United States:
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R07-93/070
September 1993
Superfund
Record of Decision:
Midwest Manufacturing/North Farm
(Operable Unit 3) (Amendment), IA

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4.
S0272-101
REPORT DOCUMENTATION ". REPORTNO.
PAGE EPA/ROD/R07-93/070
TItle and Subtitle
SUPERFUND RECORD OF DECISION
Midwest Manufacturing/North Farm (OU3) (Amendment), IA
First Remedial Action - Final
Author(a)
2.
3. ReclpIent'a AA:e_lon No.
So
Report Date
09/29/93
6.
7.
8.
Performing Organization Rep!. No.
9.
Performing Organization Nam8 and Add,..
10
Project TaskIWork Unit No.
1'. Contract(C) or Grant(G) No.
(e)
(G)
,2. Sponsoring Organization Name and Addl88s
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covar8d
Agency
800/800
14.
15. Suppl8rnertary Net.
PB94-964308
16. Abstract (Umh: 200 words)
The Midwest Manufacturing/North Farm (Operable Unit 3) site includes the North Farm QU,
a former disposal area located approximately 2 miles northeast of Kellogg, Jasper
County, Iowa. Land use in the area is predominantly agricultural, with pasture land on
and around the site. In addition, the closest residence to the North Farm OU is
approximately one mile from the site. From 1973 to 19'81 SJ!lith Jones, Inc., operated an
electroplating and painting facility at the Midwest Manufacturing QU. Chemicals used
in these processes included VOCs such as TCE, and metals such as cadmium, nickel, and
zinc. Prior to 1977, electroplating waste containing heavy metals, TCE, and paint
residue from onsite painting operations was discharged directly to North Skunk River,
adjacent to the Midwest Manufacturing OU. In 1977, the State required treatment of
wastewater to precipitate out the metals prior to disposal. To comply with this
requirement, Smith-Jones constructed an onsite wastewater treatment system. From 1977
to 1978, the resultant sludge, which contained high levels of cadmium, nickel, and
zinc, was periodically transported to the North Farm Operable Unit (OU3) for disposal.
The sludge was placed in an unlined trench and excavated to a depth of approximately
'five feet below ground surface. In 1978, the trench was 'covered with native soil.
(See Attached Page)
17. Document Analyala a. Dascrlptors
Record of Decision - Midwest Manufacturing/North Farm (OU3) (Amendment), IA
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (PCE, TCE, toluene, xylenes), other organics (PARs),
(arsenic, chromium, lead), other inorganics (cyanide)
metals
b.
ldentlfieralOpan-Ended Tarms
c.
COSATI FleldlGroup
18. Availability Stat8lll8nt
19. Security CIaaa (This Report)
None
z. Security,aua (ThIs Pags)
None
21. No. of Pagaa
39
zz. PrIea
(Sea ANSI-Z39.18)
SeeIn.rIllCtJGM on Rallel"N
OPTIONAL FORM m (4-77)
~y tms.35)
rtmart of Commerce

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EPA/ROD/R0'7-93/070
Midwest Manufacturing/North Farm (OU3)
First Remedial Action - Final
(Amendment), IA
Abstract (Continued)
During the early 1980s, EPA investigations revealed elevated heavy metal concentrations
downgradient of the unlined disposal trench at OU3. Subsequent investigations indicated
elevated hE!avy metal concentrations in subsurface soil in the disposal trench, in onsite
surface soil, and in ground water. A 1988 ROD addressed source control and provided for
excavation and treatment of the soil in the disposal trench using stabilization, followed
by off site disposal and backfilling of the excavated area with clean fill; however, the
selected remedy was never implemented. This ROD amends the 1988 ROD based on the
infor.matio~ gathered during pre-design activities. After EPA re-evaluated the site risks
posed by O~3, it was determined that only future exposure pathways resulted in
unacceptable risk levels. The primary contaminants of concern affecting the soil and
ground water are VOCs, incl~ding PCE, TCE, toluene, and xylenes; other organics, including
PARs; metals, including arsenic, chromium, and lead; and other inorganics, including
cadmium and cyanide.
The selected remedial action for
including deed, land, and ground
estimated present worth cost for
this site includes implementing institutional controls,
water use restrictions; and monitoring ground water. The
this remedial action is $27,100.
PERFORMANCE STANDARDS OR GOALS:
MCLs and secondary MCLs for cadmium,
monitoring wells.
zinc,
and nickel will not be exceeded in ground water

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STATUTORY DETERMINATIONS -
MIDWEST MANUFAcruRING/NORTH
FARM SITE
The selected amended remedy for each Operable Unit is protective of public
health, welfare and the environment, complies with federal and state applicable or
relevant and appropriate requirements, and is cost-effective. The amended remedy for
each Operable Unit does not satisfy the preference for remedies that employ treatment
which permanently and significantly reduces the volume, toxicity, or mobility of hazardous
materials as a principal element. In addition, the remedy for each Operable Unit does
not utilize permanent solutions or alternative treatment technologies (or resource
recovery technologies) to the maximum extent practicable.
Because each remedy will result in hazardous substances remaining at the Nonh
Fann Operable Unit and at the Midwest Manufacturing Operable Unit above health-
based levels, a review of each Operable Unit remedy will be conducted within five years
after commencement of these remedial actions to ensure that each specific Operable
Unit remedy continues to provide adequate protection of human health and the
environment.
Date c:)~~ /7'7.5
~~!~
. illiam. i
~r/.. ActingtRegional Administrato
Region VII
Attachments:
Decision Summary
Responsiveness Summary - Attachment A

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AMENDED RECORD OF DECISION
DECISION SUMMARY
MIDWEST MANUFAcruRING/NORTH FARM SITE
NORTH FARM OPERABLE UNIT
MIDWEST MANUFAcruRING OPERABLE UNIT
KELLOGG, IOWA
Prepared by: .
U.S. Environmental Protection Agency
Region VII
Kansas City, Kansas
September 28, 1993

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. DECLARATION
RECORD OF DECISION AMENDMENT FOR THE
MIDWEST MANUFACI'URING/NORTH FARM SITE
NORTH FARM OPERABLE UNIT
MIDWEST MANUFACI'URING OPERABLE UNIT
JASPER COUNTY
KELLOGG, IOWA
SEPTEMBER 1993
SITE NAME AND LOCATION
Midwest ManufacturingINorth Farm Site
Nonh Farm Operable Unit
Midwest Manufacturing Operable .Unit
Kellogg, Iowa
STATEMENT OF BASIS AND PURPOSE
This decision ~ocument, together with a Record of Decision (ROD) dated
September 30, 1988 for. the North Farm Operable Unit and a ROD dated September 27,
1990 for the Midwest Manufacturing Operable Unit, presents the selected remedial
actions for the Nonh Farm Operable Unit and the Midwest Manufacturing Operable
Unit which together comprise the Midwest ManufacturingINorth Farm Site, Kellogg,
Iowa. These actions were chosen in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and to the extent
practicable, the National Contingency Plan (NCP). These decisions are based on the
administrative records for these Operable Units.
The United States Environmental Protection Agency (EPA) is the lead agency for
the site, and the Iowa Department of Natural Resources (IDNR) has been designated
the support agency. This ROD amendment is being issued by the EP A. The State of
Iowa concurs on the amended selected remedies.
DESCRIYflON OF THE AMENDED SELECfED REMEDIES
NORTH FARM OPERABLE UNIT
The major components of the selected remedy, as now amended, include:
SOILS
Deed restrictions will be implemented to prevent using the disposal area as
a vegetable garden which could lead to accidental exposure to hazardous

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substances. No action would be taken to remove or control the migration
of the contaminants at the site.
GROUND WATER
Deed restrictions will be implemented to prevent the installation of a water
supply well which would be used for human consumption. Ground water
monitoring will be conducted to verify that the remedy remains protective
of human health and the environment and that no future unacceptable
exposures to contaminants at this Operable Unit occur.
MIDWEST MANUFACTURING OPERABLE'UNIT
The major components of the selected remedy, as now amended, include:
SOILS
A perimeter fence will be installed to control access to the disposal areas
located at the Midwest Manufacturing Operable Unit. Deed restrictions
will be placed on the property to prevent any changes in land usage. These
restrictions will limit any future exposure to hazardous s~bstances which
remain on-site. .
GROUND WATER
No action will be taken to remove and/or otherwise control the migration
of the contaminants within the ground water at the Operable Unit. Deed
restrictions will be implemented to prevent the installation of a water
supply well which would be used for human consumption. A survey of all
water supply wells, both public and private within one mile of the plant
site, will be conducted prior to initiating the monitoring program. Two new
monitoring wells will be installed in locations close to existing public water
supply wells. Ground water monitoring will be conducted to verify that the
remedy remains protective of human health and the environment and that
no future unacceptable exposures to contaminants at this Operable Unit,
occur.

