United Stales
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R07-B8/019
September 1988
SEPA
Superfund
Record of Decision
Midwest Manufacturing, IA
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3027?-IOT
r
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/RO 7-88/019
2.
3, Recipient's Accession No.
4. Title and Subtitle
SUPERFUND RECORD OP DECISION
Midwest Manufacturing, IA
First Remedial Action
5, Report Date
09/30/88
6.
7. Author(j)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. ContraeMC) or Grant(G) No. ,
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Wasnington, D.C. 20460
13. Type of Report & Period Covered
300/000
14.
IS. Supplementary Notes
16. Abstract (Limit: 200 words)
Tne North Farm operable unit is one of two subsit.es of the Midwest Manufacturing site
and is located in a rural area approximately two miles north and one-half mile east of
Kellogg, Jasper County, Iowa. Approximately 600 people live in Kellogg. Land use near
the site is mainly agricultural, with pastfure land on and around the site. The closest
residence to the North Farm subsite is within one mile. The subsite consists of an
unlined disposal cell containing approximately 200 yd of soil contaminated with
ng wastes. The disposal cell is located on the lower slope of a rolling
adjacent to the valley of Bear Creek, which is an intermittent, stream located 500
feet east and 50 feet lower than tne site. Records indicate that electroplating
activities took place at this site until June 1981, when the facility ceased
operations. The start, date for activities at the site is unknown. Activities involved
the use of various heavy metals, including cadmium, nickel and zinc, as well as
cyanide. In 1977, a wastewater treatment plant, was installed at. the facility to treat
the plant effluent before it was discharged into the local river. Solids generated at
the treatment plant were temporarily stored in a tank onsit.e and periodically
transferred to the disposal cell. The disposal cell was unlined and had no soil cap,
leachate collection system or run-on and run-off controls. Soil sampling was conducted
(See Attacned Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Midwest. Manufacturing, IA
First Remedial Action
Contaminated Media: soil
' Cyanide
c. COSATI Held/Group
Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
60
22. Price
(See ANS1-Z39.18)
See Instructions on Reverie
OPTIONAL FORM 272 (4-77
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R07-88/019
idwest. Manufacturing, IA
irst Remedial Action
16. ABSTRACT {continued)
onsite and downslope of the site in 1982 and 1933 to evaluate the potential foe offsite
contaminant migration due to previous waste disposal practices. Analysis of the samples
revealed that soil contamination had occurred via surface run-off. The primary
contaminants of concern affecting the soil are cadmium and cyanide.
The selected remedial action for this operable unit includes: excavation of
contaminated soil within and around the disposal cell and either onsite or offsite
treatment using stabilization, with offsite disposal of the treated soil at a permitted
RCRA Subtitle C disposal facility; and backfilling and grading of the excavated area
with clean soil to support a vegetative cover. The estimated total present worth cos1"
for tnis remediation is $140,000 - $170,000. .The remedial action for the Midwest
Manufacturing operable unit of this site will be addressed in a subsequent- ROD,
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RECORD OF DECISION
DECLARATION
Midwest Manufacturing/North Farm Site
Kellogg, Iowa
Prepared By:
U.S. Environmental Protection Agency
Region VII
Kansas City, Kansas
September 1988
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Record of Decision
North ran Operable Unit
Declaration
SITE NAME AND LOCATIOJU
Midwest Manufacturing/North Farm Superfund Site. North Farm
Operable Unit; Kellogg, Iowa.
STATEMENT OF. BASIS AND PURPOSE
This decision document presents the selected remedial action
for the North Farm Operable Unit of the Midwest Manufacturing/
North Farm Superfund site located in Kellogg, Iowa. The response
action for the Midwest Plant site portion of the Midwest Manu-
facturing/North Farm Superfund site will be addressed in
another decision as a separate operable unit. This decision
document was developed in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA),
as amended by the Superfund Amendments Reauthorization Act (SARA)
of 1986 and, to the extent practicable, the National Contingency
Plan. The selection of the preferred remedial alternative is
based on the information contained in the Administrative Record
for this site. The attached index identifies the items that
comprise the Administrative Record. Also attached is a letter of
concurrence from the State of Iowa for the preferred remedial
alternative. A copy of this letter has been included in the
Administrative Record for this subsite..
DESCRIPTION OF SELECTED REMEDY
The North Farm Operable Unit is one of two subsites within
the Midwest'Manufacturing/North Farm Superfund site. This site
has been divided into two operable units; the North Farm site and
the Midwest Plant site. This decision document addresses the
contaminants located at the North Farm Operable Unit. A separate
decision document will address the contaminants at the Midwest
Plant site.
The selected remedy provides for the excavation of the
contaminated soil within and around the disposal cell which
contains cadmium concentration levels exceeding the health-based
action level of 13 milligrams/kilogram (mg/kg). The contaminated
soil will be treated using stabilization technology to achieve
levels in accordance with the Best Demonstrated Available
Technologies. The treated soils will be disposed in a RCRA
Subtitle C disposal facility. The excavated area will be
backfilled and graded, with clean soil to support a vegetative
cover.
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DECLARATION
Consistent with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980, as amended, I have
determined that the selected remedy described above, is cost-
effective, protective of human health and the environment and
utilizes permanent solutions and alternate treatment technologies
to the maximum extent practicable. The remedy selection procedure
of the selected remedial action complies with the provisions of
CERCLA and the National Contingency Plan, 40 CFR Section 300.
Kay
Regional Administrator
- 3 o -
Date
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RECORD OF DECISION
DECISION SUMARY
Midwest Manufacturing/North Farm Site
Kellogg, Iowa
Prepared By: ,
U.S. Environmental Protection Agency
Region VII
Kansas City, Kansas
September 1988
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TABLE OF CONTENTS
Section Page
I. Introduction 1
II. Site Name, Location and Description 1
III. Site History . 2
IV. Community Relations 3
V. Site Characteristics 4
VI. Summary of Site Risks 4
VII. Potentially Applicable or Relevant
and Appropriate Requirements 8
VIII.Description of Alternatives 9
IX. Summary of the Comparative Analysis
of Alternatives 12
X. The Selected Remedy 17
XI. Rationale for Preference 18
XII. Statutory Determination 18
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DECISION SUMMARY
MIDWEST MANUFACTURING/NORTH FARM SUPERFUND SITE
NORTH FARM BOBSITE
KELLOGG, IOWA
I. INTRODUCTION
The purpose of this document is to describe the remedy that the
U.S. Environmental Protection Agency (EPA) has selected to
implement at the North Farm subsite of the Midwest Manufacturing/
North Farm Site. This document also describes the decision-making
procedures that were followed in selecting the preferred remedial
action.
This remedial action has been selected to remedy an environmental
problem which could potentially affect the health of the
residents who may choose to livfi at the Site in the future. As it
is only part of the whole action, this is referred to as an
"operable unit" remedial action. Operable units must be
consistent with the final remedy for a site and must be cost-
effective with the site-wide remedy. In this instance, this is
the final remedy selection for the North Farm subsite.
The North Farm operable unit was combined with the Midwest Plant
site and proposed for the Superfund National Priorities List
(NPL) in September, 1985. The Site became final on the NPL in
May, 1986. The NPL is EPA's list of the top priority hazardous
waste sites that are eligible for Federal money under the
Superfund program.
II. SITE NAME, LOCATION AND DESCRIPTION
Approximately 600 people live in Kellogg, Iowa, which is located
in Jasper County, approximately 42 miles east of Des Moines (See
Figure 1). The North Farm subsite is located in a rural setting
approximately 2 miles north and 1/2 mile east of Kellogg. The
land usage near the Site is mainly agricultural with pasture land
on and around the Site. The closest residence to the North Farm
subsite is approximately 1 mile. The North Farm subsite consists
of an unlined disposal cell in which electroplating wastes were
disposed. The disposal cell contains approximately 200 cubic
yards of soil contaminated with electroplating wastes.
The disposal cell is located on the lower slope of a rolling hill
adjacent to the valley of Bear Creek. Bear, Creek is an
intermittent stream located 500 feet east of the site. The site
is approximately 50 feet higher than Bear Creek. Bear Creek
flows to the south-southwest of the site for approximately 2
miles and discharges into Coon Creek. Coon Creek continues to
flow south for approximately 1/2 mile and discharges into the
North Skunk River which runs south of Kellogg (See Figure 2).
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SITE LOCATION
The surveyed legal description of the North Farm subsite is as
follows: A parcel of land located in the south half of Section 12
and the North half of Section 13 all in Township 80 North, Range
18 West of the Fifth Principal Meridian, Jasper County, Iowa.
The North Farm subsite can more particularly be described as
follows:
Commencing at the Southwest Corner of Section 12, Township 80
North, Range 18 West of the Fifth Principal Meridian, Jasper
County, Iowa;
Thence on an assumed bearing of North 90 degrees 00' 00'' East,
2,637.99 Feet along the south line of said Section 12;
Thence South 01 degrees 00' 50''West, 2.78 Feet to the point of
beginning;
Thence North 83 degrees 29( 35'' East, 189.07 Feet;
Thence North 03 degrees 13' 16•' East 202.22 Feet;
Thence South 83 degrees 21' 40'' West, 196.99 Feet;
Thence South 01 degrees 00' 50'• West, 200.58 Feet to the point
of beginning containing .882 acres more or less.
III. SITE HISTORY
Smith Jones, owner of the Midwest plant subsite, is reported to
have engaged in electroplating special order stamped metal
pieces. This process involved the use of various heavy metals to
coat manufactured products. Cadmium was used prior to 1979,
nickel was used until 1980, and zinc was used from 1980 to 1981.
All electroplating operations ceased in June, 1981.
In 1977, a wastewater treatment plant was brought on-line to
prevent pollutants from being directly discharged into the North
Skunk River. The wastewater discharged from the plant was treated
with lime and permanganate to precipitate the heavy metals from
the waste stream. A polymer was then added to coagulate the
solids. The resulting solids were temporarily stored in a tank
from which they were periodically removed and placed into a
disposal cell.
From approximately 1977 to 1978, solids containing high
concentrations of cadmium, nickel and zinc were disposed into an
unlined cell located at the North Farm subsite. This unlined cell
has no soil cap to limit infiltration of water and does not have
a leachate collection system. It also lacks run-on and run-off
control or other engineering features which would contain or
prevent the release of hazardous substances.
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In 1982, soil sampling was conducted at the North Farm subsite by
Ecology and Environment (E&E) on behalf of the U.S. EPA. The
purpose of the soil sampling was to evaluate the potential for
contaminant migration resulting from previous waste disposal
practices. Three soil samples were collected from the locations
shown in Figure 3. The three samples were analyzed for particle
size distribution and cation exchange capacity (CEC). The CEC for
the three samples were 6.5, 11.7 and 10.2 milliequivalents per
100 grams of soil. Sand percentages in these samples were 34%,
32% and 23%. It was concluded by the USEPA that additional data
was deemed necessary to evaluate contaminant migration. In April
1983 the North Farm subsite was again investigated by E & E on
behalf of the U.S. EPA. Eight soil samples were collected
downslope from the disposal cell. A background sample was
collected approximately 200 yards west of the Site. The samples,
excluding the background sample, were composited from hand auger
cuttings taken from the surface depth of 4 feet. The samples
were analyzed for priority pollutant metals and pH. In general,
the metal concentrations detected north and east (downslope) of
the trench (sample numbers AQ2701, AQ2702 and AQ2707) were higher
than those detected in other sampling locations. It was
concluded that the higher concentrations in these samples
indicated that some soil contamination had occurred via surface
run-off.
ENFORCEMENT ACTIVITIES
The Special Notice procedure of Section 122(e)(l) of CERCLA was
followed regarding the Remedial Investigation/Feasibility Study
(RI/FS) phase of this project. No Potential Responsible Party
made a good faith offer to undertake or finance the RI/FS.
Consequently, EPA proceeded to initiate the RI/FS.
IV. COMMUNITY RELATIONS
An announcement was mailed to the parties listed in the community
relations plan. This announcement notified the parties of the
availability of the Administrative Record, Proposed Plan and
other pertinent documents used by the Agency to select the
preferred remedy. These parties were also informed that EPA would
request comments from the general public beginning September 8,
1988 until September 29, 1988 on all of the remedial alternatives
as set forth in the FS.
A public meeting was held on September 21, 1988 in Kellogg, Iowa
to receive comments from the public regarding all of the
remediation alternatives detailed in the FS report. A
responsiveness summary of the public's comments received during
the public comment period, including the public meeting, is
attached to this Record of Decision. The Administrative Record
for this Site has been available for public review at the Newton
Public Library in Newton, Iowa; the Kellogg Public Library in
Kellogg, Iowa; and the New Brotherhood Building in Kansas City,
Kansas. The administrative record includes all documents, such
as the Proposed Plan, the RI/FS reports and other relevant
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material considered in developing the remedial alternatives for
this site. All community relations activities have been in
conformance with the requirements of Section 117 of CERCLA and
the National Contingency Plan, 40 CFR Section 300.
