Director, Division of Environmental Quality,
Missouri Department of Natural Resources: The
Missouri Department of Natural Resources re-
commends the alter~ative incorporating excavation
of the wastes and soil washing with downgradient
groundwater pumping and treatment be utilized for
the remedial action at the CCC site. The commentor
stated that this recommendation is consistent with
the final recommendation contained in an EPA
contractor's report on alternative remedial action
technologies at the CCC site.
. EPA Resoonse: A comparison of the three
alternatives and EPA's rationale for selection of
Alternative lOA is set forth in Section 6 above.
Written comment by Clark A. Ridpath, Manager,
Legal Services, Mobay corporation- of Kansas City,
MO: Mobay corporation has studied the documents
describing the remedial al ternati ves for the CCC
site which have been made available for public
review. The commentor stated that their review
43
c >"",; -;c=-. ,,''''''.,~. ",
',..~ -~;';"!o'-"'~'.':'~',"'<'.' ". 1-'.:-1,'.1".-.-. "---'~~:-"'~'...-~ ',I'C"--~'
-------
reflects that little, if any, discussion is
contained in these documents relative to the'
protection of adj oining , property owners,
particularly pertaining to the health and safety
of personnel in close proximity to the CCC site,
to be afforded during the implementation of a
remedy. Mobay is concerned about the health,
safety, and well-being of its personnel, which
exceed 1000 workers at its facility near the CCC
site.
, EPA ReSDOnS(:: The FFS and FFS Addendum evaluated
potential ..;emedies on the basis of several
criteria, including environmental impact and
safety. Safety encompasses both the safety of the
workers engaged in the remedial action and the
safety of the general public outside of the site
boundaries. In fact, safety is a major factor in
the decision to use the containment by onsite
pumping alternative at the CCC site, since it
involves minimal disturbance of the buried wastes.
A much more detailed safety analysis will be
performed during the remedial design phase, durin9
which the adjacent property owners, other
interested members of the general public, and
other federal, state, and local agencies will be
consulted as appropriate. Safety will always be
of utmost concern ,to the EPA in evaluating and
implementing remedies at Superfund sites,.
44
.:'~-,~ ~.' -,:,-.,--~.C'.' -."
. '-'-."" '-.'"
"-',~'..-.' C.:'::'~-;.:- c'-;T~, ," .,'" '~.'..",: - ~: ~., ;, :;. ~;"C'..: V'.", <. J-; :~.~':'..:;. ~;-::r_,.< :~7.-::- ..u': '~>;-'.,:-/ /,~'r:'i"~:'/:- ~,::::.:- '..-:-;.~,~~[:-~,.:,x.r;-"~')'~';~~~;i'~::~~~,~,~>:'Z:~._~~::;:-:::::~"C~_:~2:'+~~:~::,;~-' '.:':'- ,!~:~'(:-~:,,}~':--"-.,.2~~' ,:-';:,::~'J,~~.~,,'-1-.::~'Y'",:;:::-,-~'-"i'.I_;'\~~V'-~::~'L~-; :t:;:.?:~-. :-
-------
. ,,>c ~:;:;: ro':'~.::, :Y.:r': '-';'~'7:;':-~ ~~. :"; .."
o
o
o
o
o
~" '..;: ";::c:'. ~
TABLE 2
TECHNOLOGIES CONSIDERED I}f FFS
Increased monitoring
Excavation
Chemical solidification/stabilization
Off-site disposal
RCRA landfill
Special landfill
On-site disposal
Existing location
RCRA cell above floodplain
o
Surface treatment
o
circumferential impermeable barrier
o
Downgradient impermeable barrier
o
On-site (~nterior) withdrawal wells
Downgradient withdrawal wells
o
o
Hydraulic Barrier
On-site subsurface drain
o
o
Downgradien~ subsurface drain
Diversion pumping
o
o
Treatment of extracted groundwater
Treatment of impacted water supplies
o
o
Bottom sealing
o
Incineration
o
Permeable treatment beds
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TABLE 3
