United States        Office of
Environmental Protection   Emergency and
Agency           Remedial Response
                                         EP A/ROD/R04-93/157
                                         September 1993

                                         PB94-964014
v°/EPA   Superfund
          Record of Decision
          Helena Chemical Landfill, SC

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 50272-101

  REPORT DOCUMENTATION
           PAGE
1. REPORT NO.
EPA/ROD/R04-93/157
3. Recipient's Accession No.
    This and Subtitle
    SUPERFUND RECORD OF DECISION
    Helena Chemical Landfill,  SC
    First Remedial Action - Final
                                          5   Report OH*
                                                   09/08/93
 7.  Authors)
                                          a   Performing Organization Rept No.
 9.  Performing Organization Name and Address
                                          10  Project Taskwork Unit No.
                                                                     11.  Contrmct(C) or Grant(G) No.
                                                                     (G)
 12.  Sponsoring Organization Name and Address
    U.S. Environmental Protection Agency
    401 M  Street,  S.W.
    Washington,  D.C.  20460
                                          13.  Type of Raport A Period Covered

                                             800/800
                                                                     14.
 15.  Supplementary Notes
              PB94-964014
 ia  Abstract (Limit: 200 words)

  The 4-acre Helena Chemical Landfill  site is located on the northern portion of the
  13.5-acre Helena Chemical Company property in Fairfax, Allendale  County, South
  Carolina.  Land use  in the area is mixed commercial,  industrial,  agricultural, and
  residential.  A water  supply well to the city of  Fairfax supplies water to 2,300
  residents,  and is located 200 feet west of the property.  Surface water at the facility
  drains  into a small  ditch which subsequently drains into Duck Creek,  a tributary
  located northwest of the property that flows into the Cooswatchie River located to the
  west of the property.   In addition,  several wetland areas occur in the northern portion
  of the  facility in close proximity to the former  landfill. Prior  to the 1960s, and
  until  1978,  the Helena Chemical Company and two previous owners manufactured liquid  and
  powdered insecticides  onsite. The facility consists of three buildings: the north
  warehouse,  which was used to formulate liquid insecticides; the south warehouse, which
  was used to formulate  powdered insecticides; and  the office.  The former landfill is
  located north of the north warehouse and was reportedly used for  disposal of chemical
  wastes.   Several above-ground solvent tanks, which have since been removed, were used
  to store solvents transported to the site by rail.   Types of chemicals formulated or
  stored  onsite included pesticides, solvents, diesel fuels, and clays.  In 1980, State

  (See Attached Page)
17. Document Analysis    a. Descriptors
   Record of Decision - Helena  Chemical Landfill,  SC
   First Remedial Action - Final
   Contaminated Media:  soil, sediment, gw, sw
   Key  Contaminants:  VOCs  (benzene), other organics  (pesticides), metals  (chromium, lead)

   b.  Mentlfiers/Open-Ended Terms
   c  COSATl Field/Group
   Availability Statement
                         19.  Security Class (This Report)
                                   None
                                                    20.  Security Class (This Page)
                                                              None
          21.  No-ofPagM
                 100
                                                                              22. Price
(SeeANSt-Z39.1B)
                                   See Instruction* on Reverse
                                                  OPTIONAL FORM 272 (4-77)
                                                  (Formerly NTIS-35)
                                                  Department of Commerce

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EPA/ROD/R04-93/157
Helena Chemical Landfill,  SC
First Remedial Action  - Final

Abstract  (Continued)

investigations regarding an onsite  waste dump indicated high levels of various pesticides
at the site.  In 1981,  the  State  required Helena Chemical to provide additional information
regarding  site activities.  The  State, EPA, and Helena Chemical conducted additional site
investigations from 1981 through 1992.  These investigations confirmed the presence of
site-related  pesticides in the soil and indicated the presence of pesticides in sediment,
debris, ground water,  and  surface water in the vicinity of the former landfill.  Two
removal actions were conducted at the site during 1984 and 1992, and 500 and 1,000 yds^ of
contaminated  soil,  respectively,  were removed to a permitted hazardous waste landfill.
This ROD addresses  a first and final remedy for the remaining onsite contamination in the
soil, sediment, ground water, and surface water.  The primary contaminants of concern
affecting  the soil,  sediment, ground water, and surface water are VOCs, including benzene;
other organics, including  pesticides; and metals, including chromium and lead.

The selected  remedial  action for this site includes excavating approximately 20,000 yd^ of
contaminated  soil and  debris from the former landfill and areas adjacent to the northern
warehouse; treating the soil an  debris using hydrolytic/photolytic dechlorination (HPD),
followed by ex-situ biodegradation; returning the treated soil and debris to the original
excavated  areas; covering  the treated soil with at least one foot of clean fill; providing
for a contingent remedy including low temperature thermal desorption, if treatability
studies indicate that  the  HPD/biological treatment cannot attain the soil remediation
goals; demolishing  the former formulation buildings, if necessary, to allow for removal
and treatment of all contaminated soil; testing the demolished buildings to determine
appropriate handling and disposal options; mitigating any impact to wetlands; extracting
and treating  contaminated  ground water onsite to POTW pre-treatment requirements, with
discharge  to  the local POTW; and monitoring excavated and treated soil and ground water
(in-situ,  as  well as,  extracted  and treated) to ensure compliance with all performance
standards.  The estimated  present worth cost for this remedial action is $3,900,000.

PERFORMANCE STANDARDS  OR GOALS:

The soil excavation standard is  based on protection of human health and the environment
and is equal  to 50  mg/kg total pesticides.  Soil treatment standards are based on RCRA
LDRs and range from 66 ug/kg to  1,300 ug/kg.  Chemical-specific ground water treatment
goals are  based on  SDWA MCLs, and include benzene 5 ug/1; chromium 100 ug/1; lead 15 ug/1;
and pesticides 0.002-3 ug/1.

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           RECORD  OF  DECISION

SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
     HELENA CHEMICAL  SUPBRFUND SITE

        FAIRFAX, ALLENDALB COUNTY
              SOUTH CAROLINA
               PREPARED BY:
  U.S.  ENVIRONMENTAL PROTECTION AGENCY
                REGION IV
             ATLANTA,  GEORGIA

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              DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION

Helena Chemical
Fairfax, Allendale County,  South Carolina


STATEMENT OF BASIS AND PURPOSE

This decision document presents  the  selected  remedial action for
the Helena  Chemical  Superfund Site  (the Site)  in  Fairfax,  South
Carolina, which was chosen in accordance with the the Comprehensive
Environmental Response, Compensation  and Liability Act of 1980, as
amended by the Superfund Amendments and Reauthorization Act of 1986
and, to  the extent practicable,  the National Oil  and  Hazardous
Substances Contingency Plan (NCP).  This decision is based on the
Administrative Record file for this Site.

The State  of South  Carolina  concurs  with the  selected  remedy.
Appendix B contains the letter indicating their concurrence.


ASSESSMENT OF THE SITE

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.
DESCRIPTION OF THE SELECTED REMEDY

This  remedial  action  addresses onsite  soil contamination,  the
principal  threat  at  this  Site; as  well as  onsite  and  offsite
groundwater contamination.

The major components of the selected remedy include:

     SOURCE CONTROL

     D    Excavation of contaminated surface and subsurface
          soil, with verification sampling;

     D    Treatment of the contaminated soils by means of
          hydrolytic/photolytic dechlorination and  biological
          degradation;

     D    Placement of the  treated  soils  into on-Site excavations.

     D    Site re-grading to prevent uncontrolled storm-water
          run off into waters of the State or the United States.

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                               -2-
     GROUNDWATER
          Extraction of contaminated groundwater from the surface
          (shallow)  aquifer;

          Treatment and discharge of the treated groundwater to a
          local Publicly-Owned Treatment Works (POTW).
     MITIGATION FOR ADVERSE IMPACTS TO WETLANDS

     D    Mitigation for adverse impacts to environmental receptors
          in  accordance with  regulatory guidelines  established
          under the  authority  of  Section 404 of  the  Clean Water
          Act.
     SITE MONITORING

     D    Quarterly sampling of groundwater and nearby public water
          supply  to  monitor the  concentrations and movement  of
          contaminants  in  affected   and  potentially  affected
          aquifers.


     CONTINGENCY REMEDY

     D    Low   temperature   thermal   desorption   (LTTD)   is   a
          contingency remedy for soil  treatment, to be implemented
          should  the  chosen  soil  treatment  technology  prove
          incapable of achieving performance standards.


STATUTORY DETERMINATIONS

The  selected  remedy  is  protective   of  human health  and  the
environment, complies with Federal and State requirements that are
legally  applicable  or relevant  and appropriate to  the  remedial
action,  and is cost  effective.   This remedy  utilizes permanent
solutions and alternative and/or innovative treatment  technology to
the  maximum extent  practicable  for   this  Site.     The  selected
groundwater  remedy   component   satisfies  the preference  for
treatment.   The  selected  remedy  for source  control  and soil
treatment also satisfies the preference for treatment.

Since  selection  of  this  remedy  will   result in  contaminated
groundwater remaining onsite above health-based levels until remedy
implementation is complete,  a review will  be conducted within five
years after commencement of remedial action to  insure that the

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                               -3-
remedy continues to provide adequate protection of human health and
the environment .
Patrick M. Tobin
Acting Regional Administrator
                                            Date

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                        TABLE OF CONTENTS
SECTION                                                      PAGE

 1. 0  SITE LOCATION AND DESCRIPTION 	1

      1.1  Site Location 	1
      1.2  Site Description 	1
      1.3  Site Topography and Drainage 	4
      1. 4  Climate 	4
      1.5  Geology and Hydrogeologic Setting 	5

 2.0  SITE HISTORY AND ENFORCEMENT ACTIVITIES 	.	6

 3.0  HIGHLIGHTS OF COMMUNITY PARTICIPATION	8

 4.0  SCOPE AND ROLE OF THIS ACTION WITHIN SITE STRATEGY	9

 5 . 0  SUMMARY OF SITE CHARACTERISTICS 	9

      5.1  Site-Specific Geology and Hydrogeology 	9
      5 .2  Nature and Extent of Contamination 	18
           5.2.1  Surface and Subsurface Soils 	20
           5.2.2  Groundwater 	27
           5.2.3  Surface Water 	34

 6.0  SUMMARY OF SITE RISKS 	34

      6 .1  Contaminants of Concern 	36
      6.2  Exposure Assessment 	49
      6 .3  Toxicity Assessment	52
      6.4  Risk Characterization 	56
      6.5  Environmental (Ecological) Risks	59

 7.0  DESCRIPTION OF REMEDIAL ALTERNATIVES 	60

      7 .1  Alternative 1; No Action 	63
      7.2  Alternative 2; Landfill 	63
      7 .3  Alternative 3; Biodegradation	64
      7.4  Alternative 4; HPD	65
      7.5  Alternative 5; HPD/Biodegradation	66
      7 . 6  Alternative 6; LTTD	67

 8.0  SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES  	68

      8.1  Criteria for Comparative Analysis 	68
           8.1.1  Threshold Criteria 	68
           8.1.2  Primary Balancing Criteria 	68
           8.1.3  Modifying Criteria 	69
      8.2  Comparison of Alternatives 	69

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	Table of Contents (cont'd.)	ii

SECTION                                                      PAGE

 9 . 0  THE SELECTED REMEDY  	70

      9.1  Description of Selected Remedy  	71
           9.1.1  Source Control  	71
           9.1.2  Ground Water Remediation  	72
           9.1.3  Wetlands Mitigation  	73
           9.1.4  Compliance Testing 	74
           9.1.5  Contingency Remedy 	75

      9.2  Applicable or Relevant and Appropriate Rrequirements
               (ARARs) 	75
           9.2.1  Applicable Requirements  	75
           9.2.2  Relevant and Appropriate Requirements	76
           9.2.3  Criteria "To Be Considered"	79

      9.3  Performance Standards  	80
           9.3.1  Excavation Standards  	80
           9.3.2  Treatment Standards  	80
           9.3.3  Ground-Water Remediation Stds	81
           9.3.4  Storm Water Discharge Stds	81
           9.3.5  Wetlands Mitigation  	81

10.0  STATUTORY DETERMINATIONS 	82

APPENDICES

      APPENDIX A - RESPONSIVENESS SUMMARY

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                         LIST OF FIGURBS	iii
FIGURE                                                       PAGE

 - 1      Location Map 	2
   2      Site Layout Map	3
   3      Monitoring Well and Soil Boring Locations 	10
   4      Pesticides in Surficial Soils 	21
   5      Soil Pathway Exposure Assumptions 	46
   6      Ground-Water Pathway Exposure Assumptions 	48

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                         LIST OF TABLES	iv
TABLE                                                        PAGE

 -1       Phase II Slug Test Results  	;	14
  2       Hydraulic Gradients 	14
  3       Phase III Slug Test Results  	16
  4       Preliminary Contaminants of Concern  	19
  5       Phase II Pesticides in Surface Water & Sediment  	33
  6       Pesticides in Soils 	37
  7       Semi-Volatiles in Soils 	39
  8       Volatiles in Soils 	40
  9       Summary of Ground-Water Contamination 	41
 10       Phase III Pesticides in Surface Waters & Sediments...43
 11       GW Contaminant Exposure Data  	50
 12       Soil Contaminant Exposure Data 	51
 13       Summary of GW Exposure Risk  	53
 14       Summary of Soil Exposure Risk 	54
 15       Summary of Health-Based Risk Criteria 	55

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                         DECISION SUMMARY
                  HELENA CHEMICAL SUPERFDND  SITE
_^	FAIRFAX, ALLENPALB COUNTY, SOUTH CAROLINA	Page 1

1.0  SITE LOCATION AND DESCRIPTION

1..1  SITE LOCATION

Helena Chemical Company,  Fairfax,  South Carolina is located on 13.5
acres adjacent to Highway 321  in  Allendale County, South Carolina.
Figure 1.1 is a vicinity map.   Located at the facility is a former
landfill  which  contains  pesticide  residues  and  other  waste
materials  generated  on-Site.    The  former  landfill .occupies
approximately  four  (4)  acres on the northeast  portion of  the
Fairfax property.  Figure 1.2  is  an approximately  scaled survey of
the  facility  showing the location of the landfill. The  site is
encircled by a chain link security fence topped with barbed wire.
A city water well that is utilized by  a population  of approximately
2,300 is located 200 feet west of the property.

1.2  SITE DESCRIPTION

Three buildings exist on the Fairfax property; the  north warehouse,
the office, and  the south warehouse.   The north warehouse,  which
was  once utilized  to  house  the liquid  insecticide formulation
operation,  is   currently  used   to   store  various  pesticides,
herbicides, and  fertilizers which are sold to farmers.  There are
several  significant features  of  the  liquid formulation building
which were  focal points of  the investigation.   Two 22,000 gallon
above  ground  solvent  tanks  were once  located  near  the  north
entrance  to the  "kettle  room"  in the former  liquid formulation
building.  These tanks  were  present prior to Helena's occupancy of
the  property.    Solvents used  in the  formulation  process  were
delivered to the site by rail  car via a rail spur which was used to
serve the  facility.  The solvents were offloaded by pressurizing
the  tanker cars and pumping  the solvents  through product  lines
which ran under the formulation building to the storage tanks.  The
storage  tanks  were located in  the  area identified  as  the  "tank
farm"  on Figure 2.   The solvents were  then gravity  fed to the
kettle  as  needed.   The solvent  tanks  are  no  longer present;
however, the concrete slab on which the  tank saddles rested still
exists.  The remains of  a tank  farm  which was  used  to store the
technical grade pesticide compounds are located on the east side of
the liquid  formulation building.  Only the concrete pads on which
the tanks rested and a  retaining wall remain.  During the Remedial
Investigation  (RI)  a   drain  pipe  which  originates  inside  the
warehouse  was observed  and  is  suspected to  have been  used to
discharge effluent onto the ground surface in an area northwest of
the  structure.   The south  warehouse  where powdered insecticides
were formulated  is no  longer  in use.   A septic tank system which
serviced   the  property   is   located  between   the  north  liquid
formulation building and the  office.

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Figure 1;  Helena  Location Map
                            ^.C   .
                                             Helena Ch«mic«l  J
                                               Fairfax Site
                                                       .' • ^ /./
                                                      f /
                             CONTOUR DVTERVAL 1.5 METERS \  )

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Figure  2;   Helena  Site  Map
                                       CITY OT FAIRFAX
                                       MUNICIPAL VEIL
                                                                                                 - TREE LINE
                                                                                                 - FENCE
                                                                                           	APPROXIMATE
                                                                                                   PROPERTY BOUNDARY
                                                                                           — — - FORMER STREAM
                                                                                                   CHANNEL
                                                                                           	 INTERMITTENT STREAM
                                                                                                 - RAILROAD SPUR
APPROX. 13.5 ACRES
     BIQREHEDIATION
      PIUJT STUDY
      TEST rni«
                                       FORMER LOCATION
                                          OF HOUSE
                                                        FORMER LOCA
                                                          OF SOLVENT   \   APPROX,
                                                       \ STORAGE TANKS \   LOCATION
                                                                       OF FORMER
                                                                        LANDFILL
                                                             \ UNDERGROUND
                                                                  PIPING
  APPROX SEPTIC
  TANK LOCATION
          PAH ROAD
                                             Envlronnental ana Safety Designs. Inc.
                                                                                             FIGURE  1.8
                                                                                         FACILITY SKETCH
                                                                                       HELENA CHEMICAL CD.
                                                                                    FAIRFAX, SOUTH  CAROLINA
                   U.S.  HVY 331
                                              sitra mas oe /emoxm jwx •rmart-na
                                                                                DWG DATE: 03/29/92 I DWG NAME:HELS1T3

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Located northwest of the north warehouse are the remains of a house
that burned  sometime prior to  1988.   The house belonged  to the
previous property owner, Charles Blue.

According to City of Fairfax Water Department records, a 12" water
main constructed of cast iron  extends  across the site  between the
north warehouse and the former landfill.  The water line trends in
a  general  east-west  direction and  is  reported  to  have  been
installed approximately  ten years ago.

Between  the years  of  1971  and  1978,  Helena  used  the  Fairfax
facility for the formulation of liquid, and some dry,  agricultural
insecticides.   Prior to the ownership by  Helena Chemical Company
(beginning in 1971), two other chemical companies operated at the
Fairfax facility: Atlas Chemical Company,  owned by Billy Mitchell
(prior to the mid 60's), and then Blue Chemical Company,  owned by
Charles Blue (mid 60's through 1971).  Both Atlas Chemical Company
and Blue  Chemical  Company utilized the Fairfax  facility  for the
formulation of insecticides.  Chemicals formulated and/or stored at
the facility prior  to  Helena's ownership include:  DDT,  aldrin,
toxaphene,   disulfoton,   dieldrin,   chlordane,   BHC   (benzene
hexachloride),  and  ethoprop  (Mocap).   The  Fairfax facility  is
presently being operated as a retail sales  outlet and warehouse for
agricultural chemicals.  Chemicals used in  the previous formulation
of  insecticides  by  Helena  at the  Fairfax  facility 'include:
toxaphene,   methyl   parathion,    EPN    (ethyl    p-nitrophenyl
thionobenzene-phosphonate),  and disulfoton.    In  producing  the
insecticides, the chemicals were formulated as mixtures with other
ingredients  including diesel fuel,  aromatic solvents, and clays.

1.3  SITE TOPOGRAPHY AND DRAINAGE

The local topography of the Fairfax area  exhibits  little relief.
The Helena Chemical  property slopes slightly to the north.  North
of the property is  a topographically low area that collects surface
water during period of high rainfall.  Additionally, surface water
from the  facility drains  into  a  small ditch  that parallels the
property  to  the northwest. This  ditch carries the water to Duck
Creek, a tributary located northwest of the property,  which in turn
flows  into   the Coosawatchie  River  located  to  the  west  of the
Fairfax property.   The creek and the river are located within a
three  (3) mile  radius of the Site.


1.4  CLIMATE

The relatively temperate climate of Fairfax is  typical of the South
Carolina  coastal plains  region.  This is largely due to the close
proximity of the Atlantic Ocean and its warm Gulf Stream current
flowing  northward  near  the  southeastern  border of  the  state
creating  a warming  effect  on the region.

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Data  provided by  the  South  Carolina  State Climatology  office
indicated the annual mean temperature in the vicinity of Fairfax is
65.1°F.  The mean annual precipitation of Fairfax is approximately
47.95 inches.  These figures are based on data gathered at Hampton,
S.C. which is the closest reporting station to Fairfax (a reporting
station has recently been established in Allendale, S.C.; however,
at  the  present  time   insufficient  data  has  been  gathered  to
calculate the annual  means).

Prevailing winds in the Fairfax area exhibit seasonal variations.
In the spring, southwest winds are predominate;  summer,  south and
southwest winds  prevail;  autumn,  prevailing winds are  from the
northeast; and in winter, northeast and southwest winds have close
to the  same frequency.   Average wind speeds throughout  the year
range  from  6 to 10 miles  per hour (Climate Report No.  G5,  S.C.
State Climatology Office,  May 1990).

1.5  GEOLOGY AND HYDROGEOLOGIC SETTING

Site  specific geological   and stratigraphic data  were  developed
during  the  installation of   test  borings  and monitoring  wells.
Three distinct stratigraphic units were observed in the upper 145
feet  of  unconsolidated  sediments encountered at the site,  and a
fourth may be present.

The   lowermost   stratigraphic   unit    identified  during   the
investigation  was a  gray  to green,  fine  grained  clayey  sand
interbedded with clay laminae and numerous shell fragments.   The
unit  was  moist,  but  did not  exhibit the saturated properties as
seen  in the  overlying  sands. Based on  lithology, this unit is
presumed  to be the upper portion  of  the McBean/Santee Limestone
Formation.  The observed thickness of this unit was approximately
45 feet. The maximum thickness of this formation was not determined
during the  investigation.

Overlying  what  is presumed  to  be the  McBean  Formation  is  a
predominantly yellow  to gold, fine to coarse sand.  This unit is
also  characterized by numerous shell fragments interspersed among
the  sand  grains. These sands  are  thought  to be a member  of the
Barnwell  Group.   The  Barnwell Group is  comprised  of  the Tobacco
Road Sand and the Dry  Branch Formation. Recent investigations have
indicated that the contact  between  the formations is a one to three
foot  thick  layer, of coarse sand and gravel. This gravel layer was
not  positively  identified in any  of   the borings;  therefore,
distinct  facies  changes  were  not stratigraphically  identified
during the RI.

Overlying the sands of the  Barnwell Group is a light gray  and green
medium  sand which in  some locations graded  to a coarse tan sand
with  some pebbles  and shell  fragments.  The lower contact between
the  formations  was distinguished  by  a  silicified shell hash in
other locations. The  sands graded in a fining upward sequence to a

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very fine  to  medium grained sand intermingled with  a  dense red,
orange, and gray mottled clay. These sediments are characteristic
of what is thought to be the Duplin Formation.

Based on the boring logs from MW-12, MW-14, MW-19 and MW-20, there
appears to be a lateral  facies change to the north of the landfill.
Surface soils north of the landfill consist of a dark gray, dense
clay.   Due  to  limited  information,  it  is  unclear whether  the
detrital sand underlying this area is a continuation of the Duplin
or  if  a portion  of the Duplin  has been  eroded  and the  sand  a
product of more recent depositional processes.

The highest yielding  aquifer in  the area  surrounding  Fairfax is
found within  the  sands of  the  Cape Fear, Middendorf,  and Black
Creek Formations.  These regional aquifers are some of  the most
permeable  units   in the  stratigraphic  column,  providing  large
quantities of water for both municipal and private use.

The  high  clay content  of  the Black  Mingo Formation  results in
relatively low permeability.  This  has  led to the designation of
the  formation as  an aquitard or  aquiclude.   Some  small domestic
wells,  however, may be utilizing water from more permeable portions
of the Black Mingo.

Although previous  studies have indicated the McBean was not thought
to  be  important   as  a public or commercial   source, member beds
within this formation produce sufficient water for use.  The Town
of   Fairfax   south  municipal   well   is  screened  within  the
McBean/Santee Formation.   A  pumping  test on  the  municipal well
conducted by the  city engineers indicated a transmissivity of 500
ft.Vday at a pumping rate of approximately 298 gpm.  The overlying
sands of the Barnwell Group have been described as a relatively low
permeability,  low yielding  aquifer that  is  used  primarily  for
domestic water supply.  The  Barnwell underlying the site, however,
is recognized as  a highly permeable, saturated sand.

Previous investigations tentatively identified the presence of the
Cooper  Marl  at the Site.   Recent  investigations,  however,  have
indicated  that the surficial  sediments  are characteristic of the
Duplin Formation  of Miocene age.  The upper portion of the Duplin
Formation appears to be acting as an aquitard at the Site.


2.0  SITE HISTORY AND ENFORCEMENT ACTIVITIES

Several companies  have operated pesticide formulation facilities on
the  Site  currently owned by Helena.  Prior  to the mid-60's,  the
Site was  owned by Atlas Chemical Company, and from the'mid-60's
until 1971 by Blue Chemical  Company. Between  the years 1971-1978,
Helena Chemical company used  the  Site for the  formulation of both
liquid and dry agricultural  insecticides.  Chemicals that have been
stored  and/or formulated at the  facility  during  its active  life

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include DDT,  aldrin,  toxaphene,  disulfoton,  dieldrin,  chlordane,
benzene hexachloride (BHC), ethoprop, methyl parathion and ethyl p-
nitrophenyl   thionobenzene-phosphonate   (EPN).      During   the
formulation process these chemicals were mixed with carrying agents
including diesel  fuel,  volatile organic  chemicals  and adsorbent
materials.

The first regulatory actions  taken with respect to the Helena Site
occurred  in  November,  1980,  as  a  result  of  reports by  a  former
employee of Helena and a newspaper reporter that a waste dump was
being operated on the Site.  The Site was investigated at  that time
by  the South Carolina  Department  of  Health and  Environmental
Control  (SCDHEC).   Numerous  soil  samples  were collected  and
analyzed  in  December,  1980.   High  levels  of various pesticides,
including aldrin,  BHC isomers,  chlordane,  dieldrin,  disulfoton,
endrin and toxaphene were detected in these samples.  As a result
of  these  findings,  SCDHEC requested that  Helena provide further
information regarding activities at the Site, including chemicals
handled as  part of  the  operation,  waste  disposal  practices  and
other pertinent information with respect to past and present Site
activities.

SCDHEC issued a Notice of  Violation to Helena in July, 1981,  for
the  operation  of  a waste  disposal  facility  in  violation  of
applicable South Carolina regulations.  Negotiations between SCDHEC
and Helena resulted in the issuance of Administrative Consent Order
No. 81-05-SW  on October 1, 1981.  In compliance with the terms of
this Consent  Order,  Helena conducted  investigations at  the Site
lasting from  October, 1981,  to  July,  1982.  The results of these
studies indicated  that surficial soils were heavily contaminated
with pesticides, including those identified in the earlier sampling
described above.  The results of analyses of ground-water samples
obtained  as  part of  this investigation were contradictory;  the
positive  results  reported  from  the  first  sampling event were not
confirmed in  samples taken at that time or in subsequent sampling
events.   Surface  water samples,  taken  from water standing in the
wetland areas in the northern portion of the Site, were  found to be
heavily contaminated with site-related pesticides.

Helena prepared a plan for site remediation which was submitted to
SCDHEC  for  review,  and,  under  the  terms  of  an   amendment  to
Administrative Consent Order No.  81-05-SW, dated March 12,  1984,
remediation  efforts  were conducted that  consisted mainly  of the
removal  of  contaminated soils  to  a  permitted  hazardous  waste
landfill.

In  1985,   EPA,   in  conjunction  with  SCDHEC,  conducted a  Site
Screening Investigation  at the Helena Chemical  Site in order to
prepare a Hazard Ranking  System  (HRS) package for the Site in order
to  determine  whether the Site  should be included on the National
Priorities List  (NPL) .   The HRS ranking  was  completed  in June,
1987, and the Helena Site was proposed for listing in June, 1988.

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                                8

The Site was listed on the NPL in February, 1990.

In  April,  1989,  an  Administrative  Order by  Consent  (AOC)  was
jointly  developed,  negotiated and  agreed to  by EPA  arid  Helena
Chemical Company.  Under the terms  of  this AOC,  Helena agreed to
conduct a Remedial Investigation  (RI) and Feasibility Study  (FS) at
the Site  under the oversight of  EPA.   The purpose  of the RI/FS
process  was  to  develop an  appropriate  remedy  for the Site  as
required by the National Contingency Plan  (NCP).   Helena retained
the services of Environmental Safety and Designs,  Inc.  (ENSAFE) , of
Memphis, Tennessee as their  contractor  to  conduct  the RI/FS.  RI
field activities began in May, 1989, and were completed in April,
1992.

Two removal actions for contaminated soils  have taken place at the
Site.  In addition to the removal of  approximately 500 cubic yards
of  contaminated material conducted by Helena  in March,  1984,  as
discussed above, in April, 1992,  approximately  1000  cubic yards of
contaminated soils were also removed by Helena  under the oversight
of  EPA  and  likewise transported  to  a  secure  hazardous  waste
landfill.
3.0  HIGHLIGHTS OF COMMUNITY PARTICIPATION

Initial community relations activities at the Helena Chemical NPL
Site  included  development  and  finalization  of  the  Community
Relations  Plan  in December 1989.   An  information repository was
established at the Fairfax City Hall in January 1990.

A "kickoff" fact sheet announcing  the start of the  RI/FS was issued
in April 1990.  On April 19, 1990, EPA held a public meeting at the
Fairfax Community Center to present  the Agency's plans  for the
RI/FS.    The  meeting  was  attended by  several   local  citizens,
representatives of Helena Chemical,  elected local officials and was
covered by local newspapers.   EPA's presentation to  the public
included information on how to participate in the investigation and
remedy selection process under Superfund.  At the meeting, several
questions were asked and a fair amount of interest  was expressed by
the community.

Following  completion of the FS, a  second public meeting was held on
May 27, 1993, to update the public on the  RI findings to date, and
to present the proposed plan for the remedial actions at the Site.
The meeting was attended by only a few members  of  the public, with
no press coverage. At  this meeting, the primary concerns expressed
by  the public involved the threat posed by contaminated ground
water  to the  nearby public  supply well.

Proposed  Plan fact  sheets were distributed  on May  18,  1993.  An
advertisement was published in two  of the local newspapers on the
same date.  Both  the advertisement  and the  fact sheet highlighted

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the Public Comment period extending from May 18, 1993, until June
17, 1993.

At the Proposed Plan public  meeting on May 27, 1993, EPA presented
the Agency's  selection of  Preferred Alternatives  for addressing
soil,  sediment, surface water and groundwater contamination at the
Site.     Public comments  and  questions  are  documented  in  the
Responsiveness Summary, Appendix A.


4.0  SCOPE AND ROLE OF THIS ACTION WITHIN SITE STRATEGY

The purpose of the remedial  alternative  selected in this ROD is to
reduce current and future risks at this  Site.  The remedial action
for soil will  remove current and  future health threats  posed by
contaminated shallow soil  and will prevent leaching  of  the soil
contaminants to groundwater.  The groundwater remedial action will
remove  future risks posed  by potential  usage of  contaminated
groundwater.   It will  also  serve to remove the  threat to surface
water  by   reducing   the   concentrations   of   surficial  aquifer
contaminants  reaching nearby  surface  water  systems.   Wetlands
mitigation will address  the unacceptable  levels of environmental
risk posed by contamination of sediments and surface waters in on-
site and adjacent  jurisdictional  wetlands.  This is  the only ROD
contemplated for this Site.


5.0  SUMMARY OF SITE CHARACTERISTICS

The RI investigated  the nature and extent of contamination on and
near the Site,  and defined the potential risks to human health and
the environment posed by the Site.  A supporting RI objective was
to characterize the  Site-specific geology  and hydrogeology.   The
main portion of the  RI was  conducted from May 1989 through April
1992.   Onsite locations of soil borings, soil samples, and monitor
wells are shown in Figure 3.

5.1  SITE SPECIFIC GEOLOGY AND HYDROGEOLOGY

The  local  hydrogeologic  characterization discussed below  was
derived  from RI data,  including falling head permeability tests,
grain  size  analyses,  slug  tests,  piezometric  surface  maps,  and
numerous boring  logs.   In  addition,  the  Barnwell Group aquifer
system was monitored to determine if the City of  Fairfax Municipal
well affected the aquifer during pumping and non-pumping events as
described below.

For  the purpose  of  the   RI,   the  hydrogeologic  assessment
concentrated primarily on the uppermost  aquifer  at  the Site.  The

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                                                10
Figure  3;  Monitoring Wells and  Soil  Borings
                                                                                              100


                                                                                             feet
                                                                                     HIGHVAY
                                                                                      S-13
                                                                                         LEGEND
                                                                                          - TREE LINE
                                                                                   	•	  - fENCE
                                                                                  	 APPROXIMATE
                                                                                           PROPERTY BOUNDARY
                                                                                   —- —-  - FTIRMER STREAM
                                                                                           CHANNEL
                                                                                  	 INTERMITTENT STREAM
                                                                                   O MV-t  - MONITORING  WELL LOC.I

                                                                                     BH/HCB-* - BORING
                                                                                             UFMXDC. LOCATUkO
                      CSX RAILROAD
       HV-26.» MV-gS
              U.S. HVY 331
                                         Environnen-tal and Safety Designs. Inc.
                                           sun* racrr fle
       FIGURE  2.4
 BORING AND MONITORING
    VELL LDCATIDNS
  HELENA  CHEMICAL  CO.
FAIRFAX, SOUTH CAROLINA
                                                                          DWG DATE:03/29/92 I DWG NAME:HELFAX28

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                                11

uppermost aquifer occurs within  sands of the Barnwell Group and the
lower portion  of the Duplin Formation. Member beds  within these
formations may exhibit minor facies  changes;  however,  they are
considered to be hydraulically connected.

Beneath the  site,  the upper portion  of the Duplin  Formation at
times  demonstrates   the   hydrogeologic  characteristics  of  an
aquitard.  High clay content and corresponding low permeability are
two characteristics that  limit  vertical groundwater  flow in this
unit.  Grain size analyses and boring  logs indicate that the Upper
Duplin has a high silt and clay content. The average silt and clay
fraction from  nine  (9) soil  samples was 33  percent.   The samples
averaged 90 percent  finer than the upper limit designation- for fine
sand.  These analyses suggest  that the Upper Duplin  is  a silty,
clayey very  fine sand with the capability  to  retard groundwater
flow.

Estimates of permeability were determined with Shelby tube samples
collected  from the Upper  Duplin.   Eight undisturbed  soil samples
were obtained  from MW-4,  MW-8,  MW-10,  MW-14, MW-20,  MW-22, MW-24,
and MW-26  by pushing  a thin  walled Shelby tube  12-24 inches into
the  soil.    Rigid  wall  falling  head permeability  tests  were
conducted on these samples  in accordance with the Corp of Engineers
method EM  110-2-1906.   The resulting permeability values  were
indicative of  an aquitard, and they  highlight the  capability of
this unit  to  restrict near surface  groundwater  movement.   Two
additional thin wall Shelby tubes were collected from the clay cap
overlying the closed landfill, and  these soil samples also exhibit
low permeabilities.

The upper aquifer system appears to be comprised of,  in descending
order,   the  lower sands of the Duplin Formation,  the Tobacco Road
Sand Formation, and the Dry Branch  Formation.  These units exhibit
saturated  conditions  and  appear  hydraulically  connected  in the
study  area.    Although there are  a  few  thin clay/silt, laminae
present in the upper 30 feet  of  the unit the  limited thickness and
lateral extent of these  laminae suggest that they do  not impede
vertical groundwater  flow.   Well logs indicate  these sands to be
vertically uninterrupted from an average depth of approximately 12
feet to  a depth  of  at least 90  feet below ground  surface. The
overall  thickness of  the  uppermost  aquifer is  estimated  to be
approximately  80 feet.

The  Fairfax municipal well  log included  in the  RI  describes  a
yellow and gray clay from 90  to  103 feet.  During the installation
of soil boring HCB-5 on the north end of the Helena property a dark
gray to  green,  fine  grained clayey  sand interbedded with clay
laminae  and  numerous  shell   fragments   was  identified  from
approximately  95  to  145  feet below ground surface.   The unit was
moist,  but did not exhibit the saturated properties as seen in the
upper Eocene sands and appeared relatively impermeable.  Based on
the aforementioned lithological  descriptions, this unit is thought

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                                12

to be representative of the upper section of the McBean Formation.
Defining the lateral and vertical  extent of  this  unit was beyond
the scope of this  investigation.  The drillers log  from the City of
Fairfax  municipal  well,   however,  indicates  the  presence  of
limestone  at depths of  260 to  347 below ground surface.   The
limestone  may  be  representative   of  the  Santee  which  varies
considerably in  the area  and  may  signify actual  lateral  facies
changes between the downdip Santee and the updip McBean.

Water  level measurements   conducted  during  the RI  indicate  that
groundwater  flow directions in both the shallow and deep portions
of the upper aquifer  exhibit  seasonal variation.   Summer water
levels   indicate    that   shallow   flow   is   directed  to   the
south-southwest.  The piezometric diagram of water levels taken in
April  1991, however, reveals directional components to the south,
east and southeast.  Similarly, but to a lesser extent, groundwater
flowing in the  deeper portions of the aquifer exhibits variation in
direction  throughout  the  year.    Although deep well  control  is
limited, flow direction in  the summer is directed to the southwest.
This corresponds with shallow flow  directions.   The data for April
and September,  1991, indicate that  the  deeper groundwater flow was
toward the  south-southeast.

The lack of vertical groundwater flow is apparent from the minimal
differences  in  water  level  between  wells  in  the  nine  (9)
deep/shallow well clusters at the  site.  From the eight (8) water
level  measuring  events  that  have been  conducted,   the  maximum
downward vertical gradient  was  0.018 feet per  foot between MW-1 and
MW-2 for July,  1990.  The minimum was 0.0001 feet per foot between
MW-19  and MW-20 for October, 1991.   The average downward gradient
of the nine  (9) well clusters for the eight (8) measurement events
was 0.002  feet per  foot.

Interestingly,  the upper aquifer appears to change from unconfined
to confined conditions at different times throughout the year.  The
July,  1990  water  levels for most of the wells on site were from 2
to 2.5 feet below the  top  of the confining portion of the Duplin
formation.   This  suggests  unconfined conditions may exist for at
least  a portion of the year.  Conversely, confined conditions were
encountered in the spring of  1991 when water levels were well above
the contact between the more permeable sands of the upper aquifer
system and  the  overlying less permeable  clayey  sands.    This
artesian condition was further  supported by groundwater flowing out
the top of  MW-14  in March, 1991.   One  simple explanation for this
phenomenon  is  associated with  changing water levels in the upper
aquifer.

During the dryer portion  of  the  year (July and  August),  water
levels fall below  the base of  the clayey  sands of  the Duplin
Formation.   This effectively  dewaters the upper portion  of the
aquifer.   Dewatering is a characteristic  behavior of unconfined
aquifers.   During  wet  periods when water levels  rise above the

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                                13

contact between the permeable sands and the low permeability clayey
sand within the Duplin, the aquifer exhibits confined conditions.

To obtain  estimates  of groundwater velocity, several  slug tests
were  conducted at the site on March  4  and 5,  1991.   Testing
consisted of rising and/or falling  head slug tests for MW-2, MW-4,
MW-6, MW-8, andMW-10.

Rising and falling head slug tests were performed to characterize
the hydraulic  conductivity  (K)  of  aquifer materials.   Slug tests
were initiated during Phase II-B and Phase III of the RI.   Before
each slug  test was initiated,  the  static  water  level  in'the well
was  measured  using   an  electronic  water  level indicator.    A
stainless  steel  cylinder  of  known  volume  was then  introduced
"instantaneously" into the well, at which time, the water level and
the  time were recorded.   Periodically, water level/elapsed time
measurements were made as the head fell back to the original level.
Similarly,  rising head slug  tests  were preformed by removing the
slug and recording water level/elapsed time  measurements  as the
head rose  back  to  normal.   For slug  tests,  the  time required for
the water level to return to normal is  a function of the hydraulic
conductivity  (K) of the aquifer.

For this investigation, an In-Situ, HERMIT 1000B data logger and a
50 psi pressure transducer were used to record water level/elapsed
time measurements during each slug  test.  For purposes of graphing
data, the  instrument  was programmed to record  measurements  on a
logarithmic time  scale.   The  slug consisted of a  five-foot (5)
long, 1.66-inch diameter stainless  steel cylinder with a stainless
steel ring welded on one end.  A teflon coated  stainless steel cord
tethered to the ring  served  to suspend the slug in  the well just
above or below the water level.  At the beginning of each test, the
data logger was activated the  instant  the slug was either lowered
into or removed from the water.

The hydraulic  conductivity  (K)  calculated from  each slug test is
presented  in Table 1  below.  The methods  used to arrive at these
values are discussed below.  Rising and falling head slug test data
from each well were graphed as  time (elapsed)  versus Log(H/Ho) in
order to create a straight line. Log(H/Ho)  is the Log base ten of
the  change  in head  divided  by   the   initial  head.    Hydraulic
conductivity  (K)  was  computed from these  plots using a  method
developed by Hvorslev.

This method utilizes a variable known  as the basic time lag in an
equation that  calculates the  hydraulic  conductivity.   Hvorslev
contends that  the basic time  lag  is  the time  at which the head
ratio (H/Ho) equals 0.37.  Log (H/H<,)  was plotted against time on
standard graph paper.   A corresponding basic time  lag was taken
from  the  time  scale  at  the  bottom  of  each diagram, and  then
calculated using an equation for hydraulic conductivity.

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                                14

         Well
          MW2
Falling
2.5
          MW4
Falling
1.23
kmax  =  9.5
   ft/day
          MW6
Falling
 9.2
kmin =1.23
   ft/day
          MW6
Rising
 4.6
 kave  =5.3
   ft/day
          MW8
 Rising
 9.5
          MW10
Falling
 4.2
          MW10
 Rising
 5.6
The Hvorslev equation used in these calculations was developed for
confined  conditions  with  the assumption that  the test well  is
screened in the upper portion of a permeable unit that is overlain
by an  impermeable unit.   This  scenario  approximately  describes
Fairfax site conditions.

To  estimate  groundwater  velocity,  the  hydraulic gradient  was
derived from  the piezometric data generated during the  RI.   The
maximum and minimum slopes  between  contour lines  were  measured
directly from the isocon maps developed from this data,  and these
values are shown in Table  2.
            Shallow Wells
          Max
         0.0026
                                 Min
                       0.00033
             Deep Wells
          Max
         0.0035
                                  Min
                       0.0007
Estimates of the shallow horizontal groundwater velocity  (V) were
calculated from the  following formula:

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                                15
                    V = Ki/n

Where:
               V = groundwater velocity
               K = hydraulic conductivity
               i = hydraulic gradient
               n = porosity


A porosity  (n)  of 25 percent  was chosen based on  estimates  for
medium-to coarse-grained,  poorly sorted sand aquifers.  The maximum
and minimum estimated velocities were calculated using the maximum
and minimum hydraulic conductivities and corresponding hydraulic
gradients in the formula.

Estimated Shallow Groundwater Velocity V (ft/day)

Vmax =  (Kmax * imax)/n =0.1 ft/day
Vmin =  (Kmin * imin)/n =  0.0016 ft/day

Additional slug tests were completed upon completion of Phase III
field activities.  With  the  following exceptions,  Phase III slug
tests were conducted  in  a manner similar to  the  Phase II-B slug
tests:

     Phase III  tests  incorporated a different type of slug than
     Phase II-B.   Instead of using  the stainless  steel cylinder,
     one gallon of deionized water was "instantaneously" introduced
     in the well.

     Only  falling head  tests  were  conducted as  water was  not
     "instantaneously" removed  from the well.

For the Phase  III investigation, an In-Situ HERMIT 2000 data logger
and  a   20  psi  pressure  transducer  were  used to  record  water
level/elapsed  time measurements  during  each slug  test.    A  one
gallon jug of deionized water was used to slug each well.  At the
beginning of each test,  the  data  logger was activated the instant
that water was poured into the well.

Data reduction and  compilation  were conducted  using  the  same
equations and calculations described  for the Phase II-B slug tests.
The Phase  III slug test  graphs are presented in Appendix  C  and
Table 3 summarizes the hydraulic  conductivity values derived from
the graphs.

To determine if the aquifer supplying the Fairfax municipal well is
separate from the shallow aquifer beneath  the site,  two aquifer
communication tests were  conducted the week of November 11,  1991.
The  City  of  Fairfax  public  works  department  provided - full
cooperation during the tests.