V. SITE CHARACTERISTICS
In March 1988, EPA conducted a RI in order to identify the types,
quantities and locations of the contaminants in and around the
disposal cell. The results of the RI are summarized as follows:
1. Onsite surface soils are contaminated with various
levels of heavy metals such as calcium, cadmium and manganese.
2. The contaminated soil within the disposal cell
contains various levels of heavy metals such as cadmium, nickel,
zinc, sodium, cyanide and calcium. This material also failed the
EP Toxicity test for cadmium.
3. Approximately 200 cubic yards of contaminated soil
containing cadmium above the health based action level of 13
mg/kg established for cadmium are believed to be present at the
Site.
4. According to the Public Health Evaluation (PHE),
cadmium bioaccumulates in mammals, particularly in the kidney and
liver. Sub-chronic and chronic exposure to cadmium is associated
with a number of noncarcinogenic but toxic effects, including
kidney damage in humans and experimental animals. Non-
carcinogenic toxic effects may result from incidental
ingestion of soil, ground water or other media. The USEPA
considers cadmium a carcinogen only when inhaled.
5. The ground water beneath the site appears to be a
perched water table that has no hydraulic continuity with the
Bear Creek alluvium.
6. The contaminant concentration measured in the
ground water was at or near the action level of 18
micrograms/liter (ug/1) for cadmium and 7700 ug/1 for manganese.
Table numbers 1 through 4 present the type and concentration of the
hazardous substances detected in and around the disposal cell.
Also, Figure 4 presents the lateral and vertical extent of these
contaminants.
VI. SUMMARY OF SITE RISKS
As part of the RI report, a baseline Public Health Evaluation
(PHE) was conducted. This examination considers the potential
threat to human health and the environment in the absence of any
remedial action under both current and future use scenarios. It
provides the basis for determining if a remedial action is
necessary. Cadmium and manganese were identified as the
chemicals of concern for the ground water media. Cadmium and
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cyanide were identified as the chemicals of concern for the
contaminated soil media. The criteria for selecting the
chemicals of concern are as follows:
1. The degree of the toxicity and quantity of the
hazardous substance found in the contaminant migration media;
2. Environmental fate and transport mechanisms of the
chemical within the specific environmental media;
3. The potential human exposure pathways and the
extent of actual or expected exposure;
4. Population at risk;
5. Extent of expected harm and the likelihood of such
harm occurring; and
6. Acceptable levels of exposure based upon regulatory
and toxicological information.
Under current land use conditions no one is currently being
exposed to the contaminants of concern via the migration
pathways. Therefore, elevated health risks associated with
contaminant exposure are not present. However, under a future use
scenario, it is anticipated that the migration pathways, soil and
ground water, will be activated. The activation of these
migration pathways will serve to elevate the potential risks for
adverse health effects in local residents. The exposure scenarios
identified for future land use conditions are:
1. Ingestion of ground water;
2. Direct contact with surface soils; and
3. Ingestion of vegetables grown in contaminated soil.
The major conclusions of the PHE are as follows:
1. It is unlikely that the direct contact with
contaminated soils by future on-site residents would lead to
adverse health effects.
2. Cadmium will leach from the waste material when
subjected to the EP Toxicity test. As cadmium leaches from the
waste material it will deposit itself into the ground water. The
likelihood of future residents installing a drinking water well
at the site is low. This is because the expected yield from the
well would be from 0 gpm to 1 gpm which is an insufficient amount
to support residential needs. However, if such a scenario were to
occur, then under a maximum exposure scenario, individuals who
would drink this water may experience adverse health effects.
3. Under plausible maximum conditions, adverse health
conditions could result for future residents if they ingested
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vegetables grown on the contaminated soil at the site.
Table 5 presents the contaminants of concern including their
concentration level and health based action level per exposure
pathway. The health based action level is the contaminant
concentration level above which adverse health effects may be
experienced by persons exposed to the contaminant.
RISK CHARACTERIZATION
Health-based action levels were developed for each of the
contaminants of concern via each exposure pathway. These action
levels were developed using the procedures outlined in "The
Superfund Public Health Evaluation Manual", OSWER Directive
Number 9285.4-1, October, 1986 and " The Superfund Exposure
Assessment Manual", OSWER Directive Number 9285.5-1, October,
1987. Based upon this data in conjunction with the standards of
other pertinent Federal and State environmental laws, appropriate
response actions can be developed per migration pathway. Results
of the RI and PHE discussion indicate that no response action for
ground water would be necessary in order to protect the public
health and the environment. Also, the RI data and the FS
established an action level of 13 mg/kg for cadmium in the soil.
The following discussion presents the basis for these
conclusions.
GROUND WATER
As is shown on Table 5, an action level of 7700 ug/1
was developed for manganese. This value is 5600 ug/1
greater than the highest concentration level measured at the
Site. Also, manganese received a Hazard Index score which was
less than 1. A Hazard Index score of less than 1 indicates that
the contaminant does not pose a health risk at its present
concentration level. Finally, Table 6 presents the ground
water quality criteria developed under other Federal
environmental laws. The only criteria exceeded by manganese is
the Maximum Contaminant Level (MCL) standard developed under the
Safe Drinking Water Act. However, this MCL represents a secondary
standard which is established for aesthetic quality only. Adverse
health effects in humans would not be expected if this standard
is exceeded. Therefore, it is believed that manganese does not
represent a potential human health threat at its current
concentration level.
It is determined that no action needs be taken to protect ground
water with respect to cadmium. This decision is based on the
following factors. Cadmium received a hazard index score equal to
one, which indicates that it represents a marginal risk to humans
who may ingest cadmium contaminated water. As is shown in Table
6, the action level for cadmium is 18 ug/1. This, in turn, is 1
ug/1 less than the highest total concentration level found at the
Site. It is not considered that this differential is significant,
in view of the fact that this level was attained only in one
sample, while the balance of the samples were significantly
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lower.
In addition, the sample which exceeded the 18 ug/1 action level
was not filtered prior to analysis, so that the analytical
results represent the total cadmium present in the ground water.
None of the filtered samples, which represent the dissolved
cadmium concentration in the ground water, exceeded the action
level. It is believed that the filtered sample provides a better
model of drinking water. Monitoring wells, are typically of a
different type of construction than wells constructed for
drinking water. Consequently, monitoring wells usually produce a
greater amount of sediment mixed with the water than is the case
for a drinking water wells. Contaminants have a tendency to
attach themselves to the sediment. This causes the contaminant
concentration measured in an unfiltered (total) sample to be
greater than that of a filtered sample. Therefore, the unfiltered
contaminant concentration measured in a drinking water well would
be similar to that measured in a filtered sample collected from a
monitoring well. Cadmium, therefore, would not represent a
potential human health threat at its current concentration level.
Finally, the water beneath the Site has been identified in
Section 3.1 of the RI as being a perched water table. Such a unit
is expected to be recharged only from precipitation, and would
not be hydraulically connected to the Bear Creek alluvium. In
addition, a drinking water well located in this water table would
only produce from 0 to 1 gallons per minute (gpm). This amount
is significantly below most residential needs. Therefore, it is
unlikely that such a drinking water well would be installed in
this water table. Furthermore, at the present .time, there are no
known users of this ground water. Based upon the low yield, the
likelihood that the unit would never be used for any purpose, the
low potential for human health risks, a ground water response
action is unnecessary.
SOIL
A health-based action level of 13 mg/kg was established for
cadmium present in the soil. This action level represents the
concentration of cadmium that could be left in the soil at the
North Farm subsite without presenting adverse risks to human
health. The following soil exposure pathways were evaluated: 1}
ingestion of contaminated soil 2) dermal contact with the
contaminated soil and 3) the root uptake of cadmium by vegetables
and subsequent ingestion of these vegetables. Action levels were
developed for each of these exposure pathways. The action level
developed for the ingestion of vegetables grown on contaminated
soil was found to be the .most conservative. Thus, the health
based action level for cadmium present in the soil at the North
Farm subsite is 13 mg/kg. Section 2 and Appendix A of the
Feasibility Study Report contain a more detailed discussion of
how this action level was developed.
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VII. POTENTIALLY APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS
Section 121(d) of CERCLA provides that the remedial action
selected must require, at the completion of the remedial action,
a level or standard of control which at least attains the legally
applicable or relevant and appropriate standards, requirements,
criteria, or limitations of any Federal environmental laws or any
more stringent State environmental or facility siting laws. A
variety of Federal environmental laws were reviewed as to legal
applicability or relevance and appropriateness to the remedial
alternatives under consideration at this Site. These laws
included the Toxics Substances Control Act, the Safe Drinking
Water Act, the Clean Air Act, the Clean Water Act, and the Solid
Waste Disposal Act. Of these Federal environmental laws, only
the Resource Conservation and Recovery Act (RCRA), as amended,
and Hazardous and Solid Haste Amendments (HSWA) of 1984, which
are parts of the Solid Waste Disposal Act, were found to be
potentially applicable or relevant and appropriate to these
remedial alternatives. Review of various State environmental
laws and regulations, including those pertaining to solid and
hazardous waste management, indicate that the Federal
environmental laws are at least as or are more stringent than
State Law.
The RCRA, as amended by HSWA of 1984, regulates the generation,
transportation, treatment, storage and disposal of defined
hazardous waste. Hazardous wastes are defined in 40 CFR Part 261
in two basic ways, which are 1) by the characteristics of the
waste and 2) by specific listing of the waste as a hazardous
waste. The waste at the North Farm subsite could be classified
as RCRA hazardous waste both on the basis of its characteristics,
in that it failed the EP Toxicity Test for cadmium, and as a
listed hazardous waste, in that the wastes present at the Site
are wastewater treatment sludges from electroplating operations
(F006). Since the wastes were deposited at the site prior to the
effective date of these regulations, the RCRA hazardous waste
regulatory requirements would not be applicable if the wastes are
left undisturbed at the Site. However, if some action is taken
which amounts to generation of hazardous waste, such as
excavation of the waste under Alternatives 4 and 5, RCRA's
regulatory requirements would be applicable. Furthermore, even
though they are not legally applicable to the response action,
various aspects of the RCRA hazardous waste management
requirements may be relevant, and appropriate to the response
action.
The principle components of RCRA's hazardous waste management
regulations which might be applicable or relevant and appropriate
to the response alternatives considered at this site are as
follows:
A. RCRA Landfill Closure Standards The RCRA hazardous
waste management program requires that, upon closure, hazardous
waste management facilities be closed in a manner that (1)
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minimizes the need for further maintenance and controls; (2)
minimizes or eliminates, to the extent necessary to protect human
health and the environment, post-closure escape of contaminants
to the ground or surface waters or the atmosphere, and (3)
complies with specific closure and post-closure requirements.
Closure and post-closure requirements for landfills include (1)
covering the.landfill with a final covering which meets certain
requirements; (2) long-term maintenance of the cover; (3) and
long-term ground water monitoring. Corrective action may be
required if the water contaminant levels exceed a health-based
action level. Land use and deed restrictions may be placed on
the property for an indefinite period of time.
If the contaminant concentrations remaining at the site upon
closure are below health based action levels, long-term operation
and maintenance, ground water monitoring, and access or deed
restrictions may not be required under this option.
BJ RCRA Minimum Technology Requirements (MTRs) The RCRA
hazardous waste management regulations also impose specific
requirements on new hazardous waste management facilities, new
units at existing facilities, and on replacements of existing
units. These requirements would include installation of double
liners and a leachate collection system.
C. RCRA Land Ban Disposal Regulations (LBDRs). The
Hazardous and Solid Waste Act of 1984 amended RCRA to impose
restrictions on the land disposal of hazardous wastes. For
purposes of these land disposal regulations, land disposal is
defined as "any placement of such hazardous wastes in a landfill,
surface impoundment, ... ." EPA has promulgated regulations
establishing the conditions under which certain listed hazardous
wastes, including F006 listed wastes, could continue to be land
disposed after August 8, 1988. These conditions include
treatment of the wastes to levels achievable by the Best
Demonstrated Available Technologies(BOAT). For F006
nonwastewaters, the identified BDAT is stabilization to
immobilize the constituents. The BDAT treatment standard is
expressed as constituent concentration levels in a Toxicity
Characteristic Leaching Procedure (TCLP) extract to reflect
whether immobilization has been optimized. The BDAT treatment
standard for F006 nonwastewaters is as follows:
Constituent Treatment Standard
Cadmium .066 milligrams/liter(mg/1)
Total Chromium 5.2 mg/1
Lead .51 mg/1
Nickel .32 mg/1
Silver .072 mg/1
VIII.DESCRIPTION OP ALTERNATIVES
During the FS, five remedial alternatives were developed based
upon screening technologies from three major categories:
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biological, chemical and physical treatment. Four process
options were identified as being able to attain the clean up
standards specified in the potential Applicable or Relevant and
Appropriate Requirements (ARAB) section of the FS report. These
process options were used to develop the remedial alternatives
which are described in detail in the FS. Each of these five
alternatives is summarized below.
