United States
Environmental Protection
Agency
Office of
1 Emergency and
Remedial Response
EPA/ROD/R04-89/057
September 1989
SEPA
Superfund
Record of Decision
Stauffer Chemical/Cold Creek, AL
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO. ,
EPA/ROD/R04-89/057
3. Recipient1* Acceaeion No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Stauffer Chemical/Cold Creek,
First Remedial Action
S. Report D«U
09/27/89
AL
7. Autnor(a)
8. Performing Organization Rept No.
9. Performing Organization Name and Addmea
10. Project/Teak/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponaoring Organization Nam* and Addree*
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report ft Period Covered
800/000
14.
15. Supplementary Notea
16. Abatract (Umit: 200 worda)
The Stauffer Chemical Cold Creek Site is in Bucks, Mobile County, Alabama, approximately
20 miles north of Mobile, Alabama. The area is predominantly industrial, with a few
small rural residential communities within a few miles of the site. The Mobile River
borders the site to the east. The Cold Creek plant began operating in 1966 under the
ownership of the Stauffer Chemical Company and is currently owned and operated by ICI
Americas, Inc. Until 1974, an unknown amount of sludges and solid wastes containing a
variety of herbicides and pesticides were placed in two waste disposal sites, referred
to as the Cold Creek North and South Landfills. Both were closed in 1974 with
geomembrane caps and side-wall liners. One clay-lined lagoon was used for
neutralization of wastewater until 1975, and was closed in 1978. A new membrane-lined
pond was constructed to replace it and is currently in use. Under a consent agreement
with EPA, Stauffer completed a remedial investigation in May 1988, which identified
contamination of the soils, pond sludges, swamp sediments, and ground water. Although
there are four media of concern at the Stauffer Site, this remedial action addresses the
contaminated ground water, because ground water is the source for drinking water for the
area. Additional Records of Decision are planned for the source control operable units
and the Cold Creek Swamp. The primary contaminants of concern affecting the ground
water are VOCs including carcinogenic compounds such as carbon tetrachloride, and other
organic compounds including pesticides. (Continued on next page)
17. Document Analyaia a. Doacriptors '
Record of Decision - Stauffer Chemical/Cold Creek, AL
First Remedial Action
Contaminated Medium: gw
Key Contaminants: VOCs (carbon tetrachloride), other organics (pesticides)
b. Identiflera/Open-Ended Term
c. COSATI Held/Group
18. Availabiaty Statement
19. Security CUaa (This Report)
None
20. Security Claa* (Thla Page)
None
21. No. ofPagea
64
22. Price
(See ANSJ-Z39.18)
See toefructfo/M on Rew/w
OPTIONAL FOHM 272 (4-77)
(Formerly NTIS-15)"
Department ol Commerce
-------
EPA/ROD/R04-89/057 '
Stauffer Chemical/Cold Creek, AL
16. Abstract (Continued) -'
The selected remedial action for the ground water operable unit at this site includes a
modified ground water intercept and treatment system with surface water discharge. This
alternative involves continued operation of the existing intercept and treatment system,
which consists of aeration via spray nozzles with discharge to a treatment pond and then
to the Mobile River; installation of additional extraction wells, based on ground water
quality characteristics, water-table gradients, and pumping activities at the site and
adjacent properties; design and implementation of modifications to the treatment system;
and monitoring of effluent, ground water concentrations, and pumping rates. Further
investigation and treatability studies are necessary before EPA can determine the
remedial action for the source units'(soil and pond sediment) and the swamp.' Bench
and/or pilot-scale testing of in-situ treatment alternatives for some of the source
units, such as a wastewater treatment pond, is appropriate as part of the Remedial
Design. A range of treatment technologies including thermal desorption and vapor
extraction is being considered. The estimated total capital cost for this remedial
action is $3,119,200, which includes O&M costs. Specific O&M costs were not provided.
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-> Record of Decision
Ground Water Treatment Operable Unit
Site Name and Location; Stauffer Chemical/LeMoyne - Axis, Alabama
Stauffer Chemical/Cold Creek - Bucks, Alabama
Statement of Basis and Purpose;
This decision document presents the selected remedial action for the Stauffer
Chemical LeMoyne and Cold Creek Sites, in Mobile County, Alabama, developed
in accordance with the Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendment and
Reauthorization Act of 1986 (SARA), and to the extent practicable, the
National Contingency Plan (40 CFR 300). The decision is based on the
administrative record for the sites. The attached index identifies the items
that comprise the administrative record upon which the selection of the
remedial action is based.
The State of Alabama has concurred on the selected remedy.
Site Assessment
Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in this Record of
Decision (ROD), may present an imminent and substantial endangerment to
public health, welfare, or the environment.
m
Description of the Selected Remedy
This initial ground water operable unit is the first of three planned for the
Stauffer sites. It addresses a principal threat at the sites by controlling
the migration of contaminants present in the surficial aquifer. The operable
unit is fully consistent with all planned future site activities. Future
site activities include treatability studies or piloting of treatment
technologies for the source control and swamp operable units, which will
comprise the overall site remedy. ,
The major components of the selected remedy are as follows:
Modify existing ground water intercept and treatment system; install
additional monitoring (Detection Monitoring) and extraction wells
* Continue extracting ground water from the surficial aquifer via existing
and additional intercept wells
* Monitor ground water movement at the site to determine the adequacy of
the remedial action
* Conduct treatability studies as appropriate for source treatment of RCRA
Solid Waste Management Units (SWMUs) and CERCLA disposal sites
* Decommission wells no longer needed for monitoring
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Declaration
The selected remedy is protective of human health and the environment,
attains Federal and State requirements that are applicable or relevant and
appropriate to the remedial action, and is cost-effective. The remedy
satisfies the statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element and utilizes
permanent solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable.
Because this remedy will result in hazardous substances remaining on-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.
SEP 2?
(Date)
Greer C. Tidwell
Regional Administrator
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Record of Decision
Summary of Remedial Alternative Selection
Stauffer Chemical - LeMoyne and Cold Creek Sites
Axis and Bucks, Mobile County, Alabama
Prepared by:
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia
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_, TABLE OF CONTENTS
1.0 Site Location and Description 1
2.0 Site History 1
2.1 LeMoyne 1
2.2 Cold Creek 4
2.3 Enforcement History 4
3.0 Community Relations History « 5
4.0 Scope of Remedial Action 6
5.0 Site Characteristics 6
6.0 Summary of Site Risks 12
6.1 Exposure Assessment Summary 12
6.2 Toxicity Assessment 14
6.3 Risk Characterization 14
6.4 Environmental Risk 15
7.0 Documentation of Significant Changes 15
8.0 Description of Alternatives 15
8.1 Alternative 1 - No Action 15
8.2 Alternative 2 - Existing Ground Water Intercept and Treatment
System with Surface Water Discharge 16
8.3 Alternative 3 - Modified Ground Water Intercept and Treatment
System with Surface Water Discharge 16
8.4 Alternative 4 - Existing Ground Water Intercept and Treatment
v System with Surface Water Discharge and In-situ
Vapor Extraction 19
9.0 Summary of Comparative Analysis of Alternatives 19
9.1 Protectiveness of Human Health and the Environment 20
9.2 Compliance with Applicable or Relevant and Appropriate
Requirements (ARARS) , 20
9.3 Reduction of Toxicity, Mobility, or Volume 21
9.4 Short-term Effectiveness 21
9.5 Long-term Effectiveness 21
9.6 Implementabilty '..» '... 21
9.7 Co«t 21
9.8 State and Community Acceptance 22
10.0 The Selected Remedy 22
11.0 Statutory Determinations 23
11.1 Protection of Human Health and the Environment 23
11.2 Attainment of Applicable or Relevant and Appropriate
Requirements 23
11.3 Cost-Effectiveness 24
11.4 Utilization of Permament Solutions and Alternative Treatment or
Resource Recovery Technologies to the Maximum Extent
Practicable 24
11.5 Preference for Treatment as a Principal Element 24
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LIST OF FIGURES
~f
Figure 1.1- Site Location Map 2
Figure 2.1- Site Configuration 3
Figure 5.1- Flood Plain Map 7
Figure 5.2 - Source Well Sample Locations 9
Figure 5.3 - Area Well Sample Locations 10
Figure 9.1- Site Area Well Locations 17
LIST OF TABLES
Table 5.1 - Results of Ground Water Sampling 11
Table 6.1 - Ground Water Contaminants of Concern 13
Table 8.1 - Ground Water Cleanup Goals 18
LIST OF APPENDICES
Appendix A - Responsiveness Summary
Appendix B - State Concurrence Memorandum
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Summary of Remedial Alternative Selection
Stauffer Chemical/LeMovne Site
Ground Water Operable Unit
i.0 SITE LOCATION AND DESCRIPTION
The Stauffer Chemical LeMoyne and Cold Creek Sites (See Figure 1.1) are
located-approximately 20 miles north of Mobile, Alabama on U.S. Route 43.
The Stauffer complex is bounded by Hoerchst Celanese to the north, Courtaulds
North America (CNA), another chemical company, to the south, the Mobile River
to the east, and Route 43 to the west. M&T Chemicals is located immediately
to the west of Route 43. The area is predominantly industrial, with a few
small rural residential communities within a few miles of the site. The
LeMoyne facility manufactures multi-product organic and inorganic chemicals,
including carbon disulfide, carbon tetrachloride, sulfuric acid, chlorine,
and crystex (a sulfur compound).
Surface elevations range from 10 to 45 feet above MSL. An unnamed stream
flows north across the property and then through the Cold Creek Swamp, which
discharges into the Mobile River. Surface-water drainage is either toward
the swamp or the river and is governed by a drainage divide between the two.'
The Mobile River flows southward toward the Gulf of Mexico.
2.0 SITE HISTORY
2.1 LeMovne
The LeMoyne plant was previously owned by the Stauffer Chemical Company,
which began operations in 1953. In 1987, the facility was purchased by Akzo
Cheraie America, Inc., now called Akzo Chemicals, Inc. From 1965 to 1974,
while still operated by Stauffer, waste from the plant was placed in an
unlined landfill (Figure 2.1) located approximately one mile east of the main
plant. The waste included 11,000 to 12,000 tons of brine muds in addition to
plant refuse, used samples, and absorption oil. Under the direction of the
Alabama Water Improvement Commission (AWIC), the landfill was closed in 1975
with an impermeable membrane cap and side-wall liner.
Wastewaters from the LeMoyne plant processes were held in ponds, some of
which discharged to the Cold Creek Swamp. All of these ponds except for one
are clay-lined and have been closed under the direction of AWIC. Several
membrane-lined ponds, which are currently active, were installed during the
1970's to replace those mentioned above. One of these is regulated by a
Resource Conservation and Recovery Act (RCRA) permit. •
From 1965 to 1979, a small portion of land on the western end of the LeMoyne
site was leased by Stauffer to the Halby Chemical Company (HCC), which
manufactured dye chemicals including sodium hydrosulfide. Witco, Inc.
purchased the HCC facility in 1974, and continued to operate the plant until
1979. Although little is known of this operation, waste products and
effluents were reportedly discharged to the Cold Creek Swamp and held in an
on-site pond, which has since been closed and filled.
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-2-
COLD CREEK & I EMOYNE SITE
MOBILE COUNTY. ALABAMA 1«- 2000
rCOLD CREEK
PLANT '
7 .*" D -"
s
URTAULDS Of
AMERICA'
CAMP DRESSER & McKEE INC.
SITE LOCATION MAP
STAUFFER CHEMICAL COMPANY
MOBILE COUNTY, ALABAMA
FIGURE NO.
1. 1
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Cold Ciaak Swamp /
-if Cold Crock N. Landfill
N. Flrawalar Pond —•
Cold Crank "LaCraak" WWf Pond
Cold Ciaak Old Nautralliatlnn Pond
S. Firewater Pond
Cold Croud S. Landfill
Old CMotlna Plant WWT Pond
Old Brlna Mud Pond
300
rvn—j
0 ()(M) I I
Approximate Scale
Cold Creek Pianl
k ••••••• MBiV ••••••
L«Moyn« Plant
Qiound-Walnr
— I— Tieatrnenl I'ond
Formar llalby
Traaimani Pond
KBilna
And Pond
LaMovne Landfill
Naw CTC Plant WWT Pond
LaMoyne "L« Creak" WWT Pond
Old CTC Plant WWT Pond
- UMoyna Acid
Plant WWT Pond
Fliawatar
Pond
Explanation:
N = North
S •= South
WWf = Watiawalar Tmalmanl
CTC = Carbon lalrachlurlda
(JS2 = Caibon Ulaulliila
Old CS2/CTC
WWT Pond
Nota: Locations art approximate; taa Flgura 4-1 lor a mora proclna location of lha pioparly boundaries
(Moilillnil Allnr CUM UIM'ij
Ficjure 2.1 Cold Creuk/I.cMpync S it«- Cotif ACJUJ aLi
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-4-
2.2 Cold Creek
The Cold Creek plant began operating in 1966 under the ownership of the
Stauffer Chemical Company and is currently owned by ICI Americas, Inc. Until
1974, an unknown amount of sludges and solid wastes containing a variety of
herbicides and pesticides were placed in two waste disposal sites, referred
to as the Cold Creek North and South Landfills. Both were closed in 1974
with geomembrane caps and side-wall liners. One clay-lined lagoon was used
for neutralization of wastewater until 1975. It was closed in 1978. A new
membrane-lined pond was constructed to replace it and is currently in use.