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                                16
          MW5
Falling
10.04
         MW15
Falling
 3.23
         MW17
Falling
 3.15
The first test involved pumping the city well for three 1-hour long
intervals separated by nonpumping periods of approximately 1-hour
in  length.   This  test  was designed  to  approximate the  normal
operating conditions  of  the city pump system.  During  the test,
water  levels were  monitored  in  three  observation  wells  (MW-5,
MW-15, and MW-17).  Data  from  this test  were inconclusive because
identifiable trends did not develop from short duration pumping.

The second  test was conducted to  investigate  what  effects might
result from pumping the city well for longer than one hour. Pumping
duration  for the  second test lasted approximately  5.5  hours and
MW-5,  MW-15, and MW-17 served as observation wells again.  With a
pumping  duration  of 5.5 hours,  this  test was never designed or
intended to be  a constant rate aquifer test.

A Hermit  2000 data logger with  three pressure transducers and a
barometric  pressure  probe  were  used during  each  test.    Each
observation  well  had one of  the pressure transducers-monitoring
water level  fluctuations.  The barometric probe was placed on the
ground to measure changes in barometric pressure during the tests.
The data logger recorded  measurements  from the  four transducer
inputs simultaneously and on  five-minute intervals during pumping
and nonpumping  events.

For the  second test,  the data logger was activated approximately
17.5  hours  before  the city well  pump was started to investigate
local  water  level  trends.   The  static  water  level  in  each
monitoring well at  the time the data logger was activated became
the zero reference  level for  that well.  Throughout the recording
period,  the data logger  recorded water  level changes  from this
original reference  level.

Prior  to the test, the  city  water tank was allowed to  -drain to
approximately  1/3  capacity.   Because  some water had to remain in
the tank to maintain water pressure, this was the lowest water tank
level that Fairfax water supply officials would permit. Pumping at
390 gallons  per minute (gpm), it took the city water supply well
approximately  5.5 hours  to  refill the water tank during the test.

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                                17

Drawdown  values  from each  well were  plotted  against  time  to
investigate  water level  trends.   Drawdown  is represented  as  a
positive deflection from the original zero reference level in the
data.   Water levels recorded above  the  original  reference level
were recorded as  negative  drawdowns.   Similarly,  a rise in water
level  is  represented  by a  negative deflection.   In  all  three
monitoring wells there was  a general downward trend in water levels
with  time.    This  may be  the  result  of  increasing  barometric
pressure at the site.   When the water level graphs  were compared to
the barometric pressure graph,  however, the graphs show a definite
change in water level  with respect to pressure along the time axis.
The difference in drawdown changes may be due  to the difference in
water level elevation.

Interestingly, water levels in each observation well rose abruptly
when the pump was turned on.  Although immediate,  the maximum rise
in any  of the wells was  slightly above 0.1 feet.   While the pump
was  running,  water  levels  fluctuated  greatly.    When  the  pump
stopped, water levels  dropped to levels corresponding to prepumping
trends.

This phenomenon of abrupt rise and fall of water levels induced by
pumping is  common  in confined  and  semiconfined  aquifers.   The
occurrence  is  attributed  to the elastic properties of aquifer
materials  (Lohman,  1972} .   When the hydraulic  pressure in  an
artesian  aquifer is   reduced  from  pumping,  the  aquifer matrix
compresses to compensate.   This  matrix compression is physically
manifested  as  a  slight  net  reduction in  the thickness  of  the
aquifer.  When  pumping is  halted, the aquifer matrix elastically
rebounds and the original aquifer thickness is recovered.

Ultimately, what appears to be a rise and fall in  water levels may
actually  be a  decrease  and increase  in  the thickness of  the
aquifer.  During the test, as aquifer thickness changed, the ground
surface, well casings, and the transducers attached to the casings
were lifted  or lowered with respect to  the  nearly static water
level.  These reactions were recorded by the transducers as changes
in water level.

With regard  to  communication between the deep city water supply
aquifer and the shallow  aquifer  beneath  the site, the results of
this  test are  inconclusive.   No large scale  effects   (obvious
drawdown)  from pumping were observed in any of the  monitoring wells
over the relatively short  pumping duration used  in this test.   A
much longer pumping duration  (24-hours or more) may be necessary to
investigate whether the observed phenomenon  is   the result  of  a
hydraulic connection between the  two aquifers.

While   evaluating   the  results   of   this  pump   test,   however,
consideration  should  be  given  to  the  actual city pump system
configuration.   According  to Fairfax water supply officials,  the
city  pump  rarely  runs   longer   than  1/2  an hour at   a  time.

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                                18

Therefore, the pump  test  duration  of  5.5  hours created much more
stress on the aquifer than normal pumping conditions would create.
Even though greater stress occurred during this test, no excessive
drawdowns were observed in the monitoring wells.

Given  the uncertainty associated with  the  pump  test  already
conducted and the possibility of communication between the shallow
aquifer and the production zone of the City well, EPA believes that
further pump tests are warranted.   The details by which additional
pump tests will be conducted will be determined  during the Remedial
Design review process.


5.2  NATURE AND EXTENT OF CONTAMINATION

Environmental  contamination  at  the  Site  can  be summarized  as
follows:

     1)   Organic and inorganic constituents of concern have been
          identified   in   the  various   media.     The  primary
          constituents  of concern  at  the Site  include:  aldrin,
          alpha-BHC, beta-BHC, delta-BHC, gamma-BHC,  DDT, DDD, DDE,
          dieldrin, endosulfan,  endrin, endrin ketone, toxaphene,
          endosulfan   sulfate,  disulfoton,  benzene,   lead  and
          chromium.   Table 4, reproduced  from  the RI, identifies
          the preliminary contaminants of concern for the Site.

     2)   Surface and subsurface  soils throughout the  Site have
          been affected by past waste disposal  activities.   The
          highest levels of contamination are found in  the vicinity
          of the  former liquid formulation building now used as a
          warehouse,  in the vicinity of the old landfill, and near
          the  southernmost  building on the  Site in  an area where
          transhipments of materials from railroad cars occurred.

     3)   Ground waters in the aquifers immediately underlying the
          Site have been affected by waste disposal activities at
          the  Site.   The  ground  waters  underlying the  Site are
          considered to be Class IIB ground waters under the draft
          EPA   Guidelines    for    Ground-Water   Classification,
          indicating  that they  are a potential  source  of public
          water supply. These ground waters are also classified as
          Class GB ground waters under South Carolina regulations.
          The  ground water has been  contaminated to  levels that
          render  it  a threat to public health  should it ever be
          used  for  potable water  supply  and which  exceed state
          ambient standards  for Class GB  ground waters.  Ongoing
          sampling   has   to  date  revealed   no  site-specific
          contamination in the nearby municipal water supply well.

     4)   High levels  of  contamination remain  in soils and waste
          materials  in the old landfill  located  in  the northern

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                             19
  5)
portion of the Site.  These soils and waste materials are
likely  to  be  a  continuing  source  of  ground-water
contamination.

Surface  water and  sediments  in on-site wetlands and
drainage  pathways have been  affected  by  past  waste
disposal activities.  Pesticide concentrations in samples
taken from on-site surface waters exceeded criteria that
                                                   'ft , V-,
                       SOIL/SEDIMENTS
          Dieldrin
         Endosulfan
       Endrin Ketone
          4,4'-DDT
        Disulfoton**
Tributylphosphorotrithioate
          (TBPT)**
         Toxaphene
                                    Aldrin
                              Endosulfan Sulfate
                                    Endrin
                                 Methoxychlor
                                   4,4'-DDE
                                   4,4'-DDD
                           BHC  (a, fi, A and gamma)
                        ORODNDWATER
                          Benzene
                           Aldrin
                       Endosulfan II
                         Toxaphene
                    DDT (plus DDE & DDD)
                  BHC  (a, E, A and gamma)
                          Dieldrin
                           Endrin
                       Endrin Ketone
                     Heptachlor Epoxide
                         Disulfoton
                            TBPT
                            Lead
                          Chromium
                       SURFACE WATER
                         BHC (fi,  A)
                          Dieldrin
                       Endrin Ketone
       are protective of aquatic life.  Sediments in the on-site
       wetland areas  were found to be contaminated with site-
       related pesticides at levels that are likewise  likely to

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                                20

          have an adverse impact on indigenous aquatic life.

     6)   Background and on-site air sampling indicates that local
          ambient air has not been  affected by past waste disposal
          activities.


5.2.1  Surface and Subsurface Soils

The  results  of   the  field  investigation   identified  varying
concentrations of  polychlorinated  pesticide compounds  and minor
quantities of volatile  organics  in shallow surface  soils  (0 to 3
feet) .    Soils from  the 1 to 3  foot  interval would  normally be
considered shallow subsurface soils; however, for purposes of this
discussion soils from 0 to  3 feet  will  be referred  to as  surface
soils.    Surface  soils  were collected  employing hand, augering
techniques  as previously  described.    Figure  4 is  an  isocon
displaying the relative  distribution of total pesticides in surface
soils at the Fairfax  site.

In  addition  to  surface soil  samples,  ten   soil  borings  were
completed utilizing  hollow  stem auger  techniques.   Soil  samples
were collected for analysis  from the surface,  and from just below
the  interface of  the  vadose  and  saturated  zones.    Analytical
results from some deep soil  boring  samples have indicated elevated
levels of chlorinated pesticides.


5.2.1.1  VOCs in Soils

Soil samples collected throughout the RI have identified relatively
low levels of various volatile organic chemicals  (VOCs).  The most
commonly detected were acetone and methylene chloride; however, the
data  validation  review suggests  that  these  and  some  other
contaminants may be laboratory artifacts.   Two other chlorinated
solvents  were identified  in  soil samples,  tetrachloroethylene
(PCE),  and  trichloroethylene (TCE), although  the TCE detected in
two samples is believed to be a  laboratory artifact.  In addition,
the aromatic solvents,  benzene, toluene, ethylbenzene, and xylene
were identified.   Xylene is considered to be  directly related to
the  formulation process.    The VOCs   found  during  the   RI  are
discussed below.

Acetone

Acetone  is  a clear,  colorless  liquid with a  fragrant mint-like
odor.  Acetone is a common organic  solvent which  is highly soluble
in  water.    It  is  also  one  of the  most  common  laboratory
contaminants found in environmental samples.  Acetone was

-------
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-------
                                22

identified  in  approximately  57  percent  of  the  soil  samples
collected.  Concentrations range from 2 Hg/kg  (ppb) - 13,000 ^g/kg
(ppb).

Methylene Chloride

Methylene chloride is a clear, colorless, highly volatile liquid.
It is used as a degreaser, photographic film processing chemical,
solvent, raw material for  organic synthesis, and a fumigant.  It is
soluble in water  to  20,000  mg/1.   Methylene  chloride is a common
laboratory contaminant found in environmental samples.

Approximately  38  percent  of the  surface  soil  samples analyzed
indicated variable levels of methylene  chloride.  Concentrations
range from 2 ppb  - 140 ppb.

Tetrachloroethylene

Tetrachloroethylene  (PCE)  is a colorless  liquid with a chloroform-
like odor, and is  slightly soluble  in water (150  mg/1) .   It. is used
for dry cleaning,  metals  degreasing and heat exchange fluid.  PCE
was  formerly used in mixtures with grain protectants and certain
liquid grain fumigants (vermifuge).

Tetrachloroethylene was identified in less  than one percent of the
soil samples.  Concentrations ranged from 11 ppb - 240 ppb.

Trichloroethylene

Trichloroethylene  (TCE)  is a colorless, mobile,  volatile liquid
with a  chloroform-like odor.    It is used  as   a degreaser,  dry
cleaning  solvent,  gas purification agent,  and a raw material in
organic chemical manufacturing.

Trichloroethylene was identified in two soil samples, SS-10-1 and
SS-19-2. The concentrations were 24 and 210 ppb,  respectively. TCE
was also detected at 19 ppb in the trip blank submitted with these
samples on 02/26/91.  The samples were run consecutively indicating
the values may be laboratory artifacts or lab error.

Benzene

Benzene  is  a  clear,  colorless,  volatile liquid which' is very
slightly water soluble.  Benzene is a component of gasoline and an
organic solvent which was formerly used  (on  a  limited basis) in
pesticide  formulation.

Benzene  was  identified   in  approximately  three percent  of  the
samples.  Concentrations  ranged  from 3 to 1,300  ppb.

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                                23

Toluene

Teluene is a colorless liquid with  a benzol-like odor.  It is used
as  a  solvent,   and  in dye manufacturing,  artificial  leather
production, asphalt  and naphtha constituents, fuel  blending and
extraction of organic soluble plant materials.

Approximately eight  percent of  the  soil samples  identified low
levels of Toluene.  Samples range from a  low of 1 ppb to a high of
210 ppb.


EthyIbenzene

Ethylbenzene  is  a  colorless liquid  with  an aromatic odor and
limited water solubility  (140  mg/1) .    It  is used  in synthetic
rubber manufacturing, as a solvent, and is component of gasoline.
Ethylbenzene  was  detected  in approximately  three  percent  of the
soil samples.  Concentrations range from 3 ppb - 4100 ppb.

Xylene

Xylene is a clear liquid which consists of a mixture of three (3)
isomers:  ortho-,  meta-,   and para-.    Xylene  is  used  in  the
manufacture  of   a number  of consumer products,   and  is  also  a
component of  gasoline and a  raw material for synthesis of organic
chemicals.

Xylene was  detected in  four percent  of  the soil samples.   The
highest concentrations were  found  in the soils beneath the cap of
the  former  landfill.   The values  range  from 3 H-g/kg  to  27,000
Hg/kg.


5.2.1.2.  Semi-Volatiles in  Soils

Although no semi-volatile compounds were  confirmed  in soils during
the Data Validation report three tentatively identified compounds
(TIC's)   were   recognized:   disulfoton,   chlorobenzilate,   and
butylphosphorotrithioate.  Levels of  disulfoton ranged  from 60 ppb
-  430,000 ppb and  were identified in four percent of  the soil
samples collected. Butylphosphorotrithioate was detected in three
samples  at  a  concentrations  ranging  from  750  to  7900  ppb.
Chlorobenzilate was  not detected in  samples collected by ENSAFE,
but  was  identified  in  one split  sample  collected by the EPA
oversight contractor.   Disulfotone sulfone  was identified in one
sample at 51  ppb.  Disulfoton sulfone  is a degradation product of
disulfoton.

Disulfoton  (a.k.a. Di-syston) is a colorless, oily liquid (in the
pure  state),  and the technical  grade  is brown in color.   It is
generally  insoluble in  most organic  solvents.    Disulfoton was

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                                24

produced as an  insecticide  for  mites  and aphids  on small grains,
corn, sorghum, cotton, and other field crops.

Butylphosphorotrithioate is a colorless to pale yellow clear liquid
which is insoluble  in water.  It was  produced as a pesticide and
cotton defoliant.

Chlorobenzilate  (a.k.a. 4,4'-Dichlorobenzilic acid ethyl ester) is
a viscous liquid sometimes yellow in color,  and is slightly water
soluble.  It was manufactured as an acaricide.  It  was approved for
use  in  the USA  in  1969 for application on 11 crops  which were
primarily fruits and  vegetables.


5.2.1.3  Pesticides in Soil

Soil  samples  collected  during  the  RI  have indicated  a  varied
distribution  of  individual  pesticide  components.   Concentrations
for  total  pesticides  range  from below detection  limits  to 7170
mg/kg in surface and shallow subsurface soils.  For the purpose of
total pesticides, the values indicated represent  the summation of
all  pesticide components identified during  the RI.   The primary
pesticide  constituents identified  were  DDT  (and  its  degradation
products),  toxaphene, and BHC  (including isomers).   Contaminant
distribution  data have been generated  for the primary constituents
identified  on the  property.  Those components  comprising  a less
significant fraction  of the total  pesticides  identified include
aldrin,  chlordane   (including isomers),  dieldrin,  endrin,  endrin
ketone,  total endosulfans,  heptachlor,  heptachlor epoxide,  and
methoxychlor.

The  most significant  levels of  pesticides  identified  on the site
were found  immediately north, northwest, and/or east of the north
warehouse.  The overall levels  of  contamination generally show a
decrease in concentration with depth from the surface to three feet
below grade.   Isolated  "hot spots" however,  show an  increase in
concentrations  at  the one  to  two  foot  interval  with subsequent
decrease in concentration again  with depth.   Individual pesticides
are  further detailed  below.

Toxaphene

Toxaphene  (a.k.a.  chlorinated camphene)  is  produced as a yellow,
waxy solid with a  pleasant piney  odor.    Toxaphene  is  nearly
insoluble  in  water.-   It was used as  an insecticide  for cotton,
early stages of vegetables  (peas, soybeans, and peanuts),  and wheat
and  other  small grains.  Current uses  are  limited to cattle and
sheep dipping (under  certain provisions), disinfecting buildings,
and  termite,   insect,  rodent   and  other pest  control  (limited
application).  Toxaphene has not been  produced commercially in the
U.S. since  1982.

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                                25

Toxaphene is generally present  at the highest concentration in the
pesticide  fractions  identified at  the   Site.    Toxaphene  was
identified   in   40   percent   of  the   samples   collected   and
concentrations ranged  in value  from 42  ng/kg  (ppb)  to 2700 mg/kg
(ppm) .   Toxaphene data from the  RI indicate contamination with the
highest concentrations is found immediately northwest of the north
warehouse, and elevated concentrations were also identified east of
the building.

DDT, DDE, and DDD

DDT  (a.k.a. 4,4'-Dichlorodiphenyltrichloroethane) was produced as
colorless crystals or  white/off-white powder.   It is odorless or
has a slight aromatic odor.  DDE and DDD are found as contaminants
(minor  fraction)  in  DDT,  and may  also  be  produced  through
degradation of DDT.  These compounds are non-systemic contact and
stomach insecticides.  DDT  was  used primarily  to control insects
capable of spreading malaria, typhus, and other insect transmitted
diseases.  Use of these products has been banned in the U.S.

DDT was detected  in  approximately 61 percent of the soil samples
collected during the RI.  The reported concentration of DDT and its
degradation products  in  soils  ranged from 2.3  ppb  to  2,800  ppm.
Contaminant  distribution data  generated  during the RI  indicate
contamination from  DDT is greatest  at  the  surface  and decreases
with depth.

BHC  (Lindane) and laomers

Lindane  is  produced as  a white crystalline powder, and  is  only
slightly soluble in water (varies between isomers).  Lindane is a
organochlorine pesticide.  Lindane is the gamma isomer of benzene
hexachloride  (BHC).

All  four  BHC  isomers  (alpha,  beta,  gamma,  and  delta)  were
identified in soil samples collected during the  investigation.  The
most frequently  detected isomer was beta-BHC which  was  found in
approximately 38 percent  of  the soil  samples. Concentrations of BHC
range from 0.1 ppb - 390 ppm.   Again,  data indicate a decrease in
concentration levels with increased depth.

Aldrin

Aldrin  is  produced as  tan to dark  brown crystals  which  are
essentially  insoluble in  water.    It  was formerly  used as  an
insecticide, and has been registered as a termaticide in the USA.
The manufacture and use of aldrin have been banned in the USA.

Aldrin  was  detected  in  approximately 17  percent  of  the  soil
samples.  Values  ranged  from 1.2 ppb  -  800,000 ppb.  Predominant
soil contamination from aldrin was identified west and northwest of
the north warehouse.

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                                26

Chlordane

Chlordane  (pure  form)  exists as a colorless  to  amber,  odorless,
viscous liquid which is insoluble in water.   Chlordane  was also
produced in emulsifiable concentrates, granules, dusts and wettable
powders (for termite control) .   It was formerly used as a fumigant
and acaricide,  and also as a home and garden pesticide/insecticide.
As of 1983, the  only approved  use of  chlordane in the USA is for
termite control.

Chlordane (alpha and gamma isomers) was identified in approximately
four percent of the  soil samples.  Chlordane concentrations range
from 15 ppb - 58,694 ppb.

Dieldrin

Dieldrin was produced  as white crystals or light tan flakes which
are odorless and insoluble in water.   Dieldrin was formerly used to
control  soil  insects,  insects of  public   health  concern  and
termites.  Its use as  a broad spectrum insecticide ceased in 1974
when EPA restricted  its use  to direct soil injection for termite
control and non-food seed/plant treatment.

Dieldrin was  identified in approximately 36  percent  of  the soil
samples collected during the RI.  Dieldrin  concentrations range
from  4.6  ppb  -  96,000 ppb.   Soil  contamination  was  identified
between the warehouse and the former house and  in the low lying
areas  north and  west  of  the  former  landfill.    Concentrations
decrease with depth.

Total Endosulfans

Endosulfan  (two  (2)  isomers)  was  produced  as  brown  crystals
essentially insoluble  in water.  Its primary application was as an
insecticide for  vegetables.   Endosulfan  sulfate  is a degradation
product of endosulfan.

Endosulfan  was detected in  approximately 5 percent of  the soil
samples collected. Endosulfan sulfate was detected in approximately
13 percent of the samples analyzed. Concentrations ranged from 2.1
ppb  -  22,000  ppb.    The  most  significant  concentrations  were
identified   immediately  northwest   of   the   warehouse.     Less
significant  contamination was  identified in the  low  lying area
northwest  of  the  landfill.    Analytical  data  indicates  that
Endosulfan concentrations have decreased  with  depth.

Endrin

Endrin was produced as water insoluble white crystals dissolved in
a  liquid  carrier (organic  solvent).    The  only  uses currently
registered  in  the US  are  for  cotton  and bird perches.   It is a
persistent insecticide used on field crops to control army cutworm,

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                                27

meadow voles,  and  grasshoppers  under strict adherence to Federal
regulations on application.   Endrin  ketone  is  an impurity in and
degradation product of endrin.

Endrin and Endrin  Ketone  were identified in soil samples west of
the warehouse  and west-northwest of the landfill.  Concentrations
ranged from 0.74 ppb - 9,200 ppb.  Approximately  12 percent of the
samples collected contained endrin and 16 percent its degradation
product endrin ketone.    Concentrations  appear  to  decrease  with
depth with the exception  of one anomaly from sample SS-3-3.


Keptachlor

Heptachlor  was  produced   as  white  to  tan,  waxy-looking  solid
crystals which are nearly insoluble  in water.  It has been used as
an insecticide for termite control,  and was also formerly used in
fieldcrops (including corn, citrus, pineapples, cereal, vegetables
sugar beets,  nuts  and cotton) for pest  control  (fire ants,  boll
weevils).     Heptachlor   epoxide  is  a  degradation  product  of
heptachlor.

Heptachlor was identified in approximately 25 percent of the soil
samples.   The  concentration of heptachlor and  its  degradation
products ranged  from 1.0  ppb to 68,000 ppb.  The predominant area
of. contamination was  in the low lying area  north and west of the
landfill with some minor levels of contaminant identified, north of
the warehouse.

Meth.oxych.lor

Methoxychlor was produced as a white, crystalline solid- dissolved
in an  organic liquid  carrier.   It  is  essentially  insoluble in
water.  Methoxychlor has been used as  an  insecticide for livestock
and  poultry,   alfalfa,  citrus,  vegetables,  soybeans,  deciduous
fruits and nuts, and  other crops as  well as home use, garden and
ornamental  plants,   and   forests.     A  common  formulation  is
Methoxychlor with.Diazinon  (1:2 mix).

Four percent of the soil samples collected contained methoxychlor.
Concentrations ranged from 24 ppb - 12,000 ppb.  Methoxychlor was
identified  in  the low   lying  area   north  of  the landfill  and
northwest of the warehouse.
5.2.2  Ground Water

A total of 22 monitoring wells were installed at the Fairfax site
during the RI.   Thirteen wells were completed as shallow monitoring
wells and nine wells were completed as deep  monitoring wells.  All
wells were completed within the upper Eocene aquifer system.  The
installation and subsequent sampling of wells during Phase III of

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                                28

the RI corresponded with the third quarter sampling event of 1991
for the wells installed during Phase II-A.

Chlorinated pesticides  and volatile organics were  identified in
samples collected from on-site shallow monitoring wells.  One deep
well  (MW-3)  also  indicated  low levels  of  pesticides  in  ground
water.   Endosulfan  sulfate  was detected in MW-5; however,  the
quantity was  "j"  flagged.   Four metals were  detected in various
wells  at  concentrations   above  their  respective  MCLs  and  are
discussed below.

The City of Fairfax municipal well  (south well) was sampled during
Phases  II-A and  III of  the  field  investigation. Samples  were
collected  both  before  and  after  treatment by  a  chlorination
process. No Site-related contaminants were identified in any of the
samples collected  from the municipal well samples.  The north well
field, which is located approximately one mile north of the Site,
was not sampled.

5.2.2.1 Volatile Organics  in Groundwater

Groundwater samples collected throughout the RI have identified low
levels  of  various  fractions  of the volatile  compound list.   The
most commonly detected were acetone and carbon disulfide; however,
data validation  suggests  that these  and other minor constituents
are laboratory artifacts.   Other constituents identified include
benzene,    chlorobenzene,    chloroform,    1,2-dichloropropane,
ethylbenzene, methylene chloride, and xylene were identified.

Acetone

Acetone  was  identified  in  groundwater  samples   from all  site
monitoring wells except for  MW-1,  MW-10,  20,  21,  22,  23,  and 24.
Additionally,   acetone   was   identified   in  the   raw  (before
chlorination)  and  finished   (after  chlorination)  water  samples
collected from the Fairfax municipal well. As mentioned previously
acetone is considered to be a lab artifact.   Concentrations range
•from    3  ^ig/1  (ppb) -  150  p.g/1  (ppb)  identified  in  numerous
groundwater samples.

Carbon Disulfide

Groundwater samples  from all  site monitoring wells  except for MW-1
and  MW-3  identified varying  levels  of  carbon  disulfide.    The
untreated  city  water  was also positive  for carbon disulfide.
Concentrations  range from 3  ppb -  130  ppb.   Carbon disulfide was
only detected in eight samples collected during all  sampling events
subsequent to Phase II-A.  Many of the reported concentrations were
"j"  flagged  (estimated values).   In addition to  the Phase II-A
wells,  carbon disulfide was  identified in monitoring wells MW-18,
MW-20 and MW-22  installed  during Phase III of the RI.

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                                29

Methylene Chloride

Methylene chloride was detected in groundwater samples collected
from monitoring wells MW-1, MW-2, MW-4, MW-5,  MW-8, MW-10, MW-12,
MW-14, MW-19 and the  finished city  water during the investigation.
Concentrations range from  1  ppb -  7  ppb.  Once again,  many of the
reported concentrations were "j" flagged.

Benzene

Benzene was identified in groundwater samples collected from MW-12
during Phase II-A, the first quarterly sampling event under Phase
II-B, and the December sampling event.   Concentrations of benzene
varied  from 34 ppb  to  52  ppb  in  the three  respective  sampling
events.  Benzene was  detected in MW-4 during two sampling events at
concentrations  of 5  and  6  ppb.  During  Phase  III benzene  was
detected in MW-14 at 37 ppb.

Chlorobenzene

Chlorobenzene was detected in groundwater samples collected from
monitoring wells MW-4, MW-6,  MW-8, MW-12 and MW-14.  Concentrations
ranged from 2 ppb - 17 ppb.

Chloroform

The  finished water  sample  collected  from the  City  of  Fairfax
municipal water well  detected chloroform at 2 ppb.  This occurrence
probably results  from the  City's water chlorination process.   No
Chloroform was detected in the municipal well system during Phase
III sampling.

1,2-Dichloropropane

1,2-Dichloropropane  was   detected  in  samples   collected  from
monitoring wells MW-8, MW-12, and MW-14 in the quarterly sampling
events.  Concentrations range from 6 ppb to 28 ppb.

Ethylbenzene

Ethylbenzene  was detected  in  samples  collected  from monitoring
wells  MW-4,  MW-8, MW-12,  MW-14, MW-19,  MW-22, and MW-24 during
sampling events completed to date.  Concentrations  range from 2 ppb
- 190 ppb.

Xylene

Groundwater samples collected from monitoring wells MW-4, MW-6, MW-
8, MW-12, MW-14, MW-19, MW-22 and MW-24 exhibited elevated levels
of xylenes.  Concentrations  ranged from 5 ppb - 2000 ppb.
Monitoring well MW-4 contained  the highest concentration.

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                                30

5.2.2.2  Semi-Volatlies in Ground Water

Disulfoton was identified in monitoring wells MW-4 and MW-12 during
two of the  groundwater  sampling events.  Concentrations of 78 ppb
and 110 ppb were reported  in MW-4 while concentrations of 3 ppb and
4 ppb were reported for MW-12. Both of the concentration values for
MW-12  were  reported  as  estimated  concentrations   (i.e.,  *j"
flagged). Butyl phosphorotrithioate was identified in MW-15 during
Phase  III at  a concentration  of  49 ppb,  and was likewise "j"
flagged.


5.2.2.3  Pesticides in Groundwater

Monitoring well samples  indicate that elevated levels of pesticides
exist in  shallow groundwater.   Contaminants identified .appear to
consist primarily of toxaphene, DDT (and its  degradation products) ,
BHC (including  isomers)  and dieldrin. Those components comprising
a  less  significant fraction  of the  total  pesticides  identified
include aldrin,  chlordane (including isomers),  endrin and endrin
ketone, total endosulfans, and heptachlor and heptachlor epoxide.
Methoxychlor,  which  was   identified in  soil  samples,  was  not
identified in groundwater.

Toxaphene

Toxaphene    contamination  comprises   the   most   significant
concentrations of the pesticides fraction identified in groundwater
at the Site.  Toxaphene  was identified in groundwater samples from
monitoring wells MW-4, MW-6, MW-8, and MW-10 collected during the
Remedial Investigation.  Concentrations ranged in value  from 9.9 ppb
-  120.0  ppb.    The  laboratory did not  identify toxaphene  in
groundwater samples collected  during  the March 1991 sampling event;
however, toxaphene is believed to be present in MW-4, MW-6, and MW-
10.  Internal validation and assessment of chromatagrams indicates
the probable presence of  toxaphene in these wells-.'  Due to severe
matrix   interferences   in  these   samples,   however,   toxaphene
quantification  was not  possible.  The maximum  concentration of
toxaphene was detected  in MW-8.

The Maximum Contaminant Level (MCL)  for toxaphene in groundwater
were established at 3.0 ppb.

DDT, DDE, and DDD

DDT, DDE,  and  DDD were  detected in groundwater samples collected
from monitoring wells MW-4, MW-6,  MW-12, MW-14, and MW-22 during
the RI and ranged in value from 0.045 ppb to 2 ppb. An  MCL has not
been established for DDT,  or  its metabolites DDE  and DDD.

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                                31

BHC (Lindane)

Lindane  and  its  BHC  isomers  (alpha,  beta,  and  delta)  were
identified in groundwater samples collected from monitoring wells
MW-3,  MW-4, MW-6, MW-8, MW-10, MW-12, MW-14, MW-16, MW-18, MW-22,
and MW-24.  Concentrations of BHC range  from 0.024  ppb - 42.0 ppb.
The MCL for lindane has been established at 0.2 ppb.

Dieldrin

Dieldrin  was  identified  in  groundwater samples  from monitoring
wells  MW-4,  MW-6,  MW-8,  MW-10, MW-12,  and  MW-14 in  the first
quarterly  sampling  event.   Subsequent  quarterly  sampling events
identified dieldrin in monitoring wells MW-6,  MW-8, MW-10, MW-12,
MW-14, MW-16, MW-18, MW-22, and MW-24.  Concentrations range from
0.024 ppb .-5.5 ppb.

An MCL has not been established for dieldrin.

Aldrin

Aldrin  was   detected  in  groundwater   samples  collected  from
monitoring wells MW-4, MW-6, MW-8,  and MW-12.   Values ranged from
0.22 ppb - 7.9 ppb.   The maximum concentration was  detected in MW-
4.

An MCL has not been established for aldrin.

Chlordane

Chlordane  (alpha and  gamma isomers) was identified in groundwater
samples collected from monitoring wells  MW-4 and MW-12.  Chlordane
was detected  in MW-4  during  the Phase II-A  sampling events at 1.2
ppb. Chlordane was identified in MW-12 during  Phase II-A,  and both
Phase II-B sampling events at concentrations ranging  from  0.31 ppb
- 1.3 ppb. The MCL established for Chlordane  is 2.0 ppb.

Total EndoBulfans

Endosulfans were detected in monitoring  wells  MW-4  and MW-6 during
the  Phase  II-A  at  concentrations  of  1.8  ppb  and  .021  ppb
respectively.   Phase III groundwater sampling indicated  elevated
concentrations of endosulfans from monitoring wells MW-2, MW-5, MW-
14, and MW-24.  Concentrations ranged from  0.054 ppb to 0.62 ppb.

Endrin

Endrin and endrin ketone were identified  in  groundwater  samples
collected from monitoring wells MW-4, MW-6, MW-8, MW-10, MW-12, MW-
18, MW-22, and MW-24.  Concentrations  ranged from 0.3 ppb - 2.1 ppb
for endrin, and from 0.064 ppb - 18 ppb for endrin ketone.   The MCL
for endrin is 2.0 ppb.

-------
                                32

Heptachlor

Heptachlor and  heptachlor epoxide were  identified  in monitoring
wells MW-6 and MW-12. The concentrations identified were 0.12 ppb
for heptachlor and  0.57  ppb for heptachlor epoxide.   Groundwater
samples  collected  during  Phase III  of  the  RI  did  not  show
detectable quantities of heptachlor or heptachlor epoxide.

MCLs have been established at 0.4 ppb and 0.2 ppb,  respectively.


5.2.2.4  Metals in Groundwater

The metals analyses conducted during the  Phase II-A sampling event
did not provide  conclusive  evidence that metals contamination of
ground waters was a result of releases  from the  Site.  Most metals
in  groundwater  were  detected at concentrations below  detection
limits  or at  levels  comparable  to  background  concentrations.
During subsequent  Phase II-B and Phase  III  groundwater sampling
events beryllium,  chromium,  cadmium,  and lead were  detected in
samples at levels which exceeded their respective MCLs.

Beryllium

Beryllium was identified in monitoring  wells MW-4, MW-8, and MW-20
at concentrations of 6 ppb,  9 ppb, and  5  ppb respectively. The MCL
for  beryllium   is  4   ppb.   The  detection   of   beryllium  at
concentrations above MCLs was a one  time  occurrence in each of the
wells; therefore its presence does not appear to be significant.

Chromium

The presence of  chromium was detected in monitoring wells MW-4, MW-
6, MW-20, MW-23, and MW-24 at levels which exceeded the MCL of 100
ppb.  The maximum  concentration reported  was  415  ppb  which was
detected in MW-20.

Cadmium

Cadmium was identified  in MW-20  during both the September/October
1991 and December 1991  sampling  at a concentration of 10 ppb. The
MCL for cadmium  is  5 ppb.

Lead

Lead  was detected  above the action level of  15  ppb in samples
collected  from  monitoring wells MW-12,  MW-20,  MW-23, and MW-26.
Lead was most frequently identified  above  the action  level in MW-
12.

-------
                                33
Table 5
T.W. 4-22
Peiticidet (SurUc* W«ter/Sedimcm
Prw«« U-A/Tl-B. Ill ;
PARAMETER
alpha - BHC

beta - BHC

gamma • BHC

delta • BHC

Aldrin

Dioldfin

4.4' ODD

4,4' DOT

4.4- DOE
.
Endrin Ketona

Heptachlor

Toxaphena
Gamma '
Chlordine
Alpha
Chlordano
Endrin

MATRIX
Surface Water
Sediment
Surface Water
Sediment
Surface Water
Sediment
Surface Water
Sediment
Surface Water
Sediment
Surface Water
Sediment
Surface Water
Sediment
Surface Water
Sediment
Surface Water
Sediment •'--
Surface Watar
Sediment
Surface Water
Sediment
Surface Water
Sediment
Surface Water
Sediment
Surface Water
Sediment
Surface Water
Sediment
NUMBER OF
SAMPLES
2 .
10
2
to
2
10
2
10
2
1C
2
10
2
to
2
10
2
10
2
10
2
10
2
10
.2
10
2
10
2
10
'NUMBER OF
HfTS
0
2
2
3
0
2
1
0
0
1
2
1
2
9
1
7
0
8
2
0
0
2
1
2
0
2
0
1
0
1
RANGEIppbl
: —
0.1-60
0.57-1.2
0.1-500
—
0.1-67
—
—
—
—
0. 45-6.2
—
0.045-0.23
18-3400
—
S.7'5700
—
9.8-280
0.35-1.4
—
—
2.1-25
78-42000
18-300.7
—
—
-
MEAN(ppb)
—
30.5
1
171.7
—
33.6
0.28
—
—
990
3.5
3200
0.2
437
1.2__
862.9
—
80
1
—
—
13.6
NOT
QUANTIFIED
21039
459.4
443
—
1.6

-------
                                34

5.2.3  Surface Water and Sediments

Sediments in the wetland areas located in the northern portion of
the Site were found to be contaminated with semivolatile chemicals
and pesticides.   Table 5  summarizes the findings of  the  RI with
respect to contaminated sediments.   There are no chemical-specific
ARARs for sediments, but the levels of contamination found in the
RI exceed concentrations that have been shown through toxicological
research  to  have  an adverse impact to aquatic  life due  to toxic
effects of these contaminants.   This research is summarized in the
National  Oceanographic  and  Atmospheric  Administration  (NOAA)
publication .entitled  The   Potential  for  Biological  Effects  of
Sediment-Sorbed Contaminants  Tested in  the  National Status  and
Trends Program, NOAA Technical Memorandum NOS OMA 52, August, 1991.
The pattern  and distribution  of  contamination in  the  sediments
indicate that the primary source of contamination is the landfill
that was placed partially in the jurisdictional wetlands.  Sediment
contamination  also extends  into  off-site  drainage pathways  for
surface waters.  The sediment contamination found in both on-site
and off-site locations poses an unacceptable risk to environmental
receptors.

On-site surface waters were found  to  have  been contaminated with
pesticides at  levels  which exceed  Ambient  Water Quality Criteria
(AWQC) for the protection of aquatic life.  Federal AWQC have been
established under  the  authority of  Section 303 of the Clean Water
Act  for the  purpose  of  establishing  protective guidelines  for
ambient water quality.  AWQC as developed by EPA are identified in
Section 121 of CERCLA as amended by SARA as  chemical-specific ARARs
for NPL  sites.  In  addition,  the  AWQC have been adopted by the
State of South Carolina as ambient surface water  quality standards,
and are therefore ARARs for the Site.   Table 5 also summarizes the
findings of the RI with respect to  surface water contamination at
the  Helena  Chemical  Site.    The surface  water  contamination
identified as  part of the  RI  also  poses an  unacceptable risk to
environmental  receptors  in the  on-site  wetland  areas   and  in
drainage pathways  leading off-site.


6.0  SUMMARY OF SITE RISKS

A  Baseline Risk Assessment was conducted to  evaluate  the risks
presented by the Helena Chemical Superfund Site to human health and
the  environment,  under present day conditions  and  under  assumed
future use conditions.  Currently,  there are no residents living on
the  Site and  only a  few  residents residing close to  the Site.
There are no potable water  supply wells on the Site,  although there
is a municipal water supply well located less than  one-quarter mile
away.  Information gathered from census data regarding population
trends  in Allendale  County and surrounding areas  suggests that
future land use will remain commercial and  industrial, with little
potential  for residential  use  of  groundwater  as  a  potable water

-------
                                35

source.    The  Site  was  evaluated,  however,  under  residential
exposure scenarios, including exposure pathways involving the use
of shallow ground water as  a  potable water supply source.   These
exposure scenarios correspond to potential future use of the Site
for residential development.

Under the current land use scenario,  potential human receptors at
the Site include residents in the vicinity of the Site who may be
occasional Site trespassers, and workers  on the Site.  The Site is
surrounded by residential, agricultural and light industrial areas.
Beyond these areas immediately surrounding the Site (including the
City of  Fairfax) ,  the local  area  is  not  densely  populated,  and
consists primarily  of agricultural land and forests.   The most
likely  potential  human  receptors  under  the current  land  use
scenario  are workers  and  occasional  trespassers.   No  private
drinking water wells were identified either on-Site or immediately
downgradeent from the Site,  and no users of surface  water  for
potable water supplies were  identified downgradient from the Site.
Under current land use, the Reasonable Maximum Exposure (RME)  is
represented by the individual  worker or Site  trespasser who may be
exposed by direct contact and  incidental  ingestion of surface soil
and stream sediments.

Potential  environmental  receptors  under  the  current  land  use
scenario  include  the  plants  and animals  at  the  Site.    Site
features, including the small  unnamed stream and wetlands adjacent
to the Site, and nearby  wooded areas and  open  fields,  provide a
variety  of  habitats.   No unique or critical habitats  have been
identified at the Site, and no vegetative stress is evident based
upon  site visits  by  regulatory personnel.    No threatened  or
endangered species have been  observed at the Site or in adjacent
areas.

Future land  use  for  the Site  was considered to include potential
development  of the area as  residential property.   This potential
land use scenario  is considered to be  that which would result in
the greatest degree of risk  to human health should the Site remain
unremediated.  The RME under a residential  land  use scenario is
assumed to be an adult person  or child living on the Site property
and drinking potable water  obtained from  a  private  well drilled
into the Barnwell Formation.  Under the  future land use scenario,
environmental  receptors  would  likely be more  limited than  at
present,  since residential development of the property would in all
likelihood  involve the elimination of  the  wetland  and forested
areas on and adjacent to the Site.

EPA has  determined that the elevated levels of pesticides  in the
soils and  ground waters at the Site  pose the primary  hazard to
human health at  the Site.   In addition,  the  elevated  levels of
pesticides in the sediments  and soils located in the wetland areas
adjacent  to  and  downstream  of  the  Site  pose  a  hazard  to
environmental receptors inhabiting those areas.  Primary exposure

-------
                                36

pathways  for  humans  are  incidental   dermal  contact  with  and
ingestion  of contaminated  soils,  and  ingestion  of contaminated
ground water.   Air transport of  particulate matter contaminated
with Site-related constituents of concern is not considered to be
a significant risk to human health because the contaminated soils
are generally in vegetated areas and  the most heavily contaminated
soils have been removed prior to  this time.  Air sampling results
conducted during the Remedial Investigation indicated that airborne
contamination  was not  present  above  levels  that  would pose  a
significant  risk to human health.

EPA has established  in  the National  Oil and Hazardous Substances
Pollution Contingency Plan  (NCP), 40 CFR Part 300, a range of 1 X
10"4  to  1   X  10"6  as  acceptable   limits   for  excess  lifetime
carcinogenic risks.   Excess risk within  EPA's acceptable limits
means that  any individuals exposed  to  Site  conditions  under the
assumed exposure scenarios will  run a one in ten thousand  (1 X 10"*)
to a one in  one  million (1 X 10~6) increased chance of developing
cancer.   Under  the  "No  Action"  scenario,   (assuming  the Helena
Chemical Site is left  as it is now) the estimated carcinogenic risk
for current  land use is 8.0 X  10"5.   The  estimated excess cancer
risk calculated  for the future  land  use scenarios at  the Site is
2.6 X 10"*.  These calculated risks for the future land use scenario
exceed the acceptable risk levels established by EPA and are based
on the assumption that  no cleanup activities will have occurred.

EPA has also established acceptable exposure limits based upon non-
carcinogenic health effects. A  Hazard Index  (HI) of 1.0 or greater
has been established by EPA as the criterion  defining unacceptable
levels of exposure for non-carcinogenic health effects.  The HI is
the ratio  of exposure  levels  resulting from  site conditions to
acceptable exposure levels (ie., exposure  levels that result in no
adverse health affects)  for any  given contaminant.  The HI for
potential  non-carcinogenic  effects  under  the current  land  use
exposure  scenario  is  0.3.    The  associated Hazard  Index  for
non-carcinogenic  effects  under  the  future  land use  exposure
scenario is  8.6.