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Section
I.
II.
III.
IV.
Amended Record of Decision
Decision Summary
Contents
Page
I..oca tion and Description.............. ............. ............... ................. .....................1
Community Rela ti ons ........................ .... ...... ............ ............ ....... ........... ..........2
Reasons for Issuing the Record of Decision Amendment........................2
v.
a.
b.
North Farm Operable Unit[[[2

Midwest Manufacturing Operable Unit...........................................5
Description of the Original and Amended Remedies.................................9
a.
b.
N orth Farm Operable U nit[[[9
Midwest Manufacturing Operable U nit........................................... 10
Comparative Analysis of the Original and Amended Remedies.............12
a.
b.
N orth Farm Operable U nit[[[ 13
Midwest Manufacturing Operable Unit...........................................17
VI.
. Statutory De termina tions[[[21
a.
North Farm Operable Unit
1.
2.
Ground Water [[[21

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List of Figures:
List of Tables:
Decision Summary
Contents
1..
Site Vicinity Map
2.
Site Locator Map
3.
City Well Location Map
1.
North Farm Contaminants of ConcernlHealth Risk in both Ground Water
. and Contaminated Soils
2.
North Farm Summary of Future Risk
3.
Exposure Scenarios Quantified at the Midwest Site
4.
Summary of Carcinogenic Risk
5.
Chemicals of Potential Concern
6.
Summary of Subchronic Noncarcinogenic Health Hazards
7.
Summary of Chronic Noncarcinogenic Health Hazards
Responses Received on Proposed Plan

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DECISION SUMMARY
RECORD OF DECISION AMENDMENT
MIDWEST MANUFAcruRING/NORTH FARM SITE
NORTH FARM OPERABLE UNIT
MIDWEST MANUFACfURING OPERABLE UNIT
I. LOCATION AND DESCRIPTION
The Midwest ManufacturingINorth Farm Superfund Site consists of two non-
contiguous pieces of property known as the North Farm Operable Unit and the Midwest
Manufacturing Operable Unit. The North Fann Operable Unit is located 2 miles north
and 112 mile east of Kellogg, Iowa. Kellogg, population 700, is located in Jasper County,
which is approximately 42 miles east of Des Moines (See figure 1). The Midwest
Manufacturing Operable Unit is owned and operated by Smith Jones, Inc., Midwest
Division and is located at 101 High Street in the city of Kellogg, Iowa. The Midwest
Manufacturing Operable Unit occupies eight acres within the North Skunk River
floodplain (see figure 2).
Smith Jones, Inc. engaged in electroplating and painting operations of
manufactured products from 1973 until 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 i980-1J81 zinc was used. Prior to 1977, electroplating wastes.containing TCE,
heavy metals, and paint residue generated from on-site painting operations were disposed
directly into the North Skunk River. In 1977, a wastewater treatment system was
constructed. Sludges generated from the treatment process were pumped to a storage
tank where they were periodically removed and placed into one of two disposal areas.
Electroplating operations ceased in June of 1981.
From 1977 to 1978, the sludge resulting from this wastewater treatment process
was periodically transported to the North Fann Operable Unit for disposal. The sludge
was placed in an unlined trench excavated to a depth of approximately five feet below
ground surface. A benn was initially placed around the perimeter of the trench to divert
surface water away from the disposed material. The trench was covered with native soils
in 1978.
The disposal trench at the Midwest Manufacturing Operable Unit, located on the
main plant prE>perty, received the sludges generated by the treatment plant from 1978
until June of 1981. The areas of disposal at the Midwest Manufacturing Operable Unit
include the waste disposal trench, the buried waste met~l pile and the marsh.

Greater detail concerning the characteristics of each Operable Unit and the prior
investigation and remedial alternatives may be found in the administrative records for
each Operable Unit.
1

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II.
COMMUNITY RELATIONS
The United States Environmental Protection Agency (EP A) is issuing this Record
of Decision (ROD) Amendment to meet public participation provisions mandated under
Section 117(a) of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) as amended by Superfund Amendments and Reauthorization
Act (SARA) of 1986, and Section 300.435 (c)(2)(II) of the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP).
The Proposed Plan for this ROD Amendment was made available to the public in
the administrative record file located at the Kellogg, Iowa City Hall and the EP A Region
VII Office, Kansas City, Kansas. A public notice was published in The Newton Daily
Ne~~ on February 19, 1993, announcing the commencement and length of the public
comment period and the availability of the administrative records file at the Kellogg City
Hall.
Fact sheets were also mailed to area residents, local officials and the media
announcing the availability of the project documents and the public comment period.
EP A offered to hold a public meeting to discuss the Proposed Plan for the
Amended ROD if requested. No requests were received.
Comments received during the public comment period are ~ddressed in the
Responsiveness Summary. ...
m.
REASONS FOR ISSUING THE ROD AMENDMENT
NORTH FARM OPERABLE UNIT
REASSESSMENT OF SITE RISKS
EP A has reevaluated the site risks posed by the Nonh Farm Operable Unit. This
reevnluation included a review of the information contained within the ROD, as well as
other information EPA has obtained concerning the Nonh Farm Operable Unit. .
Section V of the ROD identified the following site characteristics: Onsite surface
soils are contaminated with various levels of heavy metals such as calcium, cadmium and
manganese. 'The contaminated soil within the disposal cell contains various levels of
heavy metals such as cadmium, nickel, zinc, sodium, cyanide and calcium. This material
failed the EP Toxicity test for cadmium. According to the Public Health Evaluation,
cadmium bioaccumulates in mammals, particularly in the kidney and liver. Sub-chronic
and l::hrOniC exposures to cadmium are associated ~th a number of noncarcinogenic but
toxic effects, including kidney damage in humans and experimental animals. Non-
carcinogenic toxic effects may result from incidental ingestion of soil, ground water or
2

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other media. EP A considers cadmium a carcinogen only when inhaled. The ground
water beneath the site appears to be a perched water table that has no hydraulic
continuity with the Bear Creek alluvium. The ground water health based action level for
cadmium is 18 micrograms/liter (ug/l) and for manganese is 7700 ug/l.
Cadmium and manganese were identified as chemicals of concern for the ground
water media. Cadmium and cyanide were identified as chemicals of concern for the
contaminated soil media. Table 1 presents the site information regarding the levels of
contaminants present in the soils and ground water and the health based action level for
these contaminants per exposure pathway. No carcinogens are present at the North
Farm Operable Unit, therefore only non-carcinogenic risks are evaluated. The health
based action level is the contaminant concentration level above which adverse health
effectS may be experienced by persons exposed to the contaminant.
Under current land-use conditions at the North Farm Operable Unit, there are no
complete exposure pathways by which human receptors could be exposed to site
contaminants. The site is relatively isolated. The nearest residence is one mile away. Of
the chemicals, only cadmium may be of concern under future-use scenarios. All others
are considered insignificant.
The exposure scenarios considered for possible future land-use conditions are:
1.
2.
3.
Ingestion of ground water;
- Direct contact with (incidental ingestion of) surface soils; and
Ingestion of contaminated vegetables.
Average and plausible maXimum exposure scenarios were developed for each of
these pathways. The exposure point concentrations of cadmium were estimated for the
potentially exposed populations. Human health risks were assessed based on these
estimates of exposure and a quantitative description of cadmium's toxicity.
The 1988 ROD concluded the following "It is determined that no action needs to
be taken to protect ground water with respect to cadmium." Cadmium received a hazard
index score equal to one, which indicates that it represents a marginal risk to humans
who may ingest cadmium contaminated water. The health based action level for
cadmium. in water is 18 ug/l. This is 1 ug/lless than the highest total concentration level
found at the site. Only one ground water sample from the monitoring wells was found to
contain cadmium. The ground water sample containing cadmium was not filtered prior
to analysis, so the analytical results represent the total cadmium present. None of the
filtered ground water samples, which represent the dissolved cadmium concentration,
exceeded the action level. Monitoring wells are typically of a different type of
construction than wells constructed for drinking water. Monitoring wells usually produce
a greater amount of sediment mixed with water than is the case for a drinking water well.
Inorganic contaminants have a tendency to attach themselves to the sediment. This .
3

