United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R07-90/037
September 1990
Superfund
Record of Decision:
Midwest Manufacturing/North Farm, IA
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50272-101
REPORT DOCUMENTATION 11. REPORT NO. 12-
PAGE EPA/ROD/R07-90/037
So AeclPlnr8 Ac--... Mo.
4. TIUe Ind SubdII8
SUPERFUND RECORD OF DECISION
Midwest Manufacturing/North Farm, IA
First Remedial Action - Final
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09/27/90
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U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
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14.
15. Supplementary NotM
16. Abetr8c1 (Umll: 2CXI WonM)
The 8-acre Midwest Manufacturing/North Farm site is located on a manufacturing site
owned and operated by Smith-Jones, Inc. in Kellog, Iowa. Land use in the area is
primarily industrial. From 1973 to 1981, Smith-Jones engaged in electroplating and
painting operations of manufactured products, which involved the use of TCE to clean
the product before it was coated with the metal. In 1977, the State required treatment
of the wastewaters to precipitate metals. The solid residuals were stored in an
above-ground tank, then transferred periodically to an unlined disposal cell onsite.
Site inspections in the early 1980s, by EPA revealed elevated heavy metal
concentrations in the 170 cubic yard waste disposal cell, the surrounding soil, as well
as a 7,200 cubic foot waste metals pile and a borrow pit area. Ground water sampling
revealed contamination of the alluvial aquifer underlying the site. This ROD addresses
both source control and ground water remediation at the site. The primary contaminants
of concern affecting the soil/waste and ground water are VOCs, including PCE, TCE,
toluene, and xylenes; and metals, including chromium, and lead.
The selected remedial action for this site includes installing a low permeability cap
over the waste disposal cell in accordance with RCRA landfill closure requirements;
(See Attached 'Paqe)
17. DocumentAn8Jy8la L DMatpt0r8
Record of Decisxo~ - Midwest Manufacturing/North Farm, IA
First Remedial Action - Final
Contaminated Media: soil/waste, gw
Key Contaminants: VOCs (PCE, TCE, toluene, xylenes), metals (chromium, lead)
b. Idenllfl8r8lOp8n-Ended T-
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20. Seauity Clue (Thl8 Pege)
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s../n.trucUon. on R.WfM
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(Formerty NTlS-35)
Department 01 Commerce
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EPA/ROD/R07-90/037
Midwest Manufacturing/North Farm, IA
First Remedial Action - Final
Abstract (continued)
treating ground water using air stripping, and possible treatment of vapor/air
mixture using carbon adsorption, and filtering water to remove inorganics, if
needed; discharging the treated water onsite to the Skunk River or offsite to a
publicly owned treatment works (POTW); implementing institutional controls including
deed and ground water use restrictions; and ground water monitoring for 30 years.
The estimated capital cost for this remedial action is $288,419, which includes a
total O&M cost of $200,425 for 25 to 30 years.
PERFORMANCE STANDARDS OR GOALS: Ground water contamination at the site will be
reduced to meet Iowa Anti-Degradation Requirements.
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DECLARATION FOR THE RECORD OF DECISION FOR THE
MIDWEST MANUFACTURING/NORTH FARM SITE
MIDWEST OPERABLE UNIT
KELLOGG, IOWA
SITE NAME AND LOCATION
Midwest Manufacturing/North Farm Superfund Site,
subsite; Kellogg, Iowa.
Midwest
STATEMENT OF BASIS AND PURPoSE
This Decision Document describes the selected remedial
action for the Midwest subsite of the Midwest Manufacturing/North
Farm Superfund Site (hereafter referred to as "the Site"). This
Decision Document has been developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act, as amended by the Superfund Amendments and Reauthorization
Act (CERCLA), 42 U.S.C. S 9601 et seq., and to the extent prac-
ticable, the National Contingency Plan.
The selection of the preferred alternative is based upon the
contents of the Administrative Record file for the Midwest
Operable Unit. The attached index identifies the ite~s that com-
prise the Administrative Record. Also attached is a letter of
concurrence from the State of Iowa for the preferred remedial
alternative. A copy of this letter has been included in the
Administrative Record file for this site.
SCOPE AND ROLE OF RESPONSE ACTION
The scope of this response action is to address the
principal threats at the Midwest subsite of the Midwest Manufac-
turing/North Farm Superfund Site. The principal threats posed by
the North Farm subsite were addressed in a Record of Decision
signed in September 1988.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from
this site, if not addressed by implementing the response action
selected in the Record of Decision (ROD), may present a current
or potential threat to public health, welfare, or the environ-
ment.
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.
DESCRIPTION OF THE REMEDY
The selected alternative provides for ground water treatment
and capping of the waste disposal cell in accordance with the
RCRA landfill closure and post-closure requirements as described
in 40 C.F.R. i 264 Subparts G and N. The design life of the cap
is estimated to be 30 years. Post-closure care requirements would
include maintenance of the final cover and the maintenance of a
ground water monitoring system. Ground water monitoring shall be
in ,accordance with the RCRA ground water monitoring requirements,
40 C.F.R. i 264, Subpart F.
An air stripping column would be constructed at the Site to
treat the volatile organic compounds (VOCs) in the extracted
ground water. The air and VOC mixture leaving the air stripper
may be treated by a vapor phase carbon adsorption unit, if
necessary to meet ARARs. The clean air would be emitted into the
atmosphere. In addition, inorganic contaminants in the ground
watE!r may be removed by a filtration unit, if one is necessary to
meet: ARARs. The treated water would be discharged either into
the North Skunk River or into the POTW. All air and surface
water discharges would comply with both state and federal standards.
Ground water monitoring would be conducted for at least 30
years. In addition, monitoring of the ground water at the Site
would continue for at least three years after the completion of
the remediation to ensure that the goals of the remedial action
have been met. Deed restrictions would also be placed on the use
of ground water for drinking water purposes until the remediation
goals are achieved.
DEClARATION
consistent with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980, as amended, I have deter-
mined that the selected alternative described above, is cost-
effec:tive, protective of human health and the environment and
utilizes permanent solutions and alternate treatment technologies
to the maximum extent practicable. The remedy selection procedure
of the selected remedial alternative complies with the provisions
of Cl:RCLA and the National Contingency Plan, 40 C.F.R. I 300.
//1~
r
/
ay
al Administrator
SEP 87190
Date
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DECISION SUMMARY FOR THE
MIDWEST MANUFACTURING/NORTH FARM
MIDWEST OPERABLE UNIT
KELLOGG, IOWA
SITE
I.
SITE NAME, LOCATION, AND DESCRIPTION
The Midwest subsite of the Midwest Manufacturing/North Farm
Superfund site is located on a manufacturing site owned and
operated by Smith Jones, Inc., Midwest Division. The Midwest
subsite (hereafter referred to as "the site") is located at 101
High Street in the city of Kellogg, Iowa, and occupies eight
acres within the North Skunk River floodplain. Kellogg,
population 700, is located in Jasper County, which is
approximately 42 miles east of Des Moines (See figure #1).
A six foot chain link fence surrounds the active portion of
the plant property and includes the waste disposal cell, waste
metals pile, the borrow pit area and the plating and painting
drain lines. The Site is bordered to the east by Holmdahl City
Park, to the west by a county road and agricultural property and
to the south by the North Skunk River. North of the Site is the
Co-Op Farm Products operation consisting of storage elevators and
a grain store and tracks from the Chicago-Rock Island and Pacific
Railroads. The vegetation surrounding the site is primarily mowed
grass with deciduous trees. No federal or state natural
resources are within close proximity of the Site.
Ground water flow and surface water drainage across the Site
is to the south towards the North Skunk River. The river flows
from the northwest to the southeast and eventually discharges
into the Mississippi River. The City of Kellogg obtains its
drinking water from three municipal wells. City well numbers 1
and 2 are both completed in the shallow alluvial aquifer and city
well #3 is completed in the deep sandstone aquifer. All three of
these wells are located upgradient of the site at distances of
1000 feet northeast, 1300 feet northwest and 3/4 of a mile east
for city well numbers 1, 2, and 3 respectively. There are no
drinking water wells located on the Site.
II.
LEGAL SITE DESCRIPTION
The legal description of the Site is given below:
Outlot Two and Lots Five, Six, Seven, Eight and Nine in
Block Five, including the alley between Lots Six and Seven, in
Blair & Adair's Addition to Kellogg, Jasper County, Iowa, as
appears in Plat Book B at page 540 in the office of the Recorder
of said County.
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Lots Two, Three, Four, Five, Six and the South Thirty-four
Feet of Lot Seven in Block Six, and all of the alleys lying
within said Block Six, EXCEPT that part of the alley lying be-
tween Lots One and Eight in said Block Six; Lots One, Two, Three,
Four, Five, Six, Seven and Eight in Block Seven, and all of the
alleys lying within said Block Seven; Outlots Five and Six; Lot
Eleven, EXCEPT the north eight feet thereof (sometimes described
as all of High Street the North Sixty-eight feet thereof) and Lot
Thirteen in Block Five, all in Blair and Adair's Addition to
Kellogg, Jasper County, Iowa, as shown by plat recorded in Plat
Book B, page 541, in the office of the Recorder of said County.
The Twelve and one-half foot alley running North and South
between Blocks Five and six, Blair and Adair's Addition to Kel-
logg, Iowa, and Lot Twelve in Block Five, Blair and Adair's
Addition to Kellogg, Jasper County, Iowa, as appears in Plat Book
B, page 541 in the office of the Recorder of said county.
All that part of Lots One and Two in the Subdivision of the
Southeast Quarter of the Northeast Quarter of Section Twenty-six,
Township Eighty North, Range Eighteen West of the Fifth P.M.,
Jasper county, Iowa, as appears in Plat Book B at page 542 in the
office of the Recorder of said County, EXCEPT that part conveyed
to the City of Kellogg, Iowa, by deed in Book 720, page 472, in
the office of the Recorder of said County.
All that part of the Southwest Quarter of the northeast
Quarter of section Twenty-six, Township Eighty North, Range
Eighteen West of the Fifth P.M.,.Jasper County, Iowa, lying North
and East of Skunk River Ditch as now located.
The section of road commencing in the center of the North-
east Quarter of section Twenty-six, Township eighty North, Range
18.
West of the Fifth P.M., Jasper County, Iowa, running thence
West Seven hundred and fifty feet (the South half of said road
lying outside the corporate limits of the Town of Kellogg, Iowa).
III.
SITE HISTORY
Smith Jones, Inc. engaged in electroplating and painting
operations of manufactured products from 1973 until June 1981.
The electroplating process involved the use of trichloroethylene
(TCE) to clean the product before it was coated with a metal.
Cadmium was used as the metal coating prior to 1979, nickel was
used until 1980, and from 1980-1981 zinc was used. Prior to 1973,
wastewaters containing TCE, heavy metals, and paint residue
generated from onsite painting operations were disposed directly
into the North Skunk River.
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Smith Jones entered into an Amended Consent Order with the
State of Iowa and in 1977 began to treat the wastewaters
resulting from its electroplating and painting operations. Metals
were precipitated from the wastewater and the resulting solids
were initially stored inside an above-ground tank until it became
full. Then its contents were transferred to an unlined disposal
cell located between the Plant and the North Skunk River.
From 1981 to 1982 several onsite inspections of the plant
Site were conducted by Ecology and Environment (E , E) on behalf
of the EPA. Samples were collected from the waste disposal cell,
from the soil located south of the disposal cell, from the
sediments within the North Skunk River, and from the city
municipal wells. A background soil sample was taken south of the
disposal cell and a background sediment sample was taken from the
river. The metal concentration levels in both the soil and waste
disposal cell samples were higher than those in the background
samples. The data also showed that the contaminants within the
disposal cell had no impact on the river or the city water
system.
This site was listed on the Superfund National Priorities
List in May 1986.
IV.
SCOPE AND ROLE OF RESPONSE ACTION
The scope of this response action is to address the.
principal threats at the Midwest subsite of the Midwest Manufac-
turing/North Farm Superfund Site. The principal threats posed by
the North Farm subsite were addressed in a Record of Decision
signed in September 1988.
V.
ENFORCEMENT ACTIVITIES
The Special Notice procedure of CERCLA section 122(e) (1) was
followed regarding the Remedial Investigation/Feasibility Study
(RI/FS) phase of this project. Smith Jones, Inc. is the only
responsible party for this Site, and it did not make a good faith
offer to undertake or finance the RI/FS.
VI.
COMMUNITY RELATIONS FOR THE ROD
On August 22, 1990, EPA announced the availability of the
Proposed Plan for the Midwest Subsite of the Midwest
Manufacturing/North Farm site. Notice of the availability of the
Proposed Plan and the administrative record file upon which EPA
intended to base its remedy selection decision was published in
the Newton DailY News. This notice also requested the public's
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comments on the proposed plan and indicated the period during
which public comments received by EPA would be considered in the
de:cision-making process. A fact sheet in which the various
remedial alternatives were described, including the
identification of a preferred alternative, was mailed to persons
who had previously expressed an interest in this site.
A public meeting was held on September 12, 1990 in Kellogg,
Iowa to receive comments from the public regarding all of the
remediation alternatives summarized in the Proposed Plan document
and detailed in the FS report. A responsiveness summary to the
pUblic's comments received during the public comment period,
including the pUblic meeting, is attached to this Record of
Decision. The Administrative Record File for this Site has been
available for public review at the Newton Public Library in
Newton, Iowa; the Kellogg Public Library in Kellogg, Iowa; and
the New Brotherhood Building in Kansas City, Kansas. All
community relations activities have been in conformance with the
requirements of section 117 of CERCLA and the National
Contingency Plan, 40 C.F.R. S 300.
VII.
SITE CHARACTERISTICS
Field activities were conducted during October' 1989 and
April-May, 1990. The purpose of these field activities was
to identify the types and quantities of contaminants that may
have originated from four potential contaminant source areas and
to identify the potential pathways for contaminant migration.
