Unitec States
Environmental Protection
Agency
Office of .
Emergency and
Remedial Response
bPA/ROD/R09-83/006
December 1983
Superfund
Record of Decision:
Taputimu Farm/Insular
Terratories Site, AS
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TECHNICAL REPORT DATA 1
(PlelUe reDd Instructions on the re~ene before completing)
,. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R09-83/006
4. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION 12/27/83
Taputimu Farm/Insular Territories Site, AS 6. PERFORMING ORGANIZATION CODE
7. AUTHOR«S) 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
". CONTRACT/GRANT ~O.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD
401 M Street, S.W. 14. SPONSORING AGENCY CODE
Washington, D.C. 20460
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Taputimu Farm is a facility owned by the gov~rnment of American Samoa and
is the territory's primary repository of unused and out-dated agricultural chemicals,
and pesticides. The facility is constructed of plywood walls with a corrugated
metal roof and is located approximately a quarter mile from a public beach.
The remedial action alternative selected for this site involves repacking or
overpacking the chemical/pesticide materials stored at the Taputimu Farm, decon-
taminating the storage facilities and sealing the decontaminated surfaces, and trans-
porting all the waste materials to the U.S. mainland for disposal. The cost of
this remedial action is estimated to be $160,000.
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17. KEY WORDS AND DOCUMENT ANALYSIS
~. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. C'OSATI Field/Group
"
Record of Decision
Taputimu Farm/Insular Territories Site, AS
Contaminated media: liquids, solids, air
Key contaminants: pesticides (2,4,5-'.1;',
heptachlor, dieldrin, aldrin, DDT),
organic solvents, PCBs, agricultural
chemicals
18. DISTRI8UTION STATEMENT 19. SECURITY CLASS (Tllis Report) 21. NO. OF PAGES
None 14
120. SECURITY CLASS (Tllis page) 22. PRICE
None
EPA Form 2220-1 (Rn. "-17)
PREVIOUS EDITION IS OBSOLETE
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INSTRUCTIONS
REPORT NUMBER .
Insert the EPA report number as it appears on the cover of the publkation.
2.
3.
LEAVE BLANK
RECIPIENTS ACCESSION NUMBER
Reserved for use by e;a~h rtport recipienl.
4.
TITLE AND SUBTITLE
Title should indicate dearly and brieny the subje.:t ~'ov.:ra!;~ uf th.: report. and be: displ;aynlpromin~'nlly. S,'I suhtitk, ifu!
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DEC 2 7 ;s@
Record of Decision
Remedial Action Selection
Site: Taputimu Farm, American Samoa
Documents Reviewed:
I have reviewed the following documents describing the
analysis of cost-effective remedial actions developed for the
Taputimu Fa~ site:
"Remedial Investigation, Insular Territory Hazardous
Waste Sites, Taputimu Farm Pesticide Storage Facility,
American Samoa, Draft Report"; Black & Veatch Consulting
Engineers; June 30, 1983.
Staff summaries and recommendations.
Recommendation by the Governor of Americ.an Samoa.
Description of Selected Option:
The remedial action involves repacking or overpacking the
chemical/pesticide materials stored at Taputimu Farm, decontamina-
ing the storage facilities and sealing the decontaminated surfaces,1
and transporting all the waste materials to the U.S. mainland for
disposal. The cost of this option is estimated to be $160,000.
Declarations:
Consistent ~ith the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA) and the National
Contingency Plan, I have determined that the packaging, transport
and disposal off-site of hazardous substances is cost-effective
and that it effectively mitigates and minimizes damage to, and
provides adequate protection of public health, welfare and the
environment. I have also determined that the action being taken
is appropriate when balanced against the need to use Trust Fund
money at other sites. In addition, I have determined that the
off-site transport of hazardous substances is more cost-effective
than other remedial actions and, therefore, is consistent with
section 101(24) of CERCLA.
M. nomas
sistant Administ ator
ffice of Solid Waste and
Emergency Response
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TAPUTIMU FARM
American Samoa
Remedial Action Briefing Document
Purpose of the Remedial Action:
The recommended remedial action is the offsite transport and
disposal of agricultural chemicals and pesticides which are
improperly stored on American Samoa..
~ackground:
o
Taputimu Farm, a facility owned by the government of
American Samoa, is the primary repository of unused and
out of date agricultural chemicals and pesticides on
American Samoa.
o
The pesticides are stored in a warehouse of plywood wall
construction with corrugated metal roof located 1/4 mile
from a public beach.
o
A threat to public health and the environment is presented
by the site. Because of the climate of American Samoa,
. there is a concern that the warehouse will flood, transporting
chemicals and pesticides to the public beach and contamina-
ting the beach and marine life. In addition, the warehouse
is used for purposes other than pesticide storage and
workers are thus exposed to the chemicals through inhalation
and direct contact.
o
On September 19, 1981,' the American Samoa Environmental
Quality Commission named the Taputimu Farm as the highest
priority site on American Samoa. It was placed on the
interim list of 115 priority waste sites in October 1981
and is included on the final National Priorities List
published on September 8, 1983.
