PB96-963111
                           EPA/AMD/R07-96/085
                           November 1996
EPA  Superfund
      Record of Decision Amendment:
      Mid-America Tanning Company,
      Superfund Site, Woodbury County, IA
      7/29/1996

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             AMENDMENT TO THE



         RECORD OF DECISION FOR THE
                        \


MID-AMERICA TANNING COMPANY SUPERFUND SITE



          WOODBURY COUNTY, IOWA
                 Prepared by:



        U.S. Environmental Protection Agency



                  Region VH



               Kansas City, Kansas



                   July 1996

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                                DECLARATION
                RECORD OF DECISION AMENDMENT FOR THE
             MID-AMERICA TANNING COMPANY SUPERFUND SITE
                         WOODBURY COUNTY, IOWA
                                  JULY 1996

SITE NAME AND LOCATION

Mid-America Tanning Company Superfund Site
Woodbury County, Iowa

INTRODUCTION

      The United States Environmental Protection Agency (EPA) is amending the Record of
Decision (ROD) for the Mid-America Tanning Company Superfund Site. On September 24,
1991, a ROD was issued for the Mid-America Tanning Company Site located in Woodbury
County, Iowa. The ROD presented the remedy selected by the EPA for this site, which called
for in-situ immobilization of the densely-contaminated sediments in the east and west aeration
lagoons and the northeast field in conjunction with the placement of soil-clay caps over the less
densely-contaminated source areas. Impoundment waters were to be treated as necessary and
either discharged to the nearby oxbow lake or transported off site to a Publicly Owned
Treatment Works (POTW). As a result of information which has been developed subsequent
to the issuance of the ROD, the EPA has determined that fundamental changes to the remedy
were necessary. The amendment to. the ROD describes and summarizes the basis for these
changes as well as documenting changes in the remedy at the site.

      The EPA is the lead agency for the site, and the Iowa Department of Natural Resources
(IDNR) has been designated the support agency.  The amendment to the ROD is being issued
by the EPA with concurrence by the state of Iowa.

      The ROD amendment together with the original ROD presents the selected remedial
action for the site. This action was chosen in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA), and the National
Contingency Plan (NCP).  Section 117(c) of CERCLA provides that after the adoption of a
final remedial action plan,  if any remedial action is taken, or if any enforcement action under
section 106 or 122 is entered into, and such action, settlement or decree differs in any
fundamental respect from such final plans, the lead agency shall publish an amendment to the
ROD with the reasons such changes were made. The ROD amendment will explain these
changes to the remedy. In accordance with the NCP, 40 C.F.R. 300.825 (a)(c)(21), this

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amendment and the information supporting these decisions are part of the administrative record
file and are available for public review and comment.  The administrative record file is
available for review at the the Sergeant Bluff City Hall, Sergeant Bluff, Iowa and the EPA
Region Vn Office, Kansas City, Kansas.

DESCRIPTION OF THE AMENDED SELECTED REMEDY

      The major components of the selected remedy, as amended, include:

      •      Contaminated soils in the northeast field will be consolidated and/or excavated
             and consolidated with the Polishing Basin sediments and covered with a
             soil/clay cap or geosynthetic cap such as high-density polyethylene (HDPE) that
             achieves the same level of performance;

      •      Sediments in the polishing basin and east and west aeration lagoons will be
             dewatered.  The dewatered sediments will then be covered with a clay/soil
             cover or comparable geosynthetic cap;

      •      On-site treatment and discharge of impoundment water to the nearby oxbow
             lake;

      •      Excavation of the burial trench material followed by on-site stabilization and
             consob'dation with the northeast field soils prior to capping;

      •      Excavation of the contaminated soil areas, other than the northeast field, and
             consolidation of this material with the aeration lagoon sediments and/or
             polishing basin sediments prior to capping;

      •      Removal of the sediments in the wet well, aeration basin, and final clarifier and
             consolidation of this material with the sediments in the aeration lagoons prior to
             capping.  The emptied basins will be decontaminated with high-pressure steam
             and backfilled with clean soil;

      •      The filter press building along with other miscellaneous contaminated debris
             will be decontaminated by washing these items with  a high-pressure steam
             cleaner.  Wash water will be treated  on-site and discharged to the oxbow lake.
             Floor scrapings and building residue will be disposed of in accordance with the
             Resource Conservation and Recovery Act (RCRA); and

      •      Land use restrictions in the form of deed restrictions will be instituted to limit
             future use of the property.