These source areas are identified in Figure #2.
POTENTIAL CONTAMINANT SOURCE AREAS
1. WASTE DISPOSAL CELL
The waste disposal cell was investigated by collecting three
samples from each of five different locations within the cell.
An estimated 170 cubic yards of waste material is in the disposal
cell. All of the samples were analyzed for volatile organic
compounds, semi-volatile organic ,~ompounds, metals, and cyanide.
Results of these analyses are presented in table 11. Samples
were analyzed using two tests that measure a waste's potential to
leach contaminants (the Toxic Characteristics Leaching Procedure
(TCLP) and Extraction Procedure Toxicity Test (EP TOX».
The contaminant concentrations exhibited by the samples
collected around the disposal cell did not differ significantly
fro:m the contaminant concentrations measured in the background
samples. Wastes within the disposal cell are classified as
lis'ted RCRA hazardous wastes, as is described in the ARARs
section herein. However, the waste material within the disposal
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cell did fail both the TCLP and EP TOX tests for cadmium. This
indicates that the waste material has the potential to leach
cadmium into the ground water.
2. WASTE METALS PILE
Three soil samples were taken from this area southeast of
the plant facility and were analyzed for volatile organic
compounds, semi-volatile organic compounds, metals, and cyanide.
Results of these analyses are presented in table #2. Copper,
lead, and zinc were found to have concentration levels exceeding
the background soil data. A magnetometer and an electromagnetic
conductivity meter qualitatively defined the boundary of the
waste metals pile to be 40 feet wide by 90 feet long, and volume
of the waste materials is approximately 7200 cubic feet.
3. BORROW PIT AREA
Five sediment samples and three surface water samples were
collected in this marshy area immediately west of the plant
facility. These, too, were analyzed for volatile organic
compounds, semi-volatile organic compounds, metals, and cyanide.
Sample location spots are shown in figure #2. Results of these
analyses are presented in tables #3A and #3B.
The borrow pit sediment samples were elevated in
concentrations of cadmium, chromium, iron, nickel, barium, and
lead when compared to the background data. Elevated concentration
levels of trichloroethylene (TCE), toluene, ethyl benzene, and
total xylene were also detected.
The borrow pit water samples detected elevated concentration
levels of cyanide, TCE, and 1,2 dichloroethylene. None of the
detected concentration levels of metals (either dissolved or
total) exceeded the primary Maximum contaminant Level (MCL) as
established under the Safe Drinking Water Act (SDWA). (This
ground water quality criteria has been established to protect
public health to the extent feasible and taking cost into
consideration, using technology, treatment techniques, and other
means. )
4. PAINTING AND PLATING DRAIN LINES
An organic vapor analyzer was used to scan the drain lines
located at the south side of the plant, as is shown on figure #2.
The analysis took place within the manholes of each drain line.
The scan revealed the presence of organic vapors at concentration
levels of 0 to 3 parts per million (PPM) in the plating area and
160-180 PPM in the painting area drains lines.
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SUBSURFACE PATHWAYS OF MIGRATION
Twenty ground water monitoring wells were installed at the
location shown on figure #2. sixteen of the wells were
constructed as well nests: each nest consists of one deep
monitoring well and one shallow monitoring well. The deep wells
were screened in the lower portion of the alluvial aquifer at
depths of 25 to 30 feet. The shallow wells were screened across
the shallow alluvial water table at 9 to 19 feet. (One well was
screened in the lower sandstone aquifer Cat 55 to 65 feet), but
no contaminants were identified in the samples collected from
that well.)
All samples collected from these monitoring wells were
analyzed for volatile organic compounds, semi-volatile organic
compounds, total and dissolved metals, and cyanide. Table #4
presents the results of these analyses. The only contaminant
concentration levels for total metals that exceeded the MCLs were
for barium, cadmium, arsenic, chromium, and lead. The other
contaminants identified in the ground water were as follows: 1,2
dichloroethylene, TCE, vinyl chloride, 2-butanone, 1,1,1-
trichloroethane, carbon tetrachloride, toluene, ethyl benzene,
and total xylenes.
Water samples were also collected for analysis from City
well numbers 1, 2, and 3. These samples were also analyzed for
volatile organic compounds, semi-volatile organic compounds,
total and dissolved metals, and cyanide. No contaminants were
found at concentrations exceeding health-based action levels.
Cit}' well numbers 1 and 2 are both completed in the shallow
alluvial aquifer and are located upgradient of the Site at
distances of 1000 feet northeast and 1300 feet northwest
respectively. City well #3 is completed in the deep sandstone
aquifer and is located upgradient of the Site at a distance of
3/4 of a mile.
VIII. SITE RISKS
As part of the remedial investigation process, a risk as-
sessment was conducted. The risk assessment analyzes the current
and potential human health and environmental risks posed by the
Site in the absence of any remedial action and considers both
current and future use scenarios. The risk assessment provides
the basis for determining if a clean up action is necessary. This
section summarizes the findings concerning the quantified risks.
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1. CONTAMINANTS OF CONCERN
Chemicals were eliminated from the risk assessment if they
were not detected in environmental samples, were detected infre-
quently, were common laboratory contaminants or if they were
chemicals that were essential nutrients (and therefore relatively
non-toxic). After exclusion of such chemicals, twenty-six chemi-
cals were selected as contaminants of potential concern. These
chemicals are presented in table #5.
2. EXPOSURE ASSESSMENT
An exposure assessment analyzes two factors that affect the
quantification of risks: potentially exposed populations and
exposure pathways. In general, Superfund Exposure Assessments
consider both current and future exposure scenarios. .
A. POTENTIALLY EXPOSED POPULATION
Current human populations that potentially may be exposed on
Site are occupational workers of the Smith Jones plant and Site
trespassers. There are no off-Site populations that would poten-
tially be exposed to the contaminants of concern.
Currently, the Smith Jones property is zoned for industrial
use and a county ordinance prohibits residential construction on
a floodplain. Therefore, it was assumed that any future develop-
ment would be industrial in nature and future onsite populations
would be engaged in similar occupational activities as current
ones. Future occupational workers could be exposed via contami-
nated drinking water if a well was drilled onsite. Future offsite
residential populations are assumed to be the same as current
populations. These populations could be exposed to contaminated
drinking water if a drinking water well were installed into a
plume that originated from the Site.
B. EXPOSURE PATHWAYS
Ten exposure pathways were selected for further quantitative
evaluation from a list of 27 exposure pathways presented in table
3-1 of the Risk Assessment report, because these ten are more
likely to present the highest potential for adverse health
effects resulting from Site exposures. These pathways are
described below.
'The current potential exposure routes that were evaluated in
the Risk Assessment report are as follows:
1) Ingestion of contaminated soils originating from the waste
disposal cell, the waste metals pile, the borrow pit area and
from the soils located south of the waste disposal celli
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2) Dermal contact with the contaminated soils originating from
the waste disposal cell, the waste metals pile, the borrow pit
area and from the soils located south of the waste disposal cell;
and
3) Inhalation of volatiles and contaminated particulates from
soils originating from the waste disposal cell, the waste metals
pile, the borrow pit area and from the soils located south of the
wa!;te disposal cell.
The future potential exposure routes that were evaluated in
the Risk Assessment report are as follows:
1) Ingestion of contaminated ground water from an onsite or
offsite well;
2) Dermal contact with contaminated ground water from an onsite
or offsite well;
3) Ingestion of surficial soils or excavated subsurface soils
from areas in and around the waste disposal cell;
4) Dermal contact with surficial soils or excavated subsurface
soils from areas in and around the waste disposal cell;
5) Ingestion of contaminated sediment or surface water whose
origin is the borrow pit or the North Skunk River;
6) Dermal contact with sediment or surface water whose origin
is the borrow pit or the North Skunk River; and
7) Inhalation of volatiles and contaminated particulates from
soils, sediment, and surface waters of the borrow pit and the
North Skunk River.
3. TOXICITY ASSESSMENT
The Toxicity Assessment portion of the Risk Assessment
report weighs the available evidence regarding the potential for
particular contaminants to cause adverse health effects in
exposed individuals. It also provides, where possible, an
estimate of the relationship between the extent of exposure to a
contaminant and the increased likelihood and/or severity of
adverse health effects.
Table #6 presents both the chronic and sub-chronic reference
doses for the contaminants of concern that have non-carcinogenic
effects, as well as the cancer potency factors for the
contaminants of concern that are carcinogens.
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References doses (RfDs) have been developed by the EPA for
indicating the potential for adverse health effects from exposure
to chemicals exhibiting non-carcinogenic effects. RfDs, which
are expressed in units of mg/kg-day, are estimates of lifetime
daily exposure levels for humans, including sensitive
individuals. Estimated intakes of chemicals from environmental
media (e.g., the amount of 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 (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 non-carcinogenic effects to occur.
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) X E-
1 are multiplied by the estimated intake of a potential carcino-
gen, 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 risks calculated from the CPF. Use of this approach
makes underestimation of the actual cancer risk hig~ly 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.
A. ASSUMPTIONS - CHILD TRESPASSERS
Child trespassers were assumed to be exposed on the site 2
days/week during the summer when school is not in session and 1
day/week during school (32 weeks/year) except when the ground is
snow covered (8 weeks/year). Thus the average number of days/year
that a child is exposed is:
(2 days/week) (12 week/year) + (1 day/week) (32 weeks/year)=
56 days/year
,- B.
ASSUMPTIONS - OCCUPATIONAL WORKERS
Occupational workers were assumed to be exposed on the Site
for 8 hours/day, five days/week, for 50 weeks/year for 40 years.
4. RISK CHARACTERIZATION
The Risk Characterization portion of the Risk Assessment
report integrates the results of the exposure and toxicity as-
sessments into a quantitative description of cancer and non-
cancer risks.
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Table numbers 7, 8, 9 and 10 present the twelve exposure
scenarios that were quantified, a summary of the carcinogenic
risks associated with the Site, a summary of the sub-chronic non-
carcinogenic health hazards associated with the Site and a
summary of the chronic non-carcinogenic health hazards associated
with the Site, respectively.
Excess lifetime cancer risks are determined by mUltiplying
the intake level with the cancer potency factor. These risks are
probabilities that are gengrally expressed in scientific notation
(e.g., 1 X E-6, or 1 X 10- ). An excess lifetime cancer risk of 1
x E.-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.
Potential concerns for non-carcinogenic effects of a single
contaminant in a single medium is expressed as the hazard quo-
tient (or the ratio of the estimated intake derived from the
cont.aminant concentration in a given medium to the contaminant's
reference dose). By adding the hazard quotients 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 within a single medium or across media. A HI of less
than 1 indicates that non-carcinogenic health effects are not
believed to occur.
A. NON-CANCER RISKS RESULTING FROM EXPOSURE TO CONTAMINANTS OF
CONCERN VIA BOTH CURRENT AND FUTURE EXPOSURE PATHWAYS
Onsite trespassers (children playing in various locations on
the Site) do not appear to have a risk of any non-cancer health
effects.
B. CANCER RISKS RESULTING FROM EXPOSURE TO CONTAMINANTS OF
CONCERN VIA BOTH CURRENT AND FUTURE EXPOSURE PATHWAYS
The baseline risk assessment report did not identify any
current human health risks posed by the Site. Onsite workers may
expel'ience a small excess cancer risk (6 X E-6) from contact with
conta.minants arsenic, beryllium and vinyl chloride in soil, and a
large risk (1 X E-3) from ingestion of the same contaminants in
ground water. This future risk calculation was based upon the
ingestion of beryllium, arsenic and vinyl chloride at
concentration levels identified in the onsite ground water.
However, the presence of both arsenic and beryllium in the
ground water can be explained by their presence in both onsite
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and offsite soils. The concentration levels of these 'two contami-
nants were found to be essentially the same in both the on- and
offsite soil samples. Therefore, the presence of both arsenic
and beryllium in the ground water is DQt a result of plant
activities b.ut is naturally occurring.
IX. ENVIRONMENTAL RISKS
An ecological assessment was conducted to determine if there
are any adverse effects occurring or likely to occur in aquatic
organisms, populations or communities exposed to contaminants
originating from the site. Three river sediment samples were
collected at an upstream and at a downstream location from the
site, for a total of six sediment samples. These samples were
collected at a depth of one foot below the river bed and analyzed
for total metals. Analysis of these samples did not indicate the
presence of metals at concentrations that would pose an adverse
threat to aquatic organisms. This conclusion is further supported
by the results obtained from analysis of two biological samples
collected from an upstream and a downstream location from the
site. Analysis of these two samples indicated that there was no
uptake of metals by these organisms.
No federal or state critical habitats, endangered wildlife,
or natural resources are potentially threatened or damaged as a
result of past waste disposal practices conducted at the site.
X.
POTENTIALLY APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs)
CERCLA section 121(d) (2) provides that at the completion of
any onsite Superfund remedial actions, if any hazardous
substance, contaminant, or pollutant remains onsite, the remedial
action shall attain other federal standards or requirements, or
more stringent state requirements that are determined to be
legally applicable or relevant and appropriate (ARAR) to the
specified circumstances at the Site. A variety of federal
environmental laws were reviewed as to legal applicability or
relevance and appropriateness to the remedial alternatives under
consideration at this Site. Further, the State of Iowa was
requested to provide a list of its statutes that may be
applicable or relevant and appropriate to this Site. One statute
provides more stringent requirements than federal laws. Those
environmental laws that were determined to be either applicable
or relevant and appropriate for the remedial actions being
considered for this Site are discussed under each medium of
concern.
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A. HAZARDOUS WASTE
c>
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
The Resource Conservation and Recovery Act (RCRA) requlates
the generation, transportation, treatment, storage and disposal
of hazardous waste as provided in 40 C.F.R. 55 260 - 270.
The RCRA hazardous waste management requlations that may be
applicable or relevant and appropriate to the response
alt:ernatives considered at this Site are described below.