Actual  or  threatened releases  of hazardous  substances  from this
Site, if not addressed  by the preferred alternative or one of the
other  active  measures  considered,   may   present  a  current  or
potential  future threat  to the  public health,  welfare,  or the
environment.
6.1  CONTAMINANTS OF CONCERN

Numerous chemical contaminants were identified in site media during
RI Phases  II-A,  II-B,  and  III.  Tables 6, 7, 8, 9, and 10 provide
a summary of those contaminants which were evaluated  or considered
for  evaluation during the Baseline  Risk Assessment  process.   In
Tables 6-10 the term "hit"  or  "hits"  refers to positive results  of

-------
Table 6
                                37
TO&njtf : ;•:'.:.
Summary of SoiPe«t>cki« Concentration*
HCFSCShe :•;
Parameter
Aldrin
alpha-BHC
beta-BHC
delta-BHC

gamma-BHC
4,4'-DDT
4,4'-DOE
4,4'-DDD
Oieldrin
Endoeulfan II
Endosulfan
Sulfate
Endrin
Endrin Ketona
SolCUaa
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Number: of.
Sample*;
261
162
261
152
261
152
261
152
261
152
261
152
261
152
261
152
261
152
261
152
261
152
261
152
261
152
Number of Hit*
35
6
32
6
52
15
22
4
19
4
124
41
66
31
72
22
79
21
13
4
33
16
26
11
35
12
• ' .
.. Range
(Ppb)
1 .2 - 800000
1.4-810O
2.1 - 390000
4.4- 1800
4.9 - 270000
4.9 - 6200
4.1 -210000
5- 1500
4.2 - 220000
5-67
5.1 - 2800000
8.5 - 220000
0.74- 21000
4.5- 15000
2.3 - 750000
4.0 - 600OO
3.7 - 960OO
4.6-44OOO
23 - 7100
23-7100
2.1 - 22000
2.6 - 22000
5.8- 1600
9.1 - 1600
2.1 - 9200
5.3 - 1200
Mean (ppbj
27100
1690
12300
530
9900
750
19000
380
11700
34
31000
19200
1100
910
16800
6 400
3500
2700
660
1820
1040
1920
390
650
530
220

-------
Table 6  (continued)
                                38
TabU
Summary of Sol Pee
HCFSI
Parameter
Heptachlor
Heptachlor
Epoxida
Methoxychlor
Toxaphene
alpha-Chlordana
gamma-
Chlordane
Sol CUM
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Number of
Sample*
261
152
261
152
261
152
261
152
261
152
261
152
7-1
:Sha
Number of Htt»
11
3
9
4
10
6
62
22
4
1
6
4

Range
(ppbl
6.1 - 68000
19-35
2.4 - 29
6-29
24- 12000
24- 12000
78 • 2700000
78 - 350000
15-9600
—
16- 14000
16-66
Mean (ppb)
9300
26
15
20
2050
3300
66000
43300
2500
15
2600
39

-------
                                             39
Table  7
Table 7-2
Summary of Soil Semivolatile Concentrations
HCFSC Site
Parameter || Soil Class
Disulfoton0
Tributylphoshoro-
trithioate"
Chlorobenzilate"
Total
Surface
Total
Surface
Total
Surface
Number
of
Samples
261
152
261
152
261
152
Number of
Hits
12
1
3
0
0
0
Range ~
60-
430000
—
750-
7900
—
—
—
Mean
(ppb)
59400
97
3200
—
—
—
  Notes: Only  disulfoton  of the  semivolatile SAS  compounds  (originally Tentatively  Identified
         Compounds) were detected in site surface soils.

  a      One disulfoton sulfone hit (51 ppb) was identified during Phase II-A. This hit occurred as a
         Tentatively  Identified Compound with estimated ("J" flag) concentration.  This hit was not
         used to compute the average disulfoton concentration.
         Compound identified in a limited area in immediate vicinity of landfill.

-------
Table 8
                               40
Table 7-3
Summary of Sol VolatB** Concentration*
HCFSCSH* ••:•'• :'y-.-- •- • . Y".;:;-'. : ^ • Y':r:: ;v': :vl
Parameter
Benzene
Chloroform

Ethylbenzera
Methylene Chloride
Toluene
Acetone
2-Butanone
Xylenes
Carbon Disulfide
Trichtoroethytene
Styrene
1 ,2-Oichloroethene
Tetrachloroethene
1 ,2-Oichloropropana
Chlorobenzene
Sof«le*»
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Total
Surface
Number of Sample**
210
151
210
151
210
151
210
151
210
151
210
151
210
151
210
151
210
151
210
151
210
151
210
151
210
151
210
151
210
151
Numb«rofHttr
6
0
5
2
7
0
80
39
17
4
119
69
31
13
9
1
4
3
2
0
2
O
2
1
2
2
2
0
4
0
Rang*
3- 1300
—
1-11
2-11
3-410O
— '
2- 140
2 - 140
1 - 120
1 -89
2- 13000
2- 13000
1 -36
3 -32
3 - 27000
—
12-48
19-48
24-210
__
—
—
2- 12
—
1 1 - 240
1 1 - 240
15-75
_
5 -9000
—
MeaMppbl
223
—
4
7
1260
—
20
30
32
35
320
600
12
13
4250
3
30
35
117
—
2
—
7
12
130
130
45
—
2300
—

-------
Table 9
                                41
Ta«a7-4 ' '.:':-- ;• • •• ;:;/.
Summary of Groundwater Contaminants .: . ...••,.- .\x/.
	 HCfscstu • ---'pf:1'-' '-* -f--0.:-:*€:
Parameter,:
Aldrin
alpha-BHC
beta-BHC
dulta-BHC
gamma-BHC
4,4'-DDT
4,4'-DDD
4,4'-DDE
Oieldrin
Endosulfen II
Toxaphene*
Endrin
Endrin Ketona
CRQL
0.05
0.05
0.05
0.05
0.05
0.1
0.1
0.1
0.1
0.1
1.0
0.1
0.1
Sampling Data
October 91
December 9 1
October 91
December 91
October 91
December 91
October 91
December 91
October 91
December 91
October 9 1
December 91
October 9 1
December 91
October 9 1
December 91
October 91
December 91
October 91
December 91
October 91
December 91
October 91
December 9 1
October 91
December 9 1
Number
oJHrU
2
2
9
8
8
7
7
5
7
6
1
1
3
1
2
0
9
7
1
0
0
1
0
1
7
6
Rang* (ppb)
at Hit*
0.88 - 2.3
0.66-1.2
O,1 T - 18
0.17-31
0.26-26
0/19 -26
O.O24 - 5.7
O.O94*1.2
0,1 Z- 6.6
O.23 - 2.2
«_.
—
O.O45-0.66
_
O.O51 - 2.0
. <_-.
O.O24-3.4
Q.23 - 6.5
—
_
_
_
__
—
0.064-18
O.17-11
Mean
(ppb»
otHrtt
1.59
0.93
2.78
6.72
5.42
4.70
1.25
0.62
1.47
0.91
0.45
1.2
0.26
2.10
1.03
_
0.99
2.70
0.62
__
—
36.O
	
0.3
6.15
4.15








' •'•
35%Upp«r:;:
Confidence
UmftMaan 1
IppW :
0.266
3.44
3.74
1.06
0.69
0.175
0.24
0.21
1.11
0.13
8.29
0.081
2.98

-------
Table  9  (continued)
                                                     42
Table 7-* " . \ •".'' '"' f'
Summary of -Groundwatar Contaminants
HCFSCSh.
Parameter
Endosulfan Sulfata
Benzene
Disulfoton
TBPT
Chromium
Lead
CRQL
0.1
5.0
5
10


Sampling Oat*
October 91
December 9 1
October 91
December 91
October 91
December 9 1
October 91
December 91
October 91
December 91
October 91
December 91
Number
ofHfta
3
0
2
1
0
2
0
1
21
14
24
16
Range (ppb)
of Hits
0,064-0,12
—
6-37
—
—
3- 11O
__
—
3.3 -416
tO.O • 298
0.7 -4A
1.0-38.2
Mean
tppbj
of Hit*
0.08
—
21
35
—
57
—
49
62.4
51.9
8.0
10.8

•

95% Upper*
Confidence.:.;.
Limit Mean
'•':•• 
-------
Table 10
                               43
Table 7-6
Pe*tWde» (Surface Witar /Sediment)
Phue II-A, (I-B, m

PARAMETER
Alpha - BHC


beta- BHC


gamma - BHC


delta • BHC


Aldrin


Dialdrin


4,4' ODD


4,4' ODT


4,4* DOE

£ndrin Ketane


Heptachlor


Toxaphene



-------
                                44

analyses.   Many  of  the  contaminants  identified  during the  RI
occurred  at  low  frequency  and/or  in  very  low  concentrations
relative to the practical quantification limit for each compound.

The selection of contaminants that  would be fully evaluated during
the Baseline Risk Assessment in order to quantify Site risks were
selected in accordance with guidance as contained in the document
Risk Assessment  Guidance  for Superfund  (RAGS),  EPA/540/1-89/002,
12/89.  The selection process included the following criteria:  (1)
the chemical has demonstrated significant toxicity to animal life
in  published  reports,   (2)  USEPA  health-based numbers  can  be
obtained   for  the   chemical,   (3)   whether   its  occurrence  is
significant,  based   on  frequency,  concentration  and  exposure
potential,  in  regard to the total  risk posed by the  Site.   The
rationale used for selection of  the evaluated contaminants and for
eliminating the  other contaminants is  provided  in  the. following
discussions.

The  selected  contaminants  of   concern  for  the  baseline  risk
assessment  are shown in  Table  4.   Pesticides  were  the  primary
hazardous contaminants detected.  In addition, a limited number of
semi-volatile, volatile, and inorganic parameters were identified
and will be carried through the baseline risk assessment process as
explained below.  Only Contract  Laboratory Program (CLP) data were
used for the evaluation  of baseline risk at the Helena Chemical NPL
Site.

In soils, DDT  (plus DDE and DDD) , BHC  (all isomers) , toxaphene and
dieldrin were the most frequently detected and  generally were found
in the higher  concentrations.  Aldrin,  endosulfan sulfate, endrin
and  endrin  ketone  were   the   next  most   frequently  detected
pesticides.      Endosulfan,   heptachlor,   heptachlor   epoxide,
methoxychlor,  and  chlordane were  the  least  frequently detected.
Disulfoton   and    tributylphosphoro-trithioate    (TBPT,
butylphosphorotrithioate) were also detected infrequently,  but were
nonetheless evaluated as part of the BRA.  Due  to the low frequency
of detection and the  relatively low concentrations of heptachlor,
heptachlor  epoxide and  chlordane   (both  isomers)  found  in site
soils, these compounds were not  evaluated as part of the BRA as it
was determined that they would not  contribute  significantly to the
overall risk posed by the site.  This approach is consistent with
the process for eliminating compounds from further consideration as
outlined  in RAGS.   Endosulfan  sulfate  and endrin  ketone  are not
listed  in EPA databases  which  contain  Agency  reviewed toxicity
data, and  as a result the reference doses (RfD's) of their parent
compounds   {endosulfan  and  endrin,  respectively)   were  used  to
compute the risk posed by these compounds. This procedure provided
a conservative estimate of risk  (or hazard index).

A  large  number  of  inorganic  parameters were  detected  in soil
samples.     No  inorganic  contamination  associated  with  site
activities  was  found,  however,  in  soils at  a  frequency and/or

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                                45

concentration sufficient to warrant consideration as a contaminant
of concern.

Site-related  contamination was  identified  in the  surface water
samples  gathered during  the  RI.    An evaluation  of  this  data
indicates  that  pesticides  are the  only  hazardous  substances
detected at significant concentration and  frequency  in this medium
to warrant further consideration.  Due to the intermittent nature
of the  surface water  on-site,  this medium was not  considered a
significant pathway for direct human exposure.

In groundwater, aldrin, BHC  (all isomers),  DDT (plus DDE & DDD),
dieldrin,  and  endrin ketone  were  detected  in  the  highest
concentration  or frequency,  and  represent  the contaminants  of
concern  from   the   groundwater perspective.     Other  detected
chlorinated pesticide  compounds included endosulfan  II,  endrin,
toxaphene,  endosulfan  sulfate,  and heptachlor epoxide.   With the
exception  of  heptachlor  epoxide,  these  compounds  were  also
evaluated  in   the  Baseline  Risk  Assessment  (BRA).   Heptachlor
epoxide was detected in one groundwater sample during Phase II-A.
It has  not been detected  in any  other sample  during subsequent
groundwater sampling events.  As a result, heptachlor epoxide was
not  considered  a  contaminant  of  concern  for  the  groundwater
pathway. Heptachlor epoxide was  therefore not evaluated as part of
the BRA process.  TBPT was  also detected in one groundwater sample
during the  3rd Quarter  1991 groundwater sampling event.  Disulfoton
was detected in two groundwater  samples from the 4th Quarter 1991
sampling event  and  was evaluated  as a contaminant  of concern in
groundwater.   Benzene, lead,  and  chromium were  also detected in
groundwater samples.  The  frequency of  detection and concentration
for these  parameters was generally higher than for the pesticide
compounds  and   they   were  evaluated  due  to  their  potential
contributions to overall risk  (or  hazard index).

Carbon disulfide was not consistently  detected between RI phases.
As a result, carbon disulfide results were  attributed to laboratory
artifacts,   and  were  not  evaluated  further.   Although  bis{2-
ethylhexyl)phthalate  (BEHP),  acetone,  methylene  chloride,  and 2-
butanone were identified in a  significant number of samples,  they
were not evaluated as contaminants  of concern.  These compounds are
common  exogenous contaminants  attributable to  sampling methods
and/or  laboratory  artifacts,   and  are  not related  to  current or
former site operations.

Numerous polynuclear  aromatic  hydrocarbons  (PAHs)  and phenolic
compounds  were  identified  in soil  and  groundwater during RI Phase
II-A.   These  compounds were  detected at low  frequencies  and at
concentrations  at or near  their  respective practical quantitation
limits.  Subsequent to Phase II-A,  the semi-volatile contaminants
of concern were limited to  tentatively identified compounds (TICs)
identified during Phase II-A.  The  TICs were  disulfoton, TBPT, and
chlorobenzilate.  As a result, the BRA focused on the TICs and

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                                                      46
Figure  5
                                                       flour* 7.3
                                         Equation* for Calculating Oral and Dermal
                                              ^Chronic .Expoaur* LavaU from .
                                                    HCFSC Site Sole
                                       Future She R**iderrt» and Currant She Worker*
       FUTURE SITE RESIDENTS
       SOIL INGESTION PATHWAY

       Age-adjusted Ingestion Factor (IF_M,)

       'F—u.* Img-yr/kg-day) = IR_,.	,j x ED..
                                         BW..
                                                           ° _•!»>•
       where:
                       age-adjusted soil ingestion factor (mg-yr/kg-day)
                       average body weight from ages 1-6 (kg)
                       average body weight from ages 7-31 (kg)
                       exposure duration during ages 1-6 (yr)
                       exposure duration during ages 7-31  (yr)
                       ingestion rate of soil age 1 -6 (mg/day)
                       ingestion rate of soil age 7-31 (mg/day)
                       age-adjusted ingestion factor (mg-yr/kg-day)
                                                                            Default Values

                                                                            109 mg-yr/kg-day
                                                                            16 kg
                                                                            70kg
                                                                            6 years
                                                                            24 years
                                                                            200 mg/day
                                                                            100 mg/day
                                                                            109 mg-yr/kg-day
       DERMAL CONTACT PATHWAY
       Age-adjusted Contact Factor (CF_, ^,)
      i (mg-yr/kg-day)
         BW..,,,
                                  .,^ x AF x ED.,..
       where:
       AF
                age-adjusted contact factor (mg-yr-event/kg-day)
                skin surface area available for contact (cm'/event)
                skin surface area available for contact (cm'/event)
                soil to tkin adherence factor (mg/cm2)
                exposure duration during age 1-6 (yr)
                exposure duration during age 7-31 (yr)
3400 mg-yr-event/kg-day
2430 cm'/event
2300 cm'/event
2 mg/cm1
6yr
24 yr
       COMBINED DAILY ABSORBED DOSE
Non-Careinogena
Daily Absorbed Dose «=
 (I
                                        ((CF^ ,^xC.x10^g/mg x EF, x
Carcinogena
Daily Absorbed Doee =
((IF— /-ixC.x10-
-------
                                                    47
Figure  5  (continued)
                                      ' Equation* :for Catenating Oral and Dsvmai -•
                                             Crronic Exposure Lmvi* from : •':.-'•'"•" -''-,'•
                                                  HCFSCSteSo**:   :   -;  : ;
                                     Future SHe Residents end Current She Workers
      where:

      C.
      EF,
      ATMC
      ATC
      ABS'
Chemical concentration in soil
Residential exposure frequency
Averaging time (non-carcinogen)
Averaging time (carcinogen)
Absorption factor (unitless)
                                                                         Default Values

                                                                         chemical-specific
                                                                         350 days/year
                                                                         10,950 days
                                                                         25.550 days
                                                                         0.01
      CURRENT SITE WORKERS
      COMBINED SOIL INGESTION AND DERMAL CONTACT PATHWAYS DAILY ABSORBED DOSE
      Non-Carcinogens
      Combined Chronic Absorbed Dose =
      (OR-.—., x C, x 10" kg/mg x EFW x EDJrtBW. x
      ((C. x 10* kg/mg x ABS x AF x SAW x EF. x EDJ/IBW. x A

      Carcinogens
      Combined Chronic Absorbed Dose =
                 C. x 10-* kg/mg x EF. x EDJ/1BW. x ATC.^,J)
      (1C. x 10* kg/mg x ABS x AF x SAW x EF, x EDJ/IBW. x ATt _ .))
      where:
ED.
BW,
AT«..
ATC_
ABS
AF
SA.
                     Worker toil inflection rate (mg/day)
                     Soil contaminant concentration (mg/kg)
                     Worker exposure frequency (days/year)
                     Worker exposure duration (years)
                     Worker body weight (kg)
                     Worker averaging time-non-carcinogen (days)
                     Worker averaging time-carcinogen (days)
                     Absorption factor (unitiess)
                     Soil to skin adherence factor (mg/cm1)
                     Skin surface area available for contact (ccrf/event)
                                                           Default Values

                                                           100 mg/day
                                                           Chemical-specific
                                                           250 days/year
                                                           30 years
                                                           70kg
                                                           10,950 days
                                                           25,550 days
                                                           0.01 ••
                                                           2 mg/cm2
                                                           2300 cm'/event

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                                                 48

Figure  6
                                 Equations For Calcualtion Of Chronic Exposure
                                       :., For The Groundwater Pathway*  :
       FUTURE SITE RESIDENTS

       Non-Carcinogenic

       Chronic Absorbed Dose from Groundwater  =

                                       Cw x IR^ x EF x ED/IBW x ATNC)



       Carcinogenic

       Chronic Absorbed Dose from Groundwater  =

                                        Cw x IRw.tl, x EF x ED/(BW x ATC)


       Where:                                                        Default Values

       C_           Groundwater contaminant concentration (mg/liter)         Chemical-specific
       IR,.W        Groundwater ingestion rate (1 /day)                     2 liter/day
       EF           Groundwater exposure frequency (days/year)             350 days/year
       ED           Residential exposure duration (years)                   30 years
       BW          Body weight (kg)                                   70 kg. \                 —
       ATNC         Averaging time for non-carcinogens (days)              30 years x 365 d/yr = 10,950 days
       ATC	Averaging time for carcinogens (days)	70 years x 365 d/yr = 2S,5SO days


       a - Default exposure assumptions value* referenced from USEPA, RAGS, 12/89 and OSWER Directive #9285.6-03.

       Note:   Assume absorbed dose to equivalent to intake/ingested dose.

               Cancer Risk =  Carcinogenic Chronic Absorbed Dose x Slope Factor

               Hazard Index = Non-Carcinogenic Chronic Absorbed Dose/RfD

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                                49

eliminated PAHs and phenolic compounds from further considerationon
the basis of low detection frequency and low concentration.


6.2  EXPOSURE ASSESSMENT

Contaminated media at the Site include surface and subsurface soil;
shallow groundwater;  and surface water and sediments in on-Site and
adjacent wetlands.   Pathways  involving air as  a medium were not
considered due to the extensive grass and vegetative cover at the
Site, and  the  lack  of  positive  results from air  monitoring for
Site-specific contaminants.

Populations that could potentially  be exposed to Site contaminants
under  current  exposure   conditions  are  on-Site  workers  and
occasional  trespassers.    Potential  future  land  use  exposure
scenarios include child and adult residents living on the Site, and
children and adults living  near the Site who might visit or play on
the Site.

Based on these potential receptors,  three general exposure pathways
were selected for numerical risk quantification:

1.   Current exposure of  adult  non-residents   (Site workers and
     trespassers)  to   contaminants   in  surface  soils  through
     incidental ingestion and dermal contact.

2.   Future  exposure  of  on-site  adult and  child residents  to
     contaminants in  shallow soils through incidental ingestion and
     dermal contact.

3.   Future  exposure  of   onsite  adult  and child residents  to
     contaminants in groundwater through ingestion.

In order  to quantify the  exposure associated with each pathway,
various standard procedures were used to determine key variables in
the exposure calculations.  These variables include  the contaminant
level in  the medium,  usually  referred to as the  exposure point
concentration;  and the amount  of the  chemical taken  into the body,
or chronic daily intake, which must be calculated using a number of
assumptions.   Since  EPA policy  is  that  exposure  estimates must
approximate a Reasonable Maximum Exposure (RME)   scenario, each of
the variables was selected with the  goal of producing the maximum
exposure that could reasonably be expected to occur. Tables  13 and
14 present  the exposure point concentrations calculated for the
contaminants of  concern in soils and  ground water.  It  should be
noted that the mean concentrations for each contaminant detected in
the  "hot spots" were used as the exposure point  concentrations in
the RME evaluation.

Calculation  of  average daily  intake requires  input  of numerous
exposure parameters which are  usually applicable to a particular

-------
                                                      50
Table  11
' % '- •,"••*"*& -"f^^'i ' v.-TaH«7-13 J*i<>'-- '
Groundwatar Contaminant Lavvta 
-------
Table   12
                                                      51
                         f                  ,- ^ s.-'.  s~rt'
                                    Sol Contaminant Laval* (mg/kg) Yielding 1O*to 1C*
                      vUppcr Bound Risk tavsb f or Fuuvv R«uiinit Expovur* Scwiwio* vt th« HCFSC Srta
                                              Potential Futu-* Site R*«U*nt
                                                 Curcnt Upper
                                                Bound K«k Level
    Notes:   No compound presented a hazard index in excess of 1; a linear relationship exists batween soil concentration and
             associated risk levels, therefore the cleanup objectives for each  risk level may be computed by determining the
             following:

             X (Soil Cleanup Goal) = Risk Level Goal x Current Soil Concentration/Current Rick Level

    NA      No Slope Factor for the compound.

    —       Current contaminant levels in soil do not present a risk in excess of the respective risk levels.

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                                52

exposure  pathway.    The  exposure  parameters  used  for  soils
aresummarized  in  Figure  5.   The same parameters for ground-water
exposure are shown on Figure 6.

The result of the exposure assessment is  a set of tables showing a
calculated  average  daily  intake   value for   each  chemical  or
compound, as well as a  summary value  for each  exposure pathway.
Tables 13 and  14  contain these data and summaries.
6.3  TOXICITY ASSESSMENT

In this portion of the Baseline Risk Assessment, the toxic effects
of  contaminants  were  investigated and  evaluated.   The  critical
variables needed to calculate estimates  of risk were obtained from
the  EPA toxicological databases.   Critical toxicity  values  for
Helena Chemical Site contaminants are presented in Table 15.

Slope  factors  (SFs)  have been  developed  by  EPA's  Carcinogenic
Assessment Group  for  estimating lifetime cancer risks associated
with exposure to potentiall carcinogenic contaminants of concern.
SFs, which are expressed  in terms of (mg/kg-day)"1, are multiplied
by  the estimated  intake  of a  potential carcinogen in  order  to
provide an upper-bound extimate of the excess lifetime cancer risk
associated with  exposure  at that intake level.   The term "upper
bound" reflects the conservative estimate of the risks calculated
from the SF.  Use of  this approach makes under-estimation of the
actual cancer risk highly  unlikely.  Slope factors  are derived from
the  results  of human  epidemiological  studies or  chronic animal
bioassays;   if    animal   bioassays  are  used,   animal-to-human
extrapolation and uncertainty  factors are applied to account for
the use of animal  data to predict effects on humans.  The SFs for
the carcinogenic contaminants of concern are contained in Table 15.

Reference  doses   (RfDs)  have been developed by  EPA for  use  in
indicating the potential  for adverse health effects from exposure
to  contaminants  exhibiting  noncarcinogenic  effects.   RfDs, which
are  expressed  in  units of  mg/kg-day,  are  estimates  of  lifetime
daily  exposure levels  for humans, including sensitive individuals
or  subpopulations.  Estimates intakes  of contaminants of concern
ingested from environmental media can be  compared to the RfD.  RfDs
are derived from human epidemiological studies or animal studies to
which uncertainty  factors have been applied,  to account for the use
of  animal  data to predict  effects  on  humans.  The  RfDs for the
noncarcinogenic contaminants of concern are also contained in Table
15.

Carcinogenic contaminants are classified according to EPA's weight-
of-evidence  system.   This  classification  scheme  is summarized
below:

     Group A:  Known human  carcinogen.

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                                53
Table 13
'»-•-,> -h, , ." ~r,Af^\. v, , .
1, ' .Tabta 7-9
Summary of Risk* forfutm Stte Ra*idant Direct IngwtioiY of GraundwaurV
. " ' ' ' ' HCFSCSits ' ' ' ~*
Parameter
Aldrin
alpha-BHC
bata-BHC
delta-BHC
gamma-BHC
DDT
DDD
DDE
Dieldrin
Endosulfan II
Endrin
Endrin Ketone
Toxaphene
Endosulfan Sulfate
Disulfoton
TBPT
Benzene
Lead
Chromium
95% UCLk
(ppbl
O.266
3.44
3.74
1.06
0.69
0.175
0.24
0.21
1.11
0.13
0.081
2.98
8.29
0.091
9.12
10.7
6.85
11.5
69.75
Slop*
Factor
(SFT
17
6.3
1.8
NA
1.3
0.34
0.24
0.34
16
NA
NA
NA
1.1
NA
NA
NA
0.029
NA
NA
Reference Dos*
IRfDr
0.00003
NA
NA
NA
.0003
0.0005
NA
NA
0.00005
0.00005
0.0003
0.0003'
NA
0.00005'
O.OOO04
NA
NA
0.0014'
1.0








:- ".*


::•-•-:'
Sum of Cancer Risks and Hazard Indices'
Upper Bound
Cancer Risk*
5.32E-5
2.54E-4
7.90E-5
NA
1 .05E-5
7.00E-7
6.75E-7
8.31E-7
2.08E-4
NA
NA
NA
;.i. 1.07E-4
NA
NA
NA
1 .99E-6
NA
NA
4ZR!sfc--7.1E.4:~.
Hazard Index'
0.24
NA
NA
NA
0.063
0.0096
NA
NA
0.61
0.073
0.0073
0.27
~~NA
0.050
6.25
NA
NA
0.23
8.19E-4
..•:::T:HI-::7,80:::::-;
a - assume* consumption of 2 liters/day of contaminated groundwater (at 95% UCL for each parameter) over
a 70 year period for carcinogens and a 30 year period for non-carcinogens.
b - Rgure 7-2 provides the equations used to compute chronic daily intake for establishing risk levels and hazard
indices.
c - 95% Upper Confidence Limits means calculated using detected values for hits and one-half the sample
quantitation limit for non-hits. Data used was derived from the 3rd end 4th Quarter 1991 Groundwater
Sampling Events.
d - RfD for endrin applied to endrin ketone; RfD for endosulfan applied to endosulfan sulfate.
e - The unit risk for lead is calculated from a treatment technology based MCL of 0.015 mg/l. A USEPA
approved RfD for lead has not been established.
f Hazard Indices have been summed as a conservative estimate of non-carcinogenic risk; generally summation
of Hazard Indices is appropriate only for contaminants having the same target organ effect (for non-
carcinogens).

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                                                       54
Table  14
,:".!"" ^.v" ;; • - •yra*»-:7-to •' . • ; .
..,...,•:. Summary of Ri*k> for Cwrent Adtrft Worker* and Ftntr* 6ita Residents .
• from Oral and Dermal Exposure to Contaminants in Sbl/Sadinienti
•• •. ..'•••<< ' • * HCFSCSttn
Concentration of
Contaminant
(mg/kg)"
1.59
0.53
0.75
0.38
0.034
19.2
6.45
0.91
2.69
«
1.82
1.92
0.65
0.22
3.3
43.3
0.097
0.0
Contaminant
Aldrin
olpha-BHC
beta-BHC
delta-BHC
gamma-BHC
DDT
ODD
DDE
Dieldrin
Endosulfan
Endosulfan Sulfate
Endrin
Endrin Ketone
Methoxychlor
Toxaphene
Disulfoton
TBPT
Sum of Upper Bound Cancer Risk . :
Sum of Hazard Indices •
Future Resident Upper
Bound Risk Level*
(or Hazard Index)
5.3E-5
(HI =0.0243)
6.5E-6
2.65E-6
NA
8.68E-8
(HI =0.00052)
1.28E-5
(Hl=0.176)
3.04E-6
6.07E-7
8.45E-5
(HI =0.246)
(HI =0.1 67),: ',
(Hl=0.176)
(HI =0.0084)
(HI =0.0034)
(HI =0.003)
9.35E-5
(HI =0.011)
NA
-' -:; : 2S7&4"-'v-"":::-.'-;""
Sum:ofHI = .82..:
Adult Worker Upper Bound
Risk Level*
(or Hazard Index)
1.56E-5
(HI =0.076)
2.0E-5
8.3E-7
NA
2.7E-8
(HI = 1.6E-4)
4.0E-6
(Hl = 0.055)
9.5E-7
1.9E-7
2.6E-5
(HI = 0.0771
(HI =07052)
(HI =0.055)
(HI = 2.6E-3)
(HI = 1.1E-3)
(HI = 9.4E-4>
2.92E-5
(HI =0.0035)
NA
8.0E-5
Sum of HI =0.32
      Notes:
      a    Mean concentration in soil (95% C.L. was not calculated as the data are not normally distributed).  The mean
          contaminant concentrations in the "hot spots" onsite were assumed to be present over the entire site area. Uniform
          exposure to all arees onsite was assumed to provide a conservative estimate of exposure.  This approach is consistent
         -with USEPA, Region IV guidance for establishing RME levels.
      b    HI (Hazard Index) of > 1 is a cause for concern.  Upper bound risk levels of 10"* to  10* are considered on a case-by-
          case basis as to  their acceptability by the USEPA.
      c    TBPT was not identified in surface soils onsite.
      NA  Not applicable

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                                                     55
Table  15
,~,v -„<(*, ^« * X, £g~*~. -J,^
* 2 < .,» *- »-^.r '
«. >T !.--•«-,
orate
Contaminant
Chlordane
Endrin
Heptachlor
Heptachlor Epoxide
Oisulfoton
Benzene
Aldrin
e-BHC
B-BHC
gamma-BHC (Ljndane)
delta-BHC
Dieldrin
Endosulfan
ODD
ODE
DDT
Toxaphene
TBPT*
Mathoxvchlor
Chlorobenzilata
Chromium'
Lead
' " .Tabt»;
H«ah»*eaaad Value* for C
TNoncarcmogans {RfD
ipo«ur« to Contaminants o
Sjopcf actor :(SR
(mg/kg/dayr*
1.3
NA
4.5
9.1
NA
0.029
17
6.3
1.8
1.3
NA
16
NA
0.24
0.34
0.34
1.1
NA
NA
NA
NA
NA
N» *?-**•
-aicinog«n» (CPF) «od
JandARARafar
f Concern rt the HCF5C Site
fWD
(mg/kgyday)
O.OO006
O.OO03
O.O005
0.000013
0.00004
NA
0.00003
NA
NA
0.0003
NA
0.00005
O.OO005
NA
NA
O.OO05
NA
NA
O.OO5
0.02
1.0
0.0014"
•-..:; • •-..: •%,,. .

ARAR
(MCt ac mg//)
0.002
0.002'
0.0004
0.0002
NA
0.005
NA
NA
NA
0.0002
NA
NA
NA —
NA .
NA
NA
0.003
NA
0.04
—
0.1
0.015'
     a        A proposed MCL of 0.002 mg//
     b        No verified risk based criteria exist for TBPT.
     c        The unit risk for lead is calculated from a treatment technology based MCL of 0.015 mg/l. A USEPA approved RfD for
             lead has not been established.
     d        based on assumption that all chromium is present in the (III) valance state.
     e    %    unit risk computed from MCL
     NA      Not available or not determined
     Slope Factor synonymous to Cancer Potency Factor (CPR

-------
                                56

     Group Bl:  Probable human carcinogen, based  on  limited human
               epidemiological evidence.

     Group B2:  Probable  human  carcinogen,  based  on  inadequate
               human  epidemiological   evidence  but   sufficient
               evidence of carcinogenicity in animals.

     Group C:  Possible  human  carcinogen,  limited  evidence  of
               carcinogenicity in animals.

     Group D:  Not classifiable due to insufficient  data.

     Group E:  Not a  human carcinogen,  based on adequate  animal
               studies and/or human epidemiological  evidence.


6.4  RISK CHARACTERIZATION

It  should be  noted  that  there  is  some  degree of  uncertainty
associated with the calculated numerical estimates of human health
risks generated in the Baseline  Risk Assessment. This is  due to
the  considerable  number  of  assumptions  required  to  provide
variables in the  equations,  and the specific selections  of each
variable  from  a  range  of possibilities.    The potential  risk
associated with  soils  and groundwater exposure was  quantified
through the standard risk assessment scenarios (Tables 13 and 14) .


6.4.1  Ground Water

Ground-water risk based  upon  residential drinking water.exposure
was evaluated  as  a potential future risk.   Samples  from several
monitoring wells  had at  least one contaminant  that  exceeded the
current MCL.

Table  13 presents   the  individual  risks  associated  with  each
parameter found in ground water along with total carcinogenic and
non-carcinogenic values.   The total groundwater risk  for future
residents consuming water from the surficial aquifer was calculated
at 7.1 x 10"4.  The summation  of the Hazard Indices for the future
groundwater exposure  scenario was  calculated at 7.8.   Toxaphene,
dieldrin and alpha-BHC account for 80 percent of the carcinogenic
risk,  Disulfoton accounts for 80 percent of the non-carcinogenic
risk.   These  values  indicate that significant  carcinogenic and
noncarcinogenic risk  may be  posed by  consumption of contaminated
groundwater  from  a  potable  water  well  located  onsite.    The
assumptions  upon   which  these  risk   levels   were   based  are
conservative.

The  groundwater  risk levels  were  computed using the  95  percent
Upper  Confidence  Limit   of   the  mean  from each well for  each
parameter.   The 95  percent  Upper Confidence Limit  was computed

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using detected values  for hits and one-half  the sample quantitation
limit  for non-detects.    The mean  value  for  each  groundwater
monitoring well (for the 3rd and 4th Quarter 1991 sampling events)
was used.  This more  rigorous statistical  approach for computing
the Reasonable Maximum Exposure  (RME)  was used due to the greater-
uncertainty associated with the distribution of contaminants in the
groundwater medium.

Under current circumstances, contaminants attributable to the site
pose  no  imminent  carcinogenic  or  non-carcinogenic risk  to  site
workers or area residents through the groundwater exposure pathway.
The adjacent municipal potable water well is screened in a deeper
saturated  zone  separated  by   a  possible  aquitard  from  the
contaminated aquifer.  The municipal well has been tested, and no
site  constituents   have been detected  in  the  potable  source.
Residences  within   the  groundwater  contaminant  plume . area  are
connected  to  the municipal water  system  rendering private wells
unnecessary.

In  light  of  these  factors,  future resident  exposure  through the
groundwater pathway may  be  minimized through control of the limited
shallow  aquifer  contamination.   Control  would  serve  to reduce
contaminant  levels   in  the  shallow  aquifer  (with  concurrent
reductions in the future resident groundwater onsite exposure risk
potential),  and would prevent  migration  of contaminants  to the
unaffected  deep aquifer   supplying  the  nearby  municipal  well.
Surface water  is not  considered a  significant  pathway for direct
human exposure.


6.4.2  Soils

Direct  soil  exposure poses  a pathway of  significant  reasonable
potential risk (current and  future).   Upper bound cancer risk and
toxicity hazard index values were calculated for the contaminants
of concern.  A summary of these calculated values is shown in Table
14.

The  soil  samples   indicated that  soils  had  a   wide  range  of
contaminant levels  with  rather defined areas of greater contaminant
concentration  (north and northeast  portions of the  Site).  The vast
majority of Site contamination exists within an area from the north
warehouse building onsite  to  300 feet north and northwest of this
warehouse building.   Careful perusal  of  the data  gathered during
the RI reveal  approximately 30% of the Site's  total soil area is
contaminated with total pesticide levels greater than 100 ppb.

Volatiles  in  soils  tend to be in these same areas  (warehouse and
old landfill) but only constituted 20-25%  of the total area.  Soil
contaminant mean concentrations were computed using the  'hot spot'
method  where  only  those  samples with  detectable  contaminant
concentrations were included  in  the calculations.   The total area

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of  the  'hot spots'  encompasses  approximately 30 percent  of  the
entire  site area.    In  order to provide a  conservative  exposure
estimate, the computed mean concentration of each contaminant (from
'hot spots') was  assumed to exist over 100 percent  of  the site.
This approach  is consistent with  EPA guidance  for  establishing
reasonable maximum exposure  (RME) levels.

Throughout most of the year,  site sediments  are not submerged,  and
as  a  result,  present the  same exposure pathways as  site  soils;
Sediment contaminant concentrations were within the range observed
in site soils.  Therefore, no differentiation was made between soil
and sediment for risk computation  purposes  for  the  ingestion  and
dermal contact pathways.

In order to provide a conservative estimate of the potential risk
posed by  the direct  ingestion and dermal  contact soil  exposure
pathways, the following  exposure scenario assumptions were applied^

The potential  for direct  soil ingestion or  dermal  contact with
soils is greatest for those soils closest to ground surface.  As a
result, the arithmetic  mean  was  computed for  each constituent of
concern using soil concentrations from samples  collected within one
foot of ground surface.  The distribution of  pesticide contaminants
indicated  that higher  concentrations  for  an area are  generally
present at  the surface.  Only  positive results  were  used for the
calculation  of mean  contaminant  concentrations  in  soil.   As  a
result, the mean values calculated  (and used for calculation of
chronic daily  intakes)  were biased toward the higher range of all
values observed  for  soils.   This approach  is  consistent  with the
'hotspot' approach discussed in USEPA, RAGS, 12/89.

In  addition for  purposes of  calculating  carcinogenic risk  (or
hazard index) ,  it was assumed that the computed average contaminant
concentrations were present over 100 percent of the site.   It was
also assumed that  current site workers and future site residents
would have uniform exposure to all areas onsite.  This assumption
is conservative in that current site operations are restricted to
approximately  25  percent of the site  area.   Highly contaminated
soils are concentrated north and northeast of  the  north warehouse;
The current operations  area is restricted to the  southern portion
of  the  north warehouse.  Current site workers do not enter other
highly contaminated  areas over the course of everyday operations.

The relevant current  and potential future soil exposure scenarios
for this  site  are  considered to be adult workers and future site
residents  exposed  through the combined pathway  of  ingestion and
dermal  adsorption of contaminated  soil.   Trespassers would be
expected  to spend a  minimal  amount of time  on-site compared to
adult  workers  and  therefore  should  be   more   than  adequately
protected based on the  occupational  risk calculations.

Table 14  summarizes  computed risk values (and hazard indices)  for

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                                59

the soil direct ingestion and dermal contact exposure pathway.  The
combined carcinogenic risk from surface  soil contaminants is 8.0 x
lO"5  for current  adult  workers and  2.57 x 10~4 for  future  site
residents.    Aldrin,  toxaphene,  and  dieldrin account  for  the
majority (approximately 85 percent) of the total upper bound cancer
risk for onsite  surface soils  for  both  current adult  workers and
future  site  residents.   The sum of  hazard indices is  less  than
unity  (1)  for  current adult  workers  and 1.0  for   future  site
residents, using only soil  exposure pathways.   It is worth noting,
however, that the sum of hazard indices  is generally relevant only
in instances  where  the target  organ for  each  contaminant  is the
same.   As  a  result,  the computed sum of  hazard indices  yields a
more conservative assessment of non-carcinogenic risk.

The  areas  directly  north and northwest  of  the  northernmost
warehouse  represent  the area  of  concern  for  most surface  soil
contaminants.  It should be noted that each individual surface soil
contaminant was  assumed to be  present  over 100 percent  of  site
surface  soils  (at  the mean  concentration).    In reality,  each
contaminant is present in a much smaller area.   The contamination
distribution  assumptions  and  the occupational  exposure  duration
assumptions used in calculating risk are conservative.  It should
also be noted that occupational exposures  are intermittent and not
continuous.   Again,  the  conservative  assumption of  continuous
exposure was used.


6.4.3  Surface Water

The surface water identified on-site is intermittent in nature, and
only exists after rainfall  associated with storm events.  Standing
water is generally isolated to the densely vegetated area along the
north property line.   This area is  not subject to recreational use,
and site  workers do not have occasion  to  enter this  area during
normal  site  operations.    As   a  result,  surface water is  not
considered a viable exposure pathway.


6.5  ENVIRONMENTAL  (ECOLOGICAL) RISKS

Surface water and sediment samples were gathered during the RI from
on-Site areas and in drainage pathways leading from the Site into
local  surface water  streams.   These  samples  were  shown to  be
contaminated with Site-specific pesticides at levels which present
an unacceptable  level of risk to environmental receptors.
Surface  water   samples  were  contaminated  with  pesticides  at
concentrations  which  exceed ARARs, namely  Federal Ambient  Water
Quality  Criteria  (AWQC)  and  State  of  South Carolina  ambient
standards  for  surface waters.   The AWQC and state standards have
been established based upon protection of aquatic life from adverse
effects  of  exposure  to  toxics,   and  it  is  presumable  that
concentrations which exceed these criteria and  standards will have

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an unacceptable adverse impact on environmental receptors.

Sediment  samples  were also found  to be contaminated  with Site-
specific  pesticides.   There  are  no promulgated  standards  or
criteria for sediment quality at either the  State or Federal level,
so no ARARs exist for sediment quality.  Considerable research has
been conducted, however, on the environmental effects of exposure
to contaminated sediments.   This research has been compiled by the
National Oceanographic  and  Atmospheric Administration  (NOAA),  in
the  document entitled  The  Potential  for  Biological  Effects  of
Sediment-Sorbed  Contaminants  Tested  in  the National  Status  and
Trends Program. NOAA Technical Memorandum NOS OMA 52, August, 1991.
The levels of sediment contamination found  at this Site exceed the
levels cited in this document  as  being  likely to  contribute  to
adverse impacts to biological receptors.


7.0  DESCRIPTION OF REMEDIAL ALTERNATIVES

The  Feasibility  Study (FS)  considered a wide  variety  of general
response  actions  and  technologies  for  remediating  soil  and
groundwater.   Based on the  FS, Baseline Risk Assessment,  and
Applicable or  Relevant  and  Appropriate Requirements (ARARs),  the
remedial action objectives (RAOs) listed below were established for
the Site.  Alternatives were developed with the goal of attaining
these objectives:

Groundwater  - EPA believes that active remediation of groundwater
(such  as  a  groundwater  pump  and treat  system) in  the Barnwell
formation  underlying the Site  is  a  practicable  and appropriate
response.   The  Barnwell  Formation  is classified under the  EPA
Guidelines for Ground-Water Classification as  a Class  IIB ground
water, ie.,  a potential source  of  potable water supply.   These
ground waters also are classified as Class  GB waters of the State.
The  contamination  at the Site has  resulted  in impairment  of  the
ground-water resource as a potential drinking water source due to
unacceptable risks to human health.  In addition, the likelihood of
a  hydraulic connection  between the  Barnwell   Formation and  the
underlying McBean/Santee  Formation exists;  the nearby municipal
supply well draws water from the McBean/Santee Formation.  In order
to prevent migration from the existing contaminant plume into the
underlying drinking  water supply aquifer,  ground-water extraction
is warranted.

The remedial action  objective for contaminated  ground water is to
restore  the  affected aquifer  to   a condition that  renders  it
suitable  for use as a potable water supply.  Criteria based upon
protection of  human health  via drinking  water exposure for site-
specific  contaminants of concern are listed in Table  6.   These
criteria  constitute the remedial goals  for ground water  at  the
Helena Site.

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                                61

Given the likelihood of a hydraulic connection between the Barnwell
and the McBean/Santee  formations,  and the inconclusive nature of
the pump  test  conducted  as part of  the  RI,  EPA anticipates that
effective implementation of  the ground-water remediation at this
Site will include another  pump  test.   The purpose of  such a pump
test will be to determine the degree of interconnection between the
formations mentioned above.   The exact means by  which this pump
test will be conducted will  be  determined during remedial design
activities.

Surface  and Subsurface Soils - Soils on  the Site, both  at  the
ground surface and at depths grater than one foot, are contaminated
at levels which exceed criteria protective of human health under an
exposure  scenario which assumes unrestricted land use, including
residential development,  and which exceed concentrations that are
likely to continue  to leach  contaminants to ground water.   The
overall remedial action objective  for the surface and subsurface
soils  is  to remove  and  remediate  contaminated soils to  such a
degree that both ground-water quality (in conjunction with ground-
water  extraction  and  treatment) and  human  health are protected.
The  RI  identified  soil   remediation  goals  for  both of  these
purposes.  Table  7 presents a comparison of these remedial goals as
developed in the  RI.  EPA review of the remedial  goals developed in
the RI for the protection  of ground water revealed, however, that
the technical basis  for these goals was inadequate.  EPA therefore
conducted an independent  analysis of soil contamination levels and
has  determined that  a soil  remediation  goal  of  50 ppm total
pesticides is protective of human health and the environment,  and
will result in the removal  of 90% of the  total pesticide mass that
exists at the site.