TECHNOLOGIES EXCLUDED FROM DETAILED DEVELOPMENT IN THE FFS
Technoloqy
Reason for Exclusion
In-situ Stabilization
Technology attempted and found not
feasible at other similar sites.
Technology is not sufficiently
developed.
Bottom Sealing
Technology has not been adequately
demonstrated at the project level.
Process is expected to be very
costly and of questionable
effectiveness.
r-
Incineration
Technology for amenable wastes
already used at site. Technology.
inappropriate for remaininq wastes,'
particularly the destruction of
cyanide and heavy metal wastes.
Diversion Pumpinq
Technology not appropriate due to
hiqh aquifer transmissivities,
other site geological
characteristics and high cost of
.O&M.
Permeable Treatment
Beds
Technology most appropriate where
contamination is at low levels.
Inability to regenerate medium
without physical removal and, with
the hiqh contaminant concentrations
onsite, medium exhaustion would
occur rapidly.
On site/Off site
Subsurface Drain
Technology prohibitive due to the
required depth of excavation and
pumpinq rquirements for recovery of
groundwater at the CCC site.
withdrawal wells determined to be
more feasible.
,-, " ',,,"" ~,. "', '." ,"' i '.,- -(" '-";"; ~"c'-"'. ," '0-,' '-',- '-"':r,.- .. T" ":~." ".,j-' "-'0,,' ~ r,- ~ J
.; :,":-~. ,",.-. ;--~~ .7~,~"d" i"/r",,;>-\-'~: ;\V)~-.-'';f-'':-~. --:~;,:~ L'~-~'7-, ':"'~~J'~";c'-(7".'.:i~ ;c-' ~.';:'::-:-"':;~~C ;
: .?'. rT::"~~-~,:::"~.~'''::,f2',:->:. ~:'~ ~;'~:';;'"};)-'~';', ,:> :':"-' ;ji.'~0::~:~L:~<\-3..~~,"~~'~~"
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TABLE 4
DESCRIPTIONS OF REMEDIAL ALTERNATIVES EVALUATED IN FFS
Alternative 1
Increased monitorinq
Alternative 2
Excavation of wastes/soil
Chemic~l sOlidification/stabili-
zation
Disposal offsite in licensed
landfill or site in special cell
above floodplain
Alternative 3
Surface treatment
includes RCRA cappinq, reveqation,
floodproofinq
I"
Alternative 4
Surface treatment
Circumferential impermeable barrier
Onsite (interior) withdrawal well
Groundwater treatment
Alternative 5
Surface treatment
Circumferential impermeable barrier
Onsite withdrawal well
Downqradient withdrawal wells
Groundwater treatment
Alternative 6
(A & B)
Surface treatment
Onsite withdrawal well
Downqradient withdrawal
Groundwater treatment
wells
Alternative 7
Surface treatment
Downqradient impermeable
Onsite withdrawal wells
Downqradient withdrawal
Groundwater treatment
barrier
--
wells
Al ternati ve 8
Surface treatment
Downqradient impermeable barrier
Onsite withdrawal well
Downqradient withdrawal wells
Groundwater treatment
Additional treatment of
impacted water supplies
" '-,'" ',~.'c-:';:', ",:' " .
0- .....,
H, u'.",'7c -',~. ',-;~.: ,~ '.- ~~'" <-.: :: or, ,'-.,",r" "'-: ~ ',: :'S...~- 'c.": .-~ :",/'~... c' ',:".. :-.l"O__~':' . c: .),;-( ~~l-~\j'r~;-,-"'i";-:/,' :! --.' -~~~-:~'>-'~'~.':;-;; -'.F\:::;£'7":-':T::;-?t;'i':,:':-\~--;:'.~:: ~::~~.';"f:'f: -~-:' -,' . . '-<~:;'~<~' ~"':';'." ,,~, '~.'1'::~:.';0;;~":;J.~,...~" '-,-::. ;,:.- -;, " .~ "'~",' <,,~ ,?_i;~ P~::r ~:"~- ~:-:>.~:
-------
TABLE 5
ADDITIONAL TECHNOLOGIES EVALUATED IN RESPONSE TO SECTION 121
OF SARA
ADDlicability
Technoloav
~
Jig
Volume Reduction
Recycle/Reuse
x
Waste Minimization
x
Toxicity
Waste Biodegradation
Detoxification
x 
 X
 X
X
x 
 X
 X
Incineration
50il Flushing
50il Washing
Heating
Freezing
Mobility
contaminant Immobilization
X
X
Vitrification
.'",:, ':'7' r,-._~--:~
-------
, ~ ~; "'c-."'- .~1. ': ;.',:-~--::~~:c.~ '-;:~~.' ;;: ~. '~i.!,.-~ .
TABLE 6