1. RCRA'S DEFINITION OF A HAZARDOUS WASTE
A RCRA hazardous waste can be defined as: 1) one that
exhibits any of the characteristics of a hazardous waste, or 2)
one that has been listed as a hazardous waste. Certain
electroplating wastes are listed as a RCRA hazardous waste (F006)
at 40 C.F.R. 5 261.31.
2. RCRA LAND BAN DISPOSAL RESTRICTIONS
The electroplating wastes generated and disposed at the
smith Jones property are a RCRA hazardous waste (F006), which
became subject to the Hazardous and Solid Waste Amendments to
RCRA on August 8, 1988.) Superfund wastes usually contain soil
and. debris that are contaminated with RCRA hazardous wastes. In
general, RCRA's Land Disposal Restrictions or LDRs were
established for waste streams that differ significantly from
Superfund wastes. Because the LDRs are not based on treating
wastes that contain soil or debris, a Treatability Variance would
be appropriate to comply with RCRA's restrictions. Under a
Treatability Variance, alternate treatment levels are established
based on data from actual treatment of soil, or best management
practices for debris.
3. RCRA LANDFILL CLOSURE AND POST-CLOSURE STANDARDS
If a waste is hazardous and was disposed of subsequent to
November 19, 1980, when RCRA requirements became effective, then
RCRA closure standards apply.
Landfill closures require post-closure care and maintenance
of the unit for at least 30 years. The landfill unit must be
capped with a final cover designated and constructed to 1)
provide long-term minimization of migration of liquids; 2)
function with minimum maintenance; 3) promote drainage and
minimize erosion; 4) accommodate settling and subsidence; and 5)
have a permeability less than or equal to any bottom liner system
or natural subsoils present. Post-closure care includes
maintenance of the final cover and maintenance of a ground water
monitoring system (~ 40 C.F.R. 55 264.117 and 264.310(b».
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4. RCRA AND DEPARTMENT OF TRANSPORTATION REGULATIONS APPLICABLE
TO TRANSPORTERS OF HAZARDOUS WASTE
A transporter must comply with the requlations under 40
C.F.R. S 263 (Subtitle C). A transporter under subtitle C is
defined as any person engaged in off-site transportation of
hazardous waste within the United States. Such transportation
requires a manifest under 40 C.F.R. S 262.
B. GROUND WATER/ SURFACE WATER
1. SAFE DRINKING WATER ACT
CERCLA section 121(d)(2)(A) requires onsite remedies to
attain Maximum Contaminant Level Goals (MCLGs) that are above
zero, if MCLGs are relevant and appropriate to the circumstances
of the release. If the MCLGs are not relevant and appropriate,
then the corresponding Maximum Contaminant Level (MCL) shall be
attained where relevant and appropriate. Currently, the MCL for
vinyl chloride is 2 micrograms per liter.
2. IOWA ANTIDEGRADATION REQUIREMENTS FOR GROUND WATER
The Iowa Department of Natural Resources (IDNR) has promul-
gated rules for determining ground water clean up levels. These
rules became effective on August 16, 1989. The rules, as stated
in chapter 133 of the Iowa Administrative Code, refer to a.
hierarchy of cleanup levels starting with the lifetime Health
Advisory Level (HAL), followed by the Negligible Risk Level (NRL)
for an additional lifetime 1 X E -6 cancer risk, and then by the
Maximum contaminant Level (MCL) as established under the Safe
Drinking Water Act.
3.
RCRA GROUND WATER MONITORING REQUIREMENTS
Landfill closure requires ground water monitoring to be
conducted in accordance with the requirements of 40'C.F.R. S 264,
subpart F. These regulations describe monitoring schedules,
continued site characterizations, and provide for corrective
action if the standards are not met.
4.
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
The Clean Water Act (CWA) controls the direct discharge of
pollutants to surface waters through the National Pollutant
Discharge Elimination System (NPDES) program. NPDES requires
permits for direct discharge to surface waters. An onsite dis-
charge from a CERCLA site to surface waters must meet the sub-
stantive NPDES requirements but need not obtain an NPDES permit
or comply with the administrative process, consistent with CERCLA
section 121(e) (1). The NPDES permits are issued, monitored and
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enforced by the State of Iowa. Chapters 60-64 of the Iowa Admin-
istrative Code address the specifics of the NPDES program.
5. PRETREATMENT PROGRAM
Under the CWA, all discharg~s by non-domestic users into the
Publicly Owned Treatment Works (POTWs) must meet pretreatment
standards. The purpose of the pretreatment standards is to avoid
the introduction of pollutants into municipal wastewater treat-
men't plants that pass through, interfere with, or are otherwise
inc,ompatible with such treatment works. Any discharge from a
CERCLA site to a POTW is considered an off-site activity. It is
therefore, subject to both substantive and administrative re-
quirements of the national pretreatment program, and all applica-
ble state and local pretreatment requlations. These requlations
are also found in Chapters 60 - 64 of the Iowa Administrative
COdE~ .
6. AQUIFER CLASSIFICATION
Although the state has not officially categorized the
aquifer beneath and around the Site, this type aquifer is one
that is a current or potential source for drinking water and has
other beneficial uses.
7. SURFACE WATER CLASSIFICATION
The state has categorized the North Skunk River as a class B
war:m water body. See Ch. 61.3(5) Iowa Admin. Code. A class B(W)
water is protected for wildlife, fish, aquatic and semi aquatic
life, and secondary contact water uses.
C. AIR
1. RCRA CLEAN AIR STANDARDS
The use of an air stripper to remove volatile organic com-
pounds (VOCs) from ground water causes the contaminants to be
transferred from a liquid phase to a vapor phase and they are
subsequently released to the ambient air. A vapor phase carbon
adsorption unit shall be used if the air emissions coming from
the i!ir stripper exceed the emission limit goals specified in 55
Fed. Reg. 25,454 (June 21, 1990) (to be codified at 40 C.F.R. S
264, Subpart AA and Subpart 88).
. ,
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XI.
DESCRIPTION OF ALTERNATIVES
ALTERNATIVE #1: NO ACTION WITH GROUND WATER MONITORING
Estimated Construction Cost:
Estimated Engineering Cost:
Estimated Operation and
Maintenance Cost:
Estimated Implementation
Timeframe:
$27,209
$9,009
$82,588*
one month
The Superfund program requires that the "no action" alterna-
tive be considered at every site. The no action alternative is
the baseline against which effectiveness of other remedial alter-
natives are judged. Under this alternative, EPA will not take a
clean up action to address the ground water contaminant plume.
However, long term monitoring would be conducted to epsure that
the plume does not impact the city municipal drinking water
wells. In order to ensure that this alternative is protective of
human health, monitoring would be implemented around the
perimeter of the Site. The monitoring well network would consist
of two new monitoring wells and four existing monitoring wells.
The four existing monitoring wells are located in the southern
portion of the site. One of the new monitoring wells would be
located in the northeast corner of the Site directly down-
gradient of the City's municipal well #1 and the other new
monitoring well would be located off-site to the west of the Site
directly down-gradient of the City's municipal well #2.
Sampling and analysis of the six ground water monitoring
wells would take place quarterly for the first two years, semi-
annually for 3 to 10 years, and annually for 11 to 45 years. The
ground water samples would be analyzed for the twenty-six
contaminants of concern.
The area of attainment defines the area over which cleanup
levels will be achieved in the ground water. This area has been
defined as the area at the site boundaries. This alternative
relies on natural attenuation to reduce the level ot
contamination. It is 60timated that the contaminant levels will
be reduced to concentrations in accordance with ARARs in
approximately 40 to 45 years.
* All operation and maintenance cost estimates for ~
alternative are in present worth, estimated over 30 years at 8
percent interest per annum.
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AvrERNATIVE #2: SOIL CAPPING OF THE WASTE DISPOSAL CELL
AND GROUND WATER PUMPING, TREATMENT AND
DISCHARGE
Estimated Construction Cost: $199,373
Estimated Engineering Cost: $89,046
Estimated Operation and
Maintenance Cost:
Estimated Implementation
Timeframe:
$200,425
five months
This alternative would require that the waste disposal cell
which received the plant's electroplating waste be capped in
accordance with the RCRA landfill closure requirements as de-
scribed in the ARARs section herein and in 40 C.F.R. S 264
Subparts G and N. The design life of the cap is estimated to be
30 years. The purpose of the cap is to minimize infiltration of
surface waters through the wastes and thus to minimize the
potential for generation of leachate. The RCRA landfill closure
requirements are applicable, because the listed waste was
disposed after RCRA's effective date. Post-closure care
requirements include maintenance of the final cover and the
maintenance of a ground water monitoring system.
An air stripping column would be constructed at the site to
treat the volatile organic compounds (VOCs) in the extracted
ground water. The air and VOC mixture leaving the air stripper
may be treated by a vapor phase carbon adsorption unit, if
necessary to meet ARARs.
The clean air would be emitted into the atmosphere. In
addition, inorganic contaminants in the ground water may be
remc>ved by a filtration unit, if one is necessary to meet ARARs.
The treated water would be discharged either into the North Skunk
River or into the POTW. All air and surface water discharges
would comply with both state and federal standards.
Ground water monitoring would be conducted during the post-
closure period. In addition, monitoring of the ground water at
the Site would continue for at least three years after the
completion of the remediation to ensure that the goals of the
remedial action have been met. Deed restrictions would also be
placed on the use of ground water for drinking water purposes
until the remediation goals are achieved.
The area of attainment for the treatment of ground water
under this alternativ~ encompasses the area outside the boundary
of the waste disposal cell and up to the contaminant plume. The
g~ound water contamination will be reduced to concentrations in
accordance with Iowa's antidegradation statute in approximately
25 to 30 years.
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ALTERNATIVE #3: SOIL CAPPING AND IN-SITU STABILIZATION
OF THE WASTE DISPOSAL CELL AND GROUND
WATER PUMPING, TREATMENT AND DISCHARGE
Estimated Construction Cost:
Estimated Engineering Cost:
Estimated Operation and
Maintenance Cost:
Estimated Implementation
Timeframe:
$232,385
$99,878
$200,425
five months
Under this alternative, a cement-silicate agent would be
used to immobilize the waste within the waste disposal cell.
Because of the shallow depth of the waste within the cell, the
immobilization agent would be added to the surface of the dispos-
al cell. After immobilization of the waste material has occurred,
a RCRA cap as described in Alternative #2 would be placed over
the disposal cell. It is estimated that 340 cubic yards of
waste material would be treated under this Alternative.
The ground water pumping, treatment and discharge scenario
would be the same as described in Alternative #2.
ALTERNATIVE #4: SOIL EXCAVATION AND STABILIZATION
OF THE WASTE DISPOSAL CELL AND GROUND
WATER PUMPING, TREATMENT AND DISCHARGE
Estimated Construction Cost:
Estimated Engineering Cost:
Estimated Operation and
Maintenance Cost:
Estimated Implementation
Timeframe:
$362,437
$109,407
$190,012
five months
This alternative provides for the excavation of the waste
material within and around the waste disposal c~ll. The
excavated material would be treated on site using immobilization
technology to achieve compliance with RCRA's land disposal
restrictions. 40 C.F.R. S 268. The disposal cell would be
closed in compliance with RCRA'3-clean landfill closure
requirements as explained in the ARARs section herein. The
treated material would be disposed into a RCRA Subtitle C
licensed disposal facility.
Transportation of the treated material would be in
compliance with RCRA's regulations for hazardous waste
transportation regulations. 40 C.F.R. S 263. It is estimated
that 340 cubic yards of contaminated material would be excavated
under this alternative. Clean offsite fill material of low
permeability will be used to back-fill the excavations. The area
would be graded with clean soil to support a vegetative cover.
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The ground water pumping, treatment and discharge scenario
would be the same as described in Alternative #2, except that the
area of attainment under this alternative would be the entire
plume including where the waste disposal cell was previously
located.
XII.
NINE EVALUATION CRITERIA
EPA has developed nine criteria to be used to evaluate
remedial alternatives to ensure all important considerations are
factored into remedy selection decisions. These criteria are
described from the statutory requirements of section 121 of
CERCLA, as well as other technical and policy considerations that
have proven to be important for selecting the preferred remedy.
A. THRESHOLD CRITERIA
The two most important criteria are statutory requirements
that: must be satisfied by any alternative in order for it to be
eligible for selection.
1. Overall protection of human health and the environment ad-
dresses whether a remedy provides adequate protection of human
health and the environment and describes how risks are
eliminated, reduced, or controlled through treatment, engineering
controls, or institutional controls.
2. Compliance with ARARs addresses whether a remedy will meet
all of the applicable or relevant and appropriate requirements of
other environmental statutes, or provide grounds for waiving such
a requirement. .
B. P:RIMARY BALANCING CRITERIA
Five primary balancing criteria are used
trade-offs among remedial alternatives. These
ultimately balanced to identify the preferred
select the final remedy.
1. ~ ~ effectiveness and permanence refers to the ability
of a remedy to maintain reliable protection of human health and
the environment over time once cleanup goals have been met.
to identify major
trade-offs are
alternative and to
2. Reduction 2t toxicity. mobility 2X volume throuah treatment
is the anticipated performance of the treatment technologies a
remedy may employ.
3. ~hort-term effectiveness addresses the period of time needed
to ac:hieve protection and any adverse impacts on human health and
the E!nvironment that may be posed during the construction and
implementation period until cleanup goals are achieved.
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4. ImDlementability is the technical and administrative feasi-
bility of a remedy, including the availability of materials and
services needed to implement a particular option.
5. Cost includes estimated capital and operation and mainte-
nance costs.
C. MODIFYING CRITERIA
These criteria may not be considered fully until after the
formal pUblic comment period on the Proposed Plan and the RI and
FS reports is complete.
1. State acceDtance addresses the support agency's comments
after it reviews the RI and FS reports and Proposed Plan.
