United States        Office of
          Environmental Protection   Emergency and
          Agency           Remedial Response
EPA/ROD/R07-93/072
February 1993
c/EPA    Superfund
          Record of Decision:
          Kern-Pest Laboratories, MO

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4.
S0272-101
REPORT DOCUMENTA11ON 11. REPORT NO.
PAGE EPA/ROD/R07-93/072
1lU8 and Subtitle
SUPERFUND RECORD OF DECISION
Kem-Pest Laboratories (Amendment), MO
Second Remedial Action - Final
Author(s)
~
3. RecIpient's Ace_Ion No.
Ii
Raport Date
02/05/93
6.
7.
8.
Performing Organization Rapt. No.
8.
Performing Organization Name snd Add-
10
Project T88IcIWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. SponsorIng Organization Name and Add,..
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period CovIf8d
Agency
800/800
14.
1!i. Suppl8m8rUry Not.
PB94-964305
16. Ab8tract (Umlt: 200 words)
The 6-acre Kem-Pest Laboratories site is a former pesticide production facility located
in Cape Girardeau County, Missouri. Land use in the area is predominantly rural, with
residences, an industrial storage tank facility, agricultural fields, and the
Mississippi River located near the site. Site features include a concrete block
building that housed a pesticide formulation operation and currently holds
approximately 11,200 gallons of contaminated water in its basement; six storage tanks
for solvents and oil; a lagoon used for the disposal of sewage and plant waste; and an
unconfined, underground aquifer system. From 1965 to 1977, Kern-Pest Laboratories
fo~ulated various pesticide products, including liquid pesticides, granular
insecticides and herbicides, and pesticide dust, on site. Waste from pesticides
production included aldrin, dieldrin, endrin, and heptachlor and was disposed of in the
onsite lagoon. No production or disposal activities have occurred onsite since 1977,
and the lagoon was backfilled with clay by the owner in 1981. Based on Federal
assessments and investigations conducted in 1981, it was determined that the lagoon and
the fo~ulation building were the most significant sources of site contamination.
. Ground water contamination has resulted from the migration of contaminants from the
soil within the lagoon; and ground water also may have acted as a flushing mechanism
(See Attached Page)
17. Document AnaIy8i8 .. Deac:rtptora
Record of Decision - Kern-Pest Laboratories
Second Remedial Action - Final
Contaminated Medium: debris
Key Contaminants: organics (pesticides)
(Amendment), MO
b.
1denl11le1'8/Op8noEnd8d T81'1118
c.
COSATI FielD'Group
18. AnIIabIIlty Stat--.t
18. Security CIu8 (This Report)
None
20. Security au. (This p.)
None
21. No. of Pages
12
22. PrIc:8
(See ANSI-Z38.18)
s.. IMtructloM on "-
OPTIONAL FORM m (4-77)
=:"y NTIS-35)
ment ofCommen:e

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EPA/ROD/R07-93/072
Kem-Pest Laboratories (Amendment), MO
Second Remedial Action - Final
Abstract (Continued)
for contaminants in the subsurface soil. A 1989 ROD addressed the contaminated surface
soil in the lagoon, surface soil in the lagoon area and near the formulation building, and
sediment in drainage channels onsite and offsite, as OUI. A 1990 ROD addressed pesticide
contamination in the formulation building and ground water, as OU2. This ROD amends the
1990 selected remedy for decontamination and offsite incineration of the formulation
building debris, but does not affect the original selected remedy for ground water and
institutional controls. New information has indicated that decontamination of surface and
subsurface porous cinder block construction would be technically infeasible because
saturation of the building cinder block construction allows for infusion of contaminants
into the block. Also, EPA determined that the roof of 'the formulation building has
deteriorated to the point that it would have to be rebuilt, rather than just
decontaminated and preserved. The primary contaminants of concern affecting the debris
are organics, including pesticides.
The amended remedial action for this site includes demolishing the formulation building,
followed by offsite disposal of the contaminated debris in a RCRA-approved landfill. The
estimated present worth cost for this remedial action is $1,230,000.
PERFORMANCE STANDARDS OR GOALS:
Not provided.