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causes the contaminant concentration measured in an unfiltered (total) sample to be .
greater than that of a filtered sample. Therefore, the unfiltered contaminant
conce:ntration measured in a drinking water well would be similar to that measured in a
filterf~d sample collected from a monitoring well. Cadmium, therefore, would not
represent a potential human health threat at its current concentration level.
The ground water at the Nonh Farm Operable Unit lacks any connection to other
off-site ground water zones. A drinking water well located in this water table would only
produce from 0 to 1 gallon per minute (gpm). This amount is significantly below most
residential needs. EP A's remedies require the collection of ground water samples from
the monitoring wells present at the North Farm Operable Unit. EP A will use the
infonnation gained from the ground water monitoring program to detect any changes in
the le:vels of contaminants present in the water table at this site.
. Table 2 is a summary of non-carcinogenic risk for human exposure to cadmium at .
the Nonh Farm Operable Unit. "CDI:RtD" is the chronic daily intakes or the Reference
Dose for the individual compound in units of milligrams per kilogram of body weight per
day (mg/kglday). The "average case" is based upon geometric mean concentrations of
contaminants used together with the most likely exposure conditions. The "plausible
maximum case" is based upon the highest concentrations of contaminants used together
with high estimates for the exposure conditions. For the "plausible maximum case," one
exposure route presents'a risk greater than 1 (> 1), that is the route for ingestion of
vegetables grown in the contaminated soils. Ingestion of ground water contaminated
with «:admium present at a concentration of 19 ugll has a risk equal to 1. As a "plausible
maximum case," these exposure routes are considered remote. Deed restrictions limiting
land use can prevent all future exposure scenarios evaluated. No one is currently
growing vegetables in the disposal cell at the North Farm Operable Unit nor is anyone
drinking the water at the site. Monitoring of the quality of the ground water at the site
will enable EP A to determine if EP A's selected remedy is protective of human health
and the environment.
As stated in the 1988 ROD, EP A has concluded that the site, in its present
conditions, poses no current risk to human health and the environment. However,
certain future risks do exist if no action is taken. Future risks can be prevented by using
institutional controls which would prohibit certain future land use, such as vegetable
gardening, and prevent the installation of a water supply well.
Exposures to Wildlife
Section 6.7.4 of the Remedial Investigation (RI) Repon assessed the site risks to
wildlife and concluded the following: ''Terrestrial and avian species foraging at the site
may be exposed to contaminants in the soil. Most animals, though, especially avian
species, forage. over a large range area relative to the size of this site. Thus, it is very
unlikely that significant adverse effects at either a population or an individual level will.occur."
4

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APPLICABLE OR RELEVANT AND APPROPRIATE ENVIRONMENTAL
REGULATIONS (ARARs)
In 1988, a variety of federal environmental laws were reviewed as to legal
applicability or relevance and appropriateness to the remedial alternatives under
consideration. Requirements under the Resource Conservation and Recovery Act
(RCRA), as amended, and the Hazardous and Solid Waste Amendments (HSW A) of
1984 were found to be potentially applicable or relevant and appropriate to these
remedial alternatives. Review of various State environmental laws and regulations,
including those pertaining to solid and hazardous waste management, indicate that the
Federal environmental laws are at least as or are more stringent than State Law.
RCRA, as amended by HSW A of 1984, regulates the. generation, transportation,
treatment, storage and disposal of defined hazardous waste. In the 1988 ROD for the
North Farm Operable Unit, the remedy selected for the contaminated soils onsite was
excavation and treatment with off-site disposal. This activity would have involved the
generation of hazardous waste and thus, RCRA was designated as an ARAR. However,
the amended remedy will result in the contaminated soils remaining undisturbed at the
subsite; therefore, no generation of hazardous waste will occur and RCRA will no longer
be an ARAR.
Then~ are no federal or state ARARs for the selected remedies, institutio~al
controls.
OTHER CONSIDERATIONS
Iowa Code Section 455B.426 identifies and lists sites where the disposal of a
"hazardous waste" or "hazardous substance" occurred at the site either illegally or prior to
regulation under Chapter 455B. The state of Iowa has notified EP A that the North
Farm Operable Unit is listed on the "Registry of Hazardous Waste or Hazardous
Substance Disposal Sites and Hazardous Waste Remedial Fund" Annual Report - 1992.
According to the State, site use cannot change due to this listing.
MIDWEST MANUFACTURING OPERABLE UNIT
REASSESSMENT OF SITE RISK
EP A has reevaluated the site risks posed by the Midwest Manufacturing Operable
Unit by reviewing the information contained within the ROD, as well as other
information EP A has obtained during pre-design activities conducted at the Midwest
Manufacturing Operable Unit.
5

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EP A reviewed Appendix 8 of the RI Report, Baseline Risk, and Section VIII of
the 1990 ROD to review the risks at the Midwest Manufacturing Operable Ur.it. The
following is the summary of this review.
A list of chemicals present at the site was compiled. Chemicals were eliminated
from the risk assessment if they were not detected in environmental samples, were
dete(:ted infrequently, 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 chemicals were selected as contaminants of potential concern.
These chemicals are presented in Table 5.
An exposure assessment analyzes two factors that affect the quantification of risks:
pote:rttially exposed populations and exposure pathways. In general, Superfund Exposure
Assessments consider both current and future exposure scenarios.
Current human populations that potentially may be exposed on the Midwest
Manufacturing Plant Site are occupational workers of the Smith Jones plant and
trespassers. There are no off-site populations that would potentially be exposed to the
contaminants of concern. Results of the risk assessment determined that the site, in its
curr~:nt conditions, poses no unacceptable health risk.
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 development 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 contaminated drinking water if a well was drilled onsite.
Future off site residential populations are assumed to be the same statistically 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.
Ten exposure pathways were selected for further quantitative evaluation from a
list of 27 exposure pathways presented in the Risk Assessment report. These ten were
selected because they were thought to present the highest potential for adverse health
effects resulting from site exposures.
Current routes with the highest exposure routes were all related to contaminated
soils and wastes. No ground water exposure routes were evaluated since this route is not
complete. The baseline risk assessment report did not identify any current human health
risks posed by the site.
For the evaluation of the future potential exposure routes, seven future potential
exposure routes were evaluated in the Risk Assessment report. Exposure scenarios are
listed in Table 3 with th~ individuals exposed, routes and media identified.
6

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Table 4 is a summary of the carcinogenic risk posed by the site. Only future risks
were found to be of concern. Onsite workers may experience a slight increase in excess
cancer risk from contact with contaminants arsenic, beryllium and vinyl chloride in soil
and a greater risk (a one in one thousand) from ingestion of the same contaminants in
the ground water, if an onsite water supply well was installed onsite and provided
contaminated water for consumption. The presence of both arsenic and beryllium in the
ground water is not a result of plant activities since these contaminants were present both
on-site and off-site and therefore, are considered to be naturally occurring.
Vinyl chloride was present in 4 out of 26 ground water samples, twice in one well
at a level of approximately 40 ug/l. The Maximum Contaminant Level (MCL)l for vinyl
chloride is 2 ug/l. The only potential exposure route of concern is that of the ingestion of
contaminated ground water.
Future site risks can be prevented through the use of "institutional controls" such
as deed restrictions which would limit land use and development and would prevent the
installation of a water supply we1l2 and access restrictions which would prevent access to
the \\-aste disposal areas and prevent the exposure of the trespasser to the hazardous
wastes which remain on-site. A perimeter fence would prevent dermal exposure to any
soil contaminants. A ground water monitoring program, for any supply wells, either
public or private, within a one mile radius of the site, will be used to determine the
presence of any contaminants within the area water supply.
Table 5 lists the twenty-six chemicals which were selected as contaminants of
potential concern of which three, arsenic, beryllium and vinyl chloride were determined
to be indicative of on-site contamination. Populations that maybe. potentially exposed to
on-site contaminants are occupational workers of the Smith Jones plant and site
trespassers. There is no current off-site exposure. The levels of contamination present
at the site are not expected to cause adverse health effects.
Tables 6 and 7 present a summary of the sub-chronic non-carcinogenic health
hazards associated with the Midwest Manufacturing Operable Unit and a summary of the
chronic non-carcinogenic health hazards associated with the Midwest Manufacturing
Operable Unit, respectively.
1 The Maximum Contaminant Level or MCL is the level at which a contaminant can
be present within the ground water without causing adverse effects.

