United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response .
EPA/ROD/R07-89/023
December 1988
Superfund
Record of Decision
Findett, MO
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50272-101
REPORT DOCUMENTATJON I'. REPOATMO.
PAGE EPA/ROD/R07-89/023
4. ne... SuIMItI8
SUPERFUND RECORD OF DECISION
Findett, MO
First Remedi~l Action
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'U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
15. ~.,., No..
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Agency
J. A8c1pi8nC'. Accn8ion No.
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The Findett/Hayford Bridge Road Ground Water site is located just north of the City of'
St. Charles, in St. Charles County, east-central Missouri. The site lies 3.2 miles
south of the Mississippi River and is within the floodplain. Land use in the site
vicinity is. primarily agriculture, but also includes a small industrial park containing
Findett Corporation, Cadmus Corporation, and several other comme~cial and light
ndustrial establishments. In addition, there are several residences within
Jproximately 1,000 feet northeast and 1,500 feet south 0: the site. The Elm Point
dellfield, the primary drinking water supply for St. Cha=les, is located 1,800 feet
northeast of the site. Until 1980, Findett Corporation reclaimed heat transfer fluids
or oils, some of which contained, PCBs, and received waste solvents for reclamation or
recycling. Subsequently, Findett has custom blended or manufactured organic chemicals
for other companies. The Findett site originally came to EPA's attention when Findett
Corporation reported handling PCBs at the site. There is PCB-contaminated soil at the
Findett facility as well as the adjacent Cadmus Corporation facility. The Elm Point
Well Field is also at r~sk of contamination by releases from the sit~. Find~tt
conducted several voluntary PCB soil cleanups pursuant to EPA A~~inistrative Orders in
1981 and 1982; however, PCBs as well as VOCs remain in the soil in concentrations above
(See Attached Sheet)
17. ~An81ywi8 .. 0Mcr1~
Record of Decision - Findett, MO
First Remedial Action
Contaminated Media: soil~ gw
Key Contaminants: VOC, organics
b. Identil\8nlOp8n-Ended Temw
Co CooA 11 ReIdIGt~,
AvlilaDil1y SbI8m8nI
I
(See A~Z38.I') ,
(PCBs)
It. S8curi1y CI... (Thl. A8por1)
None
20. S8curi1y CI- (Thl. Pee-I
Nnnp,
See,,,./ruCfiOlUl on ~-
21, No. 01 P.ge.
36
22. Price
OP110NAL FOR'" 272 (4-71)
(F~ N11~35)
~lo/Co_ce
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OPTIONAL FORM 272 BACK \
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EPA/ROD/R07-89/023
Findett, Mo
First Remedial Action
16.
Abstract (continued)
recommended levels. In addition, ground water investigations revealed substantial VOC
contamination in the shallow aquifer near the contaminant sources and in the deep
aquifer tapped by the nearby well field as a drinking water source. The primary
contaminants of concern affecting the soil and ground water are VOCs, and other
organics including PCBs.
The selected remedial action for this site includes onsite ground water pumping and
treatment using air stripping with discharge to the publicly owned treatment works
(POTW); and excavation of contaminated soil with either offsite disposal or treatment.
The estimated present worth cost for this remedial action- is $8,306,000 with annual
O&M cost of $398,000.
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RECORD OF DECISION
DEClARATION
REMEDIAL ALTERNATIVE SELECTION
SITE NAME AND LOCATION
FindettjHayford Bridge Road Ground Water
St. Charles County, Missouri
STATEMENT OF BASIS AND PURPOSE
This decision document presents the remedial actions
selected for an operable unit at the Findett/Hayford Bridge.. Road
Ground Water site in st. Charles County, Missouri. The operable
unit (OU) at issue is the shallow contaminated ground water near
the site. The selected remedial actions were developed in
accordance wi~h the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and ReauthorizatiQn Act of 1986 (SARA)
42 U.S.C. ~9601 et seq". and, to the extent practical, with the
National Oil and Hazardous Substances. Pollution contingency Plan
(NCP) , 40 C.F.R. Part 300. This decision was based upon the
documents and information contained in the Administrative Record
for the site. A copy of the Administrative Record is available
for public review at the City Hall in st. Charles, Missouri.
The state of Missouri has been consulted with and concurs on
the remedy selected for this operable unit.
DESCRIPTION 2r THE SELECTED REMEDY
"The u.s. Environmental Protection Agency (EPA) in
~onsultation with the State of Missouri, has determined that the
selected remedial actions, described and evaluated in the
Operable unit Feasibility study (OUFS) and the Proposed Plan for
remedial action (both of which are found in the Administrative
Record and were released for public review and comment), satisfy
or meet the criteria established by section 121 of SARA, for the
evaluation and selection of remedial actions, and will be
protective of human health and the environment.
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The remedial actions selected for the shallow contaminated
ground water (Operable Unit) at the Findett/Hayford Bridge Road
Ground Water site are described below:
-Hvdraulic Control, consisting of ground water extraction
wells near the suspected contaminant source (s), completed or
screened in the upper granular unit. The EPA expects that
approximately five (5) extraction wells will be needed. Howe"fe!:',
installation may be phased in, with the final namber and location
of extraction wells to be determined after review of the results
of pumping of an initial extraction well or wells.
-Ground Water Treatment to Remove Oraanic rcntaminants,
using air stripping. An option for further treatment of ground
water, using granular activated carbon (GAC), is retained. This
option would be implemented only if monitoring' determined that
contaminants were not effectively removed by the air stripping
and were present in potentially toxic concentrations or at
levels which would interfere with the operation .of the sewage
treatment plant, to which treated water is to be discharged.
-Ground Water Discharqe, after treatment to remove. organic
contaminants, to the local municipal.sewage treatment plant which
receives municipal and domestic wastewater from the City of st.
Charles and surrounding areas.
-Contaminated Soil Removal, for offsite disposal or
treatment. Surface and near-surface soils around the Findett
Quench Pond are contaminated with polychlorinated biphenyls
(PCBs) and other organic compounds. This conta~inated soil may
be a source of continuing ground water contamination and poses a
threat of direct contact exposur~s to personnel on the Findett
and Cadmus facilities. The contaminated soil will be removed to
eliminate both the threat of direct contact exposures and a
source of ground water contamination.
