PB98-963146
EPA 541-R98-160
May 1999
EPA Superfund
Explanation of Significant Difference
for the Record of Decision:
Vertac, Inc.
Jacksonville, AR
1/12/1998
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 6
QSS AVENUE SLMTE
DALLAS. TX 75202-2733
EXPLANATION OF SIGNIFICANT DIFFERENCES
TO THE SEPTEMBER 1996 RECORD OF DECISION
VERTAC, INC. SUPERFUND SITE
OPERABLE UNIT 2
JACKSONVILLE; ARKANSAS
L STATEMENT OF PURPOSE
This document explains the differences between the selected remedy for the Soils,
Foundations, and Underground Utilities, Operable Unit 2 (OU2) identified in the September 1996
Record of Decision (OU2 ROD) for the Vertac, Inc. Superfund Site, Jacksonville, Arkansas
(Venae Site or Site), pursuant to the Comprehensive Environmental Response, Compensation &
Liability Act (CERCLA or Superfund), 42 U.S.C. § 9601 £1 seq.. and the final remedy
implemented for this Operable Unit. This Explanation of Significant Differences (ESD)
documents an alteration to the selected remedy under CERCLA in the ROD for OU2 of the
Vertac, Inc. Superfund Site. This significant difference is the additional consolidation of dioxin-
contaminated residential soils from the Jacksonville Residential Areas Superfund Site (JRA Site),
Jacksonville, Arkansas, in the on-site hazardous waste landfill that was constructed as part of
Operable Unit (OU1) for the Vertac Site. The Jacksonville Residential Areas Superfund Site is
located approximately 1,000 feet east of the Vertac Site in Jacksonville, Pulaski County,
Arkansas, consisting of approximately four residential properties within an estimated radius of
three hundred feet from the intersection of Me Arthur Boulevard and Lee Street.
As a result of an Exposure Investigation (El) that was finalized on August 11, 1997, and
performed jointly by the U.S. Agency for Toxic Substances and Disease Registry (ATSDR) and
the Arkansas Department of Health (ARDOH), it was recommended that additional soil samples
be taken from a residence where an occupant had been determined to have an elevated dioxin
blood level. Soil samples taken by the ARDOH as part of the El had detected dioxin
(tetrachlorodibenzo-p-dioxin or TCDD) above the residential cleanup level of 1 ppb.
Two additional "rounds" of sampling performed by EPA, and one "round" of sampling
performed by Hercules under Federal oversight have indicated that the TCDD contamination in
the area of the original residence sampled is more widespread than the initial yard sampled.
TCDD concentrations in soil sampled from the four residential properties located in Jacksonville,
Arkansas, at the location described above and designated as the Jacksonville Residential Areas
Superfund Site, exceed the 1 ppb residential action level.
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The TCDD concentrations as a percentage of the total dioxin, and other comparisons of
the congeners of dioxins and furans, indicate that the soil contamination encountered in the
Jacksonville Residential Areas is chemically very similar to the contaminants in the soil at the
Vertac Site.
IL INTRODUCTION
The Venae, Inc. Superfund Site is approximately 193 acres in size, and is located on
Marshall Road in Jacksonville, Pulaski County, Arkansas, as shown in Figure I . Jacksonville is
about IS miles northeast of the State Capital, Little Rock. Approximately 1,000 residents live
within one mile of the site with residential areas bordering the entire east and south sides. The
west and northern sides of the Site are bounded by an industrial area and the Little Rock Air
Force base, respectively.
EPA is the lead agency for the Vertac, Inc. Superfund Site, and the State of Arkansas,
through the Arkansas Department of Pollution Control and Ecology (ADPC&E), has been
involved in all aspects of Site activities. Hercules. Incorporated (Hercules) has been identified as
one of the potentially responsible parties for the Vertac Site, and EPA has authorized Hercules
through an Unilateral Administrative Order (UAO) to design and implement the remedy for OU2,
as set forth in the 1 996 Vertac On-Site OU2 ROD.
This Explanation of Significant Differences (ESD) is prepared in accordance with Section
1 17(c) of the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA), as amended, 42 U.S.C, § 9617(c), and the National Ofl and Hazardous Substances
Contingency Plan (NCP), 40 CFR 300.43S(cX2Xi), wn>ch provide that, after adoption of a final
remedial action plan, if any remedial action is taken and if such action differs in any significant
respects from the final plan, EPA shall publish an explanation of the significant differences and the
reasons such changes were made.
This ESD was necessitated by the findings of the El, where dioxin contamination was
encountered in residential areas just to the east of the Vertac Site, resulting in the designation of
the Jacksonville Residential Areas Superfund Site and the issuance of an EPA Action
Memorandum authorizing site cleanup through CERCLA removal action. It has been reported
verbally by one resident within the JRA Site that imported backfill was used to "regrade" the
shoulder of Me Arthur Blvd., after an upgrade ww performed on a sewer or water supply line. Ho
other records exist to support this theory for the presence of TCDD contamination; however,
logic dictates that since this is a "hot spot" of TCDD, which is a common contaminant in the
nearby Vertac Site soils, then the contaminated soil may well have been "trucked in" from the
Vertac Site, or a Vertac related source in the past.
The JRA Site TCDD soil contamination is extremely similar to the type of contaminant
encountered in the soil at the Vertac Site, along with the TCDD concentrations as a percentage of
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the total dioxin. Other comparisons of the congeners of dioxins and furans indicate that the soil
contamination encountered in the Jacksonville Residential Areas is chemically very similar to the
contaminants in the soil at the Vertac Site. Thus, there is a reasonable relationship of the threat,
or the potential threat to public health and the environment posed by the TCDD contamination at
both of these non-contiguous sites, which are also closely related in their near geographic
proximity to each other. Accordingly, it would appear that the most prudent method of handling
of the excavated soil from the Jacksonville Residential Areas Site is to be consistent with the
handling of the Vertac soil addressed in Operable Unit #2 (OU2). The OU2 contaminated soil at
the Vertac Site is being consolidated or "entombed" in the Consolidation/Containment Unit (CCU
or Resource Conservation and Recovery Act [RCRA] Subtitle C compliant landfill), which is a
hazardous waste landfill (vault) that was constructed as part of OU1 at the Vertac Site.
The mechanism for disposing of, or consolidating, the contaminated soil on the Vertac
Site is the Area of Contamination (AOC) which simply states that if contamination is being
consolidated within a CERCLA Area of Contamination and is not subject to treatment, then
"placement" within the meaning of RCRA, does not occur, therefore the RCRA Land Disposal
Restrictions (LDRs) required by 40 C.F.R. 268, do not apply. See 55 Fed. Reg. 8666, at 8758-
60. In order to be consistent with the Vertac OU2 determination and given the site relationship
factors noted above, for purposes of consolidation, the contaminated soil from the Jacksonville
Residential Areas Superfund Site should be considered part of the Vertac Site, and within the
AOC. Therefore, this soil could, and properly should, be consolidated within the ort-she landfill
or CCU at the Vertac Site, which is part of the Venae Site CERCLA remedial action.
In accordance with the NCP, 40 C.F.R. 300.825(aX2), this BSD and the supporting
information EPA relied upon in preparing the ESD, will become pan of the Administrative
Record for the Vertac Superfund Site as well as the Jacksonville Residential Areas Superfund
Site. The Administrative Record files for the Venae Superfund Site and for the Jacksonville
Residential Areas Superfund Site are available at the following locations:
Jacksonville City Hall
1 Industrial Drive
Jacksonville, Arkansas 72076
(SOI) 982-3181
Arkansas Department of Pollution
Control & Ecology
8001 National Drive
Little Rock, Arkansas 72209
(501)570-2186
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U.S. Environmental Protection Agency
Region 6
12th Floor Library
1445 Ross Avenue
Dallas, Texas 75202-2733
1-800-533-3508
IH. SITE HISTORY AND ORIGINALLY SELECTED REMEDIES <*
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Site History o
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The first facilities on the Site (see Figure 1 for Site location) were constructed by the U.S.
Government in the 1930's and 1940's, These facilities were pan of a munitions complex that
extended beyond the present Site boundaries. Little is known about the operations that occurred
during that time period. In 1948, the Reasor-HUI Company purchased the property and convened
the operations to manufacture insecticides such as DDT, aldrin, dieldrin, and toxaphene. During
the 1950*3, Reasor-HHl manufactured herbicides such as 2,4-dichlorophenoxyacetic acid (2,4-D),
2,4,5-trichlorophenoxyacetic acid (2,4,5,-T), and 2,4,5-trichlorophenoxvpropionic acid (2,4,5,-
TP), which is also called Sflvex. Drums of organic material were stacked in an open field
immediately southwest of the production area, and untreated process water was discharged from
the western end of the plant to Rocky Branch Creek.
Hercules Powder Company, now known as Hercules, Inc. (Hercules), purchased the
Reasor-HUI property and plant in 1961 and continued to manufacture and formulate herbicides.
The drums that were in the open area southwest of the central process area were buried in what is
now referred to as the Reasor-Hffl Landfill. From 1964 to 1968, Hercules produced the herbicide
Agent Orange, a mixture of equal pans of 2,4,5-trichlorophenoxyacetic acid (2,4,5-T) and 2,4-
dichlorophenoxyacetic acid (2,4-D) Hercules discontinued operations at the Site in 1971.
From 1971 to 1976, Hercules leased the plant site to Transvaal, Inc. (Transvaal), a
predecessor company of Venae. Transvaal resumed production of 2,4-D and intermittently
produced 2,4,5-T. Organic wastes from these manufacturing processes were stored and then
buried by Hercules on the Site in what is now referred to as the North Landfill area. Transvaal
purchased the property and plant from Hercules in 1976. In 1978, Transvaal underwent a
Chapter XI bankruptcy reorganization and ownership of the Site was transferred to the new
company, Vertac Chemical Corporation, which is the present owner.
In 1979, ADPC&E issued an order that required Vertac to improve its hazardous waste
practices, and in 1980 EPA and ADPC&E jointly filed suit in federal district court against Vertac
and Hercules. A Consent Decree entered into by EPA, ADPC&E, Vertac, and Hercules in
January 1982 required that an independent consultant assess the conditions of onsite wastes and
develop a proposed disposal method for the wastes. The proposal, called the "Vertac Remedy11,
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was deemed by EPA to be unsatisfactory. The Court decided in favor of the proposed remedy,
which was implemented in the summer of 1984 and completed in July 1986. As part of the
remedy, the Vertac plant cooling water pond was closed, and sediment from this unit was
removed and placed in an above-ground vault. The Reasor-HHl and Hercules/Transvaal Landfills
were capped, and a French drain and leachate collection system were installed around the burial
(landfill) areas. Ground water monitoring wells were also installed, and a ground water
monitoring program was initiated.
Vertac operated the plant until 1986. On January 31, 1987, Vertac abandoned the Site
and declared bankruptcy, leaving approximately 29,000 drums of 2,4-D (D-waste) and 2,4,5-T o
wastes (T-waste). Many of these drums were corroded and leaking. At that time, EPA initiated g
an emergency removal action to stabilize and secure the Site. g
In 1988, ADPC&E contracted for the incineration of the drummed waste, using a $10.7
million combined trust fund and letter of credit obtained from Vertac during bankruptcy litigation.
A contract for the incineration of the drummed waste was signed in 1989 between ADPC&E and
Venae Site Contractors (VSC). VSC is a joint venture of MKK Incineration and Morrison-
Knudsen Environmental Services. In January 1992, ADPC&E approved the VSC trial bum and
production incineration began. Because of the difficulty in handling the Vertac drummed waste
material, incineration operations took longer than originally anticipated. In May 1993, the trust
fund money had been expended with approximately SO percent of the waste destroyed under the
State's contract In June 1993, EPA took over the incineration operation and completed the
incineration of the D-waste drums in September 1994. EPA contracted for the off-site
incineration of the remaining 3,100 drums of T-waste. Shipments of T-waste to the APTUS
commercial hazardous waste incineration facility, located in Coffeyville, Kansas, concluded on
March 29, 1996.
