United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R07-89/027
September 1989
Superfund
Record of Decision
Vogel Paint & Wax, IA
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50272.101
REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/R07-89/027
I ~
:L Rec:lpI8nI'a ACC888Ion No.
4. Title and Subtile
SUPERFUND RECORD OF DECISION
Vogel Paint & Wax, IA
First Remedial Action - Final
7. Author(a'
5. A8port DaI8
09/20/89
8.
8. P8rf0nn1ng Org8nlz81lon Rap&. No.
8. P8rfonnlng Orgalnlzallon Nanw and ~
10. Proj8c:tlTuluWorII Unl1 No.
11. Contract(C) or Grant(G' No.
(C)
(G'
1~ Sp_oring Org8nlz8llon Nanw and AddrH8
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
1:L TYJ18 of Report . Period Covered
Agency
.800/000
14.
1 S. Supplem8n1uy No...
18. Abatract (UmI1: 200 WOIda'
The Vogel Paint & Wax (VPW) site is an approximately two-acre disposal area two miles
southwest of the town of Maurice, in Sioux County, Iowa. Adjacent land uses are
primarily agricultural; however, several private residences are within one-quarter mile
of the site. An intermittent stream flows through the site and discharges to the West
Branch Floyd River one mile away. A surficial sand and gravel aquifer underlies the site
and supplies nearby private wells and the Southern Sioux County Rural Water System,
located a mile and one half southeast of the site. Paint sludge, resins, solvents, and
other paint manufacturing wastes were disposed of at the site between 1971 and 1979. The
disposal area is on two acres of an 80-acre tract owned by VPW. Liquid wastes were
poured into trenches along with filled or partially filled drums and other debris and
capped with one to two feet of soil. VPW records indicate that approximately 43,000
gallons of aliphatic and aromatic hydrocarbons and 6,000 pounds of metals waste were
buried at the site. The disposal area was covered with clay in 1984. The primary
contaminants of concern affecting the soil and ground water are VOCs including benzene,
toluene, and xylenes; and metals including chromium and lead.
The selected remedial action for this site includes excavation of contaminated soil and
separation of solid and liquid wastes; onsite bioremediation of 3,000 cubic yards of the
'...",t-o-i "".,~, ~... '" ~"".. t...o-i - {"I"I...+-~n"oA 1"1'" "'ov+- rI"'rTO\
17. Doa8n8nI An8Iy8I8 .. 088crIp80ft
Record of Decision - Vogel Paint
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene,
It. Id8nlltl8r8/Opln-End8 Tanna
& Wax, IA
toluene, xylene), metals (chromium, lead)
Co COSA 11 A8IdIQroup
11. A¥8iI8bIIty SI-.nI
11. S8curttJ aa. (ThI8 AIporQ
None
2IL S8a8tty aa. (ThI8 ....,
Nnnl'>
21. No. of P8g88
32
~ PI1ce
(See ~Z3I.1')
See flwftlctl- 0" Re-
(FOfI'MIty NT1~
~ofCo_ce
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DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT
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R Gpo. 1983 0 - 381-526 (8393)
OPTIONAL FORM 272 BACK
(4-77)
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EPA/ROD/R07-89/027
Vogel Paint & Wax, IA
16.
Abstract (Continued)
unit, or onsite thermal treatment if soil contains high metal content; stabilization of
treated soil, if necessary to prevent leaching of metals, followed by disposal in the
excavated area; offsite incineration, recycling or disposal of solid and liquid wastes;
recycling of leachate and offsite treatment at POTW of excess leachate; ground water
pumping and treatment using air stripping with discharge of treated water to a nearby
stream; and ground water and air monitoring. VOC emissions to the atmosphere from both
the soil and ground water cleanup actions will be controlled by carbon adsorption, if
necessary. The estimated present worth cost for this remedial action is $1,851,000 which
includes an annual O&M cost of $54,600.
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.. ....';.;:. -- ~'.. . ',.
RECORD OF DECISION
FOR
THE VOGE1. PAINT AND WAX COMPANY SITE
MAURICE, IOWA
Prepared by:
IOWA DEPARTMENT OF NA'l'URAL RESOURCES
September 14, 1989
,
.
"
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DECLARATION FOR THB RECORD OF DECISION
1.0
site Name and Location
Vogel Paint and Wax company; Maurice, Iowa
statement of Basis and PurDose
1.1
This decision document presents the selected remedial action for
the vogel Paint and Wax Company site, in sioux County, Iowa, which
was chosen in accordance with the requirements of the Comprehensive
Environmental Response, compensation, and Liability Act of 1980
(CERCLA), as amended by the superfund Amendments and
Reauthorization Act of 1986 (SARA) and, to the extent practicable,
the National Oil and Hazardous Substances Pollution contingency
Plan (NCP). Thfs decision document explains the factual and legal
basis for selecting the remedy for this site.
The Iowa Department of Natural Resources concurs with the selected
remedy. The information supporting this remedial action decision
is contained in the administrative record for this site.
1.2
Assessment of the site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this Record of Decision (ROD), may present an imminent and
substantial threat to public health, welfare, or the environment.
1.3
DescriDtion of the Selected Remedv
The selected remedy consists of activities involving soil and
groundwater cleanup. Contaminated soils will be excavated and
solid and liquid waste will be separated for off-site incineration,
recycling, or disposal. An estimated 3000 cubic yards of
contaminated soils will be treated using a bioremediation process
in a fully contained surface impoundment unit. If additional
testing shows bioremediation to be infeasible due to high metal
levels, on-site thermal treatment will be implemented in its place.
Treated soil will be stabilized if necessary to prevent leaching
of metals, placed back into the excavation and covered.
Groundwater will be pumped and air stripped with discharge to the
nearby stream. Losses of volatile organics to the atmosphere in
both the soil and groundwater actions will be controlled by carbon
adsorption, if necessary. Health-based standards for groundwater
and leaching standards for soils have been established. In
addition, the site is currently listed on the State Abandoned or
Uncontrolled sites Registry (SAUSR). Substantial change or
transfer of property on this registry is prohibited without written
approval of the Director of the Iowa Department of Natural
Resources. The selected remedy is believed to be capable of
1
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achieving the cleanup standards which would constitute final action
for this site.
1.4
Declaration of Statutorv Determinations
The selected remedy is protective of human heal th and the
environment, complies with Federal and state requirements that are
legally applicable or relevant and appropriate .to the remedial
action and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable, and it satisfies
the statutory preference for remedies that employ treatment that
reduce toxicity, mobility, or volume as their principal element.
Because this remedy will result in hazardous substances (below
health-based standards) remaining on site, a review will be
conduc~ed within five years of commencement of remedial action to
ensure that the remedy continues to provide adequate protection of
human health and the environment.
, )J/vl{~
~ORRIS ~Y, REGIONAL ADMINISTRATOR
ENVIRONMENTAL PROTECTION AGENCY, REGION VII
9- 20- S"r
DATE
~6'~~
ALLAN STOKES, ADMINISTRATOR
IOWA DNR, ENVIRONMENTAL PROTECTION DIV.
~. ''-I) Iq81
"DATE
2
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DBCISION SUHMARY POR THE RECORD OP DBCISION
2.0
site Name. Location. and DescriDtion
The Vogel Paint and Wax Company (VPW) is located about two
miles south and a mile west of the town of Maurice, in sioux
County, Iowa. Figure 1 shows the general site location.
The site's legal address is:
Range 45 west.
NW 1/4, Sec. 29, Township 94,
2.1
site Historv and Enforcement Activities
The site is located in a rural area on the uplands of the West
Branch Floyd River. Adj acent land uses are primarily for cropland.
The one-eighth section owned by VPW is partially used for cropland.
An unnamed intermittent stream flows to the northeast through the
northwest portion of the VPW one-eighth section and discharges to
the West Branch Floyd River about a mile away. (See Figures 2 and
3.) The West Branch Floyd River is classified for protection of
wildlife, aquatic life, and secondary body contact (e.g., wading).