Alternative «1: Kfi Action
Under this alternative, no specific action would be taken to
control the migration of the contaminants at the site.
Institutional controls, such as deed and access restrictions,
would be implemented and are included in the evaluation of this
alternative. The "no action" alternative is considered as part
of the remedial action evaluation at every Superfund site. This
alternative acts as a baseline in the risk assessment analysis in
evaluating the potential threat to human health in the absence of
any remedial action. The "no action" alternative is considered
to be appropriate only when there is no increased risk to human
health or the environment as a result of past waste management
activities.
Alternative 12; RCRA Cap vith Ground Water Monitoring
Under Alternative 2, a cap meeting the RCRA closure requirements,
40 CFR Part 264 Subparts G and N, would be placed over the
surface of the disposal cell. The purpose of the cap is both to
minimize infiltration of surface waters through the wastes and to
minimize potential for direct contact with the wastes.
Because the waste was placed in the disposal cell prior to the
effective date of the regulations defining the waste as a RCRA
hazardous waste (November 19, 1980) and the waste is not being
disturbed, the RCRA closure requirements are not legally
applicable to this remedial alternative. However, they are
considered to be relevant and appropriate requirements for this
alternative. Therefore, in addition to the RCRA cap, this
alternative would include periodic ground water monitoring to
provide information on ground water quality. Institutional
controls, including access and deed restrictions, would be
utilized for an indefinite period of time. Although not
specifically a part of 'this option, corrective action may be
necessary in the future if the contaminant levels in the ground
water exceed appropriate action levels.
Alternative 4 a Soil Cap vith Ground Water Monitoring
This alternative is similar to Alternative 2 except that a five-
foot thick soil cap would be placed over the disposal cell rather
than a RCRA cap. The soil cap would serve the same purpose as
the RCRA cap in reducing infiltration of surface waters and
minimizing potential direct contact with the wastes. A five-foot
thickness was selected for this alternative on the basis of the
freeze-thaw cycles in the locale of the Site. This alternative
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also includes ground water monitoring and the use of access and
deed restrictions for an indefinite period of time. As with
Alternative 2, future corrective action is a possibility if
contaminant levels increase in the ground water, but is not a
specific part of this alternative.
As discussed above for Alternative 2, while not legally
applicable to this remedial alternative, the RCRA Landfill
Closure Standards are considered to be relevant and appropriate
requirements for remediation scenarios relying solely on capping
technology to contain the hazardous substances. To the extent
the soil cap does not satisfy the RCRA closure requirements, this
alternative would not comply with identified relevant and
appropriate requirements as identified by the Agency.
Alternative 4 4: Excavation. Solidification and Redisposal of
Existing ff»™t*»
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placed on the property for an indefinite period of time.
Corrective action, which may also be necessary in the future if
contaminant levels in the ground water exceed an appropriate
action level, is not specifically a part of this remedial
alternative.
Alternative 5t Excavation, SoIJLdificatiOB. and Offsite Disposal
of contaminated Materials
This alternative provides for the excavation of the contaminated
soil within and around the disposal cell which contains cadmium
concentration exceeding a health-based action level of 13 mg/kg.
As with Alternative 4, above, it is estimated that 200 cubic
yards of contaminated soil would be excavated under this
alternative. The excavated soil will be treated to achieve the
BOAT standard using stabilization technology and transported off-
site for disposal in a RCRA regulated facility. The treatment
process may be conducted either on- or off-site. The excavated
area would be backfilled and graded with clean soil to support a
vegetative cover.
This alternative represents RCRA's Landfill Clean Closure Option
as defined in 40 CFR Part 264, Subpart N. A leachate collection
system would not be installed prior to backfilling the disposal
cell with clean soil and a RCRA cap would not be placed over the
disposal cell. No post-closure care, such as long term ground
water monitoring and access or deed restrictions would be
required.
IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 121 (b)(1) of CERCLA provides that the President shall
select a "remedial action that is protective of human health and
the environment.... and utilizes permanent solutions....to the
maximum extent practicable." Section 121 fb)(1) further provides
that remedial actions which include treatment measures to
permanently and significantly reduce the mobility of the
hazardous substances, pollutants, and contaminants are preferred
over remedial actions which do not include such treatment
measures. Section 121(b)(2) provides that a remedial action which.
meets these criteria may be selected whether or not such remedial
action has been achieved in practice at any other facility or
site that has similar characteristics. Thus, each of the
alternatives listed in section 7 of this document was evaluated
using the criteria listed below. Table 4 summarizes the
evaluation criteria versus the proposed remedial alternatives.
1. PROTECTION QF. HUMAN HEALTH AND THE ENVIRONMENT
Protection of human health and the environment pertains to how
risks are eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls. All of the
alternatives evaluated in the FS would provide some degree of
protection to the public health and the environment. However,
the degree of protection and permanence of the protectiveness
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13
vary between the alternatives.
The "No Action" alternative is considered as part of the remedial
action at every Superfund site. It serves as a baseline in the
risk assessment analysis in evaluating the potential threat to
human health in the absence of any remedial action. This
alternative would rely upon institutional controls, such as deed
and access restrictions, to minimize human contact with the
contaminants. However, no affirmative steps would be taken to
prevent such contact or to reduce the migration of contaminants
off-site.
Alternatives 2 and 3 would provide a a greater degree of
protection to the human health and the environment by taking
affirmative action to reduce the potential for contact with the
contaminated soils and reducing migration of contaminants by
minimizing surface water infiltration through the wastes. Over
the long term, the degree of protection to human heath and the
environment would depend largely on the quality of maintenance
provided for the cap.
Alternative 4, by providing treatment to reduce the mobility of
the contaminants and other affirmative controls, would provide a
higher degree of protection than would alternatives 1, 2, or 3,
which also involve leaving contaminants on-site above the 13
mg/kg health-based action level for cadmium. Long-term ground
water monitoring and maintenance would be necessary to maintain
the reliability of this alternative.
The excavation and off-site disposal of the contaminated soil
under Alternative 5 would provide the highest degree of
protection for human health in that all contaminants in the soil
above health-based standards would be removed from the site.
2. COMPLIANCE WITH APPLICABLE QE RELEVANT AND APPROPRIATE
REQUIREMENTS
Alternatives 2, 4, and 5 would achieve all applicable or relevant
and appropriate requirements, whereas alternatives 1 and 3 would
not.
3. REDUCTION OF TOXICITY. MOBILITY OR VOLUME
Section 121(b) of CERCLA states that remedial actions involving
treatment, which permanently and significantly reduce the volume,
mobility or toxicity of hazardous materials, are to be preferred
over those not involving such treatment. This evaluation criteria
relates to the ability of a remedial alternative to control or
eliminate risks caused by the mobility, toxicity or volume of a
hazardous waste.
Alternative number 1 would have no direct impact on the toxicity,
volume or mobility of the hazardous substances at the North Farm
subsite. Alternatives number 2 and 3 propose to rely solely on
capping technology to contain the hazardous substances at the
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Site. The capping of the waste would do nothing to reduce the
toxicity, or volume of the hazardous substances since
contaminants would remain at their current levels. However, the
mobility of the contaminants would be minimized by the reducing
the flow of ground water flow through the waste, but the leaching
of the contaminants into the ground water would continue.
However, this would be at a reduced rate compared to what would
be expected under the "No Action" scenario. The amount of water
that would filter through the wastes would be a function of the
cap's integrity. As the cap erodes with time, the amount of
water flowing through the the cap which could generate leachate
will increase. Thus, the potential for ground water contamination
will increase. The RCRA cap would provide a greater degree of
protection against the infiltration of the water through the
waste than what could be expected from the soil cap.
Alternative number 4 would use stabilization treatment technology
to reduce the mobility of cadmium in the soil. This alternative
proposes using stabilization technology in conjuntion with a RCRA
cap, liner and leachate collection system. This alternative would
do nothing to reduce the toxicity or volume of the hazardous
substances at the Site. However, it would provide the greatest
degree of protection against contaminant migration when compared
to the other alternatives which proposed on site waste
management. Also, stabilization technology has been identified as
the BOAT for treating wastewater sludges generated from
electroplating operations (see the Land Ban Disposal Regulations
of August 8, 1988). Assuming current site conditions do not
change apreciably, stabilization can be expected to be a long-
term solution in retarding the mobility of the contaminants.
Alternative number 5 proposes to use stabilization treatment
technology to reduce the mobility of the contaminants. This
treatment technology will not reduce the toxicity or volume of
this waste. However,this is not a critical factor for this
Alternative since the waste is being transported off-site for
disposal.
4. SHORT-TERM EFFECTIVENESS
Short-term effectiveness involves the period of time needed to
achieve protection and any adverse impacts on human health and
the environment that may be posed during the construction and
implementation period until clean up goals are achieved.
Of the Alternatives evaluated, in-place containment of the
contaminated soils, as proposed in alternatives number 2 and 3
would provide the highest degree of short-term protection. Short-
term protection is high because the implementation of in place
containment does not involve excavation or other soil disturbing
activities which could potentially affect site workers. Also,
short term risks would remain at current levels for Alternative
1 since no soil disturbing activities would occur.
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15
Alternatives involving excavation and subsequent treatment of the
contaminated soils, as proposed in Alternatives 4 and 5, would
provide increased opportunity for exposure to contaminants by
site workers. Worker exposure could potentially occur through
direct contact, ingestion or inhalation of contaminated soil
particles. Since this Site is in a rural setting, the surrounding
community would be at too great a distance to be affected by
airborne contaminants. Measures could be implemented which would
eliminate the potential for worker exposure during soil
disturbing and handling activities. These measures include use of
protective clothing, appropriate breathing apparatus and
effective dust control.
5. LONG-TERM EFFECTIVENESS AND PERMANENCE
Long-term effectiveness and permanence refers to the ability of a
remedy to maintain reliable protection of human health and the
environment over time once clean up goals have been met.
Alternative 1 is not a permanent remedy. It would not be
effective over the long-term in. protecting public health. Under
this alternative, the contaminants would not be inhibited from
leaching into the ground water and migrating from the Site.
Finally, this alternative would not prevent human exposure via
direct contact.
The use of capping technology as proposed in Alternatives 2 and
3 would serve to minimize the risk of human exposure via direct
contact. However, the degree of effectiveness in protecting
humans from exposure is a function of the cap's integrity.
Overtime both the RCRA cap and the soil cap will erode. As the
cap erodes, the degree of protectiveness will continue to
decline. Also, as the cap erodes the amount of water able to
filter through the waste will increase. This will cause leachate
to be generated which will increase the potential for the
contaminants to migrate into the ground water. Furthermore, a cap
will require long-term maintainence and portions of it will need
to be replaced in the future. A soil cap is not expected to last
as long as the RCRA cap. Thus, the degree, of protectivesness
afforded by a soil cap is not as great as that of a RCRA cap.
Finally, the use of access restrictions as is proposed in both
Alternatives 2 and 3 will minimize the likelihood of the .cap from
being disturbed.
The stabilization of the contaminated soil in conjunction with a
RCRA cap, a liner and a leachate collection system as proposed in
Alternative 4, will provide the highest degree of protectiveness
and reliability when compared to Alternative 1, 2 or 3 . The use
of a RCRA cap in conjunction with stabilization treatment will
significantly reduce the liklihood for ground water contam-
ination. If water should filter through the cap, then the
stabilized waste should inhibit the generation of the leachate.
The use of stabilization treatment will also significantly reduce
the potential for the contaminants to migrate from the Site.
Furthermore, the use of a RCRA cap will minimze the threat to the
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human health via direct contact. Finally, assuming current Site
conditions do not change appreciably, stabilization technology
evaluated by itself, can be expected to be a long-term solution
with a high degree of permanence.
Alternative 5 would provide the highest degree of protectiveness
and reliability of all of the remedies evaluated in the
Feasibility Study Report. This is the only Alternative that would
completely eliminate all short or long-term risks to the public
health or the environment. Also, post-closure care such as future
corrective action, long-term ground water monitoring or access
and deed restrictions would be unnecessary under this alternative.
6. IMPT-'PMENTABILITY
Implementation addresses the technical and administrative
feasibility of a remedy, including the availability of materials
and services needed to implement the chosen solution.
The implementation criterion does not apply to the no action
alternative since no" remedial measures would be taken.
The implementability of in-place containment as is proposed in
Alternatives 2 and 3 is affected by technical considerations such
as availability of suitable cover materials (rock, clay, soil and
seed for acclimated vegetation). The remedial design would take
site characteristics into account when developing the cap
blueprint. Both of these Alternatives propose using technologies
which could be readily implemented at the Site.