2 Deed restrictions which limit land use are sometimes referred to as "use
restrictions."
7

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Exposures to Wildlife
Section IX of the 1990 ROD stated the following: "An ecological assessment was
conducted to detennine 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. 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."
NEW SITE DATA
In December, 1991, EP A conducted a pump test. The infonnation gained from
this test indicated that the aquifer is less permeable than previous data indicated. This
lack of aquifer penneability lengthens the ground water remediation time from 25 years
to 35 years. which, in turn, increases the overall cost of the extraction and treatment
component of the 1990 ROD. EP A's preliminary design also included an increase in the
number of extraction wells from 5 to 8 as necessary for site remediation.
APPLICABLE OR RELEVANT AND APPROPRIATE ENVIRONMENTAL
REGULATIONS (ARARs)
In 1990, a variety of federal environmental laws were reviewed as to legal
applicability or relevance and appropriateness to the remedial alternatives under
consideration. Requirements under RCRA, as amended, and HSW A of 1984 were found
to be: potentially applicable or relevant and appropriate to the hazardous sludge present
at the site. The State of Iowa provided a list of its statutes that may be applicable or
relevant and appropriate to this site. Chapter 133 of the Iowa. Administrative Code was
one statUte identified which provided more stringent requirements than the federal law.
RCRA, as amended by HSW A of 1984, regulates the generation, transportation,
treatment, storage and disposal of defined hazardous waste. In the 1990 ROD for the
Midwest Manufacturing Operable Unit, the remedy selected for the contaminated soils
onsite was installation of a landfill cap of the waste disposal area and extraction and
treatment of the contaminated ground water. These activities would have involved the
generation of hazardous waste and thus, RCRA was designated as an ARAR. However,
the amended remedy will result in the contaminated soils and ground water remaining'
8

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undisturbed at the subsite; therefore, no generation of hazardous waste will occur and
RCRA will no longer be an ARAR.
For the contamination present in the ground water, in 1990, the state of Iowa
determined that "active" cleanup, that is extraction of the contaminated ground water
with treatment to meet MCLs was necessary to meet the criteria of Chapter 133. In
1993, the State of Iowa expressed to EP A its position regarding Chapter 133 of Iowa's
Code that "passive cleanup" satisfies the state's ARAR. "Passive cleanup" entails leaving
the contamination in the ground water and allowing natural processes to remediate the
site. This is also referred to as "natural attenuation." The selected amended remedial
alternative would meet this state ARAR.
OTHER CONSIDERATIONS
. Iowa Code Section 455B.426 identifies and lists sites where the. disposal of a
"hazardous waste" or "hazardous substance" occurred at the site either illegally or prior to
regulation under Chapter 455B. The state of Iowa has notified EP A that the Midwest
Manufacturing Operable Unit is listed on the "Registry of Hazardous Waste or
Hazardous Substance Disposal Sites and Hazardous Waste Remedial Fund" Annual
Report - 1992. According to the State, site use cannot change due to this listing.
IV.
DESCRIPTION OF ORIGINAL REMEDIES AND AMENDED REMEDIES
-
NORTH FARM OPERABLE UNIT
The ROD for the North Farm Operable Unit addresses the contaminated soils
present within the disposal cell. The original ROD requires excavation of the
contaminated soils within and around the disposal cell that contains cadmium
concentration levels exceeding a health based action level of 13 milligrams per kilogram
(mglkg). The excavated soil would then be treated using stabilization technology to the
point where that the leachate contaminant concentrations no longer exceed established
criteria. After treatment, the excavated soil would be disposed into a permitted RCRA
Subtitle C disposal facility. The excavated area must be backfilled and graded with clean
soil to support a vegetative cover. This remedy represents RCRA's Landfill Clean
Qosure Option as defined in 40 CFR Part 264, Subpart N, and therefore, requires no
long-term monitoring or deed restrictions. The 1988 ROD estimated the cost for the
total project to be $220,185. In 1993, total project costs are now estimated at
approximately $403,000. Increase design costs (from approximately $51,000 to
approximately $160,000) contributed the' largest share of the increased costs. Also, cost
for the transportation and disposal of the waste significantly increased.
The response action now being selected for the North Farm Operable Unit is
'what was described as the "No Action" alternative in the 1988 ROD, with the addition of
ground water monitoring and deed restrictions. Under this remedy, no specific response
9

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action would be taken to remove the contaminants at the site or control their migration
from the site. Deed restrictions, placed on the property, would prevent the installation of
a water supply well and the use of the disposal cell area as a vegetable garden. The
deed would also state that hazardous substances remain at this site. Project costs are
estimated to be $27,100 ($10,400 for the first year [sample 3 ground water wells
quarterly] plus costs for deed restrictions. $15,300 Present Worth estimate for years 1-4
with semi-annual sampling events, collection and analysis costs for each water sample
were estimated to be $665 per sample with a 30% contingency at an 8% interest rate.
Cost for deed restrictions are estimated to be $1,454.
EP A's response action will include the collection of ground water samples from
the three existing ground water monitoring wells at the North Farm Operable Unit.
Analytical results from these ground water samples will be evaluated to aid EP A in
ver:ifying that no unacceptable exposures are occur:ring. During the first year of
mo:nitoring, ground water samples will be collected quarterly and analyzed for both total
and dissolved metals. Once four consecutive quarters of data are available, EP A will
evaluate the information and determine the need to collect further samples. This
evaluation will focus on the levels of cadmium, zinc and nickel present in both the
dissolved and total samples. EP A will reduce the frequency of sampling if the data
indicates that the contamination present does not exceed drinking water standards for
cadmium, zinc and nickel3. If the analytical results indicate that contamination is
migrating from the North Farm Operable Unit, the sampling program will be expanded
to determine the rate and extent of migration and the response . action at the North Farm
Operable Unit will be reevaluated. Because this remedy will result in hazardous
substances remaining on-site above drinking water standards, a review will be conducted
to cmsure that this remedy continues to provide adequate protection of human health and
the envirqnment within five (5) years after commencement of the remedial action.
MIDWEST MANUFAcruRING OPERABLE UNIT
The original ROD for the Midwest Manufacturing Operable Unit addresses the
contaminated ground water and the contaminated soils in the disposal trench area. The
original selected remedy provides for ground water treatment and capping of the waste
disposal cell in accordance with the RCRA landfill closure and post-closure requirements
as descn"bed in 40 C.F.R. ~ 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 maintenance of the ground water monitoring system. The total
pr~ject cost increased considerably from the 1990 ROD estimate of $488,844 to a current
3 The May 1993 drinking water standards and health advisories for the
contamination at the North Farm site are: cadmium 5 ug/l; nickel 100 ugll and zinc 500
ug/L Cadmium and nickel are MCLs. Zinc is a secondary maximum contaminant level,
which means that it is for aesthetics.
10