A surficial sand and gravel aquifer and Dakota sandstone bedrock
aquifer underlie the site. The sand and gravel aquifer supplies
nearby private wells and the Southern Sioux County Rural Water
System located about a mile and a half southeast of the site.
Wells in the surficial aquifer are typically less than 50 feet
deep. The Dakota sandstone is the primary bedrock aquifer in the
region. Dakota wells are typically 250 to 450 feet deep. The
surficial aquifer has been identified as the primary route of
contaminant migration from the site. Ground water has been found
to flow in a southerly to southeasterly direction which is
different from the surface topography.
The _closest communities are Maurice (1980 population of 288)
located about two miles to the north-northeast of the site and
Struble (1980 population of 59) located about two and a half miles
south of the site. The Southern sioux County Rural Water System
serves approximately 3200 people. Private rural residences exist
within about a quarter mile northwest and southwest of the site.
Figure 2 is a map of the vicinity.
The site itself consists of an approximate two acre disposal area
which has been covered with clay. Monitoring wells are the only
site structures. Figure 3 is a site map.
Prior to its use for waste disposal, the northern half of the site
contained a gravel pit and the remainder of the site was tilled for
agricultural purposes. In 1971 Vogel Paint and Wax Company, Inc.
3
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FIGURE 2
VICINITY MAP
3b
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400
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Scale: 1 Inch. 400 f
eet
FIGURE 3
SITE MAP
3c
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(VPW) of Orange City, Iowa began using the site for waste disposal.
Paint sludge, resins, solvents and other paint manufacturing wastes
were disposed of at the site until 1979. Such disposal was not
prohibited at that time. . The disposal area encompasses about two
acres of the SO-acre tract owned by VPW. (See Figure 3.) Liquid
wastes were dumped into twelve or more trenches eight to twelve
feet in depth. The trenches were left open for an extended period
of time to allow volatilization of solvents. Filled or partially
filled drums and other debris were then dumped on top of the liquid
wastes, and the trenches were covered with one to two feet of soil.
Solid wastes such as wooden pallets a:1d packing materials were
disposed of in the former gravel pit after several feet of clayey
silt soil was placed on the floor of the pit.
Data from company records indicate that approximately 43,000
gallons of aliphatic and aromatic hydrocarbons have been buried at
the site, primarily including toluene, xylene, ethylbenzene, methyl
ethyl ketone, and mineral spirits. An estimated 6,000 pounds of
mercury, lead, zinc and chromium have been disposed of at the site.
The estimated quantities of materials delivered to the site are:
Solvents 43,000 gallons
Lead 3,900 pounds
Mercury 7 pounds
Zinc 1,500 pounds
Chromium 600 pounds
Assuming that two-thirds of the sol vents were poured into the
trenches, and 60 percent was released to the atmosphere by
volatilization, approximately 11,500 gallons of free solvents would
remain in the trenches to potentially enter the soil and
groundwater.
In the Spring of 1979 the State of Iowa received complaints of
paint waste disposal at the VPW site about 1.5 miles north of a
proposed rural water district well field. The State conducted
initial investigations at the site in 1979. In late 1979 VPW
initiated additional investigations at the State's request. The
site was placed on the National Priorities List (NPL) in 19S4.
Since 1979 VPW has conducted numerous investigations in cooperation
with the State. The Remedial Investigation and Feasibility Study
were conducted in accordance with a Consent Order between VPW and
the Iowa Department of Natural Resources (DNR) effective June 19S7~
4
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2.2
Hiqhliqhts of Community Participation
The Remedial Investigation and Feasibility study Reports and the
Proposed Plan for the Vogel site were released to the public for
comment on August 10 , 1989 . These two documents were made
available to the public in both the administrative record and an
information repository maintained at DNR Records Center, 5th Floor,
Wallace Building, 900 East Grand, Des Moines, Iowa, and in the
Orange City Public Library.
The notice of availability for these two documents was published
in the Sioux City Journal on August 10, 1989. A public comment
period on the documents was held from August 10, 1989 to August 31,
1989. In addition, a public meeting was held on August 21, 1989.
At this meeting, representatives from DNR, EPA, and Vogel Paint and
Wax Company answered questions about problems at the site and the
remedial al ternati ves under consideration. A response to the
comments received during this period is included in the
Responsiveness Summary, which is part of this ROD.
2.3
Scope and Role of Response Actions Within Site Strategy
The selected response actions independently address two affected
media, Le., solid waste/soil and groundwater. The solid waste and
contaminated soils in the disposal area are a source of
contaminants leaching into groundwater. Wastes were covered with
clay in 1984 and pose no threat due to direct contact. The cleanup
objective for solid waste/soils is to reduce migration of
contaminants into groundwater by removal and/or treatment of the
source, i.e., the contaminated soils/solid waste.
Contaminated groundwater is a potential threat to current and
future drinking water supplies. To a lesser degree, other
environmental risks could result from the eventual discharge of
contaminated groundwater to surface streams. The cleanup objective
for groundwater will be to reduce contaminants in groundwater to
established health-based standards for drinking water.
The response actions selected in this ROD address all principal
threats posed by this site and are intended to constitute final
actions for the site.
2.4
SummarY of Site Characteristics
A wide variety of contaminants have been detected in various media
at the site: including several potential carcinogens. Table 1
summarizes contaminants found in groundwater, surface water, and
soil. Groundwater contaminants are limited to well-defined plumes
which do not appear to be expanding. Figures 4-7 show contaminant
plume configurations. The ground water flow is likely to be in a
northerly direction in the upper sand unit. In the lower sand and
gravel unit, ground water flows in an easterly direction north of
5,
-------
direction south of the disposal area (See Figure 8.) Since March
of 1984, two wells have been used to remove floating hydrocarbons.
This activity has reduced the thickness of the floating hydrocarbon
layer from 12.4 to 1.7 feet.
In general, no significant surface water contamination has been
detected and soil contamination is concentrated in the two acre
disposal area. currently there are no populations at risk.
However, contaminated groundwater is a potential threat to current
and future drinking water supplies.
6
-------
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FIGURE 4
ETHYLBENZENE ISOCONCENTRATION r~p (1-18-89)
6a
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FIGURE 5
MEK ISOCONCENTRATION MAP (1-18-89)
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FIGURE 6
TOLUENE ISOCONCENTRATION r-1Ap (1-18-89)
6c
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FIGURE 7
XYLENE ISOCONCENTRATION r~p (1-18-89)
6d
-------
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FIGURE 8 17 89)
GROUUDWATER FLO\~ MI\P (1- -
6e
N
eI3
-------
TABLE 1
CONCENTRATION VALUES IN VARIOUS BNVIRONXEN'l'AL MEDIA
Gr~ater Surface Water soil*
(DellI) (DellI) (IIIQ/kg)
Chemical Ranae ~ Ranae !!!!D Ranae !!UD
Arsenic(PC) !fA !fA !fA !fA 4.8-'2.' 7.6
8eryl L h.lll(PC) 0.02-0.02 0.02 !fA !fA !fA !fA
Caciniun BDL-0.07 0.02 BDL-BDL BDL 0.2-6.4 1.1
Chromiun III BDL-O.OS 0.001 IDL-0.012 0.004 4.9-21,000 1240
(44) <14.8)
Lead BDL-0.32 0.007 IDL-0.026 0.009 5.2-41,000 4600.0
(140) (26.6)
Mercury BDL-0.11 0.0005 IDL-BOL BOL IDL-65 4.4
(0.04) (0.07)
NickeL NA NA !fA !fA 10.3-25.9 14.8
Zinc BOL-0.24 0.07 0.03-0.04 0.02 15.5-12,000 826.0
(44.3)
8is(2-EthyLhexyL)
Phthalate NA NA NA !fA 1.7-6.6 3.4
DibutyL
Phthalate NA !fA NA !fA BOL'0.30 0.30
Acetone SOL-0.28 0.13 !fA !fA SOL-0.37 0.12
8enzene(PC) 8OL-0." 0.05 !fA !fA 0.1-8.0 1.2
ChLorofoMII(PC) NA NA NA !fA SOL-0.007 0.006
Dichloro-
Nthane(PC) BDL-0.42 0.21 NA !fA BDL-O.14 0.04
1,2-Dichloro'
propene(PC) IDL-0.07 0.03 NA NA NA NA
Ethylbenzene 8OL-67 5.2 IDL -0.0036 0.0006 IDL-976 90
Methyl EthyL
Ketone BDL-120 3.7 IDL-0.037 0.006 IDL-0.51 0.51
Methyl Isobutyl
Ketone 8OL-0.62 0.31 NA NA BOL-0.87 0.32
Toluene 8OL-37 3.8 BOL-0.0014 0.0002 IDL-1711 145
Trichloro-
ethylene(PC) IDL-O.O' 0.006 !fA !fA IDL-O.OS9 0.04
Xylenes 8OL-260 20 IDL-O.013 0.002 IDL-704 57
NA . Not Available
BOL . Below Detection Limit
PC . Potential Carcinogen
. Mean soil values for Chromiun, Lead, Mercury end Zinc are skewed due to five of thirty-one temples.