Both Alternatives 4 and 5 have proposed the use of stabilization
technology to treat the contaminated soil. Stabilization
technology has been identified in the Land Ban Disposal
Regulations of August 8, 1988, as being the BOAT for the
treatment of wastewater sludges generated from electroplating
operations. Since this is a proven technology, no technical
difficulties are expected regarding its implementation. Also,
firms which maintain the equipment and the skilled workers needed
to implement this technology are available in the greater Des
Moines area. Some difficulty may-be encountered in locating a
RCRA Subtitle C Landfill operator to accept the treated waste as
is proposed in Alternative 5. No other administrative
difficulties are expected regarding the implementation of this
technology.
7. COST
CERCLA requires that the EPA select a cost-effective (not merely
the lowest cost) alternative that protects human health and the
environment and meets other requirements of the law. Alternative
2, 3 and 4 all have an initial capital cost which is lower than
that for Alternative 5. However, the overall cost of each of
these Alternatives, including long-term operation and maintenance
and ground water monitoring, is at a level similar to that of
Alternative 5. Furthermore, since contaminants would be left on-
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site, for Alternatives 2, 3, and 4, future corrective action is a
possibility, which could increase the cost of each alternative
above that for Alternative 5.
The 30-year present worth costs of each alternative is presented
in Table 7.
8. COMMUNITY ACCEPTANCE
This evaluation criteria addresses the concerns of the public
regarding acceptance of a particular remedy.
The comments received indicate that the public is concerned about
the costs of the proposed remedial Alternatives and who will pay
these costs. In addition, the comments presented at the public
meeting held on September 21, 1988 indicated that the public did
not perceive the Site as presenting any significant threat to the
public health or the environemnt.
9. STATE ACCEPTANCE
The state acceptance criteria indicates whether, based on its
review of the RI/FS and Proposed Plan, the State concurs with,
opposes, or has no comment on the preferred alternative.
The State of Iowa informed the Agency in a letter dated August 8,
1988 that it agreed with the EPA's selection of the preferred
remedy for the North Farm subsite.
X. THE SELECTED REMEDY
Based on the information available to evaluate the remedial
options against the previously described criteria, Alternative 5
is selected as the preferred remedy for the North Farm subsite.
This Alternative provides for the excavation of the contaminated
soil within and around the disposal cell which contains cadmium
concentration levels exceeding a health based action level of 13
mg/kg. The development of this number is discussed in Section 2.3
of the FS Study report and Section 6 of this document.
Approximately 200 cubic yards of contaminated soil above the
health-based action level of 13 mg/kg established for cadmium are
believed to be present at the Site. The excavated soil will be
treated using stabilization technology and stabilized to the
extent that the leachate contaminant concentration, as measured
using the Toxicity Characteristics Leaching Procedure, meets the
standards specified in the Land Ban Disposal Regulations of
August 8, 1988 for F006 nonwastewaters. These treatment
standards are as follows:
Constituent Treatment Standard
Cadmium .066 mg/1
Total Chromium 5.2 mg/1
Lead .51 mg/1
Nickel .32 mg/1
Silver .072 mg/1
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Subsequent to treatment, the excavated soil would be disposed
into a permitted RCRA Subtitle C disposal facility. The treatment
process will be conducted either on or off-site. The excavated
area would be backfilled and graded with clean soil to support a
vegetative cover. This Alternative represents RCRA's Landfill
Clean Closure Option as defined in 40 CFR Part 264, Subpart N.
These provisions under RCRA provide that post-closure care such
as future corrective action, long-term ground water monitoring or
land and deed restrictions are unnecessary.
XI. RATIONALE IXDR PREFERENCE
The selected remdedy is preferred over the other Alternatives
because it provides the highest degree of protectiveness at a
cost only moderately higher than the other Alternatives. This is
the only Alternative evaluated that would completely eliminate
all short and long-term risks to the public health and the
environment. Furthermore, this is the only Alternative that would
eliminate the need for post-closure care such as ground water
monitoring, or land and deed use restrictions. Also, this is the
only Alternative evaluated that would eliminate the possibility
for future corrective action. Finally, this is the only
Alternative evaluated that provides a permanent solution to the
contaminant problem at the Site.
The remedy selected for implementation at the North Farm subsite is
consistent with CERCLA, as amended by SARA and the National
Contingency Plan? 40 CFR Part 300.
XII. STATUTORY DETERMINATION
Based upon the available information, the selected remedy
satisfies the remedy selection requirements under CERCLA, as
amended and the National Contingency Plan. The selected remedy at
the Site is protective of public health and the environement,
satisfied all applicable or relevant and appropriate
environmental requirements and is cost effective. The Public
Health Evaluation analysis has determined that treating soils
within and around the disposal cell which contain cadmium
concentration levels exceeding a health based action level of the
13 mg/kg will adequately protect the public health for
unrestricted use.
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GLOSSARY 0? TERMS
- Applicable or Relevant and Appropriate Requirements refers
to to the Federal and State requirements that a remedy selected
by EPA must attain. These requirements may vary from site to
site.
Ground Water - Underground water that fills pores in soils or
opening in rocks to the point of saturation. Groundwater is often
used as a source of drinking water for municipal or domestic
wells.
L«ach*t« - A liquid that has passed through wastes and contains
some components of these wastes.
Solidification - A process used to reduce the mobility of liquid
contaminants by mixing it with a material such as cement kiln dust
in order to increase the ability to handle the waste and make the
substance less likely to leach.
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COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
MIDWEST MANUFACTURING/NORTH FARM SUPERPUND SITE
NORTH FARM SUBSITE
KELLOGG, IOWA
This Responsiveness Summary presents the responses of the
United States Environmental Protection Agency (EPA) to the
comments received during the public comment period conducted as
part of the remedy selection process for the North Farm subsite
of the Midwest Manufacturing/North Farm Superfund site.
INTRODUCTION
On September 8, 1988, EPA announced the availability of its
Proposed Plan for the remedial action at the North Farm subsite
of the Midwest Manufacturing/North Farm Superfund site. Notice
of the availability of the.proposed plan and the administrative
record upon which EPA intended to base its remedy selection
decision was mailed to persons who had previously expressed an
interest in this site and published in the Newton Daily News.
This notice also requested the public's comments on the proposed
plan and indicated the period during which public comments
received by EPA would be considered in the decision-making
process. A fact sheet in which the various remedial alternatives
were described, including identification of a preferred
alternative, was mailed with the notice.
A public meeting was held in Kellogg, Iowa, on September 21,
1988, to receive comments. Copies of the proposed plan and fact
sheet were made available to persons attending the public
meeting. A transcript was made of the public meeting. That
transcript was consulted in preparation of this responsiveness
summary. Copies of the transcript are available with the
administrative records for public review.
PUBLIC COMMENTS
The comments received in on the Proposed Plan and EPA's
response to these comments are set forth below.
The EPA received a number of comments relating to the cost
of the remedial action alternatives considered for the Site.
These comments generally fell into the following categories.
1. Is the proposed remedial action cost-effective or are
there other remedial alternatives which might provide a more
cost-effective remedial action at the aite?
CERCLA requires the EPA select a cost-effective alternative
(not merely that alternative having the lowest cost) which
protects the human health and the environment, and meets the
other requirements of the law. Alternatives 2, 3, and 4 all have
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an initial captial cost which is -lower than that for Alternative
5. However, the overall cost of each of these alternatives,
including long-term operation and maintenance and ground water
monitoring, is at a level similar to that of Alternative 5.
Furthermore, since contaminants would be left on Site, for
Alternatives 2, 3 and 4, future corrective action is a
possibility which could increase the cost of each alternative
above that for Alternative 5.
2. BOM persons questioned the manner In which the cost
estimates presented in the proposed plan ware calculated, i.e.,
vhat coats are included in tha estimates, vere costs calculated
on a site-specific basis or using national averages, and what is
tha potential rang* of tha actual cost to implement the
alternatives?
Cost projections were prepared on a site-specific basis for
each alternative and are based on capital costs and operation and
maintenance costs. The costs for operation and maintenance are
based on 1988 dollars and projected for a period of 30 years..
The costs as presented at the public meeting were for actual'
cleanup costs and did not include costs for the Remedial
Investigation/Feasibility Study. The actual Site cleanup costs
may range from -30% to +50% variance between the cost estimates
presented at the public meeting and the actual costs which would
be incurred.
3. A number of comments were received regarding the issue
of who pays for cleanup, including does EPA take into
consideration who will pay for the remedy in selecting a remedial
alternative, can EPA consider the economic impact on the
responsible parties or the community as a whole if EPA seeks to
have the responsible parties fund the response action, and can
Superfund pay for the sita cleanup costs without seeking
cost recovery from the responsible parties if those parties
cannot afford to pay for the remedial costs and can EPA hold
parties liable even though their disposal of hazardous waste
was proper, lawful, or specifically authorized by a regulatory
agency at the time?.
While the cost effectiveness of the remedial action is a
factor considered in the remedy selection process, except for
questions of fund-balancing, i.e.. in circumstances where the
Superfund does not have sufficient monies available to fund a
response action, the selection of the remedy does not consider
who will pay for the remedy. Since we are not presently in a
fund balancing situation, the question of who pays for the remedy
is not a deciding factor in the remedy selection process.
Even though the question of who pays for the remedy is not a
deciding factor in the remedy selection process, the number and
nature of the comments made on this subject indicates that it is
the key concern of the public. Therefore, some further
explanation of EPA's general policies and practices with regard
to use of the Superfund and cost recovery seem in order. The
general policy of CERCLA is that the persons responsible for
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creation of the problem are responsible for paying for remedying
the problem. CERCLA provides that the persons who generated the
wastes, arranged for disposal of the wastes and owned the site at
which the wastes were disposed of are responsible for the costs
of cleaning up the site. Liability for response costs under
CERCLA do not depend upon compliance or noncompliance with past
regulatory requirements.
Under CERCLA's special notice procedure, the persons
believed to be responsible are given the opportunity to undertake
or finance the response action before the Superfund monies are
used to do so. If the responsible parties are unwilling or
unable to finance or implement the remedy, EPA would consider
spending Superfund monies to do so. When Superfund monies are
used to finance the remedy, it is the policy of EPA to seek
recovery of those response costs from the responsible parties.
It is the policy of EPA to seek full recovery of all response
costs.
4. Will th« costs regarding this Site be available to the
public?
If the EPA undertakes the response action, then the cost is
public information. If a private party undertakes the .action,
then even the EPA may not know the costs.
5. Will this work be up for public bid or has it already
been contracted for?
If the EPA undertakes the work, two mechanisms would be
available. One mechanism is to have the U.S. Army Corps of
Engineer manage the work. In this case, the Corps of Engineers
would go through their normal bid advertising and contracting
procedures via the Commerce Business Daily (CBD).
If the EPA retains responsibility for the project, then the
work would be bid through the CBD or implemented through one of
the Agency's Superfund contracts. To a certain extent, those
contractors will try to use local labor and subcontractors if
they are qualified and available.
6. What is the relationship of EPA with the Iowa Department
of Natural Resources with respect to the cleanup of this site?
Did the State offer to pay for the cleanup of th« site?
The Remedial Investigation Report, the Draft Feasibility
Study, the Proposed Plan Document, and other pertinent documents
used to select the preferred remedy have been promptly shared
with the Iowa Department of Natural Resources; EPA has consulted
with the Department on the selection of this remedy from among
the alternatives considered, as well as all other major decisions
made with respect to the Site. The Iowa Department of Natural
Resources has not been called upon to assist in funding either
the Remedial Investigation or the cleanup, beyond the
requirements imposed by CERCLA.
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7. How vill the community be notified of EPA's selection of
the remedy to be implemented at the Site? Will the EPA conduct a
public meeting in order to discuss the party or parties who will
held responsible for the cost of the cleanup?
Subsequent to the signing of the Record of Decision, the
public will be given notice in the Newton Daily News of the
remedy selected.
No public meeting will be held to discuss the possible
liability of any party, although any lawsuit which might be
brought would, of course, be a matter of public record.
a. Is the purpose of the trust fund in the Superfund
program to cleanup haiardous vaste sites, and what is the source
of the trust funds administered by superfund?
Superfund was established by Congress as a trust fund under
the Comprehensive Environmental Response, Compensation and
Liability Act. Money for Superfund in large part comes from
taxes paid by companies which produce various chemical
substances, from costs (including fines and punitive damages)
recovered from responsible parties, and, to a lesser, extent,
from Government general revenue. The trust funds are to be used
if an immediate response is required, whether or not there is a
possibility of recovery from responsible parties; or where no
responsible party with adequate funds to pay for investigation
and cleanup can be found. If Superfund money is used for cleanup
then the EPA is bound by statute to attempt to recover these
monies from responsible parties. These include waste generators,
waste haulers, landowners, etc.
