United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R07-83/001
August 1983
SEPA
Superfund
Record of Decision:
Aidex Site,IA (IBM)
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA/ROD/R07-83/001
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
Aidex Site, IA (IRM)
5. REPORT DATE
08/24/83
6. PERFORMING ORGANIZATION CODE
7. AUTHOR
-------
INSTRUCTIONS
1. REPORT NUMBER
Insert the I PA report number as it appears on the cover of the publication.
2. LEAVE BLANK
3. RECIPIENTS ACCESSION NUMBER
Reserved for use by each report recipient.
4. TITLE AND SUBTITLE
Title should indicate clearly and briefly the subject coverage of the report, and bo displayed prominently. Sol subtitle, if used, in Miialicr
type or otherwise subordinate it to main title, when a report is prepared in more than one volume, repeal Hie primary title, add volume
number and include subtitle for the specific title.
5. REPORT DATE
Each report shall carry a date indicating at least month and year. Indicate the basis on which ii was selected (f.g.. Jaif i>J issue, dale of
approval, date of preparation, etc.).
&
6. PERFORMING ORGANIZATION CODE
Leave blank.
7. AUTHOR(S)
Give name(s) in conventional order (John R. Doc. J. Robert Doc. etc.). List author's affiliation il' it differs from the performing v.rpani-
zation.
8. PERFORMING ORGANIZATION REPORT NUMBER
Insert if performing organization wishes to assign this number.
9. PERFORMING ORGANIZATION NAME ANO ADDRESS
Give name, street, city, state, and ZIP code. List no more than two levels of an organizational hircarchy.
10. PROGRAM ELEMENT NUMBER
Use the program element number under which the report was prepared. Subordinate numbers may be included in parentheses.
11. CONTRACT/GRANT NUMBER
Insert contract or grant number under which report was prepared.
12. SPONSORING AGENCY NAME AND ADDRESS
Include ZIP code.
13. TYPE OF REPORT AND PERIOD COVERED
Indicate interim final, etc., and if applicable, dates covered.
14. SPONSORING AGbNCY CODE
Insert appropriate code.
15. SUPPLEMENTARY NOTES
Enter information not included elsewhere but useful, such as: Prepared in cooperation with. Translation of. ('resented jiYonK-u IKC ni.
To be published in, Supersedes, Supplements, etc.
16. ABSTRACT
Include a brief (200 words or less) factual summary of the most significant information contained in ihe io|>ori. II ilu- rrptiri nuiianis a
significant bibliography or literature survey, mention it here.
17. KEY WORDS AND DOCUMENT ANALYSIS
(a) DESCRIPTORS • Select from the Thesaurus of Engineering and Scientific Terms the proper authorised terms that identity the major
concept of the research and are sufficiently specific and precise to be used as index entries lor catalupni;.
(b) IDENTIFIERS AND OPEN-ENDED TERMS • Use identifiers for project names, code names, equipment designators, etc. Use- open-
ended terms written in descriptor form for those subjects for which no descriptor exists.
(c) COSAT1 HI LD GROUP - Held and group assignments are to be taken from the 1965 (OS ATI Subject Category List. Since the ma-
jority of documents are multidisciplinary in nature, the Primary Held/Group assignment^) will be specific discipline, urea of human
endeavor, or type of physical object. The application(s) will be cross-referenced with secondary I K-KI/(irou|> assignments thai will follow
the primary posting(s).
18. DISTRIBUTION STATEMENT
Denote releasabilily to the public or limitation for reasons other than security.for example "Release IJnlimiicd." Cite any availability to
the public, with address and price.
19. & 20. SECURITY CLASSIFICATION
DO NOT submit classified reports to the National Technical Information service.
21. NUMBER OF PAGES
Insert the total number of pages, including this one and unnumbered pages, but exclude distribution list, il any.
22. PRICE
Insert the price set by the National Technical Information Service or the Government Printing Office, il known.
EPA Form 2220-1 (R«v. 4.77) (R.v.n.)
-------
RECORD OF DECISION
Remedial Alternative Selection for
Initial Remedial Measures
SITE
Aidex Corporation, Council Bluffs, Iowa
DOCUMENTS REVIEWED
I have reviewed the following documents describing the cost
effectiveness analysis of remedial alternatives at the Aidex Site:
Feasibility Study for Initial RemediaJ Measure Revision I,
Aidex Corporation, Council Bluffs, Iowa, April 1983.
Remedial Action Master P]an and Project Work Statements,
Aidex Corporation, Council Bluffs, Iowa, September 1, 1982,
Description of Current Situation, Aidex Corporation,
Council Bluffs, Iowa, November 30, 1982.