The  evaluation  performed  by  EPA  was   based  upon  contaminant
distribution data provided in the  RI.   EPA used this contaminant
distribution data to calculate the contaminant mass associated with
the  soils   at  the  Site  as   it   is  related  to  contaminant
concentrations.     Contaminants  migrating   from  a   relatively
concentrated  source area  via  soils or  ground  water  tend  to be
logarithmically distributed.  By determining the concentration at
which the bulk of contaminant mass will be removed and optimizing
this concentration with relation to the volume  of soil requiring
treatment  (i.e.,  by  avoiding  a  situation whereby  the  law of
diminishing returns is created), the appropriate soil remediation
goal can  be estimated.

The proposed  remedial  action would  then  consist  of treating the
soils by a combination  of bioremediation  and hydrolytic/photolytic
dechlorination (HPD), and  replacement  of the treated soils in the
on-site excavations, followed by covering the backfilled material
with  one foot of clean soils.   The performance  standards  for
treatment of the  soils would satisfy the Land Disposal Restrictions
(LDRs) found in 40 CFR Part 268,  promulgated under the authority of
the Resource Conservation  and Recovery Act  (RCRA).  This proposal

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                                62

is based partly upon the concept that ground-water quality can be
protected  by  treatment  of  soils  in  these  source  areas  in
combination with  extraction  and treatment  of contaminated ground
water.  The removal and treatment of soils in the source areas is
also protective of human health via direct contact and incidental
ingestion.

Wetlands  and  Contaminated  Sediments  -  The placement  of  fill
material in jurisdictional wetlands, and the contamination of the
sediments in the wetlands that resulted from this placement,  have
resulted  in  an  unacceptable  level  of  risk  to  environmental
receptors.   The remedial action objective  for the  fill  and the
contaminated sediments  is  to mitigate for the  impacts  that  have
resulted  in  these unacceptable  levels  of risk  to environmental
receptors. Mitigation will comply with the requirements of Section
404 of the Clean Water Act, and specific mitigative measures will
be  determined  in accordance  with the  criteria  and  guidelines
established under Section 404(b) (1) of that Act.  These regulations
are relevant and appropriate  to the circumstances of the release of
contaminants from the landfill placed  in jurisdictional wetlands.

The  following   section  provides   a   summary  of  the  six  (6)
alternatives   developed  in  the   FS  Report  to   address   the
contamination of  soils,  sediments  and ground water at the Helena
Chemical  NPL  Site.    The  primary  objective of  the  FS was  to
determine and evaluate alternatives for the appropriate extent of
remedial action to prevent or mitigate the migration or the release
or threatened release of hazardous  substances from the Site.  With
the  exception  of the  No-Action  alternative,  all  alternatives
include  the  same provision for  extraction,  treatment  and proper
disposal of contaminated ground water.  Likewise,  all alternatives
with  the exception  of  No Action  have the  same  provision for
mitigation  of  the  adverse  effects  associated  with  pesticide
contamination in the wetlands adjacent to the Site. While wetlands
mitigation is not discussed in the FS  as a component  of any of the
alternatives, EPA has determined that unacceptable levels of risk
to environmental receptors have resulted from the  release of site-
specific contaminants into jurisdictional wetlands.  Mitigation for
these releases has been determined to be relevant and appropriate
to  the  circumstances of the  release  under  the  criteria for such
determinations  contained in  the NCP.   Alternatives  2  through 6
(Alternative 1 being the No-Action alternative)  differ only in the
technologies  to be  applied  for the  remediation  of contaminated
soils.

The following descriptions of remedial alternatives are summaries
of  more complete  descriptions  found  in  the FS  report.   The FS
report contains a more detailed evaluation of each alternative and
is available for review in the Administrative Record for the Site.
All costs are  based  upon capital costs plus the present worth of
annual operation  and maintenance costs.

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                                63

7.1  ALTERNATIVE 1 - NO ACTION

By statute, EPA is required to evaluate a "No Action" alternative
to  serve as  a basis  against  which other  alternatives can  be
compared.  Under the No  Action Alternative,  no remedial response
would be performed on any  of  the media  of concern (surface soil,
ground water or sediments)  at  the Site.  This alternative does not
reduce the risk calculated  by the Baseline Risk Assessment.  The No
Action Alternative results in  an excess cancer risk  of  8.0  X 10"5
and a Hazard Index for non-carcinogenic effects of 0.3 for current
land use exposure  scenarios, and an excess cancer risk of 2.6 X 10"4
and  a  Hazard  Index  for  non-carcinogenic  effects  of  8.6  for
potential future land use scenarios.

The estimated present worth cost for the no-action alternative is
$480,000.  This cost is  for monitoring  of ground water and soils
for thirty years.


7.2  ALTERNATIVE  2  - DEMOLISH FORMULATION BUILDINGS; CONSOLIDATE
CONTAMINATED  SOILS  AND  DEBRIS IN ONSITE  LANDFILL;  GROUND-WATER
EXTRACTION. TREATMENT AND DISPOSAL; AND WETLANDS MITIGATION

All  alternatives,  excluding  No  Action,  include  ground-water
containment  by means  of  extraction,  treatment  and appropriate
disposal.  The installation of ground-water extraction wells will
prevent the migration of  contaminants beyond  the present extent of
the contaminant plume,  and will over  time  remove contaminants from
the ground water lying beneath  the Site.   At present,  the extent of
contaminated ground water is confined to the shallow aquifer (the
Barnwell Formation)  and does not appear to extend laterally to off-
site areas.

Extracted ground water will be treated to  criteria appropriate for
the final means of disposal.   At present,  it is planned that the
extracted ground water will be treated and discharged to the local
sanitary  sewer system,  also  known  as  a  POTW.    Pretreatment
requirements will be set by the owner/operator  of  that sanitary
sewer system in order to insure that the discharge permit for the
system will not be violated.   It is  possible,  based upon initial
estimates of  ground-water  quality,  that  no  pretreatment  will be
necessary; for the purposes of preliminary cost  estimates, however,
it is assumed that some degree of pretreatment for extracted ground
water will  be required.   The  actual technologies  to be employed
will be  based upon the pretreatment criteria  established by the
owner/operator of the POTW.

Extraction  of  contaminated ground water  will  continue  until the
ground-water remediation goals are met throughout the  extent of the
plume.  Should it  prove to  be  technically  impracticable to achieve
these remedial goals, EPA will  amend the ROD to reflect any changes
in remediation criteria.

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                                64

All alternatives, with the exception of No-Action,  also include the
demolition of on-site buildings as necessary to remove contaminated
soil for treatment.   Testing  of  the demolished  buildings will be
conducted  during  remedial  design  in order  to  determine  the
appropriate  methods of  disposal  for  demolition  debris.    It  is
likely  that  the  demolition  debris  will  not  be  significantly
contaminated,  so  that  no  special  handling will  be  required,
allowing disposal of the  demolition debris as non-hazardous solid
waste.

All alternatives, with the exception of the No-Action Alternative,
also include mitigation for contaminated soils and  sediments in the
wetland  areas   adjacent  to  the  Site  and  downstream  can  be
accomplished in a number of ways under  the regulations,  guidelines
and criteria established under Section 404 (b) (1)  of the Clean Water
Act, which  is an ARAR for the remedial action at  this  Site.   The
exact form of mitigation that will satisfy the requirements of this
ROD  will  also  conform  with  the  Memorandum  of  Agreement  (MOA)
between  the  Corps  of  Engineers  and  EPA which  took  effect  on
February 7,  1990.   This MOA  is  a criterion "to  be considered" in
the determination of remedial  actions for the Site. Removal of the
fill placed in the affected wetlands, accompanied by removal of the
contamination that has  resulted from transport of toxic materials
from that  fill,  is  one potential  method.   Another would  be the
restoration  of  degraded  wetlands  at some  off-site  location.
Another possibility is the acquisition  of unaffected wetlands that
are  currently  threatened by development  or other  destructive
activities and placing  those wetland areas in a protected status.
A  number  of  factors will be used  to determine  the most  cost-
effective and environmentally sound manner in which compliance with
the mitigation guidelines will be achieved.

Alternative  2  calls for the  demolition of the former formulation
buildings  on  the  Site,  excavation  of  contaminated  soils  and
disposal of  contaminated soil in an on-site landfill constructed
especially  for this purpose.   All soils exceeding 50  ppm total
pesticides would be placed in the landfill.  The landfill would be
constructed to meet all  applicable technical requirements regarding
design  of  such  landfills,   including  top  and  bottom  liners  to
prevent infiltration of rainfall  and also to prevent any further
contamination  of  ground water.    Long-term  maintenance of  the
landfill would be required as part of the implementation of this
alternative.

The estimated cost  for  this alternative is $5.5 million.


7 .3  ALTERNATIVE 3 - DEMOLISH FORMULATION BUILDINGS. EXCAVATION AND
ON-SITE BIOLOGICAL TREATMENT OF CONTAMINATED SOILS.  GROUND-WATER
EXTRACTION.  TREATMENT AND DISPOSAL. AND WETLANDS MITIGATION

The  ground water  and wetlands  portions of  this  alternative are

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                                65

identical  to those  described under  Alternative 2.    They  will
consist  of  ground-water   extraction,   treatment  and  disposal
(preferably  in  the  local  sanitary  sewer),   and mitigation  of
wetlands impacts.  Demolition of Site buildings  will  also be as
described under Alternative 2.

Under this alternative,  contaminated soils containing greater than
50  ppm total  pesticides would  be  treated on-site  by means  of
biological degradation.   Biological degradation would take place in
treatment cells constructed on-site  that  would  be  lined to prevent
any leaching of contaminants to ground waters underlying the Site.

Biological treatment cells would consist of lined pits into which
the  contaminated soils  would be placed.   Once placed  into  the
cells, moisture content, temperature and nutrient levels would be
adjusted  and  maintained  to  maximize   the  rate  of  biological
activity.  Both aerobic and anaerobic  conditions are envisioned in
order   to   maximize  the   effect  of   biological   degradation.
Anticipated  treatment  would  consist  of  anaerobic  treatment,
particularly for soils contaminated with DDT,   followed by aerobic
treatment.   Some of  the  Site soils  may  require aerobic treatment
alone.

Treatability  studies would be  conducted  to  determine if  this
alternative  can  achieve  the remedial  goals,  but preliminary data
indicate that significant reductions in concentration of many site-
specific contaminants can  be achieved by biological degradation.
Once  soils  are  treated to  the  remedial  goals,  they would  be
replaced in the on-site  excavations from which they were removed:
The performance standard for treatment would be based upon the LDRs
for site-specific contaminants.

The estimated cost for this alternative is $8.0 million
7.4    ALTERNATIVE  4  -  DEMOLITION  OF  FORMULATION  BUILDINGS.
EXCAVATION AND HYDROLYTIC / PHOTOLYTIC DECHLORINATION OF CONTAMINATED
SOILS. GROUND-WATER EXTRACTION. TREATMENT & DISPOSAL. AND WETLANDS
MITIGATION

The  ground water and wetlands portions of  this  alternative are
identical  to those  described  under  Alternative  2.    They  will
consist  of   ground-water   extraction,   treatment  and -disposal
(preferably  in  the local  sanitary  sewer),  and mitigation  of
wetlands impacts.   Demolition of Site buildings  will  also be as
described under Alternative 2.

Under this alternative,  contaminated soils containing greater than
50 ppm total pesticides from the Site would be  treated by means of
hydrolytic/photolytic  dechlorination  (HPD)   of   the  pesticide
contaminants.  This process would be implemented at Helena Chemical
by mixing  contaminated  soils  with chemical  reagents and exposing

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them to heat and ultraviolet  (UV) radiation.  The mixing process is
necessary  to  distribute the  reagents  (usually  hydrated  lime,
possibly supplemented by sodium hydroxide) throughout the mass of
contaminated material.   The mixed material/reagent  mass  is then
placed  in  thin  layers  in  cells  similar  to those  proposed  for
biological treatment in order for the soils to be exposed to heat
and UV energy from the sun.  The soil mass would also  be kept moist
in order  to enhance biodegradation  of any  organic  end products
resulting  from the hydrolytic/photolytic dechlorination process.
Soils would be periodically  "turned over" to maximize contaminant
exposure  to UV radiation.   The  performance  standard•  for  the
treatment process would be the LDRs  for  site-specific contaminants.

Treatability studies would  also be  required to determine  if this
technology would be capable of achieving the required performance
standards.

The estimated  cost for this alternative is $7.2 million.


7.5  ALTERNATIVE  5 -  DEMOLISH FORMULATION BUILDINGS. EXCAVATION.
HYDROLYTIC/PHOTOLYTIC DECHLORINATION AND BIOLOGICAL  TREATMENT OF
SOILS ON-SITE.  GROUND-WATER EXTRACTION. TREATMENT AND  DISPOSAL. AND
WETLANDS MITIGATION

This is  the preferred alternative for  remediation of  the Helena
Site.

The  ground water  and wetlands  portions of  this  alternative  are
identical  to  those  described under  Alternative  2.    They will
consist  of  ground-water   extraction,   treatment  and  disposal
(preferably  in  the local  sanitary  sewer),  and mitigation  of
wetlands impacts.   Demolition of  Site  buildings  will  also  be as
described under Alternative 2.

Under  this  alternative,  the  two  technologies  discussed  under
Alternatives 3 and 4 above would be  combined in order  to take
advantage  of the particular benefits of  each.  Past studies and
experience with biological treatment have indicated that biological
treatment  alone is effective  for  many of  the site-related soil
contaminants   at   Helena  (notably   DDT  and  its  metabolites) ,
Biological  treatment  alone,  however,  is  less  effective  for
toxaphene, which  is another Site contaminant found in significant
concentrations,  likewise contributing  significantly to the risk
associated with Site exposure.  HPD,  on the other hand, has been
shown in pilot-scale studies to be  effective in the destruction of
toxaphene.  The two technologies would be combined in a treatment-
train mode, with HPD  treatment  followed by biological treatment.
In addition to biological treatment of  site-specific contaminants
other than toxaphene,  the second step of the treatment train would
also serve  to  further degrade the  breakdown products produced by
the  initial HPD step.

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                                67

Otherwise,  the  treatment processes would be as  described under
Alternatives  3  and 4,  above.   The  soil remediation  goal would
remain at 50  ppm  total  pesticides,  and the treatment performance
standard  would   be  based  upon  the   LDRs   for  site-specific
contaminants.   The estimated cost  for this alternative  is $3.9
million.
7 . 6  ALTERNATIVE 6 - DEMOLISH FORMULATION BUILDINGS, EXCAVATION AND
LOW TEMPERATURE THERMAL DESORPTION OF SOILS ON-SITE.  GROUND-WATER
EXTRACTION. TREATMENT AND DISPOSAL, AND WETLANDS MITIGATION

The  ground water and wetlands  portions of this  alternative are
identical  to those  described under  Alternative 2.   They  will
consist  of   ground-water   extraction,   treatment   and  disposal
(preferably  in  the  local  sanitary  sewer),   and  mitigation  of
wetlands impacts.  Demolition of Site buildings will  also be as
described  under Alternative 2.

Under this alternative, contaminated soils exceeding 50 ppm total
pesticides from the Site would be treated on-site by means of low
temperature  thermal  desorption  (LTTD).   This  process -involves
processing contaminated soils through a  rotary dryer or kiln.  The
soil mass  is  heated  to  a  temperature  level  that is sufficient to
drive the contaminants off of the soil matrix,  but not high enough
to  actually  incinerate  or  destroy  the  contaminants.     Soil
contaminants  are volatilized  from the solids  and purged from the
kiln or dryer by means of  an inert purge gas.   After the purge gas
leaves the desorption unit, it is treated by an off-gas treatment
system that prevents  the soil contaminants from being released into
the environment.  Typical  air pollution  control equipment  (such as
cyclonic precipitators and baghouses)  are also used to protect air
quality during operation of desorption units.

LTTD  typically concentrates  the Site  contaminants  into  a  low-
volume,  highly concentrated  waste stream that  must  in  turn be
disposed  of  in  a manner  that  complies with  all  environmental
regulations.   This  residual  waste stream  would be  disposed of
either  by  incineration or  by  transport to  an approved waste
disposal facility.

Numerous vendors for this type of treatment system exist,  and EPA
has  experienced good success with its  use  on soils contaminated
with pesticides  at  other Superfund sites.   Treatability  studies
would likewise be necessary in order to assess the suitability of
this technology for application at the Helena Chemical Site.  The
performance  standard for  this treatment system would likewise be
the LDRs for  site specific contaminants.

The estimated cost for  this alternative  is $4.4 million.

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8.0  SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

The alternatives for Site remediation were evaluated based on the
nine criteria set  forth in  the NCP (40  CFR § 300.430(e)(9)).   In
the sections which follow,  brief summaries  of how the alternatives
were judged against these criteria are presented.

8.1  CRITERIA FOR COMPARATIVE ANALYSIS

8.1.1  Threshold Criteria

Two threshold criteria must be achieved by a remedial alternative
before it can be selected.

1.     Overall protection of  human  health  and the  environment
addresses whether  the alternative will  adequately  protect  human
health  and  the  environment from  the risks posed  by the  Site.
Included in judgement by this criterion is an assessment of how and
whether  the  risks  will  be   properly   eliminated,  reduced,   or
controlled   through  treatment,   engineering   controls,   and/or
institutional controls.

2.     Compliance  with  applicable or relevant  and  appropriate
requirements (ARARs) addresses  whether an alternative will meet all
of the  requirements of  Federal  and  State  environmental  laws  and
regulations, as well as other  laws, and/or  justifies a waiver from
an ARAR.  The specific ARARs which will govern the selected remedy
are listed and described in Section 9.0, Selected Remedy.


8.1.2  Primary Balancing Criteria

Five criteria were used to weigh the strengths and weaknesses among
alternatives, and  to develop  the decision to select one of  the
alternatives.   Assuming satisfaction of  the threshold criteria,
these are the main considerations in selecting an alternative as
the remedy.

1.   Long term effectiveness  and permanence refers to  the ability of
the alternative to maintain reliable protection of human health and
the environment  over time, once  the  remediation goals  have been
met.

2.    Reduction  of  toxicitv,  mobility,   or volume  addresses  the
anticipated  performance of the  treatment technologies that  an
alternative  may  employ.   The  1986  amendment to CERCLA,  the
Superfund Amendments and Reauthorization Act (SARA) , directs that,
when  possible,  EPA   should   choose  a  treatment  process  that
permanently  reduces the level  of  toxicity of  site contaminants,
eliminates or reduces  their migration away from the site,  and/or
reduces their volume on a  site.

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                                69

3.  Short-term effectiveness  refers to the length of time needed to
achieve protection, and the potential for adverse effects to human
health or the  environment  posed by implementation  of the remedy,
until the remediation goals are achieved.

4.   Implementability considers the  technical  and  administrative
feasibility  of  an  alternative,  including  the availability  of
materials and services necessary  for implementation.

5.  Cost includes both the  capital (investment)  costs to implement
an alternative, plus the long-term O&M expenditures applied over a
projected period of  operation.


8.1.3  Modifying Criteria

State  acceptance  and community  acceptance  are two  additional
criteria that  are considered in  selecting  a remedy,  once public
comment has been received  on the  Proposed Plan.

1.   State  acceptance:  The  State of South Carolina  concurs with
this remedy.

2.   Community  acceptance  was  indicated by the verbal'comments
received at the  Helena  Chemical  NPL  Site  Proposed  Plan public
meeting, held on May 27, 1993.  The public comment period opened on
May 18, 1993, and  closed on June  17, 1993.

Written comments received concerning the Helena Chemical NPL Site,
and those comments expressed at the  public meeting, are addressed
in the Responsiveness Summary attached as Appendix A  to this ROD.


8.2  COMPARISON OF ALTERNATIVES

All alternatives, except Alternative  1, provide adequate protection
of human health and the environment.   All alternatives, again with
the exception of Alternative 1, achieve all identified ARARs.  With
respect   to   short-term   effectiveness   and  implementability,
Alternatives 2-6 are all are comparable.  Treatment Alternatives 3
through  6  achieve overall protectiveness and  risk  reduction by
permanently treating the waste and using the treated materials to
prevent  contact with  less affected soils  beneath  the treatment
areas.   Landfill Alternative 2 achieves similar risk reductions,
but  does not  satisfy the  statutory preference  for  reducing the
toxicity and  volume of the  waste, although the mobility of Site
contaminants would be greatly reduced.  Therefore, Alternatives 3-6
are preferable  to  Alternative  2.

Neither Alternative 3 nor Alternative 4 (biological treatment alone
or HPD alone)  has  been shown to be fully effective for the entire
range of pesticide contaminants found at the Site.   The long-term

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effectiveness of  Alternatives  3 and 4 is  therefore  less assured
than that for Alternatives 5 and 6.   Alternative 6,  treatment of
soils by LTTD, would make use of a proven treatment technology that
could  reasonably  be  expected  to achieve  the  remedial  goals
specified in this ROD.   Preliminary studies regarding the proposed
technology  described under Alternative  5  (combining  biological
treatment with  HPD) indicate  that remedial goals  for  all  Site
contaminants are likely to be achievable.

Alternatives 5  and 6,  therefore,  are those  that  best  meet  the
statutory  preference  for  permanent  solutions  that  reduce  the
toxicity,  mobility and  volume  of waste  materials  while  using
technologies  that  can reasonably be  expected to  achieve  the
remedial goals determined to be protective  of human health and the
environment, and  to achieve ARARs.  They  also  fulfill  the other
criteria  regarding  long-  and   short-term   effectiveness   and
implementability.    The  projected cost   for  Alternative  5  is
significantly  less  than  that  for Alternative  6.    Given  that
Alternative 5 can  be  implemented at significantly  less  cost than
could Alternative  6, Alternative 5 is  the preferred alternative.

EPA recognizes,  however, that  the preferred remedy includes a soil
treatment   technology   (HPD/biological  treatment)   that  is   an
innovative  technology  that has not been demonstrated  capable of
achieving performance standards specified in Section 9, below.  EPA
therefore will retain Alternative  6 as a contingency remedy to be
implemented should treatability studies of HPD/biological treatment
prove  that  this   technology   is   incapable   of  achieving  the
performance standards for this Site.  The only difference between
Alternative 5 and Alternative 6 is the  soil  treatment technology to
be  employed.    Alternative  6  contains  low temperature thermal
desorption  (LTTD)  as the soil treatment technology.


9.0  THE SELECTED  REMEDY

Based upon  consideration of the requirements of CERCLA,  the NCP,
the  detailed  analysis  of alternatives   and  public  and  state
comments, EPA has  selected a remedy that includes source control,
ground-water remediation, and mitigation for wetlands impacts for
this Site.   At  the completion of  this  remedy,  the  residual risk
associated  with  this Site will  fall within the acceptable range
mandated by CERCLA and  the NCP of  10"6  to  10"4  which is determined
to be protective of human health.  The unacceptable level of risk
posed to environmental  receptors will also be adequately addressed.
The total present worth cost of the selected remedy, Alternative 5,
is estimated at $3.9 million.

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                                71

9.1  DESCRIPTION OF SELECTED REMEDY

9:1.1.  Source Control

Source  control will  address  the  contaminated  soils and  waste
materials at the Site.  Source  control shall include excavation of
contaminated soils and waste materials,  on-Site treatment by means
of   combined   hydrolytic/photolytic  dechlorination   (HPD)   and
biological  degradation,  and placement  of  the treated soils  and
waste materials back  into on-Site excavations.  The treated soils
will then be covered  by a minimum of one foot of clean backfill.

The major components  of source control to be implemented include:

9.1.1.1.  Excavation

Excavation  of  materials contaminated with  greater than 50 ppm of
total pesticides at the Site.   Excavation  will  be limited to the
uppermost  three  feet of  soils at the  Site  in order  to prevent
creation of a preferential flow path for infiltration of rain water
into the shallow aquifer.


9.1.1.2.  Treatment of Excavated Soils

Treatment of all excavated materials by means of a combination of
hydrolytic/photolytic dechlorination and biological degradation.

Contaminated soils and waste materials containing greater than 50
ppm  total  pesticides  from the Site would  be  treated  by  means of
hydrolytic/photolytic dechlorination   (HPD)   of   the  pesticide
contaminants.  This process would be implemented at Helena Chemical
by mixing  contaminated  soils with chemical reagents and exposing
them to heat and ultraviolet  (UV) radiation.  The mixing process is
necessary  to  distribute  the  reagents  (usually  hydrated  lime,
possibly supplemented by  sodium hydroxide)  throughout the mass of
contaminated material.   The mixed material/reagent mass is then
placed  in  thin  layers in  cells  similar  to those proposed  for
biological  treatment  in order  for the soils to be exposed to heat
and UV energy from the sun.  The soil mass would also be kept moist
in order to enhance  biodegradation  of any  organic end  products
resulting  from the hydrolytic/photolytic dechlorination  process.
Soils would be periodically  'turned over"  to maximize contaminant
exposure to UV radiation.

Contaminated soils containing greater than  50 ppm  total pesticides
would also  be  treated on-site  by means of biological degradation
subsequent  to  the HPD process steps.  Biological degradation would
take place  in  treatment  cells  constructed on-site  that  would be
lined  to prevent any leaching of contaminants to  ground waters
underlying  the Site.   Treatability  studies would be conducted to
determine if this alternative  can achieve  the remedial goals, but

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preliminary   data  indicate   that   significant   reductions   .in
concentration of many  site-specific contaminants can be achieved by
biological degradation.   Once soils are treated  to  the remedial
goals, they would be replaced in the on-site excavations from which
they were removed,  and  covered  by a minimum  of one foot of clean
fill.  The performance standard for  the combined treatment process
would be based upon the LDRs for site-specific contaminants.

Biological treatment cells would consist of lined pits into which
the  contaminated soils would  be  placed.  Once placed  into  the
cells, moisture content, temperature and nutrient levels would be
adjusted  and  maintained  to   maximize   the  rate  of  biological
activity.  Both aerobic and anaerobic conditions are envisioned in
order   to  maximize  the   effect   of   biological  degradation.
Anticipated  treatment  would  consist  of  anaerobic  treatment,
particularly for  soils contaminated with DDT, followed by aerobic
treatment.  Some  of the Site  soils  may  require aerobic treatment
alone.

The  final element of the  source  control portion  of  the .overall
remedy will be  to grade the Site and  construct any structures or
appurtenances  necessary  so.  that   the   Site   complies  with  all
regulations  regarding   storm   water  run  off  from  industrial
facilities.    This will  prevent  any  further non-point  source
contribution  from  future   Site  activities  to contamination  in
adjacent waters of  the United States.


9.1.2. Ground Water Remediation

Groundwater remediation will address the contaminated groundwater
at the  Site.   Groundwater  remediation will include extraction of
contaminated groundwater,  treatment,  and discharge to  the local
Publicly Owned Treatment Works  (POTW).

The major components of groundwater remediation to be implemented
include:

Extraction from the surficial aquifer by means of pumping wells and
treatment by standard  treatment technologies generally available to
achieve pre-treatment requirements  imposed by the POTW; and

Discharge of  treated  water to the  nearest access  point  into the
sanitary  sewer collection system serving the local POTW.

The installation of ground-water extraction wells will prevent the
migration  of  contaminants beyond the present   extent  of  the
contaminant plume, and will over time remove contaminants from the
ground  water  lying beneath the Site.   At  present,  the extent of
contaminated ground water is confined to the shallow aquifer (the
Barnwell  Formation)  and   does  not  appear  to  extend  to  any
significant degree  laterally to off-site areas, although one well

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located off the Site property (MW-18) was contaminated during the
RI.

Extracted ground water will be treated to criteria appropriate for
the final means of disposal.  At present,  it  is planned that the
extracted ground water will be treated and discharged to the local
sanitary  sewer  system,  also known  as  a  POTW.    Pretreatment
requirements will be  set by  the owner/operator  of  that sanitary
sewer system in order to insure that the discharge permit for the
system will not be violated.  It is possible,  based upon initial
estimates of ground-water  quality,  that no pretreatment  will be
necessary; for  the purposes of preliminary cost estimates, however,
it is assumed that some degree of pretreatment for extracted ground
water will  be  required.   The actual technologies to  be employed
will be  based  upon  the pretreatment criteria  established by the
owner/operator of the POTW.

Extraction  of  contaminated ground  water will  continue until the
ground-water remediation goals are met throughout the extent of the
plume.  Should it prove to  be  technically impracticable to achieve
these remedial  goals,  EPA will amend the ROD to  reflect any changes
in remediation criteria.
9.1.3   Wetlands Mitigation

Mitigation  for contaminated soils  and sediments in  the wetland
areas adjacent to the Site and  downstream can be accomplished in a
number  of  ways  under the  regulations,  guidelines and criteria
established under Section 404(b)(1) of the Clean Water Act, which
is an ARAR for the remedial action at  this Site.  These guidelines
and  criteria  include  the MOA  between  EPA  and   the  Corps  of
Engineers,   effective  date  February  7,  1990,   concerning  the
determination  of  mitigation.   Removal of the  fill  placed in the
affected wetlands, accompanied  by removal of the contamination that
has resulted from transport of toxic materials from that fill,  is
one potential method. Another would be the restoration of degraded
wetlands at  some off-site location.   Another  possibility is the
acquisition of unaffected wetlands that are currently threatened by
development  or other  destructive  activities  and  placing those
wetland areas  in a protected status.  A number of factors will be
used to determine the most cost-effective and environmentally sound
manner in which compliance with  the mitigation guidelines will be
achieved.

The  exact  form  of  mitigation for the  effects of contaminated
sediments  will be  based  in  part  upon  the consideration that,
although the sediments are  contaminated to a level that is expected
to  adversely  impact  flora and  fauna normally  found in  such  a
habitat, and that therefore pose an unacceptable level of risk to
environmental  receptors,  the  habitat  function  has  not  been
completely  destroyed.    In  addition,  other  valuable  wetland

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functions  remain  intact  and  could  conceivably  be  physically
destroyed by an active removal of contaminated sediments.  Physical
reconstruction  of   wetland  areas  damaged  by   such  physical
disruptions is theoretically  possible, but  EPA's  experience with
reconstructed wetlands as  part  of  regulatory actions  taken under
the authority of Section 404 of the Clean Water Act has been that
limited  success  can be   expected  from  such  projects.    Also,
reasonable    estimates  of the  time  required  to  achieve  full
restoration of  the  existing wetlands under this  approach  may be
similar to that required for natural attenuation and biodegradation
of  site-related contamination  to  insignificant  concentrations.
Finally,   it   is   possible  that   other  sources   of  pesticide
contamination  exist  that  will  not be addressed  as part  of  the
remedy  for the Helena Chemical  Site,  since  those  sources are not
related to  the Site or activities  that  took place at  the Site.
Even should a  successful reconstruction of contaminated wetlands be
achieved,   it   is  possible  that these  other sources would  rer
contaminate  the  wetland  areas adjacent   to  the  Helena  Site,
rendering the reconstruction ineffective in the long term.

Executive Order 11990,  and regulations  related to that Order found
at 40 CFR Part 6, will also be considered in determining the most
effective  means  by  which the  mitigation will be  accomplished.
These regulations require EPA  to avoid, to the extent possible, the
adverse impacts associated with the destruction or  loss of wetlands
and  to  avoid direct or  indirect  support of new  construction in
wetlands if a practicable alternative exists.  Mitigative measures
consistent  with  these  requirements  will  therefore  be  given
preference in determining  specific actions to be required as part
of the  remedial action.

By   insuring   that   adequate  habitat   for ind  Tenous  species
potentially found in the wetlands associated with  ne  Site will be
made available by the mitigative  measures  proposed,  the adverse
impacts to the habitat  function of  the Helena wetlands  can be
remedied.   While  individuals  of  these  species  may  under some
mitigative  options  continue to be impacted by toxic effects of
contaminants  in  the  sediments at the Site, the viability  of the
various species  populations  in the area  will  be  protected and
enhanced by the  long-term stability and availability of suitable
habitat provided for by mitigation as part of the remedy.


9.1.4.  Compliance Testing

Monitoring of  groundwater (both in situ and after extraction and
treatment), excavated soils, and treated soils shall be conducted
as part of this remedial action.  After demonstration of compliance
with Performance  Standards,  Site  ground water  shall be monitored
for  five  years.   If monitoring  indicates that  the  Performance
Standards  set forth below are  being exceeded at  any time after
pumping has been discontinued,  extraction and treatment  of the

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                                75

ground water will  recommence  until  the Performance Standards are
once again achieved.

Compliance testing of the residual soils that have been subjected
to treatment will also be performed, to insure compliance with the
LDR requirements established as performance standards for- the soil
treatment technology.


9.1.5  Contingency Remedy

Should treatability  studies demonstrate that  the selected remedy
described   above,    HPD/biological   treatment,    cannot   achieve
performance  standards established  for  the  Site,  the  treatment
technology  used for  soil remediation  at  the  Site will be  low
temperature  thermal  desorption (LTTD)   in lieu  of HPD/biological
treatment.  LTTD has  been successfully used at  other NPL sites with
similar  soil  contaminants  and  levels  of  contamination,  and
therefore can  be expected to  satisfactorily  achieve performance
standards at this Site.

Using this  technology, contaminated soils exceeding 50  ppm total
pesticides from the  Site would be treated on-site by means of low
temperature  thermal  desorption  (LTTD).   This  process  involves
processing contaminated soils through a rotary dryer or kiln.  The
soil mass is heated  to a temperature  level  that is sufficient to
drive the contaminants off of  the  soil  matrix, but not high enough
to  actually  incinerate  or  destroy   the  contaminants,    Soil
contaminants are volatilized  from the  solids  and purged from the
kiln or dryer by means of an inert purge gas.  After the purge gas
leaves the desorption unit, it is treated by an off-gas treatment
system that  prevents the  soil contaminants from being released into
the environment.  Typical air  pollution control  equipment (such as
cyclonic precipitators and baghouses) are also used  to protect air
quality during operation of desorption  units.

Numerous vendors for  this type of treatment  system  exist,  and EPA
has experienced  good success  with  its  use on soils contaminated
with pesticides  at other Superfund sites.   Treatability studies
would likewise be necessary in order to assess the  suitability of
this technology for  application at the  Helena Chemical Site.  The
performance  standard for this treatment system would likewise be
the LDRs for site specific contaminants.


9.2.  APPLICABLE OR  RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
9.2.1.  Applicable Recruirements

The  remedy  will  comply  with  all  applicable  portions' of  the
following Federal and State regulations:

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                                76

40 CFR Part  6,  Subpart  C,  promulgated under the authority of the
National Environmental Policy Act.  Specifically:

     Section 6.302(a), governing protection  of wetlands, including
     referenced Appendix A to 40 CFR Part  6.   These regulations
     incorporate  Federal  Executive  Order  11990  into  Federal
     regulation.

40 CFR Part 122, promulgated under the authority of the Clean Water
Act.  Specifically:

     Section  122.26,   governing  storm  water  discharges  from
     industrial sites.

     Section  122.50,  governing  discharges  to  publicly  owned
     treatment works  (POTWs).

40  Part  136,  promulgated under the authority  of  the Clean Water
Act.   These regulations  govern  the  water  quality testing  of
discharges associated with  NPDES-related activities.   For this Site
they are applicable to testing of waters discharged to a POTW and
to the testing of storm water discharges.

South Carolina Code of Regulations  (SCCR) Chapter 61-72, governing
the discharge of storm waters from industrial sites.  Specifically:

     Section  72.307,  containing design criteria  for storm water
     discharge facilities.

SCCR Chapter  61-69, governing ambient water quality standards for
surface and ground waters.  Specifically:

     Section  61-68(C),  establishing  applicability of state water
     quality  standards.

     Section  61-68(E), establishing minimum criteria  for all state
     waters.

     Section  61-68(F), establishing ambient standards for surface
     waters.

     Section  61-68(G),  establishing  ambient standards for ground
     waters.
9.2.2.  Relevant and Appropriate Requirements

40  CFR Part  141,  promulgated  under the  authority of  the Safe
Drinking Water Act.  Specifically:

     Maximum  Contaminant Levels  (MCLs)  and  Maximum Contaminant
     Level  Goals  (MCLGs) promulgated under the  authority of the

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                                77

     Safe Drinking Water  Act are specifically identified  in the
     National Contingency Plan (NCP) as remedial action objectives
     for ground waters  that  are current or potential  sources of
     drinking water supply.  The ground waters underlying this Site
     are classified  as  Class  IIA  ground waters  under the  EPA
     Guidelines  for  Ground-Water  Classification.    Ground-water
     extraction and treatment is included in this remedy in order
     to satisfy EPA's stated goal of returning usable ground waters
     to their beneficial uses within a reasonable time frame (see
     FRVol.  53, no. 245, p 51433, and Section 300 .430 (a) (1) (ii) (F)
     of  the  NCP) .    MCLs  and MCLGs are  therefore relative  and
     appropriate for  use as  remedial  action objectives for the
     remedial action at this Site.

     Maximum Contaminant Level  Goals  (MCLGs) are  found in  40 CFR
     Part 141, Subpart F.

     Maximum Contaminant  Levels (MCLs)  are found in  40  CFR Part
     141, Subparts B and G.

40 CFR Part 230,  Subparts  B and  H, promulgated under the authority
of the Clean Water Act.  These regulations  govern the mitigation of
impacts to  jurisdictional wetlands associated with the placement of
fill material  in  waters of  the United States and  any secondary
adverse impacts resulting from that placement.

Since the solid waste on-Site is not hazardous waste, but contains
hazardous constituents,  the following regulations established under
the  authority  of  RCRA  are relevant  and  appropriate  to  the
circumstances  of  the release,  but  are not  directly  applicable.
This  includes  regulations found  at 40 CFR Parts  261-268  cited
below.

40 CFR Part  261, Subpart  B.   These regulations establish methods
for  the   testing   of  hazardous  materials   at  RCRA-regulated
facilities.    They will  be  used  to guide  testing  procedures
established  as part of  the compliance  monitoring portion of this
remedy.

40 CFR Part 264,  Subpart  B,  established under  the  authority of
RCRA.  Specifically:

     Section 264.14,  establishing criteria for Site security.

     Section 264.15,  establishing  criteria  for inspection  of the
     Site by the owner/operator.

     Section   264.16,   establishing   criteria   for  training  of
     personnel who will be involved in Site remediation.

40 CFR Part  264,  Subpart D, which requires  the  development of a
contingency  and emergency procedures plan for the Site.

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                                78

40 CFR Part 264, Subpart F, which governs  releases from solid waste
management units.  Specifically:

     Section 264.95,  which requires the establishment of a point of
     compliance  for  ground-water  protection  standards.    The
     performance standards established in this ROD for ground-water
     remediation  will  serve   as   the   ground-water  protection
     standards.  A point of compliance will be established at the
     downgradient boundary of the final disposal site for treated
     soils and waste materials.

     Section 264.97,  which establishes requirements for a ground-
     water monitoring program.   These requirements will be used to
     establish a ground-water monitoring program for the purpose of
     evaluating releases from the final disposal site for treated
     soils and waste materials.

     Section 264.98,  which established requirements  for a detection
     monitoring program.   This detection monitoring program will be
     used  to evaluate potential  releases  from the  final  disposal
     site  for treated soils and waste materials.

40 CFR Part 264, Subpart  G, which  governs closure  of solid waste
management units.  Specifically:

     Section  264.111,  which   sets   forth  closure  performance
     standards.

     Section 264.112, which requires the  submission of  a closure
     plan  for review and approval.

40 CFR Part 268, Subpart D, which establishes treatment standards
which must be achieved prior to land disposal of hazardous wastes.
These  regulations  will establish  the  performance  standards for
treatment  of contaminated  soil and waste materials excavated from
the Site.

Federal Ambient Water Quality Criteria (AWQC)  established under the
authority  of Section 304(a) of the Clean Water Act.

     These  criteria  are specifically   identified  in  Section
     121 (d) (2) (A) of CERCLA  as  amended  by SARA to  be ARARs for
     CERCLA remedial actions.   AWQC are developed as guidance for
     the States to develop ambient  surface water quality standards
     that  will  be  fully protective  of  human health   and the
     environment.  As  such, AWQC are  relevant and appropriate to
     the  selected remedial  action.   Discharge  of the  treated
     effluent from this  site  must not result  in  ambient surface
     water concentrations  that exceed chemical-specific AWQC.

SCCR  Chapter 61-79,  which contain the  State of  South  Carolina
regulations  governing  the management,   treatment,  storage and

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                                79

disposal of hazardous wastes.  These regulations are, in a manner
analogous to Federal RCRA regulations, relevant and appropriate to
the circumstances  of the releases  from this Site  without  being
directly  applicable.    In  addition,   since the  South  Carolina
regulations   simply  incorporate   verbatim  the   Federal   RCRA
regulations, the sections of  SCCR Chapter 61-79  corresponding to
the Federal RCRA sections cited above are hereby incorporated into
this ROD as relevant and appropriate requirements.


9.2.3  Criteria "To Be Considered"

CERCLA guidance recommends the identification of criteria that may
be relevant and appropriate to the circumstances of the release at
a site, but which do not  meet  the statutory  definition of an ARAR.
To  be  defined  as  an ARAR,  a  standard or criterion  must be  a
requirement  or  regulation  promulgated  under Federal  or  state
authority, and must be of general applicability.   Other standards
or  criteria,  known  as  criteria to  be considered or  TBCs,  may be
necessary in order for the remedy to be fully protective of human
health and the environment.  These  TBCs may include EPA reference
doses,  cancer potency factors,  drinking  water health advisories or
other health-based criteria.

A number  of TBC criteria  have been identified  for ground-water
remediation at the Helena Chemical  NPL Site.  They are based upon
protection of human health via drinking  water exposure, using data
contained   in   EPA  data   bases   regarding   toxicity   and/or
carcinogenicity  of  these  compounds,   and  also  using  standard
assumptions regarding intake and exposure via drinking water.

The  following TBC  criteria have  been developed  based  upon an
incremental carcinogenic risk of 1  X 10"6:

     Aldrin          0.002 parts per billion (ppb)
     alpha-BHC       0.006 ppb
     beta-BHC        0.020 ppb
     delta-BHC       0.006 ppb
     Dieldrin        0.002 ppb
     DDT             0.100 ppb
     ODD             0.100 ppb
     DDE             0.100 ppb

The following TBC criteria are based upon non-carcinogenic toxicity
(hazard index less than  1):

     Disulfoton      1.400 ppb
     Endrin Ketone   2.000 ppb
     Lead            15.000 ppb

In addition, the Memorandum of Agreement between EPA and the U.S.
Army Corps of Engineers  concerning the determination of mitigation

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                                80

under the Clean Water  Act  Section  404(b)(l)  guidelines  ia also a
TBC criterion for remedial actions related to wetlands mitigation
at this Site.
9.3. PERFORMANCE STANDARDS


The Performance Stan.dards for this component of  the selected remedy
include the following:


9.3.1.  Excavation Standards

Excavation shall continue until  the  remaining  soil  and materials
are contaminated at a  concentration  of  no  more than 50 parts per
million  (ppm)  total  pesticides.    Total  pesticides  shall  be
determined by summing the concentrations of all  pesticides found in
any  soil   sample  analyzed  for  the  pesticides  fraction  of  the
Hazardous Substances List  (HSL).  Testing methods approved by EPA
shall be used to determine if the allowable pesticide concentration
levels have been achieved.


9.3.2.  Treatment Standards

Since the remedy also  specifies land disposal of the treated waste,
the LDR-based ARARs are also performance standards for the residue
left after treatment  of the soils and  waste.   These performance
standards are found in 40 CFR Part  268,  Subpart  D, Section 268.43.
They are:


From Table CCW1:

     Aldrin                             66 parts per billion  (ppb)
     BHC, all isomers,  total          660 ppb
     Chlordane, total                 130 ppb
     Dieldrin                         130 ppb
     Disulfoton                       100 ppb
     DDT, DDE, DDD, total               87 ppb
     Endrin                           130 ppb
     Endosulfan, all  isomers, total     66 ppb
     Endosulfan sulfate              130 ppb
     Heptachlor                         66 ppb
     Heptachlor epoxide                66 ppb
     Methoxychlor                     180 ppb
     Toxaphene                       1300 ppb

     Note  1:  Compliance  to  be  determined by grab  samples  of
     treatment residue.

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                                81

9.3.3.  Ground-Water Remediation Standards

Groundwater  shall  be  extracted  until  the  following  Maximum
Concentration Levels  (MCLs) are attained  at  the wells designated
during remedial design by EPA as compliance points.