DECLARATION
The selected remedial actions are protective of human health
~nd the environment, attain Federal, State and ~~cal requirements
that are applicable or relevant and appropriate to the remedial
actions and provides a cost-effective response.. section 121 of
CERCLA identifies a statutory preference for treatment. This was
a factor in EPA's selection of air stripping for the contaminated
ground water to be extracted. Treatment, as well as disposal,
will also be considered for the contaminated .soil removed from
the site.
The selecteu actions constitute operable unit remedial
actions. Since these remedial actions result in hazardous
substances, pollutants of contaminants remaining on the site, EPA
shall review such remedial actions no less than once each five
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years after initiation of the remedial actions for t~e site to
assure that human health and the environment are being protected
as required by Section 121(c) of SARA.
The remedial actions selected in this Record of Decision
(ROD) directly address only the operable unit of the shallow
contaminated ground water near the site. However, in selecting
this remedy, EPA also believes implementation of this remedy wi]:.
have a beneficial effect on environmental media outside the
direct scope of this operable unit by controlling the source of
the contamination and managing the migration of the
contamination. In addition, the soil removal should reduce
potential exposures via the direct contact route. A significant
factor in the selection of the remedy for this operable unit is
that it is consistent with achieving a permanent remedy at the
site.
I 'J. ' 2 g-- 6-9;-
Date
//41r/4:::f-
r's Kay
Reg~onal Administrator
Attachments:
Decision Summary
Responsiveness Summary
Transcript of Public Meeting
Index to Administrative Record
3
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RECORD OF DECISION (ROD)
Findett/Hayford Bridge Road Ground Water
st. Charles County, Missouri
Prepared by:
u.S. Environmental Protection Agency (EPA)
Region VII
Kansas City, Kansas
December 1988
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Section 1,
Section 2,
Section 3,
Section 4,
Section 5,
Section 6,
Section 7,
section 8,
Table I
Table II
Table III
Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
Figure 6
Figure 7
Figure 8
.
Decision Summary
TABLE Ql CONTENTS
Site Descr~ption
Summary of the Remedial Investigation (RI)
Documentation of Significant Changes
Remedial Alternatives Evaluated
Summary of Comparative Analysis of the Alternatives
Selected Alternative
Statutory Determinations
Implementation
(Table 6-3 from the OUFS), Detailed Assessment of"' the
Alternatives
(Table 6-4 from the OUFS), Alternatives Cost Summary
Evaluation of the Probable Degree of State and.
Community Acceptance of the Alternatives
(Figure 1 from the OUFS), Area Map
(Figure 2-7 from the OUFS), Conceptual contaminant
Migration Pathway . . .
(Figure 4-1 from the RI Technical Memorandum), RI
Monitoring Well Locations
(Figure 2-2 from the OUFS), Ground Water Elevation
Contours, Shallow System
(Figure 2-3 from the OUFS), Ground Water Elevation'
Contours, Deep system . .
(Figures 5-1 and 5-2 from the Phase I RI Report) Ground
Water Contaminant Summary
(Table I, from Jacobs Engineering, October 1988 Report)
Soil Analysis Summary .
(Figure 3, from Jacobs Engineering, October 1988
Report) Ground Water contaminant Summary
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SECTION I, SITE DESCRIPTION
~ Backqround and Historv
,
The Findett corporation facility was the original facility
addressed by EPA as a potential contaminant source. As a resuJ ';.
much of the history on EPA's work at the site relates to Findet~c
The Findett site originally came to EPA's attention because
Findett reported that they had handled polychlorinated biphenyls
(PCBs) on the site. PCB-contaminated soil is still present on
the Findett facility, as well as on the adjacent Cadmus
Corporation facility. Early ground water monitoring at the
Findett facility, conducted by Findett, was limited to PCBs.
Although the presence of PCBs in ground water at the site has
never been confirmed, PCBs have been found in subsurface soils
beneath the water table. When EPA'collected ground water samples
at the site and conducted the chemical analyses, substantial
concentrations of several volatile organic compounds (VOCs) were
found. VOCs are also present in the soils at both the Find~tt
and Cadmus facilities.
In 1984, partly because of the potential for ground water
contamination and the threat posed to the nearby municipal
drinking waster supply (Elm Point Well Field), EPA nominated the
Findett site for the National Priorities List (NPL) of hazardous
waste sites. At the present time the site's status on the NPL
has not been resolved. Nevertheless, EPA Region VII has
proceeded with the evaluation and planning for site cleanup.
In August 1987 field work was begun by EPA's contractor on
the (Phase I) Remedial Investigation (RI). The investigation was
focused on the ground water route because it was via this route
that endangerment of public health was most likely to occur. A
series of shallow and deep ground water monitoring wells were
installed around the suspected contaminant source (s). Depths to
ground water were measured in all monitoring wells near the site,
including those installed as part of the RI as well as those
previously installed by Findett. Ground water samples were then
collected for chemical analysis from all monitoring wells. In
order to confirm some critical contaminant values, some wells
,were resampled.
The results of the data and information gathered during the
RI were summarized and evaluated in the RI Report. Substantial
concentrations of VOC contamination were found in the shallow
ground wate~ near the contaminant sources. Initially
contamination of the deeper ground water aquifer was not
'However, later sampling by EPA did find contamination of
ground water monitoring well, LAS, which is northeast of
found.
a deep
the
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Findett facility. This well is generally downgradient of the
suspected contaminant source and is the deep monitoring well
nearest to the Elm Point Well Field.-
In June 1988, BPA began the Operable Unit Feasibility study
(OUFS). In the OUFS, EPA evaluated alternatives for containing
the shallow ground water contamination, in order to prevent the
contamination from spreading in the shallow aquifer or reaching
the deeper ground water, which is used for drinking water by the
nearby Elm Point Well Field.
In November 1988, an EPA contractor conducted a supplemental
field investigation to further identify the sources of ground
water contamination. Four additional monitoring wells were
installed in the shallow ground water. Ground water elevations
were measured in all existing monitoring wells. Ground water
samples were collected from all existing monitoring wells for
chemical analyses. Subsurface soil samples were also collec,ted
during the drilling of the four new wells and analyzed for VOCs
and PCBs. In general the contaminant levels previously reported
in the RI were confirmed. However, contamination of a deep
aquifer monitoring well, LAS, was found for the first time in
this sampling.