2. Community acceDtance addresses concerns of the pUblic re-
garding acceptance of a particular remedy.
XIII. SUMMARy OF COMPARATIVE ANALYSIS
A detailed analysis was performed on four alternatives using
the nine evaluation criteria described above in order to identify
the preferred alternative for the Site. The following is a
summary of the comparison of each alternative's strength and
weakness with respect to the nine evaluation criteria.
1.
Protection of human health and the environment
Protection of human health and the environment pertains to
how risks are eliminated, reduced, or controlled through treat-
ment, engineering controls, or institutional controls.
With the exception of the no action alternative, all of the
alternatives provide protection of human health and the
environment by reducing or controlling risk through treatment and
engineering controls. The potential health risk resulting from
exposure to the contaminated ground water is significantly
reduced by all of the action alternatives. In addition, the
potential for migration of the contaminants within the waste
disposal cell to the ground water is also significantly reduced,
thus preventing increased health risks from further contamination
of the aquifer.
2. ComDliance with aDDlicable ~ relevant AnQ ADDroDriate
reauirements
Alternative numbers 2 through 4 would
Alternative #1 would not meet the state of
requirements for ground water nor would it
provisions.
meet all ARARs whereas
Iowa's antidegradation
comply with RCRA
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Because these criteria are threshold considerations, any
alternative that is not protective or does not comply with ARARs
cannot be considered further. Therefore, Alternative #1 is
removed from further discussion.
3.
Reduction 2t toxicitv. mobility. ~ volume
section 121(b) of CERCLA states that remedial actions in-
volving treatment that permanently and significantly reduces the
volume, mobility or toxicity of hazardous materials, are to be
preferred over those not involving such treatment. This evalua-
tion criteria relates to the ability of a remedial alternative to
control or eliminate risks caused by the mobility, toxicity or
volume of a hazardous waste.
Alternative numbers 2 through 4 will stabilize the plume and
thereby reduce its mObility by pumping and treating the ground
water. Also, as the ground water is treated the toxicity of the
contaminants will be reduced. The reduction of the contaminants
to appropriate ARARs will take 25 to 30 years.
Alternative #2 proposes to cap the waste dispo~al cell.
This action would not reduce the toxicity or volume of the
materials within the cell since the cadmium concentration
would remain at its current level. However, the mobility of the
contaminants would be minimized by reducing the flow of surface
water through the waste. The leaching of contaminants into the
ground water could continue, but at a significantly reduced rate.
Alternative numbers 3 and 4 would use immobilization
treatment technology to reduce the mobility of cadmium in the
soil. Neither of these alternatives would reduce the toxicity or
volume of the hazardous wastes within the disposal cell. However,
each would provide a great degree of protection against the
ability of the cadmium to leach into the ground water. The issue
of reduction of toxicity, mobility, and volume is resolved in
Alternative #4 by providing that the waste will be transported
offsite for disposal.
4.
Short-term effectiveness
This evaluation focuses on the effects on human health and
the environment that may occur while the remedy is being
implemented and until the remedial objectives are met. The fol-
lowing factors were used to evaluate the short-term effectiveness
of each alternative: protection of the community during the
remedial action and protection of workers during remedial action.
With respect to the community, none of the alternatives will
POSE! a risk to the community.
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Alternative number 2 would not pose a risk to workers,
because no waste will be excavated or treated as would be
required for the other two alternatives. Alternatives 3 and 4
could potentially pose a risk to workers during soil disturbing
and handling activities through direct contact, ingestion, or
inhalation of contaminated soil particles. Measures can be
implemented to eliminate the potential for worker exposure, such
as the use of protective clothing, appropriate breathing
apparatus, and effective dust control.
5.
Lonq-term effectiveness ADS ~ermanence
Long-term effectiveness and permanence refers to the ability
of a remedy to maintain reliable protection of human health and
the environment over time after clean up 90als have been met.
Alternative numbers 2 through 4 would eventually reduce the
contaminants present in the ground water through pump and treat-
ment technology in accordance with all ARARs so that long term
effectiveness and permanence is achieved.
Alternative #2 proposes to place a RCRA cap over the waste
disposal cell. This alternative would provide a high degree of
long-term effectiveness and reliability, because the waste poses
a relatively low long-term threat and it can be reliably
contained over a significant period of time by available capping
technology. A cap will require long-term maintenance and
portions will need replacement as they erode.
The use of in-situ stabilization in conjunction with a cap
as proposed in Alternative #3 may provide a higher degree of
protectiveness and reliability when compared to Alternative
number 2. The use of a cap in conjunction with immobilization
technology will significantly reduce the likelihood for ground
water contamination.
Alternative #4 would also provide a high degree of
protectiveness and reliability, because it proposes to remove the
source of cadmium from the Site.
6.
Implementability
Implementation addresses the technical and administrative
feasibility of a remedy, including the availability of materials
and services needed to implement the chosen solution. Although
all of the alternatives considered are implementable, some
alternatives are easier to implement than others.
Alternative #2 is the easiest to implement. Its
implementability would only be affected by the availability of
suitable cover materials (e.g., rock, clay, soil, and seed for
21
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acc:limated vegetation). The remedial design would take site
characteristics into account when developing the cap.
Both Alternative numbers 3 and 4 propose using an
imnlobilization technology to treat the waste disposal cell.
Since immobilization treatment is a proven technology, no techni-
cal difficulties are expected regarding its implementation.
However, Alternative #4 would probably be the most difficult to
implement because some difficulty may be encountered in locating
a RCRA Subtitle C Landfill operator to accept the treated waste.
7.
~
Capital costs consist of direct (construction) and indirect
(non-construction and overhead) costs. Annual operation and
maiJ~tenance costs are post-construction costs necessary to ensure
the continued effectiveness of a remedial action. The cost
estimates developed in the Feasibility Study are expected to
provide an accuracy of +50 percent to -30 percent. A present
worth analysis is used to evaluate expenditures that occur over
different time periods by discounting all future costs to a
comn10n base year, usually the current year. This allows the cost
of remedial action alternatives to be compared on the basis of a
single figure representing the amount of money that, 'if invested
in t:he base year and disbursed as needed, would be sufficient to
cover all costs associated with the remedial action over its
planned life.
CERCLA requires that the EPA select a cost-effective
alternative (not merely the lowest cost) that protects human
health and the environment and meets other requirements of the
law.
The primary risk at the Site is the ingestion of
contaminated ground water. No potential health risks were
identified from direct contact, ingestion or inhalation of
surface soils originating from the waste disposal cell. However,
the potential for migration of cadmium to ground water needs to
be addressed under a cost effective remedy to prevent any
increased risks from further contamination of the aquifer.
Alternative #2 would achieve this goal at a cost of 20' less than
Alternative #3 and 26' less than Alternative #4.
The total cost of Alternative #2 is $488,844 and Alternative
#3 is $532,688. The total cost of Alternative #4 is greater than
the ()ther two alternatives, due in part to the increased
construction costs involved. Its cost is $661,856.
8.
Community acceDtance
The comments received from the public indicate that they are
concerned about the costs of the preferred remedial alternative
22
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and who will pay these costs. In addition, the comments also
indicate that the public does not perceive the Site as presenting
any significant threat to the public health or the environment.
9.
State acceptance
The State of Iowa informed the Agency in a letter dated
September 21, 1990, that it agreed with the EPA's selection of
Alternative #2 as the preferred alternative for the Site.
Alternative #2 proposes ground water treatment and containment of
the contaminated soils in the waste disposal cell.
XIV.
SELECTED ALTERNATIVE
Based on the information available to evaluate the remedial
options against the previously described criteria, Alternative #2
is selected as the preferred alternative for the Site. This
alternative provides for capping of the waste disposal cell in
accordance with the RCRA landfill closure requirements as
described in the ARARs section and in 40 C.F.R. S 264 Subparts G
and N. The design life of the cap is estimated to be 30 years.
The RCRA landfill closure requirements are applicable because
disposal of hazardous waste occurred after November 19, 1980.
The purpose of the cap would be to minimize infiltration of
surface waters through the wastes, and thus to minimize the
generation of leachate. Post-closure care requirements would
include maintenance of the final cover and the maintenance .of a
ground water monitoring system. Ground water monitoring shall
meet the RCRA requirements found at 40 C.F.R. S 264, Subpart F.
This alternative also provides for ground water treatment.
Iowa's ground water protection law, described in the ARARs
section, is a comprehensive, highly regulatory statute. Its
premise is a non-degradation policy, intended to prevent further
contamination to the maximum extent practicable, and to restore
the ground water to a potable state, if necessary. other
drinking water programs relate to public (municipal) water
supplies, and do nothing to protect the extensive rural and farm
population, with their own private wells, in a state such as
Iowa. Iowa's ground water protection statute attempts to
minimize or eliminate contamination to alleviate health risks,
particularly for farm families whose water supply is not
regulated and typically not treated.
A general description of the ground water treatment is as
follows. An air stripping column would be constructed at the
Site to treat the volatile organic compounds (VOCs) in the
extracted ground water. The air and VOC mixture leaving the air
st~ipper may be treated by a vapor phase carbon adsorption unit,
if necessary to meet ARARs. The clean air would be emitted into
the atmosphere. In addition, inorganic contaminants in the ground
23
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water may be removed by a filtration unit, if one is 'necessary to
meE~t ARARs. The treated water would be discharged either into
the North Skunk River or into the POTW. All air and surface
water discharges would comply with both state and federal standards.
Environmental monitoring would be required during the life
of the treatment process. In addition, monitoring of the qround
water at the Site would continue for at least three years after
the completion of the remediation to ensure that the goals of the
renledial action have been met. Deed restrictions would also be
pla,ced on the use of ground water for drinking water purposes
until the remediation goals are achieved.
The area of attainment for the treatment of qround water.
under the preferred alternative is the area outside the boundary
of the waste disposal cell and up to the contaminant plume. The
time to reduce the ground water contaminant concentrations in
accordance with all ARARs is estimated to be 25 to 30 years.
In summary, the preferred alternative is believed to provide
the best balance among alternatives with respect to the criteria
used to evaluate remedies. Based on the information available at
this time, therefore, EPA and the State of Iowa believe the
preferred alternative would protect human health and the
environment, would comply with ARARs, would be cost-effective,
and would utilize permanent solutions to the maximum extent
practicable. The preferred alternative also satisfies the prefer-
ence for treatment as a principal element. .
XVI:r. STATUTORY DETERMINATION
Based upon the available information, the selected Alterna-
tive satisfies the remedy selection requirements under CERCLA, as
amended and the National Contingency Plan. The selected alterna-
tive is protective of public health and the environment, satis-
fie~; all applicable or relevant and appropriate environmental
re~lirements, is cost effective and would utilize permanent
solutions to the maximum extent practicable. The preferred Alter-
native also satisfies the preference for treatment as a principal
elecent.
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GLOSSARY OF TERMS
1. ARARs: Applicable or Relevant and Appropriate Requirements
refers to the Federal and State requirements that a remedy
selected by EPA must attain. These requirements may vary from
site to site.
2. Ground Water: Underground water that fills pores in soils or
opening in rocks to the point of saturation. Ground water is
often used as a source of drinking water for municipal or
domestic wells.
3. Leachate: A liquid that has passed through wastes and con-
tains some components of these wastes.
4. Immobilization Technoloqy: A process used to reduce the
mobility of liquid contaminants by mixing them with a material
such as cement kiln dust in order to increase the ability to
handle the waste and make the substance less likely to leach.
25
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-------
LIST OF CODES
USED IN TABULA TED ANALYTICAL DATA
CODE
"EXPLANA nON
u
I
B
J
E
Indicates the compound was analyzed Cor, but was not
detected.
Indjcates the data is invalid (compound mayor may not
be present). Resampling Ind/or reanalysis is necessary
for verification.
Indicates the compound was (ound in the associated
blank as well as in the sample. This indicates possible
laboratory induced contamination.
Indjcates the presence of a compound that meets the
identification criteria, but the result is less than the
quantitation Hmit, but greater than zero. For example. if
the sample quantitation limit is JO ug/I, but I.
concentratjon of 3 ug/l is calculated, it is reported as 3 J
ug/J.
Concentration exceeds calibration range of GC/MS
instrument.
-------
TABLE J
CHEMICALS or POTImlAL CONCERN-
WASTE SLUDGE TRENCH/SITE SOILS
UNITS: Ma/Ka
Sampling Area Waste Discosal Site Soil BoriDIS Site Surface Soils Backlround Soils
Sample Medium Trench Soil Soil Soil
Detected Detected Detected Detected
Chemical of Concen tration CoDcentratioD CODcentration CODcentration
Potential CODcern Rule RaDle RaDle Ranle
AJuminum 2,3OOJ-I3,oooJ '7.500- '~,OOO 6030-'7440 5,730- J3 ,300
Antimony U 3.~J-~.~J U U
Arsenic 4I.2J 2.2J-5.5 2.9-5.6 3.4-6.3
Barium 82-230J ~.7-~80 120-J76 137- J 86
Beryllium 0.70-0.8 I J 0.28B-0.80J 0."9B 0."5B-0.66B
Chromium 22-320 6.3-20 9.8-13.4 9.5-J4.7
Cobalt 2.0B-5.4J 2.9J-50 6.2B-6.8B 6.2B-9.4B
Cadmium 13- :.300 0.33B-19 1.6-79.9 0.61 B-4.4
Iron J6.400-8 I ,500 J 5,000- 30,000 J2,000- J 7,200 JJ ,200-18,700
lead J9-214 3.6-7 I '48.3-34.1 3.6-91.6
Manganese 660J - 2.480 91J-7000J 444-5JO 5J"-960
Mercury U 0.12 U 0.21
Nickel 130-3800 10.4-52 '48.2-69.2 14.0-18.8
Vanadium 3.5J-32 J 2.6-48 20.4-21.7 19.9-30.4
Cyanide 2.0- 7.0 U NA 48.6
Vinyl Chloride U NA NA NA
Carbon Disulfide 0.007-0.028 NA NA NA
: .~-DichJoroethene 0.002 -0.0 1 I J NA NA NA
- Butanone 0.280 NA NA NA
I .1 , ) - T lie hk>roethane U NA NA NA
Tetrachloroethene O.OO~ - 0.03 J NA NA NA
Trichloroethene 0.002-0.0 J 6 NA NA NA
Toluene 0.002J NA NA NA
Ethyl Benzene 0.003J-0.063 NA NA NA
Xylenes 0.002J-0.3oo NA NA NA
Phenanthrene 2.000- 2 J.ooo NA NA NA
NOTES:
. As identified in the baseline risk usessmeDt.