2.3 Enforcement History
The aforementioned disposal practices led to ground water contamination.
This was recognized by Stauffer and the Alabama Department of Environmental
Management (ADEM) in the early 1970's when contaminants were detected in both
on-site and off-site wells. Several improvements and waste-handling
modifications were made including the construction of lined wastewater ponds
and the closure of some of the old unlined ponds. In 1973, Stauffer
installed twenty-one ground water monitoring wells. By 1977, the water
quality had deteriorated substantially and seven observation wells were
placed at the southern property line of the LeMoyne facility. Using the
results from a hydrogeological investigation performed by the owner/operator,
three interceptor wells accompanied by an air stripper were installed on the
LeMoyne property in late 1980. The system was approved by the Alabama Water
Improvement Commission (AWIC) which is now the Alabama Department of
Environmental Management (ADEM).
An assessment of the site was conducted in 1982 by the Alabama Department of
Public Health (ADPH) in response to submissions made by Stauffer to the House
Committee on Interstate Commerce (the Eckhardt Survey). At the advice of
ADPH, additional monitoring wells were installed around the LeMoyne
Landfill. Data from these wells formed the basis for the Environmental
Protection Agency (EPA) placing the si,te on the National Priorities List
(NPL), which ranks hazardous disposal sites under provisions of the
Comprehensive Environmental Response, Compensation and Liability Act of 1980
(CERCLA), commonly known as "Superfund". The Stauffer Sites were placed on
the NPL in September, 1983. LeMoyne- is ranked number 467 and Cold Creek is
number 221.
In November 1984/ EPA Region IV sent a general notice letter to Stauffer
Chemical Company notifying them of potential liability for contamination at
the Stauffer Chemical Site. Camp, Dresser and McKee, Inc. (COM), under
contract with the EPA, performed preliminary sampling in May 1985 to assist
in preparing a work plan for the Remedial Investigation/Feasibility Study
(RI/FS). The Stauffer Chemical Company agreed to conduct the RI/FS under a
consent agreement with EPA, and the present owners, Akzo and ICI, completed
the RI in May, 1988. A draft FS report was submitted by the present
owner/operator in July, 1988. EPA required modifications to the FS report in
comment letters sent in November, 1988 and January, 1989. A revised report
was submitted in June, 1989. This report was reviewed by EPA and was
partially disapproved.
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-5-
The Stauffer Chemical Company/LeMoyne Plant was issued a RCRA permit on
October 9, 1986, which became effective November 9, 1986. The permit was for
the operation of two hazardous waste surface impoundments and a hazardous
waste storage tank.
Unit Hazardous Waste Code
Brine Mud Slurry Tank K071
Chlorine Plant Surge Pond 0009, K071
New Brine Mud Pond K071
Old Brine Mud Pond K071
The Chlorine Plant Surge Pond was certified clean-closed in September, 1988
according to the approved closure plan. The Old Brine Mud Pond has been
delisted.
An additional provision was included in this permit as a result of the 1984
Hazardous and Solid Waste Amendments to RCRA. This is the requirement of 40
CFR, Section 264.101, which addresses prior or continuing releases at solid
waste management units. The requirement has been satisfied by adoption of
the Remedial Investigation/Feasibility Study work plan, developed under
CERCLA, into the permit. The permit will be modified once the Record of
Decision has been issued.
3.0 COMMUNITY RELATIONS HISTORY
Community interest for the Stauffer Chemical site has been limited. Several
news articles concerning the site have been printed in the Mobile Press
Register and the Montgomery Advertiser. A Community Relations Plan was
completed, in September, 1985. In May 1986, the EPA printed and distributed a
fact sheet describing the site history and findings of investigations
conducted at the site. A fact sheet announcing EPA's Proposed Plan was issued
on July 11, 1989.
A related issue of concern to the people of Mobile County, Alabama is transport
and disposal of wastes within their county. This concern arose as a result of
a proposal to begin hazardous waste incineration in the Gulf of Mexico via the
Mobile port.
On July 13, 1989, the administrative record which contains documents related to
remedy selection at the site, including the Remedial Investigation/Feasibility
Study, and Proposed Plan, was made available to the public at the Region IV EPA
offices in Atlanta, Georgia and the Toulminville Branch Library in Mobile,
Alabama. This began a 30-day public comment period to solicit public opinion
on the proposed remedial action at Stauffer Chemical. 'A public meeting was
conducted on July 27, 1989, at which EPA presented the RI/FS report and
Proposed Plan and answered citizens' questions. The Mobile County
Commissioners and County Administrator were briefed prior to the meeting.
Public comments on the selected remedy and EPA's responses are included in the
Responsiveness Summary section of this document. This decision document
presents the selected remedial action for the Stauffer Chemical LeMoyne and
Cold Creek sites in Mobile County, Alabama,, chosen in accordance with CERCLA,
as amended by SARA, and to the extent practicable, the NCP. The decision for
these sites is based on the administrative record file.
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-6-
4^.0 SCOPE OP REMEDIAL ACTION
OO 1; Ground Water and Conta™* nant Sources
This addresses the first Record of Decision (ROD) of several planned activities
at the site. It deals with the existing ground water problem and treatability
studies on the sources of contamination.
The response actions presented in this ROD are being implemented to protect
public health and the environment by controlling the migration of contaminated
ground water in the surficial aquifer, which is a principal source of water for
industrial and domestic users located in the Mobile River Valley. The US EPA
has determined that off-site migration of the contaminated ground water is one
of the principal threats at these sites.
The response actions are consistent with the NCP (40 CFR 300.68). These
actions are also consistent with plans for future remedial work to be conducted
at the LeMoyne and Cold Creek sites.
Further investigation and treatability studies are necessary before the EPA can
make decisions concerning treatment of source materials.
OU 2; Source Units
OU 3; Cold Creek Swamp
The remedial action for the source units and the Cold Creek Swamp will be
addressed in a subsequent RODs.
5.0 SITE CHARACTERISTICS
«
The Stauffer sites are located in the southern Pine Hills Section of the East
Gulf Coastal Plain physiographic province. The site is underlain by
Pleistocene to Holocene alluvial deposits consisting of interbedded clays,
sands, and gravels. These deposits range in thickness from 130 feet to 60 feet
at the edge of the Mobile River and form the surficial Miocene aquifer which is
the principal source of water in the Mobile River Valley. The upper 80 feet
has low to moderate permeability with the lowermost sands containing the most
highly permeable material. Wells in this aquifer typically yield 470 to 816
gallons per minute (gpm) with specific capacities of 6 to 73 gpm per foot of
draw down. A dense blue-grey estuarine clay forms the.base of the aquifer.
Surface drainage for the Cold Creek site and the western portion of the LeMoyne
property is toward an unnamed stream which flows northward toward the Cold
Creek Swamp. The eastern portion of LeMoyne is adjacent to and drains toward
the Mobile River. Flooding potential at the site is considered to be minimal.
One-hundred-year to five-hundred-year flood zones are shown in Figure 5.1.
Prior to industrialization, the direction of ground water flow was eastward
toward the Mobile River and its depth ranged from 0 to 20 feet below ground
surface. Installation of wells on the adjacent Courtaulds property has
resulted in a lowering of the water table to between 25 and 75 feet below
ground surface. Furthermore, direction of ground water flow has been changed
to southwest on the western portion of the site and to the southeast on the
eastern portion. Most of the industries and local communities in the area
-------
'-7-
Men: Flood mformnion from flood Iraunnea KM*
Map, Community Paiwl No. OIBOOt 0121P ft
0160F.ltoviMd1.J4I.
Topographic Information Taten Prom USGS Topo
SCAl£
Figure 5.1 - Flood Plain Map
-------
-8-
-*t
obtain water supplied from the surficial aquifer.
As shown in Figure 1, the LeMoyne facility has two drinking water wells (LM-7
and LM-10) which provide water for 230 employees, and the Cold Creek plant has
one drinking water well (CC-12) with one backup (CC-11), serving 250
employees. The CNA plant to the south has one primary drinking water well
(CNA-16) and a backup well (CNA-4), serving 750 employees. M&T Chemicals, on
the west side of Route 43, uses well water for their 200 employees. All of
these wells draw water from the surficial aquifer.
The Remedial Investigation, conducted by the owner/operator under a consent
agreement with the EPA, was divided into two major subtasks - source and area
characterization. Source characterization was performed by soil sampling
around the landfills and ponds, and sampling of pond liquids. Ground water
sampling of two newly installed and thirteen existing monitoring wells was also
conducted. All of these wells were analyzed for location-specific compounds,
and three of them were also analyzed for priority pollutants. Area
characterization involved sampling 36 site area wells for location-specific
compounds. Seven of the 36 wells were also analyzed for priority pollutants.
In addition, two surface water samples and two soil samples were collected
off-site to determine background concentration of the contaminants of concern.
Well locations are shown in Figures 5.2 and 5.3, and results of the sampling
and analysis are summarized in Table 5.1.
As a result of the above analysis, ten areas were identified as possibly
needing remediation. These included five inactive ponds, three landfills, the
Cold Creek Swamp, and the ground water. The ponds and landfills are classified
as Solid Waste Management Units (SWMUs) under RCRA regulations. EPA has
grouped jphese units into nine Solid Waste Management Unit Areas. They are as
follows:
SWMU Area fl - Cold Creek LeCreek Wastewater Treatment Pond
Cold Creek Old Neutralization Pond
Cold Creek South Landfill
SWMU Area 12 - Old Carbon Disulfide Wastewater Treatment Pond
Old Carbon Tetrachloride Plant Wastewater Treatment Pond
SWMU Area 13 - Cold Creek North.Landfill
SWMU Area 14 - Old Brine Mud Pond
SWMU Area 15 - New Carbon Tetrachloride Plant Wastewater Treatment Pond
SWMU Area 16 - LeMoyne LeCreek Wastewater Treatment Pond
SWMU Area 17 - Old Chlorine Plant Wastewater Treatment Pond
SWMU Area #8 - LeMoyne Landfill
SWMU Area 19 - Halby Pond
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(Modified Altar COM. 1986)
0 600 Fl.
Approximate Scat*
Cold Crack Plant
.aMoyna Plant
Explanation:
• Wall Location (approximate)
I
VO
Figure 5.2 Source Well Sample Locations
-------
(Modified Alter COM. 19B5)
Cold Creek Swamp
J9f
0-14
300
IM
0 600 Ft.
Approximate Scale
LeMoyne Plaint Q Q flQ
LeMoyna Swamp
Eiplanallon:
• Wall Location (approximate)
Figure r>. J Aron
Sample Local, ions
-------
Table 5.1 - Results of Ground Water Sampling
CniMINRNIS KIECIED IN GROUMO URIEI fll DC COLD CRFiM/LIMlUC SI IF, Mild ME (IIIMY
Will I
Cirbon Cirbon
litrKMorldl lliilMdi
Cyinldi Hircury
~B>TC
"Rolif.iti "Cycloiii Ihloryinito Pliiiol fbitnlc Ccprir Mrnl /IT CHondt ftmuhot Uiloralori
•SCC-CCI2
SCC-OIT-IM
HI -03-111 '
BC4SO
BC-014
nc-oio
Stt-fll*
0*21
0-11
ft-12
o-n
0-41
0-43
0-41
0-30
0-*4
IKS
0-71
COM
CW-7-1
m'\
n-«i-iu
GCC"&"ltt
OCC-2MH
Ht-24-H
OCMS-IH
OOC-SI-IU
S-32
-70
KC-0/1
BC-OeO
ttOH-3
ICOIrt
•trxu-7
iKOJHO
otc-a-i2
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10/11
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0.0270
20/31
id
rd
rd
rd
rd
0.0011
0.0022
0.0023
0.0010
0.0021
0.0022
0.0100
rd
id
0.0012
nd
0.0014
0.0027
0.0113
rd
rd
rd
rd
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Id
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id
id
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0.0014
id
id
id
rd
rd
rd
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id
rd
rd
id
rd
rd
rd
0.00*1
rd
id
0.0021
0.0113
0.0010
14/31
nd
rd
rd
rd
id
nd
0.00(3
0.0026
0.002*
0.0012
0.0021
0.0067
0.0010
rd
0.0021
rd
0.0016
0.004*
0.0011
id
id
id
id
rd
rd
Id
rd
id
id
rd
id
id
0.0021
id
rd
id
rd
rd
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rd
id
id
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rd
id
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0.0073
rd
id
0.0020
0.0017
0.0010
14/31
nd
Id
nd
*hd
rd
n4
0.0019
MO
NO
rd
rd
0.0010
rd
id
rd
id
id
rd
id
rd
rd
rd
id
id
id
id
id
rd
id
id
id
rd
rd
rd
rd
rd
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id
rd
rd
id
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nd
id
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id
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id
0.0011
0.0001
2/31
i nd
" id
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nd
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nd
H
id
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r4
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lll
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thl l»»ri|t of In* l»o uiflii MI tiki* ftr dgpllcill tuplii.