On November 16, 1988 EPA released the RI Report, the OUFS
and a Proposed Plan for remedial action for 21 days of public
review and comment. The Proposed Plan provided additional detail
on the remedial alternative recommended by EPA in the OUFS. A
public notice of this opportunity for public comment was
published by EPA in st. Charles and st. Louis newspapers on
November 16, 1988. A public meeting-was held.in-St. Charles (at
City Hall) by EPA on December S, 1988. During this public
meeting the public was afforded the opportunity to ask questions
or make oral comments on the documents released by EPA on this
site. A transcript of the public meeting was prepared and is
attached to this ROD.
. Prior to the opening of the public comment period, EPA
prepared an Administrative Record on the site, which was placed
in the st. Charles City Hall, for the public's review. In
addition to the RI Report, the OUFS, and the Proposed Plan, the
Administrative Record includes the sup~lemental investigation
report for the additional field work done for EPA after the RI
was completed. Other relevant site records which were used by
EPA in the preparation of the Proposed Plan and this ROD were
also placed in the Administrative Record. .
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~ site Location
The Findett/Hayford Bridge Road Ground Water site is located
in st. Charles County, in eastcentral Missouri. The site is jUr"i-
north of the City o'f st. Charles, approximately 25 miles
northwest of st. Louis. (See Figure 1, Area Map.) The s~te is
in the floodplain of the Mississippi River, which is
approximately 3.2 miles to the north. The Elm Point Well Field,
which is the primary drinking water supply for st. Charles, is
located 1800 fE 't northeast of the Findett plant site.
Loess bluffs form the southern or southwestern boundary of
the Mississippi River floodplain and are located approximately
one quarter mile south of the site. Land uses surrounding the
site are primarily agricultural. A small industrial
(Gardnerville) park on Elm Point Road and Governor Drive contains
the Findett Corporation and Cadmus Corporation facilities and two
other light commercial or industrial establishments, an
excavating company ("Southern Property") and an insulation "
, installation company (See Figure 1.). Much of the land in the
area is as yet undeveloped and is used for hunting and trapping.
Residences in the area are limited to a few farm homes on Huster
Road approximately 1000 feet northeast of the site. A
residential subdivision is located up on the bluff, approximately
1500 feet south of the site.
~ Hvdroqeoloqic Settinq
The site is located in the floodplain of the Mississippi,
River which is 3.2 miles to the north. The Missouri River is
located about the same distance to the south. A series of
ditches and creeks in the area drain to Dardenne Creek, which
then flows into the Mississippi River.
Available data (including that from the RI) indicate that
there may be two alluvial ground water systems beneath the site.
(See Figure 2.) This description of site hydrogeology is limited
~o the area for which monitoring wells were installed during the
RI. (See Figure 3.) The degree of connection, if any, between
these two systems, has not been conclusively determined and
continues to be evaluated. The upper ground water unit begins at
the water table, 3-8 feet below ground surface. Soils containing
water in this zone consist of a fractured or blocky silty clay,
25-40 feet thick, underlain by a sand layer 5-25 feet thick. (See
Figure 2.)
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Beneath the upper sands is another clay layer, which appears
to be more cohesive with fewer fractures than the upper clay.
The lower clay, ranging from 10 to 40 feet thick, is believed to
be more of a barrier to the downward transport of contaminants at
or near the surface.
Beneath this second clay layer are the deeper sands, which
extend down to the top of limestone/sandstone bedrock, generally
70-90 feet below ground surface. The lower sand layer is the
most important aquifer in the area and is at the same depth from
which municipal drinking water for the Elm Point Well Field is
drawn. The two separate clay layers identified in the project
monitoring wells do not exist at the Elm Point Well Field.
Boring logs for these wells show only one water bearing sand and
gravel layer, with no intervening clay layers. It is assumed
that the upper granular unit (e.g. sand) beneath the site pinches
out northeast of the site, somewhere between the site and the Elm
Point Well Field.
Ground water flow directions and rates were measured and
evaluated several times throughout the RI/FS. Ground water flow
in the upper sands appears somewhat different than in the
lower sands, supporting the supposition of two separate ground
water units. Ground water flow in the upper sands tends to be
predominantly to the north of the Findett and Cadmus facilities.
(See Figure 4.) The expected ground water flow velocity in the
upper unit is estimated to be on the order of one {1~0} foot per
day. Ground water flow direction in the lower sands tends to be
northerly, although a northeast component of flow has been noted.
(See Figure 5.) Ground water flow velocity in the lower sands is
estimated to be in the range of four (4.0) feet per day.
At present, known ground water use in the area is limited to
the Elm Point Well Field, which has seven large (800-l000
gallon/minute) volume production wells. The nearest of these
wells is located 1800 feet northeast of the Findett plant site.
Ground water contamination is known (based upon sampling and
analysis of ground water in the RI) to exist at least as far
as monitoring well UA2 (190 feet north of Findett property line)
in the upper ground water system. (See Figure 6 for summary of
known ground water contamination existing at the conclusion of
the Phase I Remedial Investigation.) When the OUFS was prepared
contamination of deeper ground water had not been verified. Deep
aquifer monitoring well LAS has since been found to be
contaminated with VOCs.
Additional potential uses of ground water exist in both the
shallow and deep ground water systems. Findett has a deep
production well which reportedly has not been used as a water
6
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supply. Nearby property owners could also drill shallow or deep
alluvial wells to use ground water for drinking, agricultural or
industrial uses.
Recent data from a supplemental investigation done by EPA
(Jacobs Engineering Group, TES IV Contractor, October 1988
Report) indicate that the upper and deeper ground water systems
may be connected. A slug test was conducted in conjunction with
a source identification investigation after the remedial
investigation. Fluctuations in shallow ground water elevations
were noted when the only known pumping of ground water in the
area was of the deep ground water by the Elm Point Well Field.
In addition contamination (1400 ug/l total VOCs) was noted in
monitoring well LAS in the deep aquifer. (Refer to Figure 7 for
a summary of the contaminant levels from the source
identification investigation, in which deep ground water
contamination was first verified.) This increases the risk.,of
contamination of the the Elm Point Well Field and could preclude
other potential uses of the deep alluvial aquifer. The EPA
resampled a number of wells in late November 1988. Contaminants
attributable to this site were not found at detection limits in a
water .sample from the Elm Point Well Field. VOCs were again
found in LAS, but in lower concentrations than in October 1988
(e.g. 69 and 61 ug/l total VOCs in duplicate samples).