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STATUTORY DETERMINATIONS

      The selected remedy as amended remains protective of human health and the
environment, complies with federal and state requirements that were identified in the ROD as
applicable or relevant and appropriate to this remedial action and is cost effective. In addition,
the remedy, as revised, utilizes permanent solutions and alternative treatment technologies to
the maximum extent practicable for this site. These changes to the remedy will increase
projecjtiveness of human health and environment, both short term and long term.
                                            7-39 -
    .
Dennis Grams, P.E.                         \Date
Regional Administrator
Environmental Protection Agency
Region VH
Attachment:

      Decision Summary
      Responsiveness Summary-Attachment A

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                            Amended Record of Decision



                                 Decision Summary



                                     Contents








I.     Introduction	       1



n.    Community Relations	       2



m.   Reasons for Issuing the ROD Amendment	       2



IV.   Description of the New Alternatives	       3
                                          \


V.    Evaluation of Alternatives	       5



VI.   Statutory Determinations	       13



      Responsiveness Summary	  Attachment A

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                              DECISION SUMMARY
                  RECORD OF DECISION AMENDMENT for the
             MID-AMERICA TANNING COMPANY SUPERFUND SITE
                          WOODBURY COUNTY, IOWA

I.    INTRODUCTION

      The Mid-America Tanning (MAT) Company Superfund Site is located in Woodbury
County, Iowa, approximately seven miles south of Sioux City and four miles south of the town
of Sergeant Bluff.  The MAT site occupies 98.7 acres of land in an industrial area known as
the Port Neal Industrial District.  The site is bordered on the north by Kind & Knox, a gelatin
manufacturer, on the east by a Chicago and Northwestern railroad right-of-way, and on the
west and south by agricultural land and public-use hunting grounds.  The nearest stretch of the
Missouri River is approximately 1.5 miles to the southwest.

      The MAT Site operated as a hide tanning processor under several different ownerships
from 1970 until 1989.  The tanning process included fleshing, brine curing and trimming of
hides as well as brine and chrome tanning.  The tanning operations generated a wastewater
stream that contained dirt, brine, flesh, detergents, hair, sulfides, ammonia,  lime,  grease and
chromium. During a period of the operation, contaminated sludges were buried in trenches
and land farmed on the site.  The Environmental Protection Agency (EPA) completed an
Remedial Investigation/Feasibility Study (RI/FS) in July 1991 and issued a Record of Decision
(ROD) in September 1991. The selected remedy in the ROD consisted of in-situ
immobilization of the densely-contaminated sediments in the east and west aeration lagoons
and the northeast field, placement of a soil-clay cap over the less densely-contaminated source
areas, and treatment and  discharge of contaminated impoundment waters.  The EPA completed
a Remedial Design (RD) in 1993, and in  1994 the Foxley Cattle Company was ordered to
conduct a removal action at the site. Foxley complied with  the Order and completed the
removal action in May 1995.  While conducting the RD and subsequent removal action, EPA
determined that the sediments found in the clay-lined impoundment areas were generating
hydrogen sulfide gas at concentrations posing significant health risks. Air sampling and
modeling indicated that unacceptable levels of hydrogen sulfide gas would be released during
the solidification process. In response to this concern, EPA is amending the remediation to
minimize disruption of the waste and the. release of hydrogen sulfide gas.  The ROD
amendment recommends dewatering the impoundment areas using a system of wick drains and
then applying an improved cap to the area.  In addition,  the ROD amendment addresses the
need to remediate the sediments in the wet well area, aeration basin and final clarifier.  These
sediments will be consolidated with the aeration lagoon sludges and/or polishing basin
sediments and capped.  The ROD amendment also provides for decontamination of the filter
press building and other debris on site.

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 H.    COMMUNITY RELATIONS

       The EPA is issuing this ROD Amendment to meet the public participation provisions
 mandated under Section 117(a) of the Comprehensive Environmental Response,
 Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
 Reauthorization Act (SARA) of 1986, and Section 300.435 (c)(2)(U) of the National Oil and
 Hazardous Substances Pollution Contingency Plan (NCP).