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estimate of $1,091,531. Increased design costs (from approximately $89,000 to
approximately $249,000) contributed the largest percentage share of the increased costs,
Operation and Maintenance costs increased from an estimated $200,000 to an estimated
$460,000, and construction costs increased from an estimated $200,000 to an estimated
$310,000.
The remedy now being selected for the Midwest Manufacturing Operable Unit is
descn"bed as Alternative #1 "No Action with Ground Water Monitoring" in the ROD of
September 1990 with the addition of a perimeter fence to limit access to the disposal
areas at the plant site. No specific response action will be taken to remove and/or
otherwise control the migration of the contaminants at the Operable Unit. Institutional
and engineering controls, such as deed restrictions and perimeter fencing will be
implemented. Deed restrictions will prevent the installation of a ground water supply
well thereby preventing the use of the contaminated on-site ground water. A long-term
ground water monitoring program will be implemented. A private water well survey will
be conducted to identify all private water supply wells within one mile of the site. Any
private water wells identified through this survey will be included in the ground water
monitoring program.
Two new monitoring wells will be installed, one off-site to the west of the property
between the site and the city water supply Well No.2, and one in the northeast comer of
the property between the site and city water supply Well No.1 (see figure 3). These two
wells, in coJ1junction with four of the existing monitoring wells in the southern portion of
the site, the three public supply wells and any private water supply wells identified within
the. one mile radius of the site, will be sampled quarterly to track long-term changes in
the contaminant concentrations in ground water. Water samples will be analyzed for
volatile organics and both total and dissolved metals. The water samples from these
wells will allow EP A to identify any tendency for contaminant migration towards the city
. water supply wells, and will monitor the concentration of contaminants in on-site ground
water. Samples from the public supply system and any private supply wells will provide
information concerning the quality of the existing water supply.
After the collection and evaluation of the analytical results of the first round of
ground water samples, EP A may require the sampling of additional existing monitoring
wells. Once the ground water data base contains four consecutive quarters of data, EP A
will determine the sampling strategy for the next year. If data obtained from a ground
water monitoring well indicates that the ground water meets or does not exceed MCLs
for the chemicals of concern at the Midwest Manufacturing Operable Unit for two
consecutive sampling events, the monitoring well will then be sampled on an annual
basis. Once the water from a monitoring well meets the MCLs for two years, the well
will no longer be sampled. Water supply wells will be sampled quarterly for the first two
years. EP A and the State of Iowa will determine the long-term sampling frequency for
all water supply wells.
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Public access is somewhat restricted at the site perimeter. There is evidence that
the public can enter the site from the Holmdahl park area. and has used the area to ride
all terrain vehicles and other vehicles south of the plant site bordering the North Skunk
river.. A perimeter fence must be installed to prevent public access to any of the disposal
areas which contain sludge from the past disposal activities. EP A has estimated the cost
of fe:ncing to be $20 per foot, including design costs. EP A estimates that up to 400 feet
of fencing is needed and the cost of the fencing should be approximately $11,000 with a
30% contingency added. Maintenance of the perimeter fence is estimated to be less than
$lOO/year.
Project costs for the implementation of the original remedy have increased to
$1,091,531, (up from 1990 ROD estimate of $488.844). The cost of the amended remedy
is estimated at $118,530 (Alternative 1 in ROD issued September, 1990 plus monitoring
of city supply wells quarterly for the first year which is 36 water samples at $665/sample
or $31,100 with a 30% contingency). Design, engineering and construction costs are
estimated to be approximately $47,000. Total present value of the monitoring costs for
years 2-5 of the project are estimated to be $40,400 estimated at an 8% interest rate.
Fencing costS are estimated to be approximately $11,000. Cost of deed restrictions is
estim.ated to be $1454.
Because this remedy will result in hazardous substances remaining on-site above
health-based levels, a review will be conducted to ensure that this remedy continues to
provide ad~quate protection of human health and the environment. within five (5) years
after commencement of the remedial action.
v.
COMPARATIVE ANALYSIS OF THE ORIGINAL AND AMENDED REMEDIES
The NCP sets forth nine evaluation criteria which serve as a basis for comparing
the n:medial alternatives for final actions. The nine criteria are divided into three
categ,:uies: Threshold Criteria, Primary Balancing Criteria, and Modifying Criteria. If
any remedial alternatives identified during the Feasibility Study do not meet the
Threshold Criteria (Criteria 1 and 2), EP A will not consider them as possible fmal
re~edies. If the alternatives satisfy the Threshold Criteria, they then are evaluated
against the next five criteria, called the Primary Balancing Criteria. These criteria are
used to compare the remedial alternatives against each other in terms of effectiveness,
implementability, and cost. The final two criteria, state acceptance and community
acceptance, are called Modifying Criteria. The alternatives are compared against the
Modifying Criteria after the state and the community have reviewed and commented on
the P:roposed Plan and the other alternatives considered by EP A
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NORTH FARM OPERABLE UNIT
The following is a discussion of the nine criteria used by EP A for remedy
selection.
A.
Threshold Criteria:
1.
Overall Protection of Human Health and the Environment
EP A assesses the degree to which the alternatives would eliminate, reduce,
or control threats to public health and the environment through removal,
containment, and/or institutional controls. An alternative is normally
considered to be protective of human health if the excess cancer risk is
reduced to less than 1 in 1,000,000 (10-0) and risks do not pose non-
carcinogenic health risks {Hazardous Index (HI) < 1}.4
The contamination at the North Farm Operable Unit poses no current risks
to human health or the environment. Future risks can be controlled by
institutional controls, that is, deed restrictions which will be placed on the
property to prevent the installation of a ground water well and any
vegetable gardening in the disposal cell. Monitoring of the quality of the
ground water will assist EP A in determining if this action continues to be
- protective of human health and the environment.
2.
Compliance with all Applicable or Relevant and Appropriate State
and Federal Environmental Regulations
EP A assesses whether the remedial alternatives being evaluated would
comply with all applicable or relevant and appropriate requirements, called
ARARs, established by the state and federal government. The 1988 ROD
identified RCRA as relevant and appropriate for the soils removed from
the North Farm Operable Unit. The amended ROD leaves all soils in
place, therefore, RCRA is ':10t applicable to this action.