~ Enforcement Actions
The -Findett Corporation has addressed PCB contamination on
its facility. Several voluntary PCB soil cleanups have been
conducted by Findett. One of these was conducted by Findett
pursuant to an Administrative Order issued by EPA in 1981 under
section 311 of the Clean Water Act. Findett also .monitored
ground water for PCB contamination under a Consent Administrative
Order issued in 1982 under Section 3013 of the Resource
Conservation and Recovery Act (RCRA).
PCBs remain in the surface and near surface soils in
, .
concentrat10ns above levels recommended as safe by EPA. PCBs up
to 5400 mg/kg are present in surface soils on Findett and up to
6000 mg/kg in soils on Cadmus. The Findett Corporation has
expressed a desire to remove additional PCB-contaminated soils on
its property and to cap or cover any remaining residual
contamination. A plan for the PCB cleanup has been submitted by
Findett for EPA review.
At the time EPA began the RI the only known Potentially
Responsible Party (PRP) was the Findett Corporation. The EPA
sent a Notice Letter under section 104 of CERCLA to the Findett
Corporation advising them of the need for an RI/FS at the site
7
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conduct the RI/FS. The EPA, therefore, conducted the RI/FS
advising Findett that they, and any other PRP, may be held liable
for the costs of the work performed by EPA. Subsequent
environmental sampling by EPA now indicates that there may be
additional contaminant sources and additional PRPs, including t}w
Cadmus Corporation. The EPA is following up on this.
~ Community Relations
A Community Relations Plan (CRP) was developed and
implemented by EPA for the site. The RI Report, the OUFS, and
the Proposed. Plan for remedial action were released by EPA on
November 16, 1988, for a 21 day public review and comment period.
Public notices of this opportunity for review and comment were
placed in St. Charles and St. Louis newspapers. These and other
documents relating to the site were placed in the Administrative
Record on the site for the pUblic's review. Copies of the
Adm~nistrativeRecord are located both at the st. Charles City
Hall and in EPA Region VII's Docket Room in Kansas City, Kansas.
A public meeting was held in st. Charles at the City Hall on
December 5, 1988, during which oral comments on the RI Report,
the OUFS and the Proposed Plan were received, and questions on
. the proposed actions were responded to. A Responsiveness Summary
has been prepared as part of this ROD addressing all the
substantive oral and written comments received.
.SECTION 2, SUMMARY OF THE REMEDIAL INVESTIGATION (RI)
~ RI Obiectives
The Phase I RI was limited to the ground water route,
because releases via this route could pose the greatest threat to
human health and the environment. The OUFS addressed the shallow
contaminated ground water as an operable unit. The purposes of
the Phase I RI were to: 1) identify and quantify contaminants
present in ground water: 2) identify ground water flow patterns
and gradients: and 3) identify potential human exposure from
ground water contamination and adverse environmental impacts.
~ (Phase Ii Remedial Investiqation Activities
The following investigative activities were completed in the RI.
-A series of 4 additional shallow monitoring wells were
installed. Detailed boring logs were kept noting the subsurface
soil types encountered.
-Five deep monitoring wells were paired with each shallow
well installed and with one existing shallow well.
8
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-Ground water elevations were measured in all newly
installed wells, along with older monitoring wells installed by
Findett under a RCRA 3013 Consent Order. Directions and rates of
ground water flow were determined from review of this data.
-Newly installed and previously existinq monitoring wells
were sampled. Ground water samples were analyzed for hazardous
substances.
A supplemental investigation
specifically identify contaminant
Group, TES IV Contractor, October.
investigation included:
was conducted by EPA to more
sources (Jacobs Engineering
1988 Report). This
-Four additional shallow monitoring wells were installed,
two on the Findett property, one on the Cadmus property
(upgradient of Findett) and one on the "Southern" Property,
upgradient of Cadmus.
-Ground water samples were collected from all new monitoring
wells and most of the older monitoring wells. Water samples
collected were analyzed for VOCs.
-Subsurface soil saEples were collected during the drilling
of the four new wells and analyzed for VOCs.
-Ground water elevations. were again taken in all older
monitoring wells in order that current ground water flow
directions could be determined.
-A slug test was performed on one shallow to determine the
hydraulic properties of the ground water systems.
contaminant levels in ground water and subsurface soils from
the analyses of these samples are summarized in Figures 7 and 8.
~ Remedial Investigation Results/Nature 21 ~ Problem
significant levels. of PCB contamination have been found in
surface and near-surface soils at both the Findett and Cadmus
facilities. PCBs have not been confirmed in ground water samples
collected. One "borehole water" sample collected by EPA at the
Findett facility contained PCBs; however this is believed to have
resulted from the inadvertent introduction of sediment into that
water sample during collection. PCBs have not been found in any
true ground water samples.
Substantial concentrations of VOCs have been found in onsite
shallow ground water, well above levels at which EPA would
recommend for human consumption. (See Figures 6 and.8,
9
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previously referenced.) At the conclusion of the Phase I RI,
significant contamination of the deeper ground water had not been
verified. Subsequently a water sample from a deep well (LAS) was
found to contain VOCs in excess of 1400 ug/l, well above
any level recommended for human consumption. In a third water
sample collected from this well in November 1988 VOCs were again
found, but in lower concentrations (e.g. 61 and 69 uq/l total
VOCs), although still above levels acceptable in drinking water.
The public drinking water supply (Elm Point Well Field) was
sampled by EPA under this project. No VOCs, PCBs or other
contaminants attributable to the site were found. Data available
to EPA have not shown any contamination of the drinking water
supply attributable to this site.
The direction of ground water flow is generally to the north
in both the upper and deeper systems. (See Figures 4 and 5.)
Direction of flow tends to fluctuate from the northeast to
northwest. Water from the Elm Point Well Field is at risk Of
contamination by releases from the site. Although the direction
of flow is not directly to the well field (northeast),
contaminants may still reach it, especially if the lower clay
layer separating the upper and deeper ground water is absent
north of the site, or if the two systems are hydraulically
connected.
. The Elm Point Well Field is the only drinking water supply,
public or private, known to be at risk of contamination.
However, other potential uses of ground water for drinking,
agriculture, or as process water could be precluded by
contaminants released from the site. VOCs pose the greatest
threat to actual and potential ground water users, because of
their solubility in water. PCBs, other organics, and metals pose
less of a threat because of lower solubility in water, and
because they are present in ground water in lower concentrations,
if at all.