Values shown in parentheses do not include resul ts frCIII these five simples, and are as follows:
Chromiun - 9,400 -e/kg: Lead - 28,300 -e/kg: Mercury - 21.6 ~/kg: and Zinc - 4,900 -e/kg.
7
-------
, ,
2.5
SummarY of Site Risks
The U. S. Public Health Service Agency for Toxic Substances and
Disease Registry conducted a Health Assessment for the VPW site.
They concluded that the condition of the site does not pose an
immediate public health threat. The site is covered and located
in a rural area. Because of these conditions, direct exposure to
contaminants does not occur. However, the potential for off-site
migration of contaminants into the groundwater may lead to a future
public health threat. .
An Endangerment Assessment was conducted as part of the remedial
investigations. This Endangerment Assessment provided a baseline
risk assessment to assist in the development of remedial
alternatives. It concluded that there is no potential for
significant exposure to contaminants via soil, surface water, or
air. Exposure pathways have been identified via groundwater taken
from the two residential wells just west of the site; however, when
contaminants have been detected in these two wells, the
concentrations have been below health-based drinking water
standards and no increasing trend has been observed. Volatile
organic contaminants have been observed at the site boundary at
concentrations which do not pose a significant threat to public
health or the environment. However, Cadmium, Methyl Ethyl Ketone,
Ethylbenzene, and Xylenes (all non-carcinogens) have been detected
within the area of groundwater contamination at concentrations high
enough to pose a subchronic and/or chronic risk to humans if they
were to ingest this water. Benzene, a carcinogen, has also been
detected in site groundwater.
Potential risks from drinking contaminated groundwater were
calculated in the Endangerment Assessment and are summarized in
Table 2. These hazards were based upon consumption of mean
contaminant concentrations found in on-site monitoring wells,
except for benzene in which case the maximum level found was used.
Therefore, the potential hazards presented in Table 2 do not
represent current exposure to any person. As stated previously,
no significant off-site hazard has been identified: however, the
potential for migration of contaminant in groundwater does exist
which could impact a drinking water supply in the future.
8
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TABLE 2
St7HHARY OP POTENTIAL HAZARDS PROX
CONSUKPTION OP CONTAKIHATBD GROUNDWATBR
Chemical EDI RfD HQ CPF ELC
Cadmium 5. 8x10.4 2. 9X10.4 2.0
Chromium 11.6x10-5 1.00 11. 6x10.5
Lead 8. 7x10-4 1. 40X10.3 6. 21x10.'
Mercury 1. 5X10.5 2. 00x10.3 7. 25X10.3
Benzene 3. 2X10.3 5. 2X10.2 1.7x10.4
Ethylbenzene 22. 6X10-2 5. 00x10.2 4.52
Methyl Ethyl 21. 2xio.2 5. 00x10-2
Ketone 4.23
Toluene 20.3x10-2 3. 00x10.' 6. 77X10.'
Xylenes 86. 4X10.2 1. OOX10.2 86.4
Hazard Index --------------------------98.5
Total Excess Lifetime Cancer Risk------------------------l.7x10-4
EDI - Estimated Daily Intake
RfD - Reference Dose
HQ - Hazard Quotient
CPF - Cancer Potency Factor
ELC - Excess Lifetime Cancer
Risk
NOTE:
See text for description of these parameters
,
9
~.
-------
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to chemicals
exhibiting noncarcinogenic effects. RfDs, which are expressed in
units of mg/kg-day, are estimates of lifetime daily exposure levels
for humans, including sensitive individuals, that are not likely
to be without an appreciable risk of adverse health effects.
Estimated intakes of chemicals from environmental media (e.g., the
amount of a chemical ingested from contaminated drinking water) can
be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g., to account for the use of animal
data to predict effects on humans). These uncertainty factors help
ensure that the RfDs will not underestimate the potential for
adverse noncarcinogenic effects to occur.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard quotient
(HQ) (or the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the contaminant's
reference dose). By adding the HQs for all contaminants within a
medium or across all media to which a given population may
reasonably be exposed, the Hazard Index (HI) can be generated The
HI provides a useful reference point for gauging the potential
significance of multiple contaminant exposures wi thin a single
medium or across media. HI values less than one are acceptable.
Cancer potency factors (CPFs) have been developed by EPA's
carcinogenic Assessment Group for estimating excess lifetime cancer
risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day).',
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake level.
The term "upper bound" reflects the conservative estimate of the
risks calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely. Cancer
potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.
Excess lifetime cancer risks are determined by mUltiplying the
intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., 1X10.6). An excess lifetime cancer risk of 1X10.6 indicates
that, as a plausible upper bound, an individual has a one in one
million chance of developing cancer as a result of site-related
exposure to a carcinogen over a 70-year lifetime under the specific
exposure conditions at a site.
This site has not been found to currently pose any significant
environmental risks. Contaminants have not migrated far. Low
10
-------
levels of contaminants have occasionally been detected in the
adjacent intermittent stream. There are no critical habitats or
endangered species affected by site contaminants.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this ROD, however, present an imminent and substantial
endangerment to public health, welfare, or the environment.
2.6
DescriDtion of Alternatives
soil and Groundwater remedial alternatives have been evaluated
separately. One soil and one groundwater alternative have been
chosen to constitute complete remedial action for the site.
The alternatives for soil and groundwater cleanup which have been
evaluated are listed below. The uS: refers. to soil alternatives
and the "GW" refers to groundwater.
o Alternative S-l:
Excavation and Off-site Incineration and
Disposal
o Alternative S-2:
Excavation, On-Site Thermal Treatment,
Soil Stabilization (if needed), and On-
Site Disposal
Excavation, On-site Bioremediation, Soil
Stabilization (if needed), and On-site
Disposal
No Action - Soils
o Alternative S-3:
o Alternative S-4:
o Alternative GW-l: Pumping, Air Stripping, and Discharge to
Surface Water
o Alternative GW-2: In-situ Bioremediation
o Alternative GW-3: No Action - Groundwater
Common Elements: All of the soil alternatives except the "No
Action" alternative include excavation of about 3,000 cubic yards
of contaminated soils. Temporary on-site storage of excavated
materials would be utilized, if necessary. Waste material other
than soil (e.g, drums and debris) would be isolated,
decontaminated, and shipped to a municipal landfill for disposal
if it can be rendered non-hazardous, otherwise it would be disposed
of in a hazardous waste landfill or incinerated off-site. In
addition, free liquids in the excavation would be removed and
stored in temporary tanks prior to ultimate off-site treatment by
incineration or recycling. All groundwater alternatives include
monitoring to ensure contaminants are not moving off-site. Dust
control and/or air monitoring would be conducted for all on-site
activities in which the potential for release of contaminants to
11
-------
air exists. All alternatives also include listing of the site on
the state Abandoned or Uncontrolled sites Registry which has
already been done. A listing on this registry is filed with the
county recorder and requires the owner to obtain written approval
from the Director of DNR prior to selling or substantially changing
the site. other previous actions which are common to all
alternatives include the two feet thick clay cover placed on the
waste disposal area and. continued floating hydrocarbon removal.