On July 16, 1996, the Regional Administrator for EPA Region 6 executed a Non-Time
Critical Removal Action Memorandum that concluded the on-site incinerator support activities
associated with the on-stte D-waste incineration, which had concluded on January 2, 1994. That
Action Memorandum authorized the off-site disposal of 33,000 drums of salts (and the associated
pallets) that were generated during the on-stte incineration of D-wastes, and it authorized the on-
she consolidation within the RCRA Subtitle C hazardous waste landfill of both 10,000 shredded
pallets used to store drummed waste materials and of 6,300 drums of incinerator ash (and their
associated pallets). In that Action Memorandum, the Regional Administrator also granted a
variance from the RCRA JLDR treatment standard applicable to dioxin-comaining wastes found at
40 CFR 268.31. Specifically, the Regional Administrator approved a treatability variance for the
disposal of dioxin-contaminated wastes within the on-site RCRA Subtitle C landfill of 5 ppb from
the LDR standard of 1 ppb pursuant to the procedures set out at 40 CFR 268.44. Therefore,
should the LDR dioxin treatment standard be applicable to on-site disposal within the on-site
RCRA Subtitle C hazardous waste landfill, when and if placement within the unit occurs, the
treatment standard is 5 ppb. See July 18, 1996, Non-Time Critical Action Memorandum in
Administrative Record for more details.
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Currently, there are no manufacturing operations at the Site. At the time operations were
shut down, Vertac "mothballed" the plant. Mothbailing involved flushing process lines and
draining several of the process vessels. Continuing activities at the Site include operation of an
on-site wastewater treatment plant by Hercules, Inc. The treatment plant processes ground water
collected in French drains constructed downgradient (south and west) of the old waste burial
areas, and surface water runoff collected in a series of drainage ditches and sumps that surround
the central process area. This treated water was originally piped to the West Wastewater
Treatment Plant owned and operated by the city of Jacksonville and was discharged into Bayou
Meto. As part of ongoing remedial activities at the Site, Hercules has recently completed the
cleaning and regrouting of certain sections of the sewer lines that run through the Site to the West _
Wastewater Treatment Plant, and as such, water that was discharged to the sewer interceptor on g
the Site is now treated and discharged directly into Rocky Branch Creek (after meeting discharge §
limits established by ADPC&E). °
The Vertac Site was added to the National Priorities List (NPL) of hazardous waste sites
in 1981. Once the Site was placed on the NPL, money available from the EPA Hazardous
Substances Superfund established under Subchapter A, Chapter 98, Title 26, U.S. Code, and
authorized by section 111 of CERCLA, 42 U.S.C. § 961!, could be used to fund remedial action
with the meaning of sections 101(24), and 104 (a) of CERCLA, 42 U.S.C. §§ 9601(24) and
9604(a), consistent with permanent remedy taken instead of or in addition to removal actions, to
prevent or minimize the releases of hazardous substances from the Vertac Site.
Selected Remedy
A summary of the selected remedy for OU2 is presented below. This information is provided
from the OU2 ROD, dated September 1996. About 90% of this work has been accomplished by
Hercules at the time of the preparation of this ESD.
1) On-Site Surface Soils
All soils on-site with dioxin concentrations at or above the action level of S ppb will be
excavated and disposed of in the on-site landfill. The OU2 on-site soils area includes the area
around the existing Regina Paint Building, which is targeted for demolition under the OU1 ROD.
Sampling results indicate that some excavation will be necessary in the areas around the Regina
Paint Building. Following remediation, the entire northern parcel of the Site will be available for
redevelopment.
All excavated Site areas will be backfilled with clean soil compacted and revegetated.
Some surface drainage modifications may be used to control runon and runoff, thereby minimizing
the potential for erosion, and to facilitate positive drainage to eliminate the possibility for ponding
water.
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During remedial action for this remedy, there is a possibility of dust being created which
could suspend dioxin contamination. As pan of the remedial action, continuous air monitoring
will be conducted and dust suppression measures will be implemented to ensure that no airborne
contaminants migrate off-site to a receptor point. Therefore, no site-related contaminants will be
allowed to pose a threat to nearby citizens or a casual passerby.
EPA will work with the Venae Receiver and City of Jacksonville to impose deed
restrictions and notifications, or to enact specific land use restrictions to limit the future use of the ^
property as appropriate for the long term remediation efforts. Finally, upon completion of the g
remedy for OU2, long term operations and maintenance measures will be instituted to ensure, in §
pan, that the integrity of the RCRA Subtitle C hazardous waste landfill will be maintained. °
Another element of this portion of the remedy is a "phased fencing" approach for the
southern parcel. Once initial remediation is complete, the smallest possible area of the Site will be
fenced. A continuous effort will be made to provide the maximum amount of property possible
for potential commercial redevelopment, as long term remediation efforts allow the restricted area
to be reduced.
2) Crystalline Tetrachiorobenzeae (TCB) and So ill associated with the TCB spin
This component of the remedy calls for the excavation and off-site incineration of the
crystalline TCB and TCB-associated spill soils where the TCB concentrations exceed a 500 ppm
health-based action level. Excavated areas will be backfilled with dean fill, graded and
revegetated to prevent future contact with the remaining soils that fell below the 500 ppm TCB
action level. It has been estimated in the RI that there are approximately 1,400 cubic yards (2,100
tons) of crystalline TCB and associated soils for costing purposes. The actual volume of material
wiQ be determined during the remedial action.
3) Bagged Soils from Residential Areas Excavated by Hercules, Inc.* During a 1990
Removal Action
This component of the remedy calls for the consolidation of approximately 2,770 cubic
yards (4,155 tons) of dioxin-contaminated soils removed from residential yards in 1990 into the
on-site RCRA-compliarrt CCU. The Agency's 1993 ROD had deferred treating these
contaminated low level threat soils and debris until all Site soils were to be addressed. Due to the
similarity of the on-Site soils addressed in this ROD and the bagged soils from residential areas,
EPA has determined that it is appropriate to treat all low level threat media in a manner consistent
with the approach selected for the on-she soils in this ROD, that is, on-site consolidation in the
RCRA Subtitle C Landfill. Dioxin concentrations in the bagged soils range between 13 ppb and
55 ppb TCDD, which is consistent with the dioxin concentrations found in the soil and debris
principally addressed in the OU2 ROD.
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4) Off-Site Soils from the Residential Portions of Bayou Meto and Rocky Branch
Creek Flood Plain Areas from the 1990 OfT-Site Area* ROD
This component of the remedy calls for the excavation of 1 ppb or greater (approximately
4,100 cubic yards or 6,150 tons) dioxin-contaminated soils from along Rocky Branch Creek and
Bayou Meto and consolidation of this material into the on-site RCRA compliant CCU that was
constructed as pan of the remedial action phase of the 1993 OU1 ROD. These contaminated
soils and debris constitute low level threat media and had originally been addressed in the 1990
ROD for Vertac Off-Site Areas, which had required that they be incinerated in the now-
dismantled on-site incinerator. Due to the similarity to the on-site soils addressed in the OU2 ^
ROD, EPA has determined that it is appropriate to treat all low level threat media in a manner ^
consistent with the approach selected for the on-site soils in the OU2 ROD, that is, on-site §
consolidation in the RCRA Subtitle C compliant landfill. °
5) Dewatered Sludges from the Old Sewage Treatment Plant Sludge Digester and
Sediments from (he Interceptor line from the 1990 OfT-Site Areas ROD
This component of the remedy calls for the consolidation of approximately 890 cubic
yards (1,200 tons) of digester shidge from the Old Sewage Treatment Plant into the on-site
RCRA compliant CCU. Also, about 2 cubic yards of contaminated sediment from the interceptor
lines will be disposed in the CCU. The dioxin concentrations found in the sewage treatment plant
digester are consistent with those being landfilled from on-site areas. As discussed earlier, these
contaminated soils and debris had originally been addressed in the 1990 ROD for Vertac Off-Site
Areas, which had proposed that they be incinerated in the now-dismantled on-site incinerator.
Due to the similarity to the on-site soils addressed b this ROD, EPA has determined that it is
appropriate to treat all low level threat media in a manner consistent with the approach selected
for the on-site soils in this ROD, that is, on-site consolidation in the RCRA, Subtitle C compliant
landfill.
IV. DESCRIPTION OF AND BASIS FOR THE SIGNIFICANT DIFFERENCE
The OU2 ROD selected on-site consolidation of all contaminated soil in the on-site
Consolidation/Containment Unit, which is a RCRA Subtitle C compliant landfill. The only change
that this BSD documents is the additional consolidation on the Vertac Site of dioxin
contaminated soil (the substantially identical material to thai which is being disposed or
consolidated under Vertac Site remedial action pursuant to OU2) from the Jacksonville
Residential Areas Supernind Site. Through this BSD, the EPA has determined that their is a
reasonable relationship between the threat or potential threat to public health and the environment
presented by the dioxin contaminated soils from the JRA Site and the Vertac Site, due to the
similarity of their hazardous substance contaminant TCDD. Additionally, there is close
geographical proximity between the two sites in that their distance apart is approximately 1000
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feet. Accordingly, the EPA will treat the two sites as one for purposes of consolidation of the
TCDD bearing contaminated soils. In connection with that determination, the Agency believes
that the Area Of Contamination (AOC), which is continuous and encompasses the entirety of the
Vertac Site, should include the JRA Site. In fact, as noted earlier herein, EPA believes that the
TCDD contaminated material found at the JRA Site may well have originated from the Vertac
Site in the form of excavated fill material mistakenly used as backfill in the residential area. The
authority for this determination by EPA is found in section 104(d)(4) of CERCLA. 42 U.S.C. §
9604{d)(4). A discussion of the reasoning for consolidating the TCDD contaminated soil in the
on-site unit is provided below:
Consolidation S
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As long as contaminated material remains within a CERCLA Area of Contamination, EPA °
generally does not consider placement to have occurred, according to the NCP. See 55 Fed. Reg.
8666, 8758-60 (March 8, 1990). The Agency also embraced that principle in the RCRA
corrective action regulations, such as the Corrective Action Management Unh (CAMU) Rule, 58
Fed. Reg. 8658 (Feb. 16, 1993). The CAMU rule, in addition to waste consolidation, may also
permit movement of RCRA remediation waste associated with corrective action from outside an
AOC into & CAMU for on-site handling or treatment and disposal, without triggering placement
and the associated LDR treatment and disposal requirements.
For LDR's to be applicable requirements, EPA must here first determine whether
consolidation activities considered or contemplated at the Vertac Site constitute "placement"
To assist in defining when placement does and does not occur for CERCLA actions involving on-
site handling of wastes, EPA uses the concept of AOC's, which may be viewed as equivalent to
RCRA units, for the purposes of LDR applicability determinations. An AOC is delineated by the
area! extent of contiguous contamination. Such contamination must be continuous, but may
contain varying types and concentrations of hazardous substances. Depending upon Site
characteristics, one or more AOCs may be delineated.
Placement does not occur when wastes are consolidated within a land-based unit, when
they are treated in situ, when they are left in place, or when they are moved within an AOC. See
55 Fed. Reg. 8666, 8758-8760 (March 8, 1990), and "Determining When Land Disposal
Restrictions (LDR's) Are Applicable to CERCLA Response Actions," OSWER Directive 9347.3-
O5FS (July 1989). Also see 61 FR 18804-1880S (April 29 1996V Specifically, placement does
not occur when the wastes are consolidated within the AOC.
EPA considers the entire landmass of the Vertac Site to be contaminated due to the fact
that TCDD levels in the soils found on-site and on contiguous contaminated off-site areas exceed
the background TCDD level found in Jacksonville of 0.3 ppb or less. Therefore, all consolidation
actions contemplated in the removal action for the JRA site that will apply to excavated on-site
soils and debris, or to soils and debris removed from areas contiguous to the Site, are within the
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AOC for purposes of determining the applicability of LDR's due to the fact that TCDD
concentrations within the AOC and contiguous contaminated areas exceed background TCDD
• concentrations by substantial orders of magnitude. Thus, during the on-site consolidation
activities, materials will be consolidated within the AOC, and therefore, the land disposal
restrictions are not applicable.