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-12-
6^0 SUMMARY OF SITE RISKS
The following discussion provides an overview of the baseline public health and
environmental risk evaluation for the Stauffer LeMoyne and Cold Creek Sites.
It is based on the report "Endangerment Assessment Report Cold Creek/LeMoyne
Site, Mobile County, Alabama", prepared by the owner/operator. The baseline
evaluation helps determine if a remedial action is necessary at the sites. It
represents an evaluation of the "no-action alternative", in that it identifies
the risk present if no remedial action is taken. The baseline assessment also
provides the framework for developing the preliminary remediation goals for the
Stauffer sites. Field observations and analytical data as presented in the
Remedial Investigation report provided the basis for the risk evaluation.
There are four media of concern at the Stauffer Site. The Remedial
Investigation revealed contamination of the soils, pond sludges, swamp
sediments, and ground water.
Based on the frequency of detection, the concentrations detected, and the
toxicological properties of the contaminants which were detected, the following
compounds were selected as indicator compounds for this site: mercury, carbon
tetrachloride, carbon disulfide, cyanide, thiocyanate, and six thiocarbaraatea,
EPTC, butylate, vernolate, pebulate, molinate, and cycloate. Of these
compounds, all but mercury and cyanide were detected in the ground water. A
table showing the concentrations of these substances in ground water and the
associated risk can be found at Table 6.1.
The ground water data used to calculate the baseline risk assessment were
collected from wells downgradient of the intercept well system. The baseline
risk assessment should reflect the conditions for the no action alternative,
which would exist if the intercept and treatment system were shut down. Since
the risk levels in the RI do not represent these baseline risk conditions at
the sites, risk levels have been calculated for the ROD which represent the
worst case and average case scenarios.
6.1 Exposure Assessment Summary
The exposure pathway for the ground water operable unit is ingestion of
contaminated water from wells drilled into the surficial aquifer. Average and
worst-case risk estimates were developed for a 70 kg adult worker. The
exposure point concentration for the worst case scenario is based on the
consumption of ground water containing the maximum contaminant concentration.
The average exposure point concentration is based on the consumption of ground
water containing the average concentration of contaminants in the ground water
plume (i.e. wells O-29, O-31, O-39, O-41, O-45). Both estimates assumed the
worker would drink two liters of water a day for 30 years and used an
absorption factor of one (1.0) for organics and inorganics.
The number of workers served by industrial drinking water supply wells within a
two-mile radius of the sites is 1585. There are 21 residential wells within
that radius.
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-13-
TABLE 6.1 - GROUND WATER CONTAMINANTS OF CONCERN
Maximum Mean Risk
CPF Concentration Concentration Level
Carcinogens (mg/kg-dav—) (mg/1) lmg/1) Max./Mean
Carbon
Tetrachlbride l.SxlO'1
298
68.8
l.OTxlO
'1
Risk Level is for a 30 year exposure period
Maximum
RfD Concentration
Nonearcinogens (mg/kg-day—) (ma/I)
Carbon Disulfide
Carbon
Tetrachloride
Thiocyanates
Butyl ate %
Cycloate
EPTC
Molinate
Pebulate
Vernolate
1X10'1
7xlO-4
NE
5xlO~2
NE
3xlO-2
2xlO"3
NE
IxlO"3
55.6
298.0
6.0
0.014
0.007
1.2
0.231
0.002
0.009 '
15.6
ND
0.004
0.003
0.006
0.010
0.001
0.008
Mean Hazard
Concentration Quotient
Max./Mean
155/4.4
11920/2752
7.84xlO"3/
2.2 xlO"3
l.l/
5.6x10
3.2/
1.4x10
-3
-1
2.5X10'1/
2.2X10"1
NE - None established
ND - Not detected in the wells used for determining the average
exposure point concentration.
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-14-
6.2 Toxicitv Assessment
Chemicals exhibiting non-carcinogenic effects are assessed using risk reference
doses (RfDs) developed by the EPA. The RfD, expressed in units of mg/kg/day,
is an estimate of the average daily exposure of individuals (including
sensitive individuals) which will result in no adverse health effects during
their lifetime. Exposure levels to contaminants in environmental media such as
drinking water are compared to the RfO, which provides a benchmark below which
adverse health effects are not expected to occur.
Agency verified RfDs are available for six (6) of the substances identified in
the ground water at the sites: carbon disulfide, carbon tetrachloride, and four
(4) thiocarbamate pesticides (butylate, EPTC, molinate, and vernolate) These
values are contained in Table 6.1. At present there are no Agency verified
RfDs for the individual thiocyanate compounds.
The EPA's Carcinogen Assessment Group has developed cancer potency factors for
estimating excess lifetime cancer risks associated with exposure to potential
carcinogens. The cancer potency factor, measured in (mg/kg/day)~ , is
multiplied by the average intake of a potential carcinogen (in mg/kg/day) to
provide an estimate of the upper bound lifetime excess cancer risk associated
with exposure at that intake level. The term "upper bound" reflects the
conservative nature of the risks calculated using the cancer potency factor,
and they are therefore unlikely to be less than the actual cancer risks.
One of the substances at the site, carbon tetrachloride, has been classified by
EPA as a class B2 carcinogen. The cancer potency factor for carbon
tetrachloride is 1.3 X 10'1 (mg/kg/day)"1.
«
6.3 Risk Characterization
This section quantifies the potential for adverse health effects due to site
related chemical exposure. Because noncarcinogenic effects are assumed to have
a threshold dose below which an adverse effect will not occur, and carcinogenic
effects are assumed not to have a threshold dose, risk estimates for
noncarcinogenic effects are determined separately from carcinogenic risks. The
potential for noncarcinogenic health effects is assessed by dividing each
indicator chemical's exposure-route and duration-specific intake by the
reference dose (RfD). This ratio is called the Hazard Quotient (HQ). .If the
estimated intake..is greater than the RfD, the HQ will exceed one (1). By
adding the HQ* for all contaminants within a medium or across all media to
which a given population may reasonably be exposed, the Hazard Index (HI) can
be generated. The HI provides a useful reference point: for gauging the
potential significance of multiple contaminant exposures within a single medium
or across media.
The HQ for many of the individual contaminants exceeds unity for the maximum
exposure scenario, and the HQ for both carbon tetrachloride and carbon
disulfide exceeds unity for the average exposure scenario.
Excess lifetime cancer risks are determined by multiplying the intake level and
the cancer potency factor. These risks are probabilities that are expressed in
-------
-15-
scientific notation. An excess lifetime cancer risk of lxlO~ indicates
that, as a plausable upper bound, an individual has a one in one million chance
of developing cancer as a result of site-related exposure to a carcinogen over
a 70-year lifetime under the specific exposure conditions at a site. The
Agency considers individual cancer risks in the range of 10 to 10 as
protective. The 10 risk level is used as the point of departure for
setting cleanup levels at Superfund sites. The risk level associated with the
maximum and average exposure to carbon tetrachloride is in the unacceptable
range (i.e. 10~ ).
At the present time, individual exposure via the ingestion of contaminated
ground water is not occurring. However, unacceptable risk levels for the
baseline assessment indicate that ground water treatment is necessary to
prevent the potential human exposure to unacceptable levels of contaminants in
the future.
6.4 Environmental Risk
Environmental risk at the Stauffer LeMoyne and Cold Creek sites is present due
to the threat of migration of ground water to the Mobile River. The area is a
natural habitat for a variety of invertebrates, amphibians, reptiles, fish,
birds and mammals. Two species of concern are the American Alligator, which is
on the-list of threatened species, and the Alabama Red-Bellied Turtle, which is
proposed for the list. The adjacent Cold Creek site includes the Cold Creek
Swamp for which the environmental risk will be addressed in the Record of
Decision for the Swamp operable unit.
7.0 DOCUMENTATION OF SIGNIFICANT CHANGES S117(b)
m
The preferred alternatives for the ground water and source operable units as
specified in the Proposed Plan is modification of an existing intercept and
treatment system, monitoring of Detection Monitoring wells to determine the
necessity for corrective action, and pilot testing of in-situ treatment
technologies for the Old Carbon Tetrachloride Wastewater Treatment Pond and
other SWMUs. The specific technologies and SWMUs needing treatment will be
determined during remedial design. No significant changes have occurred in the
remedy described in the Proposed Plan.
8.0 DESCRIPTION OF ALTERNATIVES ' -
Four alternatives were considered for remediation of ground water, which
contains unacceptable concentrations of Carbon' tetrachloride, carbon disulfide,
thiocyanates, and thiocarbamates. The maximum and mean concentrations detected
at different locations on the Stauffer LeMoyne site is listed in Table 6.1.
The extent of the contaminant plume will be defined during the Remedial Design
stage. The following remedial alternatives were considered:
8.1 Alternative 1 - No Action
* Shut down existing intercept and treatment system
Shut down CNA Wells
* No treatment of sources
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-16-
The first alternative is no-action, as required by Section 117(B) of the
National Contingency Plan (NCP). This would entail shutting down the existing
intercept and treatment system, as well as the wells at the Courtaulds North
America property to the south, resulting in reverting the ground water flow
direction toward the Mobile River. This would allow for potential migration of
the contaminants in the aquifer toward water supply wells and the Mobile River,
increasing the likelihood of exposure to workers on site via ingestion of
ground water and enhancing the risk to aquatic life. The levels of
contamination would gradually be reduced via natural processes, but at a very
slow rate.
8.2 Alternative 2 - Existing Ground Water Intercept
and Treatment System with Surface Water Discharge
* Continued use of existing intercept and treatment system
* Surface water discharge to Mobile River
* Monitoring of effluent, ground water concentrations and
pumping rates
Alternative 2 involves the ground water intercept and treatment system which is
currently in operation at the Stauffer LeMoyne site. Ground water is pumped
from three extraction wells (Figure 8.1), located south of the Old Carbon
Tetrachloride Plant Wastewater Treatment Pond, and into the treatment system.
Treatment consists of aeration via spray-nozzles which discharge the ground
water to the treatment pond and then to the Mobile River. The surface water
discharge is regulated by the National Pollutants Discharge Elimination System
(NPDES) permit as required under the Clean Hater Act, for which standards are
currently being met. However, it is unclear whether the extraction system is
reducing^contaminant concentrations in the ground water to the cleanup
standards listed in Table 8.1. Applicable or relevant and appropriate
requirements (ARARs) and "to-be-considered" health-based levels (TBCs) from
which these cleanup levels were developed are also listed in this table.
Periodic ground water monitoring would be included in this remedial action to
determine if the ground water quality was improving at an acceptable rate.
A major assumption underlying this alternative includes the continued pumping
of the CNA wells to the south. In the event these would be shut down, the
remedy would be jeopardized due to changes in ground water flow direction which
would reduce the ability of the existing extraction wells to capture the
plume. Additional interceptor wells would be required to maintain gradient
control and minimize off-site migration of contaminants.
8.3 Alternative 3 - Modified Ground Water Intercept and
Treatment System with Surface Water Discharge
Continued use of existing intercept and treatment system
Installation of additional extraction wells
Modifications to treatment system to be determined
Monitoring of effluent, ground water concentrations and
pumping rates
-------
Cold Cittuk Swamp I
•
\.
loldCraakPlanl
.aMoyno Plan)
Explanallon:
• Well Location
Utmking-Waiar Well Locution
(Modified Alter COM. 1986 And Smuller. 1978)
L-e 8.1 Site Area Well Locations
-------
-18-
TABLE 8.1 - GROUND WATER CLEANUP GOALS
Chemical
Carbon Bisulfide
Carbon Tetrachloride
Cyanide
Mercury
Thiocyanates
Thiocarbamates**
Butyl ate
Cycloate
EPTC
Molinate
Pebulate
Vernolate
Goal fucr/1}
700
5
200
2
200*
350
if if if
210
14
7 ***
7 **
Basis
LHA
MCL
LHA
MCL
LHA
LHA
LHA
LHA
LHA
LHA
LHA
MCL - Maximum Contaminant Level
LHA - Lifetime Health Advisory/ based on RfD, 70 kg human
2 liter/day water consumption, 20% relative source
contribution
* _
** _
*** _
No Agency health-based number exists for
thiocyanates. The LHA for the more toxic cyanide
is used.
These cleanup goals could be increased a maximum of
fourfold pending an EPA Office of Drinking Water
decision to revise the LHA values for these
carbamate herbicides that allows a drinking water
source contribution up to 80% of the RfD.