9. How did EPA learn of the existence of this Site? How
was this site selected for investigation and cleanup from the
sites listed on the National Priorities List? Why was there a
delay between the identification of the Site and the initiation
of response activities?
This Site came to the attention of EPA through the National
Pollution Discharge Elimination System (NPDES) program.
The National Priorities List ("NPL") establishes a system to
determine the order in which hazardous waste sites listed are
dealt with under the Superfund program. Each site is
investigated and cleaned up in the order established as funds and
resources become available. EPA undertook its investigation of
this Site as soon as it was able to do so in light of its
ranking, the contamination reported, the hazards involved, and
the funds available for investigation and cleanup.
10. In view of the leaching potential of the colloidal clay
encountered at the Site, what has been discovered concerning the
movement of the contamination into the surrounding areas? How
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many other sites on the HPL have hazardous wastes and soil
characteristics similar to that found at the north Para subsite?
The EPA's investigation has demonstrated that the
contaminants at the Site have not migrated far from the confines
of the disposal cell.
EPA does not have information available which would allow a
determination of how many sites across the country have colloidal
clay as part of the geologic structure.
11. If the hazardous material is removed to another site,
how can the public be assured that such action will not create
another hazardous waste/Superfund site?
First, the excavated soil will be treated using
stabilization technology, which has been identified in the Land-
Ban Disposal Regulations dated August 8, 1988, as meeting the
Best Demonstrated Available Technology standard for treating
sludges generated from electroplating operations. This will
reduce the mobility of the hazardous substances in the waste
material. Second, the treated waste will be deposited into an
EPA-authorized landfill designed to accept hazardous wastes.
This landfill will be equipped with double liners and a leachate
collection system. These engineering features in conjunction
with the stabilization technology give the best assurance known
today that the contaminants will not migrate from the Site.
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\
During the Public meeting several persons voiced their
concern regarding EPA's intentions to remediate the North Farm \
subsite. These persons felt that requirement of CERCIA, which
requires the potential responsible parties (PRPs) to pay the
cleanup costs, would place an economic hardship on both the PRPs
and the community. Provided below are several of the major
comments given by members of the community.
Stat« Representative Dennis Black:
You know, we just came through a farm credit crisis in Iowa,
we are in the midst of a drought. Farm production, needless to
say, isn't what was anticipated. And if, in fact, the cost of the
removal of 70 cubic yards would be $210,000, then I think we can
see another Iowa fanner biting the dust. I'm sure Mr. Brown does
not have the money and we would see another bankruptcy.
We have in the case of Kellogg, a small community. Probably,
I'm sure, the largest employer in the community would be Smith-
Jones. And I would question very much whether their balance sheet
would allow them the encumbrance of this amount of money. Once
again we are dealing with, I'm sure, future unemployment.
Now, those are the facts. These are the things that we have
to deal with. I understand full well that you folks representing
EPA have rules that you are responsible for and have to carry
out. But it bothers me very much to think that we are looking at
such a cost for such a small site as was indicated by the lady,
one of the smallest, and who pays the bill; the farmer, Smith-
Jones? I just don't think it will happen that way.
Mayor Eva Banning:
I worked at this factory for 20 years and I never heard
anyone around here comment on any of the --well, that dump site
out there, for years. In fact, I do not think I have ever heard
anybody and we have already had this project out there with the
lagoon that has cost over $500,000, and I can't see the company
down here being taken right now. And the farmers, just as
Representative Black said, there is just too many people. This
is all we have got here in this town. There is nothing else in
this town, only the elevator, and I see no reason why at this
time, nobody has said anything about this water and where it
comes from Bear Creek and down Coon Creek and on into Skunk
River. I don't know where they are getting off saying all at once
this here community has to be taken down the drain, because that
is what it is going to amount to.
We have already seen that some of it has went out of
here, and there will be more if this keeps on. And I just can't
see the factory and the community saying that this is going to be
a very hazardous—it's going to be a hazardous project if it
costs way into the well, it will end up about a million
dollars, I imagine, before it is over with.
-------
And I do not approve of the whole thing at all until things
get in better shape around here and through the country, arid for
the fanners and everybody. And I don't believe I have ever heard
any fanner say anything about this here contamination. Someone
may speak up and say they did, but I haven't never seen any and
I've not heard any.
,'1
And that is the reason why I think we are biting off more
than we can chew now right here in the community. And the pe'ople
are taxed now to pieces over this other deal. So, I'm afraid that
if this comes to a standstill and we all have to give up what
we've made, why, I think it's going to be a bad deal. That's it.
David 8and«en, President of Smith-Jones Kidveat Division
I could probably stay here all night and ask questions, but
I would just like to make a couple of comments and clarify a
couple of things.
First of all, I agree with Representative Black that we are
not scientist or engineers, so my argument is not what should we
do with that site. But I am doggoned surely convinced I want to
walk away knowing who is going to be paying for that.
I think that there has been some misrepresentation of
numbers, too, and you might be able to clarify this for me. The
number going around here tonight is $221,000 to clean up. I do
not believe that includes the cost of the remedial investigation
and the feasibility study, which numbers were given to me and
could be in the neighborhood of another quarter-million dollars.
Also not included in that cost is Site Number 2, which we
are not discussing tonight for some other reasons, but could have
duplicate or identical costs. So, we are looking at a total cost,
if in fact the costs for the remedial investigation and
feasibility study are not included in that for the North Farm
site for in the neighborhood of half million dollars.
I've got some people here, friends and employees, that would
like to know who is going to pay for that.
And also, a comment was made by Mr. Shiel earlier this
evening that the party that created the problem should be the one
that would clean it up. as far as I am personally concerned, I
work with EPA and IDEQ for ten years, on the water treatment
facility and disposing of the sludge.
We did everything that we were supposed to do for both those
Agencies. And as far as I am concerned, they are the ones that
created the sludge pond. They are the ones that suggested hoe we
do it, they approved our plans and we did it according to their
guidelines.
I guess the question I would have is what do you anticipate
-------
the entire bill to be including the feasibility study, the
remedial investigation, over and above the $221,000 we are
talking about?
Gary Young, President of OK? Local 74:
Mr. Young provided the Agency with a written comment on
behalf of the Membership of GMP Local 74. Mr. Young expressed
concern that if Smith-Jones, Inc., is forced to pay for the clean
up of the North Farm subsite, the financial drain on the company
would threaten the security of the jobs it provides to the
community.
Community petition
The Agency received a petition signed by approximately 190
members of the community requesting that EPA 's Superfund program
finance the clean up of the North Farm subsite. It is assumed
that the concern of those signing the petition, which represent
approximately thirty per cent of the community, are also
concerned with the economic effect on the community if its major
employer is compelled to undertake or finance the cleanup.
-------
MIDWEST MANUFACTURING/NORTH FARM
OPERABLE UNIT #1
SBPERFUND SITE
KELLOGG, IOWA
ADMINISTRATIVE RECORD INDEX
U.S' ENVIRONMENTAL PROTECTION AGENCY
CONTRACT NO. 68-01-7351 (TES IV}
WORK ASSIGNMENT NO. 570
SEPTEMBER 1988
-------
INTRODUCTION
This Index of Documents describes documents considered by
the U.S. Environmental Protection Agency in determining
response actions with respect to the Midwest
Manufacturing/North Farm Operable Unit #1, Superfund Site in
Kellogg, Iowa.
Administrative Record documents for this site are indexed
chronologically in ascending order, with any undated
documents following all dated entries. This sorting scheme
corresponds to the arrangement of documents in the
Administrative Record itself. 'In cases where documents
contain only partial dates, the Index of Documents defaults
to the first month of the year and/or first day of the first
month, as appropriate.
Most of the documents described in the Administrative Record
Index of Documents a,re present in hard copy from in the
Index itself; those marked "Yes" under the REFERENCE field
have been incorporated in the .Administrative Record by
reference, and may be made available for review at the U.S..
EPA Region VII office during regular business hours.
Administrative Record documents are contained in
classification file folders. The beginning and ending dates
of each category arei as follows:
* File 1 - 03/22/77 to 12/28/83
* File 2 - 06/03/87 to 01/07/88
* File 3 - 01/13/88 to 08/22/88
* File A - 07/15/88 to 09/08/88
* Guidance Documents:
1.) "Treatment Technology Briefs,
Alternatives to Hazardous Waste
Landfills"
2.) "Superfund Public Health
Evaluation Manual"
3.) "Final Report, Guidance Manual:
Cost Estimates for Closure and Post
Closure Plans ('Subparts G and H),
Volume III - Unit Costs"
4..) "A Compendium of Technologies Used in
the Treatment of Hazardous Wastes"
5.) "Chapter 7 - Present Worth Method of
Comparing Alternatives"
6.) Cost Document
7.) Cost Factors Document
-------
\
\
DOCUMENT DATE: 03/22/77
RUBBER OF PAGES: 9
AUTHOR:),
COMPANY/AGENCY: SVAN. Region VII, U.S.EPA
RECIPIENT:
DOCUMENT TYPE: Water Section Report
REFERENCE: Ho
DOCUMENT TITLE: 'Report of Inspection, Kellogg, Iowa, Midwest
Mfg. Co., A Division of Smith - Jones Inc. '
DOCUMENT DATE: 12/08/80
HUMBES OF PAGES: 3
AUTHOR: Striker, Jim, Environmental Specialist
COMPANY/AGENCY: Iowa Department of Environmental Quality
RECIPIENT: David Sandeen, General Manager, Smith - Jones Inc.
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE: Letter re: Attached Report of Investigation
Regarding Vaste Treatment Facility Inspection
Facility No. 50-00-1-02
DOCUMENT DATE: 11/16/81
NUMBER OF PAGES: 2
AUTHOR: Keffer, William, Chief
COMPAHY/AGENCY: SVAi, EP&R, Region VII, U.S. EPA
RECIPIENT: Robert L. Derby, Chief, ARHW/HAZtt Region VII, U.S.
EPA
DOCUMENT TYPE: Memorandum
REFERENCE: Bo
DOCUMENT TITLE: Memorandum re: Followup Inspection for Midwest
Mfg., Kellogg, Iowa
DOCUMENT DATE: 04/28/82
NUMBER OF PAGES: 98
AUTHOR: Jackson, Dave
COMPANY/AGENCY: Ecology & Environment
RECIPIENT: William Keffer, U.S. EPA
DOCUMENT TYPE: Plan
REFERENCE: Ho
DOCUMENT TITLE: Field Investigation of Uncontrolled Hazardous
Vaste Sites, Site Investigation Plan for
Midwest MFG., Kellogg, Iowa.
-------
DOCCTMEST DATE: 08/04/82
•UMBER OF PAGES: 4
AUTHOR: Jackson, David
C08PAHY/AGE1CY: U.S. EPA
RECIPIENT:
DOCUMENT TYPE: Potential Hazardous Waste Site ID
REFERENCE: Bo
DOCUMENT TITLE: Potential Hazardous Waste Site Identification
and Preliminary Assessment of Midwest Mfg.
DOCUMENT DATE: OB/04/82
SUHBEH OF PAGES: 4
AUTHOR: Jackson, David
COMPANY/AGEVCY: U.S. EPA
RECIPIENT:
DOCUMENT TYPE: Preliminary Assessment
REFERENCE: Ho
DOCUMENT TITLE: Potential Hazardous Vaste Site Identification
and Preliminary Assessment of Midwest Mfg.
DOCUMENT DATE: 08/04/82
NUMBER OF PAGES: 31
AOTHOB: Hensley, Charles P.
COMPANY/AGENCY: Region VII, U.S. EPA
RECIPIENT: leffer, Region VII, U.S. EPA
DOCUMENT TYPE: Laboratory Data
REFERENCE: Yes
DOCUMENT TITLE: 'Transmittal of Laboratory Data - Midwest
Manufacturing.*
DOCUMENT DATE: 08/04/82
BUMBEH OF PAGES: 10
AUTHOR: Jackson, David
COMPANY/AGENCY:
RECIPIENT:
DOCUMENT TYPE:
REFERENCE: No
DOCUMENT TITLE:
U.S. EPA
Inspection Report
•Potential Hazardous Waste Site, Site
Inspection Report on Midwest Mfg., North Far*
Site'
DOCUMENT DATE: 09/04/82
NUMBER OF PAGES: 12
AUTHOR: Jackson, David, Chemist
COMPAHY/AGEBCY: Ecology £ Environment, Inc.
RECIPIENT: U.S. EPA
DOCUMENT TYPE: Site Inspection Report
REFERENCE: Bo
DOCUMENT TITLE: Potential Hazardous Waste Site, Site Inspection
Report
-------
DOCUMENT DATE: 08/04/82
BOMBER OF PAGES: 1
AUTHOR: Jackson, David
COMPANY/AGENCY: Ecology & Environment, Inc.