- Staff Summaries and Recommendations
DESCRIPTION OF SELECTED OPTIONS
Phase I - On-site collection, bulking, and temporary staging of
pesticide contaminated soJids, liquids and sludges.
- Analysis of collected waste materials.
- Construction of an interceptor drainage ditch around a
portion of the site.
- Off-site transport and disposal of bulk liquid wastes
by deep well injection at a permitted facility.
Phase II - Off-site transport and disposal at a permitted facility
of remaining materials staged during Phase I.
-------
-2-
DECLARATIONS
Consistent with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA) and the National
Contingency Plan, I have determined that the proposed Initial
Remedial Measure for on-site collection bulking and staging of
waste materials, off-site transportation and disposal of waste
liquid and solid materials, and on-site drainage control is
technically feasible, cost effective, consistent with final
remedial alternatives, and necessary to limit exposure to a
significant health and environmental hazard. Also, I have
determined that the action being taken is appropriate when
balanced against the need to use Trust Fund money at other
sites. Finally, I have determined that the off-site transport
of hazardous substances is more cost-effective than other
remedial actions and, therefore, consistent with section
101(24) of CERCLA.
Lee M. Thomas
Assistant Administrator
Office of Solid Waste and
Emergency Response
*fi 24 $63
-------
-3-
BRIEFING SHEET
The purpose of this briefing sheet is to obtain AA approval
for the initial remedial measures recommended by Region 7 and the
State of Iowa for the Aidex site. A "Record of Decision" has been
prepared to document the approval.
The Aidex site is an abandoned pesticide formulation facility
located approximately seven miles south-southeast of Council
Bluffs, Mills County, Iowa, and covers an area of approximately
twenty acres.
Environmental sampling and analyses from field investigations
of the Aidex site indicate significant concentrations of organophos-
phate, organochlorine, and s-triazine pesticides in the soil and
atrazine pesticides in the soil and atrazine contamination in
ground water.on-site. Contamination resulted from the handling,
storing, and disposing of pesticide formulation process wastes.
Black & Veatcn Consulting Engineers completed a Feasibility
Study for Initial Remedial Measure in April 1983. Eight initial
remedial measure alternatives were identified and evaluated. Black
& Veatch determined that three of these alternatives were technically
feasible and would solve current problems. Black & Veatch recommended
that an initial remedial measure be implemented in two phases.
Phase I: Collect, analyze, and stage the pesticide-contaminated
solids, liquids, sludges, and soil on the Aidex site; and
Phase II: Transport these materials to a permitted facility for off-
site disposal. On-site drainage control measures also were identified
for Phase I.
Each technically feasible alternative was determined to prevent
or minimize the release of hazardous substances and thereby mitigate
substantial danger to public health and the environment. Viable
alternatives and their estimated costs are presented as follows:
Preliminary Opinion of
Alternatives Probable Costs
Off-site incineration of liquids and $1,108,000 - $1,293,000
off-site land disposal of solids and
residue
Off-site land disposal of solids and $1,008,000 - $1,263,000
solidified liquids
Off-site incineration of all wastes
and off-site land disposal of $1,783,000 - $2,193,000
residue
The probable cost of the Phase I project was estimated to
be $673,000 to $680,000 regardless of the alternative chosen for
Phase II.
-------
-4-
Two alternatives were considered which involved on-site
incineration of either liquids or both liquids and solids and the
on-site land disposal of the incinerator residues and/or solids.
A third alternative involved on-site land disposal of solidified
liquids and solids. These alternatives were found not to be
feasible because: (1) mobile incinerators are not available;
(2) the site lacks adequate acceptable space for a landfill;
(3) the site lies within the flood plain of the Missouri River;
and (4) the hydrogeology of the area, and the close proximity of
the site to 42 domestic water wells screened in shallow aquifers,
make the site unsuitable for a landfill. In-situ treatment was
also considered, but it was determined that biodegradation of the
pesticide wastes is not likely to be successful. Finally, the "no
action" alternative was considered, but would not solve the problem
of rapidly deteriorating site conditions.
Black & Veatch developed the bid package for Phase I of the
IRM, and the Corps of Engineers selected D'Appolonia Waste Management
Services of Pittsburgh, Pennsylvania to perform the work. A Notice
to Proceed was issued by the Corps on June 13, 1983. Work on
Phase I is currently underway.
After the Phase I contract was awarded, D'Appolonia submitted
a proposal to the Corps to transport off-site and dispose of
approximately 46,000 gallons of bulk liquid and semi-solid wastes
by deep well injection at Empak, Inc., in Deer Park, Texas.