No Agency-verified RfDs for these chemicals; the
cleanup goal is based on the RfD for vemolate
(the most toxic thiocarbamate at the site)
-------
-19-
"i
Alternative 3 involves a modification of the existing intercept and treatment
system. Additional extraction wells would be installed, based on ground water
quality characteristics, water-table gradients, and pumping activities at the
site and adjacent properties. This alternative would allow for a more rapid
achievement of the cleanup goals mentioned for Alternative 2. Surface water
discharge must meet concentration limits specified in the NPDES permit. In
addition, as for the previous alternative, a contingency plan would be
necessary in case pumping of the CNA wells was terminated. Also, ground water
monitoring would be conducted to determine the progress of the remediation.
8.4 Alternative 4 - Existing Ground Water Intercept and
Treatment System with Surface Water Discharge and
In-Situ Vapor Extraction
' Continued operation of existing intercept and treatment system
' Removal of accumulated rainwater, soil, and sludge from the Old
Carbon Tetrachloride Plant Wastewater Treatment Pond
' In-Situ vapor extraction of soil beneath the Old CC14 Plant WWT
Pond
O&M of vapor extraction unit
* Monitoring of effluent and pumping rates
This alternative includes continued operation of the existing intercept and
treatment system coupled with in-situ treatment by vapor extraction of the
contaminated soil underlying the Old Carbon Tetrachloride Plant Wastewater
Treatment Pond area. Bench-scale tests would be performed and sludge and
accumulated rainwater would be removed from the pond prior to installation of
the treatment system. Vapor extraction involves injection of clean air into
soil containing volatile organic constituents. The constituents volatilize and
the contaminated air would then be withdrawn via a vacuum and vented through an
emission control system. Treatment of the pond area would expedite ground
water remediation activities and attainment of cleanup standards by reducing
leaching of contaminants into the ground water but would not effect ground
water of contaminants from other sources. NPDES permit discharge limits will
need to be met for all contaminants. As in Alternatives 2 and 3 a contingency
plan would be required for possible shutdown of the CNA wells, and ground water
monitoring would be conducted to evaluate progress of the remedy.
9.0 SUMMARY O7 COMPARATIVE ANALYSIS OF ALTERNATIVES
The major objective of the Feasibility Study (FS) was to develop, screen, and
evaluate alternatives for remediating the Stauffer LeMoyne and Cold Creek
sites. This decision document deals with the 'ground water, for which several
remedial technologies were identified. These technologies were screened based
on their feasibility given the contaminants present and site characteristics.
Those which remained after the initial screening were evaluated in detail based
on the nine criteria required by SARA, which are listed below:
-------
-20-
-i
1) Overall protection of human health and the environment;
2) Compliance with applicable or relevant and appropriate requirements
(ARARs)
3) Long-term effectiveness
4) Reduction of toxicity, mobility or volume
5) Short-term effectiveness
6) Implementability
7) Cost
8) State acceptance
9) Community acceptance
Cost was used to compare alternatives only when they provided similar degrees
of protection and treatment. Four alternatives remained after the detailed
evaluation and were listed in the previous section. A summary of the relative
performance of the alternatives with respect to each of the nine criteria is
provided in this section.
9.1 Protectiveneas of Human Health and the Environment
The no-action alternative is not protective of human health and the environment
because it allows off-site migration of the contaminants, leading to possible
ingestion of water from wells drilled into the surficial aquifer. Alternatives
2 and 4 would not be protective because contaminants have been detected
off-site while the existing intercept and treatment system has been in
operation. Alternative 4 may eliminate the source of carbon tetrachloride but
will not deal with the thiocarbamates and other pollutants. Alternative 3 is
potentially more protective than the other three, since additional extraction
wells will be strategically placed to capture the contaminant plume.
9.2 Compliance with ARARs
Alternatives 1 and 2 do not comply with applicable or relevant and appropriate
requirements (ARARs). Concentrations of hazardous substances in the ground
water currently exceed EPA approved standards. Alternative 4 may help to meet
the cleanup standards for carbon tetrachloride but not for the other
contaminants. Addition of extraction wells in a modified ground water
intercept system and source treatment, as described in Alternative 3, would
comply with ARARs if properly designed.
The primary ARARs for the ground water are maximum concentration limits (MCLs)
under the Safe Drinking Water Act'(SDWA). These are applicable where water
will be provided directly to 25 or more people or will be supplied to 15 or
more service connections. MCLs are relevant and appropriate where the surface
water or ground water is being used or may potentially be used for drinking
water. The LeMoyne facility has two drinking water wells which provide water
for 230 employees. Cold Creek has one drinking water well, and a backup well
serving 250 employees. Neighboring businesses also utilize well water for
drinking purposes and there are approximately 21 residential water wells within
a two-mile radius. Other ARARs that must be complied with are surface water
discharge requirements of the National Pollutant Discharge Elimination System
covered under the Clean Water Act (CWA). Air emissions specifications
established by the Clean Air Act must also be met. EPA has determined that
RCRA technical standards regarding corrective action and closure are relevant
an appropriate for the SWMUs (ponds and landfills) at this site. RCRA Land
Disposal Restrictions will be in effect once the contaminants have been
-------
-21-
extracted from the ground water. These restrictions require treatment prior to
redisposing the wastes.
V,
The no-action alternative does not comply with the SDWA ARARs because it does
not reduce ground water contaminant concentrations to MCLs. The existing
ground water intercept system, Alternative 2, has not achieved these limits.
Alternative 4 may meet these limits for carbon tetrachloride but not the other
contaminants. All alternatives would comply with the NPDES permits for surface
water discharge. Compliance with RCRA will be determined through monitoring of
the Detection Monitoring wells. Alternative 3, if properly designed, would
comply with all ARARs.
9.3 Reduction of Toxicitv. Mobility, or Volume
All alternatives except for no action would reduce the toxicity and volume of
the ground water contamination by decreasing the size of the plume and/or
eliminating part of the source. Alternatives 2 and 4 may actually increase
mobility of the contaminants by pulling them from the sources lying some
distance from the extraction wells.
9.4 Short-term Effectiveness
The alternatives will require varying amounts of time to achieve cleanup of the
site. None will be immediately effective upon completion of construction.
Alternative 3 would require the shortest remediation time because it would
remove the major sources of contamination and capture the ground water plumes
more quickly. Any short-term risk to workers involved in construction of the
remedy would be reduced through implementation of a health and safety plan.
9.5 Long-term Effectiveness
Long-term effectiveness and permanence would be provided only by Alternative 3,
assuming future treatment of source units. Alternatives 2 and 4 would not
provide long-term effectiveness because they would allow off-site migration to
continue. The no-action alternative is not effective in the short or long
term.
9.6 Implementabilitv
The implementability of each alternative is based on technical feasibility,
administrative feasibility and the availability of services and materials. All
alternatives are technically and administratively feasible. All involve
technologies which have been used in 'the past and have.a demonstrated
performance record. An intercept and treatment system is already in place and
is meeting NPDBS permit requirements. A modified system would simply require
installation of additional extraction wells and is therefore easily attainable.
9.7 Cost
There would be no cost associated with Alternative 1. since the ground water
intercept and treatment system is already in place, a relatively low cost of
$1,355,100 is estimated for Alternative 2. This cost includes repair of the
treatment pond and Operations and Maintenance (O&M) coats. For Alternative 3,
it was assumed that three additional extraction wells would be installed and
that the only ground water constituents being treated are carbon tetrachloride
and carbon disulfide. However, thiocyanates and thiocarbamates will also
-------
-22-
require treatment. Therefore, the estimated total capital cost for well
installation and O&M of the system of $3,119,200 may be low. Alternative 4
involves in-situ vapor extraction in addition to the existing treatment
system. This would raise the estimated capital cost from that of Alternative 2
to $2,006,100.
9.8 State and Community Acceptance
The State of Alabama as represented by the Alabama Department of Environmental
Management is in favor of a modified ground water intercept and treatment
system for remediating the ground water at the Stauffer sites. Based on
comments made by citizens at the public meeting held on July 27, 1989, and
those received during the public comment period, the community believes a
treatment system will effectively protect human health and the environment.
10.0 THE SELECTED REMEDY
Based on available data and analysis conducted to date, the US EPA selects
Alternative 3 as the most appropriate solution for meeting the goals of the
initial ground water operable unit at the Stauffer LeMoyne and Cold Creek
sites. This alternative involves continued operation of the existing intercept
and treatment system along with the installation of additional extraction
wells. Ground water concentrations exceeding the cleanup goals listed in Table
8.1 must be reduced through treatment in order to achieve and an acceptable
risk level. Operation and maintenance includes monitoring of contaminant
levels in the ground water and the treatment system effluent as well as
maintenance of the components of the system itself.
EPA has decided that bench and/or pilot scale testing of in-situ treatment
alternatives for some SWMUs, including the Old Carbon Tetrachloride Plant
Wastewater Treatment Pond, is appropriate as part of the Remedial Design. A
range of treatment technologies including thermal desorption and vapor
extraction is being considered, and a formal remedy for these response areas
will be incorporated in a future Record of Decision.
As part of the modified ground water intercept and treatment system, Detection
Monitoring wells will be designated and/or installed around the ponds and
landfills for contaminant detection purposes. Upon detection of contaminants
above cleanup standards, these wells will be redesignated as Point of
Compliance (POC) wells. Data from the wells will be utilized to determine
exact locations of the contaminant plumes and to design ground water extraction
modifications, which will ensure that off-site ground water activities will not
detrimentally effect remediation of the Stauffer sites. Ground water modeling
will be employed to design and verify any extraction modifications.
Information from the Detection Monitoring wells will also help determine which
source units are in need of CERCLA remedial or RCRA corrective action.
Already in existence are RCRA and NPDES permits which regulate ongoing
hazardous waate and surface water discharge activities, respectively. EPA and
ADEM are the designated agencies for enforcing these permits.
The rationale for choosing this alternative includes the following reasons.
The alternative:•
provides immediate protection to human health from the potential threats
associated with consumption of ground water;
-------
-23-
—i
* reverses the continued migration and expansion of the contaminant plume
and prevents off-site migration;
* provides for management of surface water quality through monitoring of
contaminant levels in the surficial aquifer and possible surface water
discharges;
0 is consistent with additional site actions and will be compatible with the
final site remedy;
* contributes to the implementation of a more permanent remedy at the site;
* allows for a more complete and expeditious remediation of the ground water
than the other alternatives.
The goal at the completion of the entire remedial action is to meet the ground
water cleanup standards listed in Table 8.1 at each of the designated Detection
Monitoring wells as well as at the extraction wells. These wells will be
monitored for 30 years. If a release is detected at a Detection Monitoring
well, it will be redesignated as a Point of Compliance well and CERCLA remedial
or RCRA corrective action will be instituted at the appropriate SWMU.
11.0 STATUTORY DETERMINATIONS
The US EPA and ADEM have determined that this remedy will satisfy the following
statutory requirements of section 121 of CERCLA: protection of human health and
the environment, attaining ARARs, cost-effectiveness, and utilization of
permanenf solutions and alternative treatment technologies to the maximum
extent practicable.
11.1 Protection of Human Health and the Environment
The selected remedy adequately protects human health by reducing the risk
of consumption of contaminated ground water. This will be accomplished
through the prevention of off-site migration and the capture of the ground
water contaminant plume. Environmental risk will be reduced by directing
the plume away from the Mobile River. No unacceptable short-term risks
will result from the implementation of this remedy.
11.2 Attainment of Applicable or Relevant and Appropriate Requirements
This remedy assures that drinking water supplied to current well users
will meet available MCLs under the Safe Drinking Water Act (SDWA). For
those chemicals which do not have assigned MCLs, to-be-considered
health-based values will be attained. Discharge from the ground water
treatment system will meet NPDES permit discharge limits under the Clean
Hater Act (CWA). Compliance with RCRA technical standards will be
achieved through corrective action on any SWMUe that are determined to be
releasing contaminants to the ground water. The CWA is an applicable
requirement, while the SDWA (MCLs) and RCRA are relevant and appropriate.
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-24-
-;
11.3 Cost-Effectiveness
The selected alternative, although more costly than the others, provides a
higher degree of protectiveness. The modified ground water intercept and
treatment system will protect well users from ingestion of contaminated
ground water by capturing the plume and reducing the contaminant
concentrations to health-based levels. It will also provide a more rapid
attainment of these levels and assist in the remedial action for the other
operable units. The total capital cost of this alternative is
$3,119,200. The US EPA has determined that the costs of the selected
remedy are proportionate to the overall effectiveness and is a reasonable
value for the money.
11.4 Utilization of Permanent Solutions and Alternative Treatment or
Resource Recovery Technologies to the Maximum Extent Practicable
The US EPA has determined that the selected remedy provides the best
balance among the nine evaluation criteria for the four alternatives
evaluated. The selected remedy was the only alternative to provide
definite protection of human health and the environment, to reduce the
mobility of the plume and to be effective in the long term. The remedy
contributes to and is consistent with future remedial actions at this
site. It represents the maximum extent to which permanent solutions and
treatment can be practicably utilized for this operable unit.