RECIPIENT: U.S. EPA
DOCUMENT TYPE: Site Identification
REFERENCE: Ho
DOCUMENT TITLE: Potential Hazardous Haste Site, Site
Identification
DOCUHEHT DATE: 10/15/82
IUMBES OF PAGES: 1
AUTHOR: Co*tello, J. Patrick
COMPANY/AGENCY: U.S. EPA
RECIPIENT:
DOCUMENT TYPE: Site Indentification
REFERENCE: No
DOCUMENT TITLE: Potential Hazardous Waste Site Identification
of the North Far* Site
DOCUMENT DATE: 10/15/82
NUMBER OF PAGES: 1
AUTHOR: Costello, J. Patrick
COMPANY/AGENCY:
RECIPIENT: U.S. EPA
DOCUMENT TYPE: Site Identification
REFERENCE: Ho
DOCUMENT TITLE: Potential Hazardous Waste Site Identification
10/15/82 For»
DOCUMENT DATE: 01/28/83
NUMBER OF PAGES: 26
AUTHOR: Roberts, Mark
COMPANY/AGENCY: Region VII, REM/FIT, Ecology & Environment,
Inc.
RECIPIENT:
DOCUMENT TYPE: Report
REFERENCE: Ho
DOCUMENT TITLE: "Field Investigations of Uncontrolled Hazardous
Waste Sites, Proposed Work Plan for Midwest
Manufacturing Company, Kellogg, Iowa*
DOCUMENT DATE: 02/08/83
NUMBER OF PAGES: 22
AUTHOR: Keffer, tfilliaa J., Chief
COMPAHY/AGENCY: EP&R, ENSV, Region VII, U.S. EPA
RECIPIENT:
DOCUMENT TYPE: Memorandum
REFERENCE: No
DOCUMENT TITLE: Memorandum re: Attached Proposed Work Plan for
the North Far* Site, Kellogg, Iowa
-------
DOCOHEHT DATE: 04/13/63 \
BVHBES OF PAGES: 1
AUTHOR: Roberta, Hark t
COMPANY/AGENCY: Ecology & Environment
RECIPIENT: Bill Keffer, Chief, EP4R/ENSV Region VII, U.S. EPA
DOCUMENT TYPE: Meaorandua /
REFERENCE: Bo .'',
DOCUMENT TITLE: Heaorandua re: 'Status Report for the North
Far« Site, Kellogg, Iowa, TDD*R-07-8301-05'
DOCUMENT DATE: 12/28/83
NUMBER OF PACES: 54
AUTHOR: Roberts, Mark
COMPANY/AGENCY: Region VII, REH/FIT, Ecology & Environment
RECIPIENT: William Keffer, RPO. U.S. EPA
DOCUMENT TYPE: Report
REFERENCE: No
DOCUMENT TITLE: "Field Investigation of Uncontrolled Hazardous
Haste Sites - FIT Project*
DOCUMENT DATE: 06/03/87
NUMBER OF PAGES: 13
AUTHOR: Dunkle, L.
COMPANY/AGENCY: Camp Dresser & WcKee, Inc.
RECIPIENT:
DOCUMENT TYPE: Site Health and Safety Plan Fora
REFERENCE: So
DOCUMENT TITLE: Re: Midwest Mfg., North Farm Site (with
Attached Maps of the Site)
DOCUMENT DATE: 07/01/87
NUMBER OF PAGES: 5
AUTHOR: Wagoner, David A., Director
COMPANY/AGENCY: WSTM, Region VII, U.S. EPA
RECIPIENT: Larry J. Wilson, Director, Iowa Department of
Natural Resources
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE: Letter re: Request for ARAR's
DOCUMENT DATE: 07/29/87
NUMBER OF PAGES: 7
AUTHOR: Stokes, Allan F.
COMPANY/AGENCY: Iowa Department of Natural Resources
RECIPIENT: Dana Trugley, SPFD, Region VII, U.S. EPA
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE: Response Letter re: Iowa's Response to Agency
Request for ARAR's.
-------
DOCUMEHT DATE: 09/23/87
HUHBEB OF PAGES: 39
AUTHOR: Takade. Dennis Y., Ph.D., Site Manager
COHPAHY/AGEHCY: Woodward-Clyde Consultants
RECIPIENT: Bobert L. Borby, Regional Project Officer, SPFO,
Region VII, U.S. EPA
DOCUMENT TTPE: Correspondence and Report
REFERENCE: Ho
DOCUMEHT TITLE: Letter re: Attached, 'Site Evaluation and
Remedial Investigation/Feasibility Study
(RI/FS), Scoping Document, North Fare Site*
with Attached Errata Sheet, Dated 9-23-87)
DOCUMEHT DATE: 09/29/87
HUHBEB OF PAGES: 9
AUTHOR:. Kay, Morris, Regional Administrator
COMPANY/AGEHCY: Region VII, U.S. EPA
RECIPIENT: tferl and Gerdena Brown
DOCUMEHT TYPE: Special Notice Letter/104e Letter
REFERENCE: Ho
DOCUMEHT TITLE: Letter re: Notification of Potential Liability
under CERCLA for the North Fans Site and a
Request to Finance and Conduct a RI/FS
DOCUMEHT DATE: 09/29/87
HUMBER OF PAGES: 9
AUTHOR: Kay, Morris/ Regional Administrator
COMPANY/AGENCY: Region VII, U.S. EPA
RECIPIENT: Dave Sandeen, President, Smith-Jones, Inc., Midwest
Division
DOCUMENT TYPE: Special Notice Letter/I04e Letter
REFERENCE: No
DOCUMEHT TITLE: Letter re: Notification of Potential Liability
Under CERCLA for the Midwest Plant Site and a
Request to Finance and Conduct a RI/FS
DOCUMENT DATE: 10/27/87
HUHBEB OF PAGES: 4
AUTHOR: Merl Brown
COHPAHY/AGEBCY: Midwest Mfg. Co.
RECIPIENT: Dana Trugley, Region VII, U.S. EPA
DOCUMENT TTPE: Correspondence
REFERENCE: Ho
DOCUMENT TITLE: Letter re: Response to the Agency's 104e Letter
of 9/29/87
-------
DOCUMENT DATE: 11/13/87
NUMBER OF PAGES: 16
AUTHOR: Sandeen, David, President
COMPANY/AGENCY: Midwest Mfg. Co.
RECIPIENT: Danm Tnigley, Region VII, U.S. EPA
DOCUMENT TYPE: Correspondence
REFERENCE: Ho
DOCUMENT TITLE: Letter re: Response to the Agency's 104e Letter
of 9/29/67.
DOCUMENT DATE: 12/23/87
NUMBER OF PAGES: 2
AUTHOR: Wagoner, David A., Director
COMPANY/AGENCY: WSTM, Region VII, U.S. EPA
RECIPIENT: Merl Brown
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE: Letter re: Agency's Response to Merl Browns
letter of 9/29/87.
DOCUMENT DATE: 12/23/87
NUMBER OF PAGES: 10
AUTHOR: Wagoner, David A., Director
COMPANY/AGENCY: SSTM
RECIPIENT: David E. Sandeen, President, Saith-Jones, Inc.,
Midwest Division
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE: Letter re: 'Saith-Jones, Inc., Midwest Site and
North Fara Site*
DOCUMENT DATE: 12/29/87
NUMBER OF PAGES: 6
AUTHOR: Sandeen, David E., President
COMPANY/AGENCY: Midwest Mfg., Co., Saith-Jones, Inc.
RECIPIENT: Dana Trugley, SPFD, Region VII, U.S. EPA
DOCUMENT TYPE: Correspondence
REFERENCE: Ho
DOCUMENT TITLE: Letter re: Response to Issues Presented in
Correspondence froa U.S. EPA Dated, 12/23/87
DOCUMENT DATE: 01/05/88
NUMBER OF PAGES: 1
AUTHOR: Brown, Merl G.
COMPANY/AGENCY:
RECIPIENT: Region VII, U.S. EPA
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE: Letter re: Subaittal of Ellis Clausen's Address
-------
DOCUMENT DATE: OI/OT/SS
•UMBER OF PAGES: 87
AUTHOR: Kiefer, Michael L., P.E., HEM II, Region VII Manager
C08PAHY/A6EHCT: Ca»p, Dresser & KcK.ee, Inc.
RECIPIENT:
DOCUMENT TYPE: Report
REFERENCE; Bo
DOCUMENT TITLE: 'fork Plan for RI/FS at the Saith-Jonea/Midwest
/ Division Site, North Far* and Plant Areas.
Kellogg. Iowa. Voluae I, (Technical)'
DOCUMENT DATES
NUMBER OF PAGES:
APTBOB:
COMPANY/AGENCY:
RECIPIENT:
DOCOHEHT TYPE:
REFERENCE: No
DOCUMENT TITLE:
01/13/88
92
Caap. Dresser & HcKee, Inc.
Report
•Project Operations Plan/Quality Assurance
Project Plan for the BI/FS, Saith-Jones/Midwest
Division Site/ Kellogg, Iowa*
DOCtfMEHT DATE: 01/19/88
HUMBE8 OF PAGES: 1
AUTHOR: Trugley, Dana
COMPANY/AGENCY: REMD, SPFD, WST«
RECIPIENT: Calvin Walter, 'Iowa Department of Natural Resources
DOCUMENT TYPE: Correspondence
REFERENCE: Ho
DOCUMEKT TITLE: Letter re: "Midwest (Saith-Jones), North Far*
Superfund Site'
DOCUMENT DATE: 01/28/88
NUMBER OF PAGES: 1
AUTHOR: tfolter, Calvin
COMPANY/AGENCY: Abandoned/Uncontrolled Sites Section, Iowa
Department of Natural Resources
RECIPIENT: Dana Trugley, SPFD. Region VII. U.S. EPA
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE: Letter re: Comments Regarding Project
Operations/Quality Assurance Project Plan for
Midwest MFG.
-------
\
DOCUMENT DATE: 03/11/88
•UMBER OF PAGES: 4
AUTHOR: Wagner, David A./ Director
COMPANY/AGEVCY: WSTM
RECIPIENT: David E. Saadeen, President, Midwest Manufacturing
Coepany
DOCUMENT TTPE: Correspondence
REFERENCE: Ro
DOCUMENT TITLE: Letter re: Response to Seith-Jonea Decision Not
to Let U.S. EPA Investigate the Release of
Hazardous Substances on Property
DOCUMENT DATE: 03/15/68
NUMBER OF PAGES: 3
ADTBOB: Trugley, Dana
COMPABY/AGEHCY: REMD, SPFD, VSTtf
RECIPIENT: Herl Brown, Merl Brown Property (North Fare Site)
DOCUMENT TTPE: Acce«* Letter
REFERENCE: Ro
DOCUMENT TITLE: Letter re: Request of Consent for U.S. EPA to
Access Property to Perfore Environaential
Investigations
DOCUMENT DATE: 06/16/88
RUMBEB OF PAGES: 1
AUTHOR: Trugley, Dana
COMPANY/AGENCY: Beeedial Section, SPFD, WSTM
RECIPIENT: Calvin Walter, Iowa Department of Natural Resources
DOCUMENT TYPE: Correspondence
REFERENCE: Ro
DOCUMENT TITLE: Letter re: Transaittal Letter for the -Draft
Copy of the Remedial Investigation
-------
DOCUMENT DATE: 07/13/88
NUMBER OF PAGES: 25
AUTHOR: Kaleikau, Robert M., Community Relations Specialist,
et.al.