(Contaminated solids will remain on site pending disposal under
Phase II). The price quoted was 83 cents per gallon which included
all testing, handling and rail transportation necessary for disposal.
It also eliminated two bid items associated with temporary storage
of the liquids. Installation of a railroad switch is also required
to accommodate this option.
$.83/gallon x 46,500 gallons = $38,595.00
Minus 2 bid items eliminated = $39,300.00
Add railroad switch = $ 3,640.00
Net change (plus) = $ 2,935.00
The EPA, the State, and the Corps reviewed this proposal and
found it to be cost effective to the overall IRM project. The cost
of storage tank decontamination, handling and salvaging during
Phase II will be saved. Additionally, the materials will only to
be handled once. Even though deep well injection was not considered
during the IRM Feasibility Study, this method is less expensive
than the liquid incineration option considered.
Deep well injection - $.83/gallon
(including transportation and analytical costs)
Liquid incineration - $3.76 - $5.38/gallon
(incineration only; transportation estimated to cost $10,000.00)
-------
-5-
The Region has determined that Empak has met the inspection
and permitting requirements for facilities selected for disposal
of wastes from Superfund sites. The Corps has reached an agreement
with D'Appolonia to make the proposed modification for $2,935.
The bid package for Phase II of this IRM is being developed by
Black & Veatch. As soon as analytical results are received from
the analysis of waste put into storage during Phase I, the bid
package will be transferred to the Corps. The Corps will again
select a contractor and provide oversight during the implementation
of the IRM. The RI/FS for final site remedial action is presently
nearing completion.
-------
-6-
NARRATIVE SUMMARY
Site History
The Aidex property is presently owned by the City of Glenwood
to whom title reverted following a declaration of bankruptcy by the
Aidex Corporation which operated as a pesticide formulator. The
property, covering approximately 20 acres in a rural area, is
located about 7 miles south-southest of Council Bluffs, Iowa, and
lies on the Missouri River floodplain and immediately abuts the
eastern valley bluff. The distance to the Missouri River channel
is about three miles. The property is bounded on the west by the
St. Mary's drainage ditch, on the north and east by a county road,
and on the south by a cultivated field. Fourty-two (42) shallow
domestic water wells have been identified within a two-mile radius
of the site. Two residences are located within 1/4 mile of the site.
The Iowa Department of Environmental Quality (IDEQ) and the
Environmental Protection Agency (EPA) Region VII became involved
with the Aidex site in November 1976, when a fire destroyed the
Atrazine formulation building at the facility. Of an estimated
100,000 gallons of water used to extinguist the fire, most infiltrated
into the ground or flowed into drainage ways surrounding the plant
and leading to St. Mary's ditch. At that time, chemical contaminat
of the the local plant drainage ways and property was documented
by EPA investigators. Following the fire, plant production was
greatly reduced and the company filed for bankruptcy in 1980. The
EPA began investigation of this facility as a hazardous waste
disposal site in 1980.
During the August 1961, bankruptcy sale held at the site to
liquidate the assets of the Corporation, ethoprop (Mocap) dust was
spilled during removal of the baghouse dust collector which resulted
in two workmen being hospitalized with organophosphate poisoning.
EPA responded by coordinating cleanup activities. It was also
noted that two large metal tanks were drained into a concrete-lined
pit at the site of the former atrazine formulation building. The
occurrence of these two incidents is believed to be a contributing
factor to the contaminated conditions at the site.
The Aidex site was placed on the proposed National Priorities
List in October 1981. During December 1981, immediate remedial
funds were used to fence the site to control access.
In all, Six sampling efforts have been conducted at the Aidex
site by EPA. Recently analyzed soil samples show on-site
organochlorine, organophosphate and triaz-ine pesticide contamination
ranging from several hundred parts per billion (ppb) to several
thousand parts per million (ppm). Magnetometer and conductivity
surveys have identified two burial trenches on the site.
-------
-7-
Samples of ground water under the site indicate that the
alluvial aquifer is contaminated. While there is no present
indication that this ground water contamination has migrated any
significant distance off-site/ the potential for contamination of
nearby drinking water wells is present. An organic vapor survey
did not indicate a significant level of volatile organic compounds
in the ambient air despite the strong chemical odor present.
In September 1982, Black & Veatch Consulting Engineers completed
a Remedial Action Master Plan which included recommendations for
initial remedial measures to abate the deteriorating site conditions.
The State and EPA agreed that measures to limit public exposure and
prevent wastes from migrating off site were needed even while further
remedial investigation and feasibility studies were underway. The
State of Iowa signed a State Superfund Contract on October 19, 1982,
to pledge a 10 percent match of remedial costs. Subsequently
Black & Veatch was tasked to develop a bid package for Phase I of
the IRM. The EPA also entered into a Interagency Agreement with
the Corps of Engineers to procure a cleanup contractor and to
provide oversight during implementation of the IRM.