     Aldrin          0.002 parts per billion (ppb)
     Benzene         5.0   ppb
     alpha-BHC       0.006 ppb
     beta-BHC        0.02  ppb
     delta-BHC       0.006 ppb
     Chlordane       2.0   ppb
     Chromium      100.0   ppb
     Dieldrin        0.002 ppb
     DDT             0.1   ppb
     ODD             0.I   ppb
     DDE             0.1   ppb
     Endrin          2.0   ppb
     Lead           15.0   ppb
     Lindane         0.2   ppb
     Toxaphene       3.0   ppb
     Heptachlor      0.4   ppb


9.3.4   Storm Water Discharges

Final Site grading and drainage shall comply with the substantive
design criteria contained in SCCR Chapter 61-72, Section 72.307.


9.3.5  Wetlands Mitigation

Wetlands mitigation  actions taken as  part of  this  remedy shall
comply  with the  substantive  requirements  of  40  CFR  Part  230,
Subparts B  and H, promulgated  under . the authority  of  the Clean
Water Act.  These regulations govern the mitigation of impacts to
jurisdictional  wetlands  associated  with  the  placement  of  fill
material in waters of the United States and any secondary adverse
impacts resulting from that placement.   Quantitative performance
standards  shall  be  established  as  part  of  remedial  design
activities.

Mitigation activities shall  also comply with the requirements of 40
CFR  Part  6, Subpart  C,  promulgated under the authority  of  the
National Environmental Policy Act.  Specifically:

     Section 6.302(a), governing protection of wetlands, including
     referenced Appendix A  to 40 CFR Part 6.   These regulations
     incorporate  Federal  Executive  Order  11990  into  Federal
     regulation.

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                                82

10.0  STATUTORY DETERMINATIONS

The selected remedy for this  Site meets the statutory requirements
set forth at Section 121(b)(l) of CERCLA, 42 U.S.C. § 9621(b)(l).
This section states that the remedy must protect human health and
the environment; meet ARARs (unless waived); be cost-effective; use
permanent  solutions,  and  alternative  treatment  technologies  or
resource recovery technologies to the maximum extent practicable;
and finally,  wherever  feasible, employ  treatment to  reduce the
toxicity,  mobility or  volume of        the  contaminants.    The
following  sections   discuss  how  the  remedy   fulfills   these
requirements.

Protection of human health and the  environment:  The selected soil
remedy will remove the human health risks from dermal contact and
incidental ingestion of contaminated Site soils.   The groundwater
remediation system will  extract and treat  contaminated groundwater,
thereby reducing and eventually removing  the future risks to human
health  which   could  result  from  ingestion  of  or contact  with
groundwater,  and  the  environmental  risks which could result from
continued  discharge  of  contaminants  to adjacent  jurisdictional
waters.

In addition,  the  remedy selected  to address  the contamination of
surface waters and sediments in the on-Site and adjacent wetlands
(mitigation as per CWA Section 404 guidelines)  will be protective
of the environment.

Compliance with ARARs:  The selected remedy will meet ARARs,  which
are listed in Section 9.2 of this ROD.

Cost effectiveness: The selected soil remedy component  is the most
cost  effective  of  the  alternatives  considered.    Among  the
alternatives  that  are  protective  of  human  health  and  the
environment and comply with all ARARs, the selected alternative is
the most cost-effective choice because it uses a treatment method
for which costs can be  reliably  predicted  and  because  the use of
the POTW option is the most cost-effective means to dispose of the
treated groundwater.

Utilization  of permanent solutions,  and  alternative  treatment
technologies  or  resource  recovery  technologies  to the  maximum
extent practicable:   The selected  remedy  represents  the maximum
extent to which permanent solutions and treatment can practicably
be used for this action.  All of the selected remedy components are
considered permanent solutions.

Among the alternatives that are protective  of human health and the
environment and comply with all ARARs, EPA and the State of South
Carolina have determined that the selected remedy achieves the best
balance  of trade-offs  in terms  of long-term  effectiveness and
permanence,  reduction  of  toxicity/mobility/volume,  short-term

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                               83

effectiveness,   implementability,   and  cost.     Hie   selected
groundwater action is  more readily implementable than  the other
alternatives  considered,  and  utilizes  the  most  cost-effective
option for disposal of treated water.   The selected soil remedial
action  achieves  the  best  compliance  with  the  five  balancing
criteria described in the NCP.
Preference  for
The
proposed groundwater remediation system will fulfill the preference
for  treatment  as  a principal  element,  through extraction  and
treatment of contaminated groundwater until  the remedial goals are
achieved.

The soil remedial action will also satisfy the preference, due to
the   treatment   of    soils   by   the   selected   technology,
HPD/biodegradation.    Likewise,   the  contingency  remedy  fully
satisfies this preference.

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                                      PB94-964070
                                      EPA/ROD/R04-93/144
                                      February 1995
EPA  Superfund
        Record of Decision:
        Hercules 009 Landfill Site,
        (O.U. 1) Brunswick, GA
        3/25/1993
     Information Resource Center
     US EPA Region 3
     Philadelphia, PA 19107
EPA Report Collection
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107

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50272-101
  REPORT DOCUMENTATION
           PAGE
1. REPORT NO.
EPA/ROD/R04-93/144
3. Recipient's Accession No.
4.  Title and Subtitle
   SUPERFUND RECORD OF DECISION
   Hercules  009  Landfill, GA
   Second Remedial Action - Final
                                          5.  Rsport Date
                                          	  03/25/93
                                          6.
7.   Author(s)
                                          8.  Performing Organization Rept. No.
9.   Performing Organization Nam* and Address
                                          10  Project Task/Work Unit No.
                                                                     11.  Contraet(C) or Grant(G) No.

                                                                     (C)

                                                                     (G)
12.  Sponsoring Organization Nam* and Address
    U.S.  Environmental Protection Agency
    401 M Street,  S.W.
    Washington, D.C.   20460
                                          13. Type of Report & Period Covered

                                             800/800
                                          14.
15.  Supplementary Notes

    PB94-964070

16.  Abstract (Limit: 200 words)
  The 16.5-acre Hercules  009 Landfill  site is an  inactive industrial landfill  located in
  Brunswick,  Glynn County,  Georgia.  Land use in  the area is predominantly commercial and
  residential,  with a  shopping mall, bank, and restaurant located approximately 1,000
  feet north  of the site.   From 1948 to  1980, Hercules manufactured toxaphene,  an
  agricultural  pesticide  used to control boll weevils, ticks, and mites on cattle.   Under
  a State permit, Hercules  used seven  acres at the  northern end  of the site, known as the
  009 landfill,  to dispose  of approximately 33,000  yd3 of wastewater sludge  from the
  production  of toxaphene,  empty toxaphene product  drums, and toxaphene-contaminated
  glassware,  rubble, and  trash.  The landfill was constructed as six cells,  which
  reportedly  were lined with a soil bentonite clay  mixture across the bottom and along
  the bermed  walls.  The  thickness of  the toxaphene sludge disposed of in these cells was
  reported  to be six to seven feet.  Typically, the wastewater sludge was disposed of
  directly  in the landfill;  however, occasionally it was staged  near the southeast corner
  of the landfill prior to  disposal.   In 1980, as a result of a  State investigation which
  revealed  toxaphene in soil and water samples from the drainage ditches.around the site,
  Hercules' permit was canceled, and the State ordered the landfill to be closed.  In

  (See Attached Page)
17. Document Analysis    a. Descriptors
   Record of Decision - Hercules  009 Landfill,  GA
   Second Remedial Action - Final
   Contaminated Media:  soil, sludge, gw,  sw
   Key  Contaminants:  VOCs (benzene,  TCE,  toluene, xylenes),  other organics  (dioxin,
                       pesticides),  metals  (arsenic, chromium,  lead)

   b.  Identifiers/Open-Ended Terms
   c.  COSATI Field/Group
18. Availability Statement
                          19. Security Class (This Report)
                                    None
                                                     20.  Security Class (This Page)
                                                               None  •
          21.  No. of Pages
                  72
                                                                               22.  Price
(SeeANSI-Z39.18)
                                   See Instructions on Reverse
                                                   OPTIONAL FORM 272 (4-77)
                                                   (Formerly NTIS-35)
                                                   Department of Commerce

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EPA/ROD/R04-93/144
Hercules 009 Landfill, GA
Second Remedial Action - Final

Abstract (Continued)

1982, EPA banned the use of  toxaphene and site operations ceased.  A 1991 ROD addressed an
interim action for ground  water  by extending the existing municipal water lines, as OU2.
This ROD provides a final  remedy for the site and addresses contaminated soil, debris,
sludge, ground water, and  surface water, as OU1.  The primary contaminants of concern
affecting the soil, sludge,  ground water, and surface water are VOCs, including benzene,
TCE, toluene, and xylenes; other organics, including dioxin and pesticides; and metals,
including arsenic, chromium,  and lead.

The selected remedial action for this site includes conducting a field-scale treatability
study; excavating and transporting the subsurface soil, sludge, and related material in
the staging area with levels exceeding 76 mg/kg of toxaphene, and the surface soil in the
staging area with levels exceeding 0.25 mg/kg of toxaphene to the landfill area; treating
the consolidated surface soil, subsurface soil, and sludge using in-situ stabilization as
an innovative application  to treat organics; covering treated soil and sludge using a clay
multi-media cover; backfilling excavated areas with two feet of clean native fill;
providing for a contingency  remedy to treat the soil and sludge by dewatering the soil and
sludge, onsite ex-situ chemical  extraction, with onsite disposal of the treated material,
based on the results of a  treatability study; monitoring ground water, surface water,
sediment, and air; providing for a contingency remedy to extract and treat contaminated
ground water onsite using  granular activated carbon or another treatment, followed by
onsite or offsife discharge  to a POTW, and offsite disposal of the spent granular
activated carbon, if toxaphene or other chemicals are shown to be migrating offsite or
from their current positions, or contaminants of concern begin to increase over 50% of
their current value, or it does  not seem feasible that the ground~water will naturally
attenuate over time; operating and maintaining the cover for a minimum of 30 years and
possibly abandoning onsite private wells; and implementing institutional controls,
including deed restrictions.  . The estimated present worth cost for this remedial action i'
$9/900,000, which includes an estimated annual O&M cost of $104,000 for 30 years.

PERFORMANCE STANDARDS OR GOALS:

Chemical-specific soil excavation goals are based on attaining the baseline risk equal to
or less than 1x10"^ for toxaphene,  and include surface soil 0.25 mg/kg and subsurface soil
76 mg/kg.  Chemical-specific surface soil goals are based on the risk assessment of 1x10"^
for future land:use, and include alpha-BHC 0.044 mg/kg; arsenic 5 mg/kg; acetone 360
mg/kg; benzene 10 mg/kg; beryllium 0.15 mg/kg; bis  (2-ethylhexyl) phthalate 20 mg/kg;
cadmium 41 mg/kg; carbon tetrachloride 2.1 mg/kg; chlorobenzene 720 mg/kg; chloroform 45
mg/kg; chromium (III) 56 mg/kg;  copper 3,300 mg/kg; dioxin/furans  (TEF) 0.001 mg/kg;
Endosulfan II 1.8 mg/kg; ethylbenzene 3,600 mg/kg; lead 500 mg/kg; manganese 4,900 mg/kg;
mercury 26 mg/kg; methylene  chloride 37 mg/kg; nickel 310 mg/kg; toluene 7,200 mg/kg; TCE
25 mg/kg; toxaphene 0.25 mg/kg;  vanadium 600 mg/kg; xylenes 70,000 mg/kg; and zinc 17,000
mg/kg. Chemical-specific subsurface soil goals are based on the risk assessment of IxlO"6
for future land use, and include acetone 1 mg/kg; alpha-BHC 0.01 mg/kg; arsenic 3,400
mg/kg; benzene 0.06 mg/kg; beryllium 61 mg/kg; bis  (2-Ethylhexyl) phthalate 46 mg/kg;
cadmium 11,000 mg/kg; carbon tetrachloride 0.07 mg/kg; chlorobenzene 1.7 mg/kg; chloroform
0.4 mg/kg;  chromium  (III)  1,000,000 mg/kg; copper 420,000 mg/kg; dioxin/furans  (TEF) 0.14
mg/kg; Endosulfan II 0.29 mg/kg; ethylbenzene 13 mg/kg; lead 500 mg/kg; manganese
1,000,000 mg/kg; mercury 3,400 mg/kg; methylene chloride 0.03 mg/kg; nickel 220,000 mg/kg;
TCE 0.08 mg/kg; toluene 30 mg/kg;  toxaphene 76 mg/kg; vanadium 79,000 mg/kg; xylenes 80
mg/kg; and zinc 1,000,000 mg/kg. Chemical-specific ground water goals for natural
attenuation are based on SDWA MCLs, and include benzene 0.005 mg/1; cadmium 0.005 mg/1;
chromium 0.1 mg/1; manganese 0.05 mg/1; nickel 0.1 mg/1; toluene 1 mg/1; toxaphene 0.003
mg/1; and xylenes 10 mg/1.

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           RECORD OF DECISION



SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
        HERCULES 009 LANDFILL SITE



           OPERABLE UNIT ONE




    BRUNSWICK, GLYNN COUNTY, GEORGIA
              PREPARED BY




  U. S. ENVIRONMENTAL PROTECTION AGENCY




               REGION IV




            ATLANTA, GEORGIA

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                              DECLARATION
                                of the
                          RECORD OF DECISION
                           OPERABLE UNIT ONE
SITE NAME AND LOCATION

Hercules 009 Landfill Site
Brunswick, Glynn County, Georgia


STATEMENT OF BASIS AND PURPOSE

This decision document  (Record of Decision), presents the selected
remedial action for Operable Unit One for the Hercules 009 Landfill
Site, Brunswick, Georgia, developed in accordance with the
Comprehensive Environmental Response, Compensation and Liability Act
of 1980  (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) 42 U.S.C. Section 9601 et sea., and
to the extent practicable, the National Contingency Plan (NCP) 40 CFR
Part 300.

This decision is based on the administrative record for the Hercules
009 Landfill site ("the Site").

The State of Georgia has concurred with the selected-remedy.


ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from the
Hercules site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare or the environment.

DESCRIPTION OF SELECTED REMEDY

This operable unit is one of two for this Site.  This alternative
calls for the design and implementation of response measures which
will protect human health and the environment.  Operable unit one,
which is enumerated by this Record of Decision, addresses the source
areas,  surface water, and groundwater at the Site.  Operable unit two
was enumerated in an Interim Action ROD that was signed by EPA on June
27, 1991.  Operable unit two addressed the off-site threat of future
groundwater contamination by extending the existing municipal water
lines in the City of Brunswick, Georgia to residents that live
adjacent to this Site.

The major components of the selected remedy for operable unit one
include:

•    Conducting a field-scale treatability study and implementation of

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    in-situ stabilization of subsurface soils and consolidated surface
    soils.  This remedy is an innovative application of this
    technology since EPA has minimal information on stabilization of
    manufactured pesticides;

•   Implementation of an ex-situ chemical extraction technology on the
    soils and sludges at the Site (with onsite disposal of the treated
    material) in the event the treatability study concerning the
    stabilization of Site soils and sludges fails to met the required
    standards and therefore will not be effective if implemented;

•   Construction of a cover over the treated soils to reduce rainwater
    infiltration and direct contact with the treated soil.  In
    addition, areas excavated for consolidation of surface soil would
    be graded and covered with two feet of clean, compacted, native
    fill;

•   Long-term monitoring of groundwater,  as well as- surface water and
    sediment in the onsite pond and the adjacent drainage.ditch,  with
    the contingency implementation of a pump and treat system in case
    any of the following occurs:  toxaphene begins to migrate off the
    Hercules property; if the other contaminants of concern are shown
    to be migrating from their current positions; if any levels of the
    contaminants of concern begin to increase over fifty percent of
    their current value; or in case it becomes apparent that onsite
    levels of contaminants in the groundwater will not naturally
    attenuate below MCLs over time;

•   Operation and maintenance of the cover for a minimum of thirty
    years; and

•   Institutional controls for land use and groundwater use
    restrictions.

STATUTORY DETERMINATIONS

The selected remedy is protective of human health and the environment,
complies with federal and state requirements that are legally
applicable or relevant and appropriate to the remedial action, and is
cost-effective.  This remedy satisfies the preference for treatment
that reduces toxicity, mobility, or volume as a principal element.
Finally, it is determined that this remedy utilizes a permanent
solution and alternative treatment technology to the maximum extent
practicable.

Because this remedy will result in hazardous substances remaining
onsite above health-based levels, a review will be conducted within
five years after commencement of the remedial action to ensure that
the remedy continues to provide adequate protection of human health
and the environment.
PATRICK M. TOBIN, ACTING REGIONAL ADMINISTRATOR             DATE

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                          TABLE OF CONTENTS

1.0  Site Location and Description	1

2 .0  Site History and Enforcement Activities	1

3 .0  Highlights of Community Participation	4

4.0  Scope and Role of Operable Units	5

5 .0  Summary of Site Characteristics	5
     5.1  Geology/Soils	._	5
     5 .2  Hydrology	7
     5.3  Surface Water and Sediments	8
     5 .4  Air Monitoring	9

6 .0  Summary of Site Risk	9
     6 .1  Contaminants of Concern	9
     6.2  Exposure Assessment	9
     6 .3  Toxicity Assessment	~	15
     6.4  Risk Characterization	15
     6.5  Environmental Risk	16
     6.6  Cleanup Goals	18

7.0  Description of Alternatives	20
    7.1  Alternative No.  1 - No-Action	24
    7.2  Alternative No.  2 - Pump and Treat	24
    7.3  Alternative No.  3 - RCRA Cap	7".	25
    7.4  Alternative No.  4 - In-Situ Stabilization	26
    7.5  Alternative No.  5 - Chemical Extraction	,	28

8.0  Summary of the Comparative Analysis of Alternatives.	29
    8.1  Overall Protection of Human Health and the Environment...33
    8.2  Compliance With ARARS	34
    8.3  Long-Term Effectiveness and Permanence	40
    8.4  Reduction of Toxicity,  Mobility or Volume By Treatment...43
    8.5  Short-Term Effectiveness	43
    8 . 6  Implementability	45
    8 .7  Cost	48
    8.8  State Acceptance	49
    8 . 9  Community Acceptance	50

 9.0  Summary of Selected Remedy	50

10.0  Statutory Determination	-	58
   10.1  Protective of Human Health and the Environment	59
   10.2  Attainment of ARARs	59
   10.3  Cost Effectiveness	61
   10.4  Utilization of Permanent Solutions	61
   10.5  Preference for Treatment as a Principal Element	61

11.0  Documentation of Significant Changes	62

Appendix A - Responsiveness Summary	63
Appendix B - Concurrence Letter	97

                                  -i-

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                             LIST OF TABLES
Table 6-1
Table 6-2
Table 6-3

Table 6-4
Table 6-5
Table 8-1
Table.8-2
Table 8-3
Table 8-4
Table 8-5
Chemicals of Concern - Sludge and Soil	10
Chemicals of Concern - Groundwater	12
Summary of Cumulative Potential Cancer Risk and Non-
  Carcinogenic Hazard Indices	17
Remedial Action Target Concentrations._.	22
Estimated Volumes of Affected Materials	23
Comparative Analysis of Alternatives	31
Potential Location-Specific ARARs	 .36
Potential Action-Specific ARARs for Selected Remedy	37
Potential Action-Specific ARARs for Contingent Remedies..38
Comparison of Costs	49
                                  -11-

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                            LIST OF FIGURES







Figure 1-1  Area Map for Brunswick, Georgia	2



Figure 1-2  Site Map for the Hercules 009 Landfill Site	3



Figure 5-1  Cross-Section of a Typical Landfill Cell at the Site	7



Figure 6-1  Map of Monitoring Well Locations	~	21



Figure 9-1. Map Showing Locations of Major Areas to be Stabilized...54
                                 -111-

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                           Decision Summary
                          Record of Decision
                           Operable Unit One

                      Hercules 009 Landfill Site
                          Brunswick,  Georgia


1.0 SITE LOCATION AND DESCRIPTION

The Site is located in the eastern portion of Glynn County, Georgia,
approximately two miles south of Interstate 95 and one-half mile north
of the City of Brunswick as shown on Figure 1-1.  Figure 1-2 is a map
of the Site.  The Site is a .16.5 acre property that is bordered by
Georgia State Highway 25 (Spur 25) on the west; an "automobile
dealership on the north; a juvenile slash pine forest on the east; and
several homes, a church, a school, and a strip shopping center to the
south/southeast of the property.  A shopping mall, built in 1985, a
bank, and a restaurant are located approximately 1,000 feet north of
the landfill.  The property is fenced and has only one entrance
through a locked gate.

Seven acres on the north end of the property were operated as an
industrial landfill by Hercules between 1976 and 1980 under'a permit
by the Georgia Environmental Protection Division  (GaEPD).  The permit
allowed for the disposal of wastewater sludge generated from the
production of toxaphene at the Hercules Brunswick Plant.  Six disposal
cells were constructed at the northern end of the property to receive
sludge for disposal.  During its years of operation, the 009 Landfill
was monitored by the GaEPD.

2.0  SITE HISTORY AND ENFORCEMENT ACTIVITIES

Hercules began manufacturing toxaphene, an agricultural pesticide, in
1948 and continued production through 1980.  Toxaphene received
widespread use in the southeastern United States to control boll
weevils as well as mites and ticks on cattle,  until EPA banned its use
in 1982 .  The Site had been used by the State as a borrow pit for soil
during the construction of Spur 25.  Hercules was issued a permit in
1975 by the GaEPD to use seven acres  at the northern end of the
property as a landfill to dispose of  wastewater sludge generated
during the manufacturing processes.

The 009 Landfill was constructed at the northern end of the property
as six cells, each approximately 100  to 200 feet wide (north-south
direction)  and 400 feet long (west-east direction).  The thickness of
the toxaphene sludge in the cells was reported to be six to seven
feet.  Individual cells were reported to be lined with a

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                              Figure 1-1
                    Area Map  for  Brunswick,  Georgia
soil/bentonite clay mixture across the bottom of the cell and along
the bermed walls.

The sludge deposited in the 009 Landfill consisted of very fine
calcareous particulate, diatomaceous earths and finely crushed
limestone material.  Toxaphene adsorbed to this material during
neutralization of by-product hydrochloric acid.  Reportedly, the
wastewater treatment sludge consisted of about one percent toxaphene
by weight and 50 percent solids by weight.  The sludge was transported
to the landfill in bulk by truck.  Trucks hauling material to the Site
reportedly entered the landfill through two entrances, one from
Benedict Road (south side),  the other located along Spur 25 (west
side).  Typically'the sludge was placed directly into the landfill.
However, sludge was occasionally staged near the southeastern corner

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                              Figure 1-2
                     Site Map for the Hercules  009
                             Landfill Site
of the 009 Landfill prior to placement
In addition to the sludge, the 009 Landfill was also used for disposal
of empty toxaphene product drums, and toxaphene contaminated
glassware, rubble, and trash.  Disposal of this material was primarily
limited to Cell 1.  Hercules estimated that approximately 33,000 cubic
yards of sludge had been disposed of in the landfill.  The cells were
covered with a 24 to 30 inches of "stump dirt" mixed with boiler ash.
The term "stump dirt" refers to soil that was entrained on pine stumps
purchased by the Hercules Brunswick Plant for the extraction of resins
and essential oils.

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All cells in the landfill were closed prior to 1983 in accordance with
existing GaEPD Solid Waste Management Regulations.  The final contour
of the top of the landfill has a slope of approximately one percent to
prevent pooling and to minimize infiltration of precipitation.  The
sides of the unit have a slope of about ten percent.   To control
erosion, the earthen cover was seeded with grasses that have proven to
grow well in the Brunswick area.

A drainage ditch is located adjacent to the landfill at the eastern
edge.  To control surface runoff from the surrounding area, Glynn
County periodically excavates the sediments from this ditch to ensure
adequate drainage capacity.  Prior to 1988, sediments from the ditch
were stockpiled on the eastern bank of the ditch, but in early 1988,
these sediments were removed.

During its operation, the landfill was inspected by GaEPD.  In March
1980, GaEPD collected soil and water samples from drainage ditches
around the Site.  The samples contained toxaphene.  As a result, GaEPD
canceled Hercules' permit and the 009 Landfill was closed under a plan
approved by GaEPD.

EPA calculated a Hazard Ranking Score for the closed landfill.  In
1984, the landfill was placed on the National Priority List (NPL).  As
of July 1, 1991, the Hercules 009 Landfill Site ranked 152 out of 1072
on the NPL (excluding federal facilities).  GaEPD began negotiations
with Hercules to perform an RI/FS and initiated Site investigation
activities under State Superfund authority, then withdrew as lead
agency in 1987.  EPA assumed primary control of the Site investigation
and related activities at the end of 1987.  Hercules and EPA entered
into an Administrative Order on Consent in July 1988.  The Consent
Order required Hercules to perform a Remedial Investigation
/Feasibility Study (RI/FS) of the Site.


3.0  HIGHLIGHTS OF COMMUNITY PARTICIPATION

The main branch of the Brunswick-Glynn Regional Library at 208
Gloucester Street in Brunswick, Georgia was chosen as the local
information repository for the Site.  A public comment period for the
proposed plan for operable unit #2  (concerning extension of the
municipal water lines) was held from May 13, 1991 to June 12, 1991
with a public meeting being held on May 15, 1991.

The public comment period on the proposed plan preceding this ROD
(operable unit #1) was held August 27, 1992 through October 27, 1992.
A public meeting was held on Thursday, September 10,  1992 where
representatives from EPA answered questions from approximately 150
people regarding the Site and the proposed plan under consideration.
The administrative record was available to the public at both the
information repository maintained at the Brunswick-Glynn Regional
Library and at the EPA Region IV Library at 345 Courtland Street in
Atlanta, Georgia.  The notice of availability of these documents was

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published in the Brunswick News-Herald on August 24, and September 4,
1992.  EPA received numerous oral and written comments during the
comment period.  Responses to the significant comments received are
included in the Responsiveness Summary, which is part of this ROD and
designated Appendix A.

This decision document presents the selected remedial action for
operable unit one of the Hercules site, chosen in accordance with
CERCLA, as amended by SARA and to the extent practicable, the NCP.
The decision for this Site is based on the administrative record.  The
requirements under Section 117 of CERCLA/SARA for public and state
participation have been met for this operable unit.

4.0  SCOPE AND ROLE OF OPERABLE UNITS

EPA has organized the work at this Superfund Site into two operable
units  (OUs).  These units are:

•   OU one:    The source area at the Site, including the landfilled
              sludge, the soils in the sludge-staging area, and the
              Benedict Road/Nix Lane area.  Contamination in the
              groundwater, surface water, sediment, and soils are
              addressed in OU #1.  Proper abandonment of the private
              wells replaced during OU #2 is included in OU #1 if the
              owners will allow abandonment.

•   OU two:    The extension of municipal water lines to residents
              adjacent to the Site was specified in OU #2 to address
              the threat of a groundwater plume that could affect
              residential drinking wells downgradient of the Site.

OU #1 addresses both the source of contamination in the soils as well
as the groundwater contamination underneath the Site.  The purpose of
this operable unit is to monitor groundwater restoration, treat the
source areas at the Site, prevent current or future exposure to the
contaminated soils and groundwater, and reduce contaminant migration.
OU #1 will be consistent with the actions taken during OU #2, to the
extent practicable.  The Record of Decision (ROD) governing OU #2
dated June 27, 1991 erroneously was titled OU #1.  However, the ROD
dated June 27, 1991 documents the remedial action selection for OU #2.
This ROD documents the remedial action selection for OU #1.

5.0  SUMMARY OF SITE CHARACTERISTICS

5.1  GEOLOGY/SOILS

The results of the RI led to the following findings and conclusions:

•   The Site lies in the Atlantic Coastal Plain province of Georgia.
    Surface sediments are described as relatively thin layers of
    sands, gravels, and clays of Pleistocene age.  These sedi.uents,
    generally less than 150 feet thick, represent the surficial layer.

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Beneath the surficial layer are Miocene sediments which are
represented by the Hawthorn formation.  The Hawthorne contains
several clay units and is a confining zone between the surficial
water-bearing unit and the deeper Floridan aquifer.  The Floridan
aquifer, at an approximate depth of 500 feet, is separated from
the surficial water-bearing unit by approximately 400 feet of the
Miocene sediments.  The Floridan aquifer is the primary aquifer in
the area for large irrigation and municipal supplies, while
shallower wells are used for small domestic supplies.

Soils at the Site consist of coarse to clayey sands, sandy silts,
and sandy to silty clays.  The soils can be grouped into three
distinct hydrogeologic components.  From land surface to depths of
25 to 45 feet below land surface is a zone compo'sed of silty sands
and sandy silts.  Underlying this zone is a clayey sand and sandy
clay interval ranging in thickness from 10 to 25 feet.  The clayey
interval may possibly act as a semi-confining unit within the
surficial layer dividing the silts and sands into shallow and deep
zones beneath the Site; however, the continuity of this unit to
the west side of the landfill is not completely defined due to
limited drilling on the upgradient (west)  side of the landfill.
The material that immediately underlies the clayey zone,
representing the third unit,  is composed of sands and silty sand
to approximately 85 feet below land surface, where a change to a
coarse sand containing gravel is noted.

Site-specific permeability values ranged from 4xlO"5  centimeters
per second to 9xlO"5 centimeters per second and correspond to the
shallow zone of the surficial water-bearing unit.

Toxaphene concentrations in the soils surrounding the landfilled
sludge ranged from below the detection limit to 4,900 ppm.
Concentrations of toxaphene were generally highest in the vicinity
of the landfill cells and decreased with distance from the cells.
An exception was an area near the Benedict Road/Nix Lane entrance
to the. Site.  Toxaphene concentrations of 26 ppm to 92 ppm in this
area may be the result of sludge transportation to the landfill.

Toxaphene was detected in landfilled sludge samples at
concentrations ranging from 850 to 15,000 ppm.  The average sludge
concentration of toxaphene is 6,000 ppm.

Acetone, carbon tetrachloride,  chlorobenzene, chloroform, and
xylenes were detected in the landfilled sludge samples, but were
not consistently present.  No volatile organic constituents (VOCs)
were detected in samples from cells 3, 4,  and 6.  One or more VOCs
was detected in samples from cells 1, 2, and 5.

Arsenic, chromium, copper, lead, manganese, nickel, vanadium,  and
zinc were detected in sludge samples.  Of these metals, only
copper and lead exceeded typical background concentration ranges.

Dioxins and furans were detected in all of the sludge samples.

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    When evaluated based on the Toxicity Equivalence Factor (TEF), by
    which the  concentrations of all isomers are  adjusted by their
    toxicity relative to the 2,3,7,8-TCDD isomer,  the concentrations
    ranged  from 3.2 x 10~5 to 3.9 x 10'4 ppm.   These concentrations
    exceeded background concentrations, but were less than the action
    level of 1 x lO'3
ppm.
5.2  Hvdroqeoloqy
    Groundwater  in the shallow zone of the surficial  water-bearing
    unit flows toward the east at a seepage veloci-ty  of 60 to 90 feet
    per year.  Groundwater in the lower zone  flows  toward the
    southeast at.a seepage velocity of 45 to  65  feet  per year.

    Surface elevations at the Site range from 13  to 26  feet mean sea
    level  (MSL).   Water table elevations at the  site  range from 14 to
    17 feet MSL.

    Interpretation of data obtained during the drilling of boreholes
    into the landfill and from piezometer water  levels  suggest the
    following:   water is perched above the sludge;  saturated sludge
    exists within the landfill cells; and there  is  an unsaturated zone
    beneath the  sludge at least part of the year in portions of the
    landfill.  Figure 5-1 illustrates a typical  landfill cell cross-
    section.   The saturated conditions within the  sludge are due to
    the absence  of a  clay cap on the landfill, the  low  permeability
    (7xlO~7 cm/sec) of the sludge material, and the  bentonite layer
    beneath the  sludge.
       WEST
                                                            EAST
                                                          r—MOMTORMQ
                                                          \ WELL
                                                   • ••—-.--•-.••*•_•».:;^*•.*•**•'.•• ^.^-t^i'-z* ^

                                                  OF BORROW PIT EXCmwnON (AS
                                                  BV TMP ancPMVORAi Bmojruav
                        .BOTTOM OF BORROW PIT EXCmwnON (AS
                        DBWED BY THE OOEWYSICAL BOUNDARY)
                       sot
         WATER TABLE
         PERCHED WATER
                               Figure 5-1
         Cross-Section of a Typical Landfill Cell  at  the Site

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•   Private water supply wells located near the Site have been sampled
    annually by Hercules since 1985.   Toxaphene has not been detected
    above instrumentation quantification limits in the private wells.

•   Groundwater elevations at the Site exhibit minor cyclical
    fluctuations that may be attributable to the tidal cycle.
   . However, tidal influences are insufficient to affect basic
    groundwater flow patterns.

•   Toxaphene has been detected in four monitoring wells all located
    at the-southeastern corner of the landfill at concentrations
    ranging from 0.0056 ppm to 0.076  ppm.  During the latest round of
    sampling, only one well indicated toxaphene contamination,
    measured at 0.069 ppm.

•   Both nickel and benzene have been detected aL-ove MCLs in
    groundwater samples collected adjacent to the landfill.

5.3  Surface Water

•   Surface drainage occurs by overland flow at the Site.  The flow at
    the Site is divided by the crest  of the landfill with both
    westward flow toward Highway Spur 25 and eastward flow toward the
    drainage ditch located immediately east of the Site.  The drainage
    along Spur 25 flows through a 36-inch culvert which connects to
    the drainage ditch on the eastern side of the Site. . This culvert
    transverses the Site immediately  south of the landfill cells.

•   Surface drainage from the Glynn Place Mall (approximately 1000
    feet north of the Site)  enters the east drainage ditch upstream of
    the Site.  The pond at the southern end of the Site receives
    runoff only from the immediate area surrounding the pond, and has
    no permanent surface inflow or outflow.  This onsite pond is
    believed to have been formed during the construction of Spur 25 as
    a borrow pit.

•   The water table is generally close to the bottom of the drainage
    ditch, and groundwater flow from underneath the landfill may
    seasonally discharge into the drainage ditch.  The water table
    configuration is, however,  based  on a single set of water table
    elevations from a single date. Nevertheless,  this data indicates
    that the water table would provide only minor discharge to the
    drainage ditch located immediately east of the Site.

•   Surface water and sediment samples were collected in the onsite
    pond and in the off-site drainage ditch.  Samples in the drainage
    ditch were collected both alongside the Site and over a mile away
    from the Site in the estuary.  Toxaphene was not detected in any
    surface water samples.  However,  toxaphene was detected at a
    maximum of 0.86 ppm in two sediment samples adjacent to the Site.


                                   8

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Dried Stales

Environmental Protection

Aflency
Office of
Emergency and
Remedial Response
EPA/ROORCM-90/065
June 1990


 CoPV/
Superfund
Record of Decision:


Harris/Palm Bay Facility, FL
                                   legion 3
                              Philadelphia, PA 19107

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50272-101
REPORT DOCUMENTATION 1. REPORT MO. J-
PAGE EPA/ROD/R04-90/065
4. TM*md8uMM>
SUPERFUND RECORD OF DECISION
Harris/Palm Bay Facility, FL
First Remedial Action
7. Auftor(i)
9. Ptrfeimfcig OrgcMzrion Nwra and Addraw

U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
X B»cipt«nf « Acc«««ion Mo.
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06/28/90
i
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 The 345-acre  Harris/Palm Bay Facility site is an electronics manufacturing  company in
 Palm Bay, Brevard County,  Florida.  Surrounding land use is commercial,  residential,
 and industrial.   The site overlies an unconsolidated aquifer, which  is used by a public
 wellfield located south of and downgradient of the site.  From the 1950s  to 1967,  the
 site was operated by an electronics firm when Harris Corporation  purchased the
 facility.  Current facility operations are subdivided into the Government Systems
 operations area  and the Semiconductor Complex area.  In 1981, EPA identified VOCs in
 ground water  wells located south of the Government Systems facility.  Ground water
 contamination was attributed to several onsite incidents at the Government  Systems
 plant including  two fires,  which resulted in the dumping of chemical vats,  a broken
 acid/solvent  line,  and spillage at drum storage areas.  Seepage from two  former
 treatment lagoons may also be a source of a shallow contaminant plume.   In  1985,  Harris
 constructed a treatment facility to implement an onsite ground water treatment and
 monitoring program which is still in operation.  This Record of Decision  (ROD)
 addresses ground water contamination at the Government Systems facility.  A subsequent
  (See Attached  Page)
 17. Do
    Record of Decision - Harris/Palm Bay Facility, FL
    First Remedial Action
    Contaminated Medium:  gw
    Key Contaminants:  VOCs (TCE), metals  (chromium, lead),  other inorganics

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                                                                           (Fonmrty MTO48)
                                                                                   272 (4-77)

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EPA/ROD/RO4-90/065
Harris/Palm Bay Facility, FL
First Remedial Action

Abstract  (Continued)

ROD will address the contaminated ground water at the Semiconductor Complex and all of
the contaminated onsite soil.  The primary contaminants of concern affecting the
ground water are VOCs including TCE; metals including chromium and lead; and other
inorganics including fluoride.

The selected remedial action for this site includes continued ground water pumping and
treatment using air stripping to remove VOCs; using the treated ground water as
industrial process water then reinjecting the treated ground water onsite into a deep
aquifer; and evaluating and modifying the existing ground water monitoring program to
fully characterize onsite contamination.  The estimated present worth cost for this
remedial action is $1,430,000, which includes a total O&M cost of $950,000 for five
years.

PERFORMANCE STANDARDS OR GOALS:  The goal of this remedial action is to restore the
aquifer to its beneficial use.  Cleanup standards were chosen as the more stringent of
State or Federal SDWA standards.  Chemical-specific ground water goals include TCE
5 ug/1  (MCL),  chromium 50 ug/1 (MCL), and lead 15 ug/1 (proposed MCL).

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                             RECORD  OF  DECISION
                                DECLARATION
Site Name and Location;

Harris Corporation/Palm Bay Facility
Palm Bay, Brevard County, Florida
Statement and Basis of Purpose;

This decision document represents the selected remedial action for the
Harris Corporation/Palm Bay Facility site developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act of
1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization
Act of 1986 (SARA) and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP).

This decision is based upon the contents of the administrative record for
the Harris Corporation/Palm Bay Facility site.

The United States Environmental Protection Agency and the State of Florida
agree on the selected remedy.
Assessment of the Site;

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 a current or potential threat to public
health, welfare, or the environment.
Description of Remedy;

The first operable unit defined for this site is the contaminated
groundwater associated with the Harris Corporation Government Systems
facility.  Through treatment and engineering controls, this operable unit
remedy eliminates or reduces the risks associated with the site due to
exposure to contaminated groundwater via the public water supply.

The major components of the selected remedy include:

      continued operation of the existing extraction, treatment, and
      disposal system;

         - extraction of contaminated groundwater from the surficial
           aquifer

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            treatment of the extracted groundwater by air stripping the
            volatile organic compounds

            injection of the treated groundwater into the deep Floridan
            Aquifer, which is not a source of potable water in the area
     *  a design analysis to determine the effectiveness of the existing
       system for plume containment and treatment

     '  modification of the system based on results of the design analysis

     0  continued sampling in order to monitor progress of the cleanup

     '  a review of the site within five years after initiation of remedial
       action in order to ensure protectiveneas of the remedy


 Statutory Determinations;

 The selected remedy is protective of human health and the environment,
 complies with Federal and State requirements that are legally applicable
 or relevant and appropriate to the remedial action,  and is
 cost-effective.  This remedy utilizes permanent solutions and alternative
 treatment (or resource recovery) technologies to the maximum extent
 practicable and satisfies the statutory preference for remedies that
 employ treatment that reduces toxicity, mobility, or volume as a principle
 element.  As this remedy will initially result in hazardous substances
 remaining on-site above health-baaed 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.
                                                      « 2 8 «»
Greer C. Tidwcll, Regional Administrator  x         Date

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         Record of Decision

        The Decision Summary
Harris Corporation/Palm Bay Facility

              NFL Site

  Palm Bay,  Brevard  County,  Florida
            Prepared by:
U.S. Environmental Protection Agency
              Region  IV
          Atlanta, Georgia

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                             TABLE OF CONTENTS

1.0  Introduction	1
     1.1  Site Name, Location, and Description	1
     1.2  Site History and Enforcement Activities	5
     1.3  Community Participation	8
     1.4  Scope and Role of Operable Units	8

2.0  Summary of Site Characteristics	9
     2 .1  Site Contaminants	9
     2 .2  Geology	13
     2.3  Hydrogeology	13

3.0  Summary of Site Risks	19
     3.1  Identification of the Contaminants of Concern (Indicator
          Chemicals)	19
     3.2  Exposure Assessment Summary	20
     3.3  Toxicity Assessment Summary	22
     3.4  Risk Characterization	23
     3. 5  Environmental Risks	27

4.0  Description of Alternatives	27
     4.1* Alternative 1 - No Action	27
     4.2  Alternative 2 - Continued Operation of the Groundwater
                          Extraction and Treatment System with Deep
                          Well Injection	28
     4.3  Alternative 3 - Modification of the Groundwater Extraction
                          and Treatment System	1	32
     4.4  Alternative 4 - Disposal via Spray Irrigation	34
     4.5  Alternative 5 - Disposal via Percolation	35
     4.6  Alternative 6 - Disposal via Reinjection to the Surficial
                          Aquifer	37

5.0  Summary of Comparative Analysis of Alternatives	40
     5.1  Overall Protection of Human Health and the Environment	40
     5.2  Compliance with Applicable or Relevant and Appropriate
          Requirements (ARARs)	41

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     5.3  Long-Term Effectiveness and Permanence	45
     5.4  Reduction of Toxicity, Mobility,  or Volume Through Treatment..45
     5 . 5  Short-Term Effectiveness	47
     5 . 6  Implementability	47
     5. 7  Cost	48
     5 .8  State Agency Acceptance	49
     5.9  Community Acceptance	49

6.0  Selected Remedy	49

7.0  Statutory Determinations	51
     7.1  Protection of Human Health and the Environment	51
     7.2  Compliance with Applicable or Relevant and Appropriate
          Requirements (ARARs)	52
     7.3  Cost-Effectiveness	52
     7.4  Utilization of Permanent Solutions and Alternative Treatment
          Technology or Resource Recovery Technologies to the Maximum
          Extent Practicable	52
     7. 5  Preference for Treatment as a Principle Element	53
                              LIST OF FIGURES

Figure 1 - Site Location Map	2

Figure 2 - Site Layout Map	4

Figure 3 - Government Systems Soil Sample Locations	6

Figure 4 - Isopleths of Average 1988 Total VOC Concentrations,
           40-Foot Zone	10

Figure 5 - Isopleths of Average 1988 Total VOC Concentrations,
           80-Foot Zone	12

Figure 6 - Generalized Geologic Column	14

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Figure 7 - Water-Level Elevations, 40-Foot Zone	17

Figure 8 - Water-Level Elevations, 80-Foot Zone	13
                               LIST OF  TABLES

Table I   - Sampling Data for Groundwater Contaminants of Concern at
            Government Systems	21

Table II  - Reference Doses  (RfD)  and Cancer Potency Factors (q*) for
            Constituents Detected  at Government Systems	24

Table III - Risk Characterization  for Groundwater Contaminants at
            Government Systems	26

Table IV  - Aquifer Cleanup Levels Specified in the FDER/Harris Consent
            Order	29

Table V   - Government Systems Groundwater Remediation Goals	46
                             LIST OF APPENDICES

Appendix A - Reports on Previous Investigations Conducted at the
             Government Systems Facility	54

Appendix B - Underground Injection Control Class I Permit Injection
             Limits	57

Appendix C - National Pollutant Discharge Elimination System Permit
             Discharge Limits	60

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                             RECORD OF  DECISION
                            THE  DECISION  SUMMARY
                    HARRIS  CORPORATION/PALM  BAY  FACILITY
                              OPERABLE UNIT I
                     PALM BAY, BREVARD COUNTY, FLORIDA
1.0  Introduction

The Harris Corporation (Harris) site was proposed for inclusion on the
National Priorities List (NPL) in April 1985.  The Harris site has been
the subject of numerous investigations performed by the responsible party,
Harris Corporation, under an Administrative Order on Consent with the
State of Florida that was signed in December 1983.  These previous
investigations include:  1) studies of affected groundwater, including
geologic and hydrogeologic studies; 2) studies of affected soils;
3) evaluation of methods of remediation and treatability; and
4) investigations assessing the ongoing remediation program.
1.1  Site Name, Location, and Description

The Harris Corporation/Palm Bay Facility site is located on 345 acres
along Palm Bay Road in Palm Bay, Brevard County, Florida [Figure 1].  The
site consist* of groundwater and soils contamination associated with
Harris Corporation including the groundwater plumes extending from Harris
onto the adjacent property owned by General Development Utilities (GDU).

Harris Corporation manufactures electronic components as well as
communication and information processing equipment.  There are two major

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operating divisions, the Government Systems (now called Electronic
Systems) and the Semiconductor Complex.  Harris acquired a third area,
Building 100, in 1970.