       The proposed plan for this ROD amendment was made available to the public in the
 administrative record file located at the Sioux City Public Library, 529 Pierce Street, Sioux
 City, Iowa and the EPA Region vn Office, Kansas City, Kansas. A public notice was
 published in the Sioux City Journal announcing the commencement and length of the public
 comment period and the availability of the administrative record file.  The EPA offered to hold
 a public meeting to discuss the ROD Amendment if requested; however, no requests were
 received. Comments received during the public comment period are addressed in the
 Responsiveness Summary. The EPA received no comments to the proposed plan for this ROD
 Amendment.                                '
                                            i

 m.    REASON FOR ISSUING THE ROD  AMENDMENT

       During the Remedial Design and subsequent Removal Actions at the site, the EPA
 determined that the sediments found in the clay-lined impoundments were generating hydrogen
 sulfide gas at concentrations posing significant health risks.  Air sampling indicated that the
 levels of hydrogen sulfide gas released would significantly increase when the impoundment
 sediments were disturbed.

       The selected remedy in the ROD for the impoundment sediments is in-situ stabilization
 followed by a 2-foot soil cap. In-situ solidification requires disturbing the impoundment
 sediments with a large-scale auger. Based on air sampling and modeling, the levels of
 hydrogen sulfide released during the mixing of impoundment sediments with solidification
 agents are projected to exceed worker permissible exposure limits as defined by the National
Institute for Occupational Safety and Health (NIOSH) and the Occupational Safety and Health
 Administration (OSHA).  Air dispersion modeling also indicates a reasonable likelihood that
 hydrogen sulfide emissions at the site perimeter would exceed the permissible exposure levels
for hydrogen sulfide established by the Agency for Toxic Substances and Disease Registry
 (ATSDR).

       An alternate remedy of dewatering the sediments would substantially reduce the
 disturbance of the impoundment sediments. Therefore, significantly less hydrogen sulfide gas
emissions would be generated as compared to implementation of the in-situ solidification. A
geosynthetic cap or an improved clay cap would be placed over the dewatered sediments

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forming an infiltration barrier that can resist leaching from deformations caused by settling and
drying, thereby, potentially reducing long-term cap maintenance costs.
IV.    DESCRIPTION OF THE NEW ALTERNATIVES

       The original remedy for remediation of the contaminated soil, sediment and
impoundment water included the following major components:

       •     Treatment followed by discharge or off-site disposal of impoundment waters;

       •     In-situ stabilization/solidification of contaminated sediments and soils in the east
             aeration lagoon, west aeration lagoon, and northeast field, followed by a 2-foot
             soil cap;

       •     Soil/clay capping of the polishing basin sediments and miscellaneous
             contaminated surface soils;        \

       •     Stabilization/solidification of contaminated sludges removed from burial
             trenches followed by either onsite or off-site disposal;

       •     Semi-annual monitoring and maintenance of soil/clay caps and immobilized
             materials; and

       •     Annual long-term ground water monitoring.

       The amended remedy will be as protective of human health and the environment, be
more implementable and decrease the cost of the remedial action. The changes  include the
replacement of the in-situ solidification of impoundment sediments and northeast field soils
with innovative dewatering technology followed by an improved cover design; inclusion of
additional site contaminated areas at the  site into the remedy; and documentation of the final
decisions on waste disposal options identified in the original ROD. The amended remedy will
fully meet the remedial action objectives identified in the Feasibility Study identified as
prevention of direct contact and contaminant migration to the ground water.

       The major changes in the amended remedy include:

       •     Contaminated northeast field soils would not undergo in-situ stabilization, but
             rather would be consolidated and/or excavated and consolidated with the
             Polishing Basin sediments and covered with an improved soil/clay cap meeting
             specified performance criteria or geosynthetic cap such as high-density

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       polyethylene (HDPE) that would achieve similar performance criteria.  Depth of
       the contamination in the northeast field ranges from 1 to 1.5 feet, and a
       redesigned cap will continue to provide an implementable, cost-effective, and
       equally protective

       remedy.  Contamination from this area may also be excavated and consolidation
       with the Polishing Basin sediments. This would be equally protective and may
       be even more cost-effective.