However, if the materials are treated on-site within the AOC in a manner that would
constitute "treatment" as that term is defined at RCRA Section 1004(34), 42 U.S.C. § 6903(34),
and then redeposited within the AOC such as in the consolidation unit, then placement has
occurred and the land disposal restrictions apply, unless a treatability variance under 40 CFR •<*
268.44 is obtained, or unless the ARAR is waived under CERCLA Section 121 (dX4XA), 42 g
U.S.C. § 9621(dX4XA), and NCP Section 300.430(fXlX")(C)( I), 40 CFR o
300.430(f)(lXiiXC)
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EPA and the State of Arkansas have determined that the selected remedy represents the
maximum extent to which permanent solutions and treatment technologies can be utilized in a
cost effective manner for the Vertac Superfund Site Operable Unit 2.
V. PUBLIC PARTICIPATION ACTIVITIES
A community relations plan for the Vertac Site was put in place in 1983. This plan listed
contacts and interested parties within the federal, state, and local governments, various organized
affiliations, and local citizens. It also established communication pathways to ensure timely
dissemination of pertinent information about Site activities. Extensive community outreach has
been performed in Jacksonville over the years through the release of information fact sheets, by
conducting frequent open houses and work shops, and through numerous meetings with local
civic groups and media representatives (newspapers, radio and TV). Reports updating activities o
at the Site are also distributed to the Mayor, interested civic groups, and the local media on a °
weekly basis. A satellite community relations office was established in Jacksonville in Jury 1990
to provide easy access to documents and information, and to provide a local contact for questions
and concerns.
A Technical Assistance Grant (TAG) was awarded by EPA in 1989 to a citizens group
called Jacksonville People With Pride Clean Up Coalition (JPWPCUC). This grant award was
challenged by citizen groups that had competed for the grant. Following investigation by EPA,
the grant was annulled because of a possible conflict of interest in December 1 991 . A TAG
grant was awarded to the Concerned Citizens Coalition (CCC) in April 1993, after considerable
effort by EPA to facilitate consolidation of four competing citizen groups. CCC selected the
Environmental Compliance Organization (ECO) as its technical advisor and has actively reviewed
Site documents for the community.
In February 1995, EPA released the draft feasibility study (FS) for Operable Unit 2. and
several meetings were held in Jacksonville with local citizens groups and the press to discuss the
various options being considered. The Operable Unit 2 FS was finalized in April 1995, and was
made available to the public at five local repositories (Jacksonville City Hall, Public Library,
Police Courts Building, Air Force Base Library, and ADPC&E). The official Administrative
Record for this Operable Unit is maintained at EPA in Dallas, the Jacksonville City Hall, and the
Arkansas Department of Pollution Control and Ecology in Little Rock.
In the feasibility study, EPA assumed that the future land use for the Site, based on past
land use and existing zoning ordinances, would be commercial/industrial. This reasonably
anticipated future use for this Site is consistent with EPA's directive "Land Use in the CERCLA
Remedy Selection Process," OSWER Directive No. 9355.7-04. May 25, 1995.
On May 25, 1995, EPA held an informal open house in Jacksonville to discuss EPA's
proposed plan of action for contaminated soils at the Vertac Site. The meeting was well attended
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by Jacksonville citizens, members of the city government. State Health Department
representatives, numerous local civic groups, and the technical advisor for the TAG grant At
that time, the proposed plan was released to the public for review and comment. Several weeks
prior to the informal open house, the EPA project manager met with the local press to discuss the
major elements of EPA's proposed plan which received coverage in both local papers and the
State paper. At this open house, EPA discussed with the community the anticipated future land
use scenario for the Site, which formed the basis for EPA's risk assumption. That risk assumption
presupposed that the future usage of the Site would remain consistent with both past land use and
current zoning for the Site area, which is commercial/industrial. Therefore, the EPA derived the
Site's cleanup level of 5 parts per billion (ppb) toxitity equivalents (TEQ) for dioxin due to the
fact that a commercial/industrial human exposure scenario assumes that a worker would be
exposed to post-cleanup dioxin levels over a 40-hour-per-week period. This worker exposure
scenario additionally is protective of a trespasser or a passerby, both of whose exposure period
would be less than that of a Site worker.
On June 1 5, 1995, EPA held a format public meeting in Jacksonville at the community
civic center to discuss EPA's proposed cleanup scenario for dioxin-contaminated soils at the
Vertac Site. At that meeting EPA attempted to address all comments or questions raised
concerning the proposed cleanup and formally accepted all public comments. Over 100 citizens
attended the meeting, including members from the Jacksonville Chamber of Commerce,
Jacksonville City Council, the Mayor, representatives from AOPC&E, and the State Heahh
Department. The comment period for the proposal ran from May 26 through August 1 1, 1995,
after EPA granted two extensions of time. AH comments received by EPA prior to the end of the
public comment period, including those expressed verbafly at the public meeting, are addressed in
the Responsiveness Summary section of this Record of Decision. Thus, the requirements of
CERCLA Sections in(kX2)(B)(i-v) and 117, 42 U.S.C. §§ 9613(k)(2)(B)(i-v) and 9617. were
met during the remedy selection process. During both the May open house and the June public
meeting, the community indicated its approval and acceptance of EPA's reasonably anticipated
land use for the Site and the risk assumptions based on that anticipated future land use.
EPA's original proposal for remediation of soils, foundations and underground utilities at
Vertac was presented to the community at an informal open house held in Jacksonville on May
25, 1995. At that time EPA's preferred alternative called for the off-site incineration of dioxin-
contaminated hot spots and oil-site landfUUng of dioxin contaminated soils that exceeded a she-
specific commercial/industrial exposure level. Under this scenario approximately two-thirds of
the Site would have potentially been available for future commercial reuse.
Following the release of the original Proposed Plan for OU2 in May 1995 and the
subsequent community meetings, EPA Administrator Carol M. Browner issued a series of
administrative reforms for the Superfund Program on October 3, 1 995. One purpose of the
reforms was to control remedy costs and to promote cost effectiveness, and the reforms directed
EPA to base Site cleanup decisions on practical future land usage and reasonable contaminant
exposure scenarios.
12
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As a result of those reform measures, EPA Region <5 revised the proposed plan of action
for OU2. The Supplemental Proposed Plan was issued on February 26, 1996, and presented to
the public at an Open House on March 5. 1996. The Supplemental Proposed Plan for OU2
eliminated the off-site incineration component of the original proposed plan and included capping
Ln-place soils having dioxin contamination between 5 to SO ppb. It also proposed on-she
landfilling of soil contaminated with dioxin in excess of SO ppb. The Jacksonville community
objected strongly to the Supplemental Proposed Plan.
After the March 5,1996, Open House, EPA representatives conducted numerous
meetings with several community groups to listen to the concerns of the local residents.
Following the March 5,1996, release of EPA's Supplemental Proposed Plan for OU2, EPA held
another comment period to accept formal public comment on the supplemental plan. The
response to these comments is contained separately from the original responsiveness summary in
the "Supplemental Responsiveness Summary,* which is included as Attachment B to this
document. Subsequently, EPA conducted another open house on July 30, 1996, to present to the
public the remedial elements it had reconsidered and currently held under consideration at the
time. In general, EPA has responded to community concerns and has reevaluated the OU2 FS
and the two proposed plans, and the elements discussed during the July 30, 1996, Open House are
now contained in this ROD.
VL STATE COMMENTS
The State of Arkansas concurs with this BSD.
VIL STATUTORY DETERMINATION
In accordance with subsection 104(dX4) of CERCLA, 42 U.S.C. § 9604(dX4), the EPA
finds that these two non-contiguous facilities, the Vertac Superfund Site and the Jacksonville
Residential Areas Superfund Site, are reasonably related on the basis of geography and on the
basis of the threat, or potential threat, to the public health or welfare or the environment, and that
these two facilities shall be treated as one for consolidation of the JRA Site contaminated soils
within their common AOC in the Vertac Site RCRA Subtitle C compliant landfill, pursuant to
section 104 of CERCLA, 42 U.S.C. § 9604.
Considering the new information developed during the El performed by ATSDR and the
ARDOH, and subsequent information obtained by EPA and Hercules, and the changes that have
been made to the selected remedy for OU2, the EPA believes that the Vertac OU2 remedy
remains protective of human health and the environment, complies with Federal and state
requirements that were identified as applicable or relevant and appropriate to this component of
13
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the remedial action at the time this BSD was signed, and is cost effective. In addition, the revised
remedy continues to utilize permanent solutions and alternative treatment technologies to the
maximum extent practicable for this Site.
J
X < <
ig Regional Administrator
o
o
o
o
14
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r-4
u*>
c.
o
o
o
ADMINISTRATIVE RECORD INDEX
SITS NAME: VBRTAC, INC. OPERABLE UNIT 2
SITE NUMBER: ARD000023440
IHDBX DATE: 03/06/98
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
VBRTAC, INC. OPERABLE UNIT 2
ARD000023440
000013 - 000013
02/29/96
001
Unapecified
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site Files
Notice
"BPA to Release Supplemental Proposed Plan for Operable Unit 2
Media (Soils)" (Notice published in the Jacksonville Patriot.)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE;
000014 - 000014
03/21/96
001
John Loyd, Real Estate Broker
Bart Grey Realty Company, Inc.
Wren Stenger, U.S. BPA Region 6
Public Comment
Comment about proposed plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000015 - 00001S
03/22/96
001
Emma Knight, Owner-Principal Broker
Coldwell Banker Quality Real Estate Services, Inc.
Donn Walters, Conmunity Involvement Coordinator, U.S.
Region 6
Public Comment
Comment about proposed plan
BPA
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES :
ADTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000016 - 000017
03/25/96
002
Marshall Steinberg, Vice President, Health & Environment
Hercules, Incorporated
Jane N. Saginaw, Regional Administrator, U.S. EPA Region 6
Letter w/Memorandum
Supplemental proposed plan
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
VBRTAC, INC. OPERABLE UNIT 2
ARD000023440
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000018 - 000018
03/29/96
001
Roberta A. Quinn
Resident of Jacksonville, Arkansas
Donn Walters, Community Involvement Coordinator, U.S.
Region 6
Public Comment
Comnent about proposed plan
BPA
I
O
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000019 - 000019
04/01/96
001
MS, J.G. Wright
Resident of Jacksonville, Arkansas
U.S. BPA Region £ Superfund Site Files
Public Consent
Comment about proposed plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000020 - 000020
04/04/96
001
John Loyd, Real Estate Broker
Bary Gray Realty Company, Inc.
U.S. EPA Region € Superfund Site Files
Public Content
Comnant about proposed plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000021 - 000035
08/11/97
015
Unspecified
Agency for Toxic Substances and Disease Registry
U.S. BPA Region 6 Superfund Site Filea
Health Assessment
Exposure Investigation
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
VERTAC, INC. OPERABLE UNIT 2
ARD000023440
DOCUMENT NUMBER:
DOCUMENT DATS:
NUMBER OP PAGES:
AOTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000036 • 000049
01/12/98
014
Jerry Clifford, Acting Regional Administrator
U.S. SPA Region 6
U.S. BPA Region 6 Superfund Site Files
Explanation of Significant Differences (BSD)
BSD to the September 199€ Record of Decision
§
DOCUMENT NUMBER:
DOCUMENT DATE;
NUMBBR OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000050 - 000050
03/01/98
001
Unspecified
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site Piles
Notice
"EPA Announces an BSD in the Remedy for the Vertac Superfund
Site, Jacksonville, Arkansas" (Notice published in the North
Pulaski Leader.)
DOCUMENT NUMBER:
DOCUMENT DATS:
NUMBBR OP PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
OOOOS1 - 000051
03/02/98
001
Unspecified
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site Files
Notice
"EPA Announces an BSD in the Remedy for the Vertac Superfund
Site, Jacksonville, Arkansas" (Notice published in the
Jacksonville Patriot.)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBBR OP PAGBS:
AOTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000052 - 000057
03/05/98
005
TcchLaw, Incorporated
Contractor for U.S. EPA Region 6
U.S. BPA Region 6 Superfund Site Piles
Index
"Addendum and Supplement for the Operable Unit 2
Administrative Record"
-------
o
s
o
THIS PAGE LEFT INTENTIONALLY BLANK FOR
NUMBERING PURPOSES ONLY.