ALTERNATIVE S-l
EXCAVATION AND OFF-SITE DISPOSAL
capital Cost: $6,390,000
Annual Operation and Maintenance (O&M)
Present Worth (PW) Cost: $6,390,000
Months to Implement: 2
Cost: 0
'.
The contaminated soil would be excavated, transported to and
incinerated at an approved incineration facility as regulated by
40 CFR Part 264. Metals in ash resulting from incineration would
be stabilized if necessary prior to final disposal. Clean soil
would be used to backfill the excavation and the area would be
revegetated. With this alternative, all contaminants would be
removed and there would be no need for long-term maintenance.
ALTERNATIVE S-2;
EXCAVATION, ON-SITE THERMAL TREATMENT
(STABILIZATION), AND ON-SITE DISPOSAL
Capital Cost: $2,045,000
Annual 0 & M Cost: $1,000
PW Cost: $2,060,000
Months to Implement: 1-3
Low temperature thermal treatment of contaminated soil would be
used to drive off volatile organic compounds b1 mixing of excavated
soils in a rotary kiln at temperatures of 600 -800° F. The organic
contaminants in the hot exhaust from this process would be
destroyed by an afterburner. This process would not treat metals
in the soil and the residual soil may require stabilization (e.g.,
mixing with lime or cement) to prevent leaching of metals to
groundwater. Treated, stabilized soil would be redeposited in the
excavation, covered with clean soil, and revegetated. Treatment
standards to be met prior to disposal would be at health-based
levels. For metals, the levels are based on Extraction Procedure
Toxicity standards. For organic compounds, the levels are based
on Toxicity Characteristic Leaching Procedure standards, with a
limit of 100 ppm total organic hydrocarbons. Operation and
maintenance of this site would be minimal efforts involving
periodic site inspections and repairing any erosional damage.
(30 yrs.)
12
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ALTERNATIVE 5-3:
(STABILIZATION), AND ON-SITE DISPOSAL
capital Cost: $1,370,000
Annual O&M Costs: $1,000 (30
PW Cost: $1,385,000
Months to Implement: 6-12
This alternative is the same as Alternative 5-2, except that
bioremediation of soils would be utilized instead of thermal
treatment. Bioremediation of soils would involve a fully contained
surface impoundment system complying with minimum technology
standards using conventional soil management practices (e. g. ,
nutrient addition and soil aeration) to enhance microbial
degradation and volatilization of organic contaminants. The system
would be designed to contain and treat soil leachate and
volatilized contaminants. The treatment system would be about one
acre in size consisting of a double-lined treatment bed, leachate
collection system, groundwater monitoring, and a modified plastic-
film greenhouse cover. Leachate would recycled back to the
treatment area. Excess leachate would be collected for off-site
treatment (e.g., municipal wastewater treatment plant). Vapors
would pass through activated carbon to absorb organics prior to
release. Spent activated carbon would be regenerated, if possible,
or sent to an approved landfill.
years)
High concentrations of heavy metals may prohibit use of this
process. A trial run treatability study would be necessary prior
to implementation. If small quantities of soils are identified as
containing high levels of heavy metals which are incompatible with
bioremediation, these soils would be isolated for off-site
treatment and/or disposal at an approved hazardous waste disposal
facility. If high concentrations of heavy metals pose excessive
restrictions on the use of bioremediation, Alternative S-2
utilizing thermal treatment of soils would be implemented in its
place.
ALTERNATIVE 5-4:
NO ACTION - SOILS
Capital Cost: $2,500
Annual O&M Cost: 0
PW Cost: $2,500
Months to Implement:
o
The Superfund program requires that the "no action" alternative be
evaluated at every site to establish a baseline for comparison.
Under this alternative no "additional" action would be taken
regarding 80ils. Previous covering of the disposal area with two
feet of clay and listing of the site on the State Abandoned or
Uncontrolled sites Registry are actions which have already been
13
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implemented. This alternative does include the minor cost of
placing a fence around the site.
ALTERNATIVE GW-1:
PUMPING, AIR STRIPPING, AND DISCHARGE TO SURFACE WATER
Capital Cost: $320,000
Annual O&M Costs: $53,600
PW Cost: $466,000
Months to Implement: 36+
(3 yrs.)
contaminated groundwater would be removed by pumping from one or
more wells. This well (or wells) would be located and sized to
draw water from the entire area of groundwater contamination
thereby preventing any off-site migration of groundwater
contaminants. A pumping test would be conducted during the
remedial design to determine aquifer characteristics. This
information would be used to design the pumping system, i.e.,
number and location of wells, pumping rates, and gradient controls.
The pumped water would be run through an air stripper to remove in
excess of 95% of the volatile organic contaminants. Air stripping
is a well-established process in which water is cascaded through
a column packed with an inert media (e.g., plastic balls) and air
is forced through the column in a counter direction. Volatile
organics are stripped from the water and included in the air
discharged from the top of the column. Carbon adsorption would be
used to remove contaminants in the air discharged from an air
stripper, if necessary to meet air quality standards. Treated
water, meeting water quality standards, from the air stripper would
be discharged to the nearby unnamed stream. If water from the air
stripper does not meet water quality standards, additional
treatment would be provided, as necessary. The need for additional
treatment, however, is not anticipated. Pumping and treatment
would continue as long as necessary to reduce contaminant levels
to established cleanup levels. .
ALTERNATIVE GW-2:
IN-SITU BIOREMEDIATION
In-situ bioremediation of groundwater involves enhancing the
natural biodegradation process by means such as nutrient injection,
aeration, and introduction of cultured bacterial strains. Natural
biological activity is capable of degrading organic contaminants
to innocuous compounds. Such a process would involve careful
monitoring and control of conditions to enhance biogradation until
contaminant levels are reduced to established cleanup levels. This
alternative would not address metals in groundwater. However,
existing levels of metals are largely in compliance with health-
based drinking water standards.
14
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ALTERNATIVE GW-3:
NO ACTION - GROUNDWATER
capital Cost: $30,000
Annual O&M Costs: $4,600
PW costs: $101,000
Months to Implement: 0
As with the soil "no action" alternative, this alternative is
required in the Superfund program to establish a baseline for
comparison. Under this alternative no "additional" action would
be taken regarding groundwater. However, current activities
including monthly removal of floating hydrocarbons and quarterly
groundwater sampling would be continued indefinitely. The listing
on the State Abandoned and Uncontrolled Sites Registry could
prevent future withdrawals of groundwater from the site. The site
could be reactivated if monitoring results indicated migration of
contaminants from the site.
( 3 0 yrs.)
2.7
SummarY of ComDarative Analvsis of Alternatives
Table 3 summarizes the comparison of alternatives against the nine
evaluation criteria which are discussed in more detail below.
Overall Protection: No immediate threat has been identified, the
extent of groundwater contamination does not appear to be
expanding, monitoring will be required of all alternatives,
institutional controls are in place, and direct contact with
contaminated soils is not a threat. Therefore, all of the
alternatives would provide adequate protection to human health and
the environment. All of the alternatives, except the "no action"
alternatives, accomplish this by reducing the amounts of
contaminants through treatment or removal. The "no action"
alternatives provide a much lesser degree of overall protection
because much larger amounts of contaminants would remain on site.
Alternative GW-2 involving in-situ bioremediation may have a
somewhat lower degree of overall protection because the level of
effectiveness is uncertain. The proposed alternatives would
significantly reduce the source of contaminants and levels of
contaminants in groundwater to below health-based standards for
drinking water.