The Corps selected D'Appolonia Waste Management Services of
Pittsburg, Pennsylvania to perform the Phase I work. D'Appolonia
was given a Notice to Proceed June 13, 1983. Phase I work is
currently underway.
Current Status
Procedures used by Aidex Corporation for handling, storing,
and disposing of pesticide formulation process wastes, together
with the effects of runoff from past firefighting operations, have
resulted in at least 16 pesticide compounds being available for
transport from the site by runoff or infiltration into the ground
water. The hazards presented by runoff are worsened by the fact
that the site is subjected to uncontrolled runoff by rainwater from
the bluffs to the east.
Following removal operations by others and a bankruptcy court
auction of plant equipment and fixtures, the site now contains five
above-grade tank shells, one buried tank, one below-grade open pit
and trench, approximately 3,400 drums, miscellaneous scattered
debris and extensively contaminated soil. The estimated inventory
of the buried tank, the concrete pit and trench is 34,500 gallons of
liquid and 12,000 gallons of semi-solid sludge. At the time of the
feasibility study for the IRM, it was estimated that of the 3,400
drums, 1,000 were filled with solids, 1,000 partially full of
liquids and sludges and 1,400 were empty. Since that study was
completed, some 1,200 drums of solids were removed by a responsible
party.
-------
-8-
Remedial Options
The feasibility study for Initial Remedial Measure evaluated
remedial options which could be utilized for cleanup of the Aidex
site using the following criteria:
a) Effectiveness
b) Technical feasibility
c) Cost effectiveness
d) Environmental considerations; and
e) Implementation time frame.
IRM alternatives were identified for the three most significantly
contaminated segments of the hazardous waste problems at the Aidex
site:
0 Contaminated liquids
0 Contaminated sludges
0 Highly contaminated soil beneath drum stacks.
Subsequently eight IRM alternatives were identified. They are
summarized and compared below.
Activity
1. No action
2. Treatment in-situ
3. On-site incineration and on-site
land disposal of residue
4. On-site incineration of liquids
and on-site land disposal of
solids and residue
5. On-site land disposal of solids
and solidified liquids
6. Off-site incineration of solids
and liquids and off-site land
disposal of residue
7. Off-site incineration of liquids
and off-site land disposal of
solids and residue
8. Off-site land disposal of solid
and solidified liquid wastes.
Estimated Cost ($1000)
$0.
Not technically feasible
Not technically feasible
Not technically feasible
Not technically feasible
$1,783,000 - 2,193.000
$1,108,000 - 1,293,0,00
$1,008,000 - 1,263,000
-------
-9-
These alternatives are also summarized and compared in Table 1
(see attachment). Alternative 7 (Off-site incineration of liquids
and land disposal of solids residue) and Alternative 8 (off-site
land disposal of solidified liquids and solids) were both considered
to be technically feasible, cost effective, expedient and would
protect public health and the environment. When the Feasibility
Study for the IRM was completed, disposal actions would only have
occurred as part of Phase II. However, with the proposal submitted
by D'Appolonia, and described in the Briefing Sheet, disposal of
bulk liquids could occur during Phase I.
The No-Action Alternative would not solve the problem of
continued deteriorating site conditions. Wastes would remain
uncontrolled on the surface of the site and be subject to leaching
into ground water and migration off-site via surface runoff.
On-site options were found not to be technically feasible because
mobile incinerators are not yet available for production use and
suitable space is not available for landfilling. Also, site
hydrogeology is not suitable for landfill options.
Recommended Alternataives
Section 300.68(j) of the National Contingency Plan (NCP) (40 CFR
Part 300) July 16, 1982, states that the appropriate extent of
remedy shall be determined by the lead agency's selection of the
remedial alternative which the agency determines is cost-effective
(i.e., the lowest cost alternative that is technologically feasible
and reliable and which effectively mitigates and minimizes damage
to and provides adequate protection of public health, welfare, or
the environment). Based on our evaluation of the cost effectiveness
of each alternative, on information from the State, and comments
by the public, we have determined that off-site disposal of waste
from the Aidex site and on-site drainage control meet NCP criteria.
State Input
The State of Iowa has reviewed all feasibility study and
remedial plans regarding the Aidex site which EPA prepared. The
State fully concurred on the plans for initial remedial measures by
signing Amendment No. 1 to the Aidex Superfund State Contract which
provided $50,000 in matching funds for Phase I. The State also
concurs that off-site disposal of bulk liquid wastes should occur
during Phase I, and has submitted, in draft, Amendment No. 2 to
show such concurrence. In addition, the attached letter from the
State supports the proposed actions.