NA ~mple Dot Inalyzed for that constituent.
The metals concentrations Ire reponed IS total metals.
-------
TABLE 2
CHEMICALS or POTENTIAL CONCERN-
w ASTE METALS PILE
UNITS: MaiKa
Sampling Area Waste Metals Pile Backlround SoHs
Samplina Medium SoH Soil
Detected Detected
Chemical or Concentration Concentration
Potential Concern Ranle Range
Aluminum 7,660- 22,oooJ 5,730-13,300
Antimony 6.~J U
Arsenic ~.S- J 4J 3.~-6.3
Barium 225-670J 137- n6
Beryllium 0.47B-2.7 0.45B-0.66B
Chromium J5.1-39 9.5- 14.7
Cobalt 7.7-8.8 6.2B-9.4B
Cadmium I.J-4.2 0.61 B-4.4
Iron 22,400-28,100 11,200- J 8,700
Lead 136-36OJ 3.6-91.6
Manganese 1,840-3,100 514-960
Mercury U 0.21
Nickel 25.9-43 I~.O- n.8
Vanadium 20.9-51 19.9-30.4
Cyanide 0.78-2.3 ~.6
Vinyl Chlorjde U NA
Carbon Disulfide U NA
1,2- Djchloroethene U NA
2-Butanone 0.013 NA
I, J, I - Trichloroethane U NA
Tetrachloroethene U NA
Trichloroethene U NA
Toluene U NA
Ethyl benzene 0.003J-0.019 NA
Xylenes 0.013-0.092 NA
Phenanthrene U NA
. As identiried in the baseline risk assessment.
NA Sample Dot analyzed ror that a::mtitu8nt.
The metals concentrations are reported as total metals.
-------
TABLE 3a
CHEMICALS OF POTENTIAL CONCERN-
MARSH SURFACE SEDIMENT
UNITS: .,/Ka
Samplins Area Marsh Backlround Soils
Sampling Medium Surface Sediments Soil
Detected Detected
Cbemical of Concentration Conc:entntion
Potential Concern Ranle Ranle
Aluminum J 0,300-24,300 5,73O-J3,3oo
Antimony J7.2- 17.3 U
Arsenic 3.3-6.7 3.4-6.3
8arium 196-727 137-186
8eryllium 0.658. J.3 0.458-0.668
Chromium 46.5- I 38 9.5- 14.7
Cobalt 4.5B-) 8.8 6.28-9.4B
Cadmium 7.8-275 0.61 B-4.4
Iron 20,600-97,600 J J ,200-18,700
Lead 24.9-890 3.6-9),6
Manganese 134- 1070 514-960
Mercury U 0.21
Nickel 36.5-93. I 14.0-18.8
Vanadium 30.1-56.1 19.9-30.4
Cyanide ),2- 3.8 4.6
Vinyl Chloride U NA
Carbon Disulfide U NA
I ,2-Dichloroethene U NA
2-8utanone U NA
J . J.) - Trichloroethane U NA
Tetrachloroethene U NA
Trichloroethene 0.018-0.065 NA
Toluene 0.0 IJ -0.016 NA
Ethyl benlene 0.076 NA
Xylenes J,IDOE NA
Phenlnthrene U NA
. As identified in the baseline risk assessment.
NA Sample not ana!Yled (or that ccn5titu8nt.
The metals concentrations are reported IS total metals.
-------
TABLE 3b
CHEMICALS OF POTENTIAL CONCERN.
MARSH SURFACE WATER
UNITS: .&/1
Sample Area Minh
Sample Medium Surflce Wlter
Detected
Chemical of Concentntion
Potential Concern Ringe MCL SMCl
Aluminum 63.IB - 432 -- --
Antimony U -- --
Arsel,ic U 50 --
Bari\.lm 27.8B - 36.8B J ,000 --
Beryllium J.3B - J.SB -- --
Chromium IJ.J 50 --
Cobalt U -- --
Cadrnium 2.7B - 3.9B 10 --
Iron 377 - J630 -- 300
Lead 1.9B - 4.6 50 --
Manganese 46.0 - 82.2 -- 50
Mercury U 2 --
Nickel lUB - 13.IB -- --
Vanadium 15.0B - 20.2B -- --
CyanJde 18.9 - 34.8 -- --
Vinyl Chloride U 2 --
Carbon Disulfide U -- --
1,2- Dichloroethene 7 - 12 -- --
2-Butanone U -- --
J ,1,1- Trichloroethane U -- --
Tetrachloroethene U -- --
Tric:hJoroethene JJ-18 S --
Toluene U -- --
Ethyl benzene U -- --
Xylenes U -- --
Phenanthrene U -- --
. As indentified in the baseline risk assessment.
MCL - Muium Contaminant Level u established under the Safe DriDJdn& Water Act
SMCL - Secondary Maximum Contaminant Level
The metals conc:entration are reported u total metals.
-------
TABLE ..
CHEMICALS OF POTENTIAL CONCERN.
CROUNDWATER
UNITS: -&/1
Sample Area Site Monitor Wells 1 thru 1 I City Wlter Supply Wells I thru
3 and Distribution System .
Sample Medium Groundwater Groundwater
Detected Detected
Chemical Concen tn tion 'Concentration
Potential Concern Range Ranle MCL
.
Aluminum 81.8B -49000J 39.2B --
Antimony 22J-3JJ U --
Arsenic 2.3J-87.6J U 50
Barium ) 1.7J-1350 24.4B-53.4B JOOO
Beryllium )B-8.2 U --
Chromium 4.7B- J 10 U 50
Cobalt 6.4J-284 U --
Cadmium 2.7B-23.3 3.3B-5.9 10
Iron 433-140,000 J) B-1870 --
. Lead 1.2B- J47 I.IB-2.5B 50
Manganese ) 56-29,600 2.6B-'298 --
MerCury 0.2J-0.72 U 2
Nickel 9.6J-243 U --
Vanadium J 1.8B-280 U --
Cyanide JOJ-35.9 1 0.6-79.0 --
Vinyl Chloride 3J-4J NA 2
Carbon Disulfide U NA --
Carbon Tetrachloride 87 NA --
J ,2 - Dichloroethene 9-J70 NA --
2-Butanone 26 NA --
1,1,1- Tric:hloroethane 11-13 NA --
Tetrachloroethene U NA --
Tric:hloroethene 3J-670E NA 5
Toluene 3J-3.5 NA --
Ethyl benzene 3J-3.5 NA --
Xylenes II NA --
Phenanthrene V NA --
. As identified in the baseline risk assessment.
The metals conce,ntTations are reported as total metals.
NA sample not analyzed for that constituent
-------
TABLE 5
CHEMICALS OF POTENTIAL CONCERN.
Aluminum
ADtimony
Anenic
Barium
Beryllium
Cadmium
Chromium
Coba1t
Iron
Lead
Manganese
Mercury
Nickel
Vanadium
Cyanide
Vinyl chloride
Carbon disulfide
1,2-Dichloroethene
2-Butanone
I, I, I -Trichloroethane
Trichloroethene
Tetrachloroethene
TolueDe
Ethyl benzene
Xylene
Phenanthrene
. As identified in the baseline risk assessment.
-------
TABLE 6
SUMMARY OF TOXICITY VALUES .., FOR THE CONTAMINANTS
OF POTENTIAL CONCERN AT THE MIDWEST SITE
Oral
Chfmlcal Name arD. arDc SF
Aluminum -Cb) - -
Antimony ~.O£-04fe) ~.OE-04 -
Arsenic J.0£-03Ie) J .OE-03Ie) 1.75£..00
Barium 5.0£-02 Ie) 5.0E-02(e) -
Beryllium 5.0£-03Ie) 5.0£-03 ..3£+00
Cadmium - 1.0£-031d) -
Chromium 2.0£-02/C) 5.0£-03 -
Cobalt - - -
Iron - - -
Lead - - -
Manganese 5.0£-01Ic) 2.0£-01Ic) -
Mercury 3.0£-04/C) 3.0E-04IC) -
Nickel 2.0£-02Ic) 2.0£-02 -
Vanadium 7.0E-03/C) 7.0£-03 Ic) -
Cyanide 2.0£-02IC) 2.0E-02 -
Vinyl chloride - - 2.3£ot<)Olc)
Carbon disulfide - 1.0£-01 -
1,2-Dichloroethene (Trans) 2.0£-01Ic) 2.0£-02 -
2-Butanone 5.0£-01/c) 5.0E-02 -
I, I, I - Trichloroethane 9.0£-01IC) 9.0£-02 -
Trichloroethene - - 1.1£-02IC)
Tetrachloroethene I.OE-Ollc) 1.0£-02 5.1 £-02Ic)
Toluene ..0£-01 (e) 3.0£-0 I (e) -
£thylbenzene 1.0E...ooIC) I.OE-OI -
Xylene ..0E...oole) 2.0£+00 -
Phenanthrene - - -
Ca) Toxicity Values;
RrD. - Subchronic Reference Dose
RrDe - Chronic Reference Dose
SF - Slope Factor
Cb) No value available.
Cc) Value obtained from USEPA (19891). All other values rrom USEPA (1990).
Cd) Oral RrD listed is for cadmium iD rood. This is used ror cadmium in lOil. Onl
RrD used for cadmium in Wlter is 5.0£-4.
-------
TABLE 7
EXPOSURE SCENARIOS QUANTIFIED AT THE MIDWEST SITE
Exposed
Population Exposure Point Exposure Medium Exposure Route
Trespasser J Waste Disposal Soil IDlestion
Trench DermaJ Contact
'Trespasser 2 Site Surrace Soil Inlestion
Trespasser 3 River Bank Soil IDlestion
Dermal Contact
Trespasser 3 N. Skunk River Sediment Ingestion
Dermal Contact
Trespasser 4 Borrow Pit Surface Water Ingestion
(Marsh)
Trespasser 4 Borrow Pit Sediment Ingestion
(Marsh) Dermal Contact
Occupational Future Site Surface Soil Sludge Ingestion
(Future) Groundwater Inaestion
Ingestion
~t'respasser 1 Child playing in the waste disposal trench.
:rrespasser 2 Child playing m:1 ridina a bicycle or all-terrain vehicle on-site.
Trespasser 3 auld wa1Jcin& and pl8ying along the river b8nk mS in t11e Ibrth 9c1rit River.
,t'resp&sser 4 au 1d playing in the borrow pit
-------
TABLE 8
SUMMARY OF CARCINOGENIC RISK
Exposed Exposure Exposure Specjfic Contaminant Exposure Cancer
Population Point . ~edium of Concern ( c) Route Risk la)
Adult Future Site Soil Anenic In&estion 6£-6
Occupational (b) Beryllium
(Future) Vinyl Chloride
Adult Future Site Groundwater Anenic Inaestion IE-3
Occupational (b) Beryllium
(Future) Vinyl Chloride
-
(.)
Typically, cancer risk of J £-6 or lower are considered to be of no practical significance, while
higner cancer risk levels may be cause for concern.
(0)
Adult occupational worker.
(e)
The chemicals of potential concern (Table 5) were evaluated in
exposure scenario. Those contaminants identified as pasin&
presented here.
the risk assessment under each
unacceptable health risks are
-------
TABLE' "
SUMMARY OF SUBCHRONIC NONCARCINOCENIC HEALTH HAZARDS
Exposed Exposure Exposure Specific Contaminant Exposure Huard
Population Point Medium of Concern(g) Route Index (e)
Child (b) .
Waste Disposal Soil NA In,estion 1
(a)
A Hazard Index or one (I E...o) or Jess indicates no noncarcinogenic health risks, exist for that
scenario.
(b)
Child "Ia}'ing in the ~'aste disposal trench.
(~)
Child playing and riding a bicycle or III-terrain vehicle on-site.
(11)
Child '..alking and pJayin,alona the river bank and in the Nonh Skunk River.
te)
Child playin, in the borrow ph (manh).
~
Adulr occuparional worken.
f8) The chemicals of potential concern (Table 5) were eYlluated in the risk useumenr under elc h
exposul'e acenario. Those contaminants identified as pesina unacceptable health risks Irt presented
here.
NA Nor APPlicable
-------
TABLE 10
SUMMARY OF CHRONIC NONCARCINOGENIC HEALTH HAZARDS
Exposed Exposure Exposure Specific Contaminant Exposure Haurd
Population Point Medium or Concern (g) Route Index (a)
Child (b) . Waste Disposal Soil NA In&estion ,
Total >1
(I)
A Haurd Index of one (I E+O) or less indicates no noncarcinogenic health risks exist for that
scenario.
(b)
Child playing in the waste disDosal t!'enCh.
(e)
Child playing and riding a bicycle or all-terrain vehicle on-site.
(d)
Child walking and playing along the river bank and in the Nonh Skunk River.
fe)
Child playina in the borrow pit (marsh).
CI)
Adult occupational workers.
(g)
.
The chemicals or potential concern (Table 5) were evaluated in the risk assessment under each
exposure scenario. Those contaminanu identified as posin8 unacceptable health risks are presented
here.