•      Sediments in the east and  west aeration lagoons  would not undergo
       stabilization/solidification. Instead, the impoundment areas would be dewatered
       and capped.  The impoundment covers would be redesigned to incorporate an
       improved soil/clay cap meeting the performance criteria or comparable
       geosynthetic cap such as high-density polyethylene.  Post-ROD sampling
       indicated the presence of hydrogen sulfide gas production from  the
       impoundment sediments.  Air sampling and modeling indicates  that dangerous
       levels of hydrogen sulfide gas would be emitted  should the impoundment
       sediments be disturbed which would occur under the original remedy. This
       change will provide a more cost effective remedy that greatly reduces the
       potential for releases of hydrogen sulfide gas, thereby reducing  the. health risk to
       on-site workers and the nearby public.  The amended remedy is also protective
       due to the improved cover design.

•      Contaminated soil areas, other than the northeast field, will be excavated and
       consolidated with the aeration lagoon sediments  and/or polishing basin
       sediments prior to capping.  The original remedy had these areas capped in
       place; however, by consolidating these soils, the costs associated with cap
       construction will be significantly reduced while maintaining equal protection to
       the public health and the environment.

The following are the areas where the original remedy contained options:

•      The original remedy indicated that impoundment waters were to be treated as
       necessary and either discharged to the nearby oxbow lake or transported off site
       to a POTW.  All impoundment water will be treated on-site if necessary and
       discharged to the nearby oxbow take.  The EPA has determined that on-site
       treatment would be most cost-effective due to the quantity of water potentially
       needing to be treated. This is not a change from the original remedy and just
       serves to document EPA's preference for treating the water on-site.

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       •     The original remedy indicated that contaminated sludges excavated from the
             burial trenches were to be stabilized and disposed of either on-site or off-site.
             Based on preliminary calculations, on-site stabilization and consolidation with
             the northeast field soils followed by capping will be the most cost-effective way
             to remedy this area of the site.  This is not a change from the original remedy
             and just serves to document EPA's preference for treating the burial trench
             material on-site.

       The following are the areas that the original remedy did not address.

       •     The original remedy did not address the sediments remaining in the wet well,
             aeration basin, and final clarifier. This ROD amendment addresses the removal
             of the contaminated material and consolidation of it with the sediments in the
             aeration lagoons and/or polishing basin.  These sediments would then be
             capped. The emptied basins will be decontaminated with high-pressure steam
             and backfilled with clean soil. These actions will further reduce the risk of
             direct contact to site contaminants and the potential threat of contaminant
             releases to the environment.

       •     The original remedy did  not address the decontamination of the filter press
             building and miscellaneous contaminated debris. This ROD amendment
             addresses decontamination of these areas by washing with a high-pressure steam
             cleaner. Wash water will be treated oil-site and discharged to the oxbow lake.
             Floor scrapings and building residue will be disposed  of in accordance with the
             Resource Conservation and Recovery Act (RCRA). These actions will provide
             additional protection of human health and the environment.

V.     EVALUATION OF ALTERNATIVES

       The NCP sets forth nine evaluation criteria which serve as a basis for comparing the
remedial alternatives.for final actions. The nine criteria are divided  into three categories:
Threshold Criteria, Primary Balancing Criteria, and Modifying Criteria.  If any remedial
alternatives identified during the Feasibility Study do not meet the Threshold Criteria (Criteria
1 and 2), EPA will not consider them as possible final remedies.  If  the alternatives satisfy the
Threshold Criteria, they then are evaluated against the next five criteria, called the Primary
Balancing Criteria. These criteria are used to compare the remedial  alternatives against each
other in terms of effectiveness, implementability, and cost.  The final two criteria, state
acceptance and community acceptance,  are called Modifying Criteria.  The alternatives are
compared against the Modifying Criteria after the state and community have reviewed and
commented on the Proposed Plan and the other alternatives considered by EPA.

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The following is a discussion of the nine criteria used by EPA for remedy selection.

A.    Threshold Criteria:

      1.     Overall Protection of Human Health and the Environment

             The EPA assesses the degree to which the alternatives would eliminate,
             reduce, or control threats to public health and the environment through
             removal, containment, and/or institutional controls. An alternative is
             normally considered to be protective of human health if the excess
             cancer risk is reduced to less than 1 in 1,000,000 (10"6) and risks do not
             pose non-carcinogenic health risks {Hazardous Index (HI)  < 1}.