There are no federal or state ARARs for the selected remedy, institutional
controls. No chemical-specific, action-specific or location-specific ARARs
were identified for the implementation of the selected amended alternative.
4 The Hazardous Index rating does not exceed 1.
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B.
Primary Balancing Criteria:
1.
Long- Tenn Effectiveness and Pennanence
Long-term effectiveness and permanence refers to the ability of a remedy
to maintain reliable protection of human health and the environment over
time once clean up goals have been met. Institutional controls, in the form
of deed restrictions, would prevent exposure to contaminants present at the
North Farm Operable Unit. These restrictions will apply to this property
regardless of any subsequent change in ownership, thereby offering long-
term effectiveness and permanence of the selected amended remedy. EPA
has no evidence that the levels of contamination at the site pose a current
risk to either human health or the environment. The amended remedy is
as protective as the original remedy since any future exposure to hazardous
substances will be prevented by its implementation. The amended remedy
for the North Farm Operable Unit is preferable to EP A.
Since contamination will remain on-site, EP A will conduct a 5-year review
of this amended remedy to determine if it continues to be protective of
human health and the environment and remains effective in the long-term.
The selected. amended remedy does not utilize permanent solutions or
alternative treatment technologies.
2.
Reduction of Toxicity, Mobility, or Volume Through Treatment
Section 121(b) of CERCLA states that remedial actions involving
treatment, which permanently and significantly reduce the volume, mobility
or toxicity of hazardous materials, are to be preferred over those not
involving such treatment. This evaluation 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. The proposed remedy would have
limited impact on the toxicity, volume or mobility of the hazardous
substances at the North Farm Operable Unit since no treatment would be
employed.
Information gained by EP A from the ground water monitoring program will
be used to evaluate the mobility of contaminants at the site. The toxicity
and volume of the contaminants will decrease due to natural atten~tion
processes. Natural attenuation will achieve the same reductions as the
original remedy, only it will take longer to achieve these reductions. The
rate of reduction due to natural attenuation processes will be evaluated
during the ground water monitoring program. The originally selected
remedy is th'e only remedy which considers treatment.
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3.
Short-Term Effectiveness
Short-term effectiveness evaluates the length of time needed to implement
each segment of the alternatives. EP A considers the risks that a panicular
activity may pose to site workers, nearby residents, or the local
environment. Short-term effectiveness involves the period of time needed
to achieve protection and considers any adverse impacts on human health
and the environment that may be posed during the construction and
implementation period until clean up goals are achieved.
As the amended remedy requires no construction or excavation activities,
the amended remedy would be more effective in the shon term than the
previously selected remedy. The previously selected remedy employing
excavation, solidification and disposal would disturb the contaminated soils
which could potentially affect site workers. Worker exposure could
potentially occur through direct contact, ingestion or inhalation of
contaminated soil panicles. Therefore, the amended remedy is more
effective in the short-term than the previously selected remedy.
4.
Implementability
EP A considers how difficult the alternative is to construct and operate, how
- other government agencies and EP A will coordinate .monitoring programs
and the availability of goods and services and personnel needed to
implement and manage the alternative. Implementability addresses the
technical and administrative feasibility of a remedy, including the
availability of materials and services needed to implement the chosen
solution.
Both the original and selected remedies are readily implementable. The
amended remedy (institutional controls including deed restrictions, land use
restrictions and ground water monitoring), is more easily implemented than
the original remedy (excavation, solidification and disposal). In addition,
the amended remedy requires no additional construction activities and, as
such, it can be implemented within a shan timeframe.
s.
Cost
EP A considers capital costs, operation and maintenance costs, and present
worth, which is the cost of the activities that will take place until the
remedial action is completed. Capital costs apply to activities such as
construction, land and site development, and disposal of waste materials.
Annual operation and maintenance costs are spent on activities such as on-
going operation of equipment, insurance and periodic site reviews. .
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CERCLA requires that the EP A select a cost-effective alternative that
protects human health and the environment and meets other requirements
of the law. EP A has determined that the selected remedy is as protective
and is more cost effective than the original remedy for the Nonh Farm
Operable Unit. Project costs are estimated to be less; specifically,
$403,000 for the original remedy versus $27,100 ($10,400 for the first year
[sample 3 ground water wells quanerly] plus costs for deed restrictions).
$15,300 is the Present Wonh estimate for years 1-4 with semi-annual
sampling events, with each water sample collection and analysis cost
estimated to be, $665 per sample with a 30% COntingency included at an
8% interest rate. Costs for deed restrictions are estimated to be $1,454.
C.
Modifying Criteria:
1.
State Acceptance
The State of Iowa, through the IDNR, is supponive of the amended
remedy for the Nonh Farm Operable Unit. The State of Iowa prefers the
amended remedy to the originally selected remedy.
2.
Community Acceptance
In comparing the originally developed and selected Nonh Farm Operable Unit
remedy with the amended remedy, EP A has determined that the original and amended
remedy meet the threshold criteria: overall protection of human health and the
environment and compliance with state and federal requirements.
EP A held a public comment period to allow the comm'unity to comment on
- the preferred alternative as set fonh in the Proposed Plan and the other
alternatives considered. Community response addresses the concerns of the
public regarding acceptance of a panicu]ar remedy. EP A has responded to
public comments received for consideration in the attached responsiveness
summazy. The community was opposed to the original remedy for the
Nonh Farm Operable Unit. Community response indicated that the public
did not perceive the contamination at the Nonh Farm Operable Unit as
presenting any significant threat to human health or the environment.
The selected amended remedy for the Nonh Farm Operable Unit presents the
better balance of tradeoffs, wilb respect to. Ibe primary balancing eriteria, in particuJar
with respect to cost, implementability, and shan-term effectiveness. While this amended
remedy does not meet the statutozy preference for reduction of toxicity, mobility or
volume through treatment, EP A's reevaluation of the risks at the site has lead EP A to
determine that the levels of hazardous substances remaining at the site do not Warrant
active treatment. For the modifying criteria of state and community acceptance, the
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amended alternative is preferred by both the state of Iowa and the community of
Kellogg.  In the tradeoff and balancing of all nine criteria, the proposed remedy is EPA's
selected remedy.                                                           .  .

      MIDWEST MANUFACTURING OPERABLE UNIT

      The following is a discussion of the nine criteria used by EPA for remedy
selection.

      A.    Threshold Criteria:

            1.     Overall Protection of Human Health and the Environment

            EPA assesses the degree to which the alternatives would eliminate, reduce,
            or control threats to public health and the environment through removal,
            containment, and/or institutional controls. An alternative is normally
            considered to be protective of human health if the excess cancer risk is
            reduced to less than 1 in 1,000,000 (10"6) and risks do not pose non-
            carcinogenic health risks (HI < I).5

            The contamination at the Midwest Manufacturing Operable Unit poses no
            current risks to human health or the environment. Future risks can be
            controlled by institutional controls, that is deed restrictions to prevent the
            installation of a water supply well, and engineering controls, specifically, the
            installation of a secure perimeter fence to prevent access to contaminated
            soils.  Monitoring of the quality of the ground water will assist EPA in
            determining if this action continues to be protective of human health and
            the environment.

            2.    Compliance with all Applicable or Relevant and Appropriate State
                   and Federal Environmental Regulations

            EPA assesses whether the remedial alternatives being evaluated would
            comply with all applicable or relevant and appropriate requirements, called
            ARARs, established by the state and federal government.  The 1990 ROD
            identified RCRA as relevant and appropriate for the contaminated soils
            present at the Midwest Manufacturing Operable Unit.  The amended ROD
            leaves all soils in place, therefore, RCRA is not applicable to this action.
            The original ROD identified the Clean Water Act (CWA) as an ARAR for
             the ground water extraction and treatment system.  The amended remedy
             leaves all ground water in place, therefore the requirements of the CWA
    5 The Hazardous Index rating does not exceed 1.

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are not ARARS. The original ROD identified Chapter 133 of the Iowa
Code as an ARAR and determined that "active" cleanup was ner.essary to
meet this ARAR. The state of Iowa has indicated that "passive" cleanup or
natural attenuation will meet the requirements of Chapter 133.
The selected amended remedy would comply with an federal and state
ARARs.
B.
Primary Balancing Criteria:
1.
Long-Term Effectiveness and Pennanence
Long-term effectiveness and permanence refers to the ability of a remedy
to maintain reliable protection of human health and the environment over
time once clean up goals have been met. EP A has no evidence that the
levels of contamination at the site affect either human health or the
environment, therefore, the amended remedy is as protective of human
health and the environment as the original remedy. Since contamination
win remain on-site, EP A will conduct a 5 year review of this amended
remedy to determine if it remains effective in the long-term.
2.
Reduction of Toxicity, Mobility, or Volume Through Treatment
Section 121(b) of CERCLA states that remedial actions involving
treatment, which permanently and significantly reduce the volume, mobility
or toxicity of hazardous materials, are to be preferred over those not
involving such treatment. This evaluation criteria relates to the ability of a
remedial alternative to control or eliminate risks caused by the mobility,
toxicity or volume of hazardous material. The proposed remedy would
. have limited impact on the toxicity, volume or mobility of the hazardous
substances at the Midwest Manufacturing Operable Unit since no
treatment would be employed.
Information gained by EP A from the ground water monitoring effort will
be used to evaluate the migration of contamination from the site. The
toxicity and volume of the contaminants will remain at the same level or
will be reduced due to natural attenuation. Natural attenuation will
achieve the same reductions as the original remedy, only it will take longer
to achieve these reductions. The rate of reduction due to natural
attenuation processes win be evaluated during the ground water monitoring
program. Information from the RI indicates that the contaminants remain
on-site and are not migrating off-site. The originally selected remedy is the
only remedy which considers treatment.
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3.
Short-Term Effectiveness
Short-term effectiveness evaluates the length of time ne'eded to implement
each segment of the alternatives. EP A considers the risks that conducting
a particular activity may pose to site workers, nearby residents, or the local
environment. Short-term effectiveness involves the period of time needed
to achieve protection and considers any adverse impacts on human health
and the environment that may be posed during the construction and
implementation period until clean up goals are achieved.
The amended remedy would have short term risks during the installation of
the fence and any additional monitoring welles) needed. These elevated
levels of risks will be limited and can be addressed by the Health and
Safety Plan for all on-site workers involved in the field work. The
previously selected remedy employing installation of a cap and the ground
water extraction and treatment system would disturb the contaminated soils
which could potentially affect site workers. Worker exposure could
potentially occur through direct contact, ingestion or inhalation of
contaminated soil particles. Therefore, the amended remedy is more
effective in the short-term than the previously selected remedy.
4.
Implementability
EP A considers how difficult the alternative is to construct and operate, how
other government agencies and EP A will coordinate monitoring programs
and the availability of goods and services and personnel needed to
implement and manage the alternative. Implementability addresses the
technical and administrative feasibility of a remedy, including the
availability of materials and services needed to implement the chosen
solution.
Both the original and selected remedy are readily implementable. The
amended remedy (institutional controls including deed and access
restrictions, fencing and ground water monitoring), is more easily
implemented than the original remedy (capping of disposal cell area with
ground water extraction and treatment). In addition, the amended remedy
involves limited construction activities and, as such, it can be implemented
within a shorter timeframe.
s.
Cost
EP A considers capital costs, operation and maintenance costs, and present
worth, which is the cost of the activities that will take place until the
remedial action is completed. Capital costs apply to activities such as
19