TECHNOLOGIES EXCLUDED FROM DETAILED DEVELOPMENT IN FFS
ADDENDUM
In-situ Immobilization
Technology would not effect
organic and other non-metallic
contamination: thus, these
. substances would continue to
be a source of contamination.
Immobilization reactions are
reversible.
In-situ Detoxification
Technology is not feasible in
presence of multiple
contaminants. Chemicals used
in the process are pollutants
or yield toxic byproducts.

Technology is not feasible for
deep zones of contamination
and in areas with high
moisture content. . Process
would not treat contaminated
groundwater. Process has high
energy requirements.
In-situ vitrification
In-situ Heating
. Technology would not affect
inorganic contaminants.
Process has high energy
requirements which are greater
in presence of soil moisture.
In-situ Freeze Thaw
Technology does not affect VOC
contamination, is not feasible
at the CCC site due to shallow
water table, and could
increase mobility of some
metals.
-------
.. ~-;"c'-~:~e7"-,,7'),:\7~~
"- .,-- 0.-.' ';'..~,~~-;,.-- ,. .I'.~
TABLE 7
DESCRIPTIONS OF REMEDIAL ALTERNATIVES EVALUATED IN FFS
. ADDENDUM
Alternative 10(A)
Surface treatment
On-site withdrawal wells
Groundwater treatment
Alternative 11
Excavation of wastes/soil
Downgradient impermeable
barrier
Injection/withdrawal wells
Soil Washing
Groundwater treatment
Alternative 12
Surface treatment
Injection/withdrawal wells
Downgradient impermeable
barrier
In-situ bioreclamation
system
Alternative 13
Surface treatment
Injection/withdrawal wells
Circumferential impermeable
barrier
Groundwater treatment
In-situ soil flushing system
-
Alternative 14
Surface treatment
Injection/withdrawal wells
Circumferential impermeable
barrier
Groundwater treatment
In-situ biroeclamation/soil
flushing system.
.~~.~ ~,:;C,:..., ~C"'::'--;:~:;:,C:,;::::: ,c ;-::; ,~:.- .-;--,:,' ~'<-~~:'-''':'';>,~\,,"'':.:.-.J.:;'.;~~.~3'::;;,'.''-''~; :,::~,::'.~:C~::::'.;- '.~~~:' ,:<:;, '.. '.':; ,:..: :
.,~ ~,,,, ~~. ~ :; ";;':"'/~:'-";t~:;:-'''':::='~';-;''';"'-.;~' 'E/\ "~':O:~2:;~~- t, ~~j;) ~ ,,-:':';':'; :'~~ 7~~:r l.-~:'.~, .';,- ':-:~ /~\'-} ~: ~./].; ::)~ ~ :,~~" ~r'~:",,:~ ',:-' f', .': ;~ Cc~'S~\:' ;:,.;;.~ ,,{,:::C " ->-:' :,.-'
-------
TABLE 8
COMPARISON OF COSTS FOR ALTERNATIVES 4. lOA. and 11A
Alternative
Capital
($)
O&M
Present
Worth
($)
Tota-l
Present
Worth
($)
---~-------------------------~-------------------------~----
Alternative 4: Source
Containment with
Slurry Wall
12,354,000 4,733,000 17,087,000
Alternative lOA: Site
Pumping
8,626,000 12,774,111 21,400,000
Alternative 11: Excavation
and Soil Washing
11,751,000 11,625,000 23,376,000
A Present worth evaluated at 10 percent discount rate.
-'
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TABLE 9
APPLICABLE OR RELEVANT AND APPROPRIATE REOUIREMENTS (ARARs)
FOR CONTAMINATION OF CONCERN AT THE CCC SITE
Contaminants
of Concern
Concentration
Source of ARARs
Arsenic
Cadmium
Chromium
Nickel
(Total)
50 ug/1
10 ug/l
50 uq/l
13..4 ug/l
MCL
MCL
MCL
AWQC for Human
Health
. A~QC for Human
Health
MCL (Secondary)
None
Health Advisory
Zinc
5'000 ug/l
Lead
Chloroform
300 ug/1
None
220 ug/l
(long term,
50 ug/l
0.19 ug/l
child)
Iron
Aluminum

cyanide (Total)
Trichloroethylene
2.7 ug/l
MCL
AWQC for Human
Health (10-6)
AWQC for Human
Health (10-6)
MCL
MCL
AWQC (10-:-6)
MCL
Trichloroethylene

Benzene
Vinyl Chloride'
Vinyl Chloride
5.0 ug/l
5.0 ug/l
2.0 ug/l
2.0 ug/l
. - '.....
~'~~~ -.~ ;'"- .' -~.~,-: "--.- .'.-' - "~--1- t~'..,;;~..;-''=:'' ::-:':~';-;: .".o_;,~ -0 --.i';~""'>~~-:-:~ :.-:::"."~.:;':' "".~':''':''::,~'j;::'::g~,7,,':-;~{~7i'','':;;:(~~''s:r::-;-::,~3;' :.,.~';-:-~'.~<, . ,',.:, :,<';'=.':":r.~,r:7t,-;,:~>,<,:',";'-;::';-~~2:'::';":}'--'"' ~,,,,).~-'S!\-'i'c-:'~ ;'-=C::;;,-~"-{;::.~j~::-:<,\::~~<..;:-,.f''Z\'''>:(;;, i;;;;~\:"
-------
~ABLE 9

APPLICABLE OR RELEVANT AND APPROPRIATE REOUIREMENTS (ARARs)
FOR CONTAMINATION OF CONCERN AT THE CCC SITE
(Concluded)
1,2-Dichloroethane
. 1,1,2-Trichloroethane
1,1-Dichloroethylene
1,1-Dichloroethylene
Trans-1,2-Dichloroe-
thylene
2,4 Dichlorophenol
2,4 Dimethylphenol
Phenol
5.0 ug/l
0.6 ug/l
0.033 ug/l
7.0 ug/l
70 . 0 ug/l
MCL
AWQC (10-6)
AWQC (10-6)
MCL
MCLG
0.3 ug/l
400 ug/l
300 ug/l
AWQC
AWQC
AWQC