The VOCs and PCBs present in surface and near-surface soils
{Figure 7) pose a threat of continued contaminant release to
ground and surface water. VOCs and PCBs also pose a threat via
direct contact exposures, on the Findett and Cadmus facilities.
These operable unit remedial actions do not directly addres~
surface water or direct contact exposures. (However, it is
recognized that any source control measures, such as Findett's
PCB soil removal, taken to abate ground water contamination would
also reduce the threat of direct contact exposures and -
contamination of surface water.) The goal of this OUFS is to
10
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contain the known contamination in the shallow ground water
system. The remedies selected to achieve this goal may also
result in protection of the deeper ground water and onsite
shallow ground water restoration (i.e. cleanup).
SECTION 3, DOCUMENTATION OF SIGNIFICANT CHANGES
Section 117(a) of CERCLA/SARA requires that a Proposed Plan
for remedial action be prepared by EPA and released with the
Feasibility Study for public review and comment. The Proposed
Plan highlights key information from the RI and FS reports,
briefly described the alternatives for site remediation and
identifies the preferred alternative and the rationale. EPA
released the Proposed Plan and the OUFS, along with the RI
Report, for public review and comment on November 16, with a
21-day comment period.
Section 117(b) of CERCLA/SARA further requires that any
significant changes in the remedy or response actions selected in
the ROD as remedial actions, that differ from those recommended in
the Proposed Plan, be described along with the reasons for such
changes. The response actions recommended in the Proposed Plan
are. the same as those selected in this ROD. .
SECTION 4, REMEDIAL ALTERNATIVES EVALUATED
The Operable Unit. Feasibility study (OUFS) process for
developing and evaluating remedial actions for a site includes:
identifying suitable re~edial technologies; screening the
technologies; developi~~ preliminary remedial action alternatives
using technologies passing the screening; detailed analysis of
the alternatives based on implementability, effectiveness, and
cost, as well as compatibility with likely final remedial actions
for the site.
~ Most Probable Site Conditions and Reasonable Deviations
. All of the information currently available for the site was
used to fashion a conceptual model of the site conditions. The
model provides the most informed assessment of the site by
defining the set of environmental conditions most likely to exist
at the site. The conceptual model also acknowledges that certain
data gaps and uncertainties currently exist by identifying and
defining reasonable deviations from the most probable site
conditions. These deviations, which encompass the nature and
extent of contamination and site hydrogeology, could affect the
implementation of a remedial action. The alternatives that were
evaluated in detail address only the most probable site
conditions. Mitigation measures were formulated to address the
reasonable site deviations and were costed out in order to allow
11
-------
responses to be developed that could also respond to the
deviations which may be encountered, with minimal changes and
cost impacts.
~ Remedial Alternatives
Potentially applicable technologies were iden:~ified for
containment, treatment and discharge of contaminated ground
water. Extraction wells, injection wells, and physical barriers
were found potentially applicable for ground water containment.
Several technologies were found potentially suitable for physical
or chemical treatment of contaminated ground water, and for
discharge or recycling/reuse after treatment.
In the OUFS eleven preliminary remedial actions were
assembled into a range of alternatives using the technologies
identified. These eleven alternatives were initially screened
for effectiveness, implementability, and cost to reduce the"
number of alterpatives to be evaluated in greater detail. The
initial screening carried the following remedial actions
alternatives forward for detailed evaluation.
-Alternative 3. Hydraulic control using extraction wells
located in the area of known contamination, with treatment of
organic ~ontaminants and inorganics prior to discharae of treated
water to Dardenne Creek. .
-Alternative 4. Hydraulic control using extraction wells
located in the area of known contamination, with treatment of
organic contaminants prior to discharae of treated water to the
sewaae tre' ~ment Dlant.
-Alternative 6.
located downgradient
treatment of organic
discharae of treated
Hydraulic barrier using extraction wells
of the area of known contamination, with
contaminants and inorganics prior to
water to Dardenne Creek.
-Alternative 7. Hydraulic barrier using extraction wells
located downgradient of the area of known contamination, with
treatment of organic contaminants prior to discharae of treated
water to the sewaae treatment Dlant.
12
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SECTION 5, SUMMARY OF THE COMPARATIVE ANALYSIS OF THE ALTERNATIVES
The alternatives described in section 4 were evaluated in
terms of applicability to overall site remediation. They were
also evaluated using evaluation criteria presented in EPA
Directive 9355.01, "Draft Guidance on Preparing Superfund
Decision Documents: The Proposed Plan and Record of Decision".
These criteria relate to factors mandated in section 121 of
CERCLA/SARA, and considerations of overall feasibility and
acceptability of the remedy. These nine criteria are as follows:
-Protection of human health and the environment,
-Compliance with applicable, or relevant and appropriate
regulatory requirements (ARARs),
-Long-term effectiveness and permanence,
-Short-term effectiveness, .
-Reduction of (waste) toxicity, mobility or volume,
-Implementability,
-Cost,
-State acceptance, and
-Community Acceptance.
Table I, is excerpted from the OUFS (Table 6-3), and
evaluates the short-term effectiveness, long-term effectiveness
and permanence, reduction of waste (toxicity, mobility or
volume), implementabilfty, compliance with ARARs, protection of
human health and the environment, and applicability to overall
. site remediation criteria. Table II below, is excerpted from the
OUFS (Table 6-4 from the OUFS) and evaluates the cost criterion
for the alternatives. Additional detail on the costs of the
alternatives evaluated can be found in the narrative of the OUFS
in Chapter 6.
TABLE II
ALTERNATIVES COST SUMMARY
(1988 Dollars)
. Capital Annual 30-Year
Alternative Cost O&M Cost Present Worth
($X1000) ($X1000) ($X1000)
3 2,890 667 13,604
4 1,883 398 8,306
6 2,938 670 13,704
7 1,930 402 8,426
* At 5% discount Factor
The criteria of State acceptance and community acceptance of
the various alternatives are discussed in Table III.
13
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'A IH E
III,
E""HAYION Of
Alternlltive No.3 - Hydreulic
control using extraction well.
in the area of contamlnllnt
~nurces, with treatment of
nrQAnic contaminants and
inorganics prior to discharge
of treated wAter to O.rdenne
Creek.