NA Not Applicable
-------
RESPONSIVENESS SUMXARY POR THE
KIDWEST MANUFACTURING/NORTH FARK SUPERFUND SITE
KIDWEST OPERABLE UNIT
KELLOGG, IOWA
This Responsiveness Summary presents the responses of the
United states Environmental Protection Agency (EPA) to the
comments received during the public comment period conducted as
part of the remedy selection process for the Midwest Subsite of
the Midwest Manufacturing/North Farm Superfund site.
INTRODUCTION
On August 22, 1990, EPA announced the availability of its
Proposed Plan for the remedial action at the Midwest Subsite of
the Midwest Manufacturing/North Farm Superfund Site. Notice of
the availability of the proposed plan and the administrative
record upon which EPA intended to base its remedy selection
decision was published in the Newton Dailv News. This notice
alse) requested the pUblic's comments on the proposed plan and
indicated the period during which public comments received by EPA
would be considered in the decision-making process. A fact sheet
in which the various remedial alternatives were described,
including identification of a preferred alternative, was mailed
to persons who had previously expressed an interest in this site.
A public meeting was held in Kellogg, Iowa, on September 12,
1990, to receive comments. Copies of the proposed plan and fact
sheet were made available to persons attending the public
meeting. A transcript was made of the public meeting. That
transcript was consulted in preparation of this responsiveness
summary. Copies of the transcript are included with the
administrative record file for public review.
-------
PUBLIC COMXENTS
The comments received in on the Proposed Plan and EPA's
response to these comments are set forth below.
The EPA received comments pertaining to the cost of the
remedial action alternatives considered for the Site. These
comments generally fell into the following categories.
1. Can the Superfund Tru.t fund pay for a .ite cleanup?
Superfund was established by Congress as a trust fund under
the Comprehensive Environmental Response, Compensation and Li-
ability Act. Money for Superfund in large part comes from taxes
paid by companies which produce various chemical substances, from
costs (including fines and punitive damages) recovered from
responsible parties, and, to a lesser, extent, from Government
general revenue. The trust funds are to be used if an immediate
response is required, whether or not there is a possibility of
recovery from responsible parties; or where no responsible party
with adequate funds to pay for investigation and cleanup can be
found. If Superfund money is used for cleanup then the EPA is
bound by statute to attempt to recover these monies from respon-
sible parties. These include waste generators, waste haulers,
landowners, etc.
2. Can EPA hold parties liable even though their disposal of
hazardous waste was proper, lawful, or .pecifically authorized by
a regulatory agency at the time?
The general policy of CERCLA is that the persons responsible
for creation of the problem are responsible for paying for reme-
dying the problem. CERCLA provides that the persons who generat-
ed the wastes, arranged for disposal of the wastes and owned the
site at which the wastes were disposed of are responsible for the
costs of cleaning up the site. Liability for response costs
under CERCLA do not depend upon compliance or noncompliance with
past requlatory requirements.
Under CERCLA's special notice procedure, the persons
believed to be responsible are giv~n the opportunity to undertake
or finance the response action before the Superfund monies are
used to do so. If the responsible parties are unwilling or
unable to finance or implement the remedy, EPA would consider
spending Superfund monies to do so. When Superfund monies are
used to finance the remedy, it is the policy of EPA to seek
recovery of those response costs from the responsible parties.
It is the policy of EPA to seek full recovery of all response
costs. .
2
-------
3. Did the SPA design and approve of the vaste -disposal
cell used ~y the Midwest Manutacturing Company to dispose ot
their electroplating vastes?
No, the Agency did not approve or design the disposal cells
used by the company to dispose of its hazardous waste.
During the public meeting several persons voiced their
concern regarding EPA's intentions to remediate the Midwest
Operable Unit. These persons felt that requirement of CERCLA,
which requires the potential responsible parties (PRPs) to pay
the cleanup costs, would place an economic hardship on both the
PRPs and the community. Provided below are several of the major
comments given by members of the community.
statement of Glen DeZwarte
I'm Glen DeZwarte. I live about three miles south of here. I
gue.ss, not knowing a great deal when I came here but having a
concern for this community and this town and the surrounding
areas, I find it real difficult how this company can begin to
survive if it is asked to bring up this much money to pay for
this. I think it, to me, would have to bankrupt the company which
would cost the community many jobs, cause a loss of students in
schools, and would have a lasting effect on this community and
would be devastating to it. And I guess I would like to see, for
the benefit not only for the company, but for the people in the
community, that the company not have to pick up the tab and the
costs, whatever needs to be done. Should have repair work, or
whatever needs to be done, be done at a minimal cost. And I guess
I also find it hard when I talk about--hear things that happened
in 1950 and the early seventies, why this company is required to
pick up the tab.
That means that if I own a gas station, and hire--and sell
it to a, quote, Domino's Pizza, and there is found that there is
contaminants under this old gas station, who's qoing to be re-
sponsible for digging it up? Is it qoinq to be Domino's Pizza, or
is it going to be possibly my estate? I guess I have figured out
wheJre all the blame lies and who's going to pick it up, because
my concern is we're trying to be able to keep this factory in
this community.
statement of Virgil Redding
My name is Virgil Redding. I've lived here all my life, and
I huve to refer back to the statement that was just made from
Midwest that seems as though every so often things change. You
folks will come around here and say it's got to be done this way.
Well, ten years, people who succeed you come around and say,
"That's wrong. We got to do it some other way." When is this
3
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going to stop? It's costing the taxpayers, and we aren't gaining
anything.
We found out from the landfills when that started, I said,
in my own mind, anyway, that it would never work. Well, it's
coming back now, and it isn't working. We're having to drain
water out of them, do this, and do that. We're still back to
square one again. We aren't gaining a thing, and it's costing
taxpayers billions of dollars.
Statement of Lois Pickles
Well, my name is Lois Pickles, and I've worked at the facto-
ry for 30 years, and at all times, they have made efforts to keep
everything safe and clean. And sometimes it gets a little messy,
but then it's a factory. It's not an apartment house.
And it seems to me like every two years, or at the time of
an election, this all comes back up, and I think that maybe part
of it is pOlitical, not necessary.
William King who represented Kidwest Manufacturing read the
following written statement on behalf of David Sandeen who is the
President of Kidwest Manufacturing.
In my absence, I have in advance prepared the following
statement with some comments and observations representing the
opinion of the owners and senior management of Midwest Manufac-
turing Company. .
I want to clarify that Midwest is not opposed to hazardous
waste cleanup and in general cleaning up our total environment.
What we are opposed to is the method of handling this cleanup and
the EPA's insistence that the financial responsibility belongs to
Midwest.
Over the past 17 years, the current owners of Midwest have
made a commitment to the environment evidenced in part by the
following:
Item 1: The pond area south and west of the manufacturing
facility was literally loaded with jUnk, paint drums, oil drums,
and et cetera. This area has been completely cleaned out.
Item 2: All scrap and open containers setting around the
buildings at the time of purchase have been cleaned up.
Item 3: A new oil recovery system to further extract oil for
machining chips was installed.
Item 4: Numerous process improvements have been implemented
to minimize dust, smoke, fumes, etc.
4
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Item 5: Numerous ventilation programs have been implemented
within the manufacturing facility to clean up the environment.
Item 6: Most importantly, in the early 1970's, Midwest
accepted its responsibilities to discontinue discharging hazard-
ous wastes created from its plating and painting facility into
the North Skunk River. We diligently worked with our engineering
firm and the Environmental Protection Agency, EPA, in Kansas
City, as well as, at that time, the Iowa Department of Environ-
mental Quality, IDEQ~
Through the efforts of these two groups, a plan was de-
veloped, approved and implemented to chemically treat hazardous
waste, and thus, allow for discharge of nonhazardous water into
the North Skunk River. A part of this plan consisted of providing
areas for disposal of the hazardous materials that were generated
as a part of the chemical treatment process. Initially, this
waste was transported to a fully-approved holding pond on land
leased from Merl Brown to Midwest. This is now referred to by EPA
as the North Farm Site. Later on, it was agreed that if a holding
pond were constructed closer to the plant facility, the plant
would run more economically.
In the mid 1970's, this holding area, constructed at the
Midwest site, was built under the direct supervision of EPA and
IDEQ personnel.
In the early 1980's, Midwest determined the profits generat-
ed from its plating and paint operation were no longer sufficient
to cover the cost of water treatment and related expenses. In
1981, the product lines were discontinued, and at that time the
plating and painting operations were closed down. At that time,
Midwest asked for assistance from the various regulatory agencies
as to the proper close-down of the holding ponds. We received no
assistance until more than six years later representatives from
the EPA Superfund appeared at our doorstep advising they were
going to assist us in removing our name from the EPA Superfund
list.
Unfortunately, as with most bureaucratic organizations,
there was no easy cost-effective answer. On July 30, 1987, repre-
sent,atives from EPA Superfund toured the Midwest facilities and
stated, due to the low volume which has been produced and the
current condition of the area, this would probably be a walk-away
situation.
Shortly after that visit, we began receiving from EPA large
volumes of questionnaires and requests for historic data that we
gathered and presented to them. They also, at that time, request-
ed Midwest to assume financial responsibility for both the North
5
-------
Farm and Midwest facility investigation and cleanup. In the fall
of 1987, I met with EPA officials in Kansas city during which
time they advised the cost could run as high as $250,000, to
which I replied that we were not willing to accept the financial
responsibility for the program.
A recent edition of the "Newton Daily News" stated the
cleanup portion of the North Farm Site was budgeted at $221,000;
however, that is only a portion of the cost which EPA is attempt-
ing to recover. Based on the latest information we have avail-
able, the following are the cost estimates to clean up both the
North Farm and the Midwest site.
Item A: Expenses incurred as of November 4, 1988 relating to
the Remedial Investigation/Feasibility Study for the North Farm
Site, $350,666.17.
Item B: EPAls cleanup recommendation for the North Farm
Site, $221,000.
Item C: Estimated Remedial Investigation/Feasibility Study
for the plant site, $600,000.
Item D: Alternative #2 cleanup for the Midwest plant site,
$488,844, which comes to a total of $1,660,510.
It should a1so be noted, at various times, Midwest gave the
EPA names and contacts of companies who had quoted the Remedial
Investigation/Feasibility Study and cleanup costs approximately
1/4 or 1/5 of those costs noted above. EPA responded that they
could not use any of these bids as they were committed to
companies under national contracts.
In conclusion, to the best of our knowledge, Midwest has not
violated any laws, and, in fact, has complied with every request
made in the construction and implementation of the waste treat-
ment facility, both with the Iowa DEQ and EPA. They are now
telling us this is not acceptable, and we must correct the situa-
tion.
This would be similar to an individual property owner re-
questing a building permit to build a home, and then find out a
year after the home has been constructed that the permit is no
longer valid, and thus, requiring the house to be torn down,
removed, and the land brought back to its natural state.
Representatives of the EPA have continually advised Midwest
that the parties responsible for creating the hazardous waste
should bear the financial responsibility of cleanups. We believe
that since we did everything under the direction of EPA and IDEQ,
they are the responsible party and, in fact, created the hazard-
ous waste area, and thus, are financially responsible for cleanup.
€
-------
Mz'. Sandeen'. comments have been summari.ed below, and each point
has an individual response.
1. OVer the pa.t
8ade a commitment
cleaning up drums
improvement..
Cleaning the drums and rubbish around the site does not mean
that any contamination that had previously leached into the
environment has been addressed. During site investigations
conducted in October 1989 and April/May 1990, twelve buried drums
were noted to remain in the marshy borrow pit area at the Site.
17 year., the current owner. of Kidwe.t have
to the environment evidenced in part by
and 8crap, a. .ell a. in.talling proce..
2. Midwest accepted its responsibilities to di.continue
dincharging hazardous wastes into the North Stunt River.
Midwest Manufacturing Co. was required to install the waste
water treatment plant by the NPDES permit program (National
Pollutant Discharge Elimination System), now regulated under the
Clean Water Act.
3. Midwest diligently worted with its eng~n..ring firm, BPA, and
the State of Iowa to develop and implement a plan to chemically
treat hazardous waste, in order to allov for discharge of non-
hazardous water into the North stunt River.
The predecessor to Smith Jones, Inc., Midwest International,
Inc., entered into a Consent Order with the Iowa Department of
Environmental Quality (IDEQ) (now the IDNR) on February 24, 1972.
The Order required Midwest to prepare plans to construct
facilities to eliminate the discharge of toxic wastes by May 1,
1972. When Smith Jones purchased Midwest in 1973, the Order had
already been extended twice at the request of Midwest, and was
amended again on November 1, 1973, to extend deadlines. The Order
was subsequently amended three more times at Midwest's (Smith
Jones') request. The implementation of a waste water treatment
facility, a requirement of the Order, was not accomplished until
197"7. The wastewater treatment facility never was able to comply
with the NPDES regulations. Midwest ceased all plating
oper.ations in June 1981.
4. A part of the approved plan developed by Xidwe.t con.i.ted ot
pro,riding area. for dispo.al of the hazardous .ateria18. It .a.
agreed that if a bolding pond .ere constructed clo.er to the
plant facility, the plant .ould run .ore economically. In the
.id-1970'8 a bolding area .a. con.tructed at the Xidwe.t 8ite,
and vas built under the direct .upervi.ion of BPA and IDEQ
personnel.
7
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The NPDES permit program mentioned above only regulates
discharges to waters of the United States. Thus, under that
authority EPA could and did regulate Midwest's discharge to the
river; however, EPA could not and did not regulate what Midwest
did with its treatment residuals. EPA's hazardous waste
regulations (CERCLA and RCRA) were not enacted into law until
1980, and therefore EPA had no regulatory authority to manage the
disposal of hazardous waste.
EPA did not express an opinion regarding the economics of
constructing a holding pond near the plant facility. Further,
EPA did not supervise the construction of the holding area.
5. In 1981 Midwest a.ked for a..istance from the various
requlatory agencies as to the proper close-down of the holding
ponds.
EPA has no records in its files that indicate a request from
Midwest regarding information as to closure of its holding
ponds.