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construction, land and site development, and disposal of waste materials.
Annual operation and maintenance costs are spent on activities such as on-
going operation of equipment, insurance and periodic site reviews.
CERCLA requires that the EP A select a cost-effective alternative that
protects human health and the environment and meets other requirements
of the law. EP A has determined that the selected remedy is as protective
as and is more cost effective than the original remedy for the Midwest
Manufacturing Farm Operable Unit. In a comparison based upon current
costs, the cost of the ground water extraction and treatment system has
risen due to the low-yielding aquifer and the subsequent increase in the
number of extraction wells the system would require.
Project costs for the implementation of the original remedy increased to
$1,091,531, (up from 1990 ROD estimate of $488,844). The amended
remedy is estimated at $118,530 (Alternative 1 in ROD issued September,
1990 plus monitoring of city supply wells (see figure 3) quarterly for the
first year which is 36 water samples at $665/sample or $31,100 with a 30%
contingency). Design, engineering and construction costs are estimated to
be approximately $47,000. Total present value of the monitoring costs for
years 2-5 of the project are estimated to be $40,400 estimated at 8%
interest. Fencing costs are estimated to be approximately $11,000 based
upon a cost of $20 per linear foot (including design cost) with a 30%
contingency. Deed restrictions are estimated to be $1454.
Cost estimates for each water sample collected and analyzed in support of
this ROD Amendment are derived from Appendix I of the Feasibility Study
for the Midwest Operable Unit, Midwest ManufacturingINorth Farm
Superfund site, Kellogg, Iowa dated August 23, 1990. A 30% contingency
was added to these costs. 8% interest was used for present value for all
future costs.
c.
Modifying Criteria:
1.
State Acceptance
The State of Iowa, through the IDNR, is supportive of the amended
remedy for the Midwest Manufacturing Operable Unit. The State of Iowa
prefers the amended remedy to the originally selected remedy.
2.
Community Acceptance
EP A held a public comment period to allow the community to comment on
the preferred alternative as set forth in the Proposed Plan and the other
20

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alternatives considered. EP A's responses to these comments are included
in the Responsiveness Summary section of this document.
Community response addresses the concerns of the public regarding
acceptance of a particular remedy. EPA offered the community an
opportunity to comment on the Proposed Plan for the Midwest
Manufacturing Operable Unit. The community was opposed to the original
remedy for the Midwest Manufacturing Operable Unit. Community
response indicated that the public did not perceive the Midwest
Manufacturing Operable Unit as presenting any significant threat to human
health or the environment.
In comparing the originally developed and selected Midwest Manufacturing
Operable Unit remedy with the amended remedy, EPA has determined that the original
and amended remedy meet the threshold criteria: overall protection of human health and
the environment and compliance with state and federal requirements..
The selected amended remedy for the Midwest Manufacturing Operable Unit
presents the better balance of tradeoffs, with respect to the primary balancing criteria, in
particular with respect to costs, implementability, and short-term effectiveness. While
this amended remedy does not meet the statutory preference for reduction of toxicity,
mobility or volume through treatment, EP A's reevaluation of the risks at the site has lead
EP A to detc:rmine that the levels of hazardous substances remaining at the site do not
warrant active treatment. For the modifying criteria of state and community acceptance,
the amended remedy is preferred. In the tradeoff and balancing of all nine criteria, the
proposed remedy is EP A's selected remedy.
VI.
STATuTORY DETERMINATIONS
NORTH FARM OPERABLE UNIT
o
GROUND WATER
Since the selected amended remedy and the original remedy are identical with
respect to ground water, no new statutory determinations are made herein.
o
SOILS
The EP A has determined, and the State of Iowa concurs, that the selected
amended remedy herein satisfies the statutory requirements specified in CERCLA
Section 121 which state that the selected remedy must protect human health and the
environment and comply with applicable or relevant and appropriate federal and state
requirements. The amended remedy meets the statue's further preference that the
remedy be cost-effective, utilize permanent solutions and alternative treatment
21

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technologies or resource recovery technologies to the maximum extent practicable.
While this amended remedy not meet the statute preference for remedies that employ
treatment that permanently and significantly reduce the volume, toxicity or mobility of
hazardous substances as a principal element, in the balance and tradeoffs, EP A finds it
to bf: the preferred remedy.
MIDWEST MANUFACTURING OPERABLE UNIT
o
GROUND WATER
The EP A has determined, and the State of Iowa concurs, that the selected
amended remedy herein satisfies the statutory requirements specified in CERCLA
Section 121 which state that the selected remedy must protect human health and the
environment and comply with applicable or relevant and appropriate federal and state
requirements. The amended remedy meets the statue's further preference that the
remedy be cost-effective, utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable.
While this amended remedy not meet the statute preference for remedies that employ
treatment that permanently and significantly reduce the volume, toxicity or mobility of
hazardous substances as a principal element, in the balance and tradeoffs, EP A finds it
to bf: the preferred remedy.
o
SOILS
The EPA has determined, and the State of Iowa concurs, that the selected
amended remedy herein satisfies the statutory requirements specified in CERCLA
Section 121 which state that the selected remedy must protect human health and the
environment and comply with applicable or relevant and appropriate federal and state
requirements. The amended remedy meets the statue's further preference that the
remf:dy be cost-effective, utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable.
While this amended remedy not meet the statute preference for remedies that employ
treatment that permanently and significantly reduce the volume, toxicity or mobility of
hazardous substances as a principal element, in the balance and tradeoffs, EP A fmds it
to bf: the preferred remedy.
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RESPONSIVENESS SUMMARY
RECORD OF DECISION AMENDMENT
MIDWEST MANUFACI1JRING/NORTH FARM SITE
NORTH FARM OPERABLE UNIT
MIDWEST MANUFACTIJRlNG OPERABLE UNIT
In accordance with CERCLA Section 117, a public comment period was held from
February 18, 1993 to March 19, 1993, to allow interested parties to comment on EP A's
proposed plan for the Record of Decision Amendment for the North Farm Operable
Unit and the Midwest Manufacturing Operable Unit at the Midwest
ManufacturingINorth Farm site, Kellogg, Iowa.
EPA offered to hold a public meeting if requested. No requests for such a
meeting were received.
EPA received a total of three written comments on the proposed plan; however,
only one of those was received during the public comment period. The Iowa
Department of Natural Resources (IDNR) requested that EPA modify the ground water
monitoring program proposed for each operable unit based upon the information
collected. EP A has modified the monitoring program in the following manner: On a
yearly basis, EP A and the State of Iowa will review the analytical results from the public
and private supply wells and from the monitoring wells to determine if any modifications
to the moJ!itoring program are needed for the upcoming year. EPA and the State will
review the location of the wells tested and the quantity and identity of the contaminants
present. If the review indicates that the contamination is migrating in the direction of
the public or private supply wells or off-site, additional monitoring well locations may be
sampled or a more frequent sampling effort may be implemented to verify the movement
of the contaminants or the threat posed to either the public water supply or a private
water supply. H the ground water samples are found to be at or below the MCLs for the
chemicals of concern at each of the operable units, then the sampling frequency will be
"reduced. All public and private supply wells within one mile of the Midwest
Manufacturing Operable Unit will be tested quarterly for the first two years of
remediation.
23