             Based on the results of the risk assessment performed at MAT, current
             and/or future contact to sediment in the east and west aeration lagoons,
             the polishing basin, and the soils in the northeast field, pose a potential
             human health risk.   The original remedy reduced the threat of exposure
             of the contaminants by in-situ stabilization and capping of the soils and
             sediments and the removal and discharge of contaminated impoundment
             waters.  The amended remedy would adequately protect human health
             because it addresses the principal threat of exposure by treating and
             discharging impoundment waters and by capping the associated
             contaminants and preventing direct contact.  The amended remedy would
             also reduce the likelihood of all exposure of ecological receptors to the
             contaminated areas.  The amended remedy also provides greater
             protection as compared to the original remedy by reducing  the likelihood
             of hydrogen sulfide gas emissions at levels above worker threshold
             standards during the remedial action.  In this case, the amended remedy
             is more protective.  The amended remedy also includes an improved
             capping system which will help ensure and minimize contaminant
             migration  into the groundwater in the future. Institutional controls in the
             form of deed restrictions limiting building of structures on site will
             supplement the containment measures and help to ensure that exposures
             in these areas will not increase to the extent that the carcinogenic risks
             would be unacceptable.

      2.     Compliance with all Applicable or Relevant and Appropriate State
             And Federal Environmental Regulations

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The amended remedy will comply with all federal and state applicable or
relevant and appropriate requirements (ARARs). Applicable
requirements are those state or federal requirements legally applicable to
the release or remedial action contemplated that specifically address a
hazardous substance, pollutant, contaminant, remedial action, location,
or other circumstance found at the site.  If it is determined that a
requirement is not applicable, it may still be relevant and appropriate to
the circumstances of the release.  Requirements are relevant and
appropriate if they address problems or situations sufficiently similar to
the circumstances of the release or remedial action contemplated, and are
well-suited to the site.

The majority of the ARARs which applied for the originally selected
alternative also apply  to the amended alternative.  The chemical-specific
ARARs that are relevant and appropriate at the site include Ambient
Water Quality Criteria (AWQC) and National Pollution Discharge
Elimination System (NPDES) standards.  As with the original remedy,
the amended remedy involves removal of surface water in the polishing
basin and east and west aeration lagoons followed by treatment and
discharge to an on-site surface water (oxbow lake). Soils and sediments
will be capped in place. Capping includes provisions for drainage and
runoff control.  The substantive requirements include AWQC, effluent
limitations and monitoring requirements and will be met by the amended
remedy.

The state of Iowa promulgated regulations pursuant to Iowa Code
Section 455E.5 will apply to cleanup actions at the site where significant
amounts of soil contamination are present and groundwater
contamination is occurring. These regulations, set forth in 567 LAC
133, are applicable since groundwater contamination has been observed
at the site.  As with the original ROD, groundwater contamination and
long term monitoring  will be addressed in a separate action.

The federal and state action-specific ARARs include all OSHA, all
Hazardous Materials Transportation Act (HMTA) regulations, and the
Clean Water Act (CWA) regulations applicable to discharge to POTWs.
The RCRA regulations would only be considered applicable for the
trench material because of the TCLP test results. Trench materials will
be treated through in-situ stabilization prior to consolidation and
capping.  The RCRA  regulations are not relevant and appropriate to the
chromium contaminated soils and sediments since they do not fail TCLP.

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              In addition, RCRA regulations may be considered as relevant and
             appropriate for materials which may be generated such as floor
             scrapings.  Floor scrapings which might be generated as part of the
             decontamination process will be tested. Based on the results of these
             tests, the materials will either be consolidated with the soils  and
             sediments and capped or consolidated with the trench materials prior to
             in-situ stabilization and capping.

B.     Primary Balancing Criteria

       1.     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. Institutional controls, including
             local zoning regulations which limit the uses of the property and deed
             restrictions prohibiting the construction of buildings or other structures
             on the capped areas of the site, would prevent damage or deterioration of
             the capped areas and exposure of the contaminants present at the site.
             These restrictions will apply to this property regardless of any
             subsequent change in ownership, thereby offering long-term
             effectiveness and permanence of the selected amended remedy.

             Evidence indicates that the levels of contamination in several areas of the
             site potentially pose a current and/or future risk to  human health  or the
             environment.  The implementation of the amended remedy will result in
             a reduction in the risk in all areas where contamination was found to
             pose a risk through direct contact or inhalation. The amended remedy
             provides more protection by including additional areas in the
             remediation.