Remedial Planning Activities to Date:
o
A remedial investigation and feasibility study was conducted
at the site by EPA's Interim Zone Contractor, Black and
Veatch, from November 1982 through July 1983.
o
Investigations found pesticides labeled as heptachlor,
methoxyclor, dieldrin and 2,4,S-T stored in open,
deteriorating containers and spilled across the floor of
the warehouse.
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o
Samples taken from unlabeled material contained in the
warehouse revealed significant concentrations of priority
pollutants such as pentachlorophenol, toluene, ethylbenzene,
aldrin, dieldrin and DDT.
o
About 4,000 lbs. of liquid and solid pesticide material
is stored in the warehouse.
o
Based on the results qf the sampling, alternatives were
developed for remedial action. These alternatives are
described in the attached document, entitled "Alternative
.Selection".
Regional and Territorial Recommendation:
o
Region 9 and the American Samoan
Commission recommend shipment of
u.S. mainland for disposal. The
. estimated to be $160,000.
Environmental Quality
all the wastes to the
cost of this option is
Policy Aff~cting This Site:
o
Omnibus Territories Act
Section 501 of P.L. 95-134, and section 601 of P.L. 96-20~
the Omnibus Territories Act, enable the Federal governmen~
to waive normal. cost-sharing requirements for the Insular
Territories. The Federal government must waive cost-sharing
under $100,000 for the Northern Mariana Islands and American
Samoa. The Federal government may waive cost-sharing over
$100,000 for the Northern Mariana Islands and American
Samoa. Because, American Samoa's share of the costs of
the remedial action will be less than $100,000, the cost
share requirements under CERCLA must be waived.
Enforcement:
o
During the week of September 19, 1983, a Notice Letter was
delivered to the Governor of American Samoa as the
responsible party. The Government of American Samoa owns
and operates Taputimu Farm.
o
The Governor acknowledged the American Samoan Government's
liability and requested that EPA proceed with the planned
actions. The American Samoan government has declined to
undertake or pay for the action voluntarily.
Related Planned Removal:
o
An unlisted site on American Samoa, the Tafuna Power Plant
contains several PCB contaminated transformers. Removal ~
these transformers from that site will be combined with
this project as a planned removal. Because the costs of
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mobilization in the South Pacific is by far the most
expensive component of the project, combining the planned
removal with the remedial action represents substantial
cost savings to the government. The work is expected add
no more than $20,000 to the cost of the project.
EPA Lead for Implementation:
o
Because the costs for this project are relatively small,
the U.S. Army Corps of Engineers suggested that EPA
maintain the lead for the project. CH2M Hill, the REM-
FIT contractor will subcontract the work for EPA.
o
The schedule for work calls for full implementation of
the.selected remedial action by the end of January, 1984.
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I
Alternative Selection
Taputimu Farm, American Samoa
Background
On July 1, 1983, th~ Region 9 office of EPA transmitted
the "Remedial Investigation, Insular Territory Hazardous Waste
Sites, Taputimu Farm Pesticide Storage Facility, American Samoa,
Draft Report" prepared by Black & Veatch Consulting Engineers,
to the Environmental Quality Commission, American Samoa (EQC)
and the Corps of Engineers (COE) for review and comment. The
COE determined that i~ would not be cost-effective for it to
administer any of the remedial alternatives. On July 14, 1983,
EPA made the decision to refer the project to the zone contractor,
CH2M Hill, for implementation upon approval of funding.
EQC and EPA staff reviewed the alternatives.and identified
the recommended remedial action. The action involves the removal
of all hazardous substances from the Taputimu Farm site for
disposal on the U.S. mainland.
On July 15, 1983, EPA requested that EQC manage the public
review of the RI/FS and the recommended remedial alternative
action because of the great distance of American Samoa from the
Region 9 office. A newspaper article and radio announcments
were used to notify the public that the RI/FS and the recommended
remedial alternative action were available for review from July
25 to August 12, 1983. No public comments were received by the
EQC.
Feasibility Study and Alternatives
The object of the feasibility study was to develop source
control remedial actions which would eliminate the potential
for contamination from agricultural chemicals/pesticides stored
. at the Taputimu Farm.
The chemical/pesticide materials at Taputimu Farm are
improperly stored, improperly containerized, and lack identifying
information in numerous instances. They p~esent a health hazard
to individuals working in the area via inhalation of the vapors
and 'by' di rec't'. cb'ntact. Because of the heavy annuaJ:-'p'tec ip i tation
and the proximity of the site to a public beach, the potential
also exists for human health problems and environmental damage
due to washout of materials from the warehouse.