ComDliance with ARARS: All alternatives, except the "no action"
alternatives, should meet their respective applicable or relevant
and appropriate requirements of Federal and State environmental
laws. The groundwater "no action" alternative would not meet
groundwater cleanup standards. Alternatives S-2 and S-3 involving
on-site soil disposal should be able to meet federal land disposal
requirements ("Land Ban") by treatment of wastes to health-based
levels.
.
15
v
-------
~. .' ,..J' '..':. L .:', . :,:. _: ,,'
,....,..'.... .
'fOLK 3
SUMMARY BVALUATION 01' REMEDIAL ALTERNATI~S
SOIL ALTERNATIVES
Alternative
S.1
S.2
S.3
S.4
long-term Reduction 0' Short-term
Effectiveness T M & V Effectiveness
Overall Community
Protection tance
Yes High
Yes High I Yes : Yes
.Yes High Yes ; Yes
t-b Low
High
High
High
Low
. High
High
High
Low
Medium.
Medium
Medium
High
High
High
Medium
High
6.390.000
2.060.000
1.385.000
2.500
......
c:" I
~,
GROUNDWATER ALTERNATIVES
Alternative long-term Reduction 0' Short-term Implement Present Worth CompUance Overall State Community
Effectiveness TM&V Effectiveness ability Cost lOollars) with ARARs Protection Acceotance Aoceotanoe
GW-1 High High Medium High 466.000 Yes High \.Yes ! Yes
GW-2 Medium Medium Medium Medium 624.000 Yes Medium --- ---
GW-3 low Low High High 101,000 t-b Low --- ---
KEY:
Alternative
S-1
S-2
S-3
S-4
GW-1
GW-2
GW-3
Descrl lion
Excavation and Off-Site Incineration
Excavation. (On-Site Storage). On-Site Thermal Treatment.
(Stabilization), On-Site Disposal
Excavation, (On-Site Storage), On-Site Bloremediation.
(Stabilization), On-Site Disposal
No-Action and Institutional Controls
Pumping, Air Stripping, and Discharge to Surface Water
In-Situ Bioremediation
No-Action. Institutional Controls. and Long-Term Monitoring
-------
Lena-Term Effectiveness and Permanence: Alternative S-l would
remove all contaminated soil and wastes from the site for treatment
and disposal, thereby eliminating long-term risks at the VPW site
and minimizing off-site risks. Alternative S-2 and S-3 would both
provide a high degree of long-term effectiveness by eliminating
most volatile organic contaminants and stabilizing residual soils,
if necessary, to prevent leaching of metals which will not be
removed by treatment.
The "no action" alternatives S-4 and GW-3 provide the least
assurance of long-term effectiveness and permanence since all
contaminants will remain on-site with only minimal control (i.e.,
floating hydrocarbon removal).
Alternative GW-1 would provide a high degree of long-term
effectiveness and permanence by removal of groundwater
contaminants. Successful in-situ bioremediation, Alternative GW-
2, could also be very effective; however, it is not able to address
metals in groundwater and its ability to achieve low concentrations
is uncertain.
Reduction of Toxicitv. Mobilitv. or Volume of contaminants Throuah
Treatment: Alternatives'S-3 and GW-2 involving bioremediation and
S-l involving incineration offer the greatest potential for
reduction of contaminants through treatment. However, Alternative
GW-2 has a high degree of uncertainty as to its ultimate
effectiveness.
The "no action" alternatives S-4 and GW-3 rank very low with
respect to this criterion. However, the "no action" alternative
for groundwater (GW-3) would provide some reduction in contaminant
volume through continued floating hydrocarbon recovery.
Alternatives S-2 and S-3, on-site thermal treatment of soils and
on-site bioremediation and GW-1, air stripping of groundwater,
would greatly reduce volume of contaminants on-site but would be
transferring contaminants to the air. Air emissions would be
mitigated by carbon adsorption or use of an afterburner for thermal
treatment if necessary to meet air quality standards. Spent carbon
would either be landfilled in which case the mobility of the
contaminants would be greatly reduced, or regenerated
(incinerated), in which case the volume of contaminants would be
greatly reduced. An afterburner would destroy most organic
contaminants.
None of the soil alternatives are capable of reducing the volume
or toxicity of metals. However, Alternatives S-l, S-2 and S-3
would reduce the mobility of metals through stabilization, if
necessary.
16
-------
Short-Term Effectiveness: All of the active soil alternatives can
be completed in a relatively short period of time with off-site
incineration/disposal, Alternative S-l, taking the least time and
on-site bioremediation taking the most time. These three soil
alternatives all involve excavation of soils and wastes which would
create potential for worker exposure, dust, and volatization of
contaminants into the air. The off-site Alternative (S-l) would
have a significant short-term risk due to transportation.
Alternatives S-2 and S-3 would have potential for short-term air
emissions during treatment. However, such emissions would be
mitigated by engineered controls, if necessary to meet air quality
standards.
Groundwater Alternative GW-1 would likely prove more effective
during the short-term than Alternative GW-2 because pumping would
provide a positive control thus preventing contaminant movement.
since no immediate risks exist and groundwater contamination does
not appear to be expanding at present, any difference in those two
alternatives regarding short-term effectiveness in removing
groundwater contaminants is not significant. Alternative GW-1,
involving pumping and air stripping may, however pose short-term
risks due to discharge of contaminants to the air and surface
water. Those risks would be mitigated by carbon adsorption of air
emissions and/or additional water treatment, if necessary, to
prevent significant risks to human health or the environment.
The "no action" alternatives (S-4 and GW-3) accomplish little in
the short-term. On the other hand, no immediate risk has been
identified and the "no action" alternatives will not create any
short-term risks during implementation; therefore, short-term
effectiveness is high.
Implementability: The "no action" alternatives (S-4 and GW-3) are
obviously the easiest to implement. Of the remaining soil-related
alternatives, off-site treatment/disposal (Alternative S-l) would
be the easiest to implement, followed by one-site thermal treatment
(Alternative S-2). Alternative S-3 would be the most difficult to
implement since additional testing would be required and design
considerations would be most involved.
Of the two active groundwater related alternatives, Alternative
GW-1, would be the easiest to implement. In-situ bioremediation
of groundwater has many potential implementability problems.
Cost: Obviously the "no action" alternatives (S-4 and GW-3) have
by far the lowest costs. The off-site treatment disposal option
(S-l) is the highest cost soil-related alternative. Alternative
S-3 has a significantly lower cost than the on-site thermal
treatment option, Alternative S-2. None of the soil-related
alternatives have significant operation and maintenance costs.
17
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The initial costs of Alternative GW-l, involving pumping and air-
stripping, is estimated to be slightly higher than for in-situ
bioremediation of groundwater (Alternative GW-3): however, much
lower operating costs are expected for Alternative GW-l resulting
in significantly lower overall (present worth) costs.
state Acce'Otance: The Iowa Department of Natural Resources
authored the proposed Plan and recommends the preferred alternative
without comment.
Community Acce'Otance: Very little public comment was received.
Several comments were received at the public meeting, none of which
expressed dissatisfaction with the preferred alternative. A
Responsiveness Summary addressing all comment received at the
public meeting is attached.
2.8
Selected Remedy
The selected remedy is Alternative 5-3 involving on-site
bioremediation of soils coupled with Alternative GW-l involving
pumping and air stripping of groundwater.
The selected
activities:
remedy
will
include
the
following
ancillary
o Continued listing and restrictions associated with the state
Abandoned or Uncontrolled sites Registry until no further
threat remains.
o continued floating hydrocarbon removal until no appreciable
amounts can be recovered.
o Removal of the uncontaminated cover soil and temporary storage
of the material in a protected area.
o Removal of solid waste material, other than contaminated soil
(e.g., drums, paint cans, wooden pallets, paint solids,
general trash), from the disposal trenches and temporary
storage in a protected area.
o Ultimate disposal of the solid waste material in a municipal
landfall if the material is non-hazardous or can be made non-
hazardous through decontamination. Ultimate disposal in a
hazardous waste landfill or off-site incineration of this
material may be warranted if the material is hazardous and
cannot be made non-hazardous.
o Removal of free solvent liquids from the excavation and
temporary storage in tanks, and off-site recycling of the
solvent, if possible, or off-site incineration.