Alternetive No. I, - Hydraulic
control using extrectlon well.
in the area of conteminent
sources, with treatment of
organic contaminants prior to
discharge of tceated weter to
the sewllge treatment plllnt.
Alternative.No. 6 - Hydreullc
hArrier using extraction well.
do~ngrlldient of known conte.Ine.
tion, with treatment of oraenlc
contaminants and inorg.nlc.
prior to discharge of treated
water to Oardenne Creek.
Alternative No.7 - Hydraulic
bnrrier using extraction well.
downgradient of known conte.I'
nation, with treatment of
organic contaminants prior to
discharge of treated water to
thr sewage treatment plant.
DEGREE Of
STATE ~NO COMMUNITY ACCE~TANCE OF THE ALTERNATIVES
Stote
Acceptance
Community Acceptance
The EPA beli~ves the
Missouri) finds this
acceptable.
The EPA believes that, In generel,
community find. Alternetlve. No..
6 and 1 to be equ.lly eccepteble.
Nearby property owner. would probably
prefer Alternetlve. 3 end 4 to 6 end 7.
Alternetlve. 3 end 4 preclude fewer
off.Ite property uee. th.n 6 and 1.
,
\
the
3, 4,
StAte (of
alternative
EPA believes the
this Alternative
acceptable.
State finds
to be
Same a. for Alternetlv. No.3
The EPA believes that the State
agrees that Alternatives 6 and 7 are
less effective than Nos. 3 and 4 if
other than expected'hydrogeologic
conditions are encountered. EPA
bel ieves the State prefers
Alternative Nos. 3 to Alternative
Nos. 6 and 7, because, ground
water extracted in Alternative No.4
would probably be more heavily
contaminated. Alternative No.6
would therefore be less effective
than Alternative No.3.
In gener.l, the .e.e e. for Alternetlve.
Nos. 3 end 4. Merglnelly le.s ecceptable
to edJecent property owner..
Some as for Alternative No.6.
In general, the .eme e. for Alternative
Nos. 3 and 4. "erglnelly lesl acceptable
to edJacent property ONners.
-------
SECTION 6, SELECTED ALTERNATIVE
The EPA reviewed the data and the information from the Phase
I Remedial Investigation, the supplemental field investigation,
and the Operable Unit Feasibi~ity study. The EPA has selected th<
following remedial actions recommended in the Proposed Plan for
implementation as the remedial actions for the shallow
contaminated ground water operable unit.
Alternative No.4, Hvdraulic Control using extraction wells
in the ~ of contaminant sources, with Treatment Q1 oraanic
contaminants prior to Discharae of Treated Water to the
Sewaqe Treatment Plant is the selected alternative. The specific
and detailed analyses leading to this selection are contained in
Tables I, II, and III of this ROD, the Proposed Plan and in the
OUFS. In summary the advantages of Alternative No.4 over the
other alternatives are as follows:
-Hydraulic control alternatives (pumping of contaminated
ground water near the contaminant source) should be more
effective than the hydraulic barrier alternatives (pumping of
downgradient ground water) in responding to changes in ,
hydrogeologic conditions such as a change in the dire~tion of
ground water flow direction. For example, if ground water flow
were to be altered'by the pumping of new, large vol~e process
wells, barrier extraction wells might not effectively contain
the ground water contamination. Hydraulic control extraction wells
would stil~ be effective, even if the direction of ground water
flow were to change. In addition, hydraulic control is likely to
pump more heavily contaminated ground water than would hydraulic
barrier extraction wells. It is more effective to pump more
heavily contaminated water, rather than to allow it be diluted
and end up pumping a larger ,volume of less heavily contaminated
water. Ultimately, aquifer restoration (e.g. cleanup) will be
achieved quicker if more heavily contaminated ground water is
pumped.
In general, Alternatives 3 and 4, hydraulic control, appear
to fit better with overall site remediation, and are preferred
for this reason.
Hydraulic control wells will be more easily installed than
hydraulic barrier wells. More adjacent property would be lost to
barrier extraction wells, than to hydraulic control extraction
wells. This makes it more difficult for EPA, or the potential
responsible parties, to obtain the necessary site access. A few
additional monitoring wells could be needed to monitor the
effectiveness of hydraulic control alternatives. Many more
additional monitoring wells would be required to monitor the
14
-------
effectiveness of hydraulic barrier alternatives. This increases
cost, and again makes site access more difficult to obtain for
the hydraulic barrier alternatives than for hydraulic control.
Alternative No.4, which discharges to the Sewage Treatment
Plant, requires significantly less pretreatment of extracted
ground water than does alternative No.3, which discharges to
Dardenne Creek. As a result Alternative No.4 is significantly
less expensive than No.3, while affording equal protection of
human health and the environment. Because No.4 requires less
treatment than No.3, the treatment system will be easier to
maintain and may be more reliable. For these reasons EPA selects
Alternative No.4.
The EPA has coordinated the development of the selected
remedial actions with the City of St. Charles, Missouri. The
nearby Elm Point Well Field withdraws ground water for drinking
for the City. The sewage treatment plant to which the treated
water would be discharged is also operated by the City.
Contaminated soils will be removed for offsite disposal or
treatment. In addition to removing the threat of potential
direct contact exposures, EPA believes this removal would also
remove some of the sources of continuing contaminant releases,
and threats of releases, of contaminants to ground water.
SECTION 7, STATUTORY DETERMINATIONS
Based upon all of the available information, the selected
remedial action satisfies the remedy selection requirements under
CERCLA/SARA and the NCP. The selection remedial action is
protective of public health and the environment, meets all
applicable or relevant and appropriate requirements, and is cost-
effective. Treatment has been selected for the contaminated
ground water to be extracted. Treatment will be considered for
the contaminated soil to be removed.
The selected actions constitute operable unit remedial
ections. Since hazardous substances, pollutants or contaminants
will remain on the site, EPA shall review such remedial actions
no less than once every five years after initiation of the
remedial actions to assure that human health and the environment
are being protected in accordance with Section 121(d) of SARA.
15
-'
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SECTION 8, IMPLEMENTATION
The remedial actions selected by this ROD may be implemented
by EPA or the potential responsible parties (PRPs). If the
remedial actions are to be implemented by the PRPs, a Consent
Decree will be negotiated between the PRPs and EPA and the
u.s. Department of Justice.