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After the remedial investigation was completed, six alternative
remedies for the site were evaluated. The alternatives were:
1. No Action
2. Store on American Samoa
3. Dump in Ocean
4. Treat and Dispose of on American Samoa
5. Ship to U.S. Mainland and Dispose
6. Recover Usable Material and Ship Remainder to
U.S. Mainland for Disposal
The six alternatives were evaluated for:
o
Technical Feasibility
Cost Effectiveness
Environmental Effectiveness
Protection of Public Health
and Welfare
o
o
o
As a result of the evaluation, four of the options were
excluded from consideration:
1. No Action - This alternative does not alleviate the threat
to public health posed by the site. The proximity of the
public beach and the high annual precipitation presents the
potential for the materials to wash out of the building and
causecadditional human health and environmental problems. .
In addition, the chemicals/pesticides as presently stored
pr~sent a health hazard to individuals working in the area
via inhalation and direct contact.
2. Store on American Samoa - Under this alternative, a storage
facility would be designed and built for the hazardous
materials somewhere on American Samoa. The cost for this
alternative are as high as that of other alternatives which
remove the material from the island completely. In addition,
the island climate and geology make construction of a reliable
storage facility difficult. Because this alternative was
not significantly cheaper than other alternatives and it
represented less reliable protection for the island environment,
it was not considered further.
3. Dump in Ocean - This alternative would require obtaining a
permit to dump materials into the ocean under the Ocean
Dumping Regulation (40 CFR Parts 220-28) which would delay
response action. Moreover, because of the nature of the
materials, this permit would be difficult if not impossible
to obtain.
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. 4. Treat and Dispose of material on American Samoa. No disposal
facility currently exists onsite or elsewhere on American
Samoa. The costs to design and build such a facility great~
exceed (3x) the cost to ship and dispose of the material at
an existing facility.
In addition to an assessment of the technical alternatives for
disposing of the hazardous materials, the appropriate level of
decontamination of the storage facilities at Taputimu Farm was
evaluated. Four levels were considered:
Level
1 - Sweeping, power vacuuming, washing/rinsing, and
. sealing the contaminated surfaces. Collected
material, wash and rinse water, and certain
equipment to be packed and included in the hazardous
waste shipment.
Level 2 - Levell plus removal and replacement of existing
walls.
Level 3 - Level 2 plus pouring new concrete slab over existing
slab.
Level 4 - Level 2 plus removal and reconstruction of floor
slab.
Because the intended future use of the warehouse was limited to
storage of farm equipment, Levell was determined to provide adeq~
decontamination.
Two technical alternatives were considered cost effective as remedies
for Taputimu Farm:
5. Ship to U.S. mainland and dispose
6. Recover usable material and ship remainder to
u.S. mainland for disposal
Region 9 and the American Samoa Environmental Quality Commission
recommend shipment of all of the waste to the u.S. mainland for
appropriate disposal. The sixth alternative is not recommended
because it would greatly increase the institutional complexity of
the remedy and does not represent significant cost saving ($5000-
$10,000). The permits required to repackage and distribute the
pesticides would also delay the remedy.
The estimated cost for the recommend remedy is $160,000.
Community Involvement
The RI/FS Reports and the selected remedial alternative
action were subject to a 3-week public review from July 25,
1983 to August 12, 1983.
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No comments were received on the reports or selected
remedial alternative action.
Recommended Action
Section 300.68(j) of the National Contingency Plan (NCP)
[47 CFR 31180, July 16, 1982] states that the appropriate extent
of remedy shall be determined by the lead agency's selection of
the remedial alternative which the agency determines is cost-
effective (i.e., the lowest cost alternative that is technolo-
gically feasible and reliable and which effectively mitigates
and ,minimizes damage to and provides adequate protection of public
health, welfare, or the environment). Based on our evaluation of
the cost-eftectiveness of each of the proposed alternatives, results
of the 3-week public review period, information from the Site
Investigation and Feasibility Study Reports, and information from
the Environmental Quality Commission of American Samoa, we recommend
the selected alternative above. This alternative includes: 1)
repacking or overpacking the chemical/pesticide materials stored
at Taputimu Farm and transporting it to the U. S. mainland for
disposal and 2) decontaminating the stor3ge facilities and sealing
the decontaminated surfaces. We have determined that implementation
of this alternative will effectively mitigate damage to and provide
'adequate protection of public health, welfare, and the environment.
The capital cost of this alternative is estimated to be
$160,000. There are no operation and maintenance costs associated
with this alternative.
Territory Input
. After giving careful consideration to the cost-effectiveness
of' each alternative and not receiving any public comments on the
investigation and feasibility reports or the selected alternative,
the Governor of American Samoa, with the support of the Environ-
mental Quality Commission, requested that EPA implement the
selected alternative. The letter from the Governor is attached.
Proposed Action
We request your approval for the removal of chemical/
pesticide materials from Taputimu Farm to the u.S. mainland
for disposal. In addition, we request an allocatiort of $160,000
for the project.
Tentative Schedule
Initiate
Complete
Initiate
Complete
Design
Design
Clean-up
Clean-up
November, 1983
December, 1983
January, 1984
January, 1984
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