18
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o For "clean closure" soils must pass the EP Toxicity test for
leachable metals (40 CFR 261.24), the TCLP test for leachable
organics (40 CFR 268.41) and shall not contain more than 100
mg/kg of Total organic Hydrocarbons prior to final placement.
o An air monitoring program approved by
implemented during all site work.
o Dust control will be provided during excavation.
the DNR will be
Bioremediation of soils will involve a fully contained surface
impoundment system complying with minimum technology standards
using conventional soil management practices (e.g., nutrient
addition and soil aeration) to enhance microbial degradation and
volatilization of organic contaminants. The system will be
designed to contain and treat soil leachate and volatilized
contaminants. .
A system consists of a double lined treatment bed, a sand/gravel
layer to serve as a leachate collection system with perforated
drainage pipe and a sump, and groundwater monitoring. If volatile
contaminants must be contained, the entire treatment bed will be
covered by a modified plastic film greenhouse. An overhead spray
irrigation system will be installed to control moisture and used
as a means of distributing nutrients (see Fiqure 9).
The leachate will be recycled back to the treatment area via the
spray irrigation system. Leachate in excess of acceptable limits
will be treated on-site or collected for off-site treatment.
Vapors will be treated (i.e. carbon adsorption) and released. The
spent carbon would be regenerated if possible, or sent to an
approved landfill facility. Approximately one-acre of land will
be needed for treatment of 3000 cubic yards of soil.
.,
.''1
High concentrations of heavy metals may prohibit use of this
process. Additional soil sampling and testing and a treatability
study are necessary prior to implementation. If small quantities
of soils are identified as containing high levels of heavy metals
which are incompatible with bioremediation, these soils will be
isolated and treated on-site using a stabilization process (e.g.
lime, portland cement or bentonite). Treated soil will be
redeposited in the excavation and covered with clean soil.
If high concentrations of heavy metals pose excessive restrictions
on the use of bioremediation, thermal treatment of soils would be
implemented in its place: in which case, ancillary activities would
remain the same and the soil would then be treated using low
temperature thermal treatment to drive off the volatile organic
compounds. The organic compounds in the off-gas would be destroyed
using an afterburner if ARARs for air emissions cannot be met. The
mobile low temperature thermal treatment system developed by WESTON
is designed to handle 15,000 lb/hr of contaminated soil based on
19
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Contaminated Soil
Excavation
Soil
Screening
~ Oversized Moteriol
.. ~ecial Handling
. /
Solid Phase
Treatment
Soil Loyer
Sprinkler
System
Source: Evoca Corp.
(re,-ised)
SOLID PHASt BIODEGr~DAT~OK
FIGURE 9
..
19a
.'
.'
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20% soil moisture and 1% (10,000 ppm) VOCs. The system is
comprised of three trailers that are a total of 120 feet long and
8 feet wide. The total height of the trailers, with the equipment
assembled, is under 13.5 feet. As with bioremediation, thermal
treatment will not remove metals and residual soil will be
stabilized, if necessary, prior to redeposition.
Contaminated groundwater would be removed by pumping from one or
more recovery wells. A pumping test will be conducted during the
remedial design to determine aquifer characteristics. This
information will be used to design the pumping system: i.e., number
and location of wells, pumping rates, and gradient controls. The
well (or wells) would be located and sized to draw water from the
entire contaminant plume thereby preventing any off-site migration
of groundwater contaminants. The pumped water would be treated by
air stripping to remove greater than 95 percent of the volatile
organic contaminants. Carbon adsorption-would be used to remove
contaminants in the air discharged from an air stripper, if
necessary. Treated water from the air stripper would be discharged
to the adjacent stream. Activated carbon used for air stripping
off-gas and water polishing prior to discharge would be regenerated
or disposed of in an approved landfill facility. Pumping and
treatment will be continued until groundwater ARARs are met. A
groundwater monitoring program, approved by the DNR, will be
implemented and criteria for ceasing remedial action based on
monitoring results will be developed.
Air modeling will be done to ensure that air emissions pose no
acute or chronic health risks with risks from carcinogens less than
10'6 and 1/100 threshold limit value (TLV) for non-carcinogens. Air
emissions will be evaluated during pilot studies and an air
monitoring program acceptable to the DNR will be developed for'
normal operation.
Some changes may be made to the selected remedy as a result of the
remedial design and construction processes.
Estimated costs for the selected remedy ar~ shown in Tables 4 and
5.
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TABU 4
BSTIMATBD COST OF SOIL REMEDIATION
lirect Cost Items
l.
2.
)
.:~
3.
'!
,
4.
5.
6.
7.
8.
9.
10.
1l.
12.
13.
Removal of clean soil & staging
Excavation of solid waste, staging
and disposal
Free product removal, trans-
portation and incineration
Air monitoring
Excavation & staging of
contaminated soil
Sampling & analysis of staged
soil
Land & site development
Construction of staging areas &
physical facilities for bioremediation
(Thermal Treatment)
Biological Treatment including
leachate disposal)
(Thermal Treatment)
On-site stabilization
Backfill
Clay Cap
Revegetation
~.
)ndirect Cost Items
2.
Basis
$4/cy x 9,000 cy
$150/cy x 3,200 cy
$0.50/gal x 5,000 gal
$5/cy x 3,000 cy
$33/Cy x 3,000 cy
($265/cy x 3,000 cy)
$60/cy x 3,000 cy
$4.5/cy x 3,200 cy .
$15/cy x 6,450 cy
$1,250/ac x 2 ac
TOTAL DIRECT
Engineering, design and treatability study
Contingency
Cost*
$
36,000
480,000
2,500
2,000
15,000
20,000
10,000
99,000
(40,000)
100,000
(795,000)
180,000
14,400
96,750
2.500
$1,058,150
($1,694,150)
$150,000(100,000)
$160.000(250.000)
$310,000(350,000)
$1,368,150(2,045,000)
TOTAL INDIRECT
TOTAL CAPITAL COST
O&M Cost Items
$l,OOO/year for 30 years
*NOTE:
Discount Rate =
$1,385,000(2,060,000)
5.00%
TOTAL PRESENT WORTH COST
Cost for Thermal treatment same as bioremediation except as shown in
parentheses.
21
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TABLB 5
ESTXHATED COST OP GROUNDWATER REMEDXATXOH
Direct Cost Items
Cost
1.
Construction of recovery wells
$ 40,000
2.
Installation of pumps
Construction of air stripper
10,000
3.
110,000
40
Activated carbon disposal (air treatment)
Air monitoring
3,000
5.
2,000
6.
Monitoring well installation
s
20.000
TOTAL DIRECT
$ 185,000
Indirect Cost Items
1. Engineering and Design (incl.
treatability study) $ 80,000
2. Aquifer pump test 25,000
3. contingency 30.000
TOTAL INDIRECT $ 135,000
TOTAL CAPXTAL COST $ 320,000
O&M Cost Items
'.
1. Power, operation and maintenance $50,000/year for 3 years
2. Groundwater monitoring $ 1,200/year for 3 years
3. Lab analyses $ 2,400/year for 3 years
TOTAL PRESENT WORTH COST $ 466,000
Discount Rate = 5.00%
22
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The combination of Alternative S-3 for soils and GW-1 for
groundwater, would provide a substantial risk reduction through
treatment of contaminated soils and removal and air stripping of
contaminated groundwater. The selected remedy ranks' high with
respect to the nine evaluation criteria except for implementability
of the soil remediation. If implementability of on-site
bioremediation of soils proves impractical, then Alternative S-2
(on-site thermal treatment) will be utilized as the method for
soils remediation. Alternatives S-2 and 5-3 are similar with
regard to the evaluation criteria except for costs and
implementability.