11.5 Preference for Treatment as a Principal Element
The statutory preference for treatment will be met because the principal
threat from the Stauffer sites is ingestion of contaminated ground
water. In additon, contaminated soils or sludges at the SWMUs are
sources of ground water contamination. The selected remedy will reduce
this risk through capture of the ground water plume and treatability
testing of the contaminant sources.
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RESPONSIVENESS SUMMARY
FOR THE
PROPOSED REMEDIAL ACTION PLAN
AT THE
STAQFFER CHEMICAL LEMOYNE
AND COLD CREEK SITES
MOBILE, ALABAMA
Public Comment:
July 13 through August 12, 1989
September 1989
Prepared for:
U.S. Environmental Protection Agency
Region IV
Prepared by:
Booz»Allen & Hamilton Inc.
under Subcontract Number TES VII-BAH-1, WA Number C0403:
with COM Federal Programs Corporation
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STAOFFER CHEMICAL LEMOYNE
AND COLD CREEK SITES
RESPONSIVENESS SUMMARY
FOR THE
PROPOSED REMEDIAL ACTION PLAN
TABLE OF CONTENTS
Section I.
Section II.
Section III
Section IV.
Overview
Background on Citizen
Involvement and Concerns
Summary of Major Comments Received
During the Public Comment Period and
the EPA Responses to the Comments
A. Implementation of Remedy
B. Health Concerns
C. Off-Site Contamination
D. Miscellaneous
Summary of Comments Received Following
the Closing of the Public Comment Period
and EPA Responses to the Comments
Page
1
Section V. Remaining Concerns
2
2
5
5
6
7
11
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Responsiveness Summary
Stauffer Chemical Lemoyne
and Cold Creek. Sites
This community relations responsiveness summary is divided
into the following sections:
Section I Overview. This section discusses EPA's.preferred
alternative for remedial action and public reaction to
this alternative.
Section II Background on Community TnvQlvgrn^pt* and Concerns.
This section provides a brief history of community
interest and concerns raised during remedial planning
at the Stauffer Chemical sites.
Section III
Section IV
Section V
Summary of Major Commgnts Received During fche Public
Comment Period and the EPA Responses to theComments.
Both written and oral comments are categorized by
relevant topics. EPA responses to these major
comments are also provided.
Summary of Major Comments Received Following the
Closing of the Public Comment Period andEPA Responses
to the Corf-nents . This section presents the late
comments received from Courtaulds Fibers, Inc. and
EPA's responses.
Remaining:. Concerns. This section describes remaining
community concerns that EPA and the State of Alabama
should be aware of in conducting the remedial.design
and remedial action at the Stauffer Chemical sites.
I.
OVERVIEW
At the time of the public comment period, EPA published its
preferred alternative for the Stauffer Chemical sites in Mobile
County, Alabama. EPA's recommended alternative addressed the
ground-water contamination at the site. The preferred alternative
involves a modified intercept and treatment system with surface
water discharge. This alternative involves continued operation of
the existing intercept and treatment system as well as the
installation of additional ground-water extraction wells.
II. BACKGROUND ON CITIZEN INVOLVEMENT AND CONCERNS
Community interest and concern regarding the site has been
extremely limited to date. It is believed that community
involvement at the Stauffer sites has been low because the sites
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are in a rural area with neighboring industrial plants and a few
residents constituting the entire local community.
To get public input on the proposed remedy, EPA held a public
comment period from July 13 to August 12, 1989. EPA's community
relations efforts included a fact sheet that was sent to the
information repository in July 1989, a public meeting notice that
appeared in The Mobile Press Register on July 13 and July 26,
1989, and a public meeting that was held July 27, 1989.
Approximately 14 persons attended the meeting. Site information
repositories contain the RI/FS Report and other relevant
documents. EPA also maintained contact with local officials ar.d
citizens, throughout the remedy selection process.
III. SUMMARY OF MAJOR COMMENTS RECEIVED DURING THE PUBLIC COMMENT..
PERIOD AND THE EPA RESPONSES TO THE COMMENTS
Concerns and questions on the proposed remedy for the
Stauffer Chemical sites received at the public meeting July 27,
1989 and during the public comment period can be grouped into four
categories:
A. Implementation of Remedy
B. Health Concerns
C. Off-site Contamination
D. Miscellaneous
A sammary of the comments and EPA's responses to them is
provided below.
A. Implementation of Remedy
A citizen asked if the toxins' removed from the site will be
sent to another site.
EPA Response. The plan fpr this site is-on-site cleanup.
The existing treatment system will be modified and addi-i — al
ground-water monitoring will take place to determine the-type
of cleanup that can take place on the site.
• An attendee asked about the evaporative treatment pond
method. If this method is used, the citizen assumes that
what is left would be a sludge. Would that have to gc ir.ir a
landfill?
EPA Response. EPA plans to perform on-site treatment at -r.is
facility which means that sludge would not be sent to a
landfill. At present, EPA Is considering alternatives
presented for ground-water cleanup only. As Point of
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Compliance wells, which detect the release of contaminants to
the ground water, are installed throughout the site,
additional information will be available to determine which
source units need to be treated. EPA will require
treatability studies for the particular waste on site to
determine the best treatment available for that type of
waste.
The extracted ground water will be treated by aeration, which
does not generate a sludge for the volatiles, and then
processed by the existing treatment facilities at the plant
before being discharged into the Mobile River.
A 'citizen wanted to know the likelihood that salt water
intrusion into the Mobile River, and subsequently, the
aquifer, might occur.
EPA Response. EPA feels that the transient movement of salt
water wedges up in the channel of the Mobile River will not
cause a permanent change in the salinity of that aquifer.
An attendee asked if the proposed alternative was preferred
because the other alternatives would not remove pollutants
and chemicals that are detected off-site or in other places.
SPA Response. Yes. The existing system is allowing the off-
sire migration of the contaminants. The proposed plan is to
put in more wells to capture the contaminants and keep them
from going off-site.
An attendee asked how many proposed extraction wells would be
put in the contaminated areas.
EPA Response. The number of wells will be determined during
the remedial design phase.
The Manager of Environmental- Affairs for Akzo stated that the
Old Brine Mud Pond, which was included in the proposed RD/RA
plan, is not an operable unit subject to this investigation
and should not be included in this investigation. The pond
is delisted under Resource 'Conservation and Recovery Act
(RCRA) regulations and is closed in accordance with a
deiisting petition approved by EPA and the Alabama Department
of Environmental Management (ADEM). This pond should have
been deleted from the list of RCRA facilities in the RI/FS.
I? A Response. The Old Brine Mud Pond has been delisted under
RCRA regulations; however, this does not preclude it from
being monitored as a Solid Waste Management Unit (SWMU). Any
decisions concerning this SWMU will be made in a future
Record of Decision.
-------
Akzo's representative stated that in the Proposed Plan, EPA
refers to monitoring_,wells to be designated and/or installed
around the ponds and landfills for detection purposes as
Point of Compliance (POO wells. EPA's reference to
monitoring wells as POC wells is incorrect. There has been
no determination that corrective action under RCRA is
necessary at the sites. Use of RCRA terminology is,
therefore, inappropriate.
EPA Response. EPA has determined that RCRA regulations are
relevant and appropriate at the Stauffer Chemical sites, and
therefore "Detection Monitoring" wells must be designated or
installed around the Solid Waste Management Units (ponds and
landfills) in order to detect any releases of hazardous
substances to the ground water. Upon detection of
contaminants above cleanup standards, these wells will be
redesignated as "Point of Compliance" wells.
Akzo and ICI believe that it would be more effective to
conduct ground-water monitoring instead of ground-water
modeling, which EPA proposed. The result of such modeling
and monitoring should be the basis for evaluation and
selection of ground-water treatment alternatives and/or any
requirement for modification of the existing intercept
system.
EPA Response. EPA's proposal of a modified intercept and
treatment system is based upon existing data. Ground-water
monitoring and modeling will be used to specify design
criteria, i.e., the number and location of additional
extraction wells. Monitoring of POC wells will be used to
determine which source units will require treatment.
However, treatability testing in parallel with monitoring is
appropriate in areas where wastes are homogeneous and
concentrated. Furthermore, EPA guidance recommends
treatability in order to evaluate a range of alternatives.
EPA does not propose to test every treatment alternative at
the source units, but only those appropriate for the waste to
be treated.
The Manager of Environmental Affairs for Akzo noted that
while ground-water alternatives 1, 2, and 4 are technically
and administratively feasible, the technical and
administrative feasibility of alternative 3 must be
determined by modeling to ensure that ground-water
availability to Courtaulds will not be significantly reduced.
EPA Response. Ground-water modeling is not required to show
the administrative feasibility of Alternative 3. The
technical feasibility of a design plan is tested during the
remedial design and prior to implementation. EPA will take
into account Courtaulds'' ground-water needs at this time.
-------
The AXzo representative stated that EPA indicates that
alternative 3 would"require the shortest remediation time and
achieve long-term effectiveness and performance. Akzo
believes the ground-water modeling and point source
monitoring will aid in the determination of length of time
required for remediation of ground water under various
alternatives.
SPA Response. Ground-water modeling and monitoring will aid
in the determination of the length of time required for
remediation of ground water under the selected remedy that is
set forth in the ROD.
B. Health Concerns
An attendee asked about specific health risks involved with
the site and who might be affected.
EPA Response. At this point, EPA is discussing the ground-
water unit only. The highest levels of contamination are on
site. EPA and the Agency for Toxic Substances and Disease
Registry (ATSDR), an agency of the U.S. Public Health
Service, look at the potential for people to be exposed if
the contamination is left unattended. The contamination may
migrate over time and may put people at risk for drinking it,
swimming in it, and so en. There is no specific number zf
people that are known to be at risk at this time.
The Manager of Environmental Affairs for Akzo stated that the
applicable or relevant and appropriate requirements proposed
by ^)PA for thiocarbamates other than butylite (these are
EPTC, Molinate, vernolate) do not appear to be based on
published health advisories and are, therefore, inappropriate
as cleanup standards.
EPA Response. EPA's health-based cleanup standards for
thiocarbamates are calculated from reference doses listed in
EPA's Integrated Risk Information System (IRIS), which is
available for public review. Information concerning IRIS may
be obtained bv contacting the EPA Region' IV library at (404)
347-4216.
C. Off-Site Contamination
A citizen asr.ed how much contamination has occurred to the
Mobile P^iver delta or to the Mobile River itself.
EPA Resccr.s^. From EPA's collection of data, EPA feels that
more data is needed, particularly for the river. Since 1530,
the ground-water movement toward the river has been captured
by the existing intercept and treatment system.
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D. Miscellaneous _,
A citizen asked if there were any pending permit applications
for more holding ponds or if any permit applications had
recently been approved to make more holding ponds.
ZPA Response. The RCRA permit has not changed. There is
only one permitted pond on site.
An attendee asked if a copy of the Administrative Record
could be placed in a library closer to the site area.
EPA Response. There should be no problem getting a copy for
the library in Chickasaw.
A few citizens were concerned about the public comment
period. They felt it was only 12 days long instead of 30,
and thought that it should be extended.
EPA Response. There were two public notices placed in The
Mobile Press Register, one on July 13 and one on July 26,
1989. Also, a press release appeared on July 27, 1989. The
public comment period began when notice first appeared in the
paper on July 13 and will run for 30 days.
One attendee asked who pays for the cleanup.
EPA Response. The fees are negotiated between EPA and the
responsible parties. If the responsible parties want to
perform the remedy EPA selects, then they are responsible for
financing it. The Agency also gets reimbursed for its cost
for oversight and reviewing and approving plans.
An attendee asked if EPA ever sets a numeric ground-water
standard when a state does not.
EPA Response. EPA does set ground-water protection standards
that will be protective of human health should that ground
water ever be used as a drinking water source.
A citizen asked if EPA has an overall management plan when
there arc several Superfund sites in an area.
EPA Response. From a water management standpoint, typically
that is a state activity. The Agency is organized into
divisions that deal with all the hazardous waste problems in
this particular part of Alabama and this area of the ccuntry.
EPA does not typically manage resources. It only manages the
environment protection aspect, the contamination, and
cleanup. In many instances, where Superfund sites with
ground-water plumes are close to one another, the overall
remedy is managed as one.
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• The Akzo representative stated that the LeMoyne plant's
landfill is located near the eastern property line.
EPA Response. EPA stated -hat the LeMoyne landfill is at the
eastern end of the site. The above is simply a different way
of stating this.
• The Manager of Environmental Affairs for Akzo stated that EPA
has introduced, in the Proposed Plan, a requirement for
treatment of thiocarbamates in the ground water at the sites
that is not addressed in the RI/FS and that has not been
subjected to National Contingency Plan (NCP) requirements.
It-is likely that the present low levels of thiocarbamates
will be further reduced by source control proposed in the FS.
It would be a misuse of resources that are better directed
elsewhere to install or expand a thiocarbamate ground-water
extraction/treatment system in view of the fact that the
thiocarbamate levels are very low and will be further reduced
when the proposed source control is implemented.