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NOTE :  INFORMATION OBTAINED FROM


      AMERICAN AUTOMOBILE ASSOCIATION


      CAAA) MAP OF IOWA. NEBRASKA, 1088
                            I
                   \
 MIDWEST MANUFACTURING/NORTH FARM 81
       NORTH FARM OPERABLE UNIT
	.	KELLOGG. IOWA
       rToodimrci—Clyde Consuita

       DfGQfXJQQ. OBOIOCSXRS. JJKD Uf'V'CRtlHmmi
            SITE INDEX
                                              SITE VICINITY MAP
                                  am. rr  3OC  |aur 12/23/871
                             ' IB


                        398RR1
                                                      RIGINAL

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            . j MIDWEST MANUFACTURINO

              OPERABLE UNIT    'v
              * > x x N , .  ,
                       26

NOTE: INFORMATION OBTAINED FROM U3Q8
     KELLoaa. i
     T80N R18W
   IOWA
 SUAORANOLE
   -OCATX5N
)WA
0
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QUADRANGLE. 1S80
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MDWEST yANUFACTURINO/HORTH FARM
NORTH FARM OPERABLE UNIT
KELLOQQ IOWA
• Woodimrd- Clyde Consulti

SITE LOCATION


                                                    POOR CUALI7\'
                                                       ORIGINAL

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        .    R
       - •    i n
CITY WELL #2 OSTH - 30*
CITY WELL #1 DB^TH -
                                         crnr WELL #3 DEPTH -
                               BOUNOAHY OF
                            OPERABLE UNIT SITE
                               MIDWEST OPE=ABLE UNIT
                                    KELLOGGL IOW
                              Sverdrup   rcrir
                             CITY WELL LOCATION MAP
                                                       oor
                                      POOR QUALITY
                                        ORIGINAL

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7A8lE: 1
CONT~~W;.~.i! :::- r:::~:C!~N/HE.A.L i:~ RISK
  GROUND ~~Ta   
     Holt
     Base
 D1 sse}yea Tota,1   Actio
 Cencen~ra~'on :onc:en~~ion Hazara Exoosure Leve
Contaminant Levei Levei Index Pathwav 1!!Ll
Cadmium ND(S ug/l) 19 ugil -1 Ingestion 18
Manganese 8Z-140 ug/l 5Z0-Z:'OO ug/l <1 Ingestion 1700
',,'\sit: ~:f..TERIAL/C::::;7;"~lNATEti SOIL
Hea I tt
Basee
Act; or
Leve'
{merikt
Con~ar:tinant
CQncen~rat1on
Dete!:'tea
BacKground Hazard Exoosure
Conce~tra~ion Index ?!thwav
Cadmium
0.67-830 mg/kg
0.67 mg/kg
>1
Ingestion of
vegeubles
grewn in
contaminauci
5011
13
Cyanide
ND(0.C30)-i.~ mg/kg C.05S mg/kg
<1
Ingestion of
v~etaDies
grown in .
CQntunnatea
50ii
NfA
Nom:
RIA = Net A~~licab1e
mg/kg . mi11igrams per kilogram
ug/l = micrograms per Hter
ND = not detected at levels within ()

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                                -ABLE  2

                  SUMMARY Cr RISK ASSESSMENT  RESULT;  "OR
                     HUMAN EXPOSURE 73 CADMIUM AT THE
                   MIDWEST MANUFACTURING/NORTH FARM SITE
                       NORTH FARM ASEA OPERABLE UNIT
Exoosure  ?2tftwav
                                                      CDI:SfO Ratio for
                                                   Nonearcinooeme Effec
Average
 Case
Maxi
Case
.'r.cisentai  !.-:cesr:cn  cf Ssli

Ir.eesi:cn cr Grcur.c Water

Inoestrsn cf '.'agetacies
  Grown  in  Sc*'i
 < i
 >i
  Worst cs-se scenario.

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                          TABLE  3
EXPOSURE SCENARIOS QUASHED AT THE MIDWEST SITE
Exposed
Population
Trespasser l
Trespasser 2
Trespasser 3
Trespasser 3
j
; Tresrasser A
i
Trespasser <»
Occupational
(Future)
Exposure Point
Wtste Disposal
Trench
Site
River Bank
N. Skunx River
Borrow Pit
(Mann >
Borrow Pit
(Mann)
Future Site
Exposure Medium
Soil
Surface Soil
Soil
Sediment
Surface Water
Sediment
Surface Soil Sludge
Ground water
FTPOIUTB Rotne
lagcsuon
Dermal Coaaa
Ifliestion
lotestion
Dennat Contact
Ingestion
Dermal Contact
Ingestion
lagesnon
Dermal Contact
Ingesnon
Ingesuon
Ingestion
Trtsaaaser 1  Child playing ir. the vu&e disposal treaca.

Trtsaasser 2  Child playing and riiisg a bicycle or all-terrain

Trenasaer 3  Child lailring aoa playing along cfte nver bank

            Child playing in tne Lunau pic
                                               vehicle orrnce.

                                                is rte fcrtr SaxK River.

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                                             TABLE 4
                               SUMMARY OF CARCINOGENIC RISK
     Exposed
    Population

 Adult
! Occupational
! (Future;

 Adult
 Occupational'
(Future;
                      Exposure
                        Point

                     Future Site
                     Future She
                                Exposure
                               . Medium

                                  Soil
                             Ground water
Specific Contaminant
   of Concent (c)

      Arsenic
     Beryllium
   Vinyl Chloride

      Arsenic
     Beryllium
  Vinyl Chloride
1 Exposure
Route
Jagestion
lagestion
Cancer
Risk141
6E-6
1E-3
(9)
 Typically, cancer risk of JE-6 or lower are considered to be of no practical significance, wh
 higner cancer risk levels may be cause for concern.

 Aduit occupational worker.


The chemicals of  potential concern (Table 5) were evaluated in  the risk assessment under ear
exposure  scenario.   Those contaminants  identified  as posing  unacceptable  health risks  a:
presented here.

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TABLE S
CHEMICALS OF POTENTIAL CONCERN8
Alummum
ADumoDY
AneDic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Iron
Lead
Manganese
Mercury
Nickel
Vanadium
Cyanide
Vinyl c:hloride
Carbon disulfide
1.2-Dic:hloroethene
2-Butanone
1.1.1- Trichloroethane
TrichJoroemene
Teuac:hJoroemeDe
TolueDe
Ethyl beDZeDe
XyleDe
PheDaDtftrene
. As identified in the baseliDe risk assessment.

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 Exposed
Population
                   Exposure
                   Medium
                                                    Specific Contaminant
                                                       of Concern^
                                                                    Exposure
                                                                     Route
      Child
      Trespasser j
Wt«e Disposal
Trench
                                                                         iBfestiea
                                                                         Dermsj
      Child
      Trespasser 2
                 Surface Soil
     Child 
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                                           TABLE 7
              SUMMARY OF CHRONIC NONCARCINOGENIC HEALTH HAZARDS
Exposed
Population
Child w
Trespasser I
Child   c&iid playing in the borrow pit (marsh).

w  Adult occupational workers.

w  The chemicals  of potential concern (Table 5) were evaluated in the risk assessment under each
    exposure scenario. Those contaminants identified as posing unacceptable health risks are presented
    here.
NA Not Applicable

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u.s. DEPARTMENT OF COMMERCE
N8t'on.' Technlc8' 'nform8t'on Serv'ce
S"rlIIg"e'd. Ve. 221 n 1
AN EOUAl OPPORTUNITY EMPLOYEn
OH/C/Al nUS/NESS
"""B'ty fOf PrlvBtB US". $30U
POSTAGE ANO FEES PAil)
U.S. DEPARtMENT OF COMMEnCE
COM-211
FIRST CLASS
(IJ

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