.
(Organoleptic) .
AWQC (10-6)
MCL
AWQC (10-6)
AWQC
AWQC
AWQC
2,4,6-Trichlorophenol 1.2 ug/l
Carbon tetrachloride 5.0 ug/l
Carbon tetrachloride 0.4 uq/l
Toluene 14.3 mg/l
Methylene Chloride 0.19 uq/l
2,3,7,S-Tetrachloro- 1.3XIO-S
dibenzodioxin (TCDD)
"'--~""',"""~ ---:" "~'-".-'C "'J~:.V'" ,J,.'--"--.-T ""'-''-''',. ;'T
(10-6)
(10-6)
-. < -=-~. '.c,.-;-~." ,-.' ',-~
. --''t\'''''-''' -:e"."" './,~"'-"(,~~,'~-~' ... ,-.-,'-- '. -, -<' .;.o,r-~T,7:"':\-:"'~;f'~ ," ;..'2' ~,~':;-'." ..t,~.'~'r';'--"-;>'-'-
,I,~. ". ""'-;.''-.'''-'''-!,:'ir;.:.. c".'" "".~---=-7-c;.-,~'O>
-------
CONSERVATION CHEMICAL COMPANY SITE
KANSAS CITY, MISSOURI

INDEX OF DOCUMENTS IN THE ADMINISTRATIVE RECORD
FOR THE RECORD OF DECISION
U.S. Environmental Protection Agency
Contract No. 68-01-7351 (TES IV)
Work Assignment No. 413
September 4, 1987
~:(~;. ,\;:r;{~:c': .~~;,:.(.-\':::' )~;':,':'..
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INTRODUCTION
This Index of Documents in the Administrative Record for the Record of
Decision describes documents consi~ered by the U.S. Environmental
Protection Agency in determining appropriate response actions with respect
to the Conservation Chemical Company Superfund Site in Kansas City,
Missouri.
Administrative R~cord documents for the Conservation Chemical Company Site
are indexed chrolologically in ascending order, with undated documents
following all dated entries. This sorting scheme corresponds with the
arr~ngement of documents in the Administrative Record itself. In cases
where documents contain only partial dates, the Index of Documents defaults
to the first month of the year and/or first day of the month, as
appropriate.
i i
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"11.
Conservation Chemical Company
Admlnlstratlve Record
<.
1.
u.s. Army Corps of-Engineers, Kansas City District, 7/9/55, Aerial
Photograph, confluence of Blue and Missouri Rivers and environs,
#KC-3-154, 1 pg.
2.
u.s. Army Corps of Engineers, Kansas City District, 10/7/60, Aerial
Photograph, Conservttion Chemical Company - Kansas City and environs,
#MRll 184, 1 pg.
3.
u.s. Army Corps of Engineers, Kansas City District, 3/14/63, Aerial
Photograph, Conservation Chemical Company - Kansas City and environs,
#BRM-5-200, 1 pg.

O'Connor, Howard G.' and Lowell W. Fowler, 2/25/64, Pleistocene
Geology in a Part of the Kansas City Area (Geology Report), 11 pp.
4.
5.
U.S. Army Corps of Engineers, Kansas City District, 8/13/65, Aerial
Photograph, Conservation Chemical Company - Kansas City and environs,
#M~65 12-175, 1 pg.

u.s. Army Corps of Engineers, Kansas City District, 3/4/68, Aerial
Photograph, 'Conservation Chemical Company - Kansas City and environs,
# MR 67 7-61, 1 pg.
6.
7.
Report of Engineering Geology of Lagoon Site, Conservation Chemical
Company - Kansas .City, 9/3/~, 2 pp.