EPA Response. The draft FS incorrectly infers that
thiocarbamates will not require treatment. The EPA Addendum
to the FS placed in the repository prior to the start of the
public comment period points out this deficiency explicitly.
Thiocarbamates are subject to CERCLA requirements. The EPA
requirement to treat thiocarbamates is not "newly imposed."
EPA has repeatedly stated in comment letters on the FS that
thiocarbamates are covered under CERCLA and have been found
in the ground water at the Stauffer sites in concentrations
aboye cleanup standards. These comment letters are part of
the public reccrd and have been placed in the site
repository. Possible location of an additional extraction
well or wells at the Cold Creek site was mentioned as an
example. As previously stated, ground-water modeling and
monitoring will help to determine the number and location of
additional extraction wells. Once again, levels of
thiocarbamates being discharged to the Mobile River under the
NPDES permit are a separate issue. The issue of concern here
is contaminant levels in the ground wate.r. In response to
the statement that thiocarcarr.ate levels are "very low," the
RI indicates thiocarbamate concentrations in certain wells
exceed health-based cleanup goals. Therefore, these
contaminants must be removed from the ground water at or near
their source in order to prevent spreading _of the contaminant
plume.
IV. SUMMARY OF COMMENTS RECEIVE! FOLLOWING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES
On August 6, 1989, EPA received a letter from the law office
representing Courtaulds Fibers Inc., requesting an extension of
the public comment period. The letter explained that the Proposed
-------
Plan was not received by Courtaulds until July 27, the same day as
the public meeting for th« site. Due to the late receipt of the
plan, Courtaulds was not able to comment on the plan at the
meeting. To ensure an opportunity for both Courtaulds and its
legal representative to review and comment on the plan, Courraulds
requested that the closing date of the public comment period be
extended from August 12 to August 28, 1989.
EPA did not agree to extend the public comment period beyond
30 days. EPA did agree, however, to accept and respond to
comments received from Courtaulds after the close of the formal
comment period, but on or before August 28, 1989.
The comments received and EPA responses to them follow a
summary 'of Courtaulds1 position.
Summary of Courtaulds ' Comments
Courtaulds believes that Alternative 3 is not supported by
the RI/FS, and that the Proposed Plan does not provide an
independent basis for EPA's selection. EPA's assertion that
Alternative 3 satisfies more of the selection criteria than does
Alternative 2 is unfounded. In view of Courtaulds1 disfavor with
Alternative 3, by definition only Alternative 2 satisfies the
selection criteria. Based on the reasons cited below, Courtaulds
urges EPA to reconsider its selection of Alternative 3.
Cff-Sits Contamination. EPA states that Alternative 2 would
not be protective of human health and the environment because
contaminants have been detected off site. While it is true
that contaminants have been detected off site, several facts
undermine the significance of this statement.
First, implicit in EPA's selection of Alternative 3 is the
assumption that the existing intercept system is inadequate
because off-site migration of- contamination has occurred
during the time the system has been in operation. It is not
clear whether the contamination migrated beyond the site
since the existing system, became operational, or whether such
contamination pre-existed the system's impl-ementation.
Second, if the migration occurred more recently, Alternative
2 could only be considered "less protective" of the
environment if the contamination that nu.gra.ted off-site
threatened to contaminate drinking water supplies. This is
not the case. Drinking water supplies are not and, according
to the RI/FS, likely will not be affected by off-site
contamination .
Third, the Feasibility Study states that the levels of
ground-water contamination have been substantially reduced
-------
since 1980, and that treated effluent concentrations from the
system have continuously met discharge limits set by the
Alabama Department cf Environmental Management. This
suggests that existing remediation activities at the site are
functioning successfully and as intended, and there is no
factual basis to support a decision to change.
Fourth, EPA has acknowledged that the existing system, in
conjunction with Courtauids' pumping activities, has produced
a capture zone that extends from the Southern Railway tracks,
located near the wester- Cold Creek/IeMoyne sice boundary,
east to the Mobile River. The breadth of this capture zone
makes it unlikely any contamination will migrate from it.
Based on the above, the RI/FS confirms that the only off-site
contamination is located en the Courraulds property, that
drinking water supplies are not affected by it, and that the
concentration of those contaminants has decreased
considerably and continue to decrease as a direct result of
the existing ground-water treatment system in combination
with Courtauids' pumping activities. Thus, Courtauids does
not believe the detection of off-site contamination supports
the selection of Alternative 3.
EPA Response. The existence of off-site migration is not
based solely upcr. the de~ec~ion of contaminants in
Courtauids' wells. It is also based on ground-water
modeling, which indicates that ground water in the
southeastern portion of the Stauffer sites is not being
captured by the existing extraction system. Although
existing data show no impact on drinking wells as yet, the
potential for contaminated drinking water exists. The fact
that carbon tetrachloride levels in the surface water-
discharge limits have been met does not mean that the ground
water beneath uhe entire site is being effectively
remediated. As previously mentioned, EPA has determined from
modeling data that the ground water at the Stauffer sites is
not entirely captured by the existing extraction wells.
Furthermore, the effectiveness of the PRPs' proposed remedy
relies on continued puir.pi~g.c-f the Courtauids wells. EPA is
proposing a remedy that will not depend on external entities
(i.e., the Courtauids wells) to make the remedy complete.
ARARs. According to EPA, A_cernative 2 would not attain
applicable or relevant ar.d appropriate requirements because
concentrations of hazardous substances in the ground water
currently exceed drinking water criteria and other standards
based on protection cf human health. The RI/FS states,
however, that the area irinkir.g water supply has not been
affected. Based on that statement, maximum contaminant
levels (MCLs) may not be applicable. Furthermore, the RI/F3
states that although =>.-. impact en' ground water is evident, ir.
the vicinity cf the career, bisulfide pond, the crnd is no
-------
longer affecting the ground water due to the construction of
an impermeable cap that now covers the pond.
If the configuration of the aquifer were such that drinking
water supplies were affected, the inability to achieve an
ARAR will not necessarily prevent selection of a remedy. As
EPA is aware, if a remedy is protective, cost-effective, and
otherwise adequately satisfies the statutory criteria, EPA is
authorized to select it. CERCLA expressly provides for
waivers for certain remedies that do not attain ARARs .
Although it is not necessary to seek such a waiver in these
circumstances, the fact that these statutory and policy
mechanisms are available suggest that the failure to attain
an ARAR alone is not sufficient basis for rejecting a remedy.
~?A Response. The use of MCLs as ARARs is relevant and
appropriate where the surface water or ground water is being
used or potentially may be used for drinking water. There
are drinking water wells already located on both the LeMoyne
and Cold Creek sites. The statement in the RI/FS that future
exposure to contaminated ground water is highly unlikely is
speculative. The inability to achieve ARARs is sufficient
grounds for rejecting a remedy when one that does attain them
is available.
The "Interim Guidance on Superfund Selection of Remedy"
(December 1986) states that "remedial action for a site
should be selected among those alternatives about which the
following (holds true) : ... the remedy meets or exceeds ARARs
or kealth-based levels established through a risk assessment
when ARARs do not exist." The fact that the opportunity
exists to seek an ARAR waiver does not suggest that
attainment of ARARs is not an essential criteria in remedy
selection .
Tast.-Sf fectiveness . The construction and maintenance of the
ground-water treatment system described in Alternative 3
would cost, at a minimum, over $3.1 million. This is
significantly more than the cost of the existing system, with
no demonstrated benefit. EPA's unsupported" claim that
Alternative 3 is cost-effective is thus incorrect.
Response; Alternative 3 provides a higher degree of
protectiveness than Alternative 2. A modified intercept and
treatment system will prevent off-site migration and stop the
spreading of contaminants from sources which are distant to
the existing wells. Additional extraction wells could
significantly reduce the time required for remediation and as
a result, the total cost of Alternative 3 relative to
Alternative 2.
Off-Site Uses of Ground Water. The water used in Ccurtaulds '
cooling and manufacturing processes is ground water. Surface
-------
water- cannot be used. Alternative 3 could have a profound
impact on Courtaulds1 ability to extract sufficient
quantities of ground water for use in its manufacturing
operations. Although the Proposed Plan does not state the
number and/or location of extraction and monitoring wells
that would be installed at the site under this alternative,
Courtaulds understands that EPA is considering the
installation of at least three and possibly up to twenty or
more extraction wells at the site. Assuming conservatively
that each extraction well has a pumping rate of 500 gallons
per minute, the installation and the use of up to twenty
wells would undoubtedly restrict the availability of ground
wafer for use in- Courtaulds' process. If even half of these
extraction wells were installed and operating, there is
significant doubt whether Courtaulds would be able to
continue its manufacturing operations, or expand current
manufacturing activities at the current plant location.
EPA Response. EPA does not "select" a remedy until the
Record of Decision (ROD) is signed. Furthermore, EPA does
not intend to adversely affect the availability of ground
water to Courtaulds Fibers. This issue will be considered
during the remedial design phase. It is anticipated that
only a few additional extraction wells will be required and
may or may not be located close to the Courtaulds property.
The number and location zf wells is to be determined through
ground-water monitoring and modeling, which will be conducted
during the remedial design chase. Availability of ground
water to the Ccurtaulds plant will be taken into account at
that time.
V. REMAINING CONCERNS
Local residents expressed several remaining concerns in
regard to remedial operations at the Stauffer sites. They remain
concerned about ground-water treatment, off-site contamination,
and health effects. EPA will continue to coordinate with the
other agencies involved to get site information to the citizens.
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ALD008161176
CO .
NPL Site Administrative Record
Index
As of July 11, 1989
Prepared for
Region IV
Waste Management Division
U.S. Environmental Protection Agency
With Assistance from
LABAT-ANDERSON, INCORPORATED
1111 lortb 19th «crwt, «olt» 2200 • Arlington, Virginia 222M • (703) S25-9400
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STAUFPER CHEMICAL CO. AXIS PLANT
NPL SITE ADMINISTRATIVE RECORD
Table of Contents
Volume I
1.0
PRE-REMEDIAL-
1.2 Preliminary Assessment
1.3 Site Inspection
3.0 REMEDIAL INVESTIGATION (RI)
3.1 Correspondence
3.2 Sampling and Analysis Data
Volume II
Volume III
Volume IV
Volume V
4.0
Volume VI
Volume VII
3.4 Interim Deliverables
3.6 Remedial Investigation (RI) Reports
3.6 Remedial Investigation (RI) Reports
3.7 Work Plans and Progress Reports
3.9 Health Assessments
3.10 Endangerment Assessments
FEASIBILITY STUDY (FS)
4.1 Correspondence
4.4 Interim Deliverables
4.5 Applicable or Relevant and Appropriate
Requirements (ARARs)
4.6 Feasibility Study (FS) Reports
4.6 Feasibility Study (FS) Reports
4.6 Feasibility Study (FS) Reports
4.7 Work Plans and Progress Reports
4.9 Proposed Plans for Selected Remedial Action
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STAUPFER CHEMICAL CO. AXIS PLANT
NPL SITE ADMINISTRATIVE RECORD
Table of Contents (cont'd.)
5.0 RECORD OF DECISION (ROD)
5.1 Correspondence
10.0 ENFORCEMENT
10.7 EPA Administrative Orders
10.8 EPA Consent Decrees
11.0 POTENTIALLY RESPONSIBLE PARTIES (PRP)
11.10 PRP-Specific Correspondence
13.0 COMMUNITY RELATIONS
13.2 Community Relations Plans
13.5 Fact Sheets
13.8 Scopes of Work
16.0 NATURAL RESOURCE TRUSTEE
16.1 Correspondence
16.5 Technical Issue Papers
Administrative Record Index
m
- 2 -
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INTRODUCTION
-I
Thia document is the Index to the Administrative Record for
the Stauffer Chemical Co. Axis Plant National Priorities List
(NFL) site.
The Administrative Record is available for public review at
EPA Region IVs Office in Atlanta/ Georgia/ and at the Toulmin-
ville Branch Library/ 2318 State Stephens Road/ Toulminville/
Alabama 36617.
Questions concerning the Administrative Record"should be
addressed to the EPA Region IV site manager.
The Administrative Record is required by the Comprehensive
Environmental Response/ Compensation/ and Liability Act (CERCLA)/
as amended by the Superfund Amendments and Reauthorization Act
(SARA).
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J-t«3—
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DRAFT, 07/11/89, 09:54 , Page 1
ADMINISTRATIVE RECORD INDEX
-»
for the
STAUFFER CHEMICAL CO. AXIS PLANT NPL Site
1.0 PRE-REMEDIAL
1.2 Preliminary Assessment
1. "Potential Hazardous Waste Site - Identification and
Preliminary Assessment," Javier Colon, EPA Region IV
(December 13, 1979). Concerning the Stauffer Chemical
Co. sites.
1.3 Site Inspection
1. "Hazardous Waste Site Investigation - Groundwater
Monitoring - Stauffer Chemical Corporation - Axis and
Bucks, Alabama," James Kopotic, EPA Region IV (May 18,
1983). Concerning the investigation conducted October
12, 1982, through October 16, 1982.