-------
Prepared for
United States Environmental Protection Agency
Region 6
Administrative Record Index
Addendum and Supplement
for
Vertac. Inc. Superfund Site
(Operable Unit 2)
EPA ID No. 000023440
ESS VI
Work Assignment No. ESS8033
Philip Allen
Remedial Project Manager
U.S. EPA Region 6
Prepared by
TechLaw. Incorporated
750 N St. Paul Street
Suite 600
Dallas. Texas 75201
P. 6833.0604
March 6. 1998
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
VERTAC, INC. OPERABLE UNIT 2
ARD000023440
000001 - 000009
07/24/95
009
Douglas J. Keilman, Technical Director, Health t Environment
Ha eculea. Incorporated
Donn Walters, Community Involvement Coordinator, U.S. EPA
Region 6
Public Comment w/Enclosure
Comments on proposed plan of action for Operable Unit 2
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000010 - 000010
02/27/96
001
Unspecified
U.S. EPA Region £
U.S. EPA Region 6 Superfund Site Files
Notice
"SPA to Release Supplemental Proposed Plan for Operable Unit 2
Media (Soils)" {Notice published in the Jacksonville Patriot.)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY /AGENCY :
DOCUMENT TYPE:
DOCUMENT TITLE:
000011 - 000011
02/2B/96
001
Unspecified
U.S. H?A Region S
"J.S. I?A Rsgion S
Notice
"EPA to Release Supplemental Proposed Plan for Operable Unit 2
Media (Soils)" 'Notice published in the Arkansas Democrat
Gazetre. ;
3uperr'^r:a Site Files
DOCUMENT NUMBER:
DCCTJMENT DATE:
NUMBER OF PAGES:
AUTHOR;
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000012
00001
001
Unspecified
".S. IPA x
'J.S. EPA Region S Superrunci Size Files
Notice
"EPA co Release Supplemental Proposed Plan for Operable Unit 2
Media (Soils)" (Notice published in the North Pulaski Leader.:
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR;
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
VBRTAC, INC. OPERABLE UNIT 2
ARD000023440
000013 - 000013
02/29/96
001
Unspecified
U.S. EPA Region 6
U.S. EPA Region 6 Superrund Site Files
Notice
"EPA to Release Supplemental Proposed plan for Operable Unit 2
Media (Soils)" (Notice published in the Jacksonville Patriot.)
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY /AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000014 - 000014
03/21/96
001
John Loyd, Real Estate Broker
Bart Grey Realty Company, lac.
wren Stenger, U.S. EPA Region 6
Public Comment
Comment about proposed plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
"MPAIiY/AGEKCY:
RECIPIENT:
2DCCMZNT TYPE:
DOCUMENT TITLE;
000015 - 000015
03/22/96
001
Emir.a Knic.it. Owner-Principal Broker
Coldweil Banker Quality Real Estate Servi-ss. inc.
Dorm Walters, Community Involvement Coordinator, U.S. EPA
Region 6
Public Comment
Comment about proposed plan
33CL-E:rr :TCMSER:
DOCUMENT DATE :
NUMBER CF PAGES:
COMPANY/ AGENCY :
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
00001S - 000017
03/25/96
002
Marshall Steinberr, Vice P^ssidsnt. Hsal
Hercules, Incorporated
Jane N. Saginaw, Regional Administrator,
Latter w/Memorandum
Supplemental proposed plan
•J.S. EPA Region 6
-------
ADMINISTRATIVE RECORD INDEX
SITE NAME:
SITE NUMBER:
DOCUMENT NUMBER:
DOCUMENT DATS:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGEHCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
VERTAC, INC. OPERABLE UNIT 2
ARD000023440
000018 - OOOOLB
03/29/96
001
Roberta A. Quinn
Resident of Jacksonville, Arkansas
Donn Walters, Community Involvement Coordinator, U.S. EPA
Region 6
Public Comment
Comment about proposed plan
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT;
DOCUMENT TYPE:
DOCUMENT TITLE:
000019 - 000019
04/01/96
001
Me. J.G. Wright
Resident of Jacksonville, Arkansas
U.S. EPA Region 6 Superfund Site Files
Public Comment
Cowment about proposed plan
DOCUMENT OTMBER:
DOCUMENT DATE;
NUMBER OF PAGES:
AUTHOR :
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000020 - 000020
04/04/96
001
John Lcyd, Seal Estate Broker
3ary Gray Realty C=:npany, ;--.
U.S. EPA Region 6 Superfund Site Files
Public Comment
Comment about proposed plan
DOCUMENT NUMBER:
DCrUMENT DATE:
NUMBER OF PAGES :
AUTHOR:
COMPANY /ASSN'CY:
DOCUMENT TYPE:
DOCLT1ENT TITLE:
000021 - 00003S
08/11/97
015
Unspecified
Agency for T=xic S'^bstar.rss =r.c. disease .".egi^rr-/
U.S. EPA Regi=n 6 Superfund Site Files
Health Assessment
Exposure Investigation
-------
ADMINISTRATIVE RECORD IKDEX
SITE NAME: VERTAC, IHC- OPERABLE UNIT 2
SITE NUMBER: ABE000023440
DOCUMENT NUMBER:
DOCUMENT DATB:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
R8CIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
000036 - 000049
01/12/98
014
Jerry Clifford, Acting Regional Administrator
U.S. EPA Region 6
U.S. EPA Region 6 Super fund Site Files
Explanation of Significant Differences (ESC)
BSD to the September 1996 Record of Decision
DOCUMENT NUMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT TITLE:
OOOOSO * 000050
03/01/98
001
Unspecified
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site Files
Notice
"EPA Announces an BSD in the Remedy for the Vertac Superfund
Site. Jacksonville, Arkansas" (notice published in the North
Pulaski Leader.)
DOCUMENT :rtJMBER:
DOCUMENT DATE:
NUMBER 0? PAGES:
AUTHOR:
COMPANY/AGSNCY:
RECIPIENT:
DOCUMENT TYPE:
DOCUMENT 7ITLZ:
OOOOS1 - OOOOS1
03/02/98
001
Unspecified
U.S. EPA Region 6
U.S. EPA Region 6 Superfund Site Files
Notice
"EPA Announces an £33 in the Remedy fcr the Vercac Sucer:-jr.d
Site, Jacksonville, Arkansas" [Notice published ir. the
Jacksonville Patriot.;
DOCUMENT rrjMBER:
DOCUMENT DATE:
NUMBER OF PAGES:
AUTHOR:
COMPANY .'A3ENCY:
RECIPIENT:
DOCUMENT TYPE:
000052 - 000057
03/06/98
005
TechLaw, Incorporated
Contractor f=r U.S. r?A Region s
U.S. EPA Region S Superfund Site Files
Index
"Adder-dura and Supplsre-; fcr r.-.a Operable CTr-ic -
Administrative Recora"
-------
~V~r -« '"UM VI H.rcuJ«» Incorporate
" - <••
.... .., »- 1313 North Maritet Street
"i 2C :.i^'-" Wilmington, OE 19894-0001
July 24, 1995 (302> 594-5000
Via FAX: 214-665-6460
No. of Pages: 6
Hard Copy to FoDow by Federal Express (Next-Day Delivery)
Mr. Donald Walters §
Community Involvement Coordinator (6H-MQ §
US. EPA Region VI °
1445 Ross Avenue
Dallas, TX 75202-2733
Dear Mr. Walters:
Subject: Comments on the Proposed Plan of Action for
Operable Unit II of the Venae Superfund Site
The following comments by Hercules Incorporated are submitted in response to the
Proposed Plan of Action , hereafter referred to as die Plan, issued by the U.S. EPA for Operable
Unit n of the Venae Superfund Site in Jacksonville, Arkansas, hereafter referred to as the Site.
The comments are based on knowledge gained by Hercules and its consultants and contractors
whfle working with the EPA and the Arkansas Department of Pollution Control & Ecology
(ADPC&E) on site-related activities, including the Remedial Investigation/Feasibility Study for
Operable Unit n.
Site Surface Sofl Cleanup Criteria for Dioxin
The Plan acknowledges that the Site will consist of two areas in the future. One area will
include those portions of the Site that will be involved in long-term remedial operations and
maintenance; e.g., the existing capped waste burial areas; the closed cooling pond and wastewater
equalization basin areas; the leachate collection and treatment systems; the new landfill and future
groundwater recovery and monitoring wells (see Attachment 1 V That area, referred to hereafter
as the "Containment Area," is, and wfll be, surrounded by a security fence and a buffer zone.
Attachment 2 shows the approximate location of the existing fence. The eastern boundary of the
Containment Area should be specified so the bagged soil storage building, which may be used to
house the wastewater treatment system in the future, will be included in the Containment Area.
The Venae Site Receiver has agreed to place a restriction in the property deed for that portion of
the Site to prevent disturbing it as long as hazardous substances are present. The second area,
which is referred to hereafter as the "Developable Area," includes the rest of the Venae Chemical
Corporation property (approximately 115 acres). As stated in the Plan, and as voiced by many in
the community at the June 15, ! 995, public meeting on the Plan, the Developable Area of the Site
should be remediated to allow for continued use for commercial/industrial purposes without
-------
Mr. Donald Walters, U.S. EPA Region VI (Dallas)
July 24.1995
Page 2
restrictions. Although the Plan acknowledges the existence of the two areas, it fails to recognize
unique area-specific conditions when proposing surface soil cleanup criteria; Le., the Plan
provides for a 5 ppb dioxin (TEV) cleanup criterion for surface soil for both the Containment and
Developable areas of the Site.
TN
Hercules recognizes that the Site must be remediated and has already spent tens of §
millions of dollars in that effort. In fact, Hercules is the only Potentially Responsible Party to §
either enter Consent Agreements or to comply with Administrative Orders to study or remediate °
portions of the She. It is Hercules' position that when remediation is complete, all potential
threats to the health of the community and the environment must be eliminated. The 5 ppb dioxin
surface soil cleanup criterion, however, is unnecessarily stringent and inconsistent with a past
dioxin cleanup requirement of 20 ppb used at another commercial/industrial she in Arkansas, e.g.,
the site in Arkwood, Arkansas, and at other sites. Despite the fact that a 5 ppb dioxin surface soil
cleanup criterion is unnecessarily stringent, Hercules is aware thai a not-io-exceed (NTE) surface
soil concentration of 20 ppb, shown to be protective of human health by risk analysis, may not be
acceptable to the public. The Jacksonville public's perception of the risk from dioxin has been
significantly influenced by EPA's other actions in the area. For this reason, Hercules is willing to
support EPA's proposed 5 ppb cleanup criterion for the Developable Area. However, the surface
soil cleanup criterion for the Containment Area should be based on area-specific factors.
Hercules believes that although the EPA has made an effort to estimate risks on the Site, the
effort failed to properly consider unique area-specific conditions which do and will continue to
exist within the Containment Area and, therefore, provide the basis for a higher surface soil
cleanup criterion that protects worker health and safety and is consistent with reasonable future
land use.
The Plan states that dermal contact with contaminated surface soil is the major potential
concern for future site workers. The Plan also states that future workers within the Containment
Area should not be required to wear "chemical protective equipment in order to conduct their
daily activities." Hercules believes that normal work clothing consisting of long-sleeved shirts and
pants win be adequate protection for future workers. Risk assessments made by Hercules
consultant, ENVIRON Corporation1, were based on the assumed use of normal work clothing.
The EPA has approved use of a Health &. Safety Plan for workers employed at the Site under the
presently existing conditions which requires only normal work clothing where contaminated soil is
the sole concern.
The EPA risk assessor incorrectly used EPA default risk assessment guidance when
selecting the amount of skin area exposed to soil for workers wearing the clothing described
1 Risk Assessment of Prospective Cleanup Levels for 2.3.7,8-TCDD in Surface Soils at the
Venae Chemical Corporation Site, Jacksonville. Arkansas, April 11,1994 and EPA RME
Scenarios for the Vertac Chemical Site, Jacksonville, Arkansas, June 28,1994
-------
Mr. Donald Walters, U.S. EPA Region VI (Dallas)
July 24,1995
Page 3
above. The risk assessor used 25% as the percent of the total body surface exposed every
working day for twenty-five years. This skin area corresponds to hands, anus, face and lower
legs being continually exposed. For normal work clothing, i.e., long sleeved shirt and pants, EPA
risk assessment guidance for exposure to soft indicates that the skin exposure should be 10%*
which corresponds to exposure of hands and face. This factor alone will effectively reduce the
estimate of potential risk to future workers by about 60% for any given soil cleanup criterion.