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DECLARATION
RECORD OF DECISION AMENDMENT
KEM-PEST LABORATORIES SITE
GROUND WATER AND FORMULATION BUILDING
SITE NAME AND LOCATION
Kern Pest Laboratories
Cape Girardeau County, Cape Girardeau Missouri
STATEMENT OF BASIS AND PURPOSE
This decision document, together with a Record of Decision
(ROD) dated December 31, 1990, represents the selected remedial
action for addressing contaminants in the Ground Water and
Formulation Building Operable Unit (Operable Unit #2 or OU #2) at
the Kem-Pest Laboratories site, Cape Girardeau County, Missouri,
developed in accordance with the Comprehensive Environmental
Response, compensation and Liability Act (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and to the extent practicable, the National Contingency Plan
(NCP) .
This decision is based on contents of the administrative
record file for the Kem-Pest Laboratories site, Ground Water and
Formulation Building Operable Unit.
The United states Environmental Protection Agency (EPA) is
the lead agency for the site, and the Missouri Department of
Natural Resources (MDNR) Hazardous Waste Program has been
designated the support agency. This ROD amendment is being
issued by the EPA. The state of Missouri concurs on the amended
selected remedy.
DESCRIPTION'OF THE AMENDED SELECTED REMEDY
The primary reason for amending the 1990 ROD is that new
information has indicated that decontamination of the formulation
building is technically infeasible. This selected amended remedy
does not change the 1990 ROD with respect to the required ground
water monitoring and the institutional controls.
The major components of the selected remedy, as now amended,
include:
Ground Water
No remedial action. Monitoring will be conducted to
verify that no unacceptable exposures to risks posed by
conditions at the site occur in the future.
Wells to be monitored include existing monitoring
wells, an additional monitoring well to be installed
during remedial design and private drinking water wells
located off of the site.
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Formulation Buildinq
Demolition of the formulation building with off-site
disposal of the demolition debris materials.
Institutional controls that limit future use of the
property to commercial or industrial activities.
STATUTORY DETERMINATIONS
Ground Water
No new statutory determinations.
Formulation Buildinq
The selected amended remedy is protective of human health
and the environment, complies with applicable or relevant and
appropriate federal and state requirements, and is cost-
effective. This remedy utilizes permanent solutions and
alternative treatment technologies (or resource recovery)
technologies to the maximum extent practicable. This remedy does
not satisfy the preference for remedies that employ treatment
that permanently and significantly reduces the volume, toxicity,
or mobility of hazardous wastes as a principal element.
Because this remedy will result in hazardous substances
remaining on the site above health-based levels, a review will be
conducted within five years after commencement of remedial action
to ensure that the remedy continues to provide adequate
protection of human health and the environment.
W' liam W. Rice
cting Regional Administrator
U.S. EPA, Region VII

Z/':;;/93
Dfte/
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DECISION SUMMARY
RECORD OF DECISION AMENDMENT
KEM-PEST LABORATORIES SITE
GROUND WATER AND FORMULATION BUILDING
I. . LOCATION AND DESCRIPTION
The Kern-Pest Laboratories Site is located in Cape Girardeau
County, Missouri, approximately three miles northeast of the city
of Cape Girardeau, Missouri. The site consists of approximately
6 acres.
The Kern-Pest Laboratories facility was constructed in 1964.
From 1965 to 1977, various pesticide products including liquid
pesticides, granular insecticides and herbicides and pesticide
dust were formulated in the building located at the site. Wastes
generated were disposed of in an on-site lagoon. Production and
disposal ceased in 1977. The lagoon was backfilled with clay in
1981.
The cleanup of the site was divided into two distinct
phases, or operable units. Operable Unit #1 addressed cleanup of
soils and sediment at the site. This phase of on-site clean up
commenced in March 1992 and was completed in May 1992. Operable
Unit #2 addresses the ground water and formulation building, the
subject of this ROD amendment.
Greater detail concerning the site characteristics and the
remedial alternatives may be found in the administrative record
for the site.
II.
COMMUNITY RELATIONS
The united Stat~s Environmental Protection Agency (EPA) is
issuing this 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 the Superfund Amendments and Reauthorization Act of
1986 (SARA), and Section 300.435 (c) (2) (II) of the National
contingency Plan (NCP).