The EPA will consider a phased implementation of these
remedial actions. The initial stage would likely consi~t of
installing one or more extraction wells with the treatment and
piping required for discharge to the local sewage treatment
plant. After a short period of pumping a decision will be made
on the number and location of additional extraction wells. The
removal of contaminated surface 50i15 would likely follow after
all necessary extraction well5had been installed.
The Regional Administrator retains the authority to make
changes in the scope and nature of the actions undertaken at this
site. If new information of additional data is received by'EPA,
the selected remedial actions will be reviewed and additional
response or remedial actions may be considered in light of the
new data or information.
16
-------
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TYPICAL GROuND WATER ELEVATION CONTOURS-
SHALLow SYS TEM
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TABLE I
.
SOIL A~AL YSIS SC~L"'1ARY.
. . ,
J LocI tion: U A-ll uA-ll UA-12 UA-12 CA-13 VA-I3
Depth: 10 Feet 20 Feet 10 Feet 20 Feet 10 Feet 20 Feet
.sample 1'0: T4995002 T 4995004 T49950019 T4995011 T 4995028 T4995030
t Comnound
Vin yl Chloride 10 130 2,700 360 740 120
I ].2.Dichloroethene ] 10 2,300 87,000 22,000 1,500 16,000
Carbon Disulfjd~ 5.4 1 1
Mcthylene Chloride 1,60~
I Acetone 1,500 270 2~O
1.1 Djchloroeth~IH: 55 70 100 4,30:'
1,1 Dichloroethane 48 39 270 17 ,OOC
2-Bu tanone 490 200 2iO
f ],1,1 Trichloroethane 31 150,000
],1,2,2,- T etrachlorocthane 100,000 52,000 67 1-60
] .2Dichloroethane 330
I TrichIoroethene 46,000 35,000 17 230,000
1,1,2- Trichlorethane 280 ],300 1,600
Benzene 62 140 24 250
14-McthY].2.pentanon~ 830 2,200 l6C
Tc tra ch]oro~ then e 3,900 8,000 ]20
To!uene 3,600 1,900 58 :,400
Ch]orobenzene 170 360 530 1,200
r Ethyl Benzene 35 220
Total Xylenes 93 610 1 I 29
Chloroform 14 58
I Total 120 2,435.4 246,763 ] 24,694 4,508 425, iOi
.On]y VOCs found above quantit:1tion limits are shown.
)
-------
RESPONSIVENESS SUMMARY
.
Record of Decision (ROD) for
Fi~dett/Hayford Bridge Road Grou~d
St. Charles, Missouri
W~ter
This Responsiveness Summary presents the responses of the
Environmental Protection Agency (EPA) to public comments received
regarding the proposed remedial actions, for the operable unit of
contaminated shallow ground water, at the Findett/Hayford Bridge
Road Ground Water site in St. Charles County, Missouri. This
document addresses all substantive comments received by the EPA
during the public comment period.
A remedial investigation/feasibility study (RI/FS) was
conducted on this site by EPA. A Proposed Plan was developed by
EPA, which made reco~~endations on the remedial actions for the
site. The RI and FS reports and the Proposed Plan were released
for public review and comment for a 21-day period which began on
November 16, 1988, with public notices in st. Charles and St.
Louis newspapers. A public meeting was held by EPA in St.
Charles on December 5, 1988. A number of verbal
comments were received by EPA during that public meeting. The
only written comments received were from the Findett Corporation.
The following are the substantive public comments, and EPA's
response, to the RI and FS reports and the Proposed Plan for
remedial action.
1. Comment: A commenter noted that five extraction wel.ls were
recommended in the Proposed Plan. Given the limited amount of
hydrogeologic data available on the site, the commenter
recommended that initially a single extraction well be installed
and pumped. The commenter further recommended that the need and
location of any additional extraction wells be determined after
review of data from an initial period of pumping the single
extraction well.
EPA Response: The EPA agrees that there is some benefit to
installing a single extraction well, or a few extraction wells
initially, and determining the need for additional extraction
wells after a period of initial pumping. This essentially
relates to the phasing or sequencing of extraction well
installation. If EPA receives a "good faith offer" from the
potential responsible parties for the installation of a single
extraction well initially, to be followed by an evaluation of
pumping data to determine the need and location of additional
extraction wells, EPA would give serious consideration to
accepting that offer. In essence, EPA believes this to be a
relatively minor detail, close enough to the remedy recommended
by EPA in the Proposed Plan, to be accepted by EPA. Critical to
the acceptability of this rationale to EPA will be the
commitment that all necessary extraction wells will be installed,
'1
-------
and that the reason for installing a single well initially is to
better deterilline the number and location of the rest of the
extraction wells.
2. Comment: A commenter noted that the data now available
indicates that there may be additional contaminant sources, in
addition to the Findett facility. The commenter recommended that
EPA pursue investigation of these other suspected contaminant
sources.
EPA Response: The EPA agrees that the available data now
indicates that there may be other contaminant sources, in
addition to Findett," including but not limited to the Cadmus
Corporation facility. The EPA is actively pursuing these other
potential contaminant sources. Once sufficient evidence is
available, EPA would seek to include them in the remedial actions
at this site. However, in acY~owledging the possible existence
of additional contaminant sources, EPA notes that the highest
levels of volatile organic compound (VOC) contamination in both
soil and water have been found on the Findett facility.
3. Comment: A commenter asked if the deep production well at the
Findett facility had been tested for contamination, and if so
what the results of such testing were.
EPA Response: The EPA sampled the Findett production
part of the remedial investigation. Trace levels (15
1,2-dichloroethene and 16 and 24 ug/l vinyl chloride)
were found.
well as
and 24 ug/l
of VOCs
4. Comment: A commenter asked if the analytical data on the
testing of the public drinking water supply from the Elm Point
Well Field was available to the public.
EPA Response: The water supply is occasionally tested for
contamination by the City or the state, however not for all of
the contaminants which have been found at this site. The EPA has
tested water from the Elm Point Well Field twice, once in January
1988 and again in November 1988. No VOCs were found at detection
limits in any of the samples of the drinking water collected by EPA.
5. Comment: A related question was received as to whether there
were plans for regular testing of this public drinking water
supply.
EPA Response The drinking water program has been delegated to
the state of Missouri by"EPA. The state of Missouri (Department
of Na~ural Resourc~s) intends to sample this water supply on a
quarterly basis. Analyses are to include VOCs.