GDU, a subsidiary of General Development Corporation, provides the public
water supply and "sewage treatment and disposal for at least 33,000
residents of Palm Bay.  The GDU well field consists of 25 producing
wells.  A number of these wells are located directly south of, and
downgradient from, the Government Systems facility.

Harris Corporation has been operating the Government Systems facility in
Palm Bay since 1967.  Harris purchased Radiation Corporation, an
electronics firm supporting the space industry, which operated at the site
from the 1950's to the early 1960's.  All expansion from the original
buildings has been onto undeveloped property with the exception of
Building 100.  Two previous manufacturing firms (Sorban and Mohawk Data
Services) operated at Building 100 and used the site for painting
operations, a chromium plating operation, a machine shop, and a drum
storage area.

The Harris site is surrounded to the east, west, and north primarily by
commercial and other industrial-zoned properties which in turn are bounded
by residential properties.  A municipal park, known as Knecht Park, lies
east of the site.  Site usage is not expected to change.

The significant surface features present include several small bodies of
water on the Harris property/ a pond in Knecht Park, and Turkey Creek
[Figures 1 & 2].   The Harris ponds are primarily used for stormwater
retention, although some are used for irrigation.  The site is within the
drainage basin of Turkey Creek and its tributaries which lie to the
southwest, south, and southeast.  Stormwater runoff that is not retained
on-site is discharged to the municipal stormwater drainage system and
eventually into Turkey Creek.

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                                  HARRIS  CORPORATION
                                    SUPERFUND  SITE
                            Palm  Bay, Brevard  County,  Florida
SITE   LAYOUT    MAP

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1.2  Site History and Enforcement Activities

In 1981, the EPA sampled GDU production wells which lie south of Harris
Government Systems facility as part of a nationwide survey of groundwater
quality.  In March 1982, the EPA reported to the Florida Department of
Environmental Regulation (FDER) that numerous volatile organic compounds
(VOCs) were detected in six GDU production wells.  Harris confirmed the
presence of VOCs in monitor wells on the Government Systems property in
1982.  Harris entered into a Consent Order with FDER (OGC Case No.
82-0582) in December 1983 with Amendments in January, 1984 and October,
1984.  Harris agreed to conduct a groundwater investigation to determine
the extent of chemical impacts and to develop and implement a groundwater
restoration program.  Since entering into this agreement, Harris, with
FDER oversight, has conducted numerous investigations, installed 134 wells
at Government Systems, and conducted groundwater sampling.

Although not all incidents involving the release of hazardous substances
have been identified, some contributing events are known.  Two fires
occurred in the northeast corner of Building 6, one in 1967 and another in
1974.  Chemical vats were dumped by the fire department and flushed out
through holes which were broken into the floor of the building.  The
volume of chemicals released in these two incidents is unknown.

Several possible source areas have been identified at Harris based on
knowledge of past operating and handling practices.  The volume of
materials released is not known.  From 1968 to 1970, storage drums
containing paints, solvents and similar materials were stored in the area
of the northeast corner of Building 6 and along the western sides of
Building* 10 and 11.  In the late 1960's an acid and solvent line between
Building 6 and a metal-finishing waste treatment plant apparently leaked.
As a result, source areas may include the stormwater drain extending from
this area eastward to the drainage swale along Perimeter Road and to two
former treatment lagoons located in the southeast corner of the site
[Figure 3].

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0    SUSPECTED  POSSIBLE CHEMICAL SOURCE LOCATION
                                                                                 *CO
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                        GOVERNMENT SYSTEMS SOL SAMPLE LOCATIONS
                                       Figure 3

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In addition, Building 5 ia located on the former site of two
neutralization lagoona that were cleaned out in 1980.  A neutralization
ditch was located south of these lagoons which conveyed water to the two
treatment lagoons already mentioned.  East of Building 15 is an area
suspected to be the location of an old trash site.  The old pump and lift
stations are also potential sources of contamination.  More recently,
Harris documented a 1986 acid line leak in the area of Building 4.

The estimated VOC plume configurations indicate that the major source area
is probably near Building 6.  Therefore, the major sources may be the
fires, broken solvent line, and drum storage areas near Building 6.  The
treatment lagoons previously located near Building 5 may be a source for
the shallow plume in that area.

The Harris Corporation site was proposed for the National Priorities List
(NPL) on April 1, 1985, and became a final NPL site on July 1, 1987.  EPA
issued a general notice letter to Harris Corporation on April 6, 1989,
notifying Harris of its potential liability under the Comprehensive
Environmental Response and Liability Act of 1980  (CERCLA).  This notice
letter was issued pursuant to Section 104 and other provisions of CERCLA
as amended by the Superfund Reauthorization Act (SARA). In this notice
letter, EPA recognized the remedial efforts taken by Harris Corporation at
the site* in compliance with the Consent Order executed between Harris and
the State of Florida.

FOER elected to assume management of enforcement  activities at the site
due to this existing agreement.  EPA has provided technical support by
reviewing site documents including the sampling and analytical results.

Previous investigations conducted by both Harris  and GDU have included
studies assessing the nature and extent of chemical impacts on the
groundwater and soils, methods of remediation, and assessments of the
ongoing remedial action.  Appendix A lists the reports for studies that
have been conducted to perform Contaminant Assessment Plan and Feasibility
Study activities.

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1.3  Community Participation

The EPA Proposed Plan for the Harris Corporation site was released to the
public in March, 1990.  This Proposed Plan, along with technical reports
prepared by Harris relating to Contaminant Assessment Plan and Feasibility
Study activities, was placed in the Administrative Record.  The decision
for this site is based on documents found in the Administrative Record.
The Administrative Record is located in an information repository
maintained in each of two locations:  the EPA Records Center in the Region
IV office in Atlanta, Georgia, and the Palm Bay Public Library in Palm
Bay, Florida.  The notice of availability for these documents was
published in the Florida Today newspaper on March 18, 1990.  EPA mailed a
fact sheet on March 16 to each person on the site-related mailing list.
On March 23, EPA issued a press release announcing the public meeting,
comment period, and document availability.

A 30 day public comment period was held from March 18, 1990 through April
17, 1990.  In addition, a public meeting was held on March 27, 1990 in
Palm Bay.  At this meeting, representatives from EPA and FDER presented
information and answered questions about the problems at the site and the
actions taken to date.  EPA responses to the comments received during this
period are included in the Responsiveness Summary, which is part of this
Record of Decision.
1.4.  Scope and Role of Operable Units

As with many Superfund sites, the problems at the Harris Corporation site
are complex.  Therefore, EPA has divided the Harris site into a minimum of
two operable units (OUs) for better management of the response activities.
These operable units are:

     OU One:  Contaminated groundwater associated with Government Systems

     OU Two:  Contaminated groundwater at the remainder of the site
              (including the Semiconductor Complex and Building 100) as
              well as contaminated soils at the entire site

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This Record of Decision addresses only Operable Unit One,  contaminated
groundwater associated with the Government Systems facility.   Under
oversight from PDER, this operable unit is currently in remediation using
a groundwater treatment system.

Remediation of th'e groundwater at the Semiconductor Complex is scheduled
to begin in late 1990, also under FDER oversight.  Additional soil
sampling to identify contaminant source locations along with treatability
studies may be necessary as part of Operable Unit Two.  Any interim
actions will be consistent with any planned future actions.
2.0  Summary of Site Characterization

The chemical characterization of groundwater for Operable Unit One at the
site has been studied and monitored since 1984.  Appendix A lists the
studies conducted by both Harris and GDU which provide documentation
concerning the nature and extent of chemical impacts upon the aquifer.
2.1  Site Contaminants

Contaminants identified at the Government Systems facility can be divided
into four categories:  volatile organic compounds (VOCs), acid extractable
organics (AEOs), metals, and fluoride.  These contaminants are associated
with processes conducted at Government Systems.
                                    VOCs
The contamination has been approximated vertically and horizontally and is
tracked by a network of monitor wells.  Two significant, affected
groundwater zones have been identified in the Government Systems area:
the 40-foot zone and the 80-foot zone.  There are two VOC plumes
identified in the 40-foot zone [Figure 4].  One plume lies near Building 5
at the eastern edge of the site in the vicinity of the old stormwater
drain outfall and treatment lagoons.  The other plume is located near

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                                                                               HARRIS CORPORATION GOVERNMENT  SYSTEMS

                                                                            BOPLETHS OF AVERAGE 1988 TOTAL VOC CONCENTRATIONS

                                                                                                 40-FOOT ZONE

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                                     11
Building 6.  The VOC plume in the 80-foot zone of the leaky artesian
aquifer extends from the area near Building 6, and continues
south-eastward toward and across the southeast boundary of the Harris
property [Figure 5].
                                    AEO8
Harris conducted testing for acid extractable organics (AEOs) in
groundwater from. 90 wells across the site after trace levels of phenols
were detected.  Subsequent analyses showed the level of AEOs to be below
detection limits except for a phenol concentration of 20 ug/1 in a sample
taken in 1986 from Well GS-37S, one of the Harris extraction wells.
                                  Metala
Metals above the EPA and Florida Maximum Contaminant Levels (MCLs) were
detected in some shallow well-point samples collected during
reconnaissance testing in 1986 around Building 6.  Chromium and lead were
the metals of primary concern.  Subsequent groundwater sampling of
permanent monitor wells at Harris shows these and other metals (cadmium,
silver, and mercury) to be below detection limits.  As a result,
monitoring wells are no longer routinely sampled for metals.

                                  Fluoride

Shallow well-point samples delineated an area of elevated fluoride
immediately west and south of Building 4.  Harris performed a follow-up
study which found one well (GS-M14) with significantly high fluoride
levels (6.64-6.68 mg/1).  In order to detect any migration of fluoride,
monitoring for this compound also occurs in the surrounding wells.
Fluoride has been detected in groundwater only at the 15-foot depth, not
the 40- and 80-foot depths.  There is insufficient evidence to conclude
that fluoride is moving laterally or vertically with the groundwater.

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•8
S
            LEGEND
                  HARRIS CORPORATION UONIIOR WHIL



                  ISOPUTM OF AVIRAU 1988 1OIAI VOC'S (PARIS PER BIUIUN)
                                                                             HARRIS CORPORATION GOVERNMENT SYSTEMS

                                                                          BOPLETHS OF AVERAGE 1968 TOTAL VOC CONCENTRATIONS

                                                                                               80-FOOT ZONE

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                                     13
2.2  Geology

Physiographically, the Harris site is on the Atlantic Coastal Ridge, part
of the Pamlico Terrace.  This surface is a relict beach ridge thought to
have formed about 125,000 years ago (late Pleistocene) when sea level was
approximately 25 fco 30 feet above the present level.  Land surface
elevation at Harris is approximately 19-22 feet above sea level.

The subsurface geology of coastal Brevard County is relatively uniform.
The Harris site is located in an area where the surficial deposits are
unconsolidated sediments approximately 110 feet deep.  These deposits are
comprised (in descending order) of undifferentiated Holocene sediments,
the Fort Thompson and Anastasia Formations of Pleistocene age, and Tamiami
Formation of Pliocene age.  These sediments are relatively flat-lying,
fine to medium grained sand layers containing variable amounts of clay,
shell fragments, carbonate and organic material.  The clay layers are
discontinuous and occur intermittently.  Several distinct layers of
reddish-brown, sandy silts are found in the upper 40 feet of sediments.
At depths between 4 and 12 feet, a hardened silt layer is found that has
been referred to as a "hardpan".

Underlying the upper surficial deposits, starting at about 90 to 110 feet,
are clay layers of the Miocene age Hawthorn Formation.  This formation is
comprised of clayey silts and sands, phoephatic sediments and limestone,
and is between 100 and 200 feet in total thickness.  Below the Hawthorn
Formation, from about 330 to 1920 feat below land surface, the
stratigraphic section is dominated by interbedded limestones and dolomites
of the Eocene age Ocala Limestone, Avon Park Formation and Lake City
Limestone.  Underlying this section is the Oldsmar Formation of Lower
Eocene age extending to a depth of approximately 2640 feet which is also
dominated by limestone and dolomite units.  Figure 6 shows a generalized
geologic column for the site.
2.3  Hydrogeology

Both Harris and GDU have completed studies on the characterization of the

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                                      14

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                         HARRIS CORPORATION
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                                     15
hydrologic properties of the subsurface sediments.  These studies include
direct measurement of hydrologic conductivity by laboratory analysis of
water flow through core samples as well as indirect calculation of the
estimated permeability based on particle size analysis.  Harris conducted
aquifer tests at Government Systems in addition to the aquifer tests
performed as part of the development of the GDU wellfield.  Geophysical
investigations of the permeability and stratigraphy of subsurface layers
have been completed using electro-magnetic, resistivity, and
ground-penetrating radar surveys.  Pump tests show how the pumping at GDU
affects the aquifer.  In addition, several studies characterize the
potentiometric surface from water level measurements.

An unconfined water table aquifer lies in the upper portion of the
surficial unconsolidated deposits to a depth of approximately 40 to 60
feet.  At that depth, a relatively low-permeability (3 gpd/ft ) dominant
clay layer containing fine sand and shell separates it from a lower, leaky
artesian aquifer.  This lower artesian aquifer extends to a depth of
approximately 90 to 110 feet and is underlain by impermeable clay layers
of the Hawthorn Formation.

The transmissive aquifer layers are dominated by shell hash containing
variable amounts of sand and clay [Figure 6].  The estimated average
transmissivity of the unconfined water table aquifer is 3420 gpd/ft.  The
clay layer lying between the two aquifers has an estimated average
transmissivity of only 24 gpd/ft.  This clay layer acts as an aquitard for
downward migration of groundwater.  (Estimated transmissivities of the
lower zone of high permeability leaky artesian aquifer range from 7600 to
15800 gpd/ft in this area.)  The lower zone of high permeability is about
20 to 40 feet thick and lies at depths of about SO feet.  This zone is the
principal water-producing zone from which water supplies are drawn by
GDU.  Below the lower shallow aquifer are impermeable clay layers of the
Hawthorn Formation which form an aquiclude below the production zone and
separate this shallow aquifer from the confined Floridan Aquifer below.

The Floridan Aquifer exists under artesian conditions in the area with
potentiometric levels above land surface.  As a result, there is no

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                                     16
recharge to the Floridan Aquifer from the surficial aquifer.  The FLoridan
Aquifer iiea within the limestones and dolomites of the Ocala Group,  Avon
Park Formation and the Oldsmar Formation.  Water level measurements in
wells completed in the surficial aquifer (including the water table and
leaky artesian aquifers) establish that the potentiometric surface (water
level contour) La at shallower depths on the north side of Harris than on
the south side.  Baaed on these water level measurements, a hydraulic
gradient exists across the Harris site toward the south and southeast
[Figures 7 & 8].

Field tests done with GDU wells pumping and then with the wells turned off
demonstrate that the potentiometric surface and hydraulic gradient are
significantly influenced by pumpage of the GDU production wells located
south and southeast of the site.  Under static conditions (i.e., GDU
production wells turned off), the hydraulic gradient in the production
zone (leaky artesian aquifer, 80-foot zone) was estimated to be about
0.004 ft/ft (about 20 ft/mile).  With the GDU wells pumping, the hydraulic
gradient averages 0.01 ft/ft (about 50 ft/mile) which is greater than two
times the static gradient.  The hydraulic gradient at the southeast corner
of the site is calculated to be 0.0035 ft/ft.  During another
investigation, the gradient was calculated to be 0.0094 ft/ft.  The
groundwater gradient is much steeper in the 80-foot zone than in shallower
zones due to the influence of the GDU wellfield.  As a result, this
gradient creates a potential for the downward movement of groundwater from
shallower zones.  Using the estimated hydraulic conductivities and
porosities of the transmissive layers, groundwater flow rates are
estimated for the 15-foot, 40-foot, and 80-foot zonea to be 16, 77 and 273
ft/year, respectively.

The climate in the Palm Bay area is subtropical humid, with the winter
months being generally dryer than the summer months.  As part of the
modeling of the hydrologic regime at the site, Harris Corporation
researched a number of the parameters related to the climate of the area.
Average rainfall in this area is about 56 inches per year.  Adjusting for
evapotranspiration and surface runoff, the estimated effective recharge of
the shallow aquifer is 36 inches per year.

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                                     19
3.0  Summary of Site Risks

.EPA performed an evaluation of the baseline public health and
environmental risk associated with the Harris site.  This baseline
evaluation helps determine whether or not a remedial action is necessary
by identifying the risk poaed by the site if no remedial action is taken.
The baseline assessment also provides the framework for developing the
preliminary remediation goals for the site.

EPA has determined that actual or threatened releases of hazardous
substances from this site may present an imminent and substantial
endangerment to public health, welfare, or the environment.  In order to
address this potentially imminent and substantial endangerment, EPA
recommends the implementation of the response action selected in this ROD.
3.1  Identification of the Contaminants of Concern (Indicator Chemicals)

Groundwater is the media of concern for Operable Unit One.  The
contaminants of concern are primarily volatile organic compounds (VOCs),
but also include acid extractable organics (AEOs) and inorganic
compounds.  These contaminants have been selected based on site-specific
data collected by Harris as part of initial sampling efforts as well as
the ongoing monitoring program at the Government Systems facility.  The
identified contaminants of concern consist of compounds which are the most
toxic, mobile, and presently persistent chemicals related to this operable
unit.

The indicator chemicals for this site were based on an analysis of the
compounds identified in groundwater sampling conducted by Harris.  The
analysis for VOC contamination involved data from a 1989 sampling event.
The analyses for metals and fluoride utilized less recent data because
sampling for these compounds has been less frequent than for VOCs.  Data
from wells where no contaminants of concern were detected have been
excluded.  In calculating the averages across all wells sampled, one-half
the detection limit was used for those contaminants not detected  (if at
least one contaminant of concern was detected in that well).

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                                     20
Table I shows the concentrations for groundwater contaminants of concern
based on samples collected from monitoring wells at Government Systems and
GDU.  These groundwater samples contained elevated concentrations of the
following nine VOCs:  1,1-dichloroethane (1,1-DCA), 1,1-dichloroethylene
(1,1-DCE), methylene chloride (MC), trichloroethylene (TCE), vinyl
chloride (VC),  chlorobenzene (CB), 1,2-dichlorobenzene (1,2-DCB),
1,2-dichloroethylene (1,2-DCE), and ethyl benzene  (EB).  In addition,
metals (chromium, lead, and copper) as well as fluoride were reported as
present in the groundwater associated with Government Systems.

Chromium, lead, and copper as well as other metals had previously been
detected beneath the Harris facility at levels above water quality
standards.  Subsequent sampling by Harris showed steadily declining  levels
of these metals.  In addition, the most recent data analyzed by EPA
indicates that chromium was detected in only one well and copper is  not
found at levels of concern.  Analyses for metals at GDU indicate that
metals are not detected at levels above drinking water standards.
FOER conducted split sampling at Harris in 1985.  The results of this
sampling were used to confirm the methodology and quality assurance  of the
Harris sampling procedures as well as the analytical results obtained.
3.2  Exposure Assessment Summary

This ROD addresses the groundwater exposure pathway.  The potential human
exposure pathway of primary concern is ingestion.  Other water use
pathways include dermal contact and inhalation.

The preliminary classification for the contaminated groundwater aquifer is
class II, a potential or existing drinking water source.  Class II
aquifers should be remediated to levels that are protective of human
health.

GDU is located directly south of the Harris facility.  Groundwater flow at
the site is to.the south, southeast towards the GDU facility which
provides the public water supply for Palm Bay.  Therefore, the potential
receptors of contaminated groundwater in the absence of groundwater

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                                    21
                                  Table I

                             Sampling Data for
         Groundwater Contaminants of Concern at Government Systems
Carcinogens
   Maximum
Concentration
    (uq/U
 Mean
(uq/Ua
 Number
   of
Samples
Frequency
    of
Detection
1,1-Dichloroethane
1,1-Dichloroethylene
Methylene Chloride
Trichloroethylene
Vinyl Chloride
     1790
      671
       26
     1860
     2280
 123
  50
   5
 311
 323
    29
    29
    29
    29
    29
     22
      8
      3
     16
     18
Noncarcinoqena
     VOCi
1,1-Dichloroethane
1,1-Dichloroethylene
Methlyene Chloride
Chlorobenzene
1,2-Dichlorobenzene
1,2-Dichloroethylene
Ethyl Benzene
1790
671
26
16
19
240
76
123
50
5
3
5
84
13
                              29
                              29
                              29
                              29
                              29
                              29
                              29
                          22
                           8
                           3
                          10
                           8
                          24
                           5
Chromium
Lead
Copper
Mercury

Fluoride
       30
       80
   c
  56
     8580
3181
     8
     9

    12

    15
       1
       7

       0

      11
a - This concentration represents the 95 percent upper confidence limit on
    the arithmentic average.
b - This category includes carcinogens which are also considered to have
    noncarcinogenic toxic effects.
c - Chromium was only detected at one sampling location.
d - Copper was not detected at levels of concern.
e - Mercury was not detected.  However, the detection limit that was used
    is 2.5 times greater than the EPA required quantitation limit.

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                                     22
remediation are the Palm Bay residents.  If the remediation program is
discontinued, the contaminated groundwater will migrate further into the
GDU well field.  Also, groundwater from the shallow zone of the aquifer
could potentially discharge to Turkey Creek which runs south of the
facility.  In that event, the creek could become a human health and/or
environmental exposure pathway.

Another potential human exposure pathway of concern is the inhalation of
off-gassing from the air stripping system.   During pilot testing of the
air stripping tower at Harris, FDER analyzed projected air emissions.
This analysis indicated that the volume of emissions is not high enough to
present an unacceptable health risk.  EPA performed a similar analysis in
February, 1990 to confirm these results.  However, since the FDER
analysis, exposure limits for some volatile organic compounds, including
vinyl chloride, have been reduced by the Occupational Safety and Health
Administration (OSHA) and the American Conference of Governmental and
Industrial Hygienists (ACGIH).  Therefore,  the health risks associated
with the air stripper emissions should be reviewed based on these new
limits.

The risk calculations for the ingestion of groundwater are based on the
exposure point concentrations which represent the upper (95 percent)
confidence limit on the arithmetic average.  The arithmetic average is
based on sampling data collected from wells in the area of the groundwater
contamination.  The exposure assumption used in the risk assessment is
that an exposed individual consumes two liters of the untreated water
daily for 70 years.
3.3  Toxicity Assessment Summary

Cancer potency factors (CPFs') have been developed by the EPA Carcinogenic
Assessment Group for estimating excess lifetime cancer risks associated
with exposure to potentially carcinogenic chemicals.  CPFs, which are

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                                     23

expressed in units of  (mg/kg-day)   are multiplied by the estimated
intake of a potential carcinogen, in mg/kg-day, to provide an upper-bound
estimate of the excess lifetime cancer risk associated with exposure at
that intake level.  The term "upper bound" reflects the conservative
estimate of the risks calculated from the CPF.  Use of this approach makes
underestimating the actual cancer risk highly unlikely.  Cancer potency
factors are derived from the results of human epidemiological studies or
chronic animal bioassays to which animal-to-human extrapolation and
uncertainty factors have been applied [Table II].

Reference doses (RfDs) have been developed by EPA for indicating the
potential for adverse health effects from exposure to chemicals exhibiting
noncarcinogenic effects.  RfDs, which are expressed in units of mg/kg-day,
are estimates of lifetime daily exposure levels for humans, including
sensitive individuals.  Estimated intakes of chemicals from environmental
media (e.g., the amount of a chemical ingested from contaminated drinking
water)  can be compared to the RfD.  RfDs are derived from human
epidemiological studies or animal studies to which uncertainty factors
have been applied (e.g., to account for the use of animal data to predict
effects on humans).  These uncertainty factors help ensure that the RfDs
will not underestimate the potential for adverse noncarcinogenic effects
to occur [Table II].

Hexavalent chromium is a human carcinogen when inhaled.  However, oral and
dermal exposure have not been identified as carcinogenic.  The volatile
organic contaminants of concern in the groundwater at the Harris facility
which are considered to be carcinogens from oral exposure are 1,1-DCA;
1,1-DCE; MC; TCB; and VC.  The inorganic constituents in the site
groundwater are not considered to be carcinogenic from the oral exposure
route.   Therefore, the hazards associated with these constituents are
lower than for the five potential carcinogenic VOCs.
3.4  Risk Characterization

A hazardous waste risk assessment considers the likelihood that adverse
effects will occur as a result of exposure to chemicals released into the

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                                    24
                                 Table II

           Reference Doses (RfD) and Cancer Potency Factors (q*)
              for  Constituents Detected at Government Systems
Constituent
Reference Dose
     Oral
  (mg/kg/day)
Cancer Potency Factor      EPA
        Oral             Classi-
    (mg/kg/day)         fication
Oroanics
Trichloroethylene
Vinyl Chloride
1,1-Dichloroethane
1,1-Dichloroethylene
Methylene Chloride
Chlorobenzene
1,2-Dichlorobenzene
t-1,2-Dichloroethylene
Ethyl Benzene
       0.12
       0.009
       0.060
       0.027
       0.089
       0.020
       0.10
          0.011
          2.3
          0.091
          0.6
          0.0075
B2
A
B2
C
B2
D
D
D
D
Inorganics
Mercury
Chromium
Copper
Fluoride
Lead
A -
Bl =
B2 =»
C -
D -
0.0003 	 D
0.0050 	 D(oral)
	 	 D
0.060 	 D
0.0014 	 B2
Human Carcinogen (sufficient evidence in humans)
Probable Human Carcinogen (limited evidence in humans)
Probable Human Carcinogen (limited evidence in animals)
Possible Human Carcinogen (limited evidence in animals)
Inadequate evidence of animal or human carcinogenic ity
Agency verified toxicity number is not available

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                                     25
environment.  The risk assessment includes carcinogenic as well as
noncarcinogenic effects.

Excess lifetime cancer risks are determined by multiplying the intake
level with the cancer potency factor.  These risks are probabilities that
                                                           e
are generally expressed in scientific notation (e.g., 1x10   or 1E-6).
An excess lifetime cancer risk of lxlO~  indicates that, as a plausible
upper bound, an individual has a one in one million chance of developing
cancer as a result of site-related exposure to a carcinogen over a 70-year
lifetime under the specific exposure conditions at a site.  The Agency
considers individual excess cancer risks in the range of lxlO~  to
IxlO"6 as protective.  However, the 1x10   level is generally used as
the point of departure for setting cleanup goals at Superfund sites.
Table III contains the concentrations that are equivalent to a 1x10
risk level.
Table III also contains the excess cancer risks associated with a
groundwater exposure level representing the 95 percent upper confidence
limit of the mean.  This mean value, shown in Table I on page 21, is based
on an analysis of Harris sampling data.  Therefore, a potential source of
uncertainty in this risk assessment is based on the methodology (discussed
in Section 3.1) used to determine the mean values for contaminants in the
groundwater.

Potential concern for noncarcinogenic effects of a single contaminant in a
single medium is expressed as the hazard quotient (or the ratio of the
estimated intake derived from the contaminant concentration in a given
medium to the contaminant's reference dose).  By adding the hazard
quotients for all contaminants within a medium or across all media to
which a given population may reasonably be exposed, the Hazard Index can
be generated.  The hazard index provides a useful reference point for
gauging the potential significance of multiple contaminant exposures
within a single medium or across media.  EPA has not prepared a hazard
index for this site.  However, Table III contains the hazard quotients for
the mean (upper 95 percent confidence limit) groundwater concentration for
the noncarcinogens.  This table also contains the concentration that is
equivalent•to the reference dose.

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                                    26

                                 Table III

            Risk Characterization  for Groundwater Contaminants
                           at Government Systems
Carcinogens

1,1-Dichloroethane
1,1-Dichloroethylene
Methlyene Chloride
Trichloroethene
Vinyl chloride
      Groundwater
      Risk Level
    Maximum/Average
4.6 x
1.1 x
5.5 x
5.7
      10~3/3.
      10"2/8.
    x 10'4/9
1 x 10
3 x 10
    10
    10
1 x
6 x
1.5 x 10~V2.1 x 10
-4
-4
-6
-5
-2
 10   Excess
 Cancer Risk
Concentration
    (ug/1)

   0.39
   0.06
   4.80
   3.20
   0.02
Noncarcinogens

1,1-Dichloroethane
1,1-Dichloroethylene
Methylene Chloride
Chlorobenzene
1,2-Dichlorobenzene
1,2-Dichloroethylene
Ethyl Benzene
Mercury
Chromium
Copper
Fluoride
    Hazard Quotient
    Maximum/Average
4.
2.
1.
1.
6.
3.
2.



4.
3
1
2
6
2
4
2



1
x
x
X
X
X
X
X



X
10
10
10
10
10
10
10

1.

10
-1
0
-2
-2
-3
-1
-2

7

0
/2
/I
/2
/3
/I
/I
/3
c
X
e
/I
.9
.6
.5
.6
.6
.2
.8

10

.5
x
x
X
X
X
X
X

-1

X
10
10
10
10
10
10
10



10
-2
-1
-3
-3
-3
-1
-3



0
                  Concentration
                  Equivalent to
                   RfD (ug/ll b

                      700
                       63
                      420
                      140
                      630
                      140
                      700
                        2
                       35

                      420
    This category includes carcinogens which are also considered to
    have noncarcinogenic toxic effects.  Hazard values were not
    quantified for lead since there are no current agency verified
    toxicity values for lead.

    This concentration represent* the groundwater concentration
    equivalent to the RfD and a 20% relative source contribution.

    Mercury was not detected.  However, in some cases, the detection limit
    used is 2.5 times greater than the CLP required quantitation limit.

    Chromium was detected above the detection limit in only one well.
    The maximum hazard quotient was based on the data from this well
    and the RfD for hexavalent chromium.
    The Hazard Quotient was not calculated because there is no RfD.

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                                    27
3.5  Environmental Risks

Under natural conditions, shallow groundwater discharges to Turkey Creek
which runs south of the facility.  At present, due to the pumping by GDU
and the Harris groundwater extraction system, groundwater is reportedly
not discharging to Turkey Creek.  However, if the pumping is discontinued
prior to complete remediation, terrestrial and aquatic organisms could be
exposed via contaminated surface water.  Discharge to surface waters via
stormwater run-off is another potential environmental risk.

The National Oceanic and Atmospheric Administration (NOAA) review of site
conditions identifies Turkey Creek as the principal area of either surface
discharge or groundwater discharge.  Future work on the remaining operable
unit(s) should include sampling of the creek sediments in order to verify
that past releases did not leave potentially toxic levels of contaminants
in Turkey Creek.
4.0  Description of Alternatives

EPA considered six alternatives for the remediation of the groundwater
associated with Government Systems.  All of these alternatives are based
on the use of the existing aeration treatment system operating at
       * «
Government Systems.

In order to document all remedial alternatives considered at the site,
this Record of Decision includes options eliminated early in the
evaluation process.  These options were reviewed by Harris prior to
selecting th« existing system and are presented here as Alternatives 4, 5,
and 6.  Th« comparison of all alternatives is based on a maximum system
throughput of 750,000 gpd.

4.1  Alternative 1 - No Action

The Superfund Program requires that the "no-action" alternative be
considered at every site.  Under the "no-action" alternative, EPA would
take no further action at the site to control or treat the source of

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                                     28
contamination.  The "no-action" alternative aerves as a baseline with
which other alternatives can be compared.  "No action" would involve
shutting down the existing groundwater extraction and treatment system on
each of the Harris and GDU properties.  While this alternative does
include groundwater monitoring, the only reduction of contaminant levels
would be via natural processes such as dispersion.  Potential health risks
would remain from ingestion of, or dermal contact with, untreated
groundwater.  Furthermore, discharges into Turkey Creek could potentially
result in a threat to terrestrial and aquatic organisms there.

The present (1990) value cost of this alternative is approximately
$355,000.  This estimated coat includes shutting down the existing
treatment system at $50,000 and groundwater monitoring for five years at
$61,000 per year.
4.2  Alternative 2 - Continued Operation of the Groundwater Extraction
                     and Treatment System with Deep well Injection

Alternative 2, Continued Operation of the Groundwater Extraction and
Treatment System with Deep Well Injection, is currently being performed at
the site pursuant to a Consent Order with the State of Florida.  Table IV
lists the aquifer cleanup levels specified in the FDER/Harris Consent
Order.

Groundwater withdrawal is accomplished with a combination of 11 wells, six
in the 80-foot zone and five in the 40-foot zone.  VOCs are then removed
and treated by a relatively simple multistage air stripping process.  The
treated water is currently used in a manufacturing process before being
injected approximately 2500 feet deep into the lower Floridan Aquifer.
The Floridan Aquifer is saline and nonpotable in the area.  This injection
process is regulated by FDER and EPA through an Underground Injection
Control (UIC) permit for a Class I non-hazardous industrial well.

The existing system was implemented in three stages as described beginning
on page 30.

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                                       29
                                    Table IV

                        Aquifer Cleanup  Levels Specified
                        in the FDER/Harris Consent Order
       Consent
        Agreement
       Constituent
 Design
Specification
   (uq/L>
Trichloroethylene
     <5
1,1-Dichloroethylene
     <5
Cis-l,2-Dichloroethylene
     <5
Trans-1,2-Dichloroethylene
     <5
Vinyl Chloride
     <5
1,1,1-Trichloroethane
     <5
1,1-Dichloroethane
     <5
Methylene chloride
    <2S
Ortho-Dichlorobenzene
    <25
Chlorobenzene
    <25
Ethyl Benzene
    <25
Toluene
                                                       <25
*   This concentration la higher than the current MCL or pMCL.

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                                 30
Stage 1:

To create a hydraulic capture zone on the southern boundary of the
Harris Corporation Government Systems facility, Harris instituted an
extraction program involving three wells (GS-123D, GS-124D, and
GS-125D).  These well positions allow for interception of contaminated
water from the deep zone of the main VOC plume.  The three wells
create a cone of depression upgradient from the GDU production wells.
The planned pumping rate of each of the hydraulic barrier wells was
25 gpm each.  Field checks by Harris in 1985 indicated the following
production rates for the hydraulic barrier wells:

           well     .    Rate

          GS-123D      40 gpm
          GS-124D      53 gpm
          GS-125D      52 gpm
Stage 2:

Another deep extraction well  (GS-127D) and 10 well points in the
shallow zone were added during Stage 2, in order to initiate
remediation activities in two areas.  These areas were:   (1) the
highly contaminated shallow zone near Building No. 5 and  (2) the
southern part of the deep zone contaminant plume in the Government
Systems parking lot.  Well GS-127D is identical in construction to the
three barrier wells used in Stage 1 and is equipped with  a  50-gpm
(nominal)  submersible pump discharging to a header that transmits
contaminated groundwater to the groundwater treatment system.  Well
GS-127D produced 50 gpm during continuous pumping of Stage  1 and Stage
2 wells in 1985.  The well point system installed as part of Stage 2
allowed for the extraction of groundwater from contaminated areas of
the shallow zone.  These well points were designed to have  a jetting
shoe below the screen to allow installation by jetting.   Two well
point pumps provided the vacuum to run the system.  The combined
pumping rate of the 10 well points during Stage 1 and Stage 2

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                                     31
    operation was about 30 gpm (measured at the groundwater treatment
    system).   These well points were eventually replaced with two
    permanent wells, GS-44S and GS-18S.

    Stage 3:

    Implementation of Stage 3 allowed for the extraction of the most
    highly contaminated portion of the plume, in the vicinity of Building
    6.  Six additional wells were added during this stage:   GS-35S
    (shallow or 40-foot zone), GS-35D (deep or 80-foot zone), GS-37S,
    GS-37D, GS-43S, and GS-43D.  These wells are grouped in three pairs,
    with each pair consisting of a shallow zone and a deep zone well.  All
    six wells are equipped with 50-gpm (nominal) submersible pumps.   The
    shallow and deep zone extraction wells are operated at the pumping
    rates of 25 and 50 gpm respectively.

    Treatment System Description:

    The extracted groundwater flows through a network of pipes to a
    treatment system which removes VOCs by a packed column air stripping
    tower.  The packed column aeration system is widely used for the
    removal of VOCs from contaminated drinking water.  Contaminated
    groundwater is delivered from the extraction wells to a 20,000-gallon
    raw water holding tank.  The raw water is pumped to the top of the
    6-foot diameter tower and distributed over the packing media by a
    weir-trough distributor.  The water cascades over 25 feet with
    counter-current air flow supplied by a forced draft centrifugal
    blower.  The stripping tower is mounted on top of the 20,000-gallon
    treated water holding tank.  Tower effluent flows by gravity into the
    holding tank and is then pumped to a water reuse system on the site.

The treated groundwater ia used for process water under a Consumptive Use
Permit issued by the St. Johns River Water Management District.  After use
as process water, the treated groundwater is disposed of by deep well
injection into the lower Ploridan Aquifer.  This injection process
utilizes a Class I non-hazardous well with an Underground Injection
Control (UIC) permit monitored by FDER.  The Ploridan Aquifer is not

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                                     32
considered to be a potable water source in this area due to high Total
Dissolved Solids (TDS) and chloride concentrations.

In addition to the system operating on the Harris facility, there is a
groundwater extraction and treatment system ongoing at the GDU facility.
Water from seven-production wells is pumped to an air stripper.  The
stripper effluent is mixed with water from other GDU production wells
before undergoing the standard water purification process prior to public
consumption.  The construction and monitoring of this system has been
funded by Harris.  An informal agreement exists between Harris and GDU
such that GDU is to provide Harris six months advance notice in the event
that GDU sells its property.

The existing treatment, disposal, and monitoring system has been
implemented in stages since 1984.  Alternative 2 would involve the
continued use of this existing system for at least another three years.
The present value (1990) cost of Alternative 2 is estimated to be
$792,000.  This cost includes operation and maintenance of the existing
system and groundwater monitoring for three years at a total of $264,000
per year.
4.3  Alternative 3 - Modification of the Groundwater Extraction and
                     Treatment System

Alternative 3 involves continued operation of the existing extraction and
treatment system aa well aa a modification of the system.  This
modification will ba designed to improve the capture- of site-related
contaminant plume* and optimize system effectiveness.

Modification is necessary to better define the contaminant plumes, ensure
containment of these plumes, and enhance the efficiency of aquifer
cleanup.  Source characterization indicates the possible presence of
metals and AEOs in the groundwater.  The analyses to date do not
adequately define this contamination.  Therefore, modifications may be
needed to more adequately monitor and, if necessary, treat this potential
contamination in the groundwater.

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                                     33
EPA developed a list of proposed modifications for the purpose of
estimating costs associated with Alternative 3.  These modifications may
include, but are not limited to:  (1) installing approximately four
additional extraction wells, (2) discontinuing the use of some existing
wells, and (3) decommissioning monitoring wells that are no longer of use
but are determined to be located in source areas.  The exact number of
wells affected and any altered pumping rates will be determined during the
remedial design phase.

The remedial design will include a detailed design analysis of the
existing system to determine the location of additional wells.  It will
also address, if necessary, the discontinued pumping of any existing
wells.  The design may include a schedule for temporarily shutting down
the entire system to determine remedial action success.  A shut-down would
be initiated only after contaminant levels in the aquifer met the
specified cleanup goals.  This shut-down would allow the groundwater to
recharge and reach an equilibrium condition.  Additional sampling and
analyses as well as careful monitoring of the aquifer could then determine
whether or not the sources of contamination had been removed.

The existing groundwater monitoring program will be evaluated and modified
as necessary to fully characterize the extent of contamination at the
site.  The modified monitoring program will be implemented for a period of
three years or until the cleanup goals are met.  After the onset of
remedial action, EPA will conduct a review of the site within five years
to verify that the aquifer is being restored to beneficial use.  If the
cleanup goals appear to be met after the first review, sampling would
continue annually or semi-annually for a period of time necessary to
verify that long-term restoration of the aquifer had occurred.  However,
if the review identifies a need for further remedial action, monitoring,
or attainment of cleanup goals, the appropriate action will be initiated.

The present (1990) value cost for this alternative is estimated at
$1,430,000.  This estimated cost includes design modifications and
construction of additional wells at a cost of $480,000.  Also included is
$950,000 for three years of system operation and maintenance as well as
five years of groundwater monitoring.

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                                     34
4.4  Alternative 4 - Disposal via Spray Irrigation

This alternative would utilize the aame groundwater extraction and
treatment system described in Alternative 2.  However, the method for
disposal of treated groundwater involves spray irrigation with discharge
to a drainage ditch.

Spray irrigation relies on two natural forces to dispose of water,
evapotranspiration and percolation.  Of the two, percolation is the
predominant disposal method.  Several design criteria are critical in
evaluating a spray irrigation system:  the amount of available acreage on
which to apply the treated groundwater, hydraulic assimilation capacity of
the site, and the application rate of the water.

The area has two major soil types, a satellite sand and MyaJcka sand.  The
estimated percolation rate of this area is approximately 0.6 inches/hr.
Based on a hydrologic budget model prepared for the site, the average
maximum hydraulic load the site could support is 3.9 inches per week.
However, standing water has been observed throughout the dry season.  This
phenomenon is the result of improper drainage brought about by development
on three sides of the site, creating a berming effect.  In order to meet
the requirements for spray irrigation, fill material would need to be
brought i'n to raise the area approximately three feet.

In addition to its poor drainage, this site is further restricted by
Section 17-6 of the Florida Administrative Code  (FAC), which limits the
hydraulic loading of alow rat* 
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                                     35
One of the principal disadvantages of using a spray irrigation system is
its dependence on weather conditions.  Spray irrigation systems cannot be
operated during or after periods of heavy or prolonged rainfall.  During
rainy periods, the treated groundwater would have to be stored or
discharged to the drainage ditch.  The spray irrigation system is also
more labor intensive because the system must be switched on and off
manually to meet the changing weather conditions and to avoid flooding of
the area.

Environmentally, spray irrigation is attractive because it provides a
secondary method of aerating the treated groundwater, and a portion of the
water will be percolated back into the surficial aquifer for reuse.  The
principal environmental disadvantage is that almost half of the water will
be discharged to the drainage ditch.

Harris does not currently have sufficient acreage for complete spray
irrigation.  In addition, the cost of bringing in fill to elevate the area
is prohibitive.  Environmentally, spray irrigation is preferable to
reinjection.  However, spray irrigation would be too land intensive,
requiring approximately 100 acres of land to spray irrigate 750,000 gpd.
Treated water would then have to be pumped approximately five miles.
Site-specific features thus reduce the technical feasibility of
Alternative 4.  EPA did not estimate the costs associated with this
alternative because it was eliminated early in the evaluation process and
no current cost data exists.
4.5  Alternative 5 - Disposal via Percolation

This alternative utilizes the same groundwater extraction and treatment
system described in Alternative 2.  However, the method of disposal of
treated groundwater would be to return the treated water to the surficial
aquifer through a percolation pond with overflow to a drainage ditch.

For this alternative, several simplifying assumptions were made regarding
the hydrogeology of the available eight acre tract.  The firat assumption
was that the aquifer is an unconfined, homogeneous, isotropic, single-

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                                     36
layer system.  (In reality, the site geology is known to be more complex
and actually consists of three layers:  an upper aquifer, an aquitard, and
a lower aquifer.)  Second, the assumed average permeability of the
single-layer system was 150 gpd/ft .   This value was determined by
proportioning the measured permeability values and thickness of each of
the three geologic layers.  Third, the assumed average aquifer thiclcness
was 93 feet, based on previous geological investigations.  Other data used
in this analysis include the following:

    o    average ground surface elevation at the site is +18' MSL

    o    average groundwater piezometric surface at the site is +10' MSL

    o    estimated distance to the Turkey Creek outfall is 2,500 feet

    o    percolation rate is 63 gal/day lineal foot of pond

    o    estimated water surface elevation at the Turkey Creek outfall  is
         less than +2' MSL

    o    assumed maximum percolation pond water surface is +22" MSL

    o    assumed maximum usable pond area is 625' x 525' (7.45 acres),
         based on the berm configuration

These data and a modified version of Darcy's Law, led to the conclusion
that the maximum seepage flow available at the 8 acre tract is about
40,000 gpd.  However, the achieveable  seepage rate at the site is probably
much leas than 40,000 gpd, because the actual subsurface conditions are
less favorable for percolation than assumed in this analysis.  Further,
the actual hydraulic gradient may also prove to be lower than the gradient
assumed for this analysis.  One alternative would be to construct a
percolation pond on the 8 acre tract and allow the overflow to discharge

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                                    37
to the drainage ditch.  This would mean that during normal operating
conditions, approximately 40,000 gpd would enter the soil and up to
710,000 gpd of treated groundwater would be discharged to surface waters.

There are several factors to be considered regarding the environmental
impact of a percolation pond.  On the positive side, the 8 acre pond would
provide a 110 day retention time for treated water entering the pond,
which would allow for further volatilization of any VOCs.  The negative
aspect to the percolation pond is that once the pond is filled, up to
710,000 gpd of treated water must be discharged to the surface waters and
cannot be returned to the aquifer for use.  In addition, volatilization
will occur only at the surface interface unless an aerator is used to
enhance volatilization of less accessible areas.