Schultz, George P. (Office of Management and Budget), 3/27/72,
Discount Rates to be Used in Evaluating Time-distributed Costs and
Benefits, 6 pp.
8.
9.
u.S. Army Corps of Engineers, Kansas City District, 2/24/73, Aerial
Photograph, Conservation Chemical Company - Kansas City and environs,
#BR-73 1-5-8, 1 p.


~~~~~~~iP~~~;; ~~ :~~s~:v~~t~.A~~~~n;e~~~~7~~rW~~~~e~~:~~~~ ~~~~rcif

Company, 26 pp.
10.
Williams, W. Hadley (Missouri Department of Natural Resources),
7/1/76, memorandum to Joe Fitzpatrick regarding "Sealant Procedures
at Conservation Chemical Toxic Waste S;te~, Jackson and St. Louis
Counties,1I 2 pp.
1
: "".. . '" :r"";," ::,;L "~,-'~::i;-;'~-:,~~;;''~-'':';' ~:~?~:~',;:'~~:i~- L'~ .::~:h'
-------
."<~ '-'-~",,,! ;;,"~,;'-"""\ "~";,,.!;:<., -~;: _d'"
24.
Sisk, Steven (Water Section, TECH IS VAN) I 4/25/79, Second Phase
Sampling of Conservation Chemical, sampling report for Robert Morby,
Chlef, Hazardous Materials Branch, HAZM, 11 pp.
25. .Scott, M. C., 7/1/79, "Sulfide Process Removes Metals, Produces
Disposal Sludge" (Journal Article), 5 pp.
26.
27.
29.
31.
Schoonover, Roger E. (Conservation'Chemical Company), 7/25/79,
memorandum to Norman B. Hjersted regarding "Sludge Stabilization at
the Kansas City Plant," 3 pp.

Kaiser, Lloyd T. (Conservation Chemical Company), 7/26/79, memorandum
with attachments to Norman B. Hjersted regarding "Chlorinated
Hydrocarbon Intake at Kansas ;ity Plant," 3 pp.
"National Interim Primary Drinking Water Regulations: Control of
Trihalomethanes in Drinking Water," (Regulations), 11/29/79.
Robinson, A. K. and J. C. Sum (Boeing Commercial Airplane Company,
Seattle, Washington), 6/1/80, Sulfide Precipitation of Heavy Metals,
report for U.S. EPA, Cincinnatl, Ohl0, 34 pp.

33. Herndon, Kerry B. and Steven W. Sisk (U.S. EPA), 6/19/80, Groundwater
and Offsite Pollution Movement at the Conservation Chemical Company
Site, Kansas City, Missouri, 16 pp.
32.
34. U.S. EPA (Office of Research and Development), 6/23/80, Treatability
Manual. Volume I: Treatability Data (Report), 5 pp.

35. U.S. EPA.(Office of Water Regulations and Standards, Criteria and
Standards Division), 10/1/80, Ambient Water Quality Criteria for
Chromium (Report), 10 pp.
36.
U.S. EPA (Office of Water Regulations and Standards, Criteria and
Standards Division), 10/1/80, Ambient Water Quality Criteria for
Nickel (Report), 6 pp. .
3
".: ~,r",,~. <":;- -. ~,
", .::,", -..: ,",-:'..,.-,'J ','.-'- "':/.'~':''''~'':'-~,'':'-'3-,'-('-.-I_~('" ".-"-:.-'..'-;'1,'",\~,--~'''' '. ..,',-,;
'~:i"~'~.'- :,~'~;'r/:-
':' '":'.. t '. " " ," -"~' '.' " ,r,.- ;',<, - ":-""".',
, ~,. ~.'-''''l.':' ',~,.' .':';/-~ 7 -:',~:-...,.~",.."-."
-------
76.
77.
78.
75.
Roberts, Mark (U.S. EPA), 7/26/83, letter regarding "Completion of
Subcontracted Lagoon Cover Sampling Activities at Conservation
Chemical Company, Kansas City, Missouri ," 4 pp.

Pawlak, Timothy (The Penmutit Co., Paramus, New Jersey), 8/1/83,
"Sulfide Precipitation" (Journal Article), 3 pp.
Kopsick, Deborah (Ecology & Environment, Inc.), 8/16/83,. Field
Investigation of Uncontrolled Hazardous Waste Sites (Field
jnvestigation Report), 34 pp.
79. U.S. EPA (Environmental Criteria and Assessment Office), 10/1/83, Air
Quality Criteria for Lead, Vol. I of IV (Report - Review Draft), 6---
pp.
Petrasek, Albert, Kegelman, Austern, Pressley, Winslow, and Wise
(U.S. EPA, Cincin~ati, OH), 10/1/83, "Fate of Toxic. Organic Compounds
in Wastewater Treatment P1antsll (Professional Paper), 11 pp.

81. Missouri River Public Water Supply Association, 10/7/83, IIRiver Wat~r
Data: Reports from 1981 to 198411 (Data), 504 pp.
80.
82.
83.
84.
Roberts, Mark T. (Ecology and Environment, Inc.), 10/11/83, Lagoon'
Cover Evaluation, Conservation Chemical Com an , Kansas Cit ,
1ssour1 report or pp.

Kopsick, Debbie (Ecology and Environment, Inc.), 10/12/83, memorandum
to Ron McCutcheon regarding "Surrmary of Sample Data for Conservation
Chemical Company AQ59 Series," 14 pp.
Anderson, David C. and Stephen G. Jones (K. W. Brown and Associates),
10/31/83, "Clay Barrier-Leachate Interaction" (Professional Paper),
7 pp.
85.
McCutcheon, Ronald, 12/8/83, sampling procedures for Robert Morby,
IIFie1d Sampling Procedures used at Conservation Chemical Company~
Kansas City, Kansas,lI 3 pp.
86.
Peters, Robert W., Young Ku, Dibakar Bhattacharyya, and Lih-Fen .Chen
(Dept. of Environmental Engineering, Purdue, and Dept. of Chemical
Engineering, University of Kentucky), 1/1/84, "Crystal Size
Distribution of Sulfide Precipitation of Heavy Metals" (Paper
contained within "Industrial Crysta1ization 84 Book), 13 pp.

Bhattacharyya, D. and Y. Ku (Department of Chemical Engineering,
University of Kentucky, Lexington), 1/1/84, Sulfide Preci~itation of
Heavy Metals: Effect of Complexing Agents, report for U. . EPA,
Cincinnati, Ohio, 131 pp.
87.
7
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.. :: O-;:~.'.z;~ '-;' ,,~-::'::-;;',- ~r~'~"'~'~~::':~'~~:,~-~ /;>~':.:;-~ <'~,.
101.
102.
103.
104.
105.
106.
107.
108.
109.
111.
112.
113.
Black and Veatch, 9/28/84, Review of Third-Party Interrogator¥
Responses in re United States of Amerlca v. Conservatlon Chemlcal
Company et al., Volume 1: Responses to the September 7 Interrogatory
( Report) .

Ruelle, Dick (U.S. Department of Interior), 10/5/84, lette:' with
attachments to U.S. EPA, Region VII regarding "Analytical Results of
Samples Collected from: Conservation Chemical Company, Rosecrans,
McArthur Lakefill and Aidex Sites, 11 pp.
Bunn, William W. (U.S. EPA, Region VII), 10/26/84, letter to Thierry
Sanglerat IIRequesting 8 Items Essential to Data Review Process."

Kapila, S., 11/15/84, letter and analytical results of "25 Samples and
QA/QC Sheets" "to Ri chard Graham, U. S. Department of Interi or, Fi sh &
Wildlife Service, Route 1, Columbia, MO~ 11 pp.
Burns & McDonnell, Fred C. Hart Assoc., S. S. Papadopulos, Inc.,
Woodward-Clyde Consul tants, 11/21/84, "Remedial Investigation by
Defendants: Remedial Investigation Report on the Conservation Chemical
Company Site, Kansas City, Missouri for Annco Inc., AT&T, FMC and lBW
(Remedial Investigation), 195 pp.

Burns & McDonnell Engineering Co., Fred C. Hart Assoc. Inc., S. S. ~
Papadopulos & Assoc., Woodward-Clyde, 11/21/84, AP~endix, Remedial
Investigation Report on the CCC Site, report appen ix for Annco-lnc.,
AT&T, FMC Corporation, IBM Corporation, 51 pp.
~~~~nd~~t~;t1~~1~~:,C~~~~~~~~~~~ ~~~~~ ~~~e~~an~~~e F~:~~~~l~;~ ,

Mlssouri or ARMCO Inc., AT T, FMC, and IBM easibi 1ty Study
Report), 333 pp.

Davis, Stanley N., 12/4/84, letter to Bruce Buckheit, Department of
Justice regarding "Why Analyses of Both Filtered and Unfiltered
Samples are Significant," 2 pp.
ETC Sam le No. G0690,
G0687
"Rules of Department of Natural Resources Division 20-Clean Water
Commission, Chapter 7, Water Quality,1I 12/13/84, 12 pp.

Hensley, Charles (Laboratory Branch, ENSV), 12/19/84, transmittal of
"Laboratory Data," for Keffer, 32 pp.
Peters, Robert W., and Young KU, 1/1/85, "Evaluation of Recent Treat-
ment Techniques for Removal of Heavy Metals from Industrial Waste-
water" (Ref: "Separation of Heavy Metals and Other Contaminants,"
Arch & Symposium Series, Vol. 81, 1985) (Article), 39 pp.
9
-------
....~. . P' . . ...... . P..., I - ."
Hensley, .Charles P. (U.S. EPA), 5/1/85, transmittal to. Bill Keffer
entitled "EPA Transmittal of Laboratory Data, Activity No. CKJ04,"
12 pp.

130. Hensley, Charles P. (U.S. EPA), 5/2/85, transmittal to Bill Keffer
entitled "EPA Transmittal of Laboratory Data, Activity No. CKJ04,"
13 pp.
129.
C. T. (Clement Associates, Inc.), 5/7/85, Endangerment
Conservation Chemical Com an , Kansas Cit , Missouri
pp. .

U.S. EPA, 6/1/85, Guidance on Feasibility Studies under CERCLA
(Report), 274 pp.
132.
133.
Bureau of National Affairs, Wa.shington, D.C., 6/21/85, "Part of the
Missouri Water Quality Standards II (Data), 1 pg.
"Water Analysis - Metals, Cyanide, and Phenols, Conservation Chemical
Company Site" (Data), 6/21/85, 15 pp.

135. U.S. EPA, 9/20/85, EPA 40 CFR Part 421, "Nonferrous Met~ls
Manufacturing Point SourceCitegorYi Effluent Limitations Guidelines,
. Pretreatment Standards, and New Resource Performance Standards"
A~tion: Final Rule (Report), 4 pp. .
134.
136. Hensley, Charles P. (U.S. EPA), 12/19/85, transmittal to Bill Keffer
entitled "Transmittal of Laboratory Data, Activity No. AKJ04."

137. Bhattacharyya (University of Kentucky, Lexington), 4/1/86, Sulfide
Precipitation of Nickel and Other Heavl Metals from Single and
Multi-Metal Systems, report for U.S. EPA, Cincinnati, Ohio, 112 pp.
138.
Barber, Paul D., 5/14/86, correspondence to John Chen, U.S. EPA,
Region VII regarding "Conservation Chemical Company: Review of IT
Corporation's Proposal ," 5 pp.

Kopsick, Deborah (Ecology and Environment, Inc., Shawnee Mission,
Kansas), 5/16/86, memorandum to John Chen, U.S. EPA regarding
"Conservation Chemical Company: Remedial Design and Remedial Action,"
2 pp.
139.
140. Ad~ins, Charles J. (U.S. Army Corps of Engineers, Kansas City,
Missouri), 5/27/86, Comments on Conservation Chemical Company-Health
and Safety Plan-Design, report for Heidi ~acklam, 19 pp.

141. Higgins, Thomas and Drew P. Desher, 6/1/86, "Electroplating, Metal
Finishing. and Cyanide Wastes" (Professional Paper). 4 pp.
142. Mead, Ed (U.S. Army Corps of Engineers), 6/4/86, ~s of En~ineers
Engineering Review Comments Project: Conservation em,cal ompany.
report for Heidi Facklam, 4 pp.
11
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Stiefermann, Charles A. (Missouri Department of Natural Resources),
11/25/86, memorandum to William C. .Ford regarding "List of 49
Pollutants Identified," 2 pp.

156. Willig, Carl D., 11/26/86, memorandum to U.S. Army Corps of
, Engi neers, Kansas City, Mi ssouri regardi ng "Conservati on Chemi ca 1
Company; Comments on Proposed Compatibility Studies Received in ED-S
on 7 November 1986," 2 pp.
155.
157.
158.
159.
160.
161.
162.
163.
164.
165.
166.
,:. :-~':-:;-_:; _.-~' ',,, ";-,D:"4-"':[ ..~.c;~:,.- ;.',:- ;, -',':' :.'~~
U.S. Army Corps of Engineers, 12/1/86, Hazardous Materials Technical
Center: Computerized Search 0" Concrete and Slurry Panel Walls
(Report), 18 pp.

Uarber, Paul B. (U.S. Army Corps of Engineers), 12/16/86, memorandum,
to John Chen, U.S. EPA, Region VII regarding "Conservation Chemical
Company; Transmittal of Review Comments on the Draft Treatability
Study Report, Front Street Remedial Design," 4 pp.
Moylan, John E. (U.S. Army Corps of Engineers), 12/19/86, memorandum
to ED-FG, ED-F, ED-S regarding "Comments to Revision 2, Draft Report,
Seismic Refraction Survey, Front Street Remedial Design; Kansas City,
Mi~souri (December 12, 1986),"6 pp.

Porter, J. Winston (U.S. EPA, Washington, D.C.), 12/24/86, memorandum
to Regional Administrators, Regions 'I-X regarding "Interim Guidance'on
Superfund Selection of Remedy," 10 pp. .
Barvenik, M. J., W. E. Hedge and D; T. Goldberg, 12/31/86, gualit~
,~~~i~~~t~r~~~~~~~sD~~~nDe~~~~~~~~~~no~fH~~~~~~~~t~~~~~c~~~~~~lS
eport, 3 pp.
Xanthakos, Petros P., 12/31/86, "Report on Slurry Walls," 26 pp.
Civil Works Construction, Guide Specification for Slurry Trench
Soil-Bentonite Cutoff Wall as Contaminant Control Measures, 12/31/86,
( Report), 29 pp.