The EPA risk assessor also assumed that future site workers would not conduct any of
their activities in those portions of the Containment Area that have already been remediated.
Under EPA oversight, 40% of the Containment Area has been remediated using clean, off-site soil
and is currently contaminant free. The EPA risk assessor ignores the fact that many of die Site
activities, e.g., inspection and maintenance, mowing of capped areas, measuring water levels in
monitoring wells, etc., currently and in the future will occur in the clean areas. Hercules believes
that the risk assessment for the future worker should reflect this site information. If incorporated
correctly, this factor would reduce the predicted risk to future workers by at least 40% because.
as discussed below, future Site workers are expected to spend a disproportionate share of tune in
clean areas1.
The EPA risk assessor also failed to consider that remedial plans for the Site which,
although not yet finalized, include relocation of most of the wastewater treatment facilities into a
clean building within the Containment Area. Collection and treatment of groundwater win be the
main future activity within the Containment Area. Therefore, future worker exposure to Site soil
will be further reduced from that assumed by the EPA risk assessor. Hercules has estimated that
over one-half of each worker's time in the Containment Area win be spent on operating and
maintenance activities which will occur within the clean building. This factor should also be
included in the Site risk assessment.
Two other inappropriate assumptions or procedures were used by the risk assessor that
resulted in an overly stringent cleanup standard. One inappropriate procedure was the use of a
site-specific bioavailability factor of 10% that was higher than any of the individual results
determined by the Rutgers University bioavailability study for 2,3,7,8-TCDD conducted with soil
samples taken from the Site. The individual results ranged from less than 1% to less than 9%.
An average of the site-specific results which had a geometric mean of 2.3% more accurately
describes the bioavailability of dioxin from Venae Site soil. In addition, the risk assessor used a
slope factor of 156,000 kg-day/mg for 2,3,7.8-TCDD that is substantially greater than the slope
1 Dermal Exposure Assessment: Principles and Applications, Interim Report, U.S. EPA. 1992
3 This factor is most simply addressed by a modification in the assumed exposure
frequency but could also be addressed by calculating exposure concentrations for die entire
Containment Area rather than only the impacted areas.
-------
Mr. Donald Walters. U.S. EPA Region VI (Dallas)
July 24,1995
Page*
factor of 100,000 kg-day/tug which corresponds to the risk-specific dose of dioxin (0.01 grams
TEV per kilogram of body weight results in one additional cancer in one million) stated in the
Plan (page 22).
A risk assessment performed using the appropriate site-specific factors discussed above
would yield a surface soil cleanup criterion for dioxin well above the 20 ppb dioxin that EPA has rr
used in Arkansas in the past; e.g., the Adcwood, Arkansas site. As stated in the Plan (page 4), a o
risk assessment conducted by ENVIRON Corporation showed that a 50 ppb cleanup standard for o
dioxin was only marginally outside the acceptable range for industrial she workers even though it
excluded the clean portions of the Containment Area as requested by EPA. Hercules believes that
EPA should specify a NTE surface soil cleanup standard for dioxin for die Containment Area of
the Site in the range bounded by 20 ppb, as used at the Arkwood, Arkansas, site, and 50 ppb as
determined by ENVIRON Corporation. The NTE concentration should be based upon
considerations of site-specific conditions, as allowed under EPA Risk Assessment Guidance under
Superfund. It should also recognize that the number of exposed individuals will be four or less so
that the benefit of cleanup in reducing cancers will be very small.
Rer^tt^fql Technology Se^e/ction for Site Soil
The EPA acknowledges that dioxin has very low solubility in water and adsorbs
tenaciously onto soil. Therefore, there is negligible potential for the dioxin to migrate from a
hazardous waste landfiD. Hercules supports the EPA's conclusion that dioxin contaminated soil
can be safely disposed of in an on-sire hazardous waste landfill. Hercules does not agree.
however, that application of that remediation technology should be limited to soil containing less
than 260 ppb dioxin. None of the site soil is a principal threat, especially when compared to the
thousands of tons of concentrated wastes which have been, or will be. destroyed by incineration;
e.g., the Vertac drammed wastes and the residual chemicals from the central process area. The
cost effectiveness of incinerating contaminated soil is less than one millionth of the cost
effectiveness of treating the hazardous wastes from Operable Unit I. e.g., the French drain oily
phase liquids4. Also, because there is only one commercial incinerator permitted to incinerate
dioxin contaminated soil, being forced to use that very expensive facility to treat soil, which can
be safely landfilled, may be sufficient grounds for refusing to implement that remedy.
Based on both the technical effectiveness of landfifling dioxin contaminated soil and the
very low cost effectiveness of incinerating such soil, Hercules believes that all excavated dioxin
* The cost to incinerate soil which contains one pound of hazardous substance when the
hazardous substance is present at a concentration of 450 ppb (the average dioxin concentration in
the 8 grids planned for incineration) was quoted at $4,440,000. The cost to incinerate one pound
of French drain leachate. which is composed entirely of hazardous substances, was quoted as $2.
The ratio of these costs is 2.2 million to one.
-------
Mr. Donald Walters, U.S. EPA Region VI (Dallas)
July 24.1995
PageS
contaminated surface soil should be placed in the on-site hazardous waste landfill that will be
constructed as part of Operable Unit I remediation.
Landfilling all excavated dioxin contaminated surface soil will reduce short-term risks and
have additional benefits. If all such soil is landfBled. the soil can immediately be placed in the
landfill after excavation instead of waiting for analytical results to determine which disposal option
is required. Such analyses would be necessary to avoid the very high cost of incineration for soil o
which meets the criteria for landfiBing. This would have a significant impact on shortening the o
time to remediate the Site. Hercules' earlier discussions with ADPC&E indicated that ADPC&E o
would concur with such a remedy if it is specified in the Record of Decision (ROD)1, landfill ing
on the Site would also eliminate the need to transport the soil over public highways to an off-site
incinerator as called for in the Plan. In addition, it will not be necessary to pretreat soil to
remove inert material (rocks, etc.) before shipment off site. Such pretreatment is performed to
avoid the very high cost of incinerating inert materials. Avoiding pretreatment will also reduce
short-term risk.
The Feasibility Study evaluated capping of contaminated soil in place and found the
technology to be bom technically and economically appropriate for areas of low contaminant
concentrations. The very low potential for dioxin to migrate through soil, as supported by the
low bioavailability, as mentioned above, is supportive of covering contaminated soil in place with
a layer of clean soil. Therefore. Hercules recommends that capping for some areas of low
contaminant concentrations, e.g., areas with surface soil concentrations between the NTE
concentration and 100 ppb, in the Containment Area with clean soil be selected as an optional
remediation technology. This would be of particular application where the addition of clean soil is
required for site grading purposes.
Capping some areas of low contaminant concentration would have the additional benefit
of minimizing the size of the landfill. Hercules is aware that the Jacksonville community would
like the landfill size to be minimized. If an NTE soil concentration of 50 ppb dioxin is selected
and areas with surface soil concentrations up to 100 ppb are capped, the soil requiring excavation
would be reduced over 40%. If a lower NTE concentration is selected, the reduction would be
even greater. Capping some areas where soil would otherwise be excavated and placed in the
landfill would comply with community wishes.
*f Spill Area
The assessment of potential risk to human health from exposure to contaminated soil in
the tetrachlorobenzene (TCB) spill area indicated that 500 ppm of TCB in soil provided an
1 Conversation of February 14,1995. between T. J. Grimes of Hercules Incorporated and
Mr. Randall Mathis. Director, ADPC&E
-------
cc: R. Ehrhart, US. EPA, Region VI (Dallas)
M. S. Ramesh. U.S. EPA, Region VI (Dallas)
S
o
o
o
o
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f .:-f
i-r .-/ u.
000007
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ATTACHMENT 2
oo
o
o
o
o
o
Location of Proposed Fence at the Vertac
Site, Jacksonville, Arkansas
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Mr. Donald Walters, U.S. EPA Region VI (Dallas)
July 24, 1995
Page 6
acceptable risk if exposure of workers is limited The Feasibility Study evaluated only two
remedial technologies, thermal desoiption and incineration, for TCB contaminated soil. Although
evaluation of other technologies was focused on dioxin contaminated soil, Hercules believes these
evaluations apply to TCB contaminated soil as well. Specifically, Hercules believes soil which
contains up to ten times the no-action level of 500 ppm TCB should be placed in the on-site
landfill for permanent containment. Soil containing more than 5000 ppm TCB and any crystalline ^
TCB should be sent off site for treatment in a RCRA facility. Although incineration is the most g
likely treatment for these materials, the ROD for these materials should allow other permitted g
treatments or recovery options to be evaluated and selected during the remedial design period. °
One potential option would be to melt the crystalline TCB and physically separate it by filtration
from soil for reuse or disposal.
In summary, as stated above, Hercules does not dispute the application of the 5 ppb dioxin
(TEV) cleanup criterion for surface soil in the Developable Area because that criterion may make
it easier to attract firms to locate in that area. However, Hercules believes that the cleanup
criterion for the Containment Area should be between 20 and 50 ppb dioxin (TEV) and that the
protect tveness of this criterion to human health is supported by a risk assessment performed with
the appropriate use of EPA guidance to site-specific conditions.
Hercules also supports EPA's proposal to place contaminated soil in an on-site landfill.
However, Hercules believes the plan to require incineration of some soil is arbitrary and ignores
the fact that this soil can also be safely placed in the landfill.
Covering areas of low dioxin concentrations with clean soil is a remediation technology
which was shown by the Feasibility Study to be protective of health and the environment.
Hercules believes it is arbitrary not to use this technology in areas of low dioxin concentrations.
Finally, Hercules has cooperated with the EPA and ADPC&E in performing an RI/FS for
die Site and by agreeing to remediate some of the on-site areas left behind by the Vertac Chemical
Corporation. Hercules hopes that the EPA will issue a ROD that will not prevent continued
cooperation.
Sincerely,
. A rvj
Douglas J. i
Technical Director
Health &. Environment
DJK/Ur
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3 EPA
EPA TO RELEASE
SUPPLEMENTAL PROPOSED PLAN
FOR OPERABLE UNIT 2 MEDIA (SOILS)
VERTAC SUPERFUND SITE, JACKSONVILLE. ARKANSAS
;*, M. **< *e> **>
The U.S. Environmental Protection Agency (EPA) has modified its preferred remedy lor Operable
Unit 2 me
Dallas. TX 75202-2733
(Note: The comment penod wtll not be extended beyond 30 days, because the initial Proposed Plan
lor OU2 and the supporting analysis and information for thai proposal, including the Remedial In-
vestigation and Feasibility Study reports, nave been available to the public since May 26.1995.)
Jacksonville Patriot February 27, 1996
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SEPA
EPA TO RELEASE
SUPPLEMENTAL PROPOSED PLAN
FOR OPERABLE UNIT 2 MEDIA (SOILS)
VERTAC SUPERFUND SITE. JACKSONVILLE. ARKANSAS
The U.S. Environmental Protection Agency (EPA) has modified its preferred remedy lor Operable
Unit 2 media, consisting of soils, foundations, and underground utilities, at the Venae Supertund
Sit*, in Jacksonville. Arkansas. In order to accomplish this. EPA is releasing a Supplemental Pro-
posed Plan to me puolic explaining EPA's new cleanup proposal for sort at me Venae Site.
Under the supplemental cleanup proposal, the Vertac site wtll be roughly divided in hall from east to
west, except tor a stnp along Marshall road which will serve as a buffer zone tor the nea/try commu-
nity. After remediation, the northern naif ot the site will have unrestricted access tor commercial/
industrial development. The southern naif of the site, nowaver. will remain fenced and access wtll
be restricted to on-site maintenance woncers oecause contamination will remain m place under a
soil cap atter remediation mat wiH prevent any future development ot the property.