The Proposed Plan for this ROD Amendment was made available
to the public in the administrative record file located at the
Cape Girardeau Public Library and the EPA Region VII Office,
Kansas City, Kansas. A public notice was pUblished in The
Southeast Missourian on October 21, 1992, announcing the start of
the public comment period, the date of a public meeting, and the
availability of the administrative record file at the library.
Fact sheets were also mailed to area residents, local
officials, and the media announcing the availability of the
project documents, the pUblic comment period, and the public
meeting.
On November 12, 1992, a public meeting was held in Cape
Girardeau, Missouri. At the meeting, representatives from EPA
and MDNR were available to answer questions regarding site
conditions and the proposed ROD amendment.
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On November 20, 1992, the site property owner requested an
extension of the public comment period. In January, a public
notice was published in The Southeast Missourian, indicating
that the administrative record had been supplemented and was
available for review and that the public comment period on the
Proposed Plan was extended to January 29, 1993.
A response to comments received during the public comment
period and extension is provided in the Responsiveness Summary
section of this ROD Amendment.
III. REASONS FOR ISSUING THE ROD AMENDMENT
Since the issuance of the ROD for OU #2 on December 31,
1990, new information has indicated that decontamination of
surface and subsurface porous cinder block construction as found
in the formulation building, and as outlined in the ROD for OU
#2, would be technically infeasible. Saturation of the building
cinder block construction allows for infusion of contaminants
into the block. Also, EPA determined that the roof of the
formulation building has deteriorated to the point that it would
have to be rebuilt, rather than just decontaminated and
preserved. In addition, since the issuance of the ROD for OU #2,
the regulatory deadline for land disposal of contaminated
construction debris was extended to May 8, 1993, which would
enable the cost-effective implementation of the selected amended
remedy.
This ROD Amendment addresses changes only with respect to
the formulation building, and does not change the 1990 ROD with
respect to the ground water and with respect to institutional
controls for the property.
IV.
DESCRIPTION OF THE ORIGINAL AND AMENDED REMEDIES
The originally selected remedy in the 1990 ROD for OU #2
required the decontamination of the formulation building and
ground water monitoring. Specifically, the original remedy
required decontamination of the formulation building by surface
layer removal and off-site incineration of decontamination debris
at a RCRA-authorized disposal facility. Institutional controls
to limit future land use of the site were also required. The
1990 ROD for OU #2 also considered, but did not select, the
amended remedy now selected by EPA.
The selected amended remedy for OU #2 retains the same
elements for ground water and institutional controls as in the
original remedy. However, with respect to the formulation
building, the selected amended remedy requires demolition of the
building and off-site land disposal of the debris in compliance
with the Resource Conservation and Recovery Act (RCRA) Subtitle C
requirements. .
V.
COMPARATIVE ANALYSIS OF THE ORIGINAL AND AMENDED REMEDIES
In comparing the original remedy with the selected amended
remedy, EPA has determined that the original and selected amended
remedies are equivalent with respect to the criteria of overall
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protection of human health and the environment and compliance
with state and federal requirements. This is consistent with the
comparisons made in the 1990 ROD for OU #2, in which both
alternatives met those criteria.
The current estimate of the cost of the selected amended
remedy is $1.23 million, which is greater than the $640,000
amount reflected in the Proposed Plan for this ROD amendment.
The explanation for this difference is contained in Section VII,
Documentation of Significant Changes, of this Decision Summary.

Although the cost estimate for the selected amended remedy
has risen, it is not substantially different from the slightly
higher $1.25 million estimate for the original remedy, and EPA
has determined that the selected amended remedy is cost
effective. The selected amended remedy also has the benefits,
unlike the original remedy, of being implementable and reducing'
or eliminating future exposure threats to human health and the
environment.
EPA has also determined that the selected amended remedy is
implementable, while the original remedy is not. Demolition of
the building is a proven technology, and the construction
schedule is such that the selected amended remedy can be
implemented within the timeframe of the regulatory extension for
land disposal of the contaminated construction debris. On the
other hand, decontamination, in EPA experience with similarly
contaminated structures, has proven technically infeasible due to
the infusion of contaminants into the cinder block construction
materials.