6. On July 30, 1987, BPA representatives .tated that due to the
low volume of waste and the current condition of the area, this
would probably be a walk-away situation.
EPA representatives did not state that the agency would walk
away from this Site. However, EPA did inform Midwest that the
investigation would be performed by EPA, and that it is EPA's
policy to consider a "no action" alternative in its Feasibility
Study. However, this alternative cannot be considered as a
remedy if it does not meet the two threshold criteria of overall
protectiveness of human health and the environment and compliance
with ARARs.
7. At various times, Midwest gave the BPA names of companie. who
had quoted the RIIFS and clean up costs approximately 114 or 1/5
of EPA's estimated costs. SPA responded that they could not use
any of these bid. as they were committed to companie. UDder
national contract..
Midwest hired one consultant that gave Midwest an estimate
lower than what EPA had estimated the investigation would cost.
The consultant had no previous Superfund experience, and EPA was
not provided a breakdown of the items in the estimate to assess
whether all procedures required by regulation and policy were
included. Further, this consultant never provided a bid to EPA
for its consideration. EPA is unaware of any other companies
consulted by Midwest.
EPA gave Midwest two opportunities to perform or finance the
investigation, using the engineering consulting firm of its
choice. However, Midwest declined to perform or finance the
8
-------
investigation. EPA then performed the investigations using its
contractors. EPA does have national contracts, which rely on
standard work plans as a means of utilizing economies of scale.
8. Midwest has not violated any laws, and, in fact, ha. complied
witb every request 88de in the construction and implementation of
the vaate treatment facility.
Under the provisions of CERCLA, liability for response costs
doe:s not depend upon compliance or non-compliance with past
regulatory requirements.
9
-------
STATE OF'
I
DEPARTMENT OF NATURAL RESOURCES
LARRY J. WILSON. CIRLC10"
TERRY E. BRANST AO. GovERNOR
Robert Morby, Chief
Su~rrund Br4I.Dch
U.S. EnwoM'lenta! Prote.ction Agency
Region VII
726 Minnesota Ave,
KAnsas City, KS 66101
RECEIVED
SEP ? 5 1990
~EMD :)t.~ l1VN
RE: Proposed Plan (or the Midwest Manufacturing./Nortb Farm Site
Midwest Subsite
Kellogg. Iowa
Dear Bob:
We have reviewed the Proposed P/4S'I for the Mjdwest Subsite and would lil>e to emphasiu this dep41tmeDt's
position witb res~ct to groundwater ..ctions. The 1985 Jowa ~~Iature m~d:sled tbat a groundwater protection
stnstC:g)' be devel0pe.d in respvnse to grO\l.1ng COnCtfm of groundwater cont4JIUnalion. A two.ye41 pl0",1 t") / ~, 5 :>A 1."> 145
-------
In conclusion, we concur with the prerened allernative as pre$CDled in the Propo$Cd Plan. Plc:a.se CODt3Ct me
if you have any further CODCCrtl.i reg:uding this sile.
ff~ If!~
Monis Preston
S u pc rvisor
Solid Waste Section
-------
DOCUMENT DATE: 04/28/82
NUMBER OF PAGES: 90
AUTHOR: Jackson, Dave, Team
COMPANY/AGENCY: Ecology and
RECIPIENT: William Keffer
DOCUMENT TYPE: Report
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
1.5
Leader
Environment, Inc.
Report Entitled: "Site Investigation Plan for
Midwest Manufacturing, Itellogg, Iowa"
DOCUMENT DATE: 08/03/82
NUMBER OF PAGES: 123
AUTHOR:
COMPANY/AGENCY: Ecology and
RECIPIENT: William Keffer
DOCUMENT TYPE: Report
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
1.5
Environment, Inc.
Report Entitled: "Full Field Investigation
Report for Midwest Manufacturing Company,
Kellogg, Iowa"
DOCUMENT DATE: 08/04/82
NUMBER OF PAGES: lS
AUTHOR:
COMPANY/AGENCY: Region VII, U.S. EPA
RECIPIENT:
DOCUMENT TYPE: Preliminary Assessment
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
1.5
Report Entitled: "Potential Hazardous Waste
Site Identification and Preliminary Assessment"
for Midwest Manufacturing, Kellogg, Iowa
DOCUMENT DATE: 12/28/83
NUMBER OF PAGES: 54
AUTHOR: Roberts, Mark
COMPANY/AGENCY: Ecology and Environment, Inc.
RECIPIENT: William Keffer, RPO
DOCUMENT TYPE: Report
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
1.5
Report Entitled: "Field Investigation Report
North Farm Site of the Midwest Manufacturing
Company, ltell09g, Iowa"
).
-------
DOCUMENT DATE: 03/19/85
NUMBER OF PAGES: 14
AUTHOR:
COMPANY/AGENCY: Region VII, U.S. EPA
RECIPIENT:
DOCUMENT TYPE: Site Inspection
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
1.5
"Potential Hazardous Waste Site, Site
Inspection Report", EPA Form 2070-13 for
Midwest Manufacturing/North Farm Site, Xellogg,
Iowa
-------
DOCUMENT DATE: 09/21/89
NUMBER OF PAGES: 2
AUTHOR: Trugley, Dana
COMPANY/AGENCY: Remedial Section, SPFD Branch, Waste Management
Division
RECIPIENT: Morris Preston, Supervisor of Solid Waste Section,
Iowa Department of Natural Resources
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
3.1
Letter re: Transmittal of RI/FS Work Plan,
POP/QAPP and the Health and Safety Plan to the
State
DOCUMENT DATE: 03/14/90
NUMBER OF PAGES: 1
AUTHOR: Trugley, Dana
COMPANY/AGENCY: Remedial Section, Superfund Branch, Waste
Management Division
Thayer, Iowa Department of Natural Resources
Correspondence
RECIPIENT: Jim
DOCUMENT TYPE:
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
3.1
Letter re: Transmittal of the Preliminary
Remedial Investigation Report (Not Attached)
DOCUMENT DATE: 03/20/90
NUMBER OF PAGES: 1
AUTHOR: Trugley, Dana .
COMPANY/AGENCY: Remedial Section, Superfund Branch, Waste
Management Division
RECIPIENT: David Sandeen, Smith-Jones, Midwest Division
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
3.1
Letter re: "Transmittal of Remedial
Investigation Data" (Not Attached)
DOCUMENT DATE: 04/10/90
NUMBER OF PAGES: 5
AUTHOR: Thayer, Jim, Environmental Specialist
COMPANY/AGENCY: state of Iowa
RECIPIENT: Dana Trugley, Remedial Section, Superfund Branch,
Waste Management Division, Region VII, U.S. EPA
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
3.1
Letter re: Review of the Preliminary Remedial
Investigation Report
1
-------
DOCUMENT DATE: 04/26/90
NUMBER OF PAGES: 1
AUTHOR: Truqley, Dana
COMPANY/AGENCY: Remedial section, Superfund Branch,
Manaqement Division
Stevenson, City Water supervisor
Correspondence
Letter re: .Transmittal of Remedial
Investiqation Data" (Not Attached)
RECIPIENT: Jay
DOCUMENT TYPE:
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
3.1
Waste
DOCUMENT DATE: 07/21/89
NUMBER OF PAGES: 37
AUTHOR:
COMPANY/AGENCY: Sverdrup Corporation
RECIPIENT:
DOCUMENT TYPE: Health and Safety Plan
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
3.2
Report Entitled: "Health and Safety Plan,
Midwest Operable Unit of Midwest
Manufacturinq/North Farm Superfund Site,
Kelloqq, Iowa"
DOCUMENT DATE: 08/28/89
NUMBER OF PAGES: 87
AUTHOR:
COMPANY/AGENCY: Sverdrup corporation
RECIPIENT:
DOt~NT TYPE: RI/FS Report
REFERENCE: No
DOCUMENT TITLE:
CA'I'EGORY:
3.2
Report Entitled: "Project Operations
Plan/Quality Assurance Project Plan Summary
Document for the RI/FS at the Midwest Operable
Unit Midwest Manufacturinq/North Farm Superfund
Site, Relloqq, Iowa"
DOCUMENT DATE: 08/28/89
NUMBER OF PAGES: 24
AUTHOR:
COMPANY/AGENCY: Sverdrup Corporation
RECIPIENT:
DOCUMENT TYPE: Work Plan sWIm1ary
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
3.2
Report Entitled: .Work Plan Summary Document
for the RI/FS at the Midwest Operable unit of
the Midwest Manufacturing/North Farm Superfund
Site, Relloqg, Iowa"
2
-------
DOCUMENT DATE: 09/01/89
NUMBER OF PAGES: 15
AUTHOR:
COMPANY/AGENCY: Sverdrup Corporation
RECIPIENT: EPA
DOCUMENT TYPE: Work Plan
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
3.2
Report Entitled: -Final Work Plan, Midwest
Manufacturing RI/FS and Technical Support"
DOCUMENT DATE: 03/23/90
NUMBER OF PAGES: 14
AUTHOR: Bockelmann, David J.
COMPANY/AGENCY: Sverdrup Corporation
RECIPIENT: Dana Trugley, Region VII, u.S. EPA
DOCUMENT TYPE: correspondence/Work Plan
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
3.2
Letter re: Transmittal of the "Midwest Operable
Unit, Draft Work Plan, Amendment No.1"
DOCUMENT DATE: 09/23/87
NUMBER OF PAGES: 48
AUTHOR: Takade, Dennis Y., site Manager, Michael L. Kiefer, REM
II Region VII Manager
COMPANY/AGENCY: Woodward-Clyde Consultants
RECIPIENT: Robert L. Morby, Gale A. Wright, Dana Trugley
DOCUMENT TYPE: correspondence/RIfFS Scoping Report
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
3.4
Letter re: Transmittal of the Report Entitled:
"Site Evaluation and RI/FS Scoping Document,
Smith-Jones/Midwest Division Plant Site,
Kellogg, Iowa"
. DOCUMENT DATE: 12/17/87
NUMBER OF PAGES: 2
AUTHOR: pericich, Sigrid A., Senior Staff Engineer: Dennis Y.
Takade, Site Manager
COMPANY/AGENCY: Woodward-Clyde Consultants
RECIPIENT: Dana Trugley, Regional Project Manager, Superfund
Branch, Region VII, U.S. EPA
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
CATtGORY:
3.4
Letter re: Errata Sheet for site Evaluation and
RI/FS Scoping Document for the
Smith-Jones/Midwest Division Plant Site Dated
9-23-87
3
-------
DOCUMENT DATE: 09/22/90
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT: Region VII, U.S. EPA
DOCUMENT TYPE: RI Report and Risk Assessment Report
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
3.5
Report Entitled: Remedial Investigation (RI)
Report and Risk Assessment Report tor the
Midwest Manufacturing/North Farm, Operable Unit
2, Superfund Site (Report Dated August 1990)
-------
DOCUMENT DATE: 09/23/90
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT: Region VII, U.S. EPA
DOCUMENT TYPE: Feasibility Study
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
4.5
(FS) Report
Report Entitled: Feasibility Study (FS) Report
for the Midwest Manufacturing/North Farm,
Operable Unit 2, Superfund Site (Report Dated
August 1990)
-------
DOCUMENT DATE: 09/23/90
NUMBER OF PAGES: 27
AUTHOR:
COMPANY/AGENCY:
RECIPIENT: Region VII, U.S. EPA
DOCUMENT TYPE: Proposed Plan
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
5.6
Report Entitled: Proposed Plan for the Midwest
Manufacturing/North Farm, Operable Unit 2,
Superfund site (Report Dated August 1990)
-------
DOCUMENT DATE: 04/14/81
NUMBER OF PAGES: 6
AUTHOR: Williams, steve
COMPANY/AGENCY:
RECIPIENT: Smith-Jones, Inc.
DOCUMENT TYPE: Memorandum
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
11.6
Memorandum re: Smith-Jones Indicates Intentions
to Discontinue Plating Operations by 6-30-81
DOCUMENT DATE: 09/29/87
NUMBER OF PAGES: 10
AUTHOR: Kay, Morris, Regional Administrator
COMPANY/AGENCY:
RECIPIENT: Dave Sandeen, President, Smith-Jones, Inc. - Midwest
Division
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
11. 6
Letter re: EPA's Special Notice Letter and 104e
Request
DOCUMENT DATE: 11/13/87
NUMBER OF PAGES: 16
AUTHOR: Sandeen, David, President
COMPANY/AGENCY: Midwest Manufacturing Company
RECIPIENT: Dana Trugley, Superfund Branch, Region
DOCUMENT TYPE: correspondence
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
11.6
VII, u.S. EPA
Letter re: smith-Jones Response for the EPA's
Special Notice Letter and 104e Request
DOCUMENT DATE: 12/23/87
NUMBER OF PAGES: 10
AUTHOR: Wagoner, David A., Director
COMPANY/AGENCY: Waste Management Division
RECIPIENT: David E. Sandeen, President, Smith-Jones,
Inc./Midwest Division
DOCUMENT TYPE: correspondence
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
11.6
Letter re: EPA's Response to Smith-Jones
Refusal to Conduct a Rl/FS
1
-------
DOCUMENT DATE: 12/29/87
NUMBER OF PAGES: 6
AUTHOR: Sandeen, David E., President
COMPANY/AGENCY: Midwest Manufacturinq Company
RECIPIENT: Dana Truqley, Superfund Aqency, Reqion VII,
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
u.S. EPA
Letter re: Submittal of Additional Information
to Supplement 1048 Response by Smith
Jones/Midwest Division
CATEGORY:
11.6
DOCUMENT DATE: 03/20/90
NUMBER OF PAGES: 1
AUTHOR: Truqley, Dana
COMPANY/AGENCY: Remedial section, Superfund Branch, Waste
Manaqement Division
RECIPIENT: David Sandeen, Smith-Jones, Midwest Division
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
Letter re: Transmittal of Remedial
Investiqation Data
CA'rEGORY:
11.6
-------
DOCUMENT DATE: 07/26/88
NUMBER OF PAGES: 26
AUTHOR: Barrett, Leslie L., Douglas E. Fiscus, Dennis Y.