Harris does not currently own enough acreage adjacent to the Government
Systems facility to construct a percolation pond to dispose of 750,000 gpd
solely through percolation.  Construction of a smaller percolation pond on
the available land will allow percolation of an estimated 40,000 gpd.  The
remainder of the treated water will flow to the drainage ditch.  The use
of percolation ponds is not feasible, because there is insufficient
acreage available to construct a percolation pond large enough to dispose
of most of the treated groundwater.  No current cost data exists for this
alternative.
4.6  Alternative 6 - Disposal via Reinjection to the Surficial Aquifer

This alternative utilizes the same groundwater extraction and treatment
system described in Alternative 2.  However, the method of disposal of
treated groundwater involves returning the treated water to the surficial
aquifer via reinjection wells.

A review of the hydrogeological characteristics of the Harris site shows
that reinjection into the surficial aquifer could take place in either of
the two permeable zones present.  The upper portion of the surficial
aquifer is located from approximately +17' to -20' MSL and has an average
permeability of 95 gpd/ft2.  The lower portion of the aquifer is located

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                                     38

from -30' to -80' MSL, with an average permeability of 200 gpd/ft2.

Based on the transmissivity and permeability of the surrounding areas,  20
to 30 four-inch diameter shallow wella with five-foot screens capable of
reinjecting 2 to 3.5 gpm would be required to inject 100,000 gpd treated
water into the upper aquifer.  The deeper zone of the surficial aquifer
would require only three six-inch diameter wells with ten-foot screens
reinjecting approximately 23 gpm to dispose of 100,000 gpd treated water.

In order to achieve maximum utilization of the available reinjection area,
the wells must be located in lines running east and west, generally
perpendicular to the north-south direction of groundwater flow.  The
required distance between wells is based on the cone of influence.  This
distance would be about 30 feet for the shallow wells and 200 feet for the
deeper wells.

In selecting the system location, the first consideration is to position
the reinjection wells outside the zone of influence associated with the
groundwater withdrawal wells.  This positioning is necessary to avoid a
reduction in radius of influence of a given withdrawal system, and to
avoid repumping treated groundwater.  The only available reinjection area
not in the zone of influence of the groundwater withdrawal wells is an
eight acre tract located east of Perimeter Road on the Government Systems
facility.  Either two rows of 15 shallow wells each or three deep wells
could be installed in this tract.

The presence of an aquitard at -20' to -28' MSL is another condition to
consider.  Th« aquitard limits the amount of water which can be injected
into the shallow reinjection wells.  Too great a reinjection rate will
cause an upflow of the water, which could result in ponding.  However, the
aquitard has a positive effect on the deeper reinjection wells by acting
aa a barrier preventing water from rising to the surface.

The increased pressure applied to the aquifer should check any further
dispersion of the contaminants to the east by establishing wells east of
the suspected area of contamination.  In addition, the reinjected water
can be returned to the aquifer instead of being lost to surface water

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                                     39
discharge.  However, there La a potential for introducing trace amounts  of
VOCs into groundwater currently considered free of these contaminants.

The existing groundwater treatment system has been designed to remove VOCs
to the prescribed levels in the Harris/PDER Consent Order.  This system
also has operating safeguards such as an automatic shutdown in the event
of a malfunction in the air stripping tower fan.

Despite these precautions, the possibility exists for inadvertently
contaminating the aquifer due to the lag time between sampling the treated
effluent and receiving the analytical laboratory results.  Use of a 1.2
million gallon treated water holding tank would eliminate the possibility
of discharging contaminated water into the aquifer.  However, prior to
initiating reinjection, an acceptable air to water ratio for achieving the
concentration limits established in the Consent Order would be set during
start-up activities.  Once the normal operation begins, this ratio is
expected to be fairly consistent.  Therefore, failure of the tower fan is
the only likely means of introducing contaminated groundwater into the
clean zone of the aquifer.  The motor control system design addresses this
contingency.  In the event of tower fan failure the influent pumps
automatically shut down.  As a result, the system would not require large
holding tanks.

The preferred zone of reinjection would be outside the area of
contamination in the lower surficial aquifer, which is more permeable,
requires fewer wells and prevents ponding.  Environmentally, reinjection
offers two positive aspects.  Pressurizing the aquifer will prevent the
spread of VOC contamination to the east and allow the treated water to be
reused by placing the water back into the surficial aquifer.  The
potential for reinjecting contaminated water back into a clean area may be
reduced by incorporating the proper instrumentation and motor control
switches to avoid discharge of contaminated water if the fan motor fails.

The information presented thus far for Alternative 6 relates to the
reinjection of 100,000 gpd.  In order to accommodate the reinjection of a
maximum of 750,000 gpd, 20 additional deep reinjection wells would be
required across the Government Systems property.  However/ according to

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                                     40
Harris, placement of the reinjection wells around the site would be
difficult due to the extensive network of underground utilities.  As with
Alternatives 4 and 5, no current cost data for this alternative exists.
5.0  Summary of Comparative Analysis of Alternatives

EPA uses nine criteria for evaluating remedial alternatives at NPL sites.
The first two are known as threshold criteria and are the minimum
requirements that all alternatives must meet:  overall protection of human
health and the environment and compliance with site-specific cleanup
standards.  There are five balancing criteria used for comparison of the
alternatives:  long-term effectiveness; reduction of toxicity, mobility,
or volume; short-term effectiveness; implementability; and cost.  The last
two, state acceptance and community acceptance, are known as modifying
criteria and can serve to influence the EPA preferred remedy.
5.1  Overall Protection of Health and the Environment

Alternative 1, No Action, would allow for the continued migration of
contaminants to the GDU wellfield downgradient of the site.  This
alternative is not considered effective because it does not mitigate
potential health risks associated with exposure to groundwater by
ingestion and dermal absorption.  Alternative 1 exceeds the 1 x 10   to
1 x 10   target risk range and, therefore, is not protective of human
health and the environment.  The No Action Alternative will not be
considered further aa a remedial option for this site.

Alternative* 2 through 6 are protective of human health and the
environment baaed on the use of air stripping treatment for VOCs.  By
providing a barrier for contaminant migration as well as treatment of the
contaminant plume, these alternatives mitigate the risk of migration to
the GDU well field and other potential users of the aquifer.  The capture
zone of the extraction system prevents migration as well as discharge of
contaminated groundwater to surface water, thus avoiding a potential
environmental threat.

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                                    41
5.2  Compliance with Applicable or Relevant and Appropriate Requirements
      (ARARS)

Remedial actions performed under CERCLA must comply with all site-specific
Applicable or Relevant and Appropriate Requirements (ARARs).  The ARARs
for this site can be grouped into six categories.  The Harris remediation
system must comply with cleanup standards from:  the Safe Drinking Water
Act (SDWA), the Underground Injection Control  (UIC) program, the National
Pollutant Discharge Elimination System (NPDES), the Resource Conservation
and Recovery Act (RCRA), the State of Florida Administrative Code (FAC),
and the Clean Air Act (CAA).

All alternatives except for the No Action Alternative would comply with
ARARs.  "No Action" would allow contaminants to remain in the groundwater
at concentrations above drinking water standards.  This level of
contamination would violate the SDWA and FAC.  Alternatives 2-6 assist in
restoring the levels of contaminants in the aquifer to drinking water
standards and, therefore, lead to compliance with the SDWA and FAC.  Water
injected into the Floridan Aquifer in Alternatives 2 and 3 would meet the
UIC permit requirements.  Water discharged to  the drainage ditch in
Alternatives 2 and 3 would meet NPDES permit limits.  In Alternatives 2-6,
the extracted groundwater would be treated to  meet health-based standards
prior to disposal and would, therefore, meet the current RCRA Regional
guidance regarding contaminated groundwater.   Finally, emissions from the
air stripper used in Alternatives 2-6 would meet National Ambient Air
Quality Standards.

                          Safe Drinking Water  Act

The SDWA mandate* EPA to protect human health  from contaminants  in
drinking water.  Since  the groundwater in the  area of the Harris site  is
an existing drinking water source, the aquifer is  classified as Class  II
groundwater.  Therefore, the SDWA standards set by EPA are  relevant  and
appropriate.

EPA has developed two types of drinking water  standards, primary and
secondary  standards.  Primary  standards are based  upon protection of human

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                                     42
health.  These Maximum Contaminant Levels (MCLs) are enforceable at the
federal level.  MCLs are contaminant-specific standards and are potential
ARARs for affected potable water at NPL sites.  Section 121(d)(2)(b)(i) of
CERCLA prescribes that these standards, as determined by the Safe Drinking
Water Act (SDWA) (40 CPR Part 141 and 142) and Section 304 of the Clean
Water Act, should be used in setting cleanup goals for response actions at
NPL sites.  Secondary standards (SMCLs) are often concerned with the
aesthetic quality of water as well as economic considerations and are not
enforceable at the federal level.   However, SMCLs are in the category of
standards "to-be-considered" (TBC) as ARARs in order to protect the
groundwater for future use.

For some constituents, there are no primary or secondary standards
established pursuant to the SDWA.   In this event, concentrations of
contaminants in groundwater remaining at the completion of the remedial
action must still be protective of human health and the environment.  For
carcinogens, the one in one million (1E-6) cancer risk level is considered
adequately protective of human health.  For non-carcinogens, a threshold
value may be determined from the currently available EPA toxicological
data base.  If a proposed MCL (pMCL) is available for a constituent, it
may also be used.  Proposed MCLs are not enforceable standards, but are
considered TBCs.
       «

In summary,  Alternatives 2 through 6 meet the ARARs for VOCs based on use
of the aeration treatment system.   The primary ARARs that apply to aquifer
remediation are the MCLs promulgated under the SWDA.  These are applicable
where water will be provided directly to 25 or more people or to 15 or
more service connections.  MCLs are relevant and appropriate when the
surface or groundwater is used or may be used for drinking water.  "To be
considered" remediation goals, including proposed MCLs and risk based
calculations, apply when a population is exposed to contaminants.
                       Underground Infection Control

The Safe Drinking Water Act also provides for a permit program which is
designed to prevent contamination of underground sources of drinking

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                                     43
water.  This program is known as the Underground Injection Control (UIC)
program.  The UIC program regulates underground injection into five
classes of wells.  There are two Class I permitted injection wells present
on the Harris Corporation Government Systems facility for the disposal of
industrial waste water.  These wells are not currently permitted for the
injection of hazardous waste.  Therefore, the groundwater must be treated
to health-based standards as described in the Table III on page 26 before
injection.

Alternatives 2 and 3 involve additional ARARs for the deep well injection
of treated groundwater into the Floridan Aquifer.  The Floridan Aquifer  is
not a potential source for drinking water because it is saline and
nonpotable.  The UIC permit administered by PDER lists the injectate
limits as shown in Appendix B.
          National Pollutant Discharge Elimination System  (NPDES)

In addition, the extraction and treatment system described in Alternatives
2 and 3 must comply with the National Pollutant Discharge Elimination
System  (NPDES) standards under the Clean Water Act (CWA).  Currently,
discharges from the treatment system to the drainage ditch east of
Perimeter Road may occur during equipment failure or emergencies.  As an
alternative to deep well injection, the treated groundwater can be
discharged to the surface through this permitted NPDES outfall.  Any
surface water discharge flowing into this ditch eventually runs into a
tributary of Turkey Creek.  The current NPDES discharge limits are listed
in Appendix C.
                   Resource Conservation and Recovery Act

The volatile organic compounds present  in the groundwater associated with
Government Systems are characterized as spent solvents.  Spent  solvents
are RCRA  "listed" hazardous wastes as defined in 40  CFR  261.31.  Since it
contains  a listed hazardous waste, the  contaminated  groundwater must be

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                                     44
managed as a hazardous waste.  As a result, groundwater containing
hazardous waste cannot be injected into the Class I injection wells at the
site.  To do so would be in violation of RCRA and UIC requirements,
including the Land Disposal Restrictions.  After treatment to health-based
levels, which the Harris system accomplishes, EPA considers that the
groundwater no longer contains hazardous waste.  Once these health-based
levels are reached, the groundwater is no longer subject to regulation
under Subtitle C of RCRA.

In addition, EPA has determined that Resource Conservation and Recovery
Act  (RCRA) technical standards regarding corrective action and closure are
relevant and appropriate for the groundwater plumes and contaminant source
areas at Government Systems.  Corrective action on any portion of the site
determined to be releasing contaminants to the groundwater will comply
with RCRA technical standards.
                        Florida Administrative Code

EPA considers all appropriate state standards as potential ARARs.  The
State of Florida has requested that EPA include the Florida Administrative
Code (FAC) requirement that the aquifer be cleaned up to a level such that
the groundwater is "free from nuisance".  EPA has determined that the
"free from" requirement, a secondary standard pursuant to the SDWA, is
relevant and appropriate for this site.  The existing Consent Order
between FDER and Harris lists protective standards for aquifer cleanup.
These standards are considered to meet the "free from" criteria for the
site.
                               Clean Air Act

Emissions from the air stripper used in Alternatives 2-6 must meet ambient
air standards from the National Ambient Air Quality Standards (Section 109
of the Clean Air Act as set forth in 40 CFR Part 50).

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                                     45
                    Cleanup Goals for Operable Unit One

Table V is a list of the site-specific contaminants and the appropriate
cleanup levels based on the ARARs discussed above.  These cleanup levels
are based on MCLs, the FAC "free from" requirements, pMCLs, 1E-6
health-based risk values, and SMCLs as appropriate for each contaminant
listed.

The State of Florida MCLs that are more stringent than federal standards
will be used as ARARs.  In addition, the cleanup criteria identified in
the FDER/Harris Consent Order will be used to meet the FDER "free from"
requirements.  This approach provides for consistent application of the
FDER Consent Order with respect to EPA response goals.
5.3  Long-Term Effectiveness and Permanence

Alternatives 2-6 mitigate the risk to the population of exposure to
contaminated groundwater.  The extraction and treatment system used in all
of these alternatives adequately reduces the exposure to VOCs in the
groundwater.  Alternative 3 allows for enhanced control of contaminant
migration by making the system more efficient in treating for VOCs as well
as addressing the potential for AEO and inorganic contaminants.
Alternative 3 would also remediate the groundwater to a long-term
acceptable risk range.  Alternative 6 involves some risk due to the
reinjection of treated groundwater to the surficial aquifer.  In
Alternative 6, this riak is associated with the potential exposure to
contaminant* in the drinking water from downward migration to the lower
aquifer.
5.4  Reduction of Toxicity, Mobility, or Volume Through Treatment

Alternatives 2-6 reduce the toxicity and volume of the contaminants in
groundwater through treatment.  In addition, these alternatives limit the
mobility of contaminants by decreasing the size of the contaminant plume
and/or eliminating part of the source through the use of extraction

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                                   46

                                TABLE V

           Government  Systems Groundwater Remediation Goals

                            Concentration
Contaminants                    (ppb)                Basis
Vinyl chloride
Trichloroethylene
1, 1-Dichloroethylene
c-1, 2-Dichlorethylene
Methylene chloride
1, 1-Dichloroethane
Chlorobenzene
t-1 , 2-Dichloroethylene
1 , 2-Dichlorobenzene
Ethyl benzene
Toluene
1,1, 1-Trichloroethane
Trichlorobenzene
Lead
Mercury
Chromium
Copper
1
3
5
5
5
5
25
5
25
25
25
5
25
15
2
50
1000
MCL (1)
MCL (1)
CO
CO
1E-6, pMCL, TBC
CO
CO
CO
CO
CO
CO
CO
CO
MCL ( 2 ) , TBC
MCL
MCL
SMCL
Fluoride                          2000             SMCL
MCL      Maximum Contaminant Level

         (1)  The State of Florida has promulgated MCLs for TCE and
              VC which are more stringent than EPA's MCLs, therefore,
              the State MCLs are ARARs for the Harris Site.

         (2)  The present MCL for lead is 50 ppb.  A level of 15 ppb
              has been proposed as a health-based standard and is,
              therefore, a to-be-considered (TBC) site cleanup goal.

CO       These standards are listed in the 1983 FDER/Harria Consent
         Order and are considered to be the "free from" criteria
         identified in the Florida Administrative Code.

TBC      To-be-con*idered cleanup goal

1E-6     One in one million excess cancer risk level

pMCL     Proposed Maximum Contaminant Limit (40 CFR/ Vol. 54, No. 97/
         May 22, 1989)

SMCL     Secondary Maximum Contaminant Level

Notet  This list does not include cleanup goals for acid extractable
organica (AEOs) because current sampling data do not identify
specific AEOs.

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                                     47
wells.  Alternative 3 not only allows for more efficient reduction of the
contaminant plume, it allows for treatment of the potential groundwater
contamination from metals, fluoride, and AEOs.
5.5  Short-Term Effectiveness

Alternatives 2-6 eliminate the immediate risk to the general population of
exposure to contaminated groundwater.  Any short-term risk to workers
involved in construction of the selected remedy would be reduced through
implementation of a health and safety plan.

The environmental impact of alternatives 2 and 3 is minimal since
groundwater is reinjected into the deep Floridan Aquifer which is not a
potable water source in the area.  Alternatives 4 and 5 pose some
environmental impact to aquatic organisms exposed to the surface water and
any volatile organics.  Alternative 6 poses an environmental threat to the
surficial aquifer by potentially introducing trace amounts of VOCs to an
area currently considered free of contamination.

Alternatives 2 and 3 would each require an estimated three years to
implement.  Implementation time frames for Alternatives 4 through 6 are
not applicable because these alternatives were considered and eliminated
at an early stage of the project.

FDER estimates that Alternative 2 will substantively meet the cleanup
criteria stated in the FDER Consent Order within three years.
Implementation of Alternative 3 will take approximately three years and
will produc* information necessary to estimate the time required for
restoration of th« aquifer to EPA standards.
5.6  Implementability

The implementability of an alternative is based on technical and
administrative feasibility, constructibility, and the availability of
materials and services needed to  implement a specific remedy.

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                                     48
Alternatives 2 and 3 are technically and administratively feasible.  These
two alternatives involve technologies which have been used in the past and
have a demonstrated performance record.  The groundwater recovery,
treatment, and disposal system specified in Alternative 2 is already
operational.  Alternative 3 also utilizes this system, but with
modifications.  Alternatives 4 and 5 are not currently implementable due
to a lack of available land.  Alternative 6 is not administratively
feasible because of the potential for contamination of a drinking water
aquifer in the event of equipment failure.  The technical feasibility is
questionable because of the uncertainties in our ability to predict its
effect on the physical characteristics of the aquifer.  For example,
reinjection into the surficial aquifer may introduce indeterminate
influences on the existing groundwater flow patterns.

EPA policy allows for interim remedies at sites involving groundwater
contamination.  An interim remedy can be location-specific or
medium-specific and should be used when there is enough existing
information to effect the remedy.  A limited evaluation of alternatives
can be used to compare the advantage of taking an early action to the
possible ramifications of waiting until a comprehensive site investigation
has been completed.  An interim groundwater extraction and treatment
system at Harris has served to protect the drinking water supplied by
GDU.  As a result, the phased implementation of the existing treatment
system produced data that can be used in optimizing the system
during the modifications to be determined in Alternative 3.
5.7  Cost

The present worth value represents the total cost of remediation expressed
in today's dollars.  The present worth cost associated with Alternative 1
is approximately $355,000.  Alternative 2 has an estimated present worth
cost of $792,000, including Operations and Maintenance (O&M) costs.  The
estimated present worth cost of Alternative 3 is $1,430,000, including O&M
costs.  The costs associated with Alternatives 4 through 6 have not been
estimated because these alternatives were eliminated early in the
evaluation process and no current cost data is available.

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                                    49
5.8  State Agency Acceptance

The State of Florida, as represented by the FDER,  concurs with the use of
Alternative 3 for Operable Unit One.  This alternative is acceptable to
FDER with provisions that the FDER is a part of the review process for the
design analysis.  In an early action designed to capture the contaminant
plume and protect the GDU wellfield, FDER approved the use of Alternative
2 after also considering Alternatives 4-6.
5.9  Community Acceptance

EPA received comments from local citizens at the public meeting held on
March 27, 1990 and during the public comment period.  Responses to
specific comments are available in the Responsiveness Summary for this
Record of Decision.  Based on these comments, the community supports the
EPA decision to modify the existing groundwater extraction and treatment
system at the Harris site.
6.0  Selected Remedy

Operable Unit One addresses the groundwater contamination associated with
the Government System*  facility of Harris Corporation.  The selected
remedy  for this operable unit  is Alternative 3, which requires
modification to the existing groundwater extraction and treatment
system.

This remedy consists  of:   (1)  continued operation of the existing
extraction, treatment,  and disposal  system,  (2) a design analysis  for
plume containment and treatment,  (3) modification of the system based on
results of the.design analysis,  (4)  continued  sampling and monitoring of
the cleanup, and  (5)  a  review  of the system by EPA and FDER within five
years after the onset of remedial action.  This remedy includes the
current deep well injection of groundwater treated to EPA health-based
levels.  As an alternative, the treated groundwater will be discharged to
the surface through a NPDES permitted  outfall.

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                                     50
Implementation of Alternative 3 will improve the treatment and containment
of the existing groundwater extraction and treatment system.   it will
involve a review of existing sampling data as well as the resampling of
wells outside the plume as defined by Harris.  This alternative will
determine the effects of the present remediation system in accordance
with existing EPA policy.  The effects to be determined include the
current and future effects of the air emissions from the air stripping
towers at Harris and GDU.  In addition, EPA will determine the
effectiveness of plume containment with respect to VOCs, AEOs, and
inorganics as well as the effects of the various groundwater pumping
regimes in the immediate area.  Furthermore, Alternative 3 does not
involve significant additional capital costs to attain these measures.

As part of the design analysis, "point of compliance wells" will be
designated in order to detect the presence of contamination above cleanup
standards.  Sampling information obtained from these wells will be used to
determine exact locations of the plumes and design groundwater extraction
modifications for compliance with the RCRA technical standards.

The cleanup goals for this alternative are listed in Table V on page 46.
These cleanup levels may be modified in accordance with later guidance
and/or regulations.  In addition, the goals may be modified due to
potential uncertainties about the ability of the treatment system to
achieve established cleanup goals within the existing physical groundwater
system.

The Interagency Section 7 Consultation Process, 50 CFR Part 402, requires
that EPA consult with the Department of Interior, the Fish and Wildlife
Service, and the National Marine Fisheries Service as appropriate during
remedial design.  This consultation will assure that endangered or
threatened species are not adversely impacted by implementation of this
remedy.  EPA has already consulted with the National Oceanic and
Atmospheric Administration on the potential environmental risks posed by
the site.

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                                    51
7.0  Statutory Determinations

The EPA and FDER have determined that this remedy will satisfy the CERCLA
statutory requirements for providing protection of human health and the
environment, attaining ARARs related to other federal and state
environmental statutes, is cost-effective, and utilizes either permanent
solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable.

At the date of this decision, the selected remedial action meets all
Federal and State requirements.  However, EPA is currently reviewing
Harris compliance with the FDER UIC program as well as the Safe Drinking
Water Act.  As a result of this review, Harris may be required to make
modifications as necessary.
7.1  Protection of Human Health and the Environment

The selected remedy of groundwater extraction, treatment, and deep well
injection to the Floridan Aquifer is protective of human health and the
environment.  By containing the contaminant plume, treating the
contaminated groundwater, and removing the sources of contamination, this
remedy will eliminate the contaminant plume.  This remedy will eliminate
the risk of migration to the GDU well field and the entire potable
aquifer.  By reducing the level of contamination in the groundwater, this
remedy will reduce the carcinogenic and noncarcinogenic risks associated
with exposure to the untreated groundwater.

The existing treatment system was designed for treating groundwater in
order to meet cleanup levels established in the FDER/Harris Consent
Order.  In this system, treated groundwater is discharged to the Floridan
Aquifer rather than to surface water and, as a result, presents no
environmental risk.  This water is presently recycled for manufacturing
use as exhaust scrubber water before disposal via deep-well injection.

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                                     52
7.2  Compliance with Applicable or Relevant and Appropriate
     Requirements (ARARs)

This remedy assures that the contaminated aquifer will be cleaned up to
meet appropriate MCLa under the SDWA.  For those chemicals that do not
have an assigned- MCL, the ARARs based on to-be-considered health-based
values, FAC "free from" requirements, or SMCLs will be attained.
Discharge from the groundwater treatment system will meet either the UIC
permit injection standards or NPDES permit discharge limits under the
CWA.  The treated groundwater will meet RCRA Land Disposal Restrictions
prior to disposal.  The contaminant plumes will be monitored and
remediated according to the technical standards for RCRA corrective action
and closure.  In addition, emissions from the air stripper will comply
with the National Ambient Air Quality Standards.
7.3  Cost-Effectiveness

The EPA selected remedy, Alternative 3, allows for a higher degree of
overall protectiveness.  Modification of the existing extraction and
treatment system in accordance with the EPA groundwater remediation policy
will enhance cleanup of the aquifer.  Alternative 3 requires continuation
of the.existing process for discharging the treated groundwater by
injection into the Floridan Aquifer which is a nonportable water source in
the area.  However, this remedy allows for full characterization of
contamination at Government Systems and enhances the elimination of the
contaminant plume.  Therefore, the selected remedy yields an overall
effectiveness that ia proportional to its increased costs.
7.4  Utilization of Permanent Solutions and Alternative Treatment
     Technology or Resource Recovery Technologies to the Maximum Extent
     Practicable

EPA and FDER have determined that this remedy is the most appropriate
remedy for Operable Unit One and provides the best balance among the
evaluation criteria for the remedial alternatives evaluated.  Alternative

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                                     53
3 provides both short- and long-term protection to potential human and
environmental receptors.  This remedy allows for containing, treating and
eliminating the groundwater contamination in order to reduce risk from
potential exposure to the groundwater.  In addition, this remedy utilizes
a proven technology for treating VOC contamination and can be implemented
year round.
7.5  Preference for Treatment as a Principal Element

Groundwater contamination with volatile organic compounds is the principal
threat at the site.  Air stripping is an effective remediation method for
treating groundwater contaminated by VOCs.

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                     54
                 APPENDIX A
     REPORTS.ON PREVIOUS INVESTIGATIONS



CONDUCTED AT THE GOVERNMENT SYSTEMS FACILITY

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                                   55
                  Reports  on  Previous  Investigations
             Conducted  at  the Government  Systems Facility
CH2M Hill.  Phase I Report - Aquifer Contamination Studies at Port
    Malabar Well Field.  Document GN10067.JO.  August, 1983

CH2M Hill.  First Interim Report on Groundwater Contamination Studies
    at Port Malabar Well Field - Phase II.  Document GN16067.NO.
    February, 1984.

CH2M Hill.  Second Interim Report on Groundwater Contamination
    Studies at Port Malabar Well Field - Phase II.  Document
    GN16067.NO.  March, 1984

Geraghty & Miller, Inc.  Building 6 Ground-water Assessment -
    Government Systems - Harris Corporation, Palo Bay, Florida.
    July, 1987.

Geraghty & Miller, Inc.  Addendum to Building 6 Ground-water
    Assessment in Palm Bay, Florida.  July, 1988.
         ?
Geraghty & Miller, Inc.  Harris Corporation National Priority List
    Review of Remedial Investigations, Feasibility Studies and
    Remedial Actions, Government Systems Facility.  May, 1989.

Geraghty & Millar, Inc.  Summary of Soils  Investigations and Metals
    in Ground Water, Harris Corporation, Palm Bay, Florida.
    April 1990.

Post, Buckley, Schuh & Jernigan, inc.  Harris Corporation -
    Groundwater Studies - Vicinity of General Development Utilities
    and Palm Bay, Florida - Investigations:  March - October 1982.
    October 21, 1982.

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                                   56
Post, Buckley, Schuh & Jernigan, Inc.  Analysis of Potential
    Groundwater Withdrawal and Treatment Systems.  March 8,  1983.

Post, Buckley, Schuh & Jernigan, Inc.  Harris Corporation Task
    B-4 - Final Report of Hydrogeological Study.  Document
    780-002.34.  December 2, 1983.

Post, Buckley, Schuh & Jernigan, Inc.  Harris Corporation Task
    B-l - Soil and Sediment Investigation.  Document 780-002.31.
    March, 1984.

Post, Buckley, Schuh & Jernigan, Inc.  Harris Corporation Task
    B-2 - Surficial Groundwater and Analysis Summary Report.
    Document HCf7/780-002.32.  January 25, 1984.

Post, Buckley, Schuh & Jernigan, Inc.  Bench-Scale Treatability Study
    or Air Stripping of Selected Volatile Organics.  Document
    775-003.72.  April, 1984.

Post, Buckley, Schuh & Jernigan, Inc.  Harris Corporation Task B-8 -
    Old Storm Sewer Investigation Interim Report.  Document
    780-002.38.  May, 1984.

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               57
           APPENDIX  B
 UNDERGROUND INJECTION CONTROL



CLASS I PERMIT INJECTION LIMITS

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                              53
                 Underground  Injection Control
                Claaa I Permit  Infection Limits
 PERMITTEE:
 Harris Corporation
 SPECIFIC CONDITIONS:
  I.  D. Number:
  Permit/Certification Number:
  UC05-126519
  Dace of Issue:
  Expiration Date:  7/1/92
  9.  Monitoring   -  Deep  Injection Wells

     The  deep injection  well  shall  be  monitored  in  accordance with
     the   requirements  of  Rule  17-28.26(2).   F.A.C.    The   permittee
     shall  submit monthly a  report  which shall  at  a  minimum  include
     the  following  data  foe each injection well:
          Daily  specific  conductance
          Daily  pH
          Daily  temperature
          Daily  average  injection
          Daily  maximum  injection
          Daily  minimum  injection
          Daily  minimum  flow  rate
          Daily  average  flow  rate
          Daily  maximum  Clow  rate
          Total  volume discharged
          Total  volume discharged
         Monthly avecagt of  total

 9. Monitoring - Treatment Plant
pressure (psi)
pressure (psi)
pressure (psi)
(gpm)
(gpm)
(gpm)
•* Daily (gallons)
-» Monthly (gallons)
 volume discharge  per
day
    The effluent  stream shall be monitored monthly for the following
    parameters.   A  cop/ of these data shall be  submitted  monthly to
    the Technical Advisory Committee  (TAG).

                                                  Deep Well Effluent
    Trichloroethane. ug/1
    1.1.1.-Trichloroethane. ug/1
    Methylene Chloride, ug/1
    0-Dichl«obenzene. ug/1
    Tetrachlocoethene. ug/1
                         5
                         5
                        25
                         5
                         5
DEB Form 17-1.201(5) Effective November 30. 1982 Pag* 6 of 10

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                              59
 PERMITTEE:
 Harris  Corporation
 SPECIFIC  CONDITIONS:
                                    I. 0. Number:
                                    Permit/Certification Rumbec:
                                    UC05-126519
                                    Date of  Issue:
                                    e*pieaeion Date:  7/1/92
     BOD  5 Day
     Chemical Oxygen Demand  (C.O.D.). mg/1
     Dissolved Oxygen  (D.O.). mg/1
     Total Kjeldahl Nitrogen  (T.K.N). mg/1 as N
     Ammonia, mg/1 as  N
     Un-ionized Ammonia  (NH3), mg/1 at N
     Total Phosphorus  (TP). mg/1 as P
     Total Suspended Solids,  mg/1
     Arsenic, mg/1
     Cadmium, ug/1
     Chromium, mg/1
     Copper, mg/1
     Cyanide, ug/1
     Fluoride, mg/1
     Lead, mg/1
     Mercury, ug/1
     Nickel, mg/1
     Selenium, mg/1
     Silver, ug/1
     Zinc, mg/1
    •General Limitation;
                                                          5
                                                         10
                                                          0.05
                                                          1
                                                         10
                                                        200.0
                                                          O.OS
                                                          0.
                                                          0.
                                                          1
                                                         so
                                                          5
,2
,1
     	    Must  be  compatible  with  the  injection
                           system.  injection  zone,   and   confining
                           zone   and   not   hazardous  pursuant   to
                           Section  17-30.03(1).  Florida  Administra-
                           tive Cod*.

    The treatment  plant shall  be  operated  in such  a  Banner as  to
    maintain  specific  parameters  within  the  above  listed  effluent
    limitations.

10.  Monitoring - Monitor Wells

    A representative  ground  watec  sample shall 'be obtained  from  the
    monitoc well(s)  monthly.   These  samples  shall  be analyzed  for
    the following  parameters.   The results  of these analyses  shall
    be  reported in  the monthly  operating  report  submitted to  the
    department.
    Fluoride
    Total Kjeldahl Nitrogen
    pH
    Chloride
                                   TDS
                                   Specific Conductance (field)
                                   Total Phosphorus
                                   Sulfate
DER Form 17-1.201(5) Effective November 30. 1982 Page 7 of 10

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                       60
                  APPENDIX C
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM



            PERMIT DISCHARGE LIMITS

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                                                  61
                     National  Pollutant Discharge  Elimination  Syatera
                     	   Permit Discharge  Limits	
                                                                 Page 1-1
                                                                 Permit Mo.:   ?L003<681
                                                    PART t
A.   Epfwarr LIMITATIONS  AND MONITORING RBQUIRWENTS

1.   During the period beginning October  1,  1984  (or upon  start-up of discharge) and lasting through the term
     of  this  penult,  the permittee  is  authorised  to  discharge  froa  outfall serial  nunfeer  002,   treated
     groundwater  only.

Such discharges shall be Halted and monitored by  the permittee as specified below:
BrTLUENT CHARACTERISTIC         DISCHARGE LIMITATIONS
                         kg/day  (Ibs/day)       Other units (Specify)
                         Dally           Dally           Dally
                         Average         Maxtaua         Average
Plow.  M3/Oay (MOD)
Trlchloroethene
1,1 -d i ch loroethene
1, 2-cls-dichloroethene
1, 2-trans-dlch loroethene
Vinyl  chloride
1,1,1-t rlcn lor oe thane
1,1-dlchloroe thane
Nstnyl«ne chloride
1,2 dichlorobensene
Chlorobenxene
Ethyl  bensene
Ibluene
                                                        < 5juq/l
                                                        * 5>ig/l
                                                        <5;uq/l
                                                        < 5 ng/1
                                                        < 5 .wj/l
                                                        <5 ug/1
                                                       < 25
                                                       < 25
                                                       < 25
                                                                       MONITOR INC REQDIUBiaiTS
Heaaureaent
 frequency

Continuous
1/Wtek
I/Week
1/IHek
1/Heek
I/Keen
1/Ktek
I/Week
1/Htek
I/Wee*
1/Wtek
I/Week
Sample
 Type

Recorder
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
The pR shall not  be  leas than 6.0 standard units nor  greater  than  8.5 standard units and shall be Monitored
once per  week by grab sample.

There shall be no discharge of fleeting  solids or visible fo«si  in other than trace asounts.

Staples taken in  compliance with  the monitoring requireaenta specified above shall be taken at  the foil owl no
locatlon(a)!  nearest accessible point  after  final  treatment but prior  to  actual  discharge or nixing with  the
receiving waters.

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       RESPONSIVENESS SUMMARY

HARRIS CORPORATION / PALM BAY FACILITY
             SUPERFUND SITE
  PALM BAY, BREVARD COUNTY, FLORIDA

                JUNE 28,1990

                 VOLUME I
                 PREPARED FOR:
  U.S. ENVIRONMENTAL PROTECTION AGENCY
                REGION IV
               ATLANTA, GEORGIA
          EPA WORK ASSIGNMENT NO. 06-4X18
                   UNDER
          ARCS IV CONTRACT NO. 68-W9-0048
                 PREPARED BY:


         EBASCO SERVICES INCORPORATED
              145 TECHNOLOGY PARK
             NORCROSS, GEORGIA 30092
                 404/662-2300

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                     RESPONSIVENESS SUMMARY
       HARRIS CORPORA!ION/PALM BAY FACILITY SUPERFUND SITE
                        TABLE OF CONTENTS

Section                                                     Page
1.0  INTRODUCTION                                             1
2.0  OVERVIEW OF THE PROPOSED PLAN                            3
3.0  BACKGROUND ON COMMUNITY INVOLVEMENT                      5
4.0  SUMMARY OF COMMENTS RECEIVED AND AGENCY RESPONSE         7
     4.1  Health Issues                                       7
     4.2  Technical Issues                                    19
     4.3  Air Quality Issues                                  24
     4.4  Water Treatment Issues                              25
     4.5  Local Well Water Supply Issues                      26
     4.6  Soil Testing Issues                                 27
     4.7  Water Utility Cost and Service Issues               29
     4.8  Harris Corporation Comment                          30
     4.9  General Development Utilities Comment               36
5.0  REMAINING PUBLIC CONCERNS                                39

Exhibits
Exhibit 1  Exposure and Odor Parameters for Various           14
           Volatile Organic Compounds
Exhibit 2  Degradation Reaction of Trichloroethylene          21
Exhibit 3  Government Systems Soil Sample Locations           28

Attachments
A    Proposed Plan Fact Sheet
B    Press Release and Legal Notice
C    Media Coverage
D    Record Of Public Meeting Attendance
E    Transcript of Public Meeting
F    Public Meeting Handouts
G    Written Public Response
H    Harris Corporation Response
I    General Development Utilities Responses

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1.0  INTRODUCTION

A  public  meeting  addressing  the  Harris  Corporation/Palm  Bay
Facility  Superfund  Site  was  held  by  the  U.S.  Environmental
Protection Agency (EPA),  Region  IV,  at  the  Palm  Bay  Community
Center in Brevard County, Florida on March 27, 1990.  The meeting
was chaired  by Ms.  Camilla  Warren,  Chief  of the  South Florida
Superfund Section.  Other attendees from the EPA Region IV office
in  Atlanta,  Georgia  were Ms.  Gail  Scogin,  Superfund  Remedial
Project Manager  for  the  site;  Ms. Suzanne  Durham,  the Superfund
Community  Relations   Coordinator;  Ms.   Becky  Fox,   Regional
Toxicologist and  Mr.  Robert James from  the  Office  of  Regional
Counsel.  Mr. Joe  Applegate, State Project Manager with the Florida
Department of Environmental Regulation  (FDER) and Mr. Larry Sims
from  Geraghty  &  Miller,  Incorporated,   a consultant  for  Harris
Corporation,  presented information on the site history and actions
taken to date.

The  purpose  of  the  meeting  was  to inform  the public of  the
groundwater remediation alternatives considered at the Government
Systems facility on the Harris  site and to discuss the alternative
preferred  by  EPA.    EPA  first  presented  the  evaluation  of
alternatives  and  the preferred  alternative  in the  Superfund
Proposed  Plan  Fact Sheet  mailed  to  members of  the  community on
March  16,  1990 (Attachment A).   This  Fact Sheet was  also made
available to the public along with the Administrative Record  at the
Palm  Bay  Public Library.  EPA announced the public meeting and
document availability in  a  legal advertisement in  the Florida Today
Sunday newspaper on March 18, 1990 (Attachment B).  The fact sheet
and legal notice  announced the public comment period which began
on March  18, 1990 and ended on April  17, 1990.   Local newspapers
published articles on site issues on  December 13, 1989 and March
25 and 27, 1990 as shown in Attachment C.

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This Responsiveness Summary documents the comments received by EPA
Region IV during the public comment period regarding the proposed
cleanup alternatives described in the Proposed Plan Fact Sheet and
as presented  at the public meeting held March  27,  1990.   This
Responsiveness Summary provides the EPA with information about the
views  of  the  Community  and  potentially  responsible  parties
regarding  the proposed  remedial  action and  alternatives.   The
Responsiveness  Summary  documents how public  comments  have  been
considered during the decision-making process and provides answers
and information to questions and issues raised.  The Responsiveness
Summary becomes available to  the  public as part  of the Record of
Decision (ROD) upon signature by the Agency.

The  record of  attendance,  provided as Attachment  D,  lists  49
attendees  including  representatives  from  Harris  Corporation,
General Development Utilities, Incorporated (GDU), Florida Audobon
Society, Turkey Creek Sanctuary Advisory Board,  Florida Institute
of Technology, the Orlando  Sentinel  newspaper, South Brevard Water
Authority as well as city,  county and state officials.

Attachment E contains the transcript of the public meeting. EPA and
Harris Corporation utilized overhead transparencies in the meeting
presentations   to   describe   the   site   history,   groundwater
contamination, and the  existing Harris remediation program as well
as five  additional remedial  action alternatives.    EPA provided
copies of the overheads and other information to meeting attendees.
Attachment F contains the meeting handouts.

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2.0  OVERVIEW OF THE PROPOSED PLAN

Of the  six alternatives evaluated,  EPA  has determined  that  the
preferred  alternative  is  Alternative  3,  modification  of  the
existing groundwater extraction and treatment system.  Alternative
3 compares favorably with the alternatives based on an evaluation
using the nine criteria mandated by  the  Superfund Amendments  and
Reauthorization Act of 1986  (SARA).   EPA defines Operable Unit One
as the  groundwater contamination associated with  the Government
Systems facility at Harris.  EPA has further  identified at least
one additional operable unit  for management of response activities
at other portions of the site.  Any additional operable units will
involve subsequent RODs.

This  ROD presents  Alternative 3  as the  appropriate  course  of
remedial action for Operable Unit One at the Palm Bay site.  This
remedy  consists  of  (1)  continued   operation  of  the  existing
extraction and treatment system,  (2)  a design analysis for plume
containment and treatment,  (3)  modification  of the system based on
results of the  design analysis,  (4)   continued  monitoring  of the
cleanup, and (5)  a  review of the system and cleanup progress by EPA
and FDER after a period of five years.

Based on comments  received during the public  comment period,  the
residents  and  local  officials  are  amenable  to  EPA-directed
modifications  to the  existing treatment system.    However,  one
resident stated  specifically that  he is against  the use of deep
well reinjection.   Citizens  submitted ten response cards to EPA,
six at  the conclusion of the public  meeting  and  four during the
public  comment  period.   In  addition, EPA  received five letters:
one letter presented at the public meeting by counsel for GDU and
four mailed  in during the public  comment period.   Attachment G
contains all written comments from the public received during the

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public  comment  period.    Attachment  H  contains  the  response
submitted by Harris Corporation, the potentially responsible party
(PRP).   Attachment I provides GDU comments and responses received
by EPA.

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any  potential threat  to  human health.    FDER  also  identified
successful groundwater treatment methods being used by both Harris
and  GDU.     Other  public   concerns  included   surface  water
contamination, especially if  it  should reach Turkey Creek, as well
as potential increases in water utility rates.

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4..0  SUMMARY OF COMMENTS RECEIVED AND AGENCY RESPONSE

Comments raised  during  the Harris Corporation/Palm  Bay  Facility
public comment period on the proposed plan are summarized briefly
below.  The comment period was held  from  March 18,  1990  to April
17, 1990.  All written public comments received by EPA are provided
as Attachment G.   The comments are categorized by relevant topics.

4.1  Health Issues

1.  Has a health risk analysis been performed at the site, and if
so, is it available to the public?

     EPA Response:   In October,  1988 the Florida  Department of
     Health  and  Rehabilitative  Services  (FDHRS)   published  a
     preliminary  Health  Assessment prepared  for  the  Agency  for
     Toxic Substances and Disease Registry  (ATSDR).   This report
     states that  "based  on the existing  condition  of  the Harris
     Corporation  site,  the potential environmental pathways of
     concern  are  migration  of   contaminated  groundwater  and
     windblown volatile organic compounds from the  air stripper.
     Potential human  exposure  pathways  of  primary concern  are
     ingestion and dermal absorption of contaminated groundwater,
     and inhalation of off-gassing volatiles from the air stripping
     system.11

     During pilot  testing  of  the air stripping tower  at Harris,
     FDER  analyzed  projected  air  emissions.    This  analysis
     indicated that the projected volume of emissions was not high
     enough to present an unacceptable health  risk.  EPA performed
     a  similar analysis  in February,  1990  using  the  FDER  air
     emissions criteria used  for the pilot test on the  1988  and
     1989 air stripper data from Harris. This  analysis  showed that
     the air stripper emissions  in  1988 and 1989  were within the
     limits used by FDER for the projected emissions.

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     Since the original FDER analysis,  the exposure limits for many
     of the volatile organic compounds have been reduced and newer
     clean air regulations have been enacted by  Florida  and EPA.
     EPA is currently analyzing the air  stripper emissions using
     the most recent  Florida  and  EPA criteria and  comparing the
     results with health risks and the recently revised Clean Air
     Act and  FDER equivalents.   EPA will  require  that the  air
     stripper emissions comply with the new requirements.

     In  order  to  address  the  remaining  exposure  pathway  of
     groundwater ingestion,  EPA prepared a risk (or  endangerment)
     assessment based on the available groundwater sampling data.
     This risk assessment, in the form of a memo, shows the results
     of calculations for  the risks associated with the consumption
     of groundwater.   These calculations indicate  that  drinking
     untreated groundwater at Government Systems would constitute
     an unacceptable human health  risk.   This memo as well  as the
     other  EPA   and   ATSDR  documents  are  available  in  the
     Administrative Record for public review.