COUPANY/AGENCY: Woodward-Clyde Consultants
RECIPIENT: Dana Trugley, Regional Project Manager, Superfund
Branch, Region VII, U.S. EPA
DOCUMENT TYPE: Community Relations Plan
REFERENCE: No
DOCUMENT TITLE: 'Final Community Relations Plan, Midwest
Manufacturing/North Farm Site - Kellogg, Iowa'
(Date Located on Page 4 of 25)
DOCUMENT DATE: 07/15/88
IUMBER OF PAGES: 300
AUTHOR:
COMPANY/AGENCY: REM II, Woodward-Clyde Consultants
RECIPIENT: ',
DOCUMENT TYPE: Final Draft RI Report '
REFERENCE: No ';
DOCUMENT TITLE: "Final Draft Remedial Investigation Report for j
the Midwest Manufacturing/North Far* Site, ;
North Fare Operable Unit, Kellogg, Iowa* .:
I
DOCUMENT DATE: 07/18/88
NUMBER OF PAGES:; 1 ' ,
AUTHOR: Tmgley^ Dana L. ,\
COMPANY/AGENCY: REMD, SPFD, WSTM
RECIPIENT: Calvin Walter, Iowa Department of Natural Resources
DOCUMENT TYPE: Correspondence
REFERENCE: No
DOCUMENT TITLE: Letter re: Request of Comments on Draft
Feasibility Study
DOCUMENT DATE: 08/11/88
RUMBES OF PAGES: 1
AUTHOR: Preston, Morris, Supervisor,
COMPANY/AGENCY: Solid Waste Section, Iowa Department of Natural
Resources
RECIPIENT: Dana Trugley, Region VII, U.S. EPA
DOCUMENT TYPE: Correspondence
REFERENCE: Bo
DOCUMENT TITLE: Letter re: Review of the Draft FS for the North
Fans Site in Kellogg, Iowa
-------
DOCUMENT DATE: 08/22/88
BOMBER OF PACES: 2
AUTHOR: Voltor, Calvin
COMPANY/AGENCY: Solid Vaste Section, Iowa Department of Natural
Resource*
RECIPIENT! Dana Trugley, Region VII, U.S. EPA
DOCUMENT TYPE: Correspondence
REFERENCE: 80
DOCUMENT TITLE: Letter r«: Review of the Proposed Plan for the
North Fare Operable Unit in Kellogg, Iowa
DOCUMENT DATE: 09/07/88
MUMBER OF PAGES: 100
AUTHOR:
COMPANY/AGENCY; REM II. woodw»rd-Clyde Consultants
RECIPIENT:
DOCUMEHT TYPE: Final Draft FS Report
REFERENCE: Mo
DOCUMENT TITLE: 'Final Draft Feasibility Study Report for
HidtreBt Manufacturing/North Fare, Site. North
Far* Operable Unit, Kellogg, Iowa'
DOCUMENT DATE: 09/08/88
HUMBER OF PACES: 22
AUTHOR: .
COMPANY/AGENCY: Region VII. U.S. EPA :
RECIPIENT:
DOCUMENT TYPE: Proposed Plan
REFERENCE: 80
DOCUMENT TITLE: Proposed Plan for the Midwest
Manufacturing/North Far* Site, North Farm
Operable Unit, Kellogg, Iowa
10
-------
TERRY E. BRANSTAD,
DEPARTMENT OF NATURAL RESOURCES
LARRY J. WILSON. D.RECTO"
August 11, 1988
Ms. Dana Trugley
USEPA Region VII
726 Minnesota Avenue
Kansas City, Kansas 66101
Dear Dana:
AUG 1 9 198B
REMD SECTIOII
Thank you for allowing the Iowa Department of Natural Resources to review the
draft copy of the Feasibility Study for the North Farm site at Kellogg, Iowa.
Although the site poses no increased risk to the general population under
current land use conditions, the state feels that the site presents an
undesirable situation and should be cleaned up. Therefore, the state agrees
with the EPA selection of Alternative 6 as the preferred remedial action;
treatment of the sludge and contaminated soil at an off-site treatment
facility and disposal at the treatment vendor's controlled disposal facility.
However, the State also feels that before the fdrial remedial selection is made
both the North Farm site and the Midwest Manufacturing plant site should be
evaluated together since they were proposed as one site. The preferred
remedial alternative for the plant site may be different from the one for the
North Farm site and a combination of the two or a totally different
alternative may be preferred when both sites are looked at together.
Therefore, the State would prefer that the Record of Decision for the North
Farm site not be finalized until the Remedial Investigation/Feasibility Study
for the Midwest Manufacturing plant site is completed so that the remedial
alternatives for the two sites could be compared.
If we can be of further assistance on this project, please contact us.
Sincerely,
MORRIS PRESTON, SUPERVISOR
SOLID WASTE SECTION
MP:am-M222-AEM.12
WALLACE STATE OFFICE BUILDING / DES MOINES. IOWA 5O3l9/ 515-281-5145
-------
TABLE 1
REMEDIAL INVESTIGATION RESULTS
USEPA
Sample No.
T09A1016
T09A1017
T09A10170
T09A1018
T09A1019
T09A1020
T09A1021
T09A10210
T09A1022
T09A1U23
T09A1024
T09A1025
T09A1026
T09A1027
T09A1028
T09A1026D
T09A1031
T09A1031D
T09A1040
BACKGROUND CONCENTRATION
METALS IN THE WASTE MATERIAL ABOVE BACKGROUND CONCENTRATIONS
REM II
Sample No.
NFS-1
NFS-1
NFS-1
NFS-1
NFS-2
NFS-2
NFS-5
NFS-5
NFS-5
NFS-5
NFS-7
NFS-7
NFS-9
NFS-9
NFS-1
NFS-1
NFS-1
NFS-1
NFB-3*
Depth From
Surface Aluminum Barium Beryllium Cadmium
(feet) (mg/kp) (mg/kg) (mg/kg) (mg/kgl
2.1-3.0
3.0-4.0
3.0-4.0
4.0-4.9
1.0-2.1
1.0-2.1
2.2-3.0
2.2-3.0
3.0-4.0
3.0-4.U
2.7-3.1
2.7-3.1
1.33-1.67
1.33-1.67
2.1-4.9
2.1-4.9
4.0-4.9
4.0-4.9
2.5-3.5
100
81
81
110
9U
7800 95
9B
7500 98
--,..7-3.
7400 84
9100 96
7900 97
76
100
97
99
99
140
8400 93
0.45
0.49
0.50
0.49
0.48
0.47
-.0.5?— _..--
0.56
0.61
0.54
0.48
0.53
0.51
0.47
730
.1
5.2
1.7
430
570
830
670
20
28
62
69
660
820
250
76
.1
4.3
230
Calcium Chromium
(mg/kg) (mg/kg)
41,000
2700
12 ,000
16,000
4500
5200
2300
2200
4500
4700
27 ,000
31,000
11,000
5300
3700
2200
35
21
25
12
14
14
26
32
16
7200
65
0.44
0.67
2100
II
NOTE: my/kg - milligrams per kilogram
-------
USEPA
Sample NCK
T09A1016
T09A1017
T09A10170
109A1018
T09A1019
T09A1020
T09A1021
T09A1021D
T09A1022
T09A1023
TU9A1024
T09A1025
T09A1026
T09A1027
T09A1028
T09A1028D
T09A1031
T09A1031U
T09A1040
TABLE 1
(Continued)
REMEDIAL INVESTIGATIONS RESULTS
METALS IN THE WASTE MATERIAL ABOVE BACKGROUND CONCENTRATIONS
REM II
Sample No.
NFS-1
NFS-1
NFS-1
NFS-1
NFS-2
NFS-2
NFS-5
NFS-5
NFS-5
NFS-5
NFS-7
IiFS-7
NFS-9
NFS-9
NFS-1
NFS-1
NFS-1
NFS-1
NFB-3*
ICENTRATION
Depth From
Surface
(feet)
2.1-3.0
3.0-4.0
3.0-4.0
4.0-4.9
1.0-2.1
1.0-2.1
2.2-3.0
2.2-3.0
3.0-4.0
3.0-4.0
2.7-3.1
2.7-3.1
1.33-1.67
1.33-1.67
2.1-4.9
2.1-4.9
4.0-4.9
4.0-4.9
2.5-3.5
Cobalt
(mg/kg)
5.3
6.1
6.4
5.2
5.5
8.3
7.1
6.8
6.3
5.3
7.1>
4.9
6.5
6.6
4.7
Copper
(mg/fcg)
120
——.
58
61
"40 -'
47
21
21
84
100
38
22
13
Iron
(rig/kg)
19 ,000
••
18,000
19,000
16,000
16,000
17,000
17,000
17,000
18,000
23,000
16,000
15,000
Lead
(mg/kg)
38
19
22
18
17
10
11
11
32
44
16
11
11
9.1
10
8.6
Magnesium
(mg/kg}
4000
2100
2300
1900
1900
1700
2200
2500
1600
1400
1400
1300
Manganese
(mg/kg)
390
270
210
490
190
230
210
220
210
250
150
230
250
400
480
520
380
690
270
120
NOTE: mg/kg - milligrams per kilogram
-------
TABLE 1
(Continued)
REMEDIAL INVESTI GAT-ION RESULTS
METALS IN THE WASTE MATERIAL ABOVE BACKGROUND CONCENTRATIONS
USEPA
Sample No.
T09A1016
T09A1017
T09A1017D
T09A1018
T09A1019
T09A1020
T09A1021
T09A1021D
T09A1022
T09A1023
T09A1024
T09A1025
T09A1026
T09A1027
T09A1028
T09A1028D
T09M031
T09A1031D
T09A1040
REM It
Sample No.
NFS-1
NFS-l
NFS-1
NFS-1
NFS-2
NFS-2
NFS-5
NFS-5
NFS-5
NFS-5
NFS-7
NFS-7
NFS-9
NFS-9
NFS-1
NFS-1
NFS-1
KFS-1
NFB-3*
Depth From
Surface
(feet)
2.1-3.0
3.0-4.0
3.0-4.0
4.0-4.9
1.0-2.1
1.0-2.1
2.2-3.0
2.2-3.0
3.0-4.0
3.0-4.0
2.7-3.1
2.7-3.1
1.33-1.67
1.33-1.67
2.1-4.9
2.1-4.9
4.0-4.9
4.0-4.9
2.5-3.5
Molybdenum
(mg/kg)
6.3
6.7
7.3
6.0
5.9
6.2
7.1
6.4
6.0
7.6
Nickel
(mg/kg)
190
13
12
13
120
150
14
13
17
15
-. 31
28
240
320
61
37
14
16
12
Potassium
(mg/kg)
860
1000
1100
880
910
790
760
940
870
810
760
1200
Sodium
(mg/kg)
1100
1200
1600
2500
740
880
2500
2300
1500
2000
690
650
760
860
1400
1300
1300
1700
2300
Vanadium
(mg/kg)
29
30
UACKGROUM) CONCENTRATION
5.7
11
750
200
28
Zinc
(mg/kg)
500
240
360
74
78
38
33
77
77
570
740
180
92
34
33
30
NOTE: my/ky = milligrams per kilogram
-------
TABLE 2
REMEDIAL INVESTIGATION RESULTS
USEPA
Sample No.
T09A10I6
T09A1017
T09A1017D
T09A1018
T09A1019
T09A1026
T09A1021;
T09A1021D
T09A1022'
T09A1023;
T09A1024!
T09A102E',
T09A10261
T09A1027;
T09A1028
T09A1028D
T09A1040
BACKGROUND CONCENTRATION
CYAMDE CONCENTRATIONS
REM II
Sample No.
NFS-1
NFS-1
NFS-1
NFS-1
NFS-2
NFS-2
- NFS-5
NFS-5
NFS-5
NFS-5
NFS-7
NFS-7
NFS-9
NFS-9
NFS-1
NFS-1
NFB-3
IN THE WASTE MATEklAL
Depth from
Surface
(feet)
2.1-3.0
3.0-4.0
3.0-4.0
4.0-4.9
1.0-2.1
1.0-2.1
2.2-3.0
2.2-3.0
3.0-4.0
3.0-4.0
2.7-3.1
2.7-3.1
1.33-1.67
1.33-1.67
2.1-4.9
. 2.1-4.9
2.5-3.5
Cyanide
(mg/kg)
1.2
0.061
0.035
ND(0.030)
0.40
NA
0.83
C.44
0.045
NA
0.24
NA
0.27
NA
NA
NA
0.25
0.058
NOTE: . NA = Not analyzed.
mg/kg = milligrams per kilogram
-------
TABLE 3
REMEDIAL INVESTIGATIONS RESULTS
METALS IN SOIL ABOVE BACKGROUND CONCENTRATIONS
USEPA
Sample No.
T09A1001
T09A1002
T09A1002D
T09A1003
T09A1004
T09A1005
T09A1006
T09A1007
T09A1008
T09A1009
T09A1009D
T09A1010
T09A1011
T09A1012
T09A1029
T09A1032
REM II
Sample No.
NFb-1
NFB-1
NFB-1
NFB-l
NFB-2
NFB-2
NFB-2
NFb-3
NFB-3
NFB-3
NFB-3
NFB-4
NFB-4
NFB-4
Seep
Seep
Depth from
Surface
(feet)
0-1
6-7
6-7
7-8
0-1
6-7
7-8
0-1
6-7
7-8
7-8
. 0-1
6-7
7-8
0-0.5
0-0.5
Aluminum
(mg/kg)
8000
7600
8800
8600
8200
8900
Barium
99
110
87
110
180
230
86
100
80
54
89
91
Beryllium
(nig/ kg)
0.48
0.45
0.45
0.56
0.46
0.47
0.46
0.54
0.50
0.48
0.45
Cadmium
(mg/kg)
62
0.99
1.2
77
1.1
0.97
. 4.4
9.6
1.1
0.91
20
22
Calcium
Chromium
(mg/kg)
3000
2500
2400
2700
2400
2200
2600
2200
2200
2300
2400
12
BACKGROUND CONCENTRATION
NOTE: mg/kg = milligrams per kilogram
7200
65
0.44
0.67
2100
11
-------
TABLE 3
(Continued)
REMEDIAL INVESTIGATION RESULTS
METALS IN SOIL ABOVE BACKGROUND CONCENTRATIONS
USEPA
Sample No.