This Supplemental Proposed Plan tor Operable Unit 2 and all other information mat is being consid-
ered or relied on for selecting the final remedy for the site is available lor public review and com-
ment at the following information repositories:
Jacksonville City Hall
*l industrial Drive
Jacksonville. AR 72076
U.S. Environmental Protection Agency. Region 6
7th Floor Reception Area
1445 Ross Avenue
Dallas. TX 75202-2733
Arkansas Department of Pollution Control & Ecology
8001 National Drive
Little Rock. AR 72209
On March 5. 1996. EPA wol conduct an ntormal open nouse at the new Jacksonville Community
Center (next to City Hall) from 6:30 p.m. to 9:00 p.m. to discuss me Supplemental Proposed Plan.
The public is encouraged to attend for a snort EPA presentation. Afterwards. EPA will be available
to meet with citizens in small groups to discuss any questions or comments on the new proposal.
Because this is not a formal public meeting, a court reporter wril not be present to record oral
comments. EPA. however, encourages all citizens to provide written comments during the public
comment period.
The comment penod tor trie Supplemental Proposed Plan begins on Maicn 6. 1996 and ends on
Aprt 4.1996. During that lime, wmten comments may be submitted to:
Donn Walters
Community involvement Coordinator
U.S. EPA. Region 6
1445 Ross Avenue (6SF-P)
Dallas. TX 75202-2733
(Note: The comment period will not be extended beyond 30 days, because the initial Proposed Plan
tor OU2 and the supporting analysis and information tor that proposal, including the Remedial in-
vestigation and Feasibility Study reports, have been available to the public since May 26.1995.)
Arkansas Democrat Gazette February 28, 1996
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SEPA
EPA TO RELEASE
SUPPLEMENTAL PROPOSED PLAN
FOR OPERABLE UNIT 2 MEDIA (SOILS)
VERTAC SUPERFUND SITE, JACKSONVILLE. ARKANSAS
The U.S. Environnwual Protection Agency (EPA) has modified its preferred remedy lor Operable
Unit 2 media, consisting ol sexto, foundations. and underground utilities, at the Vertac Supertund £J
Site, in Jacksonville. Arkansas. tn oraer to accomplish this. EPA is releasing a Supplemental Pro- g
posed Plan to ttie putHic explaining EPA's new cleanup proposal for sal at trie Vertac Site. o
Under the supplemental claim* proposal, the Vertac sne wdl be roughly divided in half from east to
west except tor a sinp along Marshall road which will serve as a butter zone tor the nearoy commu-
nity. After remediation, the northern naif ot (he site will have unrestricted access for commeroai/
industrial development. The southern naif of the sne. nowever will remain tenced and access will
be restricted to on-site maintenance workers because contamination wul remain tn ptace under a
soil cap aiter remediation mat will prevent any future development ot the property.
This Supplemental Proposed Plan lor Operable Unit 2 and atl other information mat is being conaid-
ered or relied on for selecting trie final remedy for the site is available for public review and com-
ment at the following information repositories:
Jacksonville City Hall
#1 industrial Drive
Jacksonville, AR 72076
U.S. Environmental Protection Agency. Region 6
7th Floor Reception Area
1445 Rosa Avenue
Dallas. TX 75202-2733
Arkansas Department ot Pollution Control & Ecology
6001 National Drive
Uttte ROCK. AH 72209
On March 5. 1996. EPA will conduct an informal open house at the new Jacksonville Community
Center (next to City Hall) from 6:30 p.m. to 9:00 p.m. to discuss the Supplemental Proposed Plan.
The public is encouraged to attend lor a shon EPA presentation. Afterwards. EPA will be available
to meet with citizens in smafl groups to discuss any questions or comments on the new proposal.
Because this is not a formal public meeting, a court reporter w*l not be present to record oral
comments. EPA. however, encourages an citizens to provide written comments during the pubHc
comment penod.
The comment penod lor the Supplemental Proposed Plan begins on Marcn 6. 1996 and ends on
Apnt 4, 1 996. During tnat time, written comments may be submitted to:
Dorm Walters
Community involvement Coordinator
U.S. EPA. Region 6
1 445 Ross Avenue |6SF-P>
Dallas. TX 75202-2733
(Note: The comment penod will not be extended beyond 30 days, because the initial Proposed Plan
tor OU2 and the supporting analysis and information tor mat oroposal. including the Remedial In-
vestigation and Feasibility Study reports, have been available lo the public smce May 26. 1995.)
North Pulaski Leader February 28, 1996
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EPA
EPft TO RELEASE
•MENTAL FfMKMe
FCM OPERABLE UNIT 2 MEDIA (9OltS)
VEHmC 8UPEBRJNO OTE. JACKSONVILLE, ARKANSAS
IMUS.1
IMtl
te«Mr«l
CMT«<
i9*«r<
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COMMENTS
EPA would like your comments on the Supplemental Proposed Plan, and the Administrative Record File for the
Vertac site. Write your comments below, and then fold, tape, stamp, and mail this form. All significant comments
will be addressed in the Responsiveness Summary for the site. If you would like to receive a copy of the
Responsiveness Summary, you must include your name and address.
The proposal modifications to "The Jacksonville Plan" is a betrayal to the city of
Jacksonville and to its citizens.
For over 10 years we have had a PROMISE from the EPA to leave Jacksonville's Vertac site
"clean enough to support a park". Now the comment of the decade as far as I'm concerned
is "VE FORGOT ABOUT THE GROUND WATER." which^is a statement made during the Public Meeting
3/5/96 at Jacksonville's Community Center by the EPA representative.
— v
v*
City officials, business owners, and citizens who have been in support of EPA^s £
c
efforts and "The Jacksonville Plan" have given this support because we trusted that the C
plan and the vovs of the EPA were honest. Now we are told that EPA has every intention
of leaving Jacksonville's Vertac site useless for future use/development. We find that
EPA is not concerned with our citizen's beat interests.
I go on record as being emphatically opposed to the proposed modifications and urge
the EPA to keep the commitment to Jacksonville. ____^_
Emma Knight
Jacksonville City Council, Ward 1, Position 1
Owner-Principal Broker, Coldwell Banker Quality Real Estate Services, Inc.
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•HERCULES
aa^M liliajfcBg _ Heieum Pta
1313 NOrtfl MarteS S&Mt
Wftrtaolnn, 06 19BB4-OM1
(302)5944000
March 23, 1996
Via FaealmHa and Regular Mad
NoLofPagee: 1
Fax No.: 214JB8MM8
Ms. Jane Saginaw
Regional Administrator 0
U.8. Environment* Protection Agency --
Region VI o
1445 Ron Avenue, Suite 1200 §
Dabs, TX 75202-2733
Subject: Vartae Supwftjnd Stta, Opwabla Unit fl
Dear Ms. Saginaw:
HorculBs Incorporated hai recently been informed that it may be Region VTs Intention to
not foQow through with the Supplemental Prepoted Ran of Action tor the Vertae Suparfund Stte,
despite fte approval of the EPA'i National Dtadn Review Gnaup and thestateniantbyttw
Agency far Toodc Stdnlancea Otease Registry that the revieed approach for OU-II Is protective
of human health end the envirenment
atwe the concenu of the citizens of Jacksonville have been provided to the Agency.
HereuJM would Uke an opportmHy to present Its position. Whie Hercules wil bo aubmrtflng
fonnsJ comiiienu to the Region uunceriBig the Supplement Plan. I would Bee to take tttt
opportunity to share with you that Harcuiaa finds it vety dtetwttng that the EPA would raconsUer
approaches which are excessive in terms of protection to human health and cost
It should be noted that Hercules has continued to work with Region VI In developing and
executing a plan of action despite ongoing litigation since 1980. Hercules t* also concerned that
abandonment of the Supplemental Proposed Plan of Action suggests that the EPA Is no longer
interested in reaching a global settlement and completing the remediation.
I would very much appreciate the opportunity to meet *«h you to discuss our position and
to determine rf we can work together to *elv» this ehaiienga. To this end, I shafl be caffngyour
office the week of March 25, 1996 to arrange vt appointment.
Sincerely.
Vtoe President
Health & Environment
ctz M. B, Meanan, Hercules, Wilmington, DE
R. Mathls, ADPC&E, Ltttte Rock, AR
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Tromi Helen L. Thompson
To I ANDERSON-MARLENE
Dates Monday, March 25, 1996 1:36 ptm
SubjectI LETTER FROM HERCULES, INC.
MARLENE/CONNZE: RA SAG I HAW RECEIVED A PAX THIS MORNING FROM
HERCULES, INCORPORATED DATED TODAY. THE LAST PARAGRAPH SAID THEY
"WOULD APPRECIATE THE OPPORTUNITY TO MEET WITH HER TO DISCUSS
THEIR POSITION AND TO DETERMINE 17 THEY CAN WORK TOGETHER TO
SOLVE THIS CHALLENGE." THEY SAID THEY WILL CALL HER THIS WEEK.
IS THE TIMING ON THE VERTAC SUPERFUND SITE SUPPLEMENTAL PROPOSED
PLAN OP ACTION APPROPRIATE FOR THE ACTING DRA TO MEET WITH THEM
AFTER APRIL 12; I.E., PUBLIC COMMENT PERIOD. r-
o
THERE IS A COPY OF THE LETTER AT THE FRONT DESK FOR YOUR ACTION §
AND ADVICE. THANKS. °
CCt SANCHEZ-CONNIE
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Questions regarding present Vertac site remedy:
1) Why is new precedent being set in regards to the allowable amount of dioxin being placed
into an on-she landfill?
2) There have been rumors that ground water contamination has been discovered off-site
(over by the railroad). Wilt EPA release ALL of the groundwatcr results and provide the
community with a groundwater plum dispersion map? Will EPA also present an outlook
groundwater plum dispersion map showing what will happen over the next 5 -10 yean?
3) Aptus in Coffeyville has just lowered their cost, $ per pound, for incinerating waste. Has
Aptus's new costs been factored into the benefit analysis?
4) Who is going to maintain the "dirty" area if Hercules Chemical declares bankruptcy? If
EPA then is the agency willing to provide binding guarantees to the community?
5) What is EPA going to do with the existing landfill - the one which was improperly built by
the same company who is now going to do this one? (Company names change but the
same people have will be involved.)
6) Why is EPA backing off from it's previous Record of Decision - especially with all of the
new information regarding the toxicity of dioxin.
,
-f /? 7 ~Lti 1
- f A 3_ - '2.
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o
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O
o
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John Loyd (right) of United Wa Stand shows Doug Ketknan of Hercules
how 300-toot grasvy field In front of Vertac woJd enhance the area.
(Loader photo by David Parker)
PHOTO TAKEN DURING FINAL PUBLIC MEETING HELD ON
Monday Aril l, 1996...
Mr. Keilman arrived unannouced and either he or someone
on his staff invited the Little Rock news media to the meeting
unfortunately or fortunately they arrived as the meeting was
over.
A lady came to the meeting with Mr. Keilman (I think it was
a member of his staff) and she asked several questions about
the wells that will (or may be) outside the the fence..
I asked her to reduce her comments to writting and I would
insure that they were forwarded along with our package.
At the time
Submit
ailing...No response or comments were receied,
LOYD APRIL 4, 1996
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Exposure Investigation
s
o
o
VERTAC, INCORPORATED °
JACKSONVILLE, PULASKI COUNTY, ARKANSAS
CERCLIS NO. ARD000023440
AUGUST 11,1997
U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
Public Health Service
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Atlanta, Georgia
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EXPOSURE INVESTIGATION II
r-i
VERTAC. INCORPORATED §
o
JACKSONVILLE, PULASKI COUNTY, ARKANSAS
CERCLIS NO. ARD000023440
Prepared by:
Exposure Investigation and Consultation Branch
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
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BACKGROUND
in April 1997, the Agency for Toxic Substances and Disease
Registry(ATSDR)conducted a second environmental exposure
investigation (El) at two residences where one of the inhabitants
in each home participated in the Arkansas Department of Health's
serum dioxin health study. Health scientists conducted the
second El to confirm the qualitative environmental sampling
results for 2, 3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD}
found in the first El [13. The initial El identified 2,3,7,8-TCDD
and other dioxins/furans in residential surface soil and indoor
wipe/dust samples. However, the analytical results had rs
significantly low percent recoveries for the contaminants. §
Conclusions from the results were that 2, 3, 7, 8-TCDD (up to g
approximately 10 parts per billion [ppb] in one sample) is
present in the areas sampled, but the results could not be used
to make a scientifically defensible public health decision for
the residents.