6. Comment: A commenter asked if-surface water samples had been
collected and analyzed at the site, and how surface water
contamination might affect the Elm Point Well Field.
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EPA Response: A number of surface 'water sediment samples were
collected by Findett at their facility, and by EPA at the
adjacent Cadmus Corporation facility, prior to the remedial
investigation. PCBs .ere found in the surface water and in the
sedi~ents at beth findett and Cadmus facilities. In addition
VOCs were found in the water and sediments a~ the Cadmus
facility. In reviewing the available data prior to beginning the
RI, EPA determined that the surface water contamination posed
much less of a threat to public health than did ground water.
Therefore, the RI focused on the ground water route. Due to the
impermeability of the surface clay soils, it is unlikely that
surface water contamination poses a significant threat of
contaminating the water of the Elm Point Well Field.
The surface water route is not directly addressed in the
operable Unit Feasibility Study, or in this ROD, and will need to
be addressed by EPA in subsequent operable units.
7. Comment: A cornmenter asked if EPA had any plans for
installing additional monitoring wells, closer to the Elm Point
Well Field.
EPA Response: Additional monitoring wells may be required to
monitor the effectiveness of the ground water extraction pr~gram
initiated. It is possible, but unlikely, that any of these wells
would be closer to the well field than currently existing
monitoring wells. The EPA will require continued monitoring of.
some of the deeper monitoring wells. Additional wells may be
required if contamination is encountered.
8. Comment: A cornmenter asked why only shallow ground water was
being addressed in the operable unit.
EPA Response: The EPA focused on the route via which public
health was most directly at risk (i.e. the risk of contamination
of the Elm Point Well Field drinking water). In order to contain
the contamination and prevent the contamination of this drinking
water supply, EPA decided to focus on the ground water route and
address other routes, such as air and surface water, in
subsequent operable units. Only the shallow ground water was
initially found to be contaminated in the RI. In order to
prevent the spread of contamination to the deeper aquifer, or
spreading further in the shallow aquifer, EPA decided to contain
~he contamination within the shallow ground water near the site.
9. Comment: A commenter asked how ~xtraction wells could
interfere with land uses.
EPA Response: In addition to the Findett facility, the property
on which extraction wells would most likely be located is a farm
field to the north of Findett. The installati9n of extraction
wells would interfere with the farming of that portion of the
field. Farm equipment, such as tractors for planting or
harvesting, would have to be careful to go around the well.
Buildings could not be easily installed over an extraction well.
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Finally / extraction ',.;ells will tend to "draw down" the shallow
aquifer, or lc~er the water table. This would limit the
availability of shallow ground water in the affected area. (At
present there are no ?hallow production wells on the affected
p:-operties.)
10. Comment: A question was received asking that the source
control measures mentioned by EPA in the public meeting be
explained.
EPA Response: The source control mentioned would consist of
removing contaminated soil for offsite treatment or disposal.
Soils near the Findett quench pond are contaminateu with PCBs and
VOCs, as are portions of the Cadmus facility. Findett has
removed some of the PCB-contaminated surface soils from their
facility for offsite disposal. Findett has also proposed to
remove additional contaminated soils from their facility and to
install an impermeable cap over any residual soil contamination.
In addition to reducing the potential for direct contact exposure
to hazardous substances, source control would remove contaminated
soil as a source of contaminant release to the ground water~
11. Comment: A related comment was received asking whether the
VOC contamination of ground water was limited to the shallow
aquifer. ".
EPA Response: At the conclusion of the RI, ground water
contamination was "thought to be limited to the upper aquifer,
although trace levels (e.g. less than 25 ug/l) were reported in
the Findett production well, which is completed in the deep
aquifer. Since this unused production well may also have been
completed in the upper aquifer , it is not known for sure whe"ther
the contamination came from the upper or lower aquifer, or both.
Subsequently, EPA resampled a deep monitoring well (LAS) and
found 1400 ug/l of VOCs. Resampling of this well confirmed VOC
contamination, -but at much lower levels (61 and 69 ug/l). In
summary, although some contamination of the lower aquifer is now
believed to exist, much higher levels of contamination are found
in the upper ground water.
12. Comment: A commenter noted that there are a number of
shallow (40-60 feet deep) drinking water wells approximately 2
miles northeast of the site. The commenter asked if drinking
water from these wells was at risk of contamination by releases
from the site.
EPA Response: During the public meeting, during which this
comment was made, the location of these wells, relative to the
site, was not clear to EPA. Subsequently, EPA has received
additional information from the County more clearly locating
these wells. The wells in question are located in, or just south
of the community of Kampville. These private drinking water
wells would be about 2 miles northeast of the site, and at least
1 1/2 miles northeast of the Elm Point ,Well Field. Although this
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may be downg~adient of the site, it is very unlikely that
contaminants from this site would reach these wells at
concentratic~s above laboratory detection limits. The EPA will
consider the need for testing these wells after reviewing
continued testing of monitoring wells at the site and of the Elm
Point Well Field wells.
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13. Comment: A commenter asked how well the upper and deeper
aquifers were defined near the site~
EPA Response: within the area defined by the .ground water
monitoring network installed by EPA in the RI, there appear to be
two distinct aquifers, an upper aquifer in the upper sands,
separated by the lower clay layer, from the deeper aquifer in the
lower sands extending down to bedrock. The degree of connection,
if any, between the upper and deeper aquifers has not been
determined and continues to be evaluated.
The EPA recognizes that this geologic setting may be fairly
localized. For example, the layers of subsurface soils
encountered at the Elm Point Well Field, 1800 feet northeast of
the site, were significantly different. The lower clay layer was
not encountered in these wells. Boring logs for these drinking
water wells reported a surficial layer of clay, underlain by
silt, then sand, gravel, boulders and then bedrocK. A single
aquifer exists at the Elm Point Well Field. Thus it appears as
if the lower clay separating the upper sand aquifer from the
lower sand aquifer beneath the site, pinches out before reaching
the well field 1800 feet to the northeast.
14. Comment: A commenter inquired as to.the nature of the
Findett operations. .
EPA Response: Originally Findett reclaimed heat transfer fluids
or oils, some of which contained polychlorinated biphenyls
(PCBs). Findett also received some waste solvents for
reclamation or recycling. Findett has not been involved in
either of these types of activities since 1980. At the present
time Findett custom blends or manufactures organic chemicals for
other companies, using chemicals or raw materials received from
that client or customer.
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