2.   Do VOCs  in  groundwater percolate up through the soil  - or
concrete, if there are cracks in the concrete?

     EPA Response;  According  to ATSDR, it is possible for VOCs to
     volatilize from the water table and migrate through the soil
     and cracks in the concrete to reach the  air above ground.  The
     VOCs migrating through the soil typically  enter the air via
     the soil/air interface or via cracks  in the concrete in areas
     where the soil is covered.

     Some workers  at  the site have expressed concern about VOCs
     entering the buildings.   A National Institute of Occupational
     Safety  and Health  (NIOSH)  representative  states that  the
     migration  of  VOCs through cracks  in concrete  and  into the
     buildings is unlikely to cause a health hazard at this site.
     While  it is possible for VOCs  to enter the buildings,  the

                                8

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     health hazard would be minimized by the air exchange rate in
     the buildings and  the  dilution  of the VOCs by  the  existing
     air in the buildings.   Please see the response to Question 3
     for more information.

3.  Are there any risks at this site  from breathing either indoor
or outdoor airborne contaminants?

     EPA Response;  FDER analyzed outdoor emission projections for
     the  air  stripper  which  do  not  indicate  that  inhalation
     presents  a  health-based risk at this  site.    Further,  EPA
     received the results from indoor  air quality studies performed
     in November,  1989  by NIOSH  and concurrently by  the Harris
     Corporation Health and  Safety   Department.   The  detection
     limits that NIOSH used are well  below the levels established
     by the Occupational Safety  and  Health Administration (OSHA)
     as permissible for  an eight hour  occupational exposure.  These
     studies  indicate that  the indoor  air in Building  8  on the
     Harris  facility  is not contaminated  with  airborne  volatile
     organic compounds.   In  addition,  the health symptoms reported
     to NIOSH in a self-administered  employee questionnaire "were
     mostly respiratory and sinus complaints which could have been
     the  result of  allergies,  colds, or episodic  respiratory
     infections commonly experienced  by any worker population."

4.  Is it acceptable for people to be working at this site?  What
are the risks,  health effects,  or possibility of  one  dying as a
result  of working 10 or  20 years  at this  site  in  a  location
directly above the  area of highest concentration  in the groundwater
plume?

     EPA Response;  Various  studies  and investigations have been
     conducted  at  the  site by  FDER,  USEPA,  ATSDR,  and NIOSH.
     Neither the information available  from these studies nor the

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     scientific  literature indicate  that  undue  or  significant
     adverse health effects can be expected or have been observed
     from exposure to the VOCs in the groundwater.

     In addition,  there  is no  information in the  scientific  or
     medical literature  that  addresses the possibility  of  dying
     from long term above-ground exposure to VOCs in groundwater.
     Further comments on this issue would be conjecture.

5.  Has  any health monitoring for chemical toxicity  symptoms  in
workers been done at this site?  If so,  are  these reports available
to the public?   Will medical  profiles  be established  for workers
at the site?

     EPA  Response;   These  are  issues  that  are  appropriately
     directed  to  the   Harris   Corporation  Health  and  Safety
     Department.  EPA contacted Harris  and  determined that certain
     Harris employees undergo routine medical monitoring based on
     the potentially hazardous  nature of  their jobs.   However,
     monitoring of other workers  at the site would be initiated at
     the request of an  individual  employee  or Program Director,  in
     the case of  a non-Harris employee.   Harris  reported that  to
     date  there  have  been no  individual  requests for  medical
     surveillance.

6.  Have local  cancer  rates  been studied  to  see  if there  is a
correlation between chemical exposure at Harris and the incidence
of cancer?

     EPA Response; EPA is not aware of any such studies.  However,
     the FDHRS  maintains a cancer surveillance program  on  each
     county in Florida.  One can obtain further information from:
                                10

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          Dr. Roger Inman,  Chief
          Toxicology and Hazard Assessment Section
          Florida Department of Health and Rehabilitative Services
          1317 Winewood Boulevard
          Tallahassee,  FL  32301

     The telephone number is (904)  488-3931.

7.  Have local health officials/professionals been given detailed
information about the location, type, and  toxicity  levels  of the
chemical pollutants related to this site?

     EPA Response;  Information on chemical pollutants at this site
     is publicly available  in two ways.  First, EPA established an
     information repository on March 6, 1990 containing information
     about  the  groundwater  contamination associated  with  the
     Government Systems facility.   Second, the Emergency Planning
     and Community Right-to-Know Act of 1986 (also known as Title
     III) establishes requirements  for  federal,  state,  and local
     governments and  industry  regarding  emergency planning and
     "community  right-to-know"  reporting on hazardous  and toxic
     chemicals.

     OSHA requires companies to compile information on the identity
     of hazardous chemicals used or produced including the health
     and physical  hazards  as  well  as  exposure  limits  for these
     chemicals.  This information  is reported on Material Safety
     Data Sheets (MSDSs).

     Section 311 of the Emergency Planning and Community Right-to
     Know Act  (Act)  requires facilities that  must  prepare MSDSs
     under OSHA regulations to submit either copies of their MSDSs
     or a list of  MSDS  chemicals  to the local emergency planning
     committee  (LEPC),  the  state  emergency  response  commission

                                11

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(SERC) ,   and  the  local  fire  department.    If  a  list  is
submitted, the facility.must submit a copy of the MSDS for any
chemical on the list at the request of the LEPC or SERC.

The LEPC for Brevard County,  Florida is based in Winter Park
and the contact person is Leslie Banks who can be reached at
(407)  645-3339.   The  SERC is located  in  Tallahassee  and is
comprised of  members  who are  appointed by the  governor to
oversee  and implement Title  III  provisions.   The  contact
person  for  the  SERC   is  Jim  Loom is  of  the  Department  of
Community Affairs.  He can be reached at (904) 488-1472.

If the  facility  submits  a list of MSDS  chemicals,  the list
must include the  chemical or common name of each substance and
must  identify  the applicable hazard  categories.    These
categories include among  others, the immediate (acute)  health
hazard and delayed (chronic)  health hazard.

Section 313 of the Act requires EPA to establish an inventory
of routine toxic chemical emissions from certain manufacturing
facilities.  These facilities  must have more  than ten full-
time  employees and manufacture,  process or otherwise  use a
listed  toxic  chemical  (from  a  list  containing  over  300
compounds) in excess of specified threshold quantities.  For
example, facilities manufacturing or processing any of these
listed  chemicals in  excess  of 50,000  pounds in  1988 were
required  to report to EPA by July  1,  1989 their  routine
releases to the environment.   This information is maintained
in the Toxic Release Inventory  System  (TRIS) database as well
as  TOXNET,  a  similar database  that  is  accessible to the
public.   EPA has  confirmed that Harris reported routine toxic
chemical emissions under Section 313  for 1987  and 1988.  This
information  is available on  request  under the  Freedom of
Information Act by contacting:
                           12

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          Ms.  Phyllis strong
          Office of Public Affairs
          U.S. Environmental Protection Agency
          345  Courtland Street.N.E.
          Atlanta,  GA  30365

8.  At what level is vinyl chloride or the other volatile organics
at the site toxic  in  air and water?  At what concentrations  can
these compounds be  smelled?

     EPA  Response;    The  OSHA  Permissible   Exposure  Limit  for
     airborne  vinyl chloride  (VC) in the workplace  is  1 part  per
     million (ppm)  over an eight hour period.   In drinking water,
     the health-based risk for VC is 0.02 parts per billion (ppb).
     The odor  threshold for VC in air is 260  ppm.

     Exhibit  1  and the  following discussion give  more detailed
     information about the toxic  levels for VC and  other VOCs in
     air and water.   For water, health-based  risk  levels can be
     expressed  as   concentrations  representing   the  lifetime
     consumption level that would result in an  additional increased
     lifetime  cancer risk of  one  in one million.   For air, three
     primary  health-based  risk  levels  are  used  to  determine
     acceptable exposures in the workplace.   These levels are the
     Threshold Limit  Values  (TLV) as determined by the American
     Conference  of Governmental  Industrial   Hygienists   (ACGIH),
     Permissible Exposure Limits (PEL)  enforced by the Occupational
     Safety and Health  Administration  (OSHA),  and  Recommended
     Exposure Limits (REL) determined by NIOSH.

     The  TLVs  as  defined   by  the   ACGIH   refer  to  airborne
     concentrations of substances and represents conditions under
     which it  is believed that nearly all workers may be repeatedly
     exposed  day after day without  adverse  effects.   There  are
     three categories of TLVs which are specified as follows:
                                13

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                            Exhibit 1

                EXPOSURE AND ODOR PARAMETERS FOR

               VARIOUS  VOLATILE ORGANIC COMPOUNDS
Acceptable
Volatile Organic Water
Compound Cone, (DPb)
Vinyl Chloride*
1, 1-Dichloroethane
Methylene Chloride*
Trichloroethylene*
Chlorobenzene
1, 2-Dichlorobenzene
1 , 2-Dichloroethylene
Ethyl Benzene
1, 1-Dichloroethylene*
Toluene
0.02a
0.4a
4.8a
3.2a
140
630
140
700
0.06a
	
Air
Exposure
Limits fppm)
lb
100b
500°
100d
75b.c
50b'9
200b'c
100b'c
lb
100b.c,d
Odor
Threshold
(coml
260 f
120 '
212 f
21 f
0.2f
0.39
1.0f
2.39

4.79
Notes;

*    Human or suspected human carcinogen

a    This  concentration  represents  the   lifetime  groundwater
     consumption level that would result in an additional increased
     lifetime cancer risk of one in one million.

b    PEL

c    TLV

d    REL

e    TLV-C

f    Source:     American  Society   for   Testing   and  Materials;
     Publication DS-48A; Compilation of  Odor  and Taste Threshold
     Values Data.

g    Source:   Amoore J.E.  and Hautala E., 1983.  Odor as an aid to
     chemical safety:   Odor  thresholds compared  with threshold
     limit values and volatilities  for 214 industrial chemicals in
     air and  water dilution;  Journal of Applied Toxicology; 3:272-
     290.

                                14

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          a)    Threshold Limit Value - Time-weighted Average (TLV-
               TWA)  - The time-weighted average concentration  for
               a normal 8-hour  workday and a 40-hour work week to
               which nearly all workers may be repeatedly exposed,
               day after day, without adverse effects.

          b)    Threshold Limit Value - Short  Term  Exposure Limit
               (TLV-STEL)  - A  15 minute time-weighted  average
               exposure which should not  be  exceeded at any time
               during a work day even if the 8-hour time-weighted
               average is within the TLV.   Exposures at the STEL
               should not be longer than 15 minutes and should not
               be repeated  more  than  four times per day.   There
               should be  at least 60 minutes  between  successive
               exposures at the STEL.

          c)    Threshold  Limit   Value  -  Ceiling  (TLV-C)  -  The
               concentration that should not be exceeded during any
               part of the working exposure.

9.   Several people working on the site have expressed concern that
a very serious and unaddressed problem exists that is threatening
worker health.    For  example,  a  government employee working in
Building 8 on the Harris Government Systems facility is concerned
about an  undiagnosed  persistent cough she  has experienced since
beginning work at the  site in 1985.  She explained that none of the
35 people in her office were informed that they work ten feet over
groundwater containing toxic wastes.  Although  she has not noticed
any VOC odors,  she is concerned about VOCs percolating into the
building  due to  a groundvater  to  air media  transfer  and  the
resulting potential adverse health effects.
                                15

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     EPA Response:  Air sampling conducted at Building 8 by NIOSH
     and the  Harris Health and  Safety Department  identified  no
     airborne contamination in the breathing  zone.   At this time
     EPA has  not  performed a risk  analysis for an  air exposure
     pathway.

     Although he sees no cause for alarm,  an ATSDR representative
     has advised  this  employee  to  contact her management about
     relocating  to  a  different  office  space if  necessary  to
     alleviate these concerns.

10.  The same government employee filed a  NIOSH  complaint which
resulted in a NIOSH air quality study conducted by  Mr.  Stanley
Salisbury  in   November,  1989.    The  employee identified  three
concerns about how the study was conducted:

     A.   Mr.  Salisbury reportedly normally deals with air quality
     issues relating to dust, spores, and bacteria rather than with
     toxic waste.

     B.   NIOSH conducted  the study during the cooler  month  of
     November and, in addition,  the air conditioning system which
     had not been operating formerly was running during the test.
     She believes that these factors may invalidate the test.

     C.   The  results  reported  values  in  the parts  per million
     range and she is concerned about parts per billion exposure.

In  addition,  has  any  other  air quality  sampling  been  done  in
Building 8 or elsewhere at the site?

     EPA Response;  The detection limits used by NIOSH were several
     orders of magnitude below the OSHA Permissible Exposure Limits
     for workers.   Also,  the existing  occupational  air exposure
     standards for  vinyl  chloride,  for example, is  in the parts
     per  million  range.    Levels  of  vinyl  chloride  in  the

                                16

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     groundwater are reported in the parts per billion  range  and
     therefore,  would not likely result in any significant  human
     exposure.

     EPA contacted Mr.  Salisbury to address  the  above-mentioned
     concerns  about  the  study.    He  stated that  he  has  had
     significant experience with indoor air  quality  and measured
     for "the six VOCs present in groundwater at concentrations in
     excess of the current groundwater standards" according to the
     established NIOSH  protocol.   He  confirmed  that the  Harris
     Health  and  Safety  Department   conducted   concurrent  air
     monitoring during  his  visit.   The Harris Health and  Safety
     Department's results were consistent with the NIOSH results
     which indicated no measurable VOC airborne contamination.

     EPA  contacted  Harris  to  determine  whether  or  not  any
     additional  indoor  air monitoring has  taken place.   Harris
     reported previous  sampling for VOCs  and carbon dioxide in
     response to worker concerns  about  contamination  from past
     manufacturing operations  in Building 6.   This sampling is
     consistent  with the  Harris policy in  which the Health  and
     Safety Department conducts air monitoring on request for the
     numerous buildings at the site.
         «

11.  Is the  contaminated groundwater getting to  GDU?  If so,  how
much contamination is the public receiving  from the drinking water?

     EPA Response:  The contamination has  reached some of the GDU
     wells.  At least one of the wells has been shut down and the
     water from several other wells is being pre-treated for VOCs
     using an air stripper.  The water undergoing pre-treatment is
     tested before and after air stripping.  The VOC test results
     after air stripping do not show VOCs to be present above the
     detection  limits  (measured  in  parts   per  billion).    In
     addition, the finished water distributed to Palm  Bay residents
     is tested before distribution.  The VOC test results for the
     finished  water  do not show  VOCs to be present  above  the

                                17

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     detection limits  (measured in parts  per  billion).   Sampling
     analyses indicate that the residents  receive  water from GDU
     that meets drinking water standards.

     In April, 1989  GDU  had Target Compound  List  (TCL)  analyses
     performed on water samples from eight production wells before
     pre-treatment and on one finished water sample.   Pesticides,
     PCBs, and semi-volatile organics were  not  present  above the
     detection limits (measured  in parts  per  billion)  in  the
     samples from the production wells.  Several VOCs were detected
     in the samples from the production wells,  but were not present
     above  the  detection limits  in the  finished  water.   Lead,
     chromium, and  zinc were  present  at  low concentrations  in
     several of the  production wells, but  the levels were within
     the primary and secondary drinking water standards.

     The  finished water sample analyses  showed no  contaminants
     above  the  detection  limits,  except  for   several  trihalo-
     methanes, chromium,  and zinc.  The trihalomethanes, which are
     common  VOCs  in  finished  water,   were  detected  at  low
     concentrations but were within the total trihalomethane MCL
     (100 ppb) for finished water.  The chromium and zinc values
     were below the  primary maximum contaminant level  (MCL)  for
     chromium (MCL is 50 ppb) and the secondary maximum contaminant
     level (SMCL)  for zinc (SMCL is 5000 ppb).

12.  A resident asked why the air stripping tower contained no air
pollution control devices, and if anyone performing maintenance of
this air stripper would be in any danger from the emissions.

     EPA  Response;    Before  construction  of this  tower,  FDER
     analyzed the projected  emissions based on  the volume  of
     groundwater to be treated.   FDER determined that based on an
     eight-hour  occupational exposure  and   24-hour  residential
     exposure over a long period  of  time, the  treatment system
     design would present no significant short or long term risk.
                                18

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4.2  Technical Issues

1.   Why does EPA want to modify the current treatment facilities?
Couldn't  modification cause  leakage  between  the  aquifers  from
further drilling or maintenance?

     EPA Response;  The current EPA cleanup goals are significantly
     different from  those  identified  in the FDER  Consent  Order.
     Therefore,  a  treatment  system  that  meets   the  criteria
     specified in  the order would  not  necessarily meet the EPA
     criteria  for  cleanup of the aquifer.   For  example,  vinyl
     chloride and trichloroethylene now have more stringent cleanup
     goals.  These and the other EPA cleanup goals are specified in
     the Record of Decision.

     EPA and FDER  will oversee  a  monitoring  program to determine
     when the aquifer has been remediated to an acceptable level so
     that the  treatment system  is no longer required.   A  design
     analysis  will   help  determine   system  effectiveness  and
     efficiency as well as predicting the remediation time frame.

     It is unlikely that modifications to the existing remediation
     system  would  result  in  leakage between the  aquifers.   The
     additional monitoring wells which are being considered would
     be drilled using established  methods that minimize the chance
     of  creating  remedy-related  leakage  between  the  aquifers.
     These drilling methods offer the ability  to place casing in
     the borehole  at  selected depths to effectively seal off one
     aquifer froa another.
                                19

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     EPA  and  FDER  would  review  any  proposed  drilling,   well
     installation, or  well  completion procedures  for  compliance
     with EPA-accepted procedures prior to drilling.  EPA and FDER
     would also  check that procedures would not  create  leakage
     between the  aquifers  in  situations  where several  aquifers
     would be dri-lled through or result in potentially contaminated
     fluids inside the casing  from one aquifer being introduced to
     another aquifer.  Deviations from accepted procedures  would
     be  corrected prior to  actual  drilling.   EPA and/or  FDER
     representatives  would  be  present   during  drilling,   well
     installation, and well completion activities  to confirm that
     proper procedures had  been followed.

     In addition to the above precautions, unused monitor wells or
     suspect monitor wells would be decommissioned to prevent them
     from being  or becoming potential conduits for downward or
     upward migration  of contaminants.  Decommissioning  would be
     in  accordance  with  recognized  methods which prevent  the
     creation of vertical conduits between the aquifers by removing
     the materials used to construct  the  decommissioned  well and
     sealing the decommissioned well borehole with an impermeable
     grout.

     The groundwater  treatment system would continue  to  operate
     during any decommissioning or additional drilling procedures.

2.   Do volatile  organics decompose on their own  naturally?   Do
they decompose to safer or more harmful components?

     EPA  Response;    Some  decompose  to  safer  materials  and
     eventually to carbon dioxide  (C02).  Others decompose through
     intermediary stages that become more  toxic.  The decomposition
     of trichloroethylene (TCE) to  vinyl  chloride (VC),  shown in
     Exhibit 2, is an  example  of the organic degradation product
     being more toxic than the original contaminant.
                                20

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                                         Exhibit 2
                 Degradation Reaction of Trichloroethylene
          1,1 DCE
                                           TCE
TRANS 1,2 DCE
                                     VINYL CHLORIDE
                                                                          DCE - Dichloroethylene
Source: McKown. GO... G.W. Dowoon, and CJ. Engfeh, 1987. Critical
      ElemcntB in Site Characterization. In: Ground-Water Monitoring
      Seminar Seriee; Techncal Papere. U.S. EPA(CEFU-87-7)

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3.   What was the Hazard Ranking System rating for Harris and how
does this compare with other sites?

     EPA Response;   The Hazard  Ranking  System  (HRS)  involves  a
     mathematical  model  which  scores  sites  from  0  to  100,
     indicating the probability  and magnitude of  risk  to public
     health and the environment.  Any  site  with  a score of 28.50
     or higher is eligible for inclusion on the National Priorities
     List  (NPL),  which  would make  available federal  Superfund
     monies for cleaning up the site as necessary.   The highest
     score received by a site is 75.60.  The Harris site received
     an HRS ranking of 35.52.

4.   What is done with the  contaminated  waste that is eliminated
from the water at Harris?

     EPA Response;  VOCs in the  groundwater are  removed from the
     water in  an  air stripping  tower.   The design  of  the tower
     allows the volatiles to disperse into the air at a rate that
     yielded  an  acceptable  risk range  for protection  of human
     health based upon the FDER projected emissions calculations.
     The treated groundwater is used as process water in parts of
     the' Harris  manufacturing process.   This  process  water  is
     subsequently discharged  into  a deep saline  aquifer under  a
     permit from FDER.

5.   Is Harris introducing new waste products into the aquifer or
has that been stopped?

     EPA Response;  EPA  is  not  aware of  any new contamination as
     a result of the  current operations  at  the site.  However,  a
     comprehensive analysis .of potential  source areas may identify
     any ongoing, previously unidentified contamination areas.
                                22

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6.   Can the water at the 40  foot zone migrate in directions other
than the southerly direction indicated by the water level contour
map?

     EPA Response;  In general, the groundwater flow direction may
     be determined from water level contour maps by drawing lines
     that inters'ect  the  water level elevation contours  at right
     angles.   This  indicates that  the overall  groundwater flow
     direction  at  Harris is  southerly  in  the  40  foot  zone.
     Localized deviations with more southeasterly or southwesterly
     directions can occur in  areas where the water level elevation
     is irregular  or where the distance between the  water level
     elevation  contours  is large relative  to the  difference in
     water level elevation thereby creating a nearly flat gradient.
     However, these  localized deviations  resume  a  southerly flow
     direction within short distances.

7.   How close  are these  contaminants  to  the surface  and what is
the highest concentration  found there?

     EPA Response:   Volatile  organic  contaminants  are present in
     the groundwater within  15  feet below the ground surface in
     some  areas   of  the Government   Systems   facility.     The
     contaminant concentrations measured in groundwater from SP-2
     (located near  Building  6 in the  15-foot zone)  in December,
     1986, are:
          42 ppb 1,1-dichloroethane (DCA)
          19 ppb chloroethane
          1.7 ppb trans-l,2-dichloroethylene
          1.5 ppb vinyl chloride
          1.2 ppb trichloroethylene
                                23

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4.3  Air Quality
1.   What is the possible  interaction of  volatile  compounds  with
other waste gases or airborne products from nearby sources and what
kind of effects does it have on the atmosphere?

     EPA Response;   EPA has not looked at local waste  gas  issues
     since the primary risk being addressed  by the  Agency at  this
     time is groundwater.  However, the State  is involved  in air
     analyses  at  and  around  the  site.    EPA will  continue  to
     coordinate any  further analysis with  the State.    However,
     during pilot testing  of  the  air stripping tower  at Harris,
     FDER  analyzed  projected  air  emissions.    This  analysis
     indicated that  the projected emission volume would not be high
     enough to present an unacceptable health risk.

2.   What are the other waste gases that are being discharged from
Harris Corporation or any other industries in the  area?

     FDER Response; The  FDER  Air Section has  collected  some air
     samples; specific information  is available from Chuck Collins
     at the FDER district office in Orlando.  His telephone number
     is (407) 894-7555.

3.   Numerous  residents  have  complained  to  City  officials  and
agencies about  odors coming  from  or around  the  area of  Harris
Corporation.  Neither FDER  nor the local fire department have been
able to identify the source.  One resident  mentioned that the smell
is heavy and sweetish.   Others  describe chlorine  or aspirin-like
smells.  The  sweet,  heavy odor occurs frequently  after  sundown,
sometimes until the  early morning hours.   This  smell can be so
repulsive  in  the  area where  one resident  lives  west of  Harris
Semiconductor that she does not go outside.  She and others are now
concerned that the odor could be from the air stripper and would
like  to know  how  to recognize the  smell  of volatile organic
compounds .
                                24

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     EPA Response:   EPA  has been  informed  by the  City of  the
     concerns of the odors and will continue to work with FDER who
     is the agency addressing this concern.   City  officials  have
     informed EPA that  this odor problem is recent.  Since the air
     stripper operation has  been ongoing  for  several years,  FDER
     will also be investigating any new sources.   Exhibit 1  (see
     page 14)  indicates the odor thresholds for various VOCs.

4.4  Water Treatment Issues

1.   What is done with the sludge residue which remains after water
treatment processes at GDU?

     GPU Response;  Sludges  from wastewater  is  treated with lime
     and is trucked as mil-organite  to  farms  for disposal  on
     pasture land.   It has some fertilizer value to  it and no heavy
     metals.   It is  tested quarterly and  meets  the  regulatory
     requirements for that type of disposal.

2.   What happens to water that is deep well injected?

     EPA Response;  Treated water is injected into a deep well in
     a  saline aquifer  which is  not  potable  or  acceptable for
     irrigation.  This disposal method is currently  operating under
     an FDER underground injection permit.  A consultant for Harris
     Corporation indicated that the case depth of the well is 2000
     feet and the aquifer  is  an open hole  to 2500 feet.  Monitoring
     wells overlaying this zone have not detected any leakage from
     the wells into other aquifers.

3.   Members of  the audience were  aware  that  GDU  had shut down a
well recently  because  of  VOC  contamination.    One member of the
audience wanted to know  how EPA can  say that Harris wells are
successfully capturing contaminants from their site when a GDU well
has to be closed due to increased contaminants.
                                25

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     EPA Response;  The GDU well that was shut down about 4 months
     ago was not part of the treatment system.   However,  none  of
     the GDU wells undergoing treatment contains volatile organics
     which exceed the allowed maximum contaminant  level (MCL) ,  even
     before treatment.

     The GDU well that was shut down  is  near  the Harris Building
     100, recently identified as an area of contamination.  It  is
     not uncommon  to find new areas of contamination or  trace
     contaminants during an investigation.  EPA is addressing these
     findings in a  subsequent  operable  unit or as a part of the
     system modification in this  Record  of Decision.   GDU has a
     program in  place  to  assure that the public water  supply  is
     tested and meets drinking water standards  before it leaves the
     plant.

4.5  Local Well Water Supply  Issues

1.   A resident living just west of the Harris site was concerned
about the circumstances under which groundwater would migrate from
Harris  in  a westerly  direction  and  thereby be  drawn into the
residential sprinkler system.

     EPA Response;  It is unlikely that groundwater would migrate
     westward  from the  Harris site.    Private wells  used  for
     sprinkler systems will not significantly  impact the southward
     directional  draw  of  groundwater which  is  created  by  the
     extraordinarily  large pumping  rate   required  at  the  GDU
     wellfield.

2.   A residential subdivision  east of Turkey Creek is not serviced
by  GDU.    A resident  of  this subdivision wanted  to  know the
possibility of contamination  in their local  wells,  perhaps  from
isolated contaminated groundwater pockets from years ago.

     EPA Response;  If  there  is concern about  the water quality or
     another potential  source of contamination nearby, EPA suggests

                                26

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     that the resident contact the local health department or FDER.
     Without additional information regarding the  local  wells  in
     question, further discussion would  be speculative.

3.   Another resident is concerned about whether well surveys have
been done for residential  wells near the Harris property.  No one
knows how long contaminated groundwater  may have been consumed by
residents, since the contamination was not found until 1981.  The
plume location  was  first  identified  in  1984.   The  resident was
concerned that contaminated water supplies may have been consumed
unknowingly over a long period of time.

     EPA Response;  A well survey was done recently as part of an
     investigation at the Semiconductor Complex on the Harris site.

     without historical  analytical and water well location data,  it
     is speculative to determine where and how much contamination
     existed before  1981.   However,  historical  contamination may
     have  originated   at   Radiation  Corporation,   which  began
     operations in 1960.  Harris has placed monitor wells east of
     the  known  plume area  near residences to  determine whether
     groundwater contamination may be  present.  Sampling data from
     these monitor wells have not shown evidence  of contamination.

4.6  Soil Testing Issues

1.   How has soil contamination been addressed?

     EPA  Response;    Harris  has  conducted • investigations  to
     determine  the  impact  of VOCs,  metals, and acid extractable
     organics at Government Systems as well as other areas of the
     site.  Soil samples at Government Systems were taken based on
     the  location of possible source  areas  identified  by past
     operating  and handling practices.   These sampling locations
     are shown  in Exhibit 3.
                                27

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                              Exhibit 3
            Harris Corporation / Palm Bay Facility
        Government Systems Soil Sample Locations
        LICCNO
        •   SOL SAMPlf LOCATIONS

        •  . SUSPECTED POSSIBLE CHEMICAL SOUftCE LOCATION
Source: Geraghty & Miller, Inc. April 1989. File No. MF0769EP01.
                              28

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     Soils found to contain VOCs were  remediated  by  a  process  of
     removal, spreading,  and discing the soil in order to allow the
     chemicals to  volatilize.   This  remediation  took place  for
     soils  in the area  of  the  old  neutralization  ditch  and
     treatment lagoons near the east side of Government Systems and
     from an area  along  the location of  the old  stormwater drain
     north of Building 6.

2.   Were soil samples taken beneath the buildings? At what levels
were these contaminants found from the surface?

     EPA Response;  Numerous soil  samples have been  taken around
     buildings at  Government Systems and on one  occasion samples
     were taken by drilling  holes into the  floor of  Building 6.
     No VOCs were  detected  in  soil samples  taken in  1985 in and
     around  Building  6.   However, some  phenolic  compounds (acid
     extractable organics) were detected at  low  levels (1 ppm or
     less) in eight samples collected  from  four  locations at the
     3-foot  and 6-foot levels.   In addition, several metals were
     found  with  copper  and   lead being  of  greatest  concern.
     Fluoride was also reported in these soil samples.  The maximum
     levels  of metals  in these samples were 407  mg/kg copper,  38
     mg/kg lead, and  94  mg/kg  fluoride,  all at the 6-foot level.
     Subsequent soils analyses done  in 1987  from three borings
     around  Building  6 showed  phenolic compounds  to  be below the
     detection limits.  These samples were taken in intervals from
     3 to 39 feet.  Copper was found  at a maximum of 37 mg/kg at
     the  39-foot  depth,  and fluoride  was  found   at maximum of 6
     mg/kg at a depth  of 5 feet.

4.7  Water Utility Costs and Services  Issues

1.   One citizen expressed concern that he is paying for the cost
of water treatment in  his monthly utility bill.

     EPA Response;  Harris Corporation has been responsible for the
     costs associated with the  groundwater treatment system on the

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     Harris  property as  well  as  the  costs  for  constructing,
     maintaining, and monitoring of the air stripping tower at GDU.

4.8  Harris Corporation Comment

Harris Corporation  submitted  a letter during the  public  comment
period identifying questions and concerns about the EPA preferred
alternative.   The  letter and  attached  report  are provided  as
Attachment H.

1.   This  letter stated the Harris  position that  "the  issues  of
chemical source areas and  metals in the soils and groundwater have
been adequately addressed" and that  "no additional work on soils
removal or metal characterization is necessary."

     EPA Response;  EPA  has reviewed  the Harris comment letter and
     report entitled "Summary  of Soils Investigation and Metals in
     Groundwater".   Despite  Harris1  assertion that  "This  report
     indicates metals are not an issue  of concern at  the site,
     there are no existing sources  of chemicals  remaining  in the
     soils and sediments,  and no additional work on soils removal
     or metal characterization is necessary.",  metals in the soil
     and groundwater are a concern.   The report is not sufficient
     to address  this  issue.    Soil remedial  levels based  upon
     analytical methods with  which  we are unfamiliar may  not  be
     sufficiently protective of groundwater quality and therefore
     may not support the  remedial action taken by Harris.   As a
     result,  additional  soil/source  characterization  may  be
     necessary at the Harris site.

     Hydroxide   sludges  were   reportedly   observed   in   the
     Neutralization Lagoon,  but metal analyses were not performed.
     EPA  has not  located a  discussion  of  what  became  of  the
     hydroxide sludges,  which  are sources for metals.  In addition,
     the  groundwater  monitoring program for  metals  has  been
     inconsistent;  not  all  wells have been  analyzed for metals.
     The  wells  which  have  undergone  metals   analyses show  an

                                30

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     irregular sampling frequency.  Many wells listed in the tables
     were only sampled  once,  typically in the fourth quarter  of
     1986.   The irregular sampling frequency makes it difficult  to
     determine the nature of the contamination and the behavior  of
     contaminants over time.   Thus, it  is not possible to conclude
     that metals- are not an issue of concern.   Also,  the existing
     treatment system (air stripping)  does not  remove metals from
     groundwater.

     There are instances  where EPA contaminant-specific  cleanup
     goals  were  exceeded,   but  subsequent   sampling   was  not
     performed.  For example,  there was no subsequent sampling  in
     well SC-17S  where lead was found at 140 parts per billion  in
     February, 1988.  The EPA health-based cleanup level for lead
     is 5 parts  per billion.   In addition, there  are  many cases
     where the detection limit exceeded the EPA  cleanup standard
     for the contaminant, but subsequent sampling was not performed
     to attain a  detection limit below the cleanup standard.

2.  The Harris comment  letter states  that "the existing recovery
system is not only reducing the concentration of chemicals in the
groundwater,  but   also  effectively   capturing   the  plume  and
effectively remediating the aquifer."  Therefore,  no modification
to the existing system is necessary.

     EPA Response;    EPA has not yet reviewed the  groundwater
     modeling  program  conducted  by  Geraghty  &   Miller  on  the
     existing  Harris recovery  system.   However,  this  recovery
     system was designed to meet the requirements specified in an
     administrative order on  consent  with FDER.   The current EPA
     cleanup criteria for the aquifer are more stringent, in some
     cases, than those identified in the order.  Also, the plumes
     have been defined by an  aggregate value for VOCs rather than
     by values for  individual contaminants.   Therefore,  it  is
     uncertain whether or  not the existing  recovery  system  is
     effectively   capturing   the  plumes   and  thus  preventing
     contaminants from escaping the recovery system.  As a result,

                                31

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     EPA must first verify through a comprehensive site groundwater
     evaluation what modifications are necessary and then determine
     the specific modifications required to optimize the system for
     treatment of the aquifer.

     Until this comprehensive evaluation  occurs,  it  is  uncertain
     what modifications will be  required.   The modifications may
     involve  a  different  groundwater   recovery system,   i.e.
     installation of  additional recovery wells or discontinued use
     of existing wells.  In addition, the sampling regime may be
     modified to verify that the system  is meeting  EPA  cleanup
     criteria.  Monitoring wells  in  potential source  areas may be
     sealed  (or decommissioned), if  necessary,  to  prevent  the
     downward  migration  of  contamination   from the   surface.
     Similarly,   EPA  will make   an  independent determination  of
     whether or not the wells "were  constructed in a  fashion that
     seals the zones  of the aquifer  from interconnecting."

3.  Harris "questions the premise that air emissions  from the air
stripping tower may require additional testing."

     EPA Response;   Testing of  the air  emissions  from  the air
     stripper will  be  required  to  demonstrate  compliance  with
     applicable air cleanup standards.  The EPA Air, Pesticides and
     Toxics  Management Division states  that the  air  stripper
     technology will comply with the  cleanup standards,  but this
     does not relieve Harris of its  responsibility to demonstrate
     that the air emissions .and  effluents are in compliance with
     federal and Florida air quality standards.

4.  Harris states that  "additional analysis  of wells outside the
identified plume areas  is  unnecessary" because  of the  extensive
sampling conducted to date.

     EPA Response:    EPA confirms  that  an  extensive amount  of
     sampling data has  been collected at  the site.   However, the
     sampling regime  was not  systematic  in some cases.    As a

                               32

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     result, it is  difficult  to get a comprehensive view  of  the
     contamination at the site.  In addition, containment of plumes
     will ultimately be determined  by the  regular sampling  of
     monitor wells outside the plume areas.

5.   The  Harris,  comment  letter  states  the  Government  Systems
groundwater remediation system is not an interim measure,  but  was
designed as  the "final remedial  alternative  for  the  identified
plumes of chemicals" under the Government Systems facility.

     EPA Response;  EPA policy on the extraction and treatment of
     contaminated groundwater considers recent evidence suggesting
     that it  may be  more  difficult than  is  often  estimated  to
     achieve  cleanup concentration  goals in  groundwater.   The
     policy  recommends  an approach  involving  the  initiation  of
     early  action while gathering more  detailed  data prior  to
     committing to  full-scale restoration.   This  recommendation
     encourages the collection of data to allow for the design of
     an efficient cleanup approach that more accurately estimates
     the time frames required for achieving the groundwater cleanup
     goals.     Early  action  proves  valuable   in preventing  the
     contaminant plume  from  spreading  while the investigation to
     optimize the remediation system progresses.

6.  The Harris letter states that "should GOU choose unilaterally
to significantly  modify its groundwater  withdrawal  scheme,  this
will directly impact the ability of the Harris remedial system to
control the plume in the lower surficial aquifer."

     EPA Response;   Due to  the long-term nature  of the cleanup
     process,  the  Harris  remediation system  must  be able  to
     function  independently of  GDU groundwater withdrawals.   The
     remedial  system should  be designed such  that it  can  take
     advantage of GDU's withdrawals and the predictable  impacts on
     the groundwater  flow, as well as  contaminant transport.   The
                                33

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     remedial system should also be  demonstrated  to  be adaptable
     and  responsive   to  modifications  in  GDU's   groundwateJ
     withdrawal scheme.

7.  The letter states that  "it is not necessary or appropriate for
water from the treatment system to meet potable  water standards"
because the treated water is used strictly for industrial purposes.
               *

     EJPA Response:  The treatment  standards for  disposing treated
     groundwater  depend  upon  the intended  disposal  method.   If
     treated groundwater is to  be used  for human consumption or
     returned to the aquifer via percolation ponds or reinjection
     wells,  the drinking water quality standards are the treatment
     criteria.

     This Record  of Decision selects a  disposal  option involving
     the use  of  permitted  underground  injection  wells  or,  as an
     alternate,  surface  water discharge.   In  either  case,  the
     treated water must meet permit requirements; the Underground
     Injection Control  (UIC) permit for deep well  injection and the
     National Pollutant Discharge Elimination System (NPDES) permit
     for surface water  discharge.  These permits specify the levels
     to which the groundwater must be treated before disposal.  For
     example, before disposal  into  the  UIC permitted wells,  the
     treated  groundwater  must  not  contain   hazardous  waste.
     Regional  guidance  states  that   EPA  considers  that  the
     groundwater  no longer contains  hazardous waste  once  it has
     been treated to health-based levels.

8.   EPA has reviewed  the report that accompanied  the comment
letter.  This report  recaps data collected between  1986 through
March 1989 which has been presented in previous reports.
                                34

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EPA  Response;    The  statement  that  "Sufficient  data  are
available to  assess the level  of  metals in  groundwater at
different depths across  the site." is inaccurate.  Most of the
monitoring wells on the site have not been analyzed recently
for metals.-  Given this, it is not possible to conclude that
"metal  levels  in  the  groundwater  do  not  currently  exceed
MCLS...

The data included in the report shows that groundwater cleanup
goals  for metals are exceeded (or  are potentially exceeded)
in  several  instances.   In twelve  wells sampled  in  1987,  a
detection limit of  50 parts per billion (ppb) was reported for
cadmium.   The Maximum  Contaminant  Level  (MCL)  is  10  ppb.
Therefore, we do not know if these wells are contaminated to
a  level that exceeds the  MCL.  These wells have  not  been
resampled.  Two  wells had  positive results  for cadmium, one
above  and one below the MCL.

Chromium  concentrations have  been  recorded at  levels  well
above  the MCL of  50  parts  per billion in  numerous wells.
Although the more recent sampling results do  not show elevated
levels of chromium in these wells,  the  likely explanation for
this phenomenon is that the contaminant plume has moved away
from these wells over the' intervening three year period.  This
situation illustrates the need to more completely characterize
the  nature  and extent  of  groundwater  contamination  at the
site.

At  least  five wells have shown levels of lead above the MCL
of  50  ppb,   and  numerous  others  have  been shown to be
contaminated above the  health-based cleanup level of 5 ppb.
The frequency of positive detections has decreased over time.
However,  it is uncertain to what locations these metals have
migrated in the groundwater.  In addition,  the assumption that
the   lead   concentration    in  SC-17S   is  anomalous  is
inappropriate.  An appropriate procedure would be to perform
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     subsequent  sampling  to  confirm either  that  the  value  is
     anomalous or that lead is present in the groundwater.

     The hydroxide sludges in the old Neutralization  Lagoon (now
     under  Building  5)  were  not  chemically  characterized  for
     metals.  EPA has not received documentation  for  what  became
     of these sludges.  Whether or not  the  hydroxide  sludges and
     underlying soils would have required remediation is not known.
     As a result, the area around Building  5  remains  a  potential
     source area.

     Based  upon the  data  presented  in  the  report,  it  is  not
     possible  to  conclude  that  "metals  are  not  present  in
     groundwater...   at  levels that warrant  remediation."     The
     above-mentioned   examples   indicate   that   the   metals
     contamination at the site is not well-defined and potentially
     significant.  If Harris  has additional data which has been
     used to reach their conclusion, the data or studies should be
     made available to EPA for analysis.

4.9  General Development Utilities  Comment

GDU  submitted  two   letters   during   the  public  comment  period
identifying concerns about EPA actions and the preferred remedial
alternative at  the  Harris Corporation  site.   These  letters are
presented in Attachment I.

1.   The GDU  letter poses  the  question  of whether  the  cleanup
standards will be the current EPA standards and not those standards
identified in the Consent Order between FDER and Harris.

     EPA Response?   The cleanup standards  identified in  the EPA
     Record of  Decision for Operable  Unit One  of  the  Harris site
     are based on the  contaminant  levels  necessary to  restore
     beneficial use of the  aquifer.  Three of these cleanup levels
     (trichloroethylene, vinyl chloride,  and methylene  chloride)
     are  more  stringent  than  those  identified  in  the  1983

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     FDER/Harris Consent Order.   These aquifer cleanup levels  are
     obtained from  a  number of  sources  as appropriate for each
     contaminant. These sources are:  the current State of Florida
     Maximum Contaminant Levels  (MCLs),  health-based criteria  for
     a one  in one million excess cancer risk  level,  the  cleanup
     criteria identified in the 1983 FDER/Harris Consent Order,  and
     Secondary MCLs.

2.  The GDU letter expresses concern that a temporary shut-down of
the Harris  remediation system will  accelerate migration of  the
contaminant plume and affect GDU wells.

     EPA Response;   Such a shut-down would be initiated only after
     contaminant levels in the aquifer had reached or was below the
     cleanup  goals  specified  in  the  ROD  and  had  reached  an
     asymptotic  level  below which  no decrease  occurred over  a
     significant period  of  time.     In  this  case,  a  temporary
     shut-down of the  extraction system concurrent  with  careful
     monitoring  of  the groundwater would  allow  us  to  determine
     whether or not  the sources of contamination had been removed.

3.  It is unclear how the  monitoring program identified in the ROD
will be implemented.

     EPA  Response;    The existing  monitoring program  will  be
     modified as necessary to fully  characterize the extent of
     contamination at the  site.  A monitoring program will continue
     for an estimated three years  or  until the cleanup goals are
     met.  Following the onset of the EPA specified remedial action
     (Alternative 3),  EPA will  conduct  a  review of  the  site to
     verify that the aquifer has been restored to beneficial use.
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4.    GDU  is  concerned that  the  Harris  remediation  system  is
dependent upon the GDU water supply wells.

     EPA Response:   As described  earlier,  due to  the long-term
     nature of the cleanup process, the Harris remediation system
     must be  abl-e to  function  independently of  GDU groundwater
     withdrawals.    The  remedial  system  may  be  able  to  take
     advantage of GDU's withdrawals and any predictable impacts on
     the groundwater flow.   The  remedial  system should  also be
     adaptable and responsive to modifications in GDU's groundwater
     withdrawal scheme.
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5.0  REMAINING PUBLIC CONCERNS

Issues and concerns which EPA was unable to address during remedial
planning activities  for Operable Unit One, groundwater remediation
at the Government Systems Complex, included the following:

o    Specifying  the  modifications  to be  made  to  the  existing
     groundwater extraction and treatment system.

o    Request for EPA to thoroughly review the issues raised at the
     public meeting and to advise the public of anticipated actions
     in a follow-up meeting.

Specific  modifications  to  the  treatment  system  will  not  be
available until a design analysis is  conducted for  the treatment
system.   EPA  will  release  this  information  as soon  as  it  is
available.

Additional operable units may be designed for groundwater cleanup
at other portions of the Harris facility,  e.g., the Semiconductor
Complex  and Building  100.   Another  potential operable  unit  is
source control or soil  cleanup of discrete sources at the facility.
The public will be notified of ongoing  investigations and findings
as well as opportunities for public participation.
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