EPA/ROD/R07-89/031
1989
EPA Superfund
Record of Decision:
KEM-PEST LABORATORIES
EPA ID: MOD980631113
OU01
CAPE GIRARDEAU, MO
09/29/1989
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ALDRIN, DIELDRIN, 2,4-DICHLOROPHENOXYACETIC ACID (2,4-D), ENDRIN, HEPTACHLOR, METHYL PARATHION
AND THIURAM.
THE PLANT WASTES WERE DISPOSED OF IN THE ONSITE LAGOON. THE LAGOON WAS BACKFILLED WITH CLAY BY
THE PROPERTY OWNER IN 1981. THERE HAVE BEEN NO PRODUCTION, TREATMENT OR DISPOSAL ACTIVITIES AT
THE SITE SINCE 1977. THE BUILDING HAS BEEN USED FOR STORAGE OF EQUIPMENT AND MATERIALS.
THE US ENVIRONMENTAL PROTECTION AGENCY (EPA) CONDUCTED A PRELIMINARY ASSESSMENT OF THE FACILITY
IN SEPTEMBER 1981. EROSION OF THE LAGOON COVER AND CHEMICAL ODORS WERE NOTED. IN MARCH 1983,
SOIL SAMPLES WERE OBTAINED FROM THE LAGOON AREA AND GROUND WATER SAMPLES WERE COLLECTED FROM THE
PLANT PRODUCTION WELL AND TWO PRIVATE WELLS IN THE AREA. PESTICIDE CONTAMINATION WAS DETECTED IN
THE SOIL SAMPLES; NO CONTAMINATION WAS IDENTIFIED IN THESE WELLS.
IN APRIL 1984, EPA INSTALLED FIVE MONITORING WELLS ONSITE AND COLLECTED GROUND WATER, SOIL AND
SEDIMENT SAMPLES. PESTICIDES, VOLATILE AND SEMIVOLATILE ORGANICS WERE DETECTED IN SOIL,
SEDIMENT AND GROUND WATER ONSITE. THE KEM-PEST SITE WAS PROPOSED FOR THE NATIONAL PRIORITIES
LIST (NPL) IN JANUARY 1987.
PURSUANT TO AN ADMINISTRATIVE ORDER ON CONSENT ENTERED INTO IN NOVEMBER 1988, THE POTENTIALLY
RESPONSIBLE PARTIES (PRPS) CONDUCTED SAMPLING OF SOILS FROM THE LAGOON AND THE FORMULATION
BUILDING IN DECEMBER 1988.
IN FEBRUARY AND MARCH 1989, EPA CONDUCTED THE RI FIELD ACTIVITIES WHICH INCLUDED COLLECTION OF
SOIL AND SEDIMENT SAMPLES, INSTALLATION OF SIX DOWNGRADIENT MONITORING WELLS, AND COLLECTION OF
GROUND WATER SAMPLES FROM ONSITE AND OFFSITE MONITORING WELLS AND TWO PRIVATE WELLS IN THE
IMMEDIATE AREA.
#CPA
4.0 COMMUNITY PARTICIPATION ACTIVITIES
PRIOR TO THE INITIATION OF THE RI, A COMMUNITY RELATIONS PLAN WAS DEVELOPED BASED ON INTERVIEWS
CONDUCTED BY THE COMMUNITY RELATIONS STAFF WITH RESIDENTS AND LOCAL OFFICIALS. THE PLAN
DOCUMENTED THE ISSUES OF CONCERN TO THE COMMUNITY AND OUTLINED FUTURE COMMUNITY RELATIONS
ACTIVITIES.
AT THE START OF RI FIELD ACTIVITIES, THE EPA REMEDIAL PROJECT MANAGER MET WITH THE CAPE
GIRARDEAU COUNTY COMMISSION AND OTHER LOCAL COUNTY AND CITY OFFICIALS TO DISCUSS THE FIELD WORK.
THE PROJECT MANAGER ALSO CONDUCTED INFORMAL INTERVIEWS AT NEARBY RESIDENCES TO INFORM THEM OF
SITE ACTIVITIES AND TO ANSWER QUESTIONS. FACT SHEETS ABOUT THE PROJECT WERE MAILED TO
RESIDENTS, LOCAL OFFICIALS AND THE MEDIA. DURING FIELD WORK, NEARBY RESIDENTS AND LOCAL
OFFICIALS WERE PROVIDED UPDATED INFORMATION ON ACTIVITIES.
IN AUGUST 1989, THE RI AND OUFS REPORTS AND PROPOSED PLAN WERE MADE AVAILABLE TO THE PUBLIC IN
THE ADMINISTRATIVE RECORD LOCATED AT THE CAPE GIRARDEAU PUBLIC LIBRARY AND AT EPA REGION VII
OFFICES IN KANSAS CITY. A PUBLIC NOTICE WAS ISSUED ANNOUNCING THE AVAILABILITY OF DOCUMENTS, THE
START OF THE PUBLIC COMMENT PERIOD AND THE DATE OF THE PUBLIC MEETING. THE PUBLIC NOTICE WAS
PUBLISHED IN THE SOUTHEAST MISSOURIAN ON AUGUST 18, 1989, AND IN THE CAPE GIRARDEAU NEWS
GUARDIAN ON AUGUST 23, 1989.
FACT SHEETS WERE ALSO MAILED TO RESIDENTS, LOCAL OFFICIALS AND THE MEDIA ANNOUNCING THE
AVAILABILITY OF DOCUMENTS, THE PUBLIC COMMENT PERIOD AND THE PUBLIC MEETING.
THE PUBLIC COMMENT PERIOD WAS HELD FROM AUGUST 18, 1989, THROUGH SEPTEMBER 18, 1989. A PUBLIC
MEETING WAS HELD IN CAPE GIRARDEAU ON SEPTEMBER 5, 1989. AT THE MEETING, REPRESENTATIVES FROM
EPA, THE AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY (ATSDR) AND THE MISSOURI DEPARTMENT OF
NATURAL RESOURCES (MDNR) PROVIDED INFORMATION ON THE SITE AND DISCUSSED THE REMEDIAL
ALTERNATIVES UNDER CONSIDERATION. DURING AN EXTENSION OF THE COMMENT PERIOD, THE EPA COMMUNITY
RELATIONS STAFF CONDUCTED INTERVIEWS WITH CONCERNED CITIZENS.
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A RESPONSE TO COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD IS PROVIDED IN THE
RESPONSIVENESS SUMMARY, WHICH IS A PART OF THIS RECORD OF DECISION.
#SROU
5.0 SCOPE AND ROIiE OF OPERABLE UNIT
REMEDIAL ACTION AT THE KEM-PEST SITE WILL BE IMPLEMENTED THROUGH A SERIES OF OPERABLE UNITS, OR
DISCRETE ACTIONS. THE PHASING OF CLEANUP ACTIONS WILL PROVIDE THE OPPORTUNITY TO ACHIEVE
SIGNIFICANT RISK REDUCTION MORE QUICKLY THAN ADDRESSING THE ENTIRE SITE AT ONE TIME. THIS FIRST
OPERABLE UNIT ADDRESSES CONTAMINATED SOIL AND SEDIMENT. FUTURE OPERABLE UNITS WILL ADDRESS
GROUND WATER AND THE FORMULATION BUILDING.
THIS FIRST OPERABLE UNIT ADDRESSES CONTAMINATED SUBSURFACE SOIL IN THE LAGOON, SURFACE SOIL IN
THE LAGOON AREA AND NEAR THE FORMULATION BUILDING, AND SEDIMENT IN DRAINAGE CHANNELS ON AND OFF
THE SITE. THESE AREAS POSE THE PRINCIPAL THREAT TO HUMAN HEALTH AND THE ENVIRONMENT DUE TO THE
POTENTIAL FOR DERMAL CONTACT, INGESTION AND INHALATION.
THE OBJECTIVES OF THIS FIRST OPERABLE UNIT ARE TO REMOVE OR REDUCE TO A PROTECTIVE LEVEL THE
RISKS POSED BY DERMAL CONTACT, INGESTION OR INHALATION OF CONTAMINATED SOIL AND SEDIMENT, TO
ELIMINATE OR REDUCE THE POTENTIAL FOR OFFSITE TRANSPORT OF CONTAMINATED MATERIAL, AND TO
REMEDIATE CONTAMINATED SOIL AND SEDIMENT IN A MANNER WHICH WILL NOT ADVERSELY AFFECT FUTURE
REMEDIAL ACTIONS, IF REQUIRED.
#ssc
6.0 SUMMARY OF SITE CHARACTERISTICS
THE EPA CONDUCTED RI FIELD WORK IN FEBRUARY AND MARCH 1989 TO DETERMINE THE NATURE AND EXTENT OF
CONTAMINATION AND THE NEED FOR REMEDIAL ACTION. THE PRPS ALSO CONDUCTED SAMPLING IN DECEMBER
1988. THIS SECTION SUMMARIZES INFORMATION OBTAINED BY THESE ACTIVITIES; SOIL SAMPLE LOCATIONS
AND RESULTS ARE PROVIDED IN ATTACHMENT A.
6.1 NATURE AND EXTENT OF CONTAMINATION
SUBSURFACE SOIL
TEN BORINGS WERE DRILLED IN THE AREA OF THE LAGOON, RANGING FROM 3 TO 14 FEET IN DEPTH. A TOTAL
OF 28 SUBSURFACE SOIL SAMPLES WERE SUBMITTED FOR ANALYSIS.
BASED ON THE BORING DATA, PESTICIDE CONCENTRATIONS GENERALLY DECREASED WITH DEPTH BELOW THE BASE
OF THE LAGOON (5-6 FEET BELOW THE SURFACE). CONTAMINATION WAS GREATEST IN THE 6-9 FOOT LEVEL.
PESTICIDES IDENTIFIED MOST OFTEN AND AT HIGHEST CONCENTRATIONS INCLUDED GAMMA-CHLORDANE (74,500
MICROGRAMS PER KILOGRAM (UG/KG)), HEPTACHLOR (45,700 UG/KG), AND ENDRIN (14,000 UG/KG).
VOLATILE ORGANICS IDENTIFIED FREQUENTLY AND AT THE HIGHEST CONCENTRATIONS INCLUDED XYLENES
(28,000 UG/KG), ETHYLBENZENE (5000 UG/KG), AND 1,2-DICHLOROETHANE (700 UG/KG). CONCENTRATIONS
GENERALLY INCREASED WITH DEPTH BELOW THE LAGOON, WITH MAXIMUM LEVELS BELOW THE GROUND WATER
TABLE. SEMIVOLATILES DETECTED INCLUDED PENTACHLOROPHENOL (19,000 UG/KG) AND 2,4-DICHLOROPHENOL
(8600 UG/KG); SEMIVOLATILES GENERALLY DECREASED WITH DEPTH. THE ONLY METAL OF CONCERN TO HEALTH
DETECTED ABOVE REGIONAL MAXIMUM BACKGROUND LEVELS WAS ARSENIC AT 160 MILLIGRAMS (MG)/KG.
SURFACE SOIL
TO BETTER CHARACTERIZE THE ENTIRE SITE, 26 COMPOSITE SAMPLES WERE COLLECTED FROM TWO GRID
SYSTEMS AND ANALYZED FOR PESTICIDES. ONE GRID CONSISTED OF 50 BY 50 FOOT SQUARES IN THE AREA OF
THE LAGOON AND FORMULATION BUILDING WITH SAMPLES OBTAINED FROM 0-6 AND 6-12 INCHES. THE SECOND
GRID CONSISTED OF 100 BY 100 FOOT SQUARES OVER AREAS WHICH MAY HAVE BEEN AFFECTED BY SITE
OPERATIONS; SAMPLES WERE OBTAINED FROM THE 0-6 INCH DEPTH.
FOR THE 0-6 INCH DEPTH INTERVAL, PESTICIDE CONTAMINATION WAS GREATEST IN GRIDS ADJACENT TO THE
BUILDING. PESTICIDES DETECTED MOST OFTEN AND AT THE HIGHEST CONCENTRATIONS INCLUDED HEPTACHLOR
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(76,000 UG/KG) , DIELDRIN (58,000 UG/KG) AND GAMMA-CHLORDANE (39,000 UG/KG) . FOR THE 6-12 INCH
INTERVAL, CONTAMINATION WAS ALSO GREATEST IN GRIDS NEAR THE BUILDING; HEPTACHLOR (94,000 UG/KG),
GAMMA-CHLORDANE (80,000 UG/KG) AND ENDRIN (26,000 UG/KG).
DISCRETE SURFACE SOIL SAMPLES FROM 0-6 INCHES WERE OBTAINED FROM SEVERAL SITE LOCATIONS
INCLUDING SOUTHEAST OF THE LAGOON, THE STORAGE TANK AREA AND SCRAPE PILE AREA. ANALYSES
INCLUDED VOLATILES, SEMIVOLATILES, PESTICIDES, TOTAL METALS AND CYANIDE.
HEPTACHLOR AT 32,000 UG/KG AND GAMMA-CHLORDANE AT 21,000 UG/KG WERE DETECTED IN SOIL SOUTHEAST
OF THE LAGOON. RELATIVELY LOW PESTICIDE CONCENTRATIONS WERE FOUND AT THE OTHER LOCATIONS.
VOLATILES AND SEMIVOLATILES WERE NOT DETECTED AT SIGNIFICANT LEVELS. ARSENIC (170 MG/KG) AND
LEAD (110 MG/KG) WERE DETECTED AT ONE LOCATION, EXCEEDING SITE BACKGROUND AND REGIONAL MAXIMUM
CONCENTRATIONS.
SEDIMENT
COMPOSITE SEDIMENT SAMPLES AT DEPTHS OF 0-6 AND 6-12 INCHES WERE COLLECTED BY EPA IN DRAINAGE
CHANNELS ON THE KEM-PEST PROPERTY AND IN THE OFFSITE DRAINAGE CHANNEL IMMEDIATELY SOUTHEAST OF
THE PROPERTY (PARALLEL TO THE RAILROAD TRACKS) TO ASSESS THE EXTENT OF CONTAMINANT MIGRATION.
THE COMPOSITE SEDIMENT SAMPLES WERE ANALYZED FOR PESTICIDES.
PESTICIDE CONCENTRATIONS ABOVE BACKGROUND WERE DETECTED IN ALL BUT ONE SAMPLE. SIGNIFICANT
CONCENTRATIONS WERE DETECTED IN DRAINAGE CHANNELS FROM THE SOUTH CORNER OF THE BUILDING AND FROM
THE SOUTHEAST CORNER OF THE LAGOON.
THE HIGHEST CONCENTRATIONS FOR THE 0-6 INCH INTERVAL WERE DETECTED IN THE OFFSITE CHANNEL WHICH
RUNS PARALLEL TO THE TRACKS. THE CHANNEL SEGMENT LOCATED SOUTHEAST OF THE BUILDING HAD THE
HIGHEST CONCENTRATIONS (20,000 UG/KG HEPTACHLOR, 58,000 UG/KG ALDRIN, 34,000 UG/KG DIELDRIN AND
26,000 UG/KG GAMMA-CHLORDANE). CONCENTRATIONS IN THIS CHANNEL GENERALLY DECREASED WITH DISTANCE
DOWNGRADIENT (TO THE SOUTHWEST).
SIGNIFICANT CONTAMINATION WAS DETECTED IN 6-12 INCH SAMPLES FROM THE SAME DRAINAGE CHANNELS
IDENTIFIED ABOVE. THE HIGHEST CONCENTRATIONS WERE ALSO IN THE OFFSITE CHANNEL, WITH LEVELS
AGAIN GENERALLY DECREASING TO THE SOUTHWEST.
6.2 CONTAMINANT FATE AND TRANSPORT
BASED ON THE RESULTS OF THE SITE INVESTIGATIONS, SOURCES OF CONTAMINATION ARE THE WASTE DISPOSAL
LAGOON AND AREAS WHERE HAZARDOUS SUBSTANCES MAY HAVE SPILLED OR LEAKED WHICH INCLUDE THE
FORMULATION BUILDING, STORAGE TANKS, LOADING AREAS AND PIPING TO THE LAGOON. THE LAGOON AND
SOIL SOUTH, SOUTHEAST AND SOUTHWEST OF THE BUILDING APPEAR TO BE THE MOST SIGNIFICANTLY
CONTAMINATED.
THE POTENTIAL ROUTES OF MIGRATION INCLUDE INFILTRATION AND DIRECT MIGRATION THROUGH SURFACE AND
SUBSURFACE SOIL, GROUND WATER TRANSPORT, EROSION AND SURFACE RUNOFF, AND AIR TRANSPORT.
THE SUBSURFACE CONDITIONS AT THE SITE INDICATE THAT SORPTION WILL RETARD THE MIGRATION OF
CONTAMINANTS DUE TO THE ORGANIC CONTENT AND LOW HYDRAULIC CONDUCTIVITY OF THE ALLUVIAL MATERIAL.
RESIDUAL CONTAMINATION BY THE MORE STRONGLY ADSORBED COMPOUNDS MAY REMAIN FOR DECADES IN THE
ALLUVIAL MATERIAL. SUBSURFACE CONTAMINATION IN THE LAGOON AREA REMAINS A SOURCE THAT COULD
CONTINUE TO RELEASE CONTAMINANTS TO GROUND WATER THROUGH INFILTRATION AND LEACHING MECHANISMS.
THE ORGANOCHLORINE PESTICIDES ARE VERY INSOLUBLE IN WATER AND ARE READILY ADSORBED TO SOIL
PARTICLES. THESE PESTICIDES ARE VERY IMMOBILE AND ARE EXTREMELY PERSISTENT. BIODEGRADATION
DOES NOT OCCUR SIGNIFICANTLY IN THE FIELD. VOLATILE ORGANICS ARE GENERALLY WATER SOLUBLE AND
LESS READILY ADSORBED TO THE SOIL AND ARE MORE MOBILE IN GROUND WATER SYSTEMS THAN PESTICIDES.
THE SOLUBILITY AND ADSORPTIVE TENDENCIES OF SEMIVOLATILE COMPOUNDS FALL BETWEEN THOSE OF THE
PESTICIDES AND THE VOLATILES.
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SURFACE RUNOFF MAY TRANSPORT CONTAMINANTS EITHER IN SOLUTION OR ADSORBED TO ERODED SOIL
PARTICLES. THE POTENTIAL MECHANISMS FOR AIR TRANSPORT OF CONTAMINANTS ARE VOLATILIZATION AND
FUGITIVE EMISSIONS OF PARTICULATES ON WHICH CONTAMINANTS ARE ADSORBED.
#SSR
7.0 SUMMARY OF SITE RISKS
TO EVALUATE THE POTENTIAL IMPACTS TO HUMAN HEALTH IN THE ABSENCE OF REMEDIAL ACTION, A RISK
ASSESSMENT WAS CONDUCTED AS PART OF THE RI. BOTH CURRENT AND FUTURE LAND USE SCENARIOS WERE
EVALUATED. THIS SECTION SUMMARIZES THE AGENCY'S FINDINGS CONCERNING RISKS FROM EXPOSURE TO
CONTAMINATED SOILS AND SEDIMENT AT THE SITE. THE COMPLETE RISK ASSESSMENT IS CONTAINED IN
VOLUME II OF THE RI REPORT.
METHODOLOGY
A TOTAL OF 39 CHEMICALS DETECTED IN THE SOIL AND SEDIMENT WERE IDENTIFIED AS CHEMICALS OF
CONCERN. A SUMMARY TABLE OF THE CHEMICALS OF CONCERN IS PROVIDED IN ATTACHMENT B.
EXPOSURE PATHWAYS BY WHICH HUMANS COULD BE EXPOSED TO CHEMICALS OF CONCERN WERE IDENTIFIED BASED
ON REASONABLE ASSUMPTIONS REGARDING CURRENT AND FUTURE USES OF THE SITE. FOR CURRENT LAND-USE
CONDITIONS, DIRECT CONTACT WITH SURFACE SOILS AND SEDIMENTS BY CHILDREN TRESPASSING ONTO THE
SITE WAS EVALUATED.
WITH RESPECT TO FUTURE LAND USES, BOTH RESIDENTIAL AND INDUSTRIAL LAND USES WERE EVALUATED. FOR
FUTURE RESIDENTIAL USE, DIRECT CONTACT WITH SOILS AND SEDIMENTS WERE EVALUATED, IN ADDITION TO
POTENTIAL INHALATION EXPOSURES. FOR FUTURE INDUSTRIAL LAND-USE CONDITIONS, BOTH DIRECT CONTACT
AND INHALATION EXPOSURES WERE ALSO EVALUATED.
IN ORDER TO ASSESS THESE EXPOSURES, DETECTED CONCENTRATIONS FROM SAMPLING OR, IN THE CASE OF
VOLATILIZATION OF CONTAMINANTS, CONTAMINANT TRANSPORT MODELING WAS USED TO ESTIMATE THE
CONCENTRATION AT THE EXPOSURE POINT.
CHRONIC DAILY INTAKES (GDIS) TO HUMANS WERE ESTIMATED BY USING THE EXPOSURE POINT CONCENTRATIONS
AND EXPOSURE PARAMETERS (SUCH AS SOIL INGESTION RATES AND FREQUENCY OF EXPOSURE) AVAILABLE FROM
EPA OR ASSUMED BASED ON REASONABLE ASSUMPTIONS ABOUT POTENTIAL SITE USES. POTENTIAL EXPOSURES
WERE ESTIMATED USING AVERAGE PARAMETERS AND GEOMETRIC MEAN CONCENTRATIONS OF CHEMICALS TO DERIVE
AN AVERAGE CASE EXPOSURE; THE MAXIMUM CONCENTRATION AND HIGHER EXPOSURE PARAMETERS WERE USED TO
CALCULATE A MAXIMUM PLAUSIBLE CASE EXPOSURE. MAXIMUM CONCENTRATIONS WERE USED IN CASES WHERE
MEAN CONCENTRATIONS WERE NOT AVAILABLE.
EXCESS LIFETIME CANCER RISKS WERE ESTIMATED FOR EACH EXPOSURE CASE USING GDIS AND
CHEMICAL-SPECIFIC CANCER POTENCY FACTORS. A CANCER RISK LEVEL OF 1 X 10-7, THE LOWEST END OF
THE RISK RANGE THAT EPA CONSIDERS PROTECTIVE OF HUMAN HEALTH, WAS USED AS A BENCHMARK FOR
COMPARISON TO THE ESTIMATED CANCER RISK LEVELS. POTENTIAL RISKS OF NONCARCINOGENIC HEALTH
EFFECTS WERE ESTIMATED BY COMPARING THE GDIS TO THE REFERENCE DOSES (RFDS). THE HAZARD INDEX
(HI) IS THE SUM OF THE CDI:RFD RATIOS FOR ALL THE CHEMICALS EVALUATED IN A GIVEN AREA. IN
GENERAL, HAZARD INDICES WHICH ARE LESS THAN ONE ARE NOT LIKELY TO BE ASSOCIATED WITH ANY HEALTH
RISKS.
RISK ASSESSMENT RESULTS
THE RESULTS OF THE RISK ASSESSMENT INDICATE THAT CONCENTRATIONS OF CONTAMINANTS IN SOIL AND
SEDIMENT AT SEVERAL LOCATIONS ON AND ADJACENT TO THE SITE RESULT IN EXCESS LIFETIME CANCER RISKS
AS HIGH AS 7 X (10-5) FOR CURRENT LAND USE AND 1 X 10 (-3) FOR FUTURE RESIDENTIAL LAND USE. THE
ESTIMATED RISKS OF CANCER AND NONCARCINOGENIC RISKS ARE SUMMARIZED BY LAND USE AND EXPOSURE
PATHWAY IN ATTACHMENT B.
THE EPA HAS DETERMINED THAT ACTUAL OR THREATENED RELEASES OF HAZARDOUS SUBSTANCES FROM THIS
SITE, IF NOT ADDRESSED BY REMEDIAL ACTION, MAY PRESENT A CURRENT OR POTENTIAL THREAT TO PUBLIC
HEALTH, WELFARE, OR THE ENVIRONMENT.
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#DA
8.0 DESCRIPTION OF ALTERNATIVES
THE REMEDIAL ALTERNATIVES EVALUATED IN DETAIL IN THE OUFS REPORT ARE DESCRIBED BELOW. THIS
DESCRIPTION IDENTIFIES ENGINEERING COMPONENTS, INSTITUTIONAL CONTROLS, IMPLEMENTATION
REQUIREMENTS, ESTIMATED COSTS, AND MAJOR APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
(ARARS) ASSOCIATED WITH EACH OPTION.
8.1 NO ACTION
AS REQUIRED BY THE NATIONAL CONTINGENCY PLAN, THE NO ACTION ALTERNATIVE WAS EVALUATED. THIS
ALTERNATIVE PROVIDES A BASELINE FOR COMPARING THE EFFECTIVENESS OF THE OTHER REMEDIAL
ALTERNATIVES. UNDER THIS OPTION, NO FURTHER ACTION WOULD BE TAKEN TO PREVENT EXPOSURE TO
CONTAMINATED SOIL AND SEDIMENT OR MIGRATION OF CONTAMINATION FROM THE SITE. THE SITE WOULD
REMAIN IN ITS PRESENT CONDITION. THERE WOULD BE NO COSTS ASSOCIATED WITH THIS ALTERNATIVE.
8.2 EXCAVATION AND ONSITE INCINERATION
THIS ALTERNATIVE WOULD INCLUDE THE EXCAVATION AND THERMAL TREATMENT OF APPROXIMATELY 4,050 CUBIC
YARDS OF CONTAMINATED SOIL AND SEDIMENT. THE AMOUNT OF CONTAMINATED MATERIAL TO BE EXCAVATED
WAS DETERMINED BY CALCULATING PROTECTIVE SOIL CONTAMINANT CONCENTRATIONS BASED ON THE MAXIMUM
CASE EXPOSURE CONDITIONS FOR FUTURE RESIDENTIAL USE OF THE SITE FOR A CANCER RISK LEVEL OF 1 X
10 (-5). A MORE DETAILED DISCUSSION REGARDING THE DETERMINATION OF PROTECTIVE SOIL
CONCENTRATIONS IS PROVIDED IN SECTION 10.2. AREAS REQUIRING EXCAVATION ARE IDENTIFIED IN FIGURE
C-l IN ATTACHMENT C.
SOIL AND SEDIMENT WITH CONTAMINANT CONCENTRATIONS ABOVE THE PROTECTIVE SOIL CONCENTRATIONS WOULD
BE EXCAVATED USING CONVENTIONAL EARTHMOVING EQUIPMENT THEN THERMALLY TREATED IN AN ONSITE MOBILE
INCINERATOR. ENGINEERING CONTROLS SUCH AS DUST SUPPRESSANTS AND BERMS WOULD BE IMPLEMENTED
DURING EXCAVATION TO MINIMIZE FUGITIVE DUST AND SURFACE RUNOFF.
SOIL SAMPLING WOULD BE CONDUCTED TO CONFIRM THAT THE HORIZONTAL AND VERTICAL EXTENT OF
EXCAVATION WAS SUFFICIENT TO REMOVE CONTAMINATION ABOVE CLEANUP LEVELS. FOLLOWING EXCAVATION,
CLEAN SOIL WOULD BE PLACED IN THE EXCAVATED AREAS, COMPACTED AND GRADED. VEGETATION OR GRAVEL
WOULD BE APPLIED TO MINIMIZE EROSION.
ADDITIONAL SITE ACTIVITIES WOULD INCLUDE SITE PREPARATION FOR THE MOBILE INCINERATOR AND ONSITE
ASSEMBLY OF THE INCINERATOR AND MATERIAL HANDLING EQUIPMENT. OPERATION OF THE UNIT WOULD
INCLUDE SAFETY AND EMISSIONS CONTROL EQUIPMENT. COMPLETION OF REMEDIATION ACTIVITIES WOULD
INCLUDE DEMOBILIZATION OF THE INCINERATION FACILITY, DECONTAMINATION AND REMOVAL OF TEMPORARY
STRUCTURES, EQUIPMENT, ETC., AND REGRADING AND SEEDING.
THIS ALTERNATIVE WOULD COMPLY WITH THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
REQUIREMENTS AND TECHNICAL STANDARDS OF 40 CFR PART 264. RESIDUAL ASH WOULD BE DELISTED AS A
HAZARDOUS WASTE TO ALLOW DISPOSAL IN A SANITARY LANDFILL OFFSITE. THE ALTERNATIVE WOULD COMPLY
WITH THE CLEAN AIR ACT AND OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) REQUIREMENTS.
STATE REQUIREMENTS WOULD INCLUDE THE MISSOURI AIR CONSERVATION LAW, MISSOURI AIR POLLUTION
CONTROL REGULATIONS, AND THE MISSOURI AIR QUALITY STANDARDS.
THE ESTIMATED TIME TO IMPLEMENT THIS ALTERNATIVE WAS APPROXIMATELY 27 MONTHS WHICH INCLUDES 5
MONTHS FOR EXCAVATION AND INCINERATION AND 12 FOR DELISTING. THE PRESENT WORTH COST FOR THIS
OPTION, REVISED BASED ON ADDITIONAL INFORMATION PRESENTED DURING THE PUBLIC COMMENT PERIOD, WAS
ESTIMATED AT APPROXIMATELY $7.6 MILLION.
8.3 EXCAVATION AND OFFSITE INCINERATION
AN OFFSITE PERMITTED HAZARDOUS WASTE INCINERATION FACILITY WOULD BE USED TO THERMALLY TREAT THE
4,050 CUBIC YARDS OF CONTAMINATED SOIL AND SEDIMENT. EXCAVATION AND RESTORATION ACTIVITIES
WOULD BE PERFORMED AS PREVIOUSLY DESCRIBED.
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AS REQUIRED BY COMMERCIAL FACILITIES, CONTAMINATED SOIL WOULD BE PLACED IN FIBER DRUMS AND
TRANSPORTED IN 15-20 CUBIC YARD TRUCKS TO THE OFFSITE INCINERATOR. THE EXTERIOR OF TRUCKS WOULD
BE DECONTAMINATED PRIOR TO LEAVING THE SITE. WASTE MANIFESTS WOULD ACCOMPANY THE WASTE
SHIPMENTS. FOLLOWING INCINERATION, RESIDUAL ASH WOULD BE DISPOSED OF BY THE OFFSITE TREATMENT
FACILITY.
THE OFFSITE TRANSPORTATION OF HAZARDOUS MATERIALS WOULD COMPLY WITH DEPARTMENT OF TRANSPORTATION
(DOT) AND RCRA PART 263 REQUIREMENTS. OSHA REQUIREMENTS FOR THE PROTECTION OF WORKERS WOULD BE
MET. THE OFFSITE RCRA FACILITY MUST BE IN COMPLIANCE WITH THE CERCLA OFFSITE POLICY.
THE TIME REQUIRED TO IMPLEMENT THIS ALTERNATIVE WAS ESTIMATED TO BE 11-29 MONTHS. THE
VARIABILITY IS DUE TO THE AVAILABILITY AND CAPACITY OF THE OFFSITE INCINERATOR. THE PRESENT
WORTH COST FOR THIS ALTERNATIVE WAS ESTIMATED TO BE APPROXIMATELY $16.5 MILLION.
8.4 EXCAVATION AND ONSITE LANDFILL
A RCRA HAZARDOUS WASTE LANDFILL WOULD BE CONSTRUCTED ONSITE TO DISPOSE OF THE 4,050 CUBIC YARDS
OF CONTAMINATED MATERIAL. AS REQUIRED BY RCRA, THE UNIT WOULD BE CONSTRUCTED ABOVE GRADE TO
MAINTAIN A SEPARATION OF AT LEAST 10 FEET BETWEEN THE BOTTOM OF THE LANDFILL AND THE SHALLOW
GROUND WATER AT THE SITE. EXCAVATION AND RESTORATION WOULD BE PERFORMED AS PREVIOUSLY DESCRIBED.
THE MAJOR LANDFILL COMPONENTS WOULD INCLUDE A MULTILINER SYSTEM, A LEACHATE COLLECTION AND
REMOVAL SYSTEM, AND A RCRA MULTILAYER CAP. POST-CLOSURE ACTIVITIES WOULD INCLUDE SEMI-ANNUAL
INSPECTIONS, CAP MAINTENANCE, AND GROUND WATER MONITORING. LAND AND GROUND WATER USE
RESTRICTIONS WOULD ALSO BE REQUIRED FOR THE ONSITE LANDFILL FACILITY.
THIS ALTERNATIVE WOULD COMPLY WITH THE LAND DISPOSAL RESTRICTIONS OF RCRA PART 268 SINCE
PLACEMENT OF A RCRA LISTED WASTE WOULD OCCUR. THE ONSITE LANDFILL WOULD COMPLY WITH THE
TECHNICAL STANDARDS AND POST-CLOSURE REQUIREMENTS OF RCRA PART 264 AND MISSOURI HAZARDOUS WASTE
MANAGEMENT LAW AND RULES. OSHA REQUIREMENTS FOR THE PROTECTION OF WORKERS WOULD BE MET.
THE ESTIMATED TIME REQUIRED TO IMPLEMENT THIS ALTERNATIVE WAS APPROXIMATELY 16-18 MONTHS. THE
PRESENT WORTH COST WAS ESTIMATED TO BE APPROXIMATELY $2.5 MILLION.
8.5 EXCAVATION AND OFFSITE LANDFILL
THIS ALTERNATIVE WOULD INVOLVE THE EXCAVATION OF THE 4,050 CUBIC YARDS OF CONTAMINATED MATERIAL
AND TRANSPORTATION TO A RCRA-APPROVED COMMERCIAL HAZARDOUS WASTE LANDFILL. EXCAVATION AND
RESTORATION WOULD BE PERFORMED AS PREVIOUSLY DESCRIBED.
CONTAMINATED MATERIAL WOULD BE TRANSPORTED TO THE OFFSITE FACILITY IN BULK SHIPMENTS BY COVERED
TRUCKS WITH CAPACITY TO HOLD UP TO 22 TONS. THE EXTERIOR OF THE TRUCKS WOULD BE DECONTAMINATED
PRIOR TO LEAVING THE SITE. WASTE MANIFESTS WOULD ACCOMPANY THE WASTE SHIPMENTS.
THE OFFSITE LANDFILL FACILITY MUST MEET THE RCRA TECHNOLOGY REQUIREMENTS FOR LAND DISPOSAL WHICH
INCLUDE DOUBLE LINER, LEACHATE DETECTION AND COLLECTION SYSTEM AND GROUND-WATER MONITORING.
THIS ALTERNATIVE MUST COMPLY WITH THE LAND DISPOSAL RESTRICTIONS OF RCRA PART 268 SINCE
PLACEMENT OF A RCRA-LISTED WASTE WOULD OCCUR. THE TRANSPORTATION OF HAZARDOUS WASTE MUST COMPLY
WITH DOT AND RCRA PART 263 REQUIREMENTS. OSHA REQUIREMENTS FOR THE PROTECTION OF WORKERS, AND
THE MISSOURI HAZARDOUS WASTE MANAGEMENT LAW AND RULES WOULD BE MET. THE OFFSITE FACILITY MUST
BE IN COMPLIANCE WITH THE CERCLA OFFSITE POLICY.
THE TIME REQUIRED TO IMPLEMENT THIS ALTERNATIVE WAS ESTIMATED TO BE 7-9 MONTHS. THE ESTIMATED
PRESENT WORTH COST WAS APPROXIMATELY $2.6 MILLION.
8.6 EXCAVATION AND CAPPING
THIS ALTERNATIVE WOULD INCLUDE EXCAVATION OF APPROXIMATELY 1,130 CUBIC YARDS OF CONTAMINATED
MATERIAL (OFFSITE DRAINAGE CHANNEL AND SOIL ALONG THE SOUTH-SOUTHEAST PORTION OF THE SITE) AND
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CONSOLIDATION ONSITE. A RCRA MULTILAYER CAP (COMPACTED CLAY, SYNTHETIC MEMBRANE, DRAINAGE LAYER
AND VEGETATIVE LAYER) WOULD BE PLACED OVER THE CONSOLIDATED MATERIAL AND OTHER AREAS WHERE THE
LEVELS OF CONTAMINANTS EXCEED PROTECTIVE SOIL CONCENTRATIONS. THE CAP WOULD EXTEND OVER SOME
AREAS WHICH DO NOT EXCEED CLEANUP LEVELS TO FACILITATE DRAINAGE AND DIVERT SURFACE WATER.
FOLLOWING CONSTRUCTION OF THE CAP, VEGETATION WOULD BE ESTABLISHED TO PREVENT EROSION.
LONG-TERM MAINTENANCE AND MONITORING WOULD BE REQUIRED. SEMIANNUAL INSPECTIONS, MONTHLY
MAINTENANCE AND GROUND WATER MONITORING WOULD BE PERFORMED. LAND AND GROUND WATER USE
RESTRICTIONS WOULD ALSO BE REQUIRED.
THIS ALTERNATIVE WOULD COMPLY WITH RCRA LANDFILL CLOSURE REQUIREMENTS IN PART 264. OSHA
REQUIREMENTS FOR WORKER PROTECTION WOULD ALSO BE MET.
THE TIME REQUIRED TO IMPLEMENT THIS ALTERNATIVE WAS ESTIMATED TO BE APPROXIMATELY 12 MONTHS.
THE PRESENT WORTH COST WAS ESTIMATED AT APPROXIMATELY $1.1 MILLION.
#SCAA
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
NINE EVALUATION CRITERIA HAVE BEEN DEVELOPED BY EPA TO ADDRESS CERCLA STATUTORY REQUIREMENTS AND
TECHNICAL, COST, AND INSTITUTIONAL CONSIDERATIONS. THE EVALUATION CRITERIA SERVE AS THE BASIS
FOR SELECTING AN APPROPRIATE REMEDIAL ACTION. THE REMEDIAL ALTERNATIVES DEVELOPED AND EVALUATED
IN THE OUFS ARE DESCRIBED BELOW IN RELATION TO THE EVALUATION CRITERIA.
9.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
WITH THE EXCEPTION OF THE NO-ACTION ALTERNATIVE, ALL THE ALTERNATIVES PROVIDE PROTECTION OF
HUMAN HEALTH AND THE ENVIRONMENT BY REMOVING, REDUCING, OR CONTROLLING RISK THROUGH TREATMENT,
ENGINEERING CONTROLS, OR INSTITUTIONAL CONTROLS. THE NO-ACTION ALTERNATIVE WILL NOT BE
DISCUSSED FURTHER SINCE IT IS NOT PROTECTIVE OF HUMAN HEALTH AND THE ENVIRONMENT.
BOTH ONSITE AND OFFSITE THERMAL TREATMENT OFFER THE SAME LEVEL OF PROTECTION. RISKS POSED BY
CONTAMINATED SOIL AND SEDIMENT ABOVE PROTECTIVE SOIL CONCENTRATIONS WOULD BE PERMANENTLY
ELIMINATED BY DESTRUCTION OF CONTAMINANTS THROUGH INCINERATION.
THE OFFSITE LANDFILL ALTERNATIVE WOULD ELIMINATE RISKS AT THE SITE BY THE EXCAVATION AND REMOVAL
OF CONTAMINATED SOIL AND SEDIMENT TO A RCRA-APPROVED OFFSITE HAZARDOUS WASTE LANDFILL. THE
OFFSITE LANDFILL, THROUGH CONTAINMENT, WOULD REDUCE RISKS POSED BY THE CONTAMINATED MATERIAL BY
REDUCING THE POTENTIAL FOR CONTAMINANT MIGRATION AND DIRECT CONTACT WITH OR INHALATION OF
CONTAMINANTS. RCRA TECHNICAL REQUIREMENTS FOR THE LANDFILL FACILITY INCLUDE DOUBLE LINER,
LEACHATE DETECTION AND COLLECTION SYSTEM AND MONITORING.
THE ONSITE LANDFILL AND CAPPING ALTERNATIVES WOULD NOT ELIMINATE RISKS AT THE SITE, BUT WOULD
REDUCE RISKS BY REDUCING THE POTENTIAL FOR CONTAMINANT MIGRATION AND DIRECT CONTACT WITH OR
INHALATION OF CONTAMINANTS THROUGH CONTAINMENT. LONG-TERM MANAGEMENT, WHICH WOULD INCLUDE SITE
INSPECTIONS, MAINTENANCE AND MONITORING, WOULD BE REQUIRED FOR BOTH ALTERNATIVES. LAND AND
GROUND WATER USE RESTRICTIONS WOULD ALSO BE REQUIRED.
9.2 COMPLIANCE WITH ARARS
CONTAMINANT-SPECIFIC ARARS WITH REGARD TO SOIL HAVE NOT BEEN PROMULGATED AND NO
LOCATION-SPECIFIC ARARS WERE IDENTIFIED. AS DISCUSSED IN THE SECTION 8.0, THE ALTERNATIVES
WOULD COMPLY WITH FEDERAL AND STATE ACTION-SPECIFIC ARARS.
THE THERMAL TREATMENT ALTERNATIVES WOULD COMPLY WITH RCRA PART 264 REQUIREMENTS AND TECHNICAL
STANDARDS. ADDITIONAL ARARS WOULD INCLUDE THE CLEAN AIR ACT AND MISSOURI AIR POLLUTION CONTROL
REGULATIONS.
THE ALTERNATIVES WHICH INCLUDE OFFSITE TRANSPORTATION WOULD COMPLY WITH RCRA PARTS 262 AND 263,
AND DOT REQUIREMENTS. THE LAND DISPOSAL ALTERNATIVES WOULD BE REQUIRED TO COMPLY WITH THE
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REQUIREMENTS AND TECHNICAL STANDARDS OF RCRA PARTS 264 AND 268.
9.3 LONG-TERM EFFECTIVENESS AND PERMANENCE
THE THERMAL TREATMENT ALTERNATIVES WOULD PERMANENTLY ELIMINATE RISKS ASSOCIATED WITH THE
CONTAMINATED SOIL AND SEDIMENT. BOTH ALTERNATIVES WOULD REQUIRE NO LONG-TERM MANAGEMENT OR
INSTITUTIONAL CONTROLS AT THE SITE.
THE REMOVAL OF CONTAMINATED SOIL AND SEDIMENT TO A RCRA-APPROVED HAZARDOUS WASTE LANDFILL WOULD
ELIMINATE LONG-TERM RISKS AT THE SITE. CONTAINMENT PROVIDED BY AN OFFSITE FACILITY MEETING THE
TECHNICAL REQUIREMENTS FOR DOUBLE LINER, LEACHATE DETECTION AND COLLECTION AND MONITORING WOULD
PROVIDE A HIGH DEGREE OF LONG-TERM EFFECTIVENESS FOR CONTAMINATED SOIL WITH THE CONCENTRATIONS
DETECTED AT THIS SITE. IN ADDITION, CONTAINMENT AT AN OFFSITE FACILITY WOULD REDUCE THE VOLUME
OF CONTAMINATED MATERIAL AT THE SITE AND PROVIDE AN OVERALL REDUCTION IN MOBILITY. THE OFFSITE
LANDFILL ALTERNATIVE WOULD ALSO NOT REQUIRE LONG-TERM MANAGEMENT OR INSTITUTIONAL CONTROLS AT
THE SITE.
CONTAINMENT OF CONTAMINATED SOIL AND SEDIMENT PROVIDED BY THE ONSITE LANDFILL ALTERNATIVE AND BY
THE CAPPING OPTION MAY REDUCE BUT WOULD NOT ELIMINATE LONG-TERM RISKS AT THE SITE. THE ONSITE
LANDFILL WOULD PROVIDE AN OVERALL REDUCTION IN MOBILITY THROUGH CONTAINMENT. BOTH ALTERNATIVES
WOULD REQUIRE LONG-TERM MANAGEMENT INCLUDING MAINTENANCE AND GROUND WATER MONITORING. LAND AND
GROUND WATER USE CONTROLS WOULD ALSO BE REQUIRED FOR THE LIFE OF BOTH ALTERNATIVES. THE CAPPING
ALTERNATIVE DOES NOT COMPLETELY ADDRESS POTENTIAL THREATS POSED BY CONTAMINATED SUBSURFACE SOILS
TO THE GROUND WATER; THE POTENTIAL FOR FUTURE RELEASE AND EXPOSURE WOULD HAVE TO BE CONSIDERED.
9.4 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME
THIS CRITERIA ADDRESSES THE DEGREE TO WHICH ALTERNATIVES EMPLOY TREATMENT WHICH REDUCE TOXICITY,
MOBILITY, OR VOLUME. ONLY THE INCINERATION ALTERNATIVES UTILIZE TREATMENT TO REDUCE TOXICITY,
MOBILITY, OR VOLUME.
AS DESCRIBED ABOVE, BOTH THE OFFSITE AND ONSITE LANDFILL ALTERNATIVES PROVIDE AN OVERALL
REDUCTION IN MOBILITY THROUGH CONTAINMENT.
9.5 SHORT-TERM EFFECTIVENESS
ALL THE ALTERNATIVES WOULD PRESENT SIMILAR SHORT-TERM RISKS TO WORKERS AND THE COMMUNITY DURING
EXCAVATION AND SOIL HANDLING OPERATIONS. POTENTIAL EXPOSURES TO FUGITIVE EMISSIONS AND SURFACE
RUNOFF CAN BE EFFECTIVELY MINIMIZED AND CONTROLLED BY IMPLEMENTING ENGINEERING CONTROLS (DUST
SUPPRESSANTS, BERMS, ETC.) AND COMPLYING WITH ACTION-SPECIFIC ARARS.
THE THERMAL TREATMENT ALTERNATIVES INVOLVE ADDITIONAL RISKS AND IMPACTS ASSOCIATED WITH
POTENTIAL MALFUNCTIONS DURING OPERATION OR INCOMPLETE DESTRUCTION OF CONTAMINANTS RESULTING IN
RELEASES OF HAZARDOUS EMISSIONS. IMPLEMENTATION OF ENGINEERING CONTROLS AND COMPLIANCE WITH
ARARS WOULD EFFECTIVELY MINIMIZE AND CONTROL POTENTIAL RISKS AND IMPACTS.
THE TWO OFFSITE ALTERNATIVES INVOLVE ADDITIONAL RISKS AND IMPACTS ASSOCIATED WITH OFFSITE
TRANSPORT. AGAIN, IMPLEMENTATION OF ENGINEERING CONTROLS AND COMPLIANCE WITH ARARS WOULD
EFFECTIVELY MINIMIZE AND CONTROL POTENTIAL RISKS AND IMPACTS.
THE ALTERNATIVES VARY CONSIDERABLY IN THE LENGTH OF TIME REQUIRED TO IMPLEMENT THE REMEDIAL
ACTION. THE OFFSITE LANDFILL ALTERNATIVE WOULD REQUIRE APPROXIMATELY 7-9 MONTHS. CAPPING WOULD
TAKE 12 MONTHS AND ONSITE DISPOSAL WOULD REQUIRE 16-18 MONTHS. OFFSITE INCINERATION WAS
ESTIMATED TO TAKE FROM 11-29 MONTHS, AND ONSITE INCINERATION WOULD REQUIRE ABOUT 27 MONTHS.
ALTERNATIVES REQUIRING A LONGER PERIOD OF TIME TO IMPLEMENT HAVE A GREATER OPPORTUNITY FOR SHORT
TERM IMPACTS.
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9. 6 IMPIiEMENTABILITY
IMPLEMENTATION OF THE OFFSITE LANDFILL ALTERNATIVE WOULD INVOLVE CONVENTIONAL CONSTRUCTION
TECHNOLOGIES. OPERATION AND MAINTENANCE AND MONITORING FOLLOWING IMPLEMENTATION OF THE REMEDY
WOULD NOT BE REQUIRED AT THE SITE. FUTURE REMEDIAL ACTIONS, IF REQUIRED, WOULD NOT BE DIFFICULT
TO IMPLEMENT. THE NUMBER AND CAPACITY OF COMMERCIAL LANDFILLS WHICH ARE PERMITTED TO RECEIVE
HAZARDOUS WASTE IS LIMITED, BUT FOUR FACILITIES CURRENTLY IN COMPLIANCE WERE IDENTIFIED IN THE
OUFS.
ONSITE DISPOSAL AND CAPPING WOULD ALSO EMPLOY CONVENTIONAL CONSTRUCTION TECHNOLOGIES.
CONSTRUCTION OF THE CAP AROUND THE BUILDING AND SECURING THE CAP TO THE STRUCTURE WOULD,
HOWEVER, BE MORE TECHNICALLY COMPLEX. IMPLEMENTATION WOULD BE LABOR INTENSIVE FOR BOTH
ALTERNATIVES. SITE INSPECTIONS, MAINTENANCE AND GROUND WATER MONITORING FOLLOWING IMPLEMENTATION
OF THE REMEDY WOULD BE REQUIRED FOR BOTH ALTERNATIVES. SINCE ONSITE LANDFILL AND CAPPING WOULD
REQUIRE INSTITUTIONAL CONTROLS FOR THE LIFE OF THE REMEDY, COORDINATION REQUIREMENTS BETWEEN
LOCAL, COUNTY AND STATE AND FEDERAL AGENCIES WOULD BE INCREASED. FOR THE CAPPING ALTERNATIVE,
THE IMPLEMENTATION OF FUTURE REMEDIAL ACTIONS WOULD BE MORE DIFFICULT, ESPECIALLY FOR REMEDIES
ADDRESSING POTENTIAL IMPACTS ON GROUND WATER BY THE CONTAMINATED SUBSURFACE SOILS.
THE THERMAL TREATMENT ALTERNATIVES WOULD BE COMPLEX TO IMPLEMENT. THE CAPACITY AND AVAILABILITY
OF OFFSITE COMMERCIAL OR MOBILE INCINERATORS COULD BE LIMITED; FACILITIES CURRENTLY AVAILABLE
WERE IDENTIFIED IN THE OUFS. OPERATION AND MAINTENANCE AT THE SITE AND INSTITUTIONAL CONTROLS
WOULD NOT BE REQUIRED FOLLOWING COMPLETION OF THERMAL TREATMENT. FUTURE REMEDIAL ACTIONS, IF
REQUIRED, WOULD NOT BE DIFFICULT TO IMPLEMENT.
9.7 COST
THE CAPPING ALTERNATIVE WAS ESTIMATED TO BE THE LEAST COSTLY AT $1.1 MILLION. THE COST FOR
ONSITE LANDFILL WAS ESTIMATED AT $2.5 MILLION. THE OFFSITE LANDFILL ALTERNATIVE WAS ESTIMATED AT
$2.6 MILLION. THE ESTIMATED COSTS FOR THE THERMAL TREATMENT ALTERNATIVES WERE THE HIGHEST. THE
REVISED COST ESTIMATE FOR ONSITE THERMAL TREATMENT WAS $7.6 MILLION; OFFSITE INCINERATION WAS
ESTIMATED TO COST APPROXIMATELY $16.5 MILLION.
9.8 STATE ACCEPTANCE
IN A LETTER OF CONCURRENCE, THE STATE OF MISSOURI SUPPORTED THE OFFSITE RCRA-APPROVED HAZARDOUS
WASTE LANDFILL ALTERNATIVE.
9.9 COMMUNITY ACCEPTANCE
DURING THE PUBLIC COMMENT PERIOD, THE AGENCY RECEIVED THREE WRITTEN COMMENTS FROM THE COMMUNITY
ADDRESSING THE REMEDIAL ALTERNATIVES. TWO RESIDENTS EXPRESSED SUPPORT FOR THE OFFSITE LANDFILL
ALTERNATIVE AND THE PRPS SUPPORTED THE CAPPING ALTERNATIVE.
RESPONSES TO ALL COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD ARE PROVIDED IN THE
RESPONSIVENESS SUMMARY, A COMPONENT OF THE RECORD OF DECISION.
#SR
10 . 0 SEIiECTED REMEDY
BASED UPON AN EVALUATION OF THE RELATIVE PERFORMANCE OF EACH ALTERNATIVE WITH RESPECT TO THE
EVALUATION CRITERIA, AND CONSIDERATION OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD,
BOTH EPA AND THE STATE OF MISSOURI HAVE DETERMINED THAT EXCAVATION AND OFFSITE LANDFILL IS THE
MOST APPROPRIATE REMEDY FOR CONTAMINATED SOIL AND SEDIMENT AT THE KEM-PEST SITE.
10.1 DESCRIPTION
APPROXIMATELY 4,050 CUBIC YARDS OF CONTAMINATED SOIL AND SEDIMENT WOULD BE EXCAVATED AND
TRANSPORTED TO A RCRA-APPROVED COMMERCIAL HAZARDOUS WASTE LANDFILL FOR DISPOSAL. THE OFFSITE
LANDFILL FACILITY WOULD PROVIDE LONG-TERM MANAGEMENT THROUGH DOUBLE LINER CONTAINMENT, A
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LEACHATE DETECTION AND COLLECTION SYSTEM AND MONITORING.
SAMPLING WOULD BE CONDUCTED TO CONFIRM THAT THE HORIZONTAL AND VERTICAL EXTENT OF EXCAVATION WAS
SUFFICIENT TO REMOVE CONTAMINATION ABOVE THE HEALTH-BASED CLEANUP GOALS. FOLLOWING EXCAVATION,
CLEAN SOIL WOULD BE PLACED IN THE EXCAVATED AREAS, COMPACTED AND GRADED. VEGETATION OR GRAVEL
WOULD THEN BE APPLIED TO MINIMIZE EROSION.
SINCE THIS REMEDY WILL NOT RESULT IN HAZARDOUS SUBSTANCES REMAINING ONSITE ABOVE HEALTH-BASED
LEVELS, ENVIRONMENTAL MONITORING, SECURITY, AND OPERATION AND MAINTENANCE WOULD NOT BE REQUIRED
FOR SOILS AND SEDIMENTS AFTER REMEDIAL ACTIVITIES ARE COMPLETED.
THE TIME REQUIRED TO IMPLEMENT THIS REMEDY WAS ESTIMATED TO BE APPROXIMATELY 7-9 MONTHS. THE
ESTIMATED PRESENT WORTH COST WAS ESTIMATED AT APPROXIMATELY $2.6 MILLION. THE MAJOR COST
COMPONENTS ARE TRANSPORTATION AT $671,000 AND DISPOSAL AT $853,000. CAPITAL COSTS FOR EACH
MAJOR COMPONENT AND INDIRECT COSTS ARE SUMMARIZED IN TABLE D-l IN ATTACHMENT D.
10.2 REMEDIATION GOALS
THE OBJECTIVES OF THIS FIRST OPERABLE UNIT ARE TO REMOVE OR REDUCE TO A PROTECTIVE LEVEL THE
RISKS POSED BY DERMAL CONTACT, INGESTION OR INHALATION OF CONTAMINATED SOIL AND SEDIMENT, TO
ELIMINATE OR REDUCE THE POTENTIAL FOR OFFSITE TRANSPORT OF CONTAMINATED MATERIAL, WHICH INCLUDES
REDUCING THE THREATS POSED BY CONTAMINATED SUBSURFACE SOILS ON GROUND WATER, AND TO REMEDIATE
CONTAMINATED SOIL AND SEDIMENT IN A MANNER WHICH WILL NOT ADVERSELY AFFECT FUTURE REMEDIAL
ACTIONS, IF REQUIRED.
A RISK ASSESSMENT WAS CONDUCTED TO EVALUATE THE POTENTIAL IMPACTS TO HUMAN HEALTH FOR CURRENT
AND FUTURE LAND USE SCENARIOS. THE RESULTS OF THE RISK ASSESSMENT INDICATE THAT CONCENTRATIONS
OF CONTAMINANTS IN SOIL AND SEDIMENT AT SEVERAL LOCATIONS ON AND ADJACENT TO THE SITE RESULT IN
EXCESS LIFETIME CANCER RISKS AS HIGH AS 7 X 10 (-5) FOR CURRENT LAND USE AND 1 X 10 (-3) FOR
FUTURE RESIDENTIAL LAND USE.
THERE ARE NO FEDERAL OR STATE STANDARDS FOR SOIL CONTAMINATION. WHEN A HEALTH-BASED STANDARD
DOES NOT EXIST, EPA CONSIDERS A RANGE OF 10 (-4) TO 10 (-7) INDIVIDUAL LIFETIME EXCESS CANCER RISK
TO BE PROTECTIVE OF HUMAN HEALTH. THE 10(-6) LEVEL IS GENERALLY USED AS THE POINT OF DEPARTURE
FOR ESTABLISHING CLEANUP LEVELS.
PROTECTIVE CONTAMINANT CONCENTRATIONS FOR SOIL AT 1 X 10 (-6) , 1 X 10 (-5), AND 1 X 10 (-4) WERE
DETERMINED FOR CHEMICALS OF CONCERN AT THE SITE. THESE CONCENTRATIONS WERE CALCULATED USING
RISK ASSESSMENT TECHNIQUES THAT COMBINE SCENARIO-SPECIFIC EXPOSURE PARAMETERS WITH AN ESTIMATED
PROTECTIVE CHRONIC DAILY INTAKE (GDI) FOR EACH CHEMICAL OF CONCERN. THE PROTECTIVE CONTAMINANT
CONCENTRATIONS FOR THE THREE CANCER RISK LEVELS FOR BOTH SURFACE SOIL AND SUBSURFACE SOIL
EXPOSURES ARE PROVIDED IN TABLES D-2 AND D-3 IN ATTACHMENT D.
THE PROTECTIVE SOIL CONCENTRATIONS FOR THE MAXIMUM CASE AT THE 10 (-5) CANCER RISK LEVEL WERE
DETERMINED TO REPRESENT A REASONABLE MAXIMUM EXPOSURE SCENARIO.
REASONABLE MAXIMUM EXPOSURE SCENARIO REFLECTS A SITUATION WHICH IS MORE CONSERVATIVE THAN AN
AVERAGE CASE BUT IS NOT THE ABSOLUTE WORST CASE SCENARIO. THE MAXIMUM CASE SOIL CONCENTRATIONS
FOR THE 10 (-5) CANCER RISK LEVEL FALL BETWEEN THE CONCENTRATION RANGE ESTABLISHED BE THE AVERAGE
CASE AND MAXIMUM CASE FOR THE 10 (-6) CANCER RISK LEVEL. AS EXPLAINED IN AGENCY GUIDANCE, THE
REASONABLE MAXIMUM EXPOSURE SCENARIO IS DEVELOPED TO REFLECT THE TYPES AND EXTENT OF EXPOSURES
THAT COULD OCCUR, BASED ON THE LIKELY OR EXPECTED USE OF THE SITE IN THE FUTURE.
THE EPA HAS THEREFORE DETERMINED THAT REMOVING CONTAMINATED SOIL AND SEDIMENT TO THE CONTAMINANT
CONCENTRATIONS FOR THE 10 (-5) RISK LEVEL WILL REDUCE POTENTIAL EXPOSURES TO PROTECTIVE LEVELS.
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#SD
11.0 STATUTORY DETERMINATIONS
SECTION 121 OF CERCLA ESTABLISHES STATUTORY REQUIREMENTS AND PREFERENCES FOR REMEDIAL ACTIONS.
THESE SPECIFY THAT WHEN COMPLETE, THE SELECTED REMEDY MUST BE PROTECTIVE OF HUMAN HEALTH AND THE
ENVIRONMENT, COMPLY WITH APPLICABLE OR RELEVANT AND APPROPRIATE FEDERAL AND STATE REQUIREMENTS,
BE COST-EFFECTIVE AND UTILIZE PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT TECHNOLOGIES OR
RESOURCE RECOVERY TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE.
IN ADDITION, THE STATUTE INCLUDES A PREFERENCE FOR REMEDIES WHICH EMPLOY TREATMENT THAT
PERMANENTLY AND SIGNIFICANTLY REDUCE THE VOLUME, TOXICITY, OR MOBILITY OF HAZARDOUS WASTES AS
THEIR PRINCIPAL ELEMENT. THIS SECTION DISCUSSES HOW THE SELECTED REMEDY MEETS THESE STATUTORY
REQUIREMENTS.
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
THE SELECTED REMEDY WILL ELIMINATE RISKS AT THE SITE BY THE EXCAVATION AND REMOVAL OF
CONTAMINATED SOIL AND SEDIMENT TO A RCRA-APPROVED OFFSITE HAZARDOUS WASTE LANDFILL. THE OFFSITE
LANDFILL, THROUGH CONTAINMENT, WILL REDUCE RISKS POSED BY THE CONTAMINATED MATERIAL BE REDUCING
THE POTENTIAL FOR CONTAMINANT MIGRATION AND DIRECT CONTACT WITH OR INHALATION OF CONTAMINANTS.
THE LANDFILL FACILITY WILL PROVIDE SECURE CONTAINMENT BY MEETING RCRA TECHNICAL REQUIREMENTS
WHICH INCLUDE DOUBLE LINER, LEACHATE DETECTION AND COLLECTION SYSTEM AND MONITORING.
THE RI RISK ASSESSMENT CONCLUDED THAT CONCENTRATIONS OF CONTAMINANTS IN SOIL AND SEDIMENT AT
SEVERAL LOCATIONS ON AND ADJACENT TO THE SITE RESULT IN EXCESS LIFETIME CANCER RISKS AS HIGH AS
7 X 10 (-5) FOR CURRENT LAND USE AND 1 X 10 (-3) FOR FUTURE RESIDENTIAL LAND USE.
BY EXCAVATION AND REMOVAL OF CONTAMINATED SOIL AND SEDIMENT TO PROTECTIVE CONTAMINANT
CONCENTRATIONS, CANCER RISKS WILL BE REDUCED TO 1 X 10 (-5) . THIS CANCER RISK LEVEL REPRESENTS A
REASONABLE MAXIMUM EXPOSURE SCENARIO AND IS WITHIN THE RANGE 10-4 TO 10 (-7) INDIVIDUAL LIFETIME
EXCESS CANCER RISK CONSIDERED PROTECTIVE OF HUMAN HEALTH.
THERE ARE NO SHORT-TERM THREATS ASSOCIATED WITH THE SELECTED REMEDY THAT CANNOT BE CONTROLLED BY
IMPLEMENTING ENGINEERING CONTROLS AND COMPLYING WITH ARARS. NO ADVERSE CROSS-MEDIA IMPACTS ARE
EXPECTED FROM THIS REMEDY.
COMPLIANCE WITH ARARS
THE SELECTED REMEDY COMPLIES WITH FEDERAL AND STATE REQUIREMENTS THAT ARE APPLICABLE OR RELEVANT
AND APPROPRIATE TO THE OPERABLE UNIT. CONTAMINANT-SPECIFIC ARARS WITH REGARD TO SOIL HAVE NOT
BEEN PROMULGATED AND NO LOCATION-SPECIFIC ARARS WERE IDENTIFIED. ACTION-SPECIFIC ARARS INCLUDE:
RCRA 40 CFR PART 262 - STANDARDS APPLICABLE TO GENERATORS OF HAZARDOUS WASTE.
RCRA 40 CFR PART 263 - STANDARDS APPLICABLE TO TRANSPORTERS OF HAZARDOUS WASTE.
RCRA 40 CFR PART 264 - STANDARDS FOR OWNERS AND OPERATORS OF HAZARDOUS WASTE TREATMENT,
STORAGE, AND DISPOSAL FACILITIES.
RCRA 40 CFR PART 268 - LAND DISPOSAL RESTRICTIONS.
OSHA 40 CFR SECT. 300.38 - WORKER HEALTH AND SAFETY.
HAZARDOUS MATERIALS TRANSPORTATION REGULATIONS 40 CFR PARTS 107, 171-177.
CERCLA OFFSITE DISPOSAL POLICY
MISSOURI HAZARDOUS WASTE MANAGEMENT LAW AND RULES
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OTHER CRITERIA, ADVISORIES OR GUIDANCE TO BE CONSIDERED FOR THIS REMEDIAL ACTION INCLUDE THE
PROTECTIVE SOIL CONCENTRATIONS FOR SOIL AND SEDIMENT BASED ON THE RISK ASSESSMENT SCENARIOS
DEVELOPED IN THE PUBLIC HEALTH EVALUATION.
COST-EFFECTIVENESS
THE SELECTED REMEDY IS COST-EFFECTIVE BECAUSE IT HAS BEEN DETERMINED TO PROVIDE OVERALL
EFFECTIVENESS PROPORTIONAL TO ITS COSTS, ESTIMATED AT $2.6 MILLION. REGARDING THE LEAST COSTLY
ALTERNATIVE, CAPPING, THE SELECTED REMEDY IS COST-EFFECTIVE WHEN THE OVERALL RELATIONSHIP
BETWEEN COST AND EFFECTIVENESS IS COMPARED TO THE COST/EFFECTIVENESS RELATIONSHIP OF CAPPING.
THE SELECTED REMEDY ASSURES A HIGHER DEGREE OF CERTAINTY THAT THE REMEDY WILL BE EFFECTIVE IN
THE LONG-TERM. CAPPING WOULD REQUIRE LONG-TERM MANAGEMENT AT THE SITE AND INSTITUTIONAL
CONTROLS. IN ADDITION, CAPPING WOULD NOT ADDRESS POTENTIAL THREATS POSED BY THE IMPACT OF
CONTAMINATED SUBSURFACE SOILS ON THE GROUND WATER.
BASED ON THE CONCENTRATIONS OF HAZARDOUS SUBSTANCES IN THE SOIL AND SEDIMENT DETECTED AT THIS
SITE, THERMAL TREATMENT OF SOILS WOULD RESULT IN LONG-TERM EFFECTIVENESS SIMILAR TO THAT
AFFORDED BY CONTAINMENT AT A RCRA-APPROVED HAZARDOUS WASTE LANDFILL.
UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT TECHNOLOGIES (OR RESOURCE RECOVERY
TECHNOLOGIES) TO THE MAXIMUM EXTENT PRACTICABLE
EPA HAS DETERMINED THAT THE SELECTED REMEDY REPRESENTS THE MAXIMUM EXTENT TO WHICH PERMANENT
SOLUTIONS AND TREATMENT TECHNOLOGIES CAN BE UTILIZED IN A COST-EFFECTIVE MANNER. OF THOSE
ALTERNATIVES THAT ARE PROTECTIVE OF HUMAN HEALTH AND THE ENVIRONMENT AND COMPLY WITH ARARS, EPA
HAS DETERMINED THAT THE SELECTED REMEDY PROVIDES THE BEST BALANCE OF TRADEOFFS IN TERMS OF
LONG-TERM EFFECTIVENESS AND PERMANENCE, REDUCTION IN TOXICITY, MOBILITY, OR VOLUME ACHIEVED
THROUGH TREATMENT, SHORT-TERM EFFECTIVENESS, IMPLEMENTABILITY, COST AND CONSIDERING STATE AND
COMMUNITY ACCEPTANCE.
THE SELECTED REMEDY PROVIDES A HIGHER DEGREE OF LONG-TERM EFFECTIVENESS AND PERMANENCE THAN THE
ONSITE LANDFILL OR CAPPING ALTERNATIVE. THE SELECTED REMEDY WOULD REQUIRE NO LONG-TERM
MANAGEMENT OR INSTITUTIONAL CONTROLS AT THE SITE. IN ADDITION, CAPPING WOULD NOT COMPLETELY
ADDRESS POTENTIAL THREATS POSED BY CONTAMINATED SUBSURFACE SOILS TO GROUND WATER; THE POTENTIAL
FOR FUTURE RELEASE AND EXPOSURE WOULD HAVE TO BE CONSIDERED. CONTAINMENT PROVIDED BY AN OFFSITE
FACILITY MEETING THE TECHNICAL REQUIREMENTS FOR DOUBLE LINER, LEACHATE DETECTION AND COLLECTION
AND MONITORING WOULD PROVIDE A HIGH DEGREE OF LONG-TERM EFFECTIVENESS FOR CONTAMINATED SOIL WITH
CONCENTRATIONS ABOVE HEALTH-BASED STANDARDS BUT NOT AT SIGNIFICANTLY HIGH CONCENTRATIONS. THE
SELECTED REMEDY WOULD THEREFORE RESULT IN A SIMILAR DEGREE OF LONG-TERM EFFECTIVENESS THAT WOULD
BE PROVIDED BY THE THERMAL TREATMENT OF SOILS WITH THESE CONCENTRATIONS.
THE SELECTED REMEDY REDUCES BOTH THE VOLUME AND MOBILITY OF CONTAMINATED SOIL AND SEDIMENT
LOCATED AT THE SITE. THE CONTAMINATED MATERIAL REMOVED FROM THE SITE WOULD BE EFFECTIVELY
CONTAINED AS DESCRIBED ABOVE. THE CAPPING ALTERNATIVE WOULD NOT REDUCE THE VOLUME OF
CONTAMINATED MATERIAL ON THE SITE AND THE MOBILITY OF CONTAMINANTS IN THE SUBSURFACE SOIL WOULD
REMAIN A CONCERN.
THE SELECTED REMEDY IS MORE EFFECTIVE THAN THE OTHER ALTERNATIVES IN THE SHORT-TERM, REQUIRING
ONLY 7-9 MONTHS TO IMPLEMENT AS COMPARED TO A YEAR FOR CAPPING, 16-18 MONTHS FOR ONSITE
LANDFILL, 11-29 MONTHS FOR OFFSITE INCINERATION AND 27 MONTHS FOR ONSITE INCINERATION.
ALTERNATIVES REQUIRING A LONGER PERIOD OF TIME TO IMPLEMENT HAVE A GREATER OPPORTUNITY FOR SHORT
TERM IMPACTS.
THE SELECTED REMEDY IS SIGNIFICANTLY LESS COSTLY THAN THE ONSITE AND OFFSITE INCINERATION
ALTERNATIVES, AND IS COMPARABLE TO THE ONSITE DISPOSAL OPTION.
WITH RESPECT TO IMPLEMENTABILITY, THE SELECTED REMEDY WILL INVOLVE CONVENTIONAL CONSTRUCTION
TECHNOLOGIES AND WILL HAVE FEWER TECHNICAL DIFFICULTIES ASSOCIATED WITH IMPLEMENTATION. THE
THERMAL TREATMENT ALTERNATIVES ARE TECHNICALLY COMPLEX TO IMPLEMENT. CAPPING WILL BE DIFFICULT
TO IMPLEMENT DUE TO THE NEED TO CONSTRUCT THE CAP AROUND THE BUILDING AND SECURE THE CAP TO THE
-------
STRUCTURE. FUTURE REMEDIAL ACTIONS, IF REQUIRED, WOULD NOT BE DIFFICULT TO IMPLEMENT, AS
OPPOSED TO CAPPING. WITH RESPECT TO ADMINISTRATIVE FEASIBILITY, THE SELECTED REMEDY WILL NOT
REQUIRE LONG-TERM MANAGEMENT OR INSTITUTIONAL CONTROLS AT THE SITE. BOTH THE ONSITE LANDFILL AND
CAPPING ALTERNATIVES WOULD REQUIRE LONG-TERM MANAGEMENT AND INSTITUTIONAL CONTROLS, INCREASING
THE COMPLEXITY OF COORDINATION WITH LOCAL, COUNTY, STATE AND FEDERAL AGENCIES.
THE SELECTED REMEDY WOULD UTILIZE PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT TECHNOLOGIES TO
THE MAXIMUM EXTENT PRACTICABLE. TREATMENT IS USUALLY PRACTICABLE FOR WASTES WHICH CANNOT BE
RELIABLY CONTAINED OR CONTROLLED IN PLACE SUCH AS LIQUIDS, HIGHLY MOBILE MATERIALS SUCH AS
SOLVENTS, AND HIGH CONCENTRATIONS OF TOXIC COMPOUNDS. THE WASTES AT THE KEM-PEST SITE ARE SOILS
AND SEDIMENTS WITH CONCENTRATIONS ABOVE HEALTH-BASED LEVELS, BUT NOT AT HIGH CONCENTRATION
LEVELS. ALSO, THE PRINCIPAL CONTAMINANTS AT THE SITE, PESTICIDES, HAVE A HIGH AFFINITY FOR
ATTACHMENT TO SOIL PARTICLES AND COULD BE RELIABLY CONTAINED BY A HAZARDOUS WASTE LANDFILL
FACILITY MEETING THE RCRA TECHNICAL REQUIREMENTS WHICH INCLUDE DOUBLE LINER, LEACHATE DETECTION
AND COLLECTION SYSTEM AND MONITORING. OFFSITE DISPOSAL IN A RCRA-APPROVED HAZARDOUS WASTE
LANDFILL WOULD PROVIDE SIMILAR LONG-TERM EFFECTIVENESS AT SUBSTANTIALLY LESS COST THAN THERMAL
TREATMENT. OTHER POTENTIAL TREATMENT TECHNOLOGIES WERE DETERMINED NOT TO BE FEASIBLE SINCE
CONTAMINANTS AND SOIL TYPES PRESENT AT THE SITE WERE NOT AMENABLE TO PHYSICAL OR CHEMICAL
TREATMENT TECHNOLOGIES. FOR THESE REASONS, TREATMENT IS NOT PRACTICABLE AT THE KEM-PEST SITE.
THE SELECTED REMEDY WAS SUPPORTED BY THE STATE OF MISSOURI. THE STATE INDICATED THAT CAPPING
WAS THE LEAST PREFERRED ALTERNATIVE DUE TO CONCERNS REGARDING THE POTENTIAL IMPACT OF
CONTAMINATED SUBSURFACE SOIL ON THE GROUND WATER. WITH RESPECT TO COMMUNITY ACCEPTANCE, TWO
RESIDENTS EXPRESSED SUPPORT FOR THE OFFSITE LANDFILL ALTERNATIVE AND THE PRPS FAVORED CAPPING.
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
THIS REMEDY UTILIZES PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT TECHNOLOGIES TO THE MAXIMUM
EXTENT PRACTICABLE FOR THIS SITE. HOWEVER, BECAUSE TREATMENT OF THE PRINCIPAL THREATS OF
CONTAMINATED SOIL AND SEDIMENT WAS NOT FOUND TO BE PRACTICABLE, AS EXPLAINED ABOVE, THIS REMEDY
DOES NOT INCLUDE TREATMENT AS A PRINCIPAL ELEMENT FOR THIS FIRST OPERABLE UNIT.
-------
#TA
TABIiES AND ATTACHMENT
TABIiE A-l
SUMMARY OF CHEMICALS DETECTED IN THE SUBSURFACE SOIL
SAMPLES FROM THE FORMER LAGOON AREA AT THE KEM-PEST LABORATORIES
SITE (ORGANICS-UG/KG, INORGANICS-MG/KG)
FREQUENCY OF GEOMETRIC MAXIMUM
CHEMICAL DETECTION(A) MEAN DETECTED
LAGOON 1.5-9 FEET
ORGANICS:
ACETONE 4/8 32.0 300.OJ
*ALDRIN 6/14 89.7 3,500.0
*ALPHA-BHC 1/9 16.9 750.OJ
*BENZENE 2/8 5.5 67.0
*BETA-BHC 1/6 6.8 23.8J
BIS(2-ETHYLHEXYL)
PHTHALATE 3/7 528.5 2,698.1
*2-BUTANONE 1/5 8.2 27. OJ
*CARBON DISULFIDE 1/8 3.1 4.0J
*CHLORDANE 10/14 1.102.5 74,500.0
*CHLORBENZENE 2/8 5.4 120.0
*CHLOROFORM 2/8 7.6 150.OJ
*DDT 2/13 178.2 8,490.0
*DELTA-BHC 1/6 5.8 9.4J
*3.3'-DICHLORO
BENZIDINE 1/7 684.8 950.OJ
*1,1-DICHLOROETHANE 1/8 3.3 6.0J
*1,2-DICHLOROETHANE 3/8 7.3 87.0
*2,4-DICHLOROPHENOL 4/7 1.019.2 8,600.0
*2,4-DIMETHYLPHENOL 1/7 419.9 680.0
*DIELDRIN 6/11 90.2 1,800.0J
*ENDRIN 8/13 146.4 14,000.0
*ENDRIN KETONE 5/12 68.8 1,300.0J
*ENDOSULFANS
I AND II 1/13 342.7 104,800.0
*ETHYLBENZENE 3/8 20.4 1,700.0
*GAMMA-BHC 1/7 7.5 11.0
*HEPTACHLOR 7/14 261.0 45,700.0
*HEPTACHLOR EPOXIDE 2/7 7.8 38.OJ
*HEXACHLORBUTADIENE 1/7 453.6 3,500.0
*METHAXYCHLOR 1/7 65.8 320.OJ
METHYLENE CHLORIDE 2/2 1.6 2.4J
*2-METHYLPHENOL 1/2 246.6 320.OJ
*N-NITROSODIPHENY
LAMINE 2/7 478.3 4,400.0
*NCPAH 2/7 1,023.9 9,900.0
*PENTACHLOROPHENOL 3/7 2,785.2 19,000.0
*TOLUENE 2/8 5.3 37.0
*1,1,1-TRICHLORO
ETHANE 1/8 3.4 9.0J
*2,4,5-TRICHLORO
PHENOL 1/1 NA 260.0J
*XYLENE (TOTAL) 3/8 29.1 11,000.0
-------
INORGANICS:
ALUMINUM
*ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
SELENIUM
SODIUM
THALLIUM
VANADIUM
ZINC
7/7
6/7
7/7
5/7
3/7
7/7
7/7
6/7
4/7
7/7
7/7
7/7
7/7
7/7
7/7
2/5
3/3
^2
7/7
7/7
11,821.4
17.9
199.9
0.48
0.9
2,857.5
19.4
10.3
16.0
20,785.0
15.0
3,472.1
774.0
24.3
923.3
0.61
169.9
1.17
28.4
73.7
16,000.0
160.0
300.0
l.OM
4.3
4,500.0
29.0
18.0
37.0
31,000.0
23. OJ
4,800.0
1,200.0
48.0
1,500.0
.8M
250. OM
1.2M
48.0
110.0
-------
TABIiE A-1 (CONTINUED)
SUMMARY OF CHEMICALS DETECTED IN THE SUBSURFACE SOIL
SAMPLES FROM THE FORMER LAGOON AREA AT THE KEM-PEST LABORATORIES
SITE (ORGANICS-UG/KG, INORGANICS-MG/KG)
CHEMICAL
LAGOON 9 FEET
ORGANICS:
FREQUENCY OF
DETECTION(A)
GEOMETRIC
MEAN
MAXIMUM
DETECTED
ACETONE 3/5
*ALDRIN 6/12
*ALPHA-BHC 3/10
*BENZENE 2/5
BIS(2-ETHYLHEXYL)
PHTHALATE 2/6
*CARBON DISULFIDE 1/5
*CHLORDANE 10/12
*CHLORBENZENE 4/5
*CHLOROFORM 3/5
*DDT 1/12
*DELTA-BHC 1/8
*1,1-DICHLOROETHANE 3/5
*1,2-DICHLOROETHANE 5/5
*2,4-DICHLOROPHENOL 5/6
*DIELDRIN 6/12
*ENDRIN 5/12
*ENDRIN KETONE 3/12
*ETHYLBENZENE 3/5
*GAMMA-BHC 4/10
*HEPTACHLOR 10/12
*METHAXYCHLOR 2/9
METHYLENE CHLORIDE 2/2
*PENTACHLOROPHENOL 2/6
*TOLUENE 1/5
*2,4,5-TRICHLORO
PHENOL 1/1
*XYLENE (TOTAL) 3/5
20.4
16.5
8.1
5.5
524.2
3.6
228.2
9.3
18.4
60.6
6.3
3.1
90.5
066.8
29.1
36.7
24.7
23.3
13.3
112.9
82.2
2.5
NR
5.4
NA
65.1
24. OJ
130. OJ
13. OJ
15. OJ
2,400.1
5.0J
5,360.0J
14.0
210. OJ
43. 5J
14. OJ
5.0J
700. OJ
8,900.0
130.0
1,300.0J
370. OJ
5,OOO.OJ
68.0
14,000.0
240.0
3.0J
400. OJ
36. OJ
470. OJ
28,OOO.OJ
INORGANICS:
ALUMINUM
*ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
SELENIUM
6/6
4/6
6/6
6/6
1/6
6/6
6/6
6/6
6/6
6/6
6/6
6/6
6/6
6/6
6/6
3/6
11,916.1
8.2
240.2
0.7
0.8
8,807.2
20.6
15.1
25.5
23,804.0
14.0
6,326.2
1,542.8
34.9
1,425.0
0.6
14,000.0
23.0
390.0
1.2J
1.9
31,000.0
23.0
29.1
35.0
33,000.0
30. OJ
11,000.0
4,700.0J
45.0
2,300.0
0.6M
-------
SODIUM 5/5 202.3 230.OM
VANADIUM 6/6 30.1 41.0
ZINC 6/6 84.4 110.0
NOTES:
J = ESTIMATED VALUE
M = CHEMICAL WAS DETECTED AT LEVEL BELOW CRQL; SIMILAR TO J VALUE.
NA = NOT APPLICABLE SINCE ONLY ONE SAMPLE.
NR = THE GEOMETRIC MEAN WAS NOT REPORTED (NR), AS THIS CONCENTRATION WAS
GREATER THAN THE MAXIMUM DETECTED VALUE (AS A RESULT OF INCLUDING
DETECTION LIMITS THAT EXCEEDED TWO TIMES THE MAXIMUM DETECTED VALUE
IN CALCULATING THE GEOMETRIC MEAN).
(A) THE NUMBER OF SAMPLES IN WHICH THE CONTAMINANT WAS DETECTED DIVIDED
BY THE TOTAL NUMBER OF SAMPLES ANALYZED. IN DETERMINING THE
FREQUENCY OF DETECTED, SAMPLES FLAGGED WITH AN "R" (REJECTED) WERE NOT INCLUDED.
* = SELECTED AS CHEMICAL OF POTENTIAL CONCERN FOR THE RISK ASSESSMENT.
-------
TABIiE A-2
SUMMARY OF CHEMICALS DETECTED IN THE SURFACE SOIL
AT THE KEMP-PEST LABORATORIES SITE BASED ON COMPOSITE SAMPLES (D) (UG/KG)
AREA/CHEMICAL
FREQUENCY OF
DETECTION(A)
GEOMETRIC
MEAN
MAXIMUM
DETECTED
GRID 1-4 FEET
ORGANICS:
*ALDRIN 1/4
*CHLORDANE 4/4
*DDT 3/4
*DIELDRIN 4/4
*ENDOSULFANS
SULFATE 4/4
*ENDRIN 1/4
*HEPTACHLOR 4/4
*HEPTACHLOR EPOXIDE 4/4
NR
14.6
29.0
6.3
4.1
NR
3.1
10.2
0.9J
29.9J
29.4J
17.OJ
6.8J
7.1J
6.1J
38.0
GRID 5
ORGANICS
*CHLORDANE 1/1
*DIELDRIN 1/1
*HEPTACHLOR 1/1
*HEPTACHLOR EPOXIDE 1/1
*TOXAPHENE 1/1
NA
NA
NA
NA
NA
4,930.0
290.0
2,600.0
620.0
46,000.0
GRID 6
ORGANICS
*BETA-BHC 1/1
*CHLORDANE 1/1
*DDT 1/1
*DIELDRIN 1/1
*ENDRIN KETONE 1/1
*HEPTACHLOR 1/1
*HEPTACHLOR EPOXIDE 1/1
NA
NA
NA
NA
NA
NA
NA
2.2J
27.OJ
121.OJ
23.0
60.0
31.0
7.3J
GRID 7
ORGANICS
*CHLORDANE 1/1
*DDT 1/1
*DIELDRIN 1/1
*ENDRIN KETONE 1/1
*HEPTACHLOR 1/1
*HEPTACHLOR EPOXIDE 1/1
NA
NA
NA
NA
NA
NA
39,OOO.OJ
41,950.0
58,000.0
2,100.0J
22,000.0
600.OJ
-------
GRID
ORGANICS
*CHLORDANE 1/1
*DDT 1/1
*DIELDRIN 1/1
*ENDOSULFANS
SULFATE 1/1
*ENDRIN KETONE 1/1
*HEPTACHLOR 1/1
*HEPTACHLOR EPOXIDE 1/1
NA
NA
NA
NA
NA
NA
NA
24,OOO.OJ
985. OJ
3,200.0
66. OJ
130. OJ
12,000.0
2,600.0
GRID 1A-4A
ORGANICS:
*ALDRIN
*CHLORDANE
*DDT
*DIELDRIN
*ENDOSULFANS
SULFATE
*ENDRIN
*ENDRIN KETONE
*HEPTACHLOR
2/8
4/8
6/8
6/8
1/8
2/8
2/8
8/8
*HEPTACHLOR EPOXIDE 4/8
NR
NR
24.4
6.1
NR
NR
NR
1.9
5.9
2.2J
63.2J
25.3J
29.0
6.1J
4.6J
1.2J
2.9J
27.0
EAST LAGOON AREA (B)
ORGANICS:
*ALDRIN 5/11
*CHLORDANE 11/11
*DDT 7/11
*DIELDRIN 10/11
*ENDOSULFANS
SULFATE 3/8
*ENDRIN 11/11
*ENDRIN KETONE 8/11
*HEPTACHLOR 11/11
*HEPTACHLOR EPOXIDE 11/11
*METHOXYCHLOR 1/6
113.7
4.898
656.3
732.7
30.4
747.5
166.6
2.353.0
444.5
81.7
17,000.0
92,000.0
9,100.0J
13,000.0
210.OJ
26,000.0
6,300.0
94,000.0
4,800.0
190.OJ
WEST LAGOON AREA (C)
ORGANICS:
*CHLORDANE 5/6
*DDT 2/6
*DIELDRIN 4/6
*ENDRIN 1/6
*GAMMA-BHC 1/1
*HEPTACHLOR 3/6
*HEPTACHLOR EPOXIDE 5/6
115.8
84.9
30.9
NR
NA
10.8
27.1
1,110.0J
328.OJ
53.0
5.7J
2.3J
60.0
330.OJ
-------
NOTES:
J = ESTIMATED VALUE
M = CHEMICAL WAS DETECTED AT LEVEL BELOW CRQL; SIMILAR TO J VALUE.
NA = NOT APPLICABLE SINCE ONLY ONE SAMPLE.
NR = THE GEOMETRIC MEAN WAS NOT REPORTED (NR), AS THIS CONCENTRATION WAS
GREATER THAN THE MAXIMUM DETECTED VALUE (AS A RESULT OF INCLUDING
DETECTION LIMITS THAT EXCEEDED TWO TIMES THE MAXIMUM DETECTED VALUE
IN CALCULATING THE GEOMETRIC MEAN).
(A) THE NUMBER OF SAMPLES IN WHICH THE CONTAMINANT WAS DETECTED DIVIDED
BY THE TOTAL NUMBER OF SAMPLES ANALYZED. IN DETERMINING THE
FREQUENCY OF DETECTED, SAMPLES FLAGGED WITH A DATA QUALIFIER "I"
(INVALID) WERE NOT INCLUDED.
(B) INCLUDES COMPOSITE SAMPLES FROM GRIDS 6A, 7A, 8A, AND 9A AND WARZYN
DISCRETE SAMPLING LOCATIONS SS03 AND SS04.
(C) INCLUDES COMPOSITE SAMPLE FROM GRID 5A AND WARZYN DISCRETE SAMPLES
SS01, SS02, AND SS05.
(D) ONLY PESTICIDES AND PCBS WERE ANALYZED FOR IN THESE SAMPLES.
* = SELECTED AS CHEMICAL OF POTENTIAL CONCERN FOR THE RISK ASSESSMENT.
-------
TABIiE A-3
SUMMARY OF CHEMICALS DETECTED IN THE SURFACE SOIL
AT THE KEMP-PEST LABORATORIES SITE BASED ON DISCRETE LOCATIONS
(ORGANICS-UG/KG, INORGANICS-MG/KG)
AREA/CHEMICAL
FREQUENCY OF
DETECTION(A)
GEOMETRIC
MEAN
MAXIMUM
DETECTED
BARE AREA (IN GRID
ORGANICS:
*ALDRIN 1/1
*CHLORDANE 1/1
*DDT 1/1
*DIELDRIN 1/1
*HEPTACHLOR 1/1
*HEPTACHLOR EPOXIDE 1/1
METHYLENE CHLORIDE 1/1
NA
NA
NA
NA
NA
NA
NA
12
33J
128
32
36
300
5.0
INORGANICS:
ALUMINUM
BARIUM
CALCIUM
CHROMIUM
IRON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
VANADIUM
ZINC
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
8,100.
72.
1,100.
13.
13,000
49.
1,600.
320.
14.
750.
20.
110.
0
0
OJ
0
.0
OJ
OJ
0
0
OJ
0
0
BURNT AREA (IN GRID
ORGANICS:
ACETONE 1/1
*ALDRIN 1/1
BETA-BHC 1/1
*CHLORDANE 1/1
*DDT 1/1
*DIELDRIN 1/1
*ENDOSULFAN II 1/1
*ENDRIN 1/1
*ENDRIN KETONE 1/1
*HEPTACHLOR 1/1
*HEPTACHLOR EPOXIDE 1/1
*METHAXYCHLOR 1/1
METHYLENE CHLORIDE 1/1
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2.0J
,900
260
761
,480
,600
130
,100
,300
180
100
,300
2.0J
-------
INORGANICS:
ALUMINUM
*ARSENIC
BARIUM
CALCIUM
CHROMIUM
COBALT
IRON
*LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
VANADIUM
ZINC
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
5,700.0
170.OJ
83.0
1,900.0J
11.0
8.0J
11,000.0
110.OJ
1,400.0
680.OJ
12.0
580.OJ
17.0
75.0
SCRAP PILE (IN GRID 6)
ORGANICS:
*CHLORDANE 1/1
*DDT 1/1
*DIELDRIN 1/1
*ENDRIN 1/1
*ENDRIN KETONE 1/1
*HEPTACHLOR 1/1
*HEPTACHLOR EPOXIDE 1/1
NA
NA
NA
NA
NA
NA
NA
648
17
62
88
160
50
510
INORGANICS:
ALUMINUM
BARIUM
CALCIUM
CHROMIUM
COBALT
IRON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
VANADIUM
ZINC
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
.400.0
150.0
.700.OJ
12.0
11.OJ
.500.0
12. OJ
.100.OJ
.900.0J
17.0
680.OJ
19.0
56.0
STORAGE TANKS (IN GRID 4)
ORGANICS:
ACETONE 1/1
BIS(2-ETHYLHEXYL)
PHTHALATE 2/2
*DI-N-BUTYLPHTHALATE 1/3
*ETHYLBENZENE 1/3
*HEPTACHLOR 1/3
METHYLENE CHLORIDE 2/2
*XYLENE (TOTAL) 1/3
NA
106.3
626.6
14.2
5.3
2.4
38.2
3.0
130.OJ
1,500.0
360.OJ
9.3
2.8J
5,900.0
-------
INORGANICS:
ALUMINUM
BARIUM
CALCIUM
CHROMIUM
COBALT
IRON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
VANADIUM
ZINC
3/3
3/3
3/3
3/3
2/3
3/3
3/3
3/3
3/3
3/3
3/3
3/3
3/3
6,878.
161
1,924.
12.
7.
8,981.
10.
1,181.
980.
15.
645.
18.
40.
1
.0
2
0
5
2
2
4
9
0
1
5
6
7,
2,
9,
1,
1,
703.2
290.0
700. OJ
12.0
9.8J
697.9
11. OJ
249. OJ
179. 8J
16.0
700. OJ
19.0
42.0
NOTES:
J = ESTIMATED VALUE
NA = NOT APPLICABLE SINCE ONLY ONE SAMPLE.
(A) THE NUMBER OF SAMPLES IN WHICH THE CONTAMINANT WAS DETECTED DIVIDED
BY THE TOTAL NUMBER OF SAMPLES ANALYZED. IN DETERMINING THE
FREQUENCY OF DETECTED, SAMPLES FLAGGED WITH AN "R" (REJECTED) WERE NOT INCLUDED.
* = SELECTED AS CHEMICAL OF POTENTIAL CONCERN FOR THE RISK ASSESSMENT.
-------
TABIiE A-4
SUMMARY OF CHEMICALS DETECTED IN THE
DRAINAGE CHANNEL SEDIMENTS AT THE KEM-PEST LABORATORIES SITE (B) (UG/KG)
AREA/CHEMICAL
ORGANICS:
FREQUENCY OF
DETECTION(A)
GEOMETRIC
MEAN
MAXIMUM
DETECTED
*ALDRIN 40/48
*ALPHA-BHC 2/25
*BETA-BHC 2/23
*CHLORDANE 47/48
*DDT 38/48
*DIELDRIN 40/48
*ENDOSULFANS IS II 9/46
*ENDOSULFAN
SULFATE 1/21
*ENDRIN 40/48
*ENDRIN KETONE 27/47
GAMMA-BHC 7/23
*HEPTACHLOR 44/48
*HEPTACHLOR EPOXIDE 43/48
*METHAXYCHLOR 4/38
114.1
5.4
5.2
1,114.7
314.2
280.0
252.5
7.3
196.0
63.1
4.0
345.8
136.3
121.3
58,000.0
24.0
19.OJ
45,900.0
44,490.0
34,000.0
4,600.0J
21.0
11,OOO.OJ
4,500.0J
21.0
240,000.0
2,800.0
2,100.0J
NOTES:
J = ESTIMATED VALUE
M = CHEMICAL WAS DETECTED AT LEVEL BELOW CRQL; SIMILAR TO J VALUE.
NA = NOT APPLICABLE SINCE ONLY ONE SAMPLE.
NR = THE GEOMETRIC MEAN WAS NOT REPORTED (NR), AS THIS CONCENTRATION WAS
GREATER THAN THE MAXIMUM DETECTED VALUE (AS A RESULT OF INCLUDING
DETECTION LIMITS THAT EXCEEDED TWO TIMES THE MAXIMUM DETECTED VALUE
IN CALCULATING THE GEOMETRIC MEAN).
(A) THE NUMBER OF SAMPLES IN WHICH THE CONTAMINANT WAS DETECTED DIVIDED
BY THE TOTAL NUMBER OF SAMPLES ANALYZED. IN DETERMINING THE
FREQUENCY OF DETECTED, SAMPLES FLAGGED WITH AN "R" (REJECTED) WERE NOT INCLUDED.
(B) ONLY PESTICIDES AND PCBS WERE ANALYZED FOR IN THESE SAMPLE.
* = SELECTED AS CHEMICAL OF POTENTIAL CONCERN FOR THE RISK ASSESSMENT.
-------
TABIiE B-l
SUMMARY OF SELECTED CHEMICALS OF POTENTIAL CONCERN
FOR THE KEM-PEST LABORATORIES SITE
CHEMICALS
ORGANICS
SURFACE SOIL
(DISCRETE (COMPOSITE
SAMPLES) SAMPLES) SEDIMENTS
ALDRIN (A)
BENZENE (B)
ALPHA-BHC (A)
BETA-BHC (A)
DELTA-BHC (A)
GAMMA-BHC (A)
2-BUTANONE (B)
CARBON DISULFIDE (B)
CHLORDANE (A)
CHLOROBENZENE (B)
CHLOROFORM (B)
DDT (A)
3,3-DICHLOROBENZIDINE (C)
1,1-DICHLOROETHANE (B)
1,2-DICHLOROETHANE (B)
2,4-DICHLOROPHENOL (C)
DIELDRIN (A)
2,4-DIMETHYLPHENOL (C)
DI-N-BUTYLPHTHALATE (C)
ENDOSULFAN SULFATE (A)
ENDOSULFAN I & II (A)
ENDRIN (A)
ENDRIN KETONE (A)
ETHYLBENZENE (B)
HEPTACHLOR (A)
HEPTACHLOR EPOXIDE (A)
HEXACHLOROBUTADIENE (C)
METHAXYCHLOR (A)
2-METHYLPHENOL (C)
N-NITROSODIPHENYLAMINE (C)
NCPAHS (C)
PENTACHLOROPHENOL (C)
TOLUENE (B)
TOXAPHENE (A)
1,1,1-TRICHLOROETHANE (B)
2,4,5-TRICHLOROPHENOL (C)
XYLENE (TOTAL) (B)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
SURFACE
SOIL
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
BUILDING
SAMPLES
(ALL MEDIA)
X
X
X
X
X
X
X
X
X
X
INORGANICS
ARSENIC
LEAD
X
X
(A) PESTICIDE
(B) VOLATILE ORGANIC
(C) SEMIVOLATILE ORGANIC
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TABIiE D-2
NUMERICAL VALUES FOR OTHER CRITERIA, STANDARDS, OR GUIDANCE TO BE
CONSIDERED FOR SELECTED COMPOUNDS DETECTED IN SURFACE SOIL AND SEDIMENTS
COMPOUND
SOIL
MAXIMUM CONCENTRATIONS DETECTED
KEM-PEST LABORATORIES SITE (MG/KG)
SURFACE
SEDIMENT
ALDRIN 17
DIELDRIN 58
HEPTACHLOR EPOXIDE 4.8
ALPHA-BHC U
HEPTACHLOR 94
ARSENIC 170
BETA-BHC 0.002
CHLORDANE 39
GAMMA-BHC 0.002
TOXAPHENE 4 6
DDT 37
34
2.8
0.024
240
0.019
39
0.021
U
32
NUMERICAL VALUES FOR OTHER CRITERIA, STANDARDS, OR GUIDANCE TO BE
CONSIDERED FOR SELECTED COMPOUNDS DETECTED IN SURFACE SOIL AND SEDIMENTS
COMPOUND
ACCEPTABLE CONTAMINANT
CONCENTRATIONS IN SOIL
MAXIMUM PLAUSIBLE CASE AT
SELECTED CANCER RISK LEVELS
(MG/KG)(A)
1X10(-6)
MDOH RECOMMENDED
SAFE SOIL LEVELS
UNRESTRICTED FUTURE
USE (MG/KG)
1X10 (-5)
1X10(-4)
ALDRIN 0 . 2
DIELDRIN 0.2
HEPTACHLOR EPOXIDE 0.3
ALPHA-BHC 0.4
HEPTACHLOR 0.6
ARSENIC 1.1
1.6
1.7
3.1
4.4
6.2
11.3
16.5
17.5
30.8
44.4
62.2
113.0
0.104
0.087
1.9
3.8
BETA-BHC
CHLORDANE
GAMMA-BHC
TOXAPHENE
DDT
1.6
2.2
2.0
2.5
8.2
15.6
21.5
20.0
25.5
82.3
156.0
215.0
200.0
254.0
824.0
1.285
1.42
0.001
U = UNDETECTED
A = MAXIMUM PLAUSIBLE CASE FOR RESIDENTIAL USE OF THE SITE. ASSUMES 30
YEARS OF EXPOSURE. 210 DAYS/YR., 120 MG SOIL INGESTED PER DAY
(WEIGHTED AVERAGE OVER EXPOSURE PERIOD). CONTACT WITH HANDS AND
FOREARMS (1,760 CM(2)); BIOAVAILABILITY FOR ORAL INGESTION IS 50%
FOR PESTICIDES AND 80% FOR ARSENIC; BIOAVAILABILITY FOR DERMAL
CONTACT IS 2% FOR DDT, 2.7% FOR GAMMA-BHC, 2% FOR OTHER PESTICIDES,
AND NO ABSORPTION OF ARSENIC.
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TABIiE D-3
ESTIMATED ACCEPTABLE CONTAMINANT CONCENTRATIONS FOR SUBSURFACE SOIL
BASED ON MAXIMUM CASE INHALATION EXPOSURE TO FUTURE RESIDENTS
CHEMICAL ACCEPTABLE CONTAMINANT CONCENTRATION
(MG/KG)
1X10(-4) 1X10(-5) 1X10(-6)
ALDRIN
ALPHA- BHC
BETA-BHC
CHLORDANE
DDT
DIELDRIN
GAMMA- BHC
HEPTACHLOR
HEPTACHLOR EPOXIDE
4.6
39
1700
62
31,000
4.0
45
0.72
5.1
0.46
3.9
170
6.2
3,100
0.40
4.5
0.072
0.51
0.046
0.39
17
0.62
310
0.040
0.45
0.0072
0.051
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RESPONSIVENESS SUMMARY
1.0 INTRODUCTION
THIS RESPONSIVENESS SUMMARY PRESENTS RESPONSES OF THE US ENVIRONMENTAL PROTECTION AGENCY (EPA)
TO PUBLIC COMMENTS RECEIVED REGARDING REMEDIAL ACTION FOR CONTAMINATED SOIL AND SEDIMENT AT THE
KEM-PEST LABORATORIES SITE IN CAPE GIRARDEAU COUNTY, MISSOURI.
A BRIEF OUTLINE OF THE RESPONSIVENESS SUMMARY IS PROVIDED BELOW:
SECTION 2.0 PROVIDES BACKGROUND INFORMATION ON THE PROPOSED PLAN WHICH PRESENTED THE
REMEDIAL ALTERNATIVES DEVELOPED FOR THE SITE AND THE PREFERRED ALTERNATIVE FOR
CLEANUP. THIS SECTION ALSO BRIEFLY DISCUSSES THE SELECTED REMEDY.
SECTION 3.0 DESCRIBES COMMUNITY PARTICIPATION IN THE SELECTION OF THE FINAL REMEDY
FOR CONTAMINATED SOILS AND SEDIMENT.
SECTION 4.0 INCLUDES A SUMMARY OF COMMENTS RECEIVED FROM ALL INTERESTED PARTIES,
INCLUDING POTENTIALLY RESPONSIBLE PARTIES (PRPS). A RESPONSE BY EPA TO EACH COMMENT
SUMMARY IS PROVIDED.
ATTACHMENT A PROVIDES A SUMMARY OF COMMENTS SUBMITTED BY THE PRPS AND THE RESPONSES
PROVIDED BY THE AGENCY. THE SUMMARY OF COMMENTS AND RESPONSES ARE BEING PROVIDED AS
AN ATTACHMENT DUE TO THE LENGTH AND DETAIL OF THE COMMENTS.
2.0 PROPOSED PLAN/SEIiECTED REMEDY
PROPOSED PLAN
ON AUGUST 18, 1989, EPA ISSUED THE PROPOSED PLAN FOR THE KEM-PEST LABORATORIES SITE. THE PLAN
PRESENTED EXCAVATION AND DISPOSAL IN AN OFFSITE HAZARDOUS WASTE LANDFILL AS THE PREFERRED
ALTERNATIVE FOR THE CLEANUP OF CONTAMINATED SOIL AND SEDIMENT AT THE SITE. THE PLAN ALSO
PROVIDED BACKGROUND INFORMATION ON THE NATURE OF THE PROBLEM AT THE SITE AND DESCRIBED OTHER
REMEDIAL ALTERNATIVES WHICH WERE CONSIDERED.
IN ADDITION TO DESCRIBING REMEDIAL OPTIONS FOR CLEANUP, THE PLAN ALSO OUTLINED HOW THE PUBLIC
COULD PARTICIPATE IN SELECTION OF THE FINAL REMEDY.
SELECTED REMEDY
BASED ON AN EVALUATION OF THE RELATIVE PERFORMANCE OF EACH ALTERNATIVE WITH RESPECT TO NINE
EVALUATION CRITERIA, AND CONSIDERATION OF COMMENTS RECEIVED FROM THE COMMUNITY, INCLUDING THE
PRPS, EPA AND THE STATE OF MISSOURI SELECTED EXCAVATION AND DISPOSAL IN AN OFFSITE HAZARDOUS
WASTE LANDFILL AS THE MOST APPROPRIATE REMEDY FOR CONTAMINATED SOIL AND SEDIMENT AT THE SITE.
A RISK ASSESSMENT WAS CONDUCTED TO EVALUATE THE POTENTIAL EFFECTS TO HUMAN HEALTH FOR CURRENT
AND FUTURE LAND USE SCENARIOS. THE RESULTS OF THE RISK ASSESSMENT INDICATED THAT CONCENTRATIONS
OF CONTAMINANTS IN SOIL AND SEDIMENT AT SEVERAL LOCATIONS ON AND ADJACENT TO THE SITE RESULT IN
EXCESS LIFETIME CANCER RISKS AS HIGH AS 7 X 10-5 CURRENT LAND USE AND 1 X 10-3 FOR FUTURE
RESIDENTIAL LAND USE.
PROTECTIVE CONTAMINANT SOIL CONCENTRATIONS WERE CALCULATED USING RISK ASSESSMENT TECHNIQUES FOR
CHEMICALS OF CONCERN AT THE SITE. BASED ON THE PROTECTIVE SOIL CONCENTRATIONS, APPROXIMATELY
4,050 CUBIC YARDS OF CONTAMINATED SOIL AND SEDIMENT WOULD BE EXCAVATED AND TRANSPORTED TO A
RCRA-APPROVED COMMERCIAL HAZARDOUS WASTE LANDFILL FOR DISPOSAL. THE RCRA FACILITY WOULD PROVIDE
SECURE, LONG-TERM MANAGEMENT THROUGH SPECIALLY DESIGNED COVERS, MULTI-LINER SYSTEMS, LEACHATE
DETECTION AND COLLECTION COMPONENTS AND MONITORING.
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3.0 COMMUNITY PARTICIPATION
PRIOR TO THE INITIATION OF THE REMEDIAL INVESTIGATION (RI), A COMMUNITY RELATIONS PLAN WAS
DEVELOPED BASED ON INTERVIEWS CONDUCTED BY THE COMMUNITY RELATIONS STAFF WITH RESIDENTS AND
LOCAL OFFICIALS. THE PLAN DOCUMENTED THE ISSUES OF CONCERN TO THE COMMUNITY WHICH INCLUDED THE
NEED FOR INFORMATION ON FUTURE SITE ACTIVITIES AND POTENTIAL THREATS TO HUMAN HEALTH.
AT THE START OF RI FIELD ACTIVITIES, THE EPA REMEDIAL PROJECT MANAGER MET WITH THE CAPE
GIRARDEAU COUNTY COMMISSION AND OTHER LOCAL COUNTY AND CITY OFFICIALS TO DISCUSS THE FIELD WORK.
THE PROJECT MANAGER ALSO CONDUCTED INFORMAL INTERVIEWS AT NEARBY RESIDENCES TO INFORM THEM OF
SITE ACTIVITIES AND TO ANSWER QUESTIONS.
FACT SHEETS ABOUT THE PROJECT WERE MAILED TO RESIDENTS, LOCAL OFFICIALS AND THE MEDIA. DURING
FIELD WORK, NEARBY RESIDENTS AND LOCAL OFFICIALS WERE PROVIDED UPDATES.
IN AUGUST 1989, THE RI AND OPERABLE UNIT FEASIBILITY (OUFS) REPORTS AND PROPOSED PLAN WERE MADE
AVAILABLE TO THE PUBLIC IN THE ADMINISTRATIVE RECORD LOCATED AT THE CAPE GIRARDEAU PUBLIC
LIBRARY AND AT EPA REGION VII OFFICES IN KANSAS CITY. A PUBLIC NOTICE WAS ISSUED ANNOUNCING THE
AVAILABILITY OF DOCUMENTS, THE START OF THE PUBLIC COMMENT PERIOD AND THE DATE OF THE PUBLIC
MEETING. THE PUBLIC NOTICE WAS PUBLISHED IN THE SOUTHEAST MