United States .
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R07-88/021
September 1988
Superfund
Record of Decision
John Deere Dubuque Works, IA
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50272. 101
REPORT DOCUMENTATION ,1. R£PORT NO. 12. 3. R8Cipient~s Accession No.
PAGE E~A/ROD/R07-88/021
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4. Title and Subtitle 5. Reff~ /~a~/8 8 \
SUPERFUND RECORD OF DECISION '
John Deere Duouque 'dorks, IA I I
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First Remedial Act.ion Final '
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7. Author(,) 8. Performin8 Or8aniz~tion Rept. No. 1
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9. Performln8 Oraanization Name and Address 10. Project/Task/Wor~ Unit No.
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11. Contract(C) or Grant(G) No. I
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(C) I
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(G) I
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12. Soonsorin8 Or.anization Name and Address ----. -------
U. Type of Report & Period Covered i
U.S. Environmental Protection Agency
401 M street, S.W. 800/000
Washington, D.C. 20460 14.
15. Supplementary Notes 1
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ilL Abstract (Limit: 200 words)
The Jonn Deere Dubuque Works (JDDW) sH.e is located approximately 2.5 miles north of I
the City of DUbuque, Iowa. The site is owned by Deere and Company, which has ope:ated a. I
inanufactlJ.r ing plant at .t.he site since 1946. The plant property includes an area of '
1,447 acres located in the. flood plain at the confluence of the Litt.le l'laquok o:t- a River :
and the Mississippi River. The waste management. history of the plant is complex, but- I
the primary area of concern is an unlined landfill originally placed in a nat-ural
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depre~s10n caused oy the L1t.tle Maquoke-a R1ver. Pr10r t.o 1968, ~as-es were placed 1n
the low areas of the landfill and combustible materials were burned. Wastes included
caustics (sodium or potassium hydroxide), acids (hydrochloric or sulfuri:), petroleum
distillates (solvents, grinding oils, and so forth), heavy metals (chromium, leaj,
zinc), cyanide, and paint sludges. Another area of concern at the facility is the site
of a 1980, 200,OOO-gallon diesel fuel spill. A diesel fuel recovery system involving an
oil/water separator for non-aqueous phase liquids (NAPLs) was implemented that- same
year. Investigations conduct.ed by John Deere indicated that. human healt~ hazards at th~
landfill could oe considered minimal wit.h t.he primary hazard being t.he possibilit.y oE
dissolved organic chemicals impacting offsite domest.ic wells located east of tne plant
along the Mississippi River. Maintaining a minimum pumping rate of 1.2 mgd in t-he plant
(See Att.ached Sheet.)
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17. Document Anal~i' a, D,scrlptors
Record of DeC1S1on
John Deere Dubuque Works, IA
First Remedial Action - Final
Contaminated Media: gw
Key Contaminants: VOCs (benzene, PCE, TCE, t.oluene)
b. Identlfiers/Open.Ended Terms
c. COSATI Field/Group
. L AV8i1abllity Statement
19. Security Class (This Report)
None
21. No. 01 Pages
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20. Security Class (This Pase)
None
22. Price
(See ANSI-Z39.18)
See Instructions on R....rse
OPTIONAL fORM 272 (4-17\
(formerly NTlS-35)
Oepartment 01 Commerce
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DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT
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INSTRUCTIONS
Optional Form 272. Report Documentation Page is based on GUidelines for Format and Production of Sci~ntific and Technical R..
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: :°,3 : - j3:-3"5 (3j93)
OPTIONAL FORM 272 SACK
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EPA/ROD/R07-88/021
John Deere Dubuque Works, IA
First Remedial Action - Final
16.
ABSTRACT (continued)
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production wells will .create sufficient drawdown to prevent migration of' contaminated
ground water to the offsite wells. The primary contaminants of concern affecting the
ground water are VOCs including benzene, PCE, TCE, and toluene.
The selected remedial action for this site includes: development of an alternate
potable water supply for the plant; extraction and offsite discharge of water from the
contaminated alluvial aquifer using the existing production wells to maintain drawdown
around the plant and landfill areas; continuation of extraction and treatment of NAPLs
from production well No.3 with offsite discharge of treated ground water and offsite
disposal of collected NAPLs; imposition of deed restrictions to prevent inappropriate
use of the plant property in the future; and development of a contingency plan to ensure
that contaminants do not migrate offsite in the event of a plant shutdown (which would
result in the loss of drawdown from production wells). The estimated present worth cost
for this remedial action is $5,151,800 with annual O&M costs of $276,600.
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THE DECIARATION
Site Name and Location
John Deere Dubuque Works, Dubuque, Iowa.
Statement Qf Basis and Purpose
This decision document presents the selected remedial action
for the John Deere Dubuque Works site in Dubuque, Iowa. It was
developed in accordance with CERCLA, as amended by SARA, and, to
the extent practicable, the National Contingency Plan. This
decision is based on the administrative record for this site.
The attached index identifies the items that comprise the
administrative record upon which the selection of the remedial
action is based.
The Iowa Department of Natural Resources has concurred with
the selected remedy.
DescriDtion of the Selected Remedv
This remedial action represents the I final action for
contaminated groundwater at the JDDW sit~. It addresses the
principal threats ~oth onsite and offsite by:
- Developing an alternate potable water supply for the plant.
- Extracting water from the contaminated alluvial aquifer
using the existing production wells. This action will
maintain drawdown around the plant and landfill areas, thus
protecting nearby wells and controlling contaminant releases.
The production wells and other monitoring wells would be
periodically checked for contamination.
- Continuing to extract and treat non-aquepus phase liquid (NAPL)
from the alluvium near production well-3 (PW-3). The source
of this material is probably diesel fuel spills and waste oil
leaks. .
- Using deed restrictions to prevent inappropriate.use of the
plant property in the future.
- Developing a contingency plan which would assure that
contaminants do not migrate off-site in the event of a plant
shutdown.
Declaration
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate for this remedial action,
and is cost effective. This remedy utilizes permanent solutions
and alternative treatment technologies to the maximum extent
practicable for this site. Because treatment of the principal
threats of the site was not found to be practicable, however,
this remedy does not satisfy the statutory preference for
treatment as a principal element of the remedy.
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RECORD OF DECISION
John Deere Dubuque Works Company Superfund Site
Dubuque, Iowa
Prepared by:
u.S. Environmental Protection Agency
Region VII
Kansas City, Kansas
September 29, ,1988
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DECLARATION
Because this remedy will leave hazardous substances on-
site above health-based levels, a review will be conducted
within five years after commencement of remedial action to
assure that the remedy continues to provide adequate protection
of human health and the environment.
~(~
Regional Administ~ator
Region VII
9-l r-~c;
Date
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DECISION SUMMARY
This document was prepared using EPA Guidance for Developing
Superfund Records of Decision (July 1988). Source material for
site description, history, and characteristics was primarily the
Remedial Investigation (RI) Report. The Feasibility Study Report
was the main source for the description of alternatives and
comparative analysis.
site Name. Location. and DescriDtion
The John Deere Dubuque Works (JDDW) plant is located
approximately 2.5 miles north of the city of Dubuque in north-
eastern Iowa. Plant buildings are located on a relatively flat
delta at the confluence of the Little Maquoketa River on the
north and the Mississippi on the east. State highway 386
services the plant site and the CMSP & Pacific Railroad lies
between the plant and the Mississippi River. The plant property
includes an area of 1,447 acres as shown in Figure 1. The factory
itself covers over five million square feet and is located in the
eastern half of the site. This area also contains parking lots,
storage areas, waste disposal areas, and other facilities that
serve the plant. The portion of the Mississippi River adjacent
to the plant site is presently part of the Upper Mississippi
River Wildlife and Fish Refuge, which was established in 1924.
Approximately twenty cottages, leased from the Corps of Engineers
to private residents, are located on this tract, between the JDDW
facility and the river on the Mississippi River flood plain.
The land surface at JDDW is relatively flat with zero to
five percent slopes. In limited areas the top soil has been
removed and redistributed. The surficial soils over the majority
of the plant site consists of loams, which are a mixture of silt,
sand, clay, and some organic matter. Silty-loams are present
north of the former landfill and along the Little Maquoketa
River. Drainage on the plant property is highly variable and is
related to the permeability of the soil. The permeability of
the loams present over most of the plant property is moderate to
low. Soil materials that were once five to twenty-five feet
below the surface and are now on the surface have a higher
density than the original surficial soils. Other areas have been
compacted by heavy equipment, resulting in less pore space and
higher density. The surficial soils along the Little Maquoketa
are poorly drained due to the nearly level "land surface topo-
graphy. This area is frequently subject to flooding for short
periods of time. Surface water drainage at the north end of the
plant is, and has been, to the north into the Little Maquoketa.
Surface water drainage in the south and central portions of the
plant property has historically been to the east and south into
the Mississippi River.
The climate for the State of Iowa is characterized by
marked seasonal variations. The average annual temperature
at Dubuque is 46.6 degrees F., with average temperatures for
July and January of 72.6 and 19.2 degrees F. respectively.
National Oceanic and Atmospheric Administration records indicate
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Figure 1
REGIO~AL LOCATION OF
JOHN DEERE DUBUQUE WORKS
Prcp.~d For: John Dee~ Dubuque Works
Project ManalCr: StCWD D. Cbaman
II AlJproumate Boua:luy
- - of ForJIICr Ludfill
- Pea11&181 ~ ia 1956
WIoV!-' Jlucura ~ iD 1972
- FcaCUI"U Mapped after 1978
- Plq)crty BoUDduy
Geraghty &: Miller, Inc.
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that the average annual precipitation between 1937 and 1987 at
Lock and Dam 11 (located approximately three miles downstream of
JDDW) is 31.75 inches, with monthly averages ranging from 0.99
inches in February to 4.39 inches in June. Monthly average wind
speeds are highest in the spring at 13 miles per hour.
General land use in Dubuque County and northeastern Iowa
is primarily agricultural .except near major population centers.
The JDDW site,' although once farmland, now remains largely
undeveloped except in the immediate vicinity of plant operations.
Major natural resources other than agricultural land are lime-
stone, sand and gravel, trees, and water. The City of Dubuque is
the county seat and the major commercial hub for the region. The
area is a national manufacturing center for construction
equipment due to the presence of JDDW. Other local industries
include meat processing, grain storage and transportation,
quarrying, and mining. Lead mining was an important industry
in the area during the mid-1800s.
More than 150 sightings of rare species have been reported
in Dubuque County. Within a 10-mile radius of the plant there
have been 31 reported sightings of 20 rare species. No rare
species have been sighted on the JDDW property and only one
species, the pirate perch, was sighted immediately adjacent to
the property.
The principal surface water bodies affecting ground water
resources at the site are the Mississippi River on the east and
the Little Maquoketa River on the north and west. The surface
elevation of the Mississippi River adjacent to the JDDW site
is controlled by Lock and Dam No. 11 which is located approx-
imately three miles downstream at river mile 583.1. The minimum
surface water elevation at the JDDW site was calculated to be
601.1 ft. msl. The mean surface water elevation for the Mississ-
ippi adjacent to the site was determined to be 602.5 ft. msl and
the maximum elevation was calculated to be 614.3 ft. msl.
Surface water elevations above Lock and Dam No. 11 can be
expected to equal or exceed 613.1 ft. once in 50 years, 616.2 ft.
once in 100 years, and 625.9 ft. once in 500 years. Maximum
surface water elevations of the Mississippi River adjacent to
the JDDW site can be expected to be 0.3 ft. higher.
Floods on the Little Maquoketa River have been well
. documented since 1935. The greatest flood of record, a 500-
year flood, occurred on August 1, 1972. the surface water
elevation'at the gauging station was 635.85 ft. msl, and the
discharge was 40,000 cubic feet per second'(cfs). The average
discharge for the period of record is 85.1 cfs. The high
discharge during flood stages is due to the physical character-
istics of the basin and probably to the fact that the gauging
station is located just downstream, from the confluence of the
three principal tributaries.
Hvdroqeology
A comprehensive description of aquifers at the JDDW site
is given in the RI Report. The information generated by the
RI was used to evaluate the possible migration pathways of
contaminants beneath the site and also provided the basis for
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development and calibration o~ the numerical ground water model
which was, in turn, use to evaluate possible remediation options.
Alluvial sediments at the JDDW site vary in thickness from
100 to 158 feet and consist ~rincipally of fine-to coarse-
grained sand deposited mainly by glacial meltwaters. A thin
silty layer has also been deposited by the Little Maquoketa and
Mississippi Rivers. Thin, interbedded gravel lenses are present
but these are not significant barriers to vertical and horizontal
ground water flows. The plant site is located above the thickest
portions of the alluvium in the Peru Bottoms area. Toward the
bluffs'the elevation of the bedrock surface increases and the
alluvial deposits become thinner.
Three distinct bedrock aquifers are present in the
Dubuque, Iowa area: The Galena-Platteville aquifer represents
the most shallow of the principal bedrock aquifers. The
formation consists of limestone and dolomite with thin shaly
layers found in the uplands adjacent to the river valley and at
the bottom of shallow alluvia~ filled valleys. This aquifer
yields low to moderate quantities of water for domestic supplies.
Ground water withdrawal rates are not known. The Cambrian-
Ordovician aquifer is a major source of water across the state
of Iowa. Wells withdrawing from it can yield from 500 to 750
gpm regionally. The formation is comprised primarily of sand-
stones. The Dresbach Group is also comprised of sandstones and
represents the deepest of the principal bedrock aquifers. It
is present over a large geographic area but yields are generally
not as great as those from the Cambrian-Ordovician.
Ground water in the'alluvial aquifer near the site is
derived from several sources, including direct infiltration of
precipitation, leakage from the Little Maquoketa and Mississ-
ippi Rivers, and lateral inflow and vertical leakage from
bedrock. Underflow from the Maquoketa River valley and slope
runoff from adjoining upland areas are also minor sources.
JDDW obtains its water supply from both the alluvial aquif~r
and the underlying bedrock units, with most coming from the
alluvial aquifer. From 1962 to 1988; an average of 0.75 million
gallons per day (mgd) was withdrawn from the bedrock aquifer and
3.71 mgd was withdrawn from the alluvial aquifer for a total of
4.46 mgd. Peak demand occurred in 1975 at 7.03 mgd. The 1987
level averaged 3.12 mgd. Water levels in the alluvial aquifer
near the site fluctuate largely in response to pumping from plant
production wells, and to a lesser extent by variations in aquifer
recharge and river stage. Upward movement .of ground water from
the Cambrian-Ordovician aquifer into the alluvial deposits will
continue as long as pumpage from the bedrock production wells or
other bedrock wells in the immediate area is not significantly
increased.
The City of Dubuque obtains its water supply from alluvial
wells along the Mississippi River and wells tapping the under-
lying bedrock aquifers. The location of this well field is
shown in Figure 2. Their location and capacities suggest that
the majority of water to the wells is derived from infiltration
from the Mississippi River. These wells have no effect on water
levels and water supply at the JDDW site.
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Figure 2
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LOCATION OF WATER PLANT AND
ALLUVIAL WELL FIELD FOR DUBUQUE, IOWA
Prepared for: John Deere Dubuque Worlts
OIMAYS8ADF
Project Mana,c:r: Steven D. Cl\atma~
Geraghty & Miller. Inc.
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SITE HISTORY AND ENFORCEMENT ACTIVITIES
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site Historv
This John Deere facility began operations in 1946. The
types of manufacturing processes at JDDW have remained relatively
stable; however, factory space-has increased from 600,000 square
feet to more than 5,000,000 as the product line diversified and
manufacturing increased. The waste management history of the
facility is complex and varies based on changes in manufacturing
processes, raw materials used, modifications in final products,
and increasing environmental awareness by JDDW personnel, the
public, and state and federal environmental regulatory personnel.
The plant has utilized two separate' landfills for waste
disposal. The newer of the two, and the one presently in use,
is located to the northwest of the plant site. It is equipped
with'a synthetic liner and a leachate collection system which
pumps the collected liquids back into the landfill. The other
landf1ll, shown in Figure 3, is the main concern of the RI/FS
study. This older landfill was originally placed in a natural
depression caused by the Little Maquoketa floodplain. Before
1974, John Deere had placed their wastes up to the banks of the
river. In 1974, the Iowa Natural Resources Council, along with
the Iowa Department of Environmental Control (now IDNR), required
John Deere 'to place all wastes at least 140 feet from the river
banks. John Deere bulldozed the wastes back within the limits
the same year and placed fences around the perimeter. Some
flooding of the low areas occurred during the filling operations
but no known flooding has occurred since 1965.
Prior to 1968, wastes were placed in the low areas of the
old landfill and combustible material was burned. Wastes
included caustics (sodium or potassium hydroxide), acids
(hydrochloric or sulfuric), petroleum distillents (solvents,
grinding oils, etc.), heavy metals (chromium, lead, zinc used
in electroplating), cyanide (used in heat treating and tool
room), and paint sludges. The only major changes in the manu-
facturing process that affected types of waste generated were
the elimination of cyanide heat treating processes in 1965 and
of cyanide zinc electroplating process in 1977. There are no
records showing quantities of these materials or whether there
were other wastes in addition to those suspected of being
placed in the old landfill. In addition to these wastes, an
unknown amount of foundry sands were deposited in the old
landfill. This sand contained approximately one percent oil-
based resin which was used as a hardener.
In 1980, the John Deere-Dubuque Works had a diesel fuel
spill. The volume of released fuel was estimated to have been
approximately 200,000 gallons. Soil borings showed the fuel was
floating on the water table. A diesel fuel recovery system was
implemented on November 10, 1980. The recovered fuel was
retained for on-site reclamation and the water from the oil-
water separator was discharged to the Mississippi River.
Eighteen monitoring wells were installed February through June,
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Figure 3
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LOCATION OF HISTORICAL FEATURES
Water
',',. ~ Bui Irli fII
Ibil road
Property Wile
Prc:parerJ (or: Juhn Deere
,','
Dubu~uc Wurlts
16JU1.88ADF
rrujccl M.n:l~er: Sleven D, Chal"IOIr
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1981 to monitor the effectiveness of the recovery system. By
October 1985, approximately 86,000 gallons of diesel fuel had
been recovered. One recovery well (RW-3) remains in operation.
Previous Investiaations
JDDW notified the EPA of its status as a hazardous waste
site on June 5, 1981. A preli~inary assessment report, issued
in July 1983, summarized site conditions and cited an initial
hazardous waste rating of 34.95 (low to moderate hazard). A
site investigation was conducted by Ecology & Environment in
1984 and a report was issued in January 1986.
In 1985 JDDW contracted with Geraghty & Miller, Inc. to
perform limited site studies related to the former landfill.
Four supplemental monitoring wells were installed to provide
additional subsurface data. Ground water samples were collected
from 11 on-site monitoring wells and five domestic wells for
analyses of metals and volatile organic compounds. John Deere
personnel have collected additional ground water samples for
analyses. The data'from those activities are presented in
Appendix 1.2 of the RIjFS and are also discussed in Section
4.5 of the main report.
JDDW attempted to estimate the quantities of wastes disposed
of on the plant'property and, in particular, in the former
landfill;portion of the plant. This information is contained in
a document entitled "Superfund Information John Deere Dubuque
Works." The above reports are all on file and available in the
Administrative Record.
Enforcement Activities
The site scored 34.95 under EPA's Hazard Ranking System
(a score of 28.5 is sufficient to place a site on the National
Priority List or NPL). On September 18, 1985, the facility was
proposed as a candidate to be placed on the NPL. However, the
site was never placed on the final NPL. On June 24, 1988, EPA
announced its new national policy in the Federal Register (53
FR 23978) whereby RCRA treatment, storage, or disposal facilities
would not be placed on the NPL. As a result of this policy, the
.EPA announced its intention to remove several sites, including
the JDDW site, from the list of sites proposed for the NPL. One
of the main purposes of this policy was to avoid spending
Superfund money at RCRA sites that are subject to the corrective
action authorities of RCRA. The policy does not prohibit site
cleanup from proceeding under a CERCLA consent decree pursuant
to which the potentially responsible party (PRP) funds the work.
Region VII plans to continue to treat the facility as a
Superfund site.
Deere and Company is the sole PRP for the site. On Sept-
ember 29, 1986, theEPA Region VII Regional Administrator and
Deere and Company entered into a Consent Order pursuant to
Section 106(a) of CERCLA which provided for the development and
implementation of a RIjFS, with the anticipation that upon
completion the EPA would select the appropriate remedial action
measures. The RIjFS has been completed pursuant to this order.
7
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Technical discussions between EPA, JDDW, and their respective
contractors during the RI/FS are summarized in the Administrative
Record for the site.
Deere has indicated a willingness to perform the Remedial
Design/Remedial Action pursuant to a consent decree. The Agency
anticipates that the agreement with Deere to perform the remedy
will be incorporated into' a judicial consent decree within the
next few months.
COMMUNITY RELATIONS HISTORY
The EPA conducts community relations activities to ensure
that the local public has input into the decisions about
Superfund actions and is kept well informed about the progress
of those actions. The community relations program at this site
provides an opportunity for the community to learn about and
participate in the Superfund remedial process and site
activities.
John Deere Dubuque Works and EPA have an open working
relationship. Information sharing is done on an informal basis.
Weekly ~elephone conference calls were held throughout the
RI/FS study to coordinate activities and to resolve issues and
disagreements. The Company routinely shares its weekly
employee bulletins with EPA.
At this time, EPA's community relations activities have
included the following:
-- Established an information repository at the Carnegie-
stout Public Library in Dubuque.
-- Prepared mailing lists.
-- Designated an agency contact.
-- Distributed a fact sheet about project activities to area
interested parties.
-- The Remedial Investigation/Feasibility Study Report and
Proposed Plan were made available for public review at the
information repository.
-- Maintained telephone contact with the community and company.
-- Held a public meeting at the Carnegie-Stout Public Library
in Dubuque on September 24, 1988.
SUMMARY OF SITE CHARACTERISTICS
The old landfill was utilized from 1946 to 1974. It is
approximately 20 acres in area and is situated on the northern
section of the site. Some portions are now covered by
buildings and concrete slabs. It's average depth is 15 to 20
feet. No cover material is in place. nor does it have a
leachate collection system or liner.
, It was not possible to estimate the amount of liquid waste
disposed in the old landfill. They were basically of two types:
1) waste oils and coolants; and 2) caustics, solvents and
paints. Used oils and coolants were disposed of in various ways
I
I
8
-------
both on-site and off-site while the former landfill was active.
.
until about 1968, temporary surface impoundments of oil in the
former landfill and north and south skimmer ponds were ignited
periodically to volatilize hydrocarbons and other combustible
materials. JDDW personnel believe these burn areas would now be
located beneath the existing northern plant buildings. Prior to
1974, used oil or coolant generally was disposed of by selling to
road oilers, spraying on stored coal to increase the energy
gained from its burning and spraying to suppress fugitive dust
emissions.
Waste solvents are generally depleted by way of evaporative
losses prior to treatment or disposal, thus reducing the volume
of waste solvents to be treated and discarded. Before 1980,
waste solvents were typically blended with used oils and disposed
of with the oils. Beginning in 1974, waste solvents were
disposed of in the oil reclamation system. since approximately
1980, waste solvents have been segregated and reclaimed through
the services of an off-site contract reclaimer. According to
JDDW personnel, solvents, oils, and coolants were discharged
directly to the surface water along with other process fluids
prior to the start of operation of the wastewater treatment plant
in 1977. l,l,l-Trichloroethane (l,l,l-TCA) is used as a general
solvent throughout the plant. Plant wide use of 1,1,1-TGA limits
JDDW's ability to strictly control solvent use and disposal. It
is possible that unauthorized disposal of small quantities waste
oils could result in relatively low concentrations of organic
compounds beneath the site. .
Caustic solutions and metal-plating acids generally were
not directed into the former landfill. Plating bath solutions
normally were disposed of off-site via a contract disposer or
were mixed with noncontact water, process water, and storm water
runoff prior to discharge. It is likely that prior to 1977,
caustic solutions and metal plating acids were probably
discharged directly to the surface water along with other process
fluids.
A John Deere estimate of the total amount of solid wastes
materials placed in the landfill include the following:
Sand and Ash
Cyanides
Heavy metals (arsenic, chromium, lead,
and zinc)
Waste Paint sludge
Waste paint filters
Alkali (NaOH salt bath residue)
Miscellaneous Waste
Quantitv (tons)
- 290,000
- 1/2
- 1/2
- 2811
- 320
- 262
- 34,107
In order to assess the impact of disposal of these
materials, a Remedial Investigation (RI) was conducted. The
purpose of the remedial investigation was to collect necessary
data to characterize the site and to assess the potential
release of hazardous materials from the site. Data collection
efforts included surface and subsurface soil sampling, ground
9
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water sampling, and air monitoring.
The collected data were then
used to evaluate potential hazards associated with possible
exposure to the detected contaminants; taking into account
toxicity, physical/chemical factors, measured concentrations,
and present and future exposure pathways. Results of this
process are included in the "Baseline Risk Assessment" below.
The September 15, 1987 RI/FS Work Plan identified known
releases of potentially hazardous materials. Areas and events'
identified in the Work Plan as being potential source areas are:
.i
Old foundry ponds.
Chrome basin leak related to the industrial wastewater
treatment plant.
Diesel fuel line leak.
Several isolated waste oil/coolant spills.
Coal storage yard.
Former landfill.
. ~
The remedial investigation identified the following areas
of concern:
Surface Water- Any chemical discharges through the Company's
NPDES system will enter the Mississippi or Maquoketa River
systems. Also, surface runoff and seepage from the landfill
enters the Little Maquoketa River. Any contaminants contained
in the runoff would then enter the Upper Mississippi River
Wildlife and Fish Refuge. . Chemicals entering the rivers might
impact downstream wildlife and biota. Disturbances of the
landfill slopes would be a concern in ca~es of extremely high
river water levels, but the landfill slopes appear to be stable.
The Company reported that the Little Maquoketa experienced a
500 year flood in 1972 with no instances of slope failure at the
landfill.
Potential parameters of concern which were detected in the
surface water discharges were benzene, bromodichloromethane,
1,2-dichloroethene, chloroform, 1, 1, l-trichloroethane, trichloro-
ethylene, and xylenes.
Ground Water - The plant obtains its water supply from eight
production wells located on-site. Two wells are installed into
deep bedrock aquifers while six wells are constructed into the
alluvial aquifer. The predominant direction of ground water
flow in the alluvial aquifer is toward the 'production wells.
contamination has been detected in the on-site alluvial
production and monitoring wells. The chemicals include: 1,1,1-
trichloroethane, l,l-dichloroethene, carbon tetrachloride,
tetrachloroethene, trichloroethene, benzene, nitrate, chromium,
iron, and manganese.
Specific sources of ground water contamination were not
identified. However, localized areas of contamination appear to
exist near production well-3 (PW-3) and soil boring well-3
(SBW-3). The locations of these wells are shown in Figure 4.
A nonaqueous phase liquid (NAPL) is currently being recovered
in the vicinity of PW-3. This material may be present due to
10
-------
the diesel fuel spill of 1980.
Some of the constituents
detected at PW-3 may be due to dissolution of the NAPL into the
ground water system. However, low levels of chlorinated volatile
organics, which are not common components of diesel, were also
detected in ground water and the NAPL samples. The source of the
chlorinated compounds is assumed to be from previous solvent
handling practices at the site. contamination at SBW-3 may be
related to a past chrome basin leak (the chrome basin is part of
the industrial waste water treatment system).
The City of Dubuque's shallow well field is located about
3.5 miles from the JDDW plant. The contaminants in the alluvial
aquifer at JDDW have no influence on ground water at the Dubuque
well field.
Surficial Soils - Data indicate some concern for transport
of potentially contaminated soil via runoff and seepage from the
landfill into the Little Maquoketa. The constituent of concern
is lead at the old landfill. possible exposure points would be
direct contact with contaminated soil and ingestion both off-
site and at the JDDW grounds. .
Air- A large percentage of the immediate plant work area is
covered by pavement and buildings. Volatile organic con-
centrations in soil and sediment samples are minimal and are
not expected to be present at levels that would impact overall
air quality. Lead could present a concern due to possible
inhalation of fugitive dust at the JDDW grounds and the off-
site residences along the Mississippi.
Ground Water Flow Durina Plant Shutdown - Pumpage of
production wells on the JDDW property controls ground water
flow in the alluvium beneath the site. The flow of water is
from the Mississippi River toward the pumping wells. However,
in the absence of well pumpage, flow would be toward the Miss-
issippi River and the private wells in the vicinity of JDDW,
particularly those to the east between the plant and the
Mississippi.
SUMMARY OF SITE RISKS
Baseline Risk Assessment
A baseline (no remedial action) public health evaluation
was conducted on the potential hazards associated with possible
exposure to contaminants detected at the site. Sampling at the
JDDW facility has revealed inorganic metals and several organics
in the soils at the former landfill, inorganic metals at the
foundry sands area, and petroleum hydrocarbons and solvents
beneath the JDDW plant and near the chrome treatment basin.
Indicator chemicals were selected to identify the highest risk
chemicals at the site so that the risk assessment focused on
the chemicals of greatest concern.
11
-------
Of the constituents found at the site, lead and manganese
were designated as indicator chemicals for the inorganic
constituents in soils (only low levels of organics were detected) .
Benzene, carbon tetrachloride, 1,1-dichloroethene, and trichloro-
ethene were designated as indicator organic compounds for ground
water. The major pathways of potential exposure to these
contaminants are:
- Contact w"ith, and ingestion of, small quantities of
surficial soils;
- Inhalation of fugitive dust;
- Swimming in the Mississippi River; and
- Contact with water pumped at the JDDW facility.
Exposure to the soils at the old landfill and foundry
sands area were assessed for workers, off-site residents and
hikers. Estimated chronic intake levels of the indicator
chemicals were calculated for potential routes of exposure.
Human health hazards are considered minimal based on the
comparison of estimated intake levels to acceptable chronic
intake levels as published by the USEPA in the Superfund
Public Health Evaluation Manual.
Discharge of organic constituents to the Mississippi
River was assessed for swimming and fish ingestion exposures.
Swimming in the Mississippi River in the vicinity of the plant
is considered an infrequent event and the constituents detected
in the NPDES discharges have low bioconcentration factors.
Consequently, the potential for discharged organic constituents
producing adverse effects from swimming or fish ingestion is
very low. .
Environmental risks at the site are considered low. Access
to the site is controlled and there has been no identifiable
stress to off-site vegetation. Concentrations of the inorganic
parameters in the Little Maquoketa and Mississippi Rivers were
at background levels and below federal aquatic-life water quality
criteria. Bioconcentration factors and biomagnification
potential for the organic constituents are low. Therefore, the
organic parameters should not concentrate in the aquatic food
chain. Overall, the potential for adverse effects to the
terrestrial or aquatic ecosystems adjacent to the JDDW facility
is low.
Figure 4 shows the production wells at the plant in relation
to the Mississippi River and off-site private wells. There are
no wells other than the JDDW production wells that are currently
being impacted by the organic constituents in the ground water
because flow in the alluvial aquifer is toward the production
wells. Future hypothetical risks associated with the ground
water are related to discontinuation of production well pumping
for a period of time sufficient for the organic constituents to
migrate to the residences located east of the facility. Based
on computer simulations under non-pumping conditions, it appears
possible that the concentrations of the indicator chemicals could
exceed the federal drinking water standards if pumping were to
cease for long periods of time. Concentrations of chemicals
in drinking water supplies above these standards would result in
12
-------
8r..-
--
..------ -- -
.
- ..
,
G5M ConsuItin& £n&ineei'S. 'Inc.
.
-.
Figure 4
. ': '........, -~--= = --~-' :!' ~ --- - "-'" ,
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--~. ".. ' ,~~ii:, ~ ~~, \
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-'=--' "-=:'.' 0 """,,',~ .~~~ S R=-=~-:;"=s~-~I
---:. ~~-" '~1 ~e~,,~ ;".,~~-.; ~~=~ e'~t;e ~~~I
---".' ~~'~~;~ ,1.'>", ,"'-'~ = ~"--=-
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." :x '~- ~. .. '" ~~ --- -=---.-'"'-;~-~
" . : ),~ PW 3.d'RW.3 JO:~ ~~~~ - .,=:=;;;-:=:::'i
. # '>~.. ..., . ,.....-:'~:.... ~::'k"" ~ ~ '''-,~ * -~._--'":.-'""'-'"~.::::::I
. '\.,. ",,~~':'1"~,> ~~ ',,~-.-.:~ --- -~---_...--
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. - . }-, - '. ,~~. , "" -,~iif.:.;.. '<" .C"')---- . - ~ . .-.~-,._.~~
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. .- --- -Oil' ".-t,¥,~."<:A',:,,, ~... '~"''-~ -~ -~_._-...;=----
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. :;.~f :.:.~.. <. c' ~~~' -..,. ..,...:t::;.~J':~;:;:3i~. . "~~~~.=~=~'~~
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~ -~~.~:" t! \, V . ~'""i~~~~ .-;';.:.. .~ '~~--==~;:
,.;' -~~:-_~ "\ i; '.....? 7' ~t~:.u.' , ~'!.~:, SBW-3.. '~~~'~=';'==I
;.. -:-;.:::.:( '\:' ! ': V" , '\.~ .. '.. . , ....... :;:..:.:~~, ". ,,\'..~..==::;.:..-:::.=:
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-- ~/"'.'" "'i, ~-,..w,;,_:,,~ "~""".'-:' \\.,----
..~ ~~ ~\ .'. , ~.. -.;;.), <;~~.~!:::.t~.F~.:.':~.~~,.,.:':. \'.;..=1
,- F.' ". , '\.' ":~"~~"~ """'.'::;;.'- <.. ..",-'-
~.,~,_::' . .-:~"'-{ \-- .>~, ~w-7\~ii;~~~\;~~~:.:: ,~
...'!: --'. .J",r" '/. '\':.-s.~';;-:~~"':~',"""";;" " ',: . ,-;::-
. . .~." jf \'~""."., ~~~~.~;:':.:".....". ..,:~"' fi .,-:
LEGEND' ,,\- v
-------
the potential for adverse health effects. Continued pumping at
a minimum rate will maintain the "capture zone" and prevent the
off-site wells from becoming contaminated. CUrrent modeling
simulations indicate that a pumping rate of 1.2 million gallons
per day (mgd) is sufficient to maintain the capture zone.
Plant production water and potable water are also in the
process of being separated. Thus, all potable water at the
facility will come from uncontaminated deep bedrock aquifer
wells. This action will also eliminate future showering
exposure, although the potential cancer risks associated with
showering are much less than one in a million.
Preliminary results of the risk assessment indicated the
need to complete exposure scenarios involving worker exposure
to possible air emissions of VOCs. From the production wells,
ground water contaminants are pumped into the water distribution
system, where plant manufacturing processes dilute, degrade, and
volatilize the compounds before they are discharged to a holding
pond prior to being discharged to the Little Maquoketa or Miss-
issippi Rivers. JDDW and the EPA agreed to the following tasks
to evaluate air emissions: :
-- Review of available air monitoring data collected by
JDDW through the confined spaces monitoring program.
-- Selection of confined spaces for ,air sampling based on
~ review of the JDDW confined spaces monitoring program
and the proximity of confined spaces to possible
contaminant plumes.
Air sampling of the selected confined air spaces using
a portable field gas chromatograph.
JDDW has an air monitoring program to test air quality
in confined spaces in all plant buildings and facilities.
Areas included in the program are open and closed tanks, under-
ground passages, equipment sumps, and selected rooms and
buildings. Results from the program showed that, in general,
unless a confined space contains a specific chemical as in a vat
containing solvent for cleaning metal parts, there does not
appear to be any historic problem or concentration of volatile
compounds exceeding Occupational Safety and Health Administration
(OSHA) worker exposure ,standards.
John Deere Dubuque Works and their consultant reviewed
confined spaces and selected two for air sampling based on;
the proximity of the confined space to the known NAPL plume
a possible 1,1,1-trichloroethane plume in the south-central
portion of the plant, (2) the depth of the confined space below
ground (the deeper confined spaces were chosen), and (3) worker
accessibility. Two air samples were collected at each confined
space. The first was an ambient background air sample above the
confined space. The second was collected in the confined air
space itself. A portable gas chromatograph was used to perform
the analyses. The instrument was calibrated for the following
compounds:
plant
(1)
or
13
-------
.
ComDound
.
1, 1, 1-trichloroethane
1,1-dichloroethane
1,2~dichloroethane
benzene
tetrachloroethene
toluene
trichloroethane
Detection Level(DDb}
100
5
100
5
5
5
5
No compounds were reported above the detection levels.
In summary, the primary hazard associated with the JDDW
site is the possibility of dissolved organic chemicals impacting
off-site domestic wells located east of the plant along the
Mississippi River. Maintaining a minimum pumping rate of 1.2
mgd will prevent migration of contaminated ground water to the
off-site wells. The reader is encouraged to see the Remedial
Investigation Report for a more detailed discussion of the risk
assessment. .
14
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DOCUMENTATION OF SIGNIFICANT CHANGES
The selected remedy is the one presented as the preferred
alternative in the Proposed Plan. There have been no significant
changes made as a result of public comments.
DESCRIPTION-OF ALTERNATIVES
Table 1 summarizes the effectiveness, implementability, and
cost factors of various response actions for both landfill and
ground water remediation. Eight alternatives were initially
examined and "pre-screened" prior to drafting of the feasibility
study. Each included some combination of the Table 1 response
actions. One alternative was a contingency plan which was
prepared to address the conditions which may occur if the JDDW
production wells were shut down for a prolonged period of time,
or if production well water required additional treatment.
The preliminary alternatives also included some form of
remedial action at the former landfill. With the exception of
the contingency plan, all included access restrictions to the
landfill. Four of the alternatives considered either a cap or
cover to prevent direct contact with contaminated soils and
reduce ground water contamination due to percolation and leaching.
In addition, two other alternatives included excavation with soil
disposal in an on-site RCRA landfill to prevent contaminant
leaching, direct contact, and inhalation.
During the RI, a risk assessment (discussed previously)
was conducted to determine the potential exposures and associated
risks involved with the constituents released to the environment
as a result of JDDW past operations. The RI soil data indicated
that, in general, contamination was broadly dispersed at
relatively low concentrations. Conclusions drawn from the risk
assessment indicated that human health hazards at the landfill
could be considered minimal, based on comparison of estimated
intake levels to acceptable chronic 'intake levels as published
by the USEPA. In addition, contaminated leachate seeping into
the ground water is unlikely to be a problem based on EP-
toxicity testing. As a result of these determina~ions, excav-
ation, capping, or covering the landfill were not considered
necessary and those parts of the alternatives were eliminated.
However, access restrictions, specifically deed restrictions
and a security fence, were retained for consideration in order
to control future uses of the area. -
After preliminary screening, five alternatives were
selected for final evaluation. These alternatives and their
respective response actions are presented in Figure 5. All of
the alternatives include continued pumping of alluvial
production wells for on-site containment of the contaminants.
15
-------
Sofl,~. rei
Air ~ Acticn
MXDS IES1IICTIOIS
DIIP/IDoSI :
CDfTAIIIeIT
DtAVATIOI
1M) 0 I SR.I!iAL (01-
SITE lOA LNOF Ill)
~ leter Resp:nIe
Act i as
AL~TE ~TER
SJIPL Y: 19'1A TE
POI'A8L£ ~TER
IOfITCRIIG ~ AI.IJNlAL,
POI'MU, /IIIJ fill>
IU:TICJI Ia1.S
ElnUcrICJI rE
PmU:TICJI Nt)
AU.I.NJAL Ia1.S
PMYSICAL TJEAMNT
WITH EXI ST Uli SY'ST9C
-AWN1AL \al.S &
..... 5P I Ll
Table 1
IESFCN5E N:1'ICJI I.MWrf
Clmtial ~i.,. t1f AltlrT8tiws)
Effcti......
DI8f rwtrictfcn we
........ t ~ l~tInI
.1.. -- t. A .8:Uity
fret f. effcti"'8 if
.frafrw:1.
Effcti"'8. lav. CD
f. PM fI.....d. .i. fraI
dil"8Ct CD1t8:t i. ~
CG"It88i rwt i en t1f IJ"QId
II8tW ~ bJt rot
el illirwtld. ~i.,. i5 a
wll-.tel ilNd t8dTolcgy.
Effecti... rd reI ilCle;
rw:iDs p!Jt8"ltial for
CXII"It81ri IW'It l..n i r;.
Pr'atctien I"tq.lire lUIIirst
dlnl81 CD'ItaCt rd imalat;en
t1f Cl2"Ulril'lltld d.&t.
Effcti... rd aa:2r'8tely
relilble. CD ~re to
pI"8W'It lrdf i II f8il\l"'e.
Effect i... in pI"e\IWIt i r; \.&e
t1f c:cr'It8Irirwted crirti.,.
l8ter at ft pllnt; I"81c i r;
rislc to ft loer ~fer.
hn:f 18t.. .mtorl.,. will .
cD:uIrIt CII'di ticn rei
8CtrIt t1f plu. iii W"8t; en.
Doa rat I"8d.I:e CICI'It8Iri rwt i en.
Effcti... rd rel iele;
~ 18t.. .mtcrir'8 will
...ty effcti...- t1f ft
ertractien I)'St8L AqJf fer
ct'IW:tv\ ~re to .irain
.. Gf 'nfl'-8'CI.
Effcti... rd reI ilCle for
~I at IUiIpIIr'dIId 8:>1 ic&.
1IqJi,.. .1,* di IJXUI.
lID~i I ftv
~l ~r...u . f
fer c8ad rwtricticn; 8:Ulty
fret f. _fly .88'It81.
A ClIP or COIW' 'a _fly
..88'ItId bJt ttw. ...
... l8gl1 ~r...u for
c8ad rwtricticn.
~ly illpl8W'ltlble.
IDA lrdfill relati...ly
88Y to i.8IIr'It. 110
offsita czrst~ien.
Pnri ts 7?
~ I y i.p 8II!I"IUble;
c:crMr1Cicnl czrst~ien.
IlCily IIIpl..uble.
IICi I y lIIpl-uble. --
i..... JOIoiI-t. ... t1f .istlr'8
walla.
lIIp(~e; IDINw
~ity t1f .iatir; ~ttm
wi II I illi t wlu. t1f l8ter
tfwt C8"\ be trwta:1.
-
IIIllgUII. fer c8ad
rwtrlctfcn; 101
Clpit8l rd CD for
8U'ity fret.
LOI to a.dw 6t1t
Clpit8l; lalll to hi",
.iruwa ~r;
«I' t)p t1f COIW'
""'ial.
Mlldlnte to hi '"
CllPi~l ~t1nS.
Mlldlnte c:apital.
ftr:i!nte apital, ICIoI
CD.
l.CII CIpi t81 , lGIII CD!.
l.CII CIpi t81 , lalll CD.
110 Gfiticnl apital
~t1nS; II:dI!nte
(1M.
-------
Table 1
(cont.)
Effer:tf-- 18X..ubi I itv ~
IJCUGJCAL TlEAMNT -- b8 I'Hctf.,. for IIIdIty -~., III) 8d:titicnl Cllpft8l
WJT1I EXlSTIIIi sm9II rilllMt fit Ndty bfO" ...... Cllp8:f ty of ~tI.r8; 8:dIr8te
-...uNIAL .aLS .. ~. .....,tea .... wi It I fIIIt _&8 CIM.
IN flail Y to b8 ..., I'Hctf.,. ", .... tIwt CIr'I b8
.., .at CII'It8IIrwu fit tr'IIC8t.
CII'&:8f'ft.
""'lex. TlEAMMT II:Itft efr 8trf~,.. nI -~. b.a pilat Afr Itr'f~,.. . law
WJT1I C8:JI ..,.101 C8tI:n ~fcr'l ... ~ 18tf,.., dIIIf.., nI CIIpi t8l, 8IIdr8te CIM.
8~ AIR STRIPPIIG t8drDlagi.. TI'8t88'C fit ~i.., ,...,n1"8d c:.ta'I ~fcr'l .
4D.Cr10i & AWNIAL Jl"llkticr'l wl t .... br ~ .tIo. Clpital, hilitl
.au 8Ctf~ C8tIcr'I -r b8 CIM.
irwffctf.,. cia to l8"I!
.... -1.88 nI Nl8tfwt y
law~"" ...'-oj(,n,liers.
StrfFPir'l tQ8r ._iers
antrola ~y rat ~1"Id;
.... wpr -r b8 . pUX811
fn wlru-.
CFF-sm DISOME Effectf.,. for r'8U:ir'l ~ II8:fi I y f~8IIr1tICle. Law Clpit8l, law CIM.
Wlter CCI1t8Iri ret f cr'I. E HlL8"lt Existir'l di 8dwge IZ"Iri ts
a:nt8Irirw1tS aat r'I:It a:Mrvly -r I"8:JIi re !Wi I f cr'I.
~ Mi.i.f~i rd Lfttle
~ Rf*'S.
-------
ALTERNATIVE 1 -- NO ACTION
The Superfund program requires that the "no action" alter-
native be considered at every site. Under this scenario, John
Deere would take no further action at the site to control the
contamination. Extraction of the ground water from production
wells and discharge of wastewaters at selected NPDES outfalls
would continue for on-site containment .of ground water contam-
ination as part of normal production activities. Under
Alternative 1, JDDW would not be required to continue ground
water pumpage in the event of plant shutdown. Also, the quality
of the plant's potable water supply would not be improved.
Monitoring of specified potable and production wells, as well
as those installed to monitor the NAPL spill, would continue.
The "no action" alternative would not require any capital
expenditures by JDDW.
ALTERNATIVE 2 -- EXPOSURE PREVENTION AND CONTAINMENT
This alternative would eliminate the potential risks
associated with the alluvial ground water through installation
of an alternate water supply for potable water usage at the
site. Currently, an alternate water supply is being installed
at JDDW to replace alluvial wells PW-4, 5, and 7 as potable
water supply wells. The new water supply will use bedrock
wells PW-1 and PW-2, which are uncontaminated based on data
from the RI. Production well usage will then be as shown in
Figure 5. Halting production well pump age of the bedrock
aquifer will also reduce the threat to that aquifer by main-
taining an upward gradient. Extraction and monitoring of
production wells would continue under normal operations. The
alluvial wells and those wells connected with the NAPL spill
would be monitored.
ALTERNATIVE J -- NAPL MANAGEMENT
This alternative includes the same actions as alternative 2.
In addition, the NAPL spill would be extracted and treated using
an existing system (oi~/water separation). The existing system
consists of a recovery well installed near PW-J to intercept
the NAPL and an API separator. The ground water effluent is
discharged to the south skimmer pond and ultimately NPDES 005
(Figure 6). Following implementation of this alternative,
floating phase NAPL from the separator would be collected and
transported for off-site waste management. Collected NAPL
would not be stored on-site for a period longer than 90 days.
Reduction of the PW-J pumping rate may be considered to
reduce the tendency of NAPL to enter the PW-J well screen.
Should PW-J pumping be reduced, the pumpage rates at PW-4,
5, and 7 would be increased, as necessary, to meet plant water
usage needs and to contain potential ground water contamination
on-site. Thus, continuation of existing NAPL management
methods would supplement the remedial action objective of
aquifer restoration.
16
-------
".
Figure 5
~
I
f
J
'."er.' ..... .. I.tt... AIU,net .". , AIU,n"I". I A It.,,,.. '''I J A" .,11" ,,,. .. alter..."., ..
A'.' .r uo"o,.,.. "'Ctl' .' fllp.IU'. Ir,.'.,", tr..,.,", .f "..,..", .f
..ell"" c.",.," 'rPI Optl." Act"" ".",,,'1." ., "'l IA'l .nd "V.1 .r.. ,A'l .hI "V.1 .,..
., DUf'd ,.tt"lt alt"":~I' 'v,. 'VI . . . .
u.t., V,"r ..",1, V".r' I., U..,.
,'V) ..."1,,,1,,. 'pu"led . . . . .
u.' II
""uct It" "1ft""'"' 'PU""d . . 0 . .
V,II VU., V.I ..
"'nc"." h" tI", . . . . .
v.lI.
Off..I" ."n . . . . .
.18.11.". ou'h'h
.1I"l ..,", '0' '"I 'pul"'d . . . . .
v,1 ..
h'nc"... h'U'"' . . .
V,lIt
'hyt'ca' hl.tI", . . .
'r..'..,,' '1"".
Off' ,II. ~~~'l:1U ,en . . .
.......,
Off. ,,,, ."'11 . . . .
II ..118,., au'h".
IIV.J ar.. ""''''''"1 ,pu, , ..11 Jt- ~ . . .
v., II
"'n.tI... I.c.""y . .
v., II
'111'1"" Alt .
"..,...., 11,'_1"1 ...
"""'C.. '1 "'"' .
'n".."t '''"1
Oil...,. ....n ". . .
""h",. au'h".
"
.... ...
._".....
;Y' ~;i~
'4W'. ...,
~ . ,,..
...... ..1'
~~( ".,."
GMCE
..,,, 1"0..,.......,. ,.......... l1li:
-------
Figure 6
A
®__-
S— •
V_x
•^. ^
n
— *Tfl
— * TP
"X
OMESTIC
IEATMENT
PI ANT ».
c — '
i 1 PLANT v r
C§ • ii fcj
" '" ' " ioci»iuci 1
i ccuMiwMtn
C —i *" f cumiwMin
fc ...... 1 - n,r, , . k
*
NORTH
SKIMMER
POND
SOUTH
SKIMMER
POND
DOMESTIC
«»,»« l1171^ MAOUOKETA
POND 'ftlVERl
(UTUE MAOUOKETA RIVER)
(MSSISSPPI RIVER)
C. . . SKnUVKIIH
FIRE prwww mi
^ DonTcr-Tirtu 1
'
f mm* M* ">
(J •/•/!•
•*•<• »•«»
• aio i cwi •• *
LEGEND*
tf*»UH
INDUSTRIAL
WASTEWATER
TREATMENT
PLANT
(7) ALLUVUt MOOUCTtOM WELL
/^\ BCONOCN WOOUCTION WtLL
mCHLOHINt . SOOWM IKXAMCTAPHOSPHATC
ADDITION
-^'NPDES 011 ft> NPDES 006
(MSSISSPP) RIVER)
f 1
M}if: /• "\ r' AITFRMATf* POTABLE A
PMXCSS »*n« owowAifjo »«OM PW .«. rw.» AMI fw.r. ***•• JrrrSSii ^.Ji innr v
SUSCOfOnMACnous APf\r;A>CNS unoudout i»c P1ANT. ^% • m f^ mm • WAI Cn 9UKI"!.*
ins WAIER MAY OE CUSCKAIM n M niirAus no?.oo«i. Am on. X3I IVI Vr t FOR JDDW
it«u f«iM^tniiNi; iMiMiiMi wi: f CASIH.IT V STUW: JO*40(CnC CWHJQ^ WOWHS
1 DUBUOUE. IOWA 1
V _ J V -/ j
-------
ALTERNATIVE 4A -- NAPL AND ALLUVIAL GROUND WATER (SBW-3 AREA)
MANAGEMENT
Alternative 4A is basically the same as number 3: that is,
an alternate potable water supply, extraction of the production
wells, and physical treatment of the NAPL spill. In this case,
localized remediation of the alluvial ground water system
would also be achieved by extraction of well SBW-3, followed by
treatment via the existing biological industrial waste water
treatment plant. Treatability studies may be required to
determine if the ground water extracted from SBW-3 could be
managed in the existing plant. Hydraulic capacity of the
plant may also limit the implementablity of this alternative.
:,The biological plant would effectively remove the volatile
:organics from extracted ground water. Aeration achieved in the
:carousel ditch of the system should be adequate to remove the
volatile organics.
,
'ALTERNATIVE 4B -- NAPL AND ALLUVIAL GROUND WATER (SBW-3 AREA)
MANAGEMENT
:Alternative 4B is the same as 4A with the exception that
:an afr stripper wou~d be used at SBW-3 for treatment of recovered
;grou~d water prior to discharge to the biological plant and
eventually the Mississippi River via NPDES outfall 011. 'Air
stripping would probably' be performed in either a packed air
stripper tower or in an air diffuser tank system. Based on
available hydraulic capacities, treated ground water would be
discharged into the carousel ditch for additional aeration
and VOC removal prior to surface water discharge. Treatability
. studies may be required to determine the appropriate process
options, and to optimize removal efficiencies.
CONTINGENCY PLAN
This plan was prepared to address the conditions which may
occur if the JDDW production wells were shut down for. a
prolonged period of time or if recovered ground water from
production wells required additional treatment prior'to use as
process waters for the plant. John Deere has gone on record as
saying appropriate pumping of production wells will be maintained
at the site, as necessary. .
Prior to implementation of any contingency plan it would be
necessary for JDDW and regulatory personnel to evaluate changes
in site conditions, regulations, remedial technologies, etc.
Studies may be performed to optimize the effectiveness of
implementing the contingency plan.
This plan was provided to illustrate remediation strategies
that could be implemented. Ground water recovery rates from
PW-3, 4, 5, and 7 would be maintained for a minimum total
recovery rate of 1.2 mgd, the minimum flow for containment of
the alluvial aquifer underlying JDDW. Constituents recovered
in ground water could be treated in air stripping units,
installed at each production well. Treated ground water may
17
-------
be managed in two different scenarios: 1) treated effluent
could be discharged to surface waters from NPDES permitted
outfalls via the industrial treatment facility, the sanitary
facility, and/or 2) treated effluent could be injected into
the alluvial aquifer to recharge the aquifer and form a
hydraulic barrier between the impacted ground water and
potential off-site ground water users. Use of the hydraulic
barrier may make it possible for JDDW to decrease ground water
recovery rates and still maintain on-site containment. The
existing NAPL recovery system would remain in use and recovered
NAPL would be incinerated off-site. Use of the API separator
.would still be used and ground water still would be discharged
to the south skimmer pond and then to NPDES 005.
****************
Alternatives 1, 2, 3, 4A, and 4B were then screened with
respect to effectiveness, implementability, and cost. This
analysis is summarized in Table 2. Alternative 2 was eliminated
from further consideration based on the initial screening as
presented in the feasibility study report. The alternative was
protective by virtue of providing an alternate water supply and
aliuvial aquifer restoration. However, it did not address the
NAPL floating on the ground-water surface near PW~3. If the
NAPL is not extracted in a separate system it may be extracted
from PW-3, which could impact plant process operations and
surface water quality at NPDES outfalls.
. Alternatives 1, 3, 4A, and 4B then underwent a more
detailed analysis according to nine criteria as defined by EPA
in the 1988 draft guidance for conducting a RIfFS. A summary
of the detailed analysis of the final alternatives is presented
in Table 3.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT. This
criterion addresses whether or not a remedy provides adequate
protection and describes how risks ~re eliminated, reduced or
controlled through treatment, engineering controls, or
institutional controls.
All of the alternatives, with the exception of the "no
action" alternative, would provide adequate protection of human
health and the environment. Risks are reduced and controlled
by maintaining a capture zone such that contaminated ground
water will not migrate off-site and gradually reducing levels
of contaminants. Replacement of the potable water supply
with the use of uncontaminated bedrock ground water from PW-1
and PW-2 would mitigate the potential risks for direct contact
by on-site workers to contaminated ground water. The NAPL
recovery system expedites remediation of the alluvial aquifer
by removing concentrated quantities of undesirable constituents.
This unit consists of an API separator which'removes the floating
NAPL for subsequent off-site management.
18
-------
Table 2
Inltl.' Screenlne 0' 1e.ed'.1 Altern.tl.es
'e.sfbllltv Study: John Deere Dubuque Uork.
Oubuque. low.
....dl.1
'I Urn.t I".
(flIIG tlnflJ~
letl.ette..
'rot.et'.en...
8.1::r:::I::)'
- 0 .round-w.t.r "on'tor'n,
o Contlnu.d 'roductlon
"el' 'u.p...
-
o Cont'nued eplrot'en .f the
production w.I'. would
pr...nt .'f..'t. .'.r.t'on 0'
,round-wltlr cont..ln.t'on
o Ih. pltent'., ,...Inl for
..po.ur. of JDD" plrlonn.' to
eont..ln.ted potlbl. w.t.r
~~
AIUrn.tlv. Z
o Cround~v.ter "onltor'n,
° Continued 'roductlon
Veil PU8Ip.,e
o Altern.te V.t.r Supply
o Addr..... the r...dl.1
.ctlon obJectl.ea
eat.bllahed fn the FS
o A .'n',,' rl":
e.po.ur. would
conduct In, the
.ctlon.
'or worhr
relult 'ro.
,.Mdl.1
° 'h. r.-adl.' .ctlon.
conducted vould not
.dver.ely ."ect the
aurroundln, co..unlty
° Continued oper.tlon 0' the
production ve'l. vou'd
preyent olf..'te .I,rltlon
01 conte.ln.ted ,round ~Iter
-- - Altern.".. ]
° Cround-".t.r "onlt.r'n,
o Continued 'roductlon
Ve" 'W8p.,.
° A't.rn.te V.t.r IUPP',
° MAPl lecovery/lr.et..nt
o Addr..... the r..ed'.'
.ct'on object'...
e.t.b".hed 'n the 'I
o A .Inl.., r'lt f., ..rt.r
'.po.ur. would r..u't fr..
conduct In, the re-.dl.'
.c tI on.
o Ih. r...dl., .ctlen.
conducted "ould net
.dyer.ely .,f.et the
.urroundln, eo..unlt,
o Continued operlt'en .f the
production "e". "ould
pteyent off..lt. .I,r.tlon
01 cont..ln.t.d ,round ".t.r
o 'eeovery of tAPl would
enh.nce .qulfer re.tor.t'on
Att.rn.tlv. 4A & ..
o 'round.".t.r Ron'tor'n,
o Continued 'roductlon .
".U 'WIp.,.
o Alt.rn.t. V.t.r IUPP"
o tAPl I.eo.ery,'r..t..nt
o I'''-J Ar.. M.n..e.ent
o Addr..... th. r888d'.'
let 'on obJ.ct'.el
..tlb'l.h.d In the fl
o . .In,..t rl,t f.r work.r
..po.ur. would r..u't fr..
eonductln, the r...dl.,
leUonl
o 'h. ,...dl.' .ctlon.
conductld "ould not
.dv.r..I, .'flct thl
.urroundln, c...unlty
o Continued oper.t'on If the
production ".11. "ould
prlv.nt off..lt. .I,r.t'on
of cont..ln.t.d ,round
w.t.r
o I.eo..ry .f .APl would
InII.ne. .qu' ler
r..tor.tlon
° I.cov.ry .f cont..ln.ted
,round v.ter .t SIU-]
yould enh.nc. Iquller
restorltlon
~
3:
g
i
i
"
j3:
W
- .
-------
Table 2
(cont.)
'nltlol Scr~."In8 0' l.-.dlo' Altern.tly~.
'e.sibitlty Study: John D~er~ Dubuqu~ York,
Oubuque. low.
, ....dlol
Ilternulve
~
° .round-wot.r "onlto,ln,
° Continued 'roductlon
V.tI 'UIIIP','
"Uernotlve Z
° Ground-~ot.r "onltorln,
o Continued Production
Ve II PUlllpo.e
o "Itern.t~ V.ter Supply
Altern.th. S
o Oround-w.t.r "onltl,ln,
o Continued ',oductlon
Veil 'UlllpO,.
o "Itern.t. u.t., Suppl,
o NAPl .ecovery/rr.ot.ent
AI',rna,IVI &A I &1
I .,IUnd..,t., lonlto,Int
. Continued "oductlon
Voll 'UIIp','
. "It.,n.t. u.t., luppl,
o I"'l I.cov.r,"r..t..nt
o SIV.) ",.. ..on.,..ent
[(III' CIU'UIA
l.-.ntobillt, (Continued)
A dill I nhtnt I".
'enlbll Ity
t (lolotlYI)
C.plul
..pt oee.eM
0&"
. olned for De..lled
,ty.t. 0' AU.,n8tly..
'081. fS1
IASern. tbt
o ""'1.11 f,.. '1IUI.to"
o..nel.. tl I.,I...nt
olt.rn.tl.. I. unllk.l,
o A~'tl ..,t fo,c.,
..t.rl.I', .pacl.ll.t. .r.
ovellobl. -
° low
. low
o lo~
0'"
o ""'0.01 f,.. ,e,ulot.',
o..nel., to 1.,1...nt
otte,n.tly. I. unllk.ly duo
to pre..nee 0' IAPl
o Adequate ~ork fo,e.,
.ot.rlol. ond .p.eloll.t.
.r. ovoll.bl.
o ....dlol octlon t.e~nolo"
co~onent. oyoll.bte .nd
eoutd b. ...Ity IMpl..,nted
.t 'he .It,
o ""'0'1101 fr.. ,.eulot."
o,.ncl.o to I.,l...nt
ol,.rn.tlv. ,. llk.l,
o "d'qUoto wo,k f.,c.,
.0,.,1.1. and op.cl.II.t.
a,. ovellobl.
o 1...dl.I .ctlon tocllnel..,
c..,.n,nt. or. .vollobl.
and could be .0.11,
18p1,.,nt.d ot the olto
I Appr...1 f,.. ,o.ul.,."
o,onelo. to 18plo..nt
81to,notlvo I. llkol,
. Ad8qu8tl ..,t f.rc.,
..t.,I.Io .nd .poclol,.to
or. o.ollobl.
. ''''''01 octlon .ocllnel..,
c08pOft8nt. a'. o.olloblo
.nd could be .0.It,
t.,I...nt.d at the .It.
o lOll 0 lIodent. I "od"ot.
o lOll 0 lOll . "odo"t.
o Mod.rote 0 Modero" 0 "od,nt.
o 10 0 ,.. . Yo,
. .
~
~
G'
iJ
J
i
!
w
-------
Table 2
(cont. )
Inltlel Screenln. 0' .e8ed'el .Iternetlvee
"8sibilitv Study: John De,r, Dubuque Uort,
Dubuque. 10'"
.
~
~
~
~
fQ
i
J
5'
f'\
.0
....dlel
Alurnetln
ft.:::'::: I::) ,
. 'round-weter "onlto,In,
o Continued 'roductlon
Veil 'U8pe,e
AI terneHve Z
° Ground-.,eter "onltorln,
o Continued production
Uell P"",pe,e
o Alt,rn,te U.ter Supply
.Cte,nltlve J
o Ground-w.ter "onlt,'fnt
o Continued Production
Veil Pu.p..e
o Altern... U.t.r Suppl?
o MAPl leeovery"r.et..nt
Alte,n'tf.e 4. . 4'
. 'reund-w.ter Monltorfnt
. Continued productIon
VeIl pUllpe,e
. .Ite,n.te V.te, supply
. '.'l lecovery,T,e.t..nt
. IIU-' .,e. "~ne,e.ent
iC.Ef"I, CRITEIIA
:I'ectlv~ee (continued)
'eductlon 01 ro.lelty,
"obility 0' Volu.e 0'
VII II
..,Ie.entebillty
hchnlul'
""Ibltlty
. ..cev.red ,reund wet.r would
be tr..ted t. reduce the
toalclty, ..blllty end
volu.e 0' the .qu'OUI welt.
conltltuentl detected In the
.IIuvl.I .qul'er
. ..-.dl.I .ctlon. on-,oln,
o 'erlodlc ..Inten.nc. would be
contlnu.d '.r the e.lltln,
production end .0"ltorln,
well 1,.t"l
o Gr~'weter ~Itorln. would
b. r.qulr.d to .0"ltor the
.ff.ctlv.n... of re.edl.1
.etlvltle.
o ..covered ,round "eter
vould be tre.ted to reduce
the to.lclty, ~bliity end
volU8e of the equeou. ve.te
con.tltuent. detected In the
.lluvl.1 .quller
° ....dl.I .ctlon, on-,oln.,
.It.rn..e v.t.r lupply b.ln,
11IIp1..,.nttd
o '.rlodle ..Int.nlnce would
be r.qulred lor the ..lltln,
production .nd .onltorln,
veil sylte..
o Ground-v.t.r .onltorln,
vould b. required to .onltor
the eff.ctlven... of
r.-edl.1 .ctlvltles
o 'ecoyered Iround w.ter .nd
IAPl would be treeted to
reduce the to.lclt"
.obility .nd volu.e 0' the
wute .tr...1
o 'e..dl.I .ctlone could be
11Ip1...nt.d without
.I,nlflc.nt probl..e
o 'erlodlc ..Intenenee weuld
b. requlr.d lor the e.letln,
production end 8Onltorln,
well .Ylt..., end the MA'l
re-edhtlon IYlt.. .
o Ground-w.t.r 8OOltorln,
would be required to .onl'or
the effectlv.n"1 0'
re.edlll ,ctlvltl'l
o '.c...r" iround v.t.r .nd
MA'l would b. tre.ted to
redue. the to.lclty,
..blllt, end volu.. 01 the
w..t. It,ee..
. .....111 Ictlene could be
I.,I...nted without
el,nl'I..nt probl...
. 'erl"I. ..Inten.nee MOuld
be requl,ed 'or the
productIon .nd 8Onltorlnl
well .y.t..., the I.Pl
,...dletlon .y.t.., end
the recoyery'tre.t.ent
.y.te. 'or the SIV-] e,e.
. .reund-w.ter 8OOltorl",
would be requlr.d to
RIOnltor the ,'fectlven~.'
of re..dl.1 .ctlvltle.
-------
Table 3
C08P8rl.on of 1e8ed1.' A'ternatlve.
fe.slbllity Study: John Deere Dubuque York.
Dubuque. Iowa
AU.rn.tlve 1
(10 Action)
Alternative J
A't.rnatly. 'A and ,.
Screenln,
Crlterle
o Ground-water "onltorln,
o Continued Production Yel'
'Ullpa.e
o Ground-water Monltorln,
o Continued production Yet'
o Altern.te Yater Supply
o NAPL Mana,eMent
o Ground-water "onltorlnt
o Continued 'roductlon W...
o A't.rn.t. Wat.r Supply
o MA'L "ana,...nt
o SIW-J Ar.a Mana'888ftt
PUllpa,e
'..,a..
Short~ter. fffectlv.ne..
lon,-t.r. (ffectlvene.. and
Per..nence
leductlon of 'oalclty,
Mobl'lty end Vol~e
IMpleaentablllty
o 'otentla' rl.k. ...oclated
with .round-water .onltor-
In, Mould be controlled
o COIIp'ete
o ..-.dlat.. a"uvla' .qulfer
o 'roductlon and 8Onltor we"
.y.t..a 'raqulre lon,-Ur.
..Intenanc.
o 'oalclty, 8Gbl'lty, .nd
VOlUMe of aqueous con'
ta.lnant. In the ground
water reduced
o t.qulr.. operation and
aalntenance of eal.tln,
.ystea.
o Potential for additional
reaedlal action In the
future
o Potential rl.k. reduced for
reaedlatlon worker.
o 'ot.ntl.. rl... reduced for
re-.dl.tlon wor..r.
o Mlnl.a' addltlona' threat to
the co.-unlty, aurroundlng
envlronaent, andior JDDY
worker. doln, reaedlal
activities
o Mini.., addition.' thr..t to the
coaaunlty. .urroundln, environ-
..nt, .nd/or JDDW work.r. doing
r...dl., .ctlvltl..'
o Co.plete In epproal.etely one
year.
. Coap..t. In 8ppr..I..t., y one
year
o te.edlate. al'uvlal .qulfer
o ..-.dl.t.. ."uvl., .qulfer
o MAPl and ,round-water reCOYary
.nd treat..nt .yate.. require
aonltorln, and lon,-t.ra
.alntenance
I IA'L and ,round-Mltlr r.covery
.nd tr..t..nt .yat... r.qul,.
8Oftltorln, end 'on,-ter.
..Intenane.
o 'oalclty. .obillty, and voluae
of aqueous conta.lnant. In the
ground ..ater reduced
o Mini... lner.... In r.cov.ry
.fflcl.ney contributed by
recov.ry w." .t SIW-]
o 'oalelty, 8Gb1'lty, .nd VOlUMe
of lqu.OU' eont..lnlnt. In the
,round w.t.r r.duced
o Utll',e. conventional
construction and In.tallatlon
Methods
o Utili... cony.nt'onll con.truc-
tlon and In.tlll.tlon .ethod.
o Negligible potential for
additional r.a.dial action
o Negll,lble potential for
additional reaedlal action
.
~
~
~
.t
i
B
!i
f"
-------
Table 3
(cont. )
C08Parlaon of le8edll' A'ternatlve.
Feasibility Study: John Deere Dubuque Yorkl
Dubuque. Iowa
AUernltlve I
(10 Action)
.Itern.tln ]
A'tlrnlt'v. 'A Ind 'I
Scr..nlng
Crherl.
o Ground-wlter Monitoring
o Contlnuld Production Well
PUllpa,e
° Ground-vlter ~onltorln.
° Continued production w.II
° Alternat. Wat.r Supply
° NAPl "8nlge..nt
o Ground-w.t.r "onltorlnt
o Continued Production -UI"
o Alt.rnat. U.t.r lupp"
o MA'L M.na,...nt
o IIU-) Ar.. Mlna,...nt
PUllpI,1
P&8Ip8'.
~1...nt.bl'Ity (Contlnuld)
- Dlt
Capl t.I
"pllc...nt
Annu.1 0'"
'ot.I 'r..lnt Worth
- 0-.1 lanca wi th AUI.
. "'erell 'rotlctlon of .&88"
. '..Ith Ind the EnvlronMe~t
St.t. Accept.nce
Co..unlty Accept.nce
o Non.
o Ion.
° 168,IOO/yr
o 11,046,900
o ,...dl.' Ictlon ,0.1.
vould be Itt.ln.d un I...
re..dl.tlon I. II.'ted by
be.t Iv.I,.bl. t.chnololt..
o 'educ.. rl.k of e.po.ur. to
,round-wlt.r cont..lnent.
off-.lt8
. ,I.kl ...ocllted with
cont.ct between con-
t..ln.tld wlter Ind JDDW
vork.r. .IY .t.II ....t
o Un"hly
o Unllhly
o Mlter'III, per.onn.I, end
technologl.. Ir. .v.ll.bl. for
'.pl ellentat Ion
. ".t.rl.I., per.onnel, .nd
techno'oll.. .r. .v.".bl. for
"~I...nt.t Ion
o S 800,000
0' 69,000
0' 278,600lyr
o 15, 151 ,800
o le.edl.I Ict'on 101t. would bl
.ttalned unll.. r...d'atton' t.
11.lted by b..t Iv.lt.bll
tlchnololl..
o A. 11,017,'00 .. 81,'66,000
o AI 1 '9,000 II 8 "',000
o A.. 309,JOO/yr " I- 315,900/yr
o A. 1',1",200 II 16,'11,200
o '888dI.1 let Ion ,0.1. would be
Itta'ned unt... ,.-.dlltlon I.
'1.lted by be.t .v.li.bi.
tlchnoiol'"
o ,.cov.,y o. I.PL would .ddr...
r...dl.1 .ctlon '0'" fot ...I~
r.cov.rlb'. 880Unt of IAPL.
o lecov.ry of MAPL would Iddr...
re.ed'.1 Ict'on '0.'. for
...I.U8 recovarlbl. I..unt of
IIAPl
o laduca. t I.k of ..po.uta to
Iround-wltar cont..ln.nt. off-
.lta
o leduc.. rl.. of ..po.ur. to
,round-wlt.r cont..ln.nt. off-
.It.
o leduc.. ,1.. of dlrlct contlct
vlth cont..in.ted vat.r by
JDOW worhrs
o ladue.. rl.. of dlract cont.ct
with cont..ln.tld wlt.r by JDDU
worh,.
° leduce. rl.k of
1119r.tlon IIAPl
o likely
o LIkely
° I.duc.. rl.. of
.t,rat Ion MAPL
o U..',
° Ukely
off-.lt8
off-.lte
f£0081.FS1\Tbi \
~e.e. tbl
~
~
:I
i-
f
5"
(\
-------
COMPLIANCE WITH ARARs addresses whether or not a remedy will
meet all of the applicable or relevant and appropriate
requirements of other environmental statutes and/or provide
grounds for invoking a waiver.
Compliance with ARARs would be accomplished by alternatives
3, 4A, and 4B. Treatment of the recovered NAPL and contam-
inated ground water will focus. on attaining chemical-specific
ARARs for surface waters at the discharge points for treated
ground water. Specifically, State water quality standards and
federal water quality criteria in the Mississippi and Little
Maquoketa Rivers would not be violated by the discharges to the
NPDES system with these alternatives. In order to assure that
these standards and criteria are not violated, the State of Iowa
may require additional NPDES permit limitations for any organic
contaminants that are discharged during implementation of the
selected remedy.
Due to the presence of the NAPL, implementation of
Alternative 1, no action, may result in nonattainment of
chemical-specific ARARs for surface water at NPDES 005.
Extraction of contaminated ground water (all alternatives)
will eventually attain federal MCLs and/or meet the State of
"Iowa's Ground Water Protection Policy.
LONG-TERM EFFECTIVENESS AND PERMANENCE refers to the ability of
a remedy to maintain reliable protection of human health and the
environment once cleanup goals have been met.
Alternative 3 would replace the current potable water
supply with an uncontaminated source. continual pumpage of
plant production wells and NAPL recovery would prevent
contaminant migration off-site. Eventually, contaminants would
achieve levels that are in compliance with State ARARs.
contaminant reduction already occurs as water is pumped from the
affected aquifer, through the various unit processes involved
with production, and finally to the NPDES outfalls. Potential
risks associated with direct contact with contaminated ground
water would also be mitigated. The ground water monitoring
system surrounding the plant will assess the effectiveness of
the extraction process.
Alternatives 4A and 4B would achieve relatively the same
long-term effectiveness and permanence as Alternative 3. The
proposed recovery well near SBW-3 might also increase the
efficiency of alluvial aquifer remediation. However, it is
anticipated that the increase in contamination recovery
efficiency contributed by the recovery well near SBW-3 would
not significantly reduce the time required for remediation of
the alluvial aquifer system. The low levels of contaminants
detected in the SBW-3 area would be removed by continued pumping
at PW-7, and the additional aquifer restoration provided by a
recovery system at SBW-3 was predicted to be minimal. Thus,
installation of such a system was deemed unnecessary.
Alternative 1 would not increase the quality of the plant's
potable water supply. Discontinuing usage of the NAPL recovery
system may also adversely impact the water quality of alluvial
ground water extracted from production wells and used as process
or potable water at the plant.
19
-------
REDUCTION OF TOXICITY, MOBILITY, OR VOLUME is the anticipated
performance of the treatment technologies a remedy may employ.
with the exception of Alternative 4B, treatment using
existing systems would be employed. contaminant reduction would
be achieved with all alternatives via the various plant
production processes. Alternative 1 does not treat the NAPL
spill which would delay reduction of toxicity, mobility, and
volume of the contaminants in .the alluvial aquifer.
Alternative 3 would recover and treat the NAPL, thus
reducing contamination in the alluvial aquifer. Alternatives
4A and 4B's use of a recovery well at SBW-3 would also continue
to reduce the toxicity, mobility, and volume of alluvial
contamination.
SHORT-TERM EFFECTIVENESS involves the period of time needed to
achieve protection from any adverse impacts on human health and
the environment that may be posed during the construction and
implementation period until cleanup goals are achieved.
Alternative 3 would replace the potable water supply
an uncontaminated source drawn from the bedrock aquifer.
could be accomplished within one year after initiation of
alternative. Workers would be provided protection as
appropriate. The NAPL recovery system and ground water
extraction system are currently existing and functional. The
NAPL that has been collected thus far has been stored on-site
and would be disposed in accordance with prevailing RCRA and/or
CERCLA requirements. Off-site disposal of the NAPL could be
implemented within three months after initiation of this
alternative.
Alternatives 4A and 4B would have the same short-term
effectiveness as the preferred alternative. In addition, the
SBW-3 recovery system could be installed within nine months of
implementation. The biological treatment units are already in
use at the site. Alternative 4B may require treatability
studies. The design and installation of the air stripping
system would be completed within one year of implementation.
Activated carbon filters would have to continue to be
maintained at drinking water sources should alternative 1 be
implemented because the potable water supply would not be
replaced. JDDW workers involved with production well main-
tenance and ground water monitoring would be provided
protection as necessary.
with
This
this
IMPLEMENTABILITY is the technical and administrative feasibility
of a remedy, including the availability of materials and services
needed to implement the chosen solution.
The no action alternative (number 1) can be readily
implemented at the site. The existing ground water monitoring
network would be utilized and the program implemented within a
short time frame. Likewise, Alternative 3 should pose no
significant construction or operation problems. The potable
water supply wells, PW-l and PW-2, are already installed into
the bedrock aquifer and are being readied for connection to the
domestic water supply. The existing ground water and NAPL
recovery systems have been operational for several years and, in
20
-------
"
addition, the equipment, specialists and technologies required
to implement Al ternati ve 3 are available. Nor would
implementation difficulties be expected with 4A and 4B.
Installation of the air stripping unit should not present any
special difficulties and the biological treatment units are
currently operational. However, the capacity of the biological
system to treat additional volumes of water may be limited.
. .
COST includes capital costs and operation and maintenance costs.
Estimated capital cost of implementing the preferred alternative
is $800,000, with replacement and annual O&M costs estimated at
$69,000 and $276,600/year respectively. The estimated capital
cost, replacement costs, and annual O&M cost for implementation
of Alternative 4A are $1,017,500, $69,000, and $305,400/year
respectively. The estima~ed capital cost, replacement cost,
and annual O&M cost for Alternative 4B are $1,166,000, $161,000,
and $312,000/year respectively. The costs of implementing
Alternative 1 relate to ground water monitoring and would be
approximately $63,700 /year. A more more detailed cost analysis
for each of the final alternatives is presented in the
Feasibility Study.
STATE ACCEPTANCE indicates whether, based on its review of the
RI/FS and Proposed Plan, the State concurs with, 'opposes, or
has no comment on the preferred alternative.
The Iowa Department of Nat~ral Resources has reviewed the
Proposed Plan, the RI/FS Reports, and the draft ROD. The State
concurs with the selected remedy (presented below) as indicated
by the September 21, 1988 letter from Morris Preston, Iowa
Department of Natural Resources, to Glenn Tucker, EPA Remedial
Project Officer. Since each of the final alternatives would
involve the discharge of certain organic chemicals to the Little
Maquoketa and Mississippi Rivers, the NPDES permits may be
revised by the State as required.
COMMUNITY ACCEPTANCE reflects local residents' preferences
regarding the implementation of specific alternatives.
During the public comment period, concern was raised
regarding the ability of the monitoring program to detect spills
and whether contamination from JDDW was reaching off-site private
wells. The Agency has agreed to require monitoring of a number
of off-site wells in response to the concerns of residents living
near the site. Specific comments and the ~gency's responses are
given in the Responsiveness Summary following the Decision
Summary section.
21
-------
THE SELECTED REMEDY
Alternative 3, the Contingency Plan, and requirements
placing future use restrictions on the plant property is the
selected remedial action for the John Deere site. The selected
remedy will consist of these major actions:
- Develop an alternate potable water supply for the plant.
The new water supply will use bedrock wells PW-1 and PW-2,
which are uncontaminated based on analytical data contained
in the RI.
- Extract water from the alluvial aquifer using the existing
production wells. This action will maintain drawdown
around the plant and landfill areas, thus protecting nearby
wells and controlling contaminant releases. The production
wells and other monitoring wells would be periodically
checked for contamination.
- Continue to extract and treat non-aqueous phase liquid
(NAPL) from the alluvium near product~on we1l-3. The
source of this material is probably diesel fuel spills and
waste oil leaks. Contaminated oils would be collected and
transported for off-site waste management.
- Use deed restrictions to prevent inappropriate use of the
property in the future. Future use of the current plant
property will be limited to industrial activities only. In
addition, water wells tapping the alluvial aquifer beneath
the current JDDW property would not be allowed.
- Develop, and be prepared to implement, a contingency plan
which would assure that contaminants do not migrate off-site
in the event of a plant shutdown. The plan would address
conditions which may occur if the plant is shut down for
a prolonged period of time, if process modifications are
made which decrease production well pumpage below 1.2 mgd
or pumping rates developed in the RD/RA, or if constituents
recovered in ground water from production wells require
additional treatment prior to surface water discharge.
Maintaining a drawdown and controlling ground water flows
beneath the plant would assure that contaminants do not migrate
to private wells in the vicinity, while extraction and discharge
lowers the level of contamination in the ground water. John
Deere will monitor the NPDES outfalls to assure that contaminants
are not discharged at levels which would cause State water
quality standards or federal ambient water quality criteria in
the Mississippi and Little Maquoketa Rivers to be violated. The
appropriate pumping rate and configuration would be maintained
during periods of plant shutdown as well as normal operations.
This rate and configuration will be based on computer simulations
of ground water flow.
Although some volatile organics and metals will remain in
the ground water and soils at the site, these actions will
reduce the levels over the long-term while providing protection
of human health and the environment. EPA believes the selected
remedy is the best balanc~ among the nine evaluation criteria.
22
-------
Recovery operations will be continued until ground water
quality meets the remedial action goals (e.g., Federal primary
drinking water standards, USEPA Health Advisories), and until
the maximum recoverable amount of NAPL is withdrawn. An
evaluation will be conducted every five years, which will consist
of a detailed review of the monitoring program and a summary of
the effectiveness of site remedial actions. EPA will then make
a decision on whether additional remedial measures are required
or if remedial- actions can be terminated.
STATUTORY DETERMINATIONS
EPA believes the selected remedy satisfies the requirements
of section 121 of CERCLA and is the most appropriate solution
for the site.
Protectiveness
The selected remedy mitigates the human health and environ-
mental risks identified in the risk assessment. Replacement of
the potable water supply at the JDDW site with the use of
uncontaminated bedrock ground water from PW-1 and PW-2 would
mitigate the potential risks for direct contact by on-site
workers to contaminated ground water. In addition, the alluvial
production well extraction rates will continue to maintain the
hydraulic gradient of the alluvial aquifer such that ground water
flows towards the production wells, effectively containing the
contaminated ground water on-site. The NAPL recovery system
will ~lso expedite remediation of the alluvial aquifer by
removing the NAPL which contains concentrated quantities of
undesirable constituents.
Deed restrictions are protective by assuring that the
site will remain industrial, and by prohibiting the installation
of domestic water wells in the alluvial aquifer beneath JDDW
property.
Attainment of Applicable or Relevant and Appro9riate Reauirements
The recovery of the NAPL and contaminated ground water
should restore the alluvial aquifer to the chemical-specific
ARARs for ground water. Ground water remediation would be
specifically monitored and maintained until chemical-specific
ARARs are met or constituent recovery is limited by the best
available technologies. Compliance with chemical-specific
ARARs for surface water would also be accomplished by monitoring
NPDES outfalls and controlling discharges depending upon.
monitoring results.
Cost Effectiveness -
Alternative 3 has the highest cost/benefit ratio among all
remedial alternatives evaluated for the site. Capital costs
relative to the other final alternatives are moderate, operation
and maintenence costs are also moderate, and replacement costs
are low. The remedy can be readily implemented at the site
because several of the technologies incorporated in Alternative 3
23
-------
are already in use at JDDW. Tables 2 and 3 summarize the
estimated implementation costs for the selected remedy in
comparison with other evaluation criteria.
utilization of Permanent Solutions and Alternative Treatment
Technoloqies to the Maximum Extent Practicable
The selected remedy will provide for long-term effectiveness
and permanence as the incorporated technologies are reliable and
address potential risks associated with the site. Replacement
of the potable water supply, the continual pumpage of plant
production wells, and NAPL recovery minimize future potential
risks by removing exposures to contaminated ground water and
restoring the aquifer.
Preference for Treatment ~ ~ Principal Element
The total volume of extracted ground water is not treated
using state of the art technologies (e.g. activated carbon
filtration). The tremendous volumes of extracted water make
such actions impractical. However, the extracted water is used
in plant processes; thus the contaminant levels are reduced by
such mechanisms as dilution, degradation, and volatilization
in conduits, open storage basins, skimmer ponds, and the
industrial wastewater treatment system. Ground water in the
vicinity of the 1980 diesel fuel spill is treated through the
NAPL recovery and treatment system. .F! ROD. RES
24
-------
RESPONSIVENESS SUMMARY
Record of Decision for
John Deere Dubuque Works
Dubuque, Iowa
" "
This Responsiveness Summary "presents EPA's responses to
public comments received regarding the proposed remedial
actions for contaminated ground water at the John Deere Dubuque
Works site in Dubuque, Iowa. This document addresses all
comments received by the Agency during the public comment period
conducted as part of the remedy selection process. The
Responsiveness Summary is a component of the Record of Decision
(ROD) package, which also includes the ROD declaration, ROD
summary and index to the administrative record.
Introduction
On August 5, 1988 EPA announced its Proposed Plan for
remediation of the ground water contamination at the John
Deere Dubuque Works in Dubuque, Iowa. Under the Proposed
the preferred remedial alternative would consist of the
following major actions:
Plan
- Develop an alternate potable water supply for the plant.
~ Extract water from the alluvial aquifer using the existing
production wells. This action will maintain drawdown
around the plant and landfill areas, thus protecting
nearby wells and controlling contaminant releases. The
production wells and other monitoring wells would be
periodically checked for contamination.
- continue to extract and treat non-aqueous phase liquid
(NAPL) from the alluvium near production well-3. The
source of this material is probably diesel fuel spills and
waste oil leaks.
- Use deed restrictions to prevent inappropriate use of the
plant property in the future.
- Develop and be prepared to implement a contingency plan
which would assure that contaminants do not migrate off-
site in the event of a plant shut down.
Although some volatile organics and metals will remain in
the ground water and soils at the site, these actions will
reduce the levels over the long-term while providing protection
of human health and the environment. EPA believes the preferred
alternative represents the best ba~ance among the evaluation
criteria used to evaluate remedies.
Public Partici9ation
EPA Region VII received five comment letters in response
to its request for public comment on the Proposed Plan and
Remedial Investigation/Feasibility Study for the John Deere
1
-------
Dubuque Works Superfund site. The following are summaries of
the written comments received and the Agency's response.
Two commenters expresse4 4issatisfaction with the time
allowe4 by EPA for submittal of comments. They both
state4 that they ha4 less than the 21 4ays between the
time they actually receive4 the notice and the public
comment closure date. .
The minimum time allowed for public comment is 21 days
according to EPA regulations. Based upon previous public
input regarding this project, the Agency felt that 21 days
would be an adequate amount of time for the public to
respond. The appropriate documents. were made available to the
public on August 5, 1988 and an announcement was made requesting
comments on that same date in the local newspaper. Shortly
thereafter, "fact sheets" were sent to "interested parties" in
the vicinity of the plant to further inform them of project
actions and plans. These fact sheets would have arrived after
the date of formal opening of the public comment period. We
acknowledge that the fact sheets should have been sent earlier
so they would have arrived at the same time the public notice
was published in the newspaper.
To assure that the public, particularly nearby residents,
were allowed sufficient opportunity for comment, EPA and John
Deere held a public meeting in Dubuque on September 24, 1988.
Comments and responses from that'meeting are summarized below.
Four commenters live in the immediate vicinity of the
plant and expressed concern about either the immediate
safety of their water supply or the potential for future
contamination. Three people suggested that John Deere make
an alternate source of water available to homeowners whose
supplies may become threatened if the contamination moves
off-site. Two commenters requested that, at the very least,
John Deere perio4ically test their wells.
The off-site well analyses that have been conducted thusfar
have not shown any contamination in these wells as a result
of activities at JDDW. Potential off-site ground water
contamination is currently controlled by production well
pumpage. Furthermore, EPA will require that sufficient
pumpage continue even in the event of a plant shutdown.
A monitoring program designed to detect any potential off-
site contaminant migration would also be implemented
should this occur. Sampling and analysis of off-site wells
would be incorporated into the monitoring program if potential
off-site movement were indicated.
However, to alleviate concerns about the current safety
of water supplies, EPA will require the testing of selected
private wells in the area on a perio4ic basis. The well
location and monitoring frequency will be determined in the
near future. This program will be reviewed five years after
ROD implementation to determine its continued necessity.
2
-------
.
One commenter vanted to knov vher~\~he contaminated
water goes after it is pumped out of the vells. Se
concerned since his vell vas close to the river.
vell
was
The contaminated well water is not direstly discharged to the
Mississippi River. It is used in the production processes of
the plant. By the time it is eventually, discharged to the
river, the original concentrations have/been reduced and would
be further diluted by the river.
One commenter vas Deere' Company. Two comments
regarded corrections on. the .i.8 of the old landfill and
the volumes of hazardous vaste disposed there. Another
expressed concern that a statement in the Baseline Risk
Assessment section of the Proposed Plan left the
impression that ground vater vould immediately begin to
flow toward private vells if pumpage stopped. One
recommended that SPA not specify vater vithdrawal rates
from each vell unless shown to be necessary to prevent
offsite migration: while another recommended that the
Agency not specify specific methods of handling and
disposing the NAPL, allowing the Company to choose the
methods as long as they meet existing regulations. The
final comment requested that RCRA comments and require-
ments be addressed in the ROD so as to avoid imposition
of a4ditional remedial actions' after issuance of the ROD.
The Agency has made the appropriate corrections regarding
the size of the old landfill and the vo'lumes of hazardous
wastes disposed there in the Summary of site Characteristics
section of the ROD. We will acknowledge, in the risk assess-
ment section of the ROD, that ground water flow would not
immediately reverse if pumpage ceased; nor will we specify
specific well withdrawal rates and methods of NAPL handling
and disposal. Finally, the EPA RC~ Branch has been reviewing
the RI/FS and Proposed Plan. Their comments will be taken into
account before the ROD is finalized.
'--
The Iowa Department of Natural Resources (IDHR) reviewed
the data that vas collected at the NPDES outfalls during
the RI. In a letter to Deere' company, they presented the
results of a vasteload allocation for JDDW's discharge of
ground vater to the Little xaquoketa River. The following
contaminant levels at Outfall 005 were determined to be
required to protect fish flesh for human consumption (i.e.
human health criteria for a risk of 10E-6 cancer cases):
Chloroform .
1,2-dichloroethene
18 ug/l or 1.35 lbs/day
2.1 ug/l or 0.16 lbs/day
Concern over contaminated ground water discharges was also
expressed by a previous commenter. The IDNR is responsible for
overseeing water quality programs and setting discharge limits
in the State of Iowa. Since surface water quality standards are
considered ARARs for the JDDW site, JDDW must assure that
3
-------
.
\.
\
compliance with these ARARs will ',be achieved through monitoring
the NPDES outfalls and, if necessary, implementation of
additional treatment to meet any!mandated permit requirements.
One commenter noted that no/mention was made of an oil
film on a sand pit located pear the residences. This
person was concerned since~is water supply is located
"less th.n 150 feet from' th.e sand pit." Be was also was
concerned about the cancer risks associated with the site
and felt that people in the area be "notified of these
danqers." Be also requested a meetinq between area
residents, John Deere, and BPA.
Based upon the results of the remedial investigation, the
contamination that can be attributed to activities of JDDW has
been contained either on the JDDW property or beneath it. We
do not know, at this time, where the source of the oil in the
sand pit is. The potential health risks for both plant workers
and off-site residents have been evaluated and are presented in
the Risk Assessment section of the RI. It appears unlikely that
there are unacceptable health effects currently associated with
site contaminants, based on exposure scenarios presented in the
risk assessment.
***********
In response to the request for a meeting and to also allow
more time for public input, EPA and John Deere held a public
meeting at the Carnegie-Stout Public Library in Dubuque on .
September 24. The remainder of the Responsiveness Summary
summarizes the questions, comments, responses, and answers that
were voiced at that meeting. A copy of the transcript of the
meeting is available in the Administrative Record.
Bow much more time will it take to recover the 1980 spill
material?
There will always some material left because the oil attaches
to the soil particles and all of it can not be extracted.
Usually 50 to 60 percent is the maximum that can be recovered.
The Company is continuing to extract material, but there is a
possibility that they may very well have recovered about all
they can at this time. .
When will the bedrock water wells be implemented?
Construction is already underway and the system should be on-
line and functional by the first of the year.
Doubt was expressed about whether the monitorinq proqram
proqram would be able to detect contaminant releases off-
site, such as throuqh the storm sewers. The commenter
cited specific spill incidents. In addition, how will the
proqram insure that the diesel fuel recovery system and
4
-------
process wa~er vi~hdrawal wells opera~e properly?
The Company has implemented an Oil Spill Prevention and Counter-
measure Plan as well as other measures to prevent such spills in
the future. EPA has a role and responsibility to see that
John Deere monitors these systems according to our standards
and reporting requirements. If problems are detected, they will
be required to ,take corrective actions. These various require-
ments will be explained in' the 'Consent Decree which will be
lodged in federal district court making it relatively easy to
enforce compliance.
A primary concern of residen~s was tha~ 'diesel fuel from
the 1980 spill vas qe~~inq into ~heir veIls. Severe taste
and odor problems were cited.
The diesel fuel recovery system, plus the other'withdrawal wells
draw water in such a fashion as to capture the plume and prevent
migration off-site. The RIfFS Study showed that the gr,)und water
pumpage is controlling the contaminants that were found at the
site. This does not mean that there are not some contaminants
in the private wells. However, our study results show 'that when
the off-site private well sampling was conducted, no evidence
of toxic contaminants was found that could be linked with the
, site. Some secondary contaminants that could affect' taste and
odor were detected, but we don't believe that John Deere is:the
source of these problems. ' I
Based on the written requests and concerns expressed at
the public meeting, EPA will require monitoring at representative
off-site private wells in the vicinity.
Concern was expressed over the lonq-term health
consequences of contaminants, especially heavy metal~
Potential health effects posed by contaminants at the site have
been evaluated~ and to the best of our knowledge, there is no
predictable or measurable health effects that can be anticipated
from the concentrations that are present. While we cannot be
sure that acceptable safe levels will not change in the future,
the current contaminant levels are present in acceptable
concentrations 'for the given exposure settings.
Are there any materials ~ha~ were used in the construction
of the dike ~hat could affect water quality?
We do not know at this time. EPA will ask John Deere to review
their files to see if we can determine what was disposed there
and what potential impact it might have.
Dead fish and hiqh wa~er temperatures have been period-
ically observed near ~he pumpinq station on the
Mississippi.
John Deere withdraws non-contact cooling water and then puts
it back into the river, adding about 20 degrees temperature
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during the process. That is the only thing that is added to it.
Thermal radiation during the summertime can also increase the
temperature. The discharge is a regulated NPDES discharge.
One resident expressed concern that the residents could
~e evicted from the Corps of Engineers owned property.
Were this to occur, the resident's wells could no longer ~e
used as monitoring points.
The Corps and EPA are separate Federal Agencies. EPA does not
have any influence over any of the Corps leasing activities.
The monitoring system we are relying upon is not dependent on
the private wells that are located near the facility.
Could the tremendous volume of water that John Deere
is pumping have an affect on water .quality in the area?
The alluvial aquifer of the Mississippi River is probably one
of the most productive aquifers anywhere in the' country. The
aquifer is capable of yielding those quantities: of water, and"
recharge from the river is almost continuous. By pumping large
volumes of water, the flow of the contaminated ground water is
toward the Company production wells and not the off-site wells.
What are the long~term consequences to the ~iota in the
in the vicinity, particularly in the rive~? :
I
The organic chemicals are the types that degrade in the
environment fairly rapidly and they do not tend to bioaccumulate
in the body. In terms of heavy metals, they do have a tendency
to bioaccumulate, but they are also the type of metals that
people are naturally exposed to in the environment. The body
has mechanisms .to use these chemicals and to dispose of excess
amounts to a degree. You run into problems when there is an
overdose of these chemicals, but we do not have over-exposure
conditions at John Deere.
There is a "ponding condition" in the Mississippi adjacent
to the plant, but siltation processes are also taking place.
Metals are settling out in the river but are also being
covered. up at the same time: so we are not actually running
into a situation where lead is increasing at unacceptable levels
at the bottom surface. . .
,
What happens to the ground water that is extracted?
It is used in the various process operations' throughout the
plant. Some of it goes through an oil/water separator. Most
is merged and then discharged to the Mississippi and Little
Maquoketa Rivers.
How are discharges to the Mississippi River monitored?
Water is monitored before it actually goes into the discharge
pipes. John Deere meets all of the current Iowa NPDES discharge
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standards relative to the required parameters and monitoring
frequency. Results are periodically reported to the state and
they periodically inspect John Deere's discharges.
The organic contaminants detected in the discharges are not
currently in John Deere's permits to discharge. Mr. Morris
Preston, from the Iowa Department of Natural Resources, stated
that the permits are periodically reviewed and this is an
appropriate time to look at the additional information that has
become available, and determine if those limits are acceptable.
EPA has also told John Deere that there may be additional, more
stringent NPDES permit requirements in the future coming from
the state.
What is the extent of the contaminated aquifer that
underlies the John Deere plant? Is it controlled by land
faults?
We know the extent of the aquifer and the extent of the
contamination. We believe that migration of contaminants off-
site is being controlled. These assertions have been documented
in the RI Report. There is no evidence at all to indicate any
interaction with faults that would impact the flow.
What are the obstacles'that are connected with cleaning
up the old land~ill?
.
..
. A determination has to be made on how bad the situation is based
on the concentration of materials throughout the depth of the
landfill, concentrations near the surface, and whether any
material is leaching out of it into the ground water. In the
case of John Deere, lead was found to be the primary contamin-
ant of concern at the old landfill. However, it is not
impacting the groundwater, nor is it in the type of setting
that people are likely to be exposed to unsafe levels at the
surface.
One resident requested access to the plant drinking water
and yearly testing of his well by John Deere.
John Deere maintained that they have not affected the off-site
wells and they have an adequate monitoring program in effect.
They do not plan, at this time, to provide water for the off-
site residents. As state above, the Agency will require sampling
of a representative number of off-site wells.
Is it possible for ground water to be released over the
top of the aquifer?
The water's surface is drawn down in a conical shape around the
welles), so that water is also within the capture zone. All of
the water migrates toward the welles).
will the coal storage area have any impact on the wells?
Soil samples were taken and wells installed nearby to address
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this question. Some metals were detected in the
the ground water. So, the ground water does not
impacted by the coal storage area and even if it
go back to John Deere via the production wells.
What standards are applied to construction of the new
landfill?
soil but not in
appear to be
was, it would
~
The landfill is a permitted sanitary landfill, subject to
inspections by the State of Iowa. Hazardous wastes are not
disposed there. It is lined and has a leachate collection system
to prevent ground water contamination.
8
Hazardous ~I
Information
US EP A Reg;.
Philadelphia!i
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