COMPANY/AGENCY: Woodward-Clyde Consultants
RECIPIENT: Dana Trugley, Regional Project Manager, Steve
DOCUY.ENT TYPE: Correspondence/Community Relations Plan
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
13.2
Takade
Wurtz
Letter re: Attached Report Entitled: "Final
Community Relations Plan for Midwest
Manufacturing/North Farm Site in Kellogg, Iowa"
-------
DOCUMENT DATE: 03/14/90
NUMBER OF PAGES: 2
AUTHOR: Trugley, Dana
COMPANY/AGENCY: Remedial section, Superfund Branch, Waste
Management Division
RECIPIENT: Sheila Huff, Department of Interior, Superfund
Coordinator
DOCUMENT TYPE: Correspondence
R1~FERENCE : No
DOCUMENT TITLE:
Letter re: Transmittal of two Copies of the
Draft Preliminary Remedial Investigation Report
(Not Attached)
CATEGORY:
16.1
DOCUMENT DATE: 04/26/90
NUMBER OF PAGES: 1
At~OR: Nelson, Richard C., Field Supervisor
COMPANY/AGENCY: United States Department of the Interior
RECIPIENT: Dana Trugley, Superfund Branch, Region VII, U.S. EPA
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
Letter re: Response to the Draft Preliminary
Remedial Investigation Report
CATEGORY:
16.1
-------
DOCUMENT DATE: 02/20/90
NUMBER OF PAGES: 4
AUTHOR: Price, Ceil, Assistant Regional Counsel
COMPANY/AGENCY: Region VII, U.S. EPA
RECIPIENT: steven B. Nosek, Dunkley, Bennett & Christensen,
P.A.
DOCUMENT TYPE: correspondence
REFERENCE: No
DOCUMENT TITLE:
Letter re: .Smith Jones, Inc./Midwest
Manufacturing Plant Access" and the Transmittal
of Information .
CATEGORY:
17.1
DOCUMENT DATE: 02/21/90
NUMBER OF PAGES: 2
AUTHOR: Nosek, steven B. .
COMPANY/AGENCY: Dunkley, Bennett
RECIPIENT: Ceil Price, Assistant
U.s. EPA
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
& Christensen, P.A.
Regional Counsel, Region VII,
Letter re: Will Not Consider an Amended or
Expanded Access Agreement on Smith Jones, Inc.
CATEGORY:
17.1
DOCUMENT DATE: 02/27/90
NUMBER OF PAGES: 2
AUTHOR: Price, Ceil, Assistant Regional Counsel
COMPANY/AGENCY: Region VII, U.S. EPA
RECIPIENT: Steven B. Nosek, Dunkley, Bennett & Christensen,
P.A.
DOCUMENT TYPE: correspondence
REFERENCE: No
DOCUMENT TITLE:
Letter re: .Smith Jones, Inc., Midwest
Manufacturing Site Access"
CATEGORY:
17.1
DOCUMENT DATE: 03/14/90
NUMBER OF PAGES: 6
AUTHOR: Price, Ceil, Assistant Regional Counsel
COMPANY/AGENCY: Region VII, U.S. EPA
RECIPIENT: Steven B. Nosek, Dunkley, Bennett' Christensen,
P.A.
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
Letter re: Transmittal of the Amemded Access
Agreement tor Execution by Recipient's Client
CATEGORY:
17.1
1
-------
DOCUMENT DATE: 03/14/90
NUMBER OF PAGES: 1
AUTHOR: Nosek, Steven B.
COMPANY/AGENCY: Dunkley, Bennett
RECIPIENT: Ceil Price, Assistant
u.S. EPA
~)CUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
17.1
& Christensen, P.A.
Regional Counsel, Region VII,
Letter re: Requesting an Amended Access
Agreement
DOCUMENT DATE: 03/15/90
NUMBER OF PAGES: 1
AUTHOR: Nosek, steven B.
COMPANY/AGENCY: Dunkley, Bennett
RECIPIENT: Ceil Price, Assistant
u.s. EPA
DOCUMENT TYPE: correspondence
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
17.1
, Christensen, P.A.
Regional Counsel, Region VII,
Letter re: Did Not Agree to the Activities set
forth in Nos. 2, 3 or 7 of Section 3 of the
Access Agreement
DOCUMENT DATE: 03/15/90
NUMBER OF PAGES: 3
AUTHOR: Price, Ceil, Assistant Regional Counsel
COMPANY/AGENCY: Region VII, U.S. EPA
RECIPIENT: Steven B. Nosek, Dunkley, Bennett & Christensen,
P.A.
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
CA'rEGORY:
17.1
Letter re: Transmittal of the Revised Page One
of the Amended Access Agreement
DOCUMENT DATE: 03/19/90
NUMBER OF PAGES: 1
AUTHOR: Nosek, Steven B.
COMPANY/AGENCY: Dunkley, Bennett'
RECIPIENT: Ceil Price, Region VII,
DO<::uMENT TYPE: correspondence
REFERENCE: No
DOC::t1KENT TITLE:
CATEGORY:
17.1
Christensen, P.A.
u.s. EPA
Letter re: PRP Agreeable to Execute the Amended
Acc.s.-Agreement
-.".
2
-------
DOCUMENT DATE: 03/22/90
NUMBER OF PAGES: 10
AUTHOR: Price, Ceil, Assistant Regional Counsel
COMPANY/AGENCY:
RECIPIENT: Steven B. Nosek, Dunkley, Bennett & Christensen,
P.A.
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
Letter re: Client Willing to Sign the Proposed
Access Agreement
CATEGORY:
17.1
DOCUMENT DATE: 03/29/90
NUMBER OF PAGES: 2
AUTHOR: Nosek, Steven B.
COMPANY/AGENCY: Dunkley, Bennett' Christensen, P.A.
RECIPIENT: Ceil Price
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
CATEGORY: 17.1
Letter re: Transmittal of the Term of Agreement
DOCUMENT DATE: 03/30/90
NUMBER OF PAGES: 1
AUTHOR: Nosek, Steven B.
COMPANY/AGENCY: Dunkley, Bennett
RECIPIENT: Ceil Price, Assistant
u.S. EPA
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
& Christensen, P.A.
Regional Counsel, Region VII,
Letter re: Transmittal of the Amended Access
Agreement (Not Attached)
CATEGORY:
17.1
DOCUMENT DATE: 04/11/90
NUMBER OF PAGES: 1
AUTHOR: Price, Ceil, Assistant Regional Counsel
COMPANY/AGENCY:
RECIPIENT: Steven B. Nosek, Dunkley, Bennett' Christensen,
P.A.
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
Letter re: Transmittal of the Executed Access
Agreement (Not Attached)
CATEGORY:
17.1
3
-------
DOCUMENT DATE: 05/02/90
NUMBER OF PAGES: 4
AUTHOR: Price, Ceil, Assistant Regional Counsel
COMPANY/AGENCY: Region VII, U.S. EPA
RECIPIENT: Steven B. Nosek, Dunkley, Bennett' Christensen,
P.A.
DOCUMENT TYPE: Access Agreement
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
17.1
Transmittal of a Second Amended Access
Agreement
DOCUMENT DATE: OS/24/90
NUMBER OF PAGES: 5
AUTHOR: Price, Ceil, Assistant Regional Counsel
COMPANY/AGENCY:
RECIPIENT: Steven B. Nosek, Dunkley, Bennett' Christensen,
P.A.
DOCUMENT TYPE: Access Agreement
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
17.1
Transmittal of the Second Amended Access
Agreement
DOCUMENT DATE: 02/26/87
NUMBER OF PAGES: 1
AUTHOR: Wagoner, David A., Director
COMPANY/AGENCY: Waste Management Division
RECIPIENT: Larry J. Wilson, Director, Iowa
Natural Resources
DO'~NT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
CATEGORY:
17.10
Department of
Letter re: EPA's Request for ARAR's from the
state
DOCUMENT DATE: 07/01/87
NUMBER OF PAGES: 5
AUTHOR: Wagoner, David A., Director
COMPANY/AGENCY: Waste Management Division
RECIPIENT: Larry o. Wilson, Director, Iowa
Natural Resources
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
CAT:EGORY:
17.10
Department of
Letter re: EPA's Request for AltAR's from the
State
4
-------
DOCUMENT DATE: 07/29/87
NUMBER OF PAGES: 18
AUTHOR: Stokes, Allan E., Administrator
COMPANY/AGENCY: Environmental Protection Division, state of
Iowa .
RECIPIENT: Dana Truqley, Superfund Branch, Reqion VII, u.s. EPA
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE:
Letter re: State's Transmittal of Potential
ARAR's
CATEGORY:
17.10
-------
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r ' .
12:39
P.02
.,
. J'"p ...~,
{sJ
.~'II./
VNlTEO n A rES ENVIRONMENTAL PROiECTION AGENCY
WASHINGTON. D.C. 2046:1
JAN 2 9 I99C
MEMORABDVK
ur.,c~c.
'OIo,C ""''''1''1 &"'0 IiVlI80''''CV II\.S.O"'S~
SOBJEC1':
TWen~y F1rst Rem.dr, Del.
Don R. Cla~"'';
Assistan~ ~1~tra
TO :
Req10nal ~4m1n1st at
Regions I-X
FROM:
PURPOSE:
To delegate selection of remedy author1ty tor all Superfund
Records of Decision (RODs; scheduled for s1qnature Curing rr '0.
BACKGROUND:
EPA D81eqation of Authority 14-5 authorizes deleqation of
r.~Qdy salection decisions to the Reqlonal Administrators. These
~roQeduras are outlined in OSWER Directive 9260.1.9, dated
March 24, 1986. To further streamline this process ana
!acili~.te planninq, I am deleqatinq all RODs scheduled for
ai9natura durlnq FY 90 which are lilted in CERCLIS and tarqete~
~or completion. Soma RODg may requ1re consultation as ~escribed
below. Our objQ~tiv. ia to provide Re~ional ~anaqernent Qreater
control for mQQti~9 project co~itm.nts by providin; broad
delegation of RODc, and by rQd~cin9 incominq submittals and the
~umber ot Headquart8ra' formal consultations.
At your discretion, this authority ~ay ba r.dQl.9at.~ to tha
Depu~y ~.gional Administrator.
ZMPL!M!NTA'I':ON.
The reme~lal actions dele9ated 1n this report are tho~e
current SPMS FY 90 ROD targets (includin9 alternate~) listed in
CERCLIS as of January 9, 1990 (see attache~). It rour Re9ion ha,
revisions to th1S list curing the year) a De~oran~um tQ
Head~art.rs requesting ~ele9ation of ad01t1onal RODS w111 be
requ.red. For:al Reqlonal consultation w1tn Headquarters D1v1s1~~
Cirector in OERR (Fund-lead) or OWPE (Enforcement-lead), or
respective Office Director or AA I' appropriate, is required onl}'
tor the followinQ 11aited 8ituations where the proposed reme~l:
-------
-=-UG-20-90
MON
12:40
P.03
.~
-2-
exceeQa $30 million
utilizes a tund balancing waiver [SARA 121(d) (4))
involves real property acquisition for a fund-financed
response
involves a ROD amendment result!n; from PRP settle~ent/
neQotiations
involves nationally precedent-settinq issues, e.g.
reme4iation of dioxin vastes, complex area-wide
contamination, etc.
This consultation should occur p~ior to issuance of the Proposed
Plan or amended Proposed Plan.
In addition to on-901n9 coordination between Remedial Project
Manager. and Headquarters' Regional Coordinat~rs (OERR/O~PE),
Region; ~ust con~ult wi~h tha appropriate Headquarters Sranch Chie~
tor tho.e 8ites where th~re 18 an Explan~tion of S19nit1c~nt
Difference. (..0) planne~, and .ho~ld oonsul~ on an unresolved
issue relating to State oonourrenoe, ARAR oo~plianoe or use of
waivers, PRP 8Qttl.mQnt/n.~otia~ion8, multi-.ource groundwater
contamination, risk a.s...men~, permanent relocation, or o~her
eiqnificant issues. Reqional Coordinators can assi~t your staff in
identifyini these sites.
O$W~~ ~ire~tiv. "".'-08, aated November 30, 198', disc~55es
the role of the ~e9ional Coordinators an~ 1~ent1ties key quality
them85 tor the 6elec~ion ot reme~y process. I s~ronqly r.comme~~
that your statt work w1~h the Req10nal coor~1nators on 1~plement1n~
these themes in all Proposed Plans and RODs in orOer to cont1nuall¥
improve program qua11ty and cons1stency.
Dele9at1on briefing sheets formerly requeste~ for beth Fu~c-
lead and Enforcement-lead sites will not be required this y.a~ d~a
to th1s deleqation. However, briefing materials on ~ajor site
issues ~r be necessary tor those RODs which require Hea~quarte:s
consultat on.
Delegation que.tions should be 8~dress.4 to Carol Jacobso~
(FTS 4'5-'834) in the HazardoU8 Site Control Diviaion or
Joe Tieger (FTS 47!-8372) in the CERCLA !nforoemen~ Divi.ion.
-------
It\II D"ts '''OV90 ":":17
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(
. ~ L' c; - 2 e - 9 e M 0 N
12:41
P.04
-3-
Attachment
cc:
Director, Waste Manaiement D!viaion, Re9ion8 I, IV, V, and
VII
Cirector, Emergency and Remedial Response D!viaion, Re9ior.
II
Director, Hazardous Wast. Kanaqement Diviaion, Req10ns III,
VI and VI II
Director, Toxic. and Waste Management Diviaion, Reqior. IX
Director, Hazardous Waste Division, Req10n X
Reqional counsels, Regions I - X
Superfund Branch Chiefs, Re9ions I - X
"
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