With respect to short-term effectiveness, the original
remedy and the selected amended remedy present similar site risks
and take approximately the same time to implement.
With respect to long-term effectiveness, the selected
amended remedy is preferred because it reduces or eliminates the
threat to human health and the environment at the site from
releases from the formulation building by demolishing the
building and removing all debris off-site. Under the original
remedy the building could not feasibly be decontaminated, and any
preservation of the building for future use would require sealing
the building surfaces with a coating to prevent dermal contact,
with the risk of future releases should the seal be broken.
With respect to the reduction of toxicity, mobility, or
volume through treatment, the selected amended remedy does not
employ treatment. As discussed in the 1990 ROD for OU #2, the
original remedy is the only alternative considered which employs
such treatment.
With respect to the modifying criteria of state acceptance,
the state of Missouri concurs with the selected amended remedy.
Finally, with respect to community acceptance, the response
to comments received during the public comment period and
extension is provided in the Responsiveness Summary, which is a
part of this ROD Amendment.
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The selected amended remedy presents the better balance of
tradeoffs, with respect to cost, implementability, long-term
effectiveness and permanence. The statutory preference for
reduction of toxicity, mobility or volume through treatment is
not met. However in the tradeoff and balancing of all nine
criteria, the selected amended remedy is EPA's preferred
alternative, in particular since it constitutes an implementable
remedy that provides for long-term effectiveness and permanence.
VI.
STATUTORY DETERMINATIONS
Ground Water
The 1990 ROD determined no remedial action was necessary for
ground water. Since the selected amended remedy and the original
remedy are alike with respect to groundwater, no new statutory
determinations are made herein.
Formulation Buildinq
The EPA has determined, and the State of Missouri concurs,
that the selected amended remedy herein satisfies the statutory
requirements specified in CERCLA Section 121, which establishes
the statutory requirements and preferences for remedial actions.
These specify that, when complete, the selected remedy must
protect human health and the environment, comply with applicable
or relevant and appropriate federal and state requirements, be
cost-effective, and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. In addition, the statute includes a
preference for remedies that employ treatment that permanently
and significantly reduces the volume, toxicity, or mobility of
hazardous wastes as a principal element.
Protection of Human Health and the Environment
The 1990 ROD considered the remedial alternative of
demolition and off-site disposal, which is the selected amended
remedy herein, and determined that it was protective of human
health and the environment.
Attainment of Applicable. or Relevant and Appropriate
Requirements lARARs)
The 1990 ROD considered the remedial alternative of
demolition and off-site disposal, which is the selected amended
remedy herein, and determined that it met all ARARs applicable to
the site.
Cost-Effectiveness
The selected amended remedy is cost effective.
utilization of Permanent Solutions and Alternative Treatment
Technoloqies to the Maximum Extent Practicable
The selected amended remedy reduces or eliminates the threat
to human health and the environment at the site from releases
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from the formulation building by demolishing the building and
removing all debris off-site.
Preference for Treatment as a PrinciDal Element
The selected amended remedy does not meet the preference of
treatment as a principal element.
VII. DOCUMENTATION OF SIGNIFICANT CHANGES
The current estimate of the cost of the selected amended
remedy, $1.23 million, is greater than the $640,000 amount
published in the Proposed Plan for this ROD amendment.

Since the publication of the Proposed Plan and the extension
of the public comment period to January 29, 1993, the issuance of
this ROD Amendment has occurred later than anticipated by EPA.
Construction activities for the selected amended remedy cannot
proceed prior to issuance of the ROD Amendment, and construction
activities must be substantially completed by the May 8, 1993
RCRA Land Ban deadline for disposal of the debris from demolition
of the formulation building. As a result of a construction start
later than anticipated, the construction and off-site disposal
schedule had to be compressed, resulting in higher costs. Such
costs include higher labor costs, different phasing of work tasks
to comply with the deadline, higher equipment costs, and other
changes to complete the work in an expedited manner. The current
cost estimate is included in the administrative record for the
site.
For estimated costs similar to the $1.25 million estimate
for the original remedy, the selected amended remedy is cost
effective and has the benefits, unlike the original remedy, of
being implementable and reducing or eliminating future exposure
risks at the site.
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