Barber, Paul D. (U.S. Army Corps of Engineers), 1/13187,
correspondence to John Chen, U.S. EPA, Region VII regarding
"Conservation Chemi ca 1 Company: Transmi tta 1 of Li terature Search on
Slurry and Panel Wall Construction," 19 pp.
Grube, Walter E. Jr. (U.S. EPA), 1/20/87, memorandum to John Chen,
U.S. EPA Region VIr regarding "Slurry Trench Information. ' (Attached
are Copies of Several Articles on Slurry Trenches for Pollution
Control.)," 290 pp.
Clement, Paul (Jacobs Engineering Group, Inc., Albuquerque, New
Mexico), 2/12/8i, record of communication to James Montgomery, Holley
Carburetor regarding "Sulfide Precipitation of Metals in a Metal
Plating Effluent," 2 pp. '
13
. ,. ~',~,: O:".~..: ...'-;',~.,.f~- ~:c,.'.,:°r'. -,;:;'7',:,:~,!,;;,-,-,,=,;;;~':~:F~: :.;~~~ ";.,~~'-~;';.',....;2":.-;;-' >:.;>vx: j '~";'.c. '::'~{",~-:.<~"~: i; ".:~~'~ '':;T:;:;:,::;::::' .~.~-:.:,-;""~:',::'~.;rT-:';{~'t:;::'~.:,:-:...:,~?-,::-- .',:;--' ;'\--,-';:-, J<.~""';';;~ ,..-:::~'~,.--'~,'-: ",;: ~. .-;~::- ';.';~-::, "-=J"~--~ ~-: "q~: -:.,\'~,7-';;;-:;" ~":.~::- <~":r '-:: " "
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177. . Fish, Mary Frances, 4/23/87, "Public Meeting Concerning the CCC Site,
Kansas City, Missouri" (Minutes~, 17 pp.
178.
179.
Ridpath, Clark (Mobay Chemicals), 5/4/87, correspondence to Steve
Wurtz, U.S. EPA, Region VII regarding "Correspondence Comment on'
Remedial Options' for CCC, Kansas City, MO," 3 pp.
Cooley, Donald F. (Black and Veatch, Kansas City,
correspondence to John Chen, U.S. EPA, Region VII
"Conservation Chemical Groundwater Cleanup Design
2 pp.
Missouri), 5/5/87,
regarding
Concentra ti ons, II
180.' Hustand, P3ul A., 8/6/87, Seismic Refraction Survey Front Street
Remedial Design, Kansas City, Mlssour1, report for David Wagoner,
112 pp.
181.
182.
183.
184.
185.
186.
187.
Aldrich, James (Air Force Institute of Technology), Ferrous and
Sulfide, a Proven Technology (Report), 6 pp. ~

Higgins, Thomas E. and Stephen G. TerMaath (Arizona State University,
Tempe, Arizona and Tyndall Air Force Base, Florida), "Plating Wastes;
Treatment of Plating Waste Waters by Ferrous Reduction, Sulfide
Precipitation, Coagulation and Upflo~ Filtration" (Professional
Paper), 10 pp. .
Eisenberg, Talbert N., William P. Bonner, Nai Syun R. Chuang, and
Karen M. Guss (Tennessee Tech University, Cookeville, and J. R.
Wauford, Nashville, TN), "An Evaluation of Venniculite, Iron Filings,
Lime, Sulfide, and Lime Sulfide in the Treatment of Plating
Rinsewaters" (Professional Paper), 8 pp.

Ellis, William D., Thomas R. Fogg and Anthony N. Tafuri (Science
Applications INT Corp., McLean, Virginia), "Treatment of Soils
Contaminated with Heavy Metals" (Professional Paper), 7 pp.
Iskandar, K., Lawrence B. Perry, Thomas F. Jenkins and Janet M.
Houthoofd (U.S. Anny Cold Regions Research and Engineering Lab.,
Hanover, NH and U.S. EPA, Cincinnati, OH), "Effect of Freezing on the
Level of Contaminants in Uncontrolled Hazardous Waste Sites - Part II:
Preliminary Results" (Professional Paper), 8 pp.

Kosson, D. S., R. C. Ahlert, J. D. Boyer, E. A. Dienemann and J. F.
Magee II (Chemical and Biochemical Engineering, Rutgers University,
Piscataway, NJ), "Development and Application of On-Site Treatment
Technologies for Sludge Filled Lagoons" (Professional Paper), 10 pp.
Nash, James and Richard Traver (Mason & Hanger-Silas Mason Co. and
Hazardous Waste Engineering Research Lab Releases Control Branch),
"Fie1d Evaluations of In-Situ Washing of Contaminated Soils with
WaterlSurfactants" (Professional Paper), 10 pp.
15
':CC' ",,,-"~,:-<.:;,;;,;', ~f:'\ 'j'-: --:,;. >f:."~~:", ,-';0";-. :.-:~ '~~<:-;:-'. . {~"",;-; ,-. "":"~ :;~"-,>:,,"'-c' -,c ~-'- <~~i, ~-::: 0':~~~'~ ~;..; ::..;1,':::;: ',,,,; ,.~;' ~/~,? .:.~ . ".
','- ,\-~" -:~': :..::.-. ~ ~:,'~/~: ~:' .:~:;.~~' ~>'j;:"_7-
-c-. ".:-c.".,..,"S
.~ ~ '1'-'~;=;';'-""- ."'" ':..- --:~;.O-""':"""-I','-' '., "',;;:... ,~~~,~'::~ '~'~"-,-"-,~>c.. 7:,,-t""'.~-y c.:;;o:~.:..: "
-------