2. "Potential Hazardous Waste Site - Site Inspection
Report," Jennifer Scott-Simpson, EPA Region IV (July
13, 1983). Concerning the Stauffer Chemical Co. Axis
Plant site.
3.0 REMEDIAL INVESTIGATION (RI)
3.1* Correspondence
1. Cross-Reference: Letter from J.D. Sheehan, Stauffer
Chemical Company, to James Orban, EPA Region IV
(December 21, 1984). Concerning participation by
Stauffer Chemical Company in a remedial investigation
and feasibility study at Stauffer's Cold Creek plant.
[Filed and cited as entry number 1 in 11.10
POTENTIALLY RESPONSIBLE PARTIES
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DRAFT, 07/11/89, 09:54 t Page 2
3.2 Sampling and Analysis Data
-•i
The Sampling and Analysis Data for the Remedial
Investigation (RI) may be reviewed, by appointment only,
at EPA Region IV, Atlanta, Georgia
1. "Remedial Investigation/Feasibility Study - Cold Creek/
LeMoyne Site - Sampling & Analysis Manual," Stauffer
Chemical Company (August 9, 1985). Note: The
appendices to this manual have not been copied for the
administrative record. They are contained within
items 7, 8, 9, 11, and 31 in the Guidance Documents
section of this index.
2. Letter from Horst Caspers, Stauffer Chemical Company,
to Jim Orban, EPA Region IV (November 18, 1985).
Transmitting the attached pages updating the August 9,
1985, "Remedial Investigation/Feasibility Study - Cold
Creek/LeMoyne Site - Sampling & Analysis Manual,"
Stauffer Chemical Company.
3. Letter from Horst Caspers, Stauffer Chemical Company,
to Wade Knight, EPA Region IV (April 25, 1986).
Transmitting the attached revisions to analytical
methods in the August 9, 1985, "Remedial Investigation/
Feasibility Study - Cold Creek/LeMoyne Site - Sampling
& Analysis Manual," Stauffer Chemical Company.
3.4 Interim Deliverables
1. "Sensitive Receptor Report - Cold Creek/LeMoyne
Remedial Investigation Study," Stauffer Chemical
Company [?] (September 5, 1986).
*
3.6 Remedial Investigation (RI) Reports
1. Letter from Thomas Sayers, Stauffer Chemical Company,
to Thu Kim Dao, EPA Region IV (February 20, 1987).
Concerning transmittal of the draft "Remedial
Investigation Report 'for the Cold Creek/LeMoyne Site,
Mobile County, Alabama".
2. Memorandum from Cody Jackson, Agency for Toxic
Substances and Disease Registry, to. Thu Kim Dao, EPA
Region IV (April 1, 1987). Concerning comments on the
draft "Remedial Investigation Report for the Cold
Creek/LeMoyne Site, Mobile County, Alabama".
3. Letter from Thu Kim Dao, EPA Region IV, to Thomas
Sayers, Stauffer Chemical Company (May 19, 1987).
Concerning comments on the draft "Remedial
Investigation Report for the Cold Creek/LeMoyne Site,
Mobile County, Alabama".
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DRAFT, 07/11/89, 09:54 , Page 3
3.6 Remedial Investigation (RI) Reports (cont'd.)
4. Letter from Sylvie Olney and Wanda Ratliff, ERT for
Akzo Chemicals Inc. and ICI Americas Inc., to Ellen
VanDuzee, EPA Region IV (January 27, 1988).
Concerning transmittal of the draft "Remedial
Investigation Report for the Cold Creek/LeMoyne Site"
(revision 2) and draft "Endangerment Assessment Report
- Cold Creek/LeMoyne Site".
5. Letter from Wanda Ratliff, ERT for Akzo Chemicals Inc.
and ICI Americas Inc., to Ellen VanDuzee, EPA Region .
IV (February 9, 1988). Transmitting the attached
corrected version of Appendix XXVI of the "Remedial
Investigation Report for the Cold Creek/LeMoyne Site,
Mobile County, Alabama".
6. Memorandum from Ellen VanDuzee, EPA Region IV, to
Mariam Tehrani, Akzo Chemicals Inc. (February 17,
1988). Concerning comments on the draft "Remedial
Investigation Report for the Cold Creek/LeMoyne Site"
(revision 2) and draft "Endangerment Assessment Report
- Cold Creek/LeMoyne Site".
7. "Remedial Investigation Report for the Cold Creek/
LeMoyne Site, Mobile County, Alabama - Final Report,"
Akzo Chemicals Inc., and ICI Americas (May 1988).
8. Letter from Charles Margin and Sylvie Olney, ERT for
Akzo Chemicals Inc. and ICI Americas Inc., to Larry
Meyer, EPA Region IV (May 16, 1988). Responding to
the February 17, 1988, comments from Ellen VanDuzee,
EPA Region IV.
9. Letter from Kurt Batsel, Camp Dresser & McKee Inc., to
Larry Meyer, EPA Region IV (July 15, 1988).
« Concerning comments on the May 16, 1988, ERT response
to EPA Region IV comments.
10. Letter from Lee Erickson, ICI Americas Inc., to
Benjamin Moore, EPA Region IV (September 22, 1988).
Responding to EPA Region IV comients on the draft
"Remedial Investigation Report for the Cold Creek/
LeMoyne Site, Mobile County, Alabama" (revision 2).
3.7 Work Plans and Progress Reports
/ -
1. "Final Work Plan for Stauffer Chemical Cold Creek and
LeMoyne Sites - Remedial Investigation/Feasibility
Study - Mobile County, Alabama - Volume I," Camp
Dresser t McKee Inc. (August 27, 1985).
2. "Final Work Plan for Stauffer Chemical Cold Creek and
LeMoyne Sites - Remedial Investigation/Feasibility
Study - Mobile County, Alabama - Volume II," Camp
Dresser & McKee Inc. (August 27, 1985).
3. "Amendment to Work Plan for Stauffer Chemical Company
Sites - Mobile County, Alabama - Volume II," Camp
Dresser & McKee Inc. (August 1, 1988).
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3.9 Health Assessments
1. "Health Assessment for Stauffer Chemical Company
National Priorities List (NPL) Sites, Mobile,
Alabama," Agency for Toxic Substances and Disease
Registry (January 6, 1989).
2. Letter from Diane Scott, EPA Region IV, to Dan Cooper,
State of Alabama Department of Environmental
Management (February 14, 1989). Concerning
transmittal of the Health Assessments for the Stauffer
Chemical Co. sites.
3. Letter from Diane Scott, EPA Region IV, to James
Hathcock, State of Alabama Department of Environmental
Management (February 14, 1989). Concerning
transmittal of the Health Assessments for the Stauffer
Chemical Co. sites.
3.10 Endangerment Assessments
1. "Endangerment Assessment Report - Cold Creek/LeMoyne
Site, Mobile County, Alabama - Draft," ERT for Akzo
Chemicals Inc. and ICI Americas Inc. (January 1988).
2. Letter from E.R. Roach, U.S. Fish and Wildlife
Service, to Ellen VanDuzee, EPA Region IV (February
12, 1988). Concerning comments on the January 1988
"Endangerment Assessment Report - Cold Creek/LeMoyne
Site, Mobile County, Alabama - Draft," ERT for Akzo
Chemicals Inc. and ICI Americas Inc.
3. "Endangerment Assessment Report - Cold Creek/LeMoyne
Site, Mobile County, Alabama," ERT for Akzo Chemicals
Inc. and ICI Americas Inc. (May 1988).
m
4.0 FEASIBILITY STUDY (FS)
4.1 Correspondence
1. Letter from Benjamin Moore, EPA Region IV, to Mariam
Tehrani, Akzo Chemicals Inc. (September 7, 1988).
Concerning the decision to conduct a biological study
of the Cold Creek Swamp and other matters.
4.4 Interim Deliverables
1. "Stauffer Chemical Company - Cold Creek and LeMoyne
Sites, Mobile, Alabama - Contaminant Transport
Modeling - Final Report," Camp Dresser & McKee Inc.
(June 30, 1988).
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DRAFT, 07/11/89, 09:54 Page 5
1
4.5 Applicable or Relevant and Appropriate Requirements
(ARARs)
1. Letter from Diane Scott, EPA Region IV, to Charles
Horn, State of Alabama Department of Environmental
Management (May 30, 1989). Concerning Alabama water
quality criteria as applicable to the Stauffer
Chemical Co. sites.
4.6 Feasibility Study (FS) Reports
1. Letter from Benjamin Moore, EPA Region IV, to Mariam
Tehrani, Akzo Chemicals Inc. (September 7, 1988).
Concerning comments on the draft "Feasibility Study
Report for the Cold Creek/LeMoyne Site, Mobile County,
Alabama".
2. Cross-Reference: Letter from Lee Erickson, ICI
Americas Inc., to Benjamin Moore, EPA Region IV
(September 22, 1988). Responding to EPA Region IV
comments on the draft "Remedial Investigation Report
for the Cold Creek/LeMoyne Site, Mobile County,
Alabama" (revision 2). [Filed and cited as entry
number 10 in 3.6 REMEDIAL INVESTIGATION (RI) -
Remedial Investigation (RI) Reports]
3. Letter from Mariam Tehrani, Akzo Chemicals Inc., to
Benjamin Moore, EPA Region IV (September 28, 1988).
Responding to the Mr. Moore's comments of September 7,
1988.
4. Letter from Benjamin Moore, EPA Region IV, to Mariam
Tehrani, Akzo Chemicals Inc. (November 16, 1988).
Concerning additional comments on the draft
. "Feasibility Study Report for the Cold Creek/LeMoyne
Site, Mobile County, Alabama".
5. Letter from Benjamin Moore, EPA Region IV, to Mariam
Tehrani, Akzo Chemicals Inc. (January 24, 1989).
Concerning comments on the draft "Feasibility Study
Report for the Cold Creek/LeMoyne Site, Mobile County,
Alabama".
6. Meeting Agenda, EPA Region IV and Akzo Chemicals Inc.
(March 16, 1989). Concerning discussion of comments
on the draft "Feasibility Study Report for the Cold
Creek/LeMoyne Site, Mobile County, Alabama*.
7. Letter from Patrick Tobin, EPA Region IV, to Mariam
Tehrani, Akzo Chemicals Inc. (March 24, 1989).
Transmitting a summary of the March 16, 1989, meeting
between representatives of EPA Region IV and Akzo
Chemicals Inc.
8. Letter from Mariam Tehrani, Akzo Chemicals Inc., to
Patrick Tobin, EPA Region IV (April 6, 1989).
Responding to EPA Region IV comments on the draft
"Feasibility Study Report for the Cold Creek/LeMoyne
Site, Mobile County, Alabama".
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DRAFT, 07/11/89, 09:54 Page 6
l
4.6 Feasibility Study (FS) Reports (cont'd.)
*t
9. Letter from Lee Erickson, ICI Americas Inc., to
Patrick Tobin, EPA Region IV, with Attachments (April
13, 1989). Responding to EPA Region IV comments on
the draft "Feasibility Study Report for the Cold Creek/
LeMoyne Site, Mobile County, Alabama".
10. Letter from Diane Scott, EPA Region IV, to Mariam
Tehrani, Akzo Chemicals Inc. (April 21, 1989).
Responding to Ms. Tehrani's letter of April 6, 1989,
to Patrick Tobin.
11. Letter from Diane Scott, EPA Region IV, to Mariam
Tehrani, Akzo Chemicals Inc. (May 11, 1989).
Concerning Point of Compliance wells at the Stauffer
Chemical Co. sites.
12. "Feasibility Study for the Cold Creek and LeMoyne
Sites, Mobile County, Alabama," ENSR Consulting and
Engineering for Akzo Chemicals Inc. and ICI Americas
Inc. (June 1989).
13. Letter from Diane Scott, EPA Region IV, to James
Hathcock, State of Alabama Department of Environmental
Management (June 22, 1989). Transmitting the draft
Proposed Plan and the "Feasibility Study for the Cold
Creek and LeMoyne Sites, Mobile County, Alabama," ENSR
Consulting and Engineering for Akzo Chemicals Inc. and
ICI Americas Inc.
4.7 Work Plans and Progress Reports
1. Cross-Reference: "Final Work Plan for Stauffer
Chemical Cold Creek and LeMoyne Sites - Remedial
• Investigation/Feasibility Study - Mobile County,
Alabama - Volume I," Camp Dresser & McKee Inc. (August
27, 1985). [Filed and cited as entry number 1 in 3.7
REMEDIAL INVESTIGATION (RI) - Work Plans and Progress
Reports]
2. Cross-Reference: "Final Work Plan for Stauffer
Chemical Cold Creek and LeMoyne Sites - Remedial
Investigation/Feasibility Study - Mobile County,
Alabama - Volume II," Camp Dresser & McKee Inc.