Since no immediate risk has been identified, the risks (i.e., time
and development costs) of attempting to implement Alternative S-
3 are justified. If Alternative 5-3 proves impractical,
Alternative S-2 will provide a well-proven technology as a
substitute.
2.9
StatutorY Determinations
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, section 121 of CERCIA establishes several other statutory
requirements and preferences. These specify that when complete,
the selected remedial action for this site must comply with
applicable or relevant and appropriate environmental standards
established under Federal and State environmental laws unless a
statutory waiver is justified. The selected remedy also must be
cost-effective and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. Finally, the statute includes a
preference for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of hazardous
wastes as their principal element. The following sections discuss
how the selected remedy meets these statutory requirements.
Protection of Human Health and the Environment:
The selected remedy protects human health and the environment by
removing, destroying, and/or stabilizing all contaminants on the
site resulting in residual levels below health-based standards.
This will be accomplished through biodegradation of volatile
organics in soil: stabilization of metals-contaminated soil, if
necessary: covering the stabilized soil: and pumping and air
stripping of groundwater-contaminated volatile organics: and carbon
adsorption of the air stripper off-gas, if necessary.
The removal, treatment, and stabilization of contaminated soils
will eliminate the source of groundwater contaminants. Removal of
contaminated groundwater will result in residual contaminant levels
below health-based standards. currently there is no exposure to
23
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groundwater contaminants above health-based standards. However,
the contaminant plume contains carcinogens at a level which would
present a 1.7x10.4 cancer risk if consumed on a regular basis and
non-carcinogens above lifetime health advisory levels. Remedial
actions will result in residual groundwater contaminants posing a
cancer rate of 10.6 or less (within acceptable exposure, level of
between 10.4 and 10.6) and non-carcinogens below lifetime health
advisory levels. There are no short-term threats or cross-media
impacts that cannot be readily controlled.
ComDliance with
Reauirements:
ADDlicable
or
Relevant
and
ADDroDriate
The selected remedy of excavation, on-site bioremediation,
stabilization, groundwater extraction and air-stripping will comply
with all applicable or relevant and appropriate chemical- and
action-specific requirements (ARARs). No location-specific ARARs
have been identified. Tables 6 through 8 summarize all ARARs.
24
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...". .
TABLE ,
ARARs FOR SOIL REMEDIATION
ARAR
COMPLIANCE
ACTION SPECIFIC
Excavation from uncontrolled waste disposal
trenches and subsequent placement of soil
after treatment (40 CFR Parts 264 & 268)
Compliance
Waste pile storage of hazardous materials
(not soil) to be decontaminated and non-
hazardous materials (40 CFR Part 264,
Subpart L)
Compliance
Tank storage of liquid free product
recovered from waste disposal area
(40 CFR Part 264, Subpart J)
DOT Hazardous Material Regulations
(49 CFR, Subpart C)
Compliance
IAC 567
Off-site transport to comply
with applicable Sections: 171,
172, 173, 177 and 178
Compliance with Chapters 140 &
141
Bioremediation treatment of soil
(40 CFR 264, Subpart M)
Compliance with applicable
sections
Treatment of soil by stabilization
CFR 264, Subpart M) if metal
concentrations are too high
Compliance with applicable (40
sections
Thermal treatment of soil
(40 CFR 265, Subpart P) if
bioremediation cannot be implemented
Compliance with applicable
sections
OSHA 29 CFR 1910 (Health and Safety
considerations for workers at site
during remediation)
Compliance
.
CHEMICAL SPECIFIC (see Table 8)
Placement of treated and/or excavated
soils
Acceptable EP Toxicity and TCLP
and Total Organic Hydrocarbons
below 100 mg/kg achieved
Compliance with applicable
sections of State and Federal
Clean Air Act and 10'6 risk for
TLV carcinogens and 1/100 TLV
for non-carcinogens
Air emissions from excavating and treat-
ment"(C1ean Air Act) (Risk from exposure
to carcinogens less than 10.6 and 1/100
for non-carcinogens)
25
.;.
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TABLE 7
ARABS POR GROUNDWATER REMEDIATION
ARARS
CHEMICAL SPECIFIC (see Table 8)
IGAL for all contaminants
SDWA MCLs for arsenic, cadmium,
chromium, lead, and benzene
SDWA proposed MCLs an MCLGs
ethyl-benzene, toluene, xylenes
Drinking water health advisory
standard for MEK
Treatment of groundwater by air
stripping (Clean Air Act) (Risk
from exposure to carcinogens
less than 10-6, and 1/100 TLV
for non-carcinogens)
Discharge of treated groundwater
to receiving stream (Clean water
Act: substantive requirements
of NPDES program including
existing and proposed Iowa Water
Quality Standards (Table 8)
ACTION SPECIFIC
OSHA 29 CFR 1910 (Health and
safety considerations for
workers at site during
remediation)
COMPLIANCE
Remediation of groundwater
to IGAL can be achieved
Remediation of groundwater to
MCLs can be achieved
Remediation of groundwater to
MCLs/MCLGs can be achieved
Remediation of groundwater to
MEK standard can be achieved
Compliance with applicable
sections of state and Federal
Clean Air Act 10-6 risk for
carcinogens, and 1/100 TLV
for non-carcinogens
Compliance with applicable
sections of State and Federal
Clean Water Act
Compliance
26
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.ategory
Air Emmissions
Groundwater
Surface Water
Discharge
50ils Placement
TABLE 8
SUMMARY OP CHEMICAL SPECIPIC ARARs
Compound
Carcinogens (Benzene)
Non-Carcinogens
Arsenic
Cadmium
Chromium
Lead
Benzene
Ethylbenzene
'0
Methyl Ethyl Ketone
Toluene
Xylenes
1,2-Dichloropropane
Methvlene Chloride
Arsenic
Cadmium
Chromium
Lead
Benzene
Ethyl Benzene
Toluene
Methyl Ethyl Ketone
Xvlenes
Metals
Organics
Maximum Limiting
Concentration authoritv
10'0 cancer riskCAA
O.OlTLV CAA
0.05 mg/l I GAL
0.005 mg/l Proposed MCL/MCLG
( SDWA)
IGAL & proposed
MCL/MCLG (5DWA)
Proposed MCL (SDWA)
I GAL
IGAL & Proposed
MCL/MCLG (SDWA)
IGAL
IGAL & Proposed
MCL/MCLG (5DWA)
IGAL & Proposed
MCL/MCLG (SDWA)
I GAL
IGAL
Proposed Chronic IWQC
Proposed Chronic IWQC
Proposed Chronic IWQC
Proposed Chronic IWQC
CWA (freshwater acute)
CWA (freshwater acute
Proposed acute IWQC
CWA
CWA
40 CFR 261. 24
0.10 mg/l
0.005 mg/l
0.001 mg/l
0.7 mg/l
0.17 mg/l
2.0 mg/l
10.0 mg/l
0.0006 mg/l
0.050 mall
0.2 mg/l
0.015 mg/l
0.04 mg/l
0.03 mg/l
5.3 mg/l*
32 mg/l*
2.5 mg/l*
*
*
Acceptable
EP Toxicity
Acceptable
TCLP Test
100 mg/kg Total
Organic
Hvdrocarbons
KEY:
CAA - Clean Air Act/Iowa Proposed Air Toxic
I GAL Iowa Groundwater Action Levels
SDWA - Safe Drinking Water Act
IWQC - Iowa Water Quality criteria
CWA - Clean Water Act
MCL - Maximum Contaminant Level
MCLG - Maximum Contaminant Level Goal
TLV - Threshold Limit Values
Rules
40 CFR 268.41
*Treatment-based standard (i.e., 95% minimum removal likely to control)
27
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Cost Effectiveness:
The selected remedy is cost-effective because it is the least
expensive active alterative and yet provides a high degree of
overall protection. It also provides certainty of effectiveness
in the long-term due to a significant reduction in the volume of
volatile organic contaminants through treatment of soils and air-
stripping of groundwater, and a significant reduction in mobility
of metals in soil through stabilization, if needed. The more
expensive alternatives provide no significant advantages.