Public Input
A community relations program was initiated for the Aidex site
in October 1981 when the site was placed on the Interim National
Priority List and the FIT investigation was begun. In November
1981, EPA Region VII staff spoke at a county supervisors meeting in
Glenwood, Iowa, concerning the problems at the Aidex site. This
meeting was open to the public.
-------
-10-
On May 12, 1983, an informational public meeting on the
Aidex site as a Superfund Project was held at the Courthouse in
Glenwood, Iowa. This public meeting was arranged for the purpose
of familiarizing citizens with governmental agencies providing
oversight of the work, to discuss with them the work to be performed
during each phase, and to give citizens the opportunity to ask
questions and voice concerns. Off-site disposal of waste was
specifically discussed. Citizens and members of the media alike
expressed their agreement with the plan to move the materials to a
secure permitted disposal facility.
Copies of technical reports and the IRM Feasibility Study have
been made available to the public in the, office of the County
Auditor for Mills County. Bi-weekly progress reports are being
sent to the County Auditor.for dissemination to the public. The
citizens living in the area around the site have shown most concern
for a prompt implementation of remedial measures and that they are
kept informed on site activities.
Enforcement Status
A civil action filed pursuant to Section 7003 of RCRA against
Aidex Corporation for injunctive relief is pending. A responsible
party search is being completed by the National Enforcement
Investigation Center (NEIC). Upon completion, we will amend the
complaint to add additional parties and a count for cost recovery
under §107 of CERCLA, or file a completely new complaint for cost
recovery.
In proceedings before the U.S. Bankruptcy Court, District of
Nebraska, we have filed an order for transfer to EPA of funds
remaining in the estate and which have been put aside pursuant to a
stipulation between EPA and secured creditors of the bankrupt
corporation. Additionally, we are seeking an order of the court
declaring agency expenditures for cleanup of the site as administrative
expenses of the estate entitled to first priority payment.
Proposed Action
We request your approval for off-site disposal of bulk liquids
and semi-solids by deep well injection during Phase I of the IRM
for the Aidex site. Additionally, we request approval for off-site
disposal of solids, soils, and debris from the site during Phase II
of the IRM for this site.
If you have any questions, please contact Kerry Herndon at
FTS 758-6864.
Attachments
-------
IAIII.K I
cotipAiusoM U^BEHNANVKS
Solves
Current
Allciii.il jve
I. No Action
2. Treatment
NO
NO
3. On-sile inciner- Doubtful
a I inn and 011-
sile land
i ettidue
l>. On-tiite inciner- Doubtful
ill ion of I i<|iiids
and on-sile land
diKpoNal of solids
and reuidue
S. On-uili: liiiul Yes
diiipoiiiil of
sol ills and
Kolidlfied Ilipiids
6. Olf-iiile ini inftr- Yes
aI ion and of f-
sile land disposal
of residue
7. Off-Kile Inciner- Yes
al ion of I i«|iiids
and off-vile land
ditipoKal of solids
and residue
H. OH-nile hind Yes
di ii|ii>iiiil of
IKI I iilti and
snl idi I ir.d
I i
-ihy iHi !?•»» J kllil y
N/A
Moal of tlu; petit iride com-
pounds not uiuenahlc to
llnliile lm:in<:ra!ore not
uv.iiluhle for |uodiu'lloii
Mobile incinorat01u nut
uvailahle. No suitable
uii-uilc for landfill
No Biiitiiblc «|»ace oil-site
for landfill. Kludy needc<|
to teat sol itli f i cut I on
methods
Yes
Yes
iilmly needed to test
t»ol idi f (cat ion methods
I'rel iminary Opinion
ol ||rj>babl^
N/A
N/A
N/A
N/A
N/A
1,100-1,293
KiivlroiMcntat
|:i>its|derat i oils
N/A
N/A
N/A
TiMjIjonlliiO
N/A
N/A
N/A
I'oor Betting for
liazardoim waste
landfill
I'oor netting for
hazardous waste landfill
' None apparent
None B|i|iir<: Yiihle 2 for details of roul .-111.11 yy is. «
2. lMiplnuriil.il ion linn: ib the tiaii: iri|iiiii-d lo develop I In.- «onl i arf diiiwiiiKU .tnd dm imiriil a, neli-ct a Cunl rartor nml fompli-le the work.
'I. II.i.-.ill on lime lo develop .111.11 yl i ( ,i I i iilniin.il ion .lin inj; I'li.i.-.i- I ar
------- |