(August 27, 1985). [Filed and cited as entry number 2
in 3.7 REMEDIAL INVESTIGATION (RI) - Work Plans and
Progress Reports]
3. Cross-Reference: "Amendment to Work Plan for Stauffer
Chemical Company Sites - Mobile County, Alabama -
Volume II," Camp Dresser & McKee Inc. (August 1,
1988). [Filed and cited as entry number 3 in 3.7
REMEDIAL INVESTIGATION (RI) - Work Plans and Progress
Repofts]
4. "Bioaccumulation Study Work Plan for Akzo Chemical
Inc., Axis, Alabama," Jeffrey Reidenauer, BCM Converse
Inc. (October 1988).
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DRAFT, 07/11/89, 09:54 , Page 7
4.7 Work Plans and Progress Reports (cont'd.)
5. Letter from Benjamin Moore, EPA Region IV, to Mariam
Tehran!, Akzo Chemicals Inc. (October 26, 1988).
Concerning receipt of the October 1988
"Bioaccumulation Study Work Plan for Akzo Chemical
Inc., Axis, Alabama," Jeffrey Reidenauer, BCM Converse
Inc.
6. "Addendum to Feasibility Study Report - Stauffer
Chemical LeMoyne and Cold Creek Sites," Diane Scott,
EPA Region IV (July 11, 1989).
4.9 Proposed Plans for Selected Remedial Action
1. "EPA Announces Proposed Plan," EPA Region IV (July 11,
1989). Concerning the Stauffer Chemical Co. sites.
5.0 RECORD OF DECISION (ROD)
5.1 Correspondence
1. Letter from James Scarbrough, EPA Region IV, to Mariam
Tehran!, Akzo Chemicals Inc. (March 17, 1988).
Concerning the need for a "letter of request" from
Akzo for an extension of their Record of Decision date.
2. Letter from Mariam Tehrani, Akzo Chemicals Inc., to
Lee DeHihns, EPA Region IV (March 24, 1988).
Concerning a request that the deadline for the Record
of Decision be extended to February 1, 1989.
10.0 ENFORCEMENT
10.7 EPA Administrative Orders
1. Letter from Wendy Tisch, Stauffer Chemical Company, to
Anne Heard, EPA Region IV (October 15, 1985).
Concerning comments on the draft Administrative Order
on Consent, In the Matter of Stauffer Chemical Company
Sites, LeMoyne and Cold Creek Plans, Mobile County,
Alabama.
2. Administrative Order on Consent, In the Matter of
Stauffer Chemical Company Sites, LeMoyne and Cold
Creek Plants, Mobile County, Alabama, Stauffer
Chemical Company, Respondent, Docket No. 86-04-C
(January 21, 1986).
10.8 EPA Consent Decrees
1. Letter from Patrick Tobin, EPA Region IV, to Steve
Perry, Akzo Chemicals Inc. (October 14, 1988).
Concerning the status of the consent decree to be
issued by EPA Region IV to Akzo Chemicals Inc. and ICI
Americas.
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11.0 POTENTIALLY RESPONSIBLE PARTIES (PRP)
-I
11.10 PRP-Specific Correspondence
1. Letter from J.D. Sheehan, Stauffer Chemical Company,
to James Orban, EPA Region IV (December 21, 1984).
Concerning participation by Stauffer Chemical Company
in a remedial investigation and feasibility study at
Stauffer's Cold Creek plant.
13.0 COMMUNITY RELATIONS
13.2 Community Relations Plans
1. "Final Community Relations Plan - Stauffer Chemical
Company Sites - Remedial Investigation/Feasibility
Study," Camp Dresser & McKee Inc. (September 4, 1985).
13.5 Fact Sheets
1. "Remedial Investigation/Feasibility Study Fact Sheet -
Stauffer Chemical Company Site - Mobile County,
Alabama," EPA Region IV (May 1986).
13.8 Scopes of Work
1. "Statement of Work - Community Relations Plan -
Stauffer NPL Sites, Mobile County, Mobile, Alabama,"
EPA Region IV (1988).
16.0 NATURAL RESOURCE TRUSTEE
16.1 Correspondence
1. Letter from Bruce Blanchard, U.S. Department of the
Interior, to Gene Lucero, EPA Headquarters (January
16, 1987). Concerning the results of a preliminary
natural resources survey of the Stauffer Chemical Co.
Cold Creek Plant site.
2. Letter from Bruce Blanchard, U.S. Department of the
Interior, to Gene 'Lucero, EPA Headquarters (January
16, 1987). Concerning the results of a preliminary
natural resources survey of the Stauffer Chemical Co.
Axis Plant site.
16.5 Technical Issue Papers
1. "Preliminary Natural Resource Survey - Stauffer
Chemical Company LeMoyne Plant, Axis, Alabama," U.S.
Fish and Wildlife Service (December 1986).
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ction IX
-------
_, GUIDANCE DOCUMENTS
EPA Guidance documents may be reviewed at EPA Region IV,
Atlanta, Georgia.
General BPA Guidance
1. Comprehensive Environmental Response. Compensation, and
Liability Act of 198Q. amended October 17, 1986.
2. "Guidelines Establishing Test Procedures for the Analysis of
Pollutants under the Clean Water Act; Final Rule and Interim
Final Rule and Proposed Rule* (40 CFR Part 136), Federal
Register. October 26, 1984.
3. Letter from Lee M. Thomas to James J. Florio, Chairman,
Subcommittee on Consumer Protection and Competiveness,
Committee on Energy and Commerce, U.S. House of
Representatives, May 21, 1987 (discussing EPA's
implementation of the Superfund Amendments and
Reauthorization Act of 1986).
4. Memorandum from Gene Lucero to the U.S. Environmental
Protection Agency, August 28, 1985 (discussing community
relations at Superfund Enforcement sites).
5. Memorandum from J. Winston Porter to Addressees ("Regional
Administrators, Regions I-X; Regional Counsel, Regions I-X;
Director, Waste Management Division, Regions I, IV, V, VII,
and VIII; Director, Emergency and Remedial Response
Division, Region II; Director, Hazardous Waste Management
Division, Regions III and VI; Director, Toxics and Waste
Management Division, Region IX; Director, Hazardous Waste
Division, Region X; Environmental Services Division
Directors, Region I, VI, and VII"), July 9, 1987 (discussing
interim guidance on compliance with applicable or relevant
and appropriate requirements ) .
6. "National Oil and Hazardous Substances Pollution Contingency
Plan," Coda ef Federal Regulations (Title 40, Part 300),
1985.,
;
7. AmerIJH£public Health Association, American Water Works
it and Water Pollution Control Federation.
ter. Washingtoni APHA, 1981.
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Methods
11
12
13
14
15
16.
17
18.
and
Plant Growth Regulators,
Academic Press, 1963-
n.S. Department of Health and Human Services. National
Institute for Occupational safety and Health. NIOSH
(NIOSH 77-157-A) f 1977.
8.
9.
10. U.S. Department of Health and Human Services. National
Institute for Occupational Safety and Health, and
Occupational Safety and Health Administration. Q
-------
19. U.S. Environmental Protection Agency. Office of Emergency
and RsjMdial Response. Superfund Public Health '
Directive 9285.4-1), October 1986.
20. U.S. HP&. Office of Ground-Water Protection. Ground-Water
Protection Strategy for the Environmental Protection Agency.
August 1984.
21. U.S. Environmental Protection Agency. Office of Research and
Development. Hazardous Waste Engineering Research
Laboratory. Handbook? Remedial Action at Waste Disposal
Sites ( Revised! (EPA/625/6-85/006), October 1985.
22. U.S. Environmental Protection Agency. Office of Research and
Development. Hazardous Waste Engineering Research
Laboratory . Technology Brief si Data Requirements for
Selecting Remedial Action Technology (EPA/600/2-87/001),
January 1987.
23. U.S. Environmental Protection Agency. Office of Research and
Development. Hazardous Waste Engineering Research
Laboratory. Treatment Technology Briefs i Alternatives to
Hazardous Waste Landfills (EPA/600/8-86/017), July 1986.
24. U.S. Environmental Protection Agency. Office of Research and
Development. Municipal Environmental Research Laboratory.
Biodeqradation and Treat^hi ifcy of Specific Pollutants
(EPA-600/9-79-034), October 1979.
25. U.S. Environmental Protection Agency. Office of Research and
Development. Municipal Environmental Research Laboratory.
(EPA-600/8-80-023), April 1980.
26. U.S. Environmental Protection Agency. Office of Research and
Development. Municipal Environmental Research Laboratory.
for Evaluating Remedial Action Technology Plans
Office of Solid Waste
(EPA-600/2-83-076), August 1983.
27. U.S. RnviromMntal Protection Agency,
and BMKOency Response. L __
ritiaet Development Process (BPA/540/G-87/003),
28. U.S. •SvironMntal Protection Agency. Office of Solid Waste
Emergency Response. Guidance on Feasibility Studies undea
t Concrelienflive Environmental Resoonse. Casoensatlon.
and Liability Actl (EPA/540/G-85/003), June 1985.
-------
29
30
U.S. Environmental Protection Agency. Office of Solid Waste
and Baatrgency Response. Guitjp^ce on RTBJTJlfl]. Investigations
/ ConDrehens ive Environmental RA«rv-tn«A
1985. -*.
(EPA/540/G-85/002), June
U.S. Environmental Protection Agency. Office of Solid Waste
and Emergency Response. Int**ri^" Guidance on Superfund
Selection of Remedy (OSWER Directive 9355.0-19), December 24,
1986.
31. U.S. Environmental Protection Agency. Office of Solid Waste
and Emergency Response. Test Methods for Evaluation of;
Solid Waatei Physical/Chemical Methods (SW-846), July
1982-
32. U.S. Environmental Protection Agency. Office of Solid Waste
and Emergency Response and Office of Emergency and Remedial
Response. Mobile Treatment Technologies for Superfund Wastea
(EPA/540/2-86/003 (f)), September 1986.
33. U.S. Environmental Protection Agency. Office of Solid Waste
and Emergency Response, Office of Emergency and Remedial
Response, and Office of Research and Development. Review of
- vrj^nme 1: Technical Evaluation (BPA-540/2-84-003a),
September 1984.
-------
;- s-- *~T ^^n^^^s
fbnitorinf°naientai p^
^^"'^SSsS^y^
-------
19
20
21
22
23
24
25
26
27
U.S. Environmental Protection Agency. Office of Emergency
and RosBdial Response. Suoerfund Public Health Bvaluatlon
[OSWKR Directive 9285.4-1), October 1986.
U.S. BMk. Office of Ground-Water Protection. Ground-Water
protection Strategy for the Environmental Protection Agency.
August 1984.
U.S. Environmental Protection Agency. Office of Research and
Development. Hazardous Waste Engineering Research
Laboratory. Handbook: Remedial Action at Waste Disposal
sites i'Revised1 (EPA/625/6-85/006)/ October 1985.
U.S. Environmental Protection Agency. Office of Research and
Development. Hazardous Waste Engineering Research
Laboratory. Technology Briefai Data Requirements for
Selecting P*W?dial.Action Technology (EPA/600/2-87/001)/
January 1987.
U.S. Environmental Protection Agency. Office of Research and
Development. Hazardous Waste Engineering Research
Laboratory. Treatment Technology Briefsi Alternatives to .
Hazardous Waste Landfills (EPA/600/8-86/017)/ July 1986.
U.S. Environmental Protection Agency. Office of Research and
Development. Municipal Environmental Research Laboratory.
Biodegradation and Treat*^ilitv of Specific Pollutants
(EPA-600/9-79-034), October 1979.
U.S. Environmental Protection Agency. Office of Research and
Development. Municipal Environmental Research Laboratory.
(
aro
EPA-
600/8-80-023), April 1980
U.S. Environmental Protection Agency. Office of Research and
Development. Municipal Environmental Research Laboratory.
Handbook for Evaluating Remedial
(EPA-600/2-83-076), August 1983.
U.S. Bnviro
and
.tal Protection Agency. Office of Solid Waste
xritiest Development Process (BPA/540/G-87/003) /
28. U.S. BMronaental Protection Agency. Office of Solid Waste
and KSMurgencT Response. Guidance on Feasibility Studies undei
Rnvri ronmont ji 1 9t»
knaatIon
and Liability Aet^ (EPA/54O/G-85/003), June 1985.
-------
29. U.S. Environmental Protection Agency. Office of Solid Waste
and BMSoency Response.
1983
(EPA/54O/G-85/002), June
Office of Solid Waste
30. U.S. Environmental Protection Agency,
and Emergency Response. "
Selection of Remedy (OSWER Directive 9355.0-19), December 24,
1986.
31. U.S. Environmental Protection Agency. Office of Solid Waste
and Emergency Response. Test Methods for Evaluation of
1982-
32. U.S. Environmental Protection Agency. Office of Solid Waste
and Emergency Response and Office of Emergency and Remedial
Response. Mobile Treatment Technologies for Superfund Waateg
(EPA/540/2-86/003 (f)), September 1986.
33. U.S. Environmental Protection Agency. Office of Solid Waste
and Emergency Response, Office of Emergency and Remedial
Response, and Office of Research and Development. Review of
- Volume 1« Technical Evaluation (BPA-540/2-84-003a),
September 1984.
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