             The amended alternative includes treatment of contaminants and
             engineering controls. Surface waters will be treated if necessary prior to
             discharge.  Although contaminated soils and sediments will be left in
             place and capped, potential for direct exposure will significantly be
             reduced. Mobility of the contaminants will be reduced through
             dewatering and an improved capping system. The  improved cap will
             limit the ability of surface water runoff to cause contaminants to migrate
             into the groundwater.  Both the original remedy and the amended
             remedy rely on groundwater monitoring to ensure that the remedy
             continues to provide effective long-term protection of human health and

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       the environment. The improved cap contained in the amended remedy
       will be constructed and maintained in a manner that provides long term
       effectiveness and permanence. Groundwater will be monitored to ensure
       that the remedy is operating as designed.

2.     Reduction of Toxicity, Mobility, or Volume Through Treatment

       Section 121(b) of CERCLA states that remedial actions involving
       treatment which permanently and significantly reduce the volume,
       mobility or toxicity of the 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 hazardous wastes.

       The amended alternative will reduce the toxicity of the surface waters of
       the polishing basin and east and west aeration lagoons by treating these
       waters prior to discharge.  Neither the original nor the amended remedy
       reduce the toxicity of the hazardous constituents in the contaminated
       soils and sediments.

       The original remedy employed in-situ stabilization to reduce the mobility
       of the contaminants. The amended alternative will employ capping and
       engineering controls to reduce the mobility of the hazardous constituents.
       The amended remedy will reduce mobility of the contaminants through
       the use of the clay-lined impoundment system.  An improved cap will
       further reduce the likelihood of infiltration of surface water causing the
       contaminants to migrate.

       The original remedy's use of in-situ stabilization would have increased
       the volume of material significantly. The amended alternative is an
       improvement in that the volume of contamination will actually be
       decreased through the dewatering of the polishing basin and
       impoundment areas.

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3.     Short-Term Effectiveness

       Short-term effectiveness evaluates the length of time needed to
       implement each segment of the alternatives. The EPA considers the
       risks that a particular activity may pose to site workers, nearby residents,
       or the local environment.  Short-term effectiveness involves the period
       of time needed to achieve protection and considers 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.

       The amended remedy requires less disturbance of the contaminated
       sediments in the impoundment areas, thereby,  reducing their agitation
       and potential for release of emissions of hydrogen sulfide gas which may
       affect on-site workers and nearby residents. The previously selected
       remedy anticipated the use of a large-scale auger which would have
       significantly disturbed the sediments and resulted in releases of high
       levels of hydrogen sulfide gas into the air.  Based on air sampling and
       modeling, the levels of hydrogen sulfide released during the action of
       mixing impoundment sediments with solidification agents as. specified in
       the original ROD would exceed worker permissible exposure limits as
       defined by NIOSH and OSHA. In addition, air dispersion modeling
       indicates that when conducting the original ROD there would be
       a reasonable likelihood that hydrogen sulfide emissions at the site
       perimeter would exceed the permissible exposure levels for hydrogen
       sulfide established by ATSDR.

4.     Implementability

       The EPA considers how difficult the alternative is to construct and
       operate, how other government agencies and EPA will coordinate
       monitoring programs and the availability of goods and services and
       personnel needed to implement and manage the alternative.
       Implementability addresses the technical and administrative feasibility of
       a remedy, including the availability of materials and services needed to
       implement the chosen solution.

       Given the potential for releases of high levels of hydrogen sulfide gas
       into the atmosphere, the original remedy is no  longer as readily
       implementable.  Higher levels of worker protection would be necessary.
       This would increase the time necessary to implement the remedy and add
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       an additional risk factor which must be accounted for in completing the
       effort.  The amended remedy is readily implementable in that dewatering
       the impoundment areas can be implemented more easily than dewatering
       followed by solidification.  In addition, the amended remedy minimizes
       the disturbance of the areas lowering the threat of hydrogen sulfide gas
       releases.  Therefore, special provisions for dealing with these releases
       can be eliminated. Because of the increased concern over the releases of
       hydrogen sulfide gas, the original remedy would have taken longer to
       complete; however, the amended remedy should be able to be completed
       in the original time frame (44 weeks).
5.     Cost
       The EPA considers capital costs, operation and maintenance costs, and
       present worth, which is the cost of the activities that will take place until
       the remedial action is completed.  Capital costs apply to activities such
       as construction, land and site development, and disposal of waste
       materials.  Annual operation and maintenance costs are spent on
       activities such as on-going operation of equipment, insurance and
       periodic site reviews.