Utilization of Permanent Solutions and Alternative Treatment
Technoloaies (or Resource Recovery Technologies) to the Maximum
Extent Practicable:
The Iow~ DNR and EPA have determined that the selected remedy
represents the maximum extent to which permanent solutions and
treatment technologies can be practically utilized in a cost-
effective manner for the final response actions at the VPW site.
Of those alternatives that are protective of human health and the
environment and comply with ARARs, the State and EPA have
determined that this selected remedy provides the best balance of
tradeoffs in terms of long-term effectiveness and permanence;
reduction in toxicity, mObility, or volume achieved through
treatment; short-term effectiveness; implementability; cost;
consideration of the statutory preference for treatment as a
principal element; and State and community acceptance. All of the
active soil alternatives ranked similarly with respect to these
primary balancing criteria except for cost and implementability.
Cost is the deciding factor for choosing bioremediation of soils
as the selected alternative. The selected soil alternative does
rank lower with respect to implementability. If implementability
on soil bioremediation proves impractical, the thermal treatment
of soil will be implemented in its place. The thermal treatment
alternative ranks high in implementability and ranks similarly to
soil bioremediation with respect to the other criteria except cost.
The selected groundwater remedy ranks nighest with respect to all
criteria for the active alternatives, including cost. The selected
soil and groundwater remedies are the same as presented in the
Proposed Plan which met no objection from the public.
Bioremediation of soils is an alternative treatment technology.
Since bioremediation is not as proven as other technologies, its
implementability is somewhat in question. If treatability studies
and additional waste characterization indicate that bioremediation
of soils is not effective, the more proven thermal treatment
technology will be implemented in its place.
In-situ bioremediation of groundwater is an alterative treatment
technology which was not selected over the conventional pump and
air-strip technology because of its uncertainty in effectiveness
and implementability in addition to its higher cost.
28
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Preference for Treatment as a PrinciDal Element:
By treating soils contaminated with volatile organics with
bioremediation and stabilizing any residual metal-contaminated
soil, the selected remedy addresses one of the principal threats
posed by the site through the use of a treatment technoloqy. The
threat of groundwater contamination will be treated by removal of
the source through treatment of soils and by withdrawal and
treatment of contaminated groundwater. Therefore, the statutory
preference for remedies that employ treatment as a principal
element is satisfied.
2.10
Documentation of Sianificant Changes
The Proposed Plan for the VPW site was released for public comment
in ~ugust 1989. The Proposed Plan identified Alternative S-3,
excavation and on-site bioremediation of soils, and Alternative GW-
1, pumping and air stripping of groundwater, as the preferred
alternatives. The Iowa DNR reviewed all comments received during
the public comment period. Upon review of these comments, it was
determined that no significant changes to the remedy, as it was
originally identified in the Proposed Plan, were necessary.
29
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"
..'
.,
~.. .
RESPONSIVENESS SUMHARY I'OR TJIB RECORD 01' DBCISIOH
The Remedial Investigation and Feasibility study Reports and the
proposed Plan for the Vogel site were released to the public for
comment on August 10, 1989. These two documents were made
available to the public in both the administrative record and an
information repository maintained at DNR Records Center, 5th Floor,
Wallace Building, 900 East Grand, Des Moines, Iowa, and in the
Orange City Public Library.
The notice of availability for these two documents was published
in the sioux City Journal on August 10, 1989. A public comment
period on the documents was held from August 10, 1989 to August
31, 1989. In addition, after publication of notice a public
meeting was held on August 21, 1989, at the Northwestern state
Bank, Orange City, Iowa. At this meeting, representatives from
DNR, EPA, and Vogel Paint and Wax Company answered questions about
problems at the site and the remedial alternatives under
consideration.
No written comments were received. Several oral comments were
received at the public meeting as discussed below.
1.
Comment: Has the installation of any new well be denied
because of groundwater contamination from the Vogel site?
Response:
No.
2.
Is Superfund money going to be used for this
Comment:
cleanup?
Response: Under a consent order with DNR, Vogel Paint and
Wax Company has paid for the costs to date and we anticipate
they will also fund the cleanup work. If for any reason the
company is not able to, or refuses to continue to do so,
Superfund monies would be available to implement the proposed
cleanup work.
3.
Comment: What quantity of groundwater will be pumped and
treated? Will this cause lowering of the groundwater thereby
contaminating more soil and increasing the volume of soil to
be treated: as related to floating hydrocarbons, in
,particular?
ReSDonse: Floating hydrocarbons have been significantly
decreased since removal of floating hydrocarbons was begun.
In fact, a significant floating hydrocarbon layer was not
detected during the latest sampling in JUly. In addition,
the floating hydrocarbon layer has been detected in a sand
and gravel formation which is confined above by a clay layer.
This sand and gravel formation is under artesian pressure and
as such pumping will reduce pressure without actually
30
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,~
<
. ~
-.\
..
..;
,:
dewatering the aquifer to a point, and it is not expected that
this formation will be dewatered. Therefore, the expressed
concern should not be a significant problem. In the remedial
design an aquifer pumping test will be conducted for use in
determining the size and location of recovery wells.
4.
Comment: What is the plan for disposal of drums, pallets,
and things like this?
ReSDonse: The intention is to make a basic classification of
hazardous and non-hazardous material. Non-hazardous material
will be taken to a licensed sanitary landfill. Hazardous
material will be taken to a landfill which is licensed for
taking that type of hazardous waste.
5.
Comment: Will any kind of special trucks or hauling equipment
be necessary to transport this hazardous waste on public
highways?
ReSDonse: Yes, the hazardous waste would be regulated under
the Resource Conservation and Recovery Act which includes
regulations for the transportation, storage, treatment and
disposal of hazardous waste. Also, Department of
Transportation and Department of Labor (OSHA) regulations must
be met. Some liquid waste may be taken to the Vogel plant for
recycling.
6.
Comment: Would the spent carbon from carbon adsorption used
in the air stripping be treated as a hazardous waste also?
ResDonse:
Yes.
7.
What is the time frame for the proposed action?
Comment:
ResDonse: The intent is to begin remediation in the
Spring of 1990, with completion in 3-5 years for
groundwater.
8.
Have all the alternatives been proven to work?
Comment:
9.
ResDonse: Yes, all have been tried and proven. The
bioremediation of soil and groundwater are less proven than
other alternatives. The type of chemicals at the site are
conducive for soil bioremediation. However, if it does not
work, the more proven thermal treatment technology will be
implemented. The groundwater pump and air stripping
technology is very well proven.
Comment: If the bioremediation of soil doesn't work how long
will it take to implement another technology?
~
31
.f-
-------
. -
----.,----,
Hazdrdous Vv
Informatiof'l r.
I_..'~ -' ~
us EPA r~egio
Philade\phla,
"ReSDonse: It is possible that cleanup could still begin ~s~.~~,v
early as next spring. The overall schedule would not be
significantly modified, if another technology for soil
treatment is implemented.
. . to,
10.
Comment: When the proposed remedial efforts are completed
will there be continued monitoring and further cleanup, if
necessary?
ResDonse: There are two levels of monitoring. At a minimum,
groundwater samples will be collected and analyzed and then
that data evaluated every five years. Also, more frequent
monitoring may be required on a site-specific basis.
Additional remedial "action will be taken, if necessary.
SUMMARY
No comments were received which expressed dissatisfaction with the
proposed alternatives. The lack of comments in general implies
acceptance by the community. Therefore, no changes to the Proposed
Plan have been made based on community acceptance.
"
,'J
- .~
,
32
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