T09A1001
T09A1002
T09A10020
T09A1003
T09A1004
T09A1005
T09A1006
T09A1007
T09A1008
T09A1009
T09A1009D
T09A1010
T09A10U
T09A1012
T09A1029
T09A1032
REM II
Sample No.
NFB-1
NFB-1
NFB-1
NFB-1
NFB-2
NFB-2
NFB-2
NFB-3
NFB-3
NFB-3
NFB-3
NFB-4
NFB-4
NFB-4
Seep
Seep
Depth from
Surface
(feet)
0-1
6-7
6-7
7-8
0-1
6-7
7-8
0-1
6-7
7-8
7-8
0-1
6-7
7-8
0-0.5
0-0.5
Cobalt
BACKGROUND CONCENTRATION
6.1
4.8
7.6
6.8
11
12
5.7
5.9
7.5
11
5.5
6.5
4.7
Copper
14
19
14
13
Iron
16,000
23,000
17,000
18,000
22,000
20,000
15,000
Lead
(mg/kg)
9.5
12
9.3
8.9
8.6
12
12
8.6
Magnesium
1500
1400
1600
1400
1300
Manganese
(mg/fcg)
290
180
210
550
410
760
1300
440
400
180
130
290
560
320
360
340
120
NOTE: my/kg = milligrams per kilogram
-------
TABLE 3
(Continued)
REMEDIAL INVESTIGATION RESULTS
METALS IN SOIL MiUVE BACKGROUND CONCENTRATIONS
USEPA
Sample No.
T09A1U01
T09A1002
T09A1002D
T09A1003
T09A1U04
T09A1005
T09A1006
T09A1007
T09A1008
T09A1009
T09A1009D
T09A1010
T09A1011
T09A1012
T09A1029
T09A1032
REM 11
Sample No.
NFB-1
NFB-1
NFB-1
NFB-1
NFB-2
NFB-2
NFb-2
NFB-3
NFb-3
NFB-3
NFB-3
NFB-4
NFB-4
NFB-4
Seep
Seep
Depth from
Surface Molybdenum
(feet) (my/kg)
0-1
6-7
6-7
7-8
0-1
6-7
7-8
0-1
6-7
7-8
7-8
0-1 b.i!
6-7
7-8
0-0.5
0-0.5 6.7
Nickel Potassium
(mq/kgl (my /kg)
17
U
21
16
21
19
12
17
14
17
16
12 800
790
Sodium Vanadium
(mg/kg) (mg/kg)
1200
250
250
260
400
330
350
2300
520
350
320
510
420
400
860
880
Zinc
(mg/kg)
41
33
45
44
33
33
32
41
32
37
44
BACKGROUND CONCENTRATION
NOTE: mg/kg = milligrams per kilogram
5.7
11
750
200
28
30
-------
TABLE 4
REMEDIAL INVESTIGATIONS RESULTS
CYANIDE CONCENTRATIONS IN SOIL
Depth from
USEPA REM II Surface Cyanide
Sample No. Sample No. (feet) . (mg/kgl
T09A1001 NFB-1 0-1 0.14
•T09A1002 NFB-1 6-7 0.21
:t09A1002D NFB-1 6-7 0.075
T09A1003 NFB-1 7-8 ND(0.030)
T09A1004 - NFB-2 0-1 0.2
T09A1005 NFB-2 6-7 ND(0.030)
T09A1006 NFB-2 7-8 ND(0.030)
T09A1007 NFB-3 0-1 0.14
T09A1008 NFB-3 6-7 . ND(O.OSO)
T09A1009 NFB-3 7-8 ND(0.030)
T09A1009D NFB-3 7-8 ND(0.030)
fa9A10IO NFB-4 0-1 0.22
T09A1011 NFB-4 6-7 ND(0.030)
T09A1012 NFB-4 7-8 ND(0.030)
T09A1013 NFB-5 0-1 0.058
T09A1014 NFB-5 6-7 ND(O.OSO)
T09A1U15 NFB-5 7-8 ND(0.030)
T09A1029 Seep 0-0.5 0.12
'BACKGROUND CONCENTRATION 0.058
NOTE: my/kg = milligrams per kilogram
-------
TABLE 5
CONTAMINANTS OF CONCERN/HEALTH RISK
Contaminant
Cadmium
Manganese
Contaminant
Cadmium
Dissolved
Concentration
Level
ND(5 ug/1)
82-HO* ug/1
WASTE
Concentration
Detected
0.67-B30 mg/k
GROUND WATER
Total
Concentration Hazard Exposure
Level Index Pathway
19 ug/1 =1 Ingestion
520-2100 ug/1 <1 Ingestion
MATERIAL/ CONTAMINATED SOIL
Background Hazard Exposure
Concentration Index Pathway
g 0.67 mg/kg >1 Ingestion
Health-
Based
Action
Level
(ug/1)
18
7700
Health-
Baseo
Action
Level
(mg/kg)
of 13
Cyanide
ND(0.030)-l.i? my/kg, 0.058 mg/kg
-------
TABLE 6
POTENTIAL APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS
Contaminants of Concern - Ground Mater
Contaminant
Dissolved Cadmium
Total Cadmium
Dissolved Manganese
Total Manganese
Contaminant
Cadmium
Cyanide
Op si ope "ell..
Concentration
(ug/1)
ND(S.O)
ND(S.O)
125
645
Background
Concentration
(mg/kg)
0.67
0.058
Concentration
(ug/1)
ND(5.0)
ND(5.0)-19
82-UO
390-2100
Concentration
Range
(mg/kg)
0. 67-830
ND(0.030)-1.2
cw<2,3)
MQC: 10 ug/1
WQC: 10 ug/1
N/A
N/A
Contaminants of Concern
RCRA<*>
1 mg/1 in EP
Toxicity extract
defines a charac-
teristic hazardous
waste
N/A
Potency , .
Factor RCRAV '
N/A N/A
N/A N/A
N/A N/A
N/A N/A
- Soil
LOR16'9'
0.066 mg/1 in
TCLP extract
t
N/A
"£?*•
0.0005
ing/kg/day
0.0005
mg/kg/day
0.22 mg/
kg/day
0.22 ing/
kg/day
Potency
Factor
N/A
N/A
SOW*6'7'
HCL: 10 ug/1
HCL: 10 ug/1
5HCL: 50 ug/1
SHCL: 50 ug/1
Hef erfBce
Dose131
0.0005 mg/
kg/day
0.02 mg/kg/
day
Health-Bas
Action Lev
-------
TABLE 6 (Continued)
POTENTIAL APPLICABLE OH RELEVANT AND
APPROPRIATE REQUIREMENTS
NOTES:
ND = Not detected with detection limit in parentheses.
N/A = Not applicable.
(1) Total metal concentrations are reported in parentheses below dissolved metal concentrations.
(2) CWA is the Clean Water Act.
(3) WQC refers to the water quality criteria for surface water.
(4) RCRA is the Resource Conservation und Recovery Act.
{5} The reference dose is acceptable daily intake for cadmium. Refer to Section 6.0 of the Rl report.
(6) SDWA is the Safe Drinking Hater Act.
(7) The notation MCL refers to the enforceable Maximum Contaminant Level. SMCL refers to the Secondary Maximum
Contaminant Level, an aesthetic criteria established for finished water supplies.
(8) LOR is the Land Disposal Restrictions for First Third Scheduled Wastes.
(9) For F006 wastes, the following constituents are part of the LOR treatment standards:
Cadmium 0.066 mg/1 in TCLP extract
Total Chromium 5.2 mg/1 in TCLP extract
Lead 0.51 mg/1 in TCLP extract
Nickel 0.32 mg/1 in TCLP extract
Silver 0.072 mg/1 in TCLP extract
-------
Table 7
REMEDIAL ALTERNATIVES
Rl TER I A
NO ACTION
INCLUDES ACCESS i
DEED RESTRICTIONS
RCRACAP AND
GROUND WATER
HON1TOR ING
SOIL CAP AND
GROUND WATER
MON1TOR I NG
EXCAVATI ON,
SOLIDIFICATION
t DISPOSAL IN
EXISTING 0 ISPOSAL
CELL/GROUND UATER
HONI TOR ING
EXCAVATION,
SOL 101FI CAT ION
AND OFFSITtE
D I SPOSAL
vera I I None
Protection
o«pl i »nce
with ARARs
ong-term None
ef feet i veness
H educ t i on of No
t ox t c i t y ,
mob i 1 t t y
or vo I ume
:hor t - t *rm
effectiveness None
Ion t h s t o 1
i mp I ement
lost 1500
(Total Present
Worth)
; t a t e Ho
Acceptance
: ommun i t y Acceptance The commun
SUBJECT TO
Yes
Por t t ons of
cap replace-
ment poss i bl e .
Potent i al for
ground water
C ont ami nation.
No
CAP INTEGRITY Reduce huaen health
and env iron. risk.
Yes
Porti ons of
cap replace-
ment poss i bl e .
Potential for
ground water
cont am i no t i on .
No
Eliminate human .exposure vi
7
»162 , 000
No
5
(132.000
No
RCRA's LDRS I LCRs
are applicable.
RCRA'a tUR are
appropriate and
re I evant .
Portions of cap
rep 1 acement
poss i bl e . Reduced
chance of ground
water ,
Reduce mobi I i ty .
a Direct Contact
9
»175,000
No
RCRA'* LDRS are
applicable. Dlipoaal
of ua*te Into a RCRA
subtitle C Undfi 11 .
RCRA't LCCR are appl 1 .
Yes
Reduce toxic ty and
mobi 1 i ty .
Yes
9
iUO.OOO- LCCR ' Landfill Clean
$170.000 Closure Resolution
LOR = L and .Disposal
Yes t CH = Landfill Closure
Resolution
ty concern centered on the cost of remediation 4 who would pay. Technology
-------
•r^rr ' 1ff¥tl,,
E4J
N(W" LJ-^~ ;>..t».t.
Ihl'on I i' ° "~ '7*'
'^-f sf-'i ./-•
Lf^L>^; j i
-<^:f"^v"1" K.».-.-sir^
SCALE: 1 INCH = APPROXIMATELY 13 MILES
NOTE : INFORMATION OBTAINED FROM
AMERICAN AUTOMOBILE ASSOCIATION
(AAA) MAP OF IOWA. NEBRASKA, 1986
SITE INDEX
N
MIDWEST MANUFACTURING/NORTH FARM SITE
NORTH FARM OPERABLE UNIT
KELLOGG, IOWA
Woodward-Clyde Consultants
. .GEOLOGISTS. A>"D ES\I7RO>1VCE>TA^ SCIENTISTS
SITE VICINITY MAP
DRK BY SDC
CHTD
DATE 12/23/87
OiTT ^ - .'V
.TC-r NO
395FR1
na NO
1-1
-------
.: NORTH FARM OPERABLE UNIT
i '/ \ V \.\.VI, ' •&<•.- S.J ' ' I I i ^ - I
APPROXIMATE BOUNDARY OF
SMITH-JONES MIDWEST PLAN^Ti
NOTE: INFORMATION OBTAINED FROM USGS
KELLOGG. IOWA QUADRANGLE, 1080
T80N R18W
IOWA
QUADRANGLE
LOCATION
i
H
scaie
2000 4000
feet
MIDWEST MANUFACTURING/NORTH FARM SITE i
NORTH FARM OPERABLE UNIT '-
KELLOGG.IOWA . i
Woodimrd— Clyde Consultants ;
SITE LOCATION
DRX. BfY SDC
cmro HTT
DATT 12/24/87
DiTZ
PHOJTXT
395FR1
-------
Coon Crttk
Approt. 300 y«v. £»,,
Or«(nto, oiled *
Appro*. 160 7*1. Nerth
AO 2702
AO 2703
AQ 0310
AQ 2708
AQ 2701
AQ 0311
AO 2704
AO 2707
\
*
V
AO 2706
\
AQ t?e«
AQ 2709 Appro.
200
N
AQ C312
A
b n
LEGEND
Appre>. Boundary of
01*901 tl Ti «nch
o
7f.«
S»moli Point (April 6. 1983)
Simpt. Point May 11. 1882
Apprei. Scile
30 f»tt
NORTH FARM SUBSITE
KELLOGG, IOWA
SOIL AND SLUDGE SAMPLING LOCATIONS
NORTH FARM DISPOSAL SITS
FIGURE NO: 3
-------
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0
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intc*wt» or MCPM ttnicn W.UBW
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MID WC IT UANUf kCTUftlMa/NdHTH F Aft It (
Wood ward-Clyde Consultants
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------- |