       The CERCLA requires that the EPA select a cost-effective alternative
       that protects human health and the environment and meets other
       requirements of the law.  The EPA has determined that the selected
       remedy is as protective and in some cases more protective of human
       health and is more

       cost effective to implement. The estimated capital cost for the original
       remedy was $4,621,300 and Operation & Maintenance cost for 30 years
       of $21,000 per year. Costs are estimated to have increased through
       inflation to approximately $5,574,000 using today's pricing data for the
       same remedy. The original remedy's cost estimate did not include the
       cost for remediating the wet well, aeration basin, final clarifier, filter
       press building or miscellaneous contaminated soils nor did it include
       dewatering and treatment of the total volume of water now contained in
       the impoundment areas. The potential for hydrogen sulfide emission
       would also increase the cost of implementing the original remedy in that
       a higher level of worker protection would be needed during construction
       activities.  This higher level of protection would cause work to proceed
       at a slower pace increasing the overall time needed to complete the
       remediation. The increased time on-site would increase the labor costs
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                    associated with the construction causing the overall costs to be even
                    higher than the estimate above.

                    The preliminary cost estimate to implement the amended remedy is
                    $2,661,593 depending on the amount of consolidation of the
                    contamination that is possible. This estimate also includes remediation of
                    all areas identified in the original remedy plus the wet well, aeration
                    basin, final clarifier, filter press building and miscellaneous
                    contaminated soils.   This estimate prices out the remediation of the
                    northeast field as a separate containment cell, but does assume that a
                    moderate amount of consolidation of the contaminated areas is possible.
                    When these factors are taken into consideration, the cost to implement
                    the amended remedy is significantly less than the cost to implement the
                    original remedy. In addition, if a geosynthetic cap is utilized, Operation
                    & Maintenance (O&M) costs could be reduced since there are minimal
                    costs associated with long term maintenance of synthetic caps. Overall,
                    the amended remedy is seen'to be a more cost effective remedy
                    providing equivalent or greater protection to human health and the
                    environment.
       C.    Modifying Criteria:

             1.    State Acceptance
                   The state of Iowa, through the Iowa Department of Natural Resources
                   (IDNR), is supportive of the amended remedy for this site and prefers
                   this remedy to the originally selected remedy.
             2.    Community Acceptance

                   The EPA held a public comment period to allow the community to
                   comment on the preferred alternative as set forth in the proposed plan
                   and supported by the administrative record.  In addition, the EPA
                   notified the public regarding its willingness to conduct a public
                   availability session on the proposed plan.  The EPA did not receive any
                   comments regarding the proposed ROD Amendment at the site nor
                   requests to conduct a public meeting.

      In comparing the original remedy with the amended remedy, the EPA has determined
that the original and amended remedy meet the threshold criteria, overall protection of human
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health and the environment, and compliance with state and federal requirements.

       The amended remedy presents the better balance of tradeoffs, with respect to the
primary balancing criteria, in particular with respect to implementability and cost. In addition,
the amended remedy continues to be protective of human health and reduces mobility of the
contamination by providing an improved capping system. For the modifying criteria of state
and community acceptance, the amended alternative is preferred.  In the tradeoff and balancing
of all nine criteria, the amended remedy is EPA's preferred remedy.

VI.    STATUTORY DETERMINATIONS

       The EPA has determined, and the state of Iowa concurs, that the selected amended
remedy herein satisfies the statutory requirements specified in CERCLA Section 121 which
state that the selected remedy must protect human health and the environment and comply with
applicable or relevant and appropriate federal and state requirements.  In addition, the
remedy, as amended, utilizes permanent solutions and alternative treatment technologies to the
maximum extent practicable for this site.  These changes to the remedy will increase
protectiveness of human health and environment, both short term and long term.
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                              ATTACHMENT A

                        RESPONSIVENESS SUMMARY
                    RECORD OF DECISION AMENDMENT
            MID-AMERICA TANNING COMPANY SUPERFUND SITE

      In accordance with CERCLA Section 117, a public comment period was held from May
13, 1996 to June 11, 1996, to receive comments from interested patties on the EPA's proposed
plan for the Record of Decision Amendment for the Mid America Tanning Company Superfund
Site, Sergeant Bluff, Iowa. The EPA received no written comments on the proposed plan.

      The EPA offered to hold a public meeting if requested. No requests for a public meeting
were received.

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