The Exposure Investigation Section, the health assessor, and the
Arkansas Department of Health (ARDOH) agreed that environmental
sampling should be repeated. In addition, because the presence
of 2,3,7,8-TCDD was confirmed in the first El, they agreed that
serum dioxin testing would be offered to the four residents of
the homes. Refer to attachments 1 and 2 for the results of the
first El and the respective workplan.
METHODS
With coordination from the {ARDOH} and permission from the
homeowners, ATSDR collected surface soil, indoor dust, and indoor
surface wipe samples for 2,3,7,6-tetrachlorodibenzo-p-dioxin
(TCDD) and TCDD equivalent analyses. Sample locations
approximated those of the first exposure investigation. Refer to
the attached workplan for a more detailed description of
activities (Attachment 2).
Investigators collected three composite surface soil samples and
two indoor floor dust samples at one residence. They collected
two composite surface soil samples, two wipes from surfaces of
utility shelves used for canned goods storage, two indoor floor
dust: saunples, and one dust trip blank, at the second residence.
Samples were shipped to Midwest Research Institute (MRI) for
analyses through an Inter Agency Agreement with the Division of
Federal Occupational Health. Data Chem weighed the surface dust
samples before their shipment to MRI. He requested a four-month
analytical turnaround time.
One resident agreed to serum dioxin testing. This resident
participated in the health study, making it this person's third
serum dioxin test. The American Red Cross (Little Rock, AR) drew
and shipped the blood sample to the Centers for Disease Control
-------
and Prevention {CDC) Center for Environmental Health laboratories
for analyses. Results of this test are pending.
RESULTS
Table 1 summarizes the results of the environmental sampling.
Table 1. Environmental Sampling Result Summary for Two
Residential Properties Near the Vertac
National Priorities List Site
Samples Collected April 15, 1997
Sample Type
Surface Soil
Composite
Indoor
Surface
Wipe***
Indoor
Surface Dust
Surface Dust
Blank
Number of
Samples
5
2
4
1
2,3,7,8-TCDD*
Concent rat ion
Range
0.172 -
2.81** ug/kg
13.0** -
14 . 0 ng/m2
ND -
0.697 ug/kg
ND
TCDD Equivalents
0.18 - 2.8 ug/kg
13.4 -
14,7' ng/m2
0.17 - 0.7lug/kg
ND
* TCDD - tetrachlorodibenzo-p-dioxin
** * concentration exceeded the upper limit of the
calibration range
*** - from shelving
ug/kg * microgram (ug) contaminant: per kilogram (kg) of
soil or dust or part per billion (ppb)
ng/m2 = nanogram (ng) contaminant per square meter of
surface
ND - not detected
o
o
DISCUSSION
The Agency for Toxic Substances anri Disease Registry's (ATSDR's)
policy regarding dioxins in soil Indicates that a level of 1
microgram per kilogram of soil tug/kg) or part per billion, (ppb)
or less of 2,3,7,8-TCDD equivalents in residential surface soil
is protective of public health [2-5] .
In one residence, the TCDD equivalents (TEQ) in 2 of the 3
surface soil samples exceeded 1 ppb (2.8 and 1.6 ppb TEQ). These
levels confirm the results of the first exposure investigation.
The indoor dust results of this residence did not exceed the 1
ppb action level; the back door and front door entryway results
identified 0.26 and 0.71 ppb TEQ, respectively. The indoor areas
-------
sampled should reflect: worst case concentrations from
contaminated soil track-in. If this is the case, then levels in
dust elsewhere in the home should be lower.
In the other residence, TEQ levels in the two surface soil
samples were below 1 ppb (0.18 and 0.48 ppb TEQ). Similarly, the
indoor surface dust samples from the back and front entryways
were below the soil action level (0.17 and 0.6 ppb TEQ}.
However, wipe sample results of the pantry utility shelving
revealed the presence of 2,3,7,8-TCDD. The shelving, in a
utility room in the garage, is used to store canned goods. Wipe
sample results are not used for quantitative purposes; the
results indicate that the contaminant is present. The use of the
shelving for storing food items suggests that dermal and oral
exposure to 2,3,7,9-TCDD is possible. JQ
o
CONCLUSION o
o
The levels of 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD)
equivalents (TEQ) in one residence's soil and in the other
residence's utility shelving pose a public health concern.
The number of environmental samples collected does not provide
sufficient information to determine the extent of the TEQ
contamination at either residence, or in adjacent yards. The
results do indicate that TCDD equivalents are present in these
residents' environment and that exposures are likely. Additional
sampling will be necessary for better characterization of the
source and extent of TCDD contamination in this area.
RECOMMENDATIONS
1. Stop exposures to the contaminated shelving.
2. Conduct additional residential surface soil sampling to
determine the extent of environmental contamination.
3. Offer serum dioxin testing to the other occupants of the two
homes.
Lynn C. Wilder, CIH
Attachments
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REFERENCES
1. Exposure Investigation, Vertac Site, Jacksonville, Arkansas.
February 1997, ATSDR DHAC EIC3.
2. Memorandum, From: Vernon N. Houk, M.D., Assistant Surgeon
General, Director, Center for Environmental Health, Subject:
Missouri Dioxin Sites Cleanup, To: Barry L. Johnson, Ph.D.,
Assistant Administrator, ATSDR, Date: May 8, 1987.
3. Letter, From: Morris Kay, Regional Administrator, U.S.
Environmental Protection Agency, Region VII, To: Renate D.
Kimbrough, Center for Environmental Health, Centers for
Disease Control, Date: January 16, 1987.
4. Letter, From: Barry L. Johnson, Ph.D., Assistant
Administrator, ATSDR, To: Mr. David Wagner, Director, Waste ^
Management Division, U.S. Environmental Protection Agency, g
Region VII, Date: July 30, 1987. o
o
o
5. Dioxin Issue Paper, Prepared by: Office of Regional
Operations, Office of the Assistant Administrator, and
Division of Health Assessment and Consultation, ATSDR, U.S.
Public Health Service. Approved by: Barry L. Johnson,
Ph.D., Assistant Surgeon General, Assistant Administrator,
ATSDR, February 10, 1993.
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EXPOSURE INVESTIGATION
VERTAC SITE
JACKSONVILLE, ARKANSAS
February 1997
fS
o
U.S. Department of Health and Huinan Services
Public Health Service
Agency for Toxic Substances and Disease Registry
Division of Health Assessment and Consultation
Atlanta, Georgia
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BACKGROUND
In October 1996 an environmental exposure investigation (El) was
conducted at two residences where one of the inhabitants
participated in the health study. The El was requested by the
ATSDR health assessor to determine if the homes/yards contained
2,3,7,8-tetrachlorodibenzo-p-dioxin {2,3,7 , 8-TCDD) . Filling in
this data gap would assist in determining the reason for 2 of the
occupants' serum dioxin levels increasing, while all other study
participants' levels decreased.
METHODS
oo
With coordination from the Arkansas Department of Health (ARDOH) o
and permission from the homeowners, ATSDR collected surface soil, §
indoor dust, and indoor surface wipe samples for 2,3,7,8-TCDD and °
TCDD equivalent (TEQ) analyses. Refer to the attached workplan
for a more detailed description of activities.
At one residence, the following samples were collected: 3
composite surface soil; 1 indoor floor surface wipe; 2 indoor
floor dust samples r and 1 dust trip blank. At the second
residence, the following"samples were collected: 2 composite
surface soil; 1 indoor floor surface wipe; 3 utility shelf
surface wipes (used for canned goods storage); 1 indoor floor
dust sample; and 1 trip blank.
Samples were shipped to Midwest Research Institute (MRI) for
analyses, through the EICB Inter Agency Agreement with the
Division of Federal Occupational Health. The surface dust
samples were sent to Data Chem for dust sample weight prior to
shipment to MRI. A four-month analytical turnaround time was
requested.
RESULTS
Sample results indicated the presence of 2,3,7,8-TCDD and other
polychlorinated dioxins and furans. However, the analytical
quality assurance tests (spike sampling) indicated that there was
a low recovery of the contaminants from the sample extraction
process (6 to 17%). Therefore, the data was considered to be
qualitative, not quantitative, which renders the data inadequate
to make a health determination.
Because the presence of 2,3,7,8-TCDD was found, ATSDR and the
Arkansas Department of Health determined that a second exposure
investigation was necessary. The next El would resample the
environment and offer serum dioxin testing to each of the 4
residents. This message, along with a copy and explanation of
their individual results, was delivered to the residents in-
person by the ARDOH. Both households agreed to retesting.
CONCLUSION
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The quality of the analytical results for the environmental
samples was not precise enough to make a public health impact
determination. On a qualitative basis, the data revealed that
2, 3 , 7, 8-TCDD and other dioxins and furans are present in the
areas sampled.
Additional sampling is needed to better quantitate the potential
for adverse health impacts,
RECOMMENDATIONS
Hesample indoor surface dust, wipe, and surface soil to better
quantitate the concentrations of dioxins.
Offer serum dioxin testing to the occupants of these two homes,
Evaluated the results, when they become available.
Lynn C. Wilder, CIH
attachment
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I VERTACDU.PLN , " ' _ ; ''' ' Page
Indoor Dust Sampling Protocol
Exposure Investigation
Vertac NPL Site, Jacksonville, Arkansas
(CR# 6004)
Introduction
The Arkansas Department of Health (ADH), through a grant from ATSOR's Division of
Health Studies (DHS), conducted an exposure study in March 1991. This investigation
found elevated dioxin {2,3,7,8-TCDD) levels in blood lipid for the residents who had
been living within 1300 yards of the Vertac NPL site for 15 years or more. In March
1995, a second investigation of blood dioxin levels was conducted by ADH for the same ^
participants. It was reported that two individuals (from different families) had dioxin o
levels that had increased from their 1991 results. One participant's levels increased o
from 90 ppt to 103 ppt; the other participant's levels increased from 80 ppt to 126 ppt.
Dioxin levels for all other participants decreased from 1991 to 1995.
An ATSDR health assessor presented these results to the exposure investigation
section (EIS) on August 14,1996. The EIS, with concurrence from the ADH, agreed
that the situation met the criteria for an exposure investigation (EE). This El is being
conducted to determine if there is an indoor/residential source of dioxin (2,3,7,8-TCDD
and total dioxin equivalents (TEQ)) exposure present in the residences of the 2
participants whose dioxin levels were observed to have increased from 1991-1995.
Objective:
In an attempt to better characterize possible sources of exposure to dioxin
(2,3,7,8-TCDD and TEQ) in the home, this exposure investigation will:
1) assist in determining if dioxin is present in surface (0- to 3-inch depth) soils near
the main residential entryway (leading it to be tracked indoors),
2) determine if dioxin is present in indoor dust (floors), and
3) determine if dioxin is present on any hems in the home that may have been
brought from the Vertac facility.
This information will be useful to the residents and state and local health agencies in
determining if a possible source of dioxin exposure is present in the home. If one or
more sources are found, recommendations will be made to mitigate or stop exposures.
Initial Contacts:
The Arkansas Department of Health is scheduling the sampling with residents and
ATSDR.
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rage,
EIS has briefed DHS on our plans to sample (they are supportive of this effort). This El
should not interfere with other ongoing hearth investigation activities.
Target Areas:
The residences of the two individuals who were observed to have elevated dioxin levels
will be the focus of this El. Areas to be sampled include surface soil near the main
entryway; indoor dust (floor) sample from main entryway; indoor dust (floor) sample
from main living area; and a wipe sample of any materials once located at the Vertac
facility.
Consent Forms:
Prior to collecting any environmental samples, the resident/property owner will be —
asked to provide consent for access and sampling. They will be requested to sign a o
consent form (attached). o
Sample Collection:
Up to two surface (0-3") soil samples will be collected from each individual's yard: one
sample will be collected near the entryway used the most; based on professional
judgement, if another sample is needed, it will be collected from a high-use,
unvegetated area of the yard.
Two floor dust samples will be collected inside of each home. One sample will be
collected from the main entryway floor and another sample will be collected from the
main living area (or other area where the individual spends the bulk of their time). A
1 /4 square-meter template will be used to measure the area sampled. For each
sample, a composite of 4 adjacent template areas will be collected. Samples will be
collected using the "Cincinnati method" (low volume pump with cassette fitter). A
minimum of 10 grams of dust should be collected for analysis to allow a detection limit
of 1 ppt.
If the individual informs the sampling team that some of the materials in the home used
to be in the Vertac facility, then 2-3 wipe samples will be collected from these objects.
Sampling will focus on areas that are the most accessible to the residents. Wipe
samples will be collected using isopropyl alcohol wipes. A 1/4 square-meter template
will be used to measure the area sampled.
Sampling Handling and Storage:
Samples will be handled, stored, and shipped in accordance with applicable
Environmental Protection Agency (EPA) and Department of Transportation (DOT)
guidelines.
Chemical Analysis of Samples:
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Page:
Through an Interagency Agreement with Division of Federal Occupational Health,
samples will be analyzed for dioxins using EPA method 8290 (9/94). A 1 - to 2-month
turnaround time for analysis is expected.
QA/QC:
One trip blank will be sent with the samples
Calibration data
Matrix spike
Presentation of Results: S
o
o
Sample results from individual homes will be provided to the respective resident along o
with an interpretation of the information. Recommendations for followup actions will be
provided if contaminant levels are found above background.
An exposure investigation report will be provided to the ATSDR health assessor. DHS,
the ADH, and to the Regional Office for comment/followup activities.
Follow-up Activities:
Depending on the analytical results, follow-up activities may include:
-If contamination is found, recommendations will be made to reduce or eliminate
exposure. ADH will work with the residents to ensure that exposure is stopped.
-If contamination is found, the health assessor may request another El to offer serum
dioxin testing to the spouses and other occupants of the 2 residences investigated in
this El.
-If residential contamination is not found, a recommendation to investigate other
possible sources of exposure will be made.
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Paae
Sampling Protocol
Exposure Investigation II
Vertac NPL Site, Jacksonville, Arkansas
(CR# 6004}
Introduction
r-l
O
o
O
The Arkansas Department of Hearth (ADH), through a grant from ATSDR's Division of
Hearth Studies (DHS), conducted an exposure study in March 1991. This investigation
found elevated dioxin (2,3,7,8-TCDD) levels in blood lipid for the residents who had
been living within 1300 yards of the Vertac NPL she for 15 years or more, in March
1995, a second investigation of blood dioxin levels was conducted by ADH for the same
participants. It was reported that two individuals (from different families) had dioxin °
levels that had increased from their 1931 results. One participant's levels increased
from 90 ppt to 103 ppt; the other participant's levels increased from 80 ppt to 126 ppt
Dioxin levels for all other participants decreased from 1991 to 1995. The ATSDR
Division of Hearth Assessment and Consultation's Exposure Investigation Section
(EIS), with concurrence from the ADH, agreed that the situation met the criteria for an
exposure investigation (El). This El was conducted in October 1996 and involved the
collection of surface soil, indoor dust and wipe sampling for 2,3,7,8-TCDD and total
dioxin equivalents (TEQ)) in the residences of the 2 participants whose dioxin levels
were observed to have increased from 1991-1995.
Results of the initial El revealed the presence of 2,3,7,8-TCDD and other droxin/furans
in residential surface soil and indoor wipe/dust samples. However, analytical results
had significantly low percent recoveries for the contaminants. Conclusions from the
results were that 2,3,7,8-TCDD (up to 10 ppb in one sample) is present in the
environments sampled, but the results cannot be used to make a scientifically
defensible public health decision for the residents. The EIS and SSAB, with agreement
from the ADH, agreed that environmental sampling/testing should be repeated. In
addition, because the presence of 2,3,7,8-TCDD was confirmed in the El, it was agreed
that serum dioxin testing would be offered to the 4 residences of the two homes.
Objective:
Verify the levels of dioxin (2,3.7,8-TCDD and TEQ} in the homes/yards of the two
residences by resampling and testing. Determine if the occupants of these homes
have serum dioxin levels above the national average.
This information will be useful to the residents and state and local health agencies in
determining if a possible source of dioxin exposure is present in the home. If one or
more sources are found, recommendations will be made to mitigate or stop exposures.
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( V£RTAC2,PLN
Initial Contacts:
The Arkansas Department of Health is scheduling the sampling with residents, the
American Red Cross, and ATSDR.
EIS has briefed SSAB, and DHS on our plans to resample and offer serum d'toxin
testing (they are supportive of this effort). This El should not interfere with other
ongoing health assessment or investigation activities.
The ATSDR Regional Representative has informed EPA Region VI of our findings to
date and our plans to retest
TT
Target Areas: 3
§
The residences of the two individuals who were observed to have elevated serum °
dioxtn levels will be the focus of this El. Areas to be sampled are the same as in the
original exposure investigation (surface soil near the main entryway; indoor dust (floor)
sample from main entryway; indoor dust (floor) sample from main living area; and a
wipe sample of materials once located at the Vertac facility).
Occupants of these residents will be given the choice to have their blood tested to
determine if their serum dioxin level(s) is above the national average.
Consent Forms:
Prior to collecting any environmental samples, the resident/property owner will be
asked to provide consent for access and sampling. They wilt be requested to sign a
consent form (attached). If the residents accept the offer for serum dioxtn testing, they
wilt be requested to sign a separate consent form (attached).
Sample Collection:
Environmental samples wilt be collected in the same general areas as in the first El and
will Include surface soil, indoor floor dust, and indoor surface wipe samples.
The AOH is arranging to have a phfebotomist available to draw blood.
Sampling Handling and Storage:
Environmental samples will be handled, stored, and shipped in accordance with
applicable Environmental Protection Agency (EPA) guidelines. Biological samples will
be packaged, stored, and shipped according to CDC guidelines.
Chemical Analysts of Samples:
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Through an Interagency Agreement with Division of Federal Occupational Health,
samples will be analyzed for dioxin using EPA method 8290 (9/94). A 1-month
turnaround time for analysis is expected.
Blood serum samples will be analyzed for 2,3,7,B-TCDD and TEQ by the CDC's
Centers for Environmental Health (CEH) laboratory. A 2- to 3-week analytical
turnaround is expected.
QA/QC:
One trip blank will be sent with the environmental samples £
Calibration data o
Matrix spike o
Presentation of Results:
Sample results from individual homes and persons tested will be provided to the
respective resident along with an interpretation of the information. Recommendations
for follow-up actions will be provided if contaminant levels are found above
background.
An exposure investigation report will be provided to the ATSDR health assessor, DHS,
the ADH, and to the EPA Regional Office for comment/follow-up activities.
Follow-up Activities:
Depending on the analytical results, follow-up activities may include:
-If contamination is found, recommendations will be made to reduce or eliminate
exposure. ADH will work with the residents to ensure that exposure is stopped.
-If residential contamination is not found, a recommendation to investigate other
possible sources of exposure will be made.
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MORTH PULASKI DEADER, i MAR 98
oEPA
EPA ANNOUNCES AN EXPLANATION OF
SIGNIFICANT DIFFERENCES (ESDI IN THE REMEDY
FOR THE VERTAC SUPERFUNO 6(TE
JACKSONVILLE, ARKANSAS
The U- S. Environment ii Prouetmn Age*er ICMJ hH d«eonin«d that
• eignfflcint c-mnge it reoufred regarding mt caMcnd remedy for fh»
Sofli, Foundation!. «nd Underground uQCtfM, torOpenwe UottJ IOU2J
•f Hit V«rttC SJC*r*i*)d Srte in JtckMHMili. A/tanui. BMM on an
d«ermined tf>ei • change MM neeoed eince tht rgnin j Dl the September,
Th> ugnifictit (H1tl(»nc« i» tfi» loditJonai contolidtHon of dioxin-
cenumlnmd r«ud*nnil toll* from T*I« JKtianvUlc MttHMnttcl A/MI
SuMifund Si» kiRAStM. JicnonvUM. Aitmn. in tna OA-IIM itn*ra«ui
WTHM linafill ih« WM cannruciM *t p»n of OnnUe Umi 1 (OUi| for
ttt* V*fQC Site. Th« J)W SVtl » hX*tM IpprQiDnuMv 1.000 f*M ••»! of
in* v«n»c sri«, con«l«r:ng of four retUtnH»> prap4tttn n*ir ttit
IntwMCUOn of McAnhur toultwinl «nd Lot Stnrt. Tht JRA Sit* TCOO
(i»tf»CJilofa of. th« lot* 0fo«ln. At *
remit. t»* most orwdwii rtnwi<«J o* Mndtlng in* «Mi*i«p( wiA tnt ntndllng of IN* v«ruc Dart of OUi
rt>« ecfPo «i* eocjm*nt«:>on for tnt EPA1* modified remedy,
E.(X»n»;,oii of S;«nf :c*n:
•t ff • follDwing inform man rtpoMoriee:
review
JieuonviUc C ty H«it
• ' indunriai Or ve
.3CntOnvi(lt. AH 7207S
U.S. £»A. *)t«nni
TQ1 loot Rrnption Ar««
144S ROM / -nue
ArkifttM Depentrent of Pollution Control
4k Environment
1001 Netanw O':ve
k. Aft ~220»
O
O
O
O
The Administrative Hecora ::l« for the Wtrwc S'te.a recocooi »:i
inforneiion in si ii a*tng eiypdcred or rrtto on wf>en leieebng cne
f». t iv*iltOle *: inete
nftvnudon. p:«**t Conucr:
Cammumiy Aeuuom Coo'
UJ. EPA. Region •
IMS nutArenuc HSF-^O
0«im. TXTSwa-r>31
toil tree »( 1-MM33-35C6
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JactecrwiLle IttrirX ttodi 2, 1996
&EPA
EPA ANNOUNCES AN EXPLANATION OF
SIGNIFICANT DIFFERENCES (ESD) IN THE REMEDY
FOR THE VERTAC SUPERFUND SfTE
JACKSONVILLE. ARKANSAS
The U. S. Environmental Protection Agency (EPA) has determined ittM
• significant change is required regarding the selected remedy for the
Solli, Foundation!, and Underground Utilities, for Operetta Unit 2 (OU3I
at the Varuc Superfund Site in Jacksonville, Arkansas. Baaed on an
Exposure InvaitigMion (ED that was finalized on August 11,1997. the EPA
determined that • change was needed since the signing of the September.
1996 Record of Decision (ROD).
The significant difference is the additional consolidation ot diorin-
cantarninated residential soil* from ttie Jacksonville Residential Ames
Superfund Site I JRA Site). Jacksonville. Arkansas, in the on-site hazardous
waste landfill that was constructed as part of Operable Unit 1 (OU1I for
the Vertac Site. The JHA Site is located approximately 1.000 feet east of
the Vertsc Site, consisting of four residential properties near the
intersection of McAnhur Boulevard and Lee Street. The JRA Site TCDO
(tetrachlorodibanro-p-dioxin) soil contsminatian is extremely similar to
the type of contaminant encountered in the soil at Bis Vertac Sita, along
with the TCDO concentrations as a percentage of the total dioxin. As a
result, the most prudent method of handling the excavated soil from the
JRA Site is to oe consistent with the handling of the Vertac soil addressed
in OU2. The OU2 contaminated soil at the Vertac She is being consolidated
or 'entombed* in the Consolidation/Containment Unit or Resource
Conservation and Recovery Act IHCHA} Subtitle C compliant landfill, which
is a hazardous waste landfill (vault) that was constructed as part of OU1
at the Vertac Sita.
The complete documentation for the EPA's modified remedy, called an
Explanation of Significant Differences (E SO) is available for public review
at the following information repositories:
Jacksonville City Hall
»1 Industrial Drive
Jacksonville, AR 72075
U. S. EPA. Region 6
7th Floor Reception Area
1446 Rosa Avenue
Dallas. TX 75202-2733
Arkansas Department of Pollution Control
& Environment
8001 National Drive
Little Rock. AR 72209
VI
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The Administrative Record Rle, for the Vertac Site, a record of all
information that is being considered or relied on when selecting the
final remedy for the site, is available at these repositories.
If you na>v» »ny qumttions about trie Vmrtmc tit*, or nevcf tddition*!
n. p/ease contact
Donn Walters
Community Relation* Coordinator
U.S. EPA. Region •
1445 Rots Avenue (6SF-POI
Dallas. TX 76202-2733
toll free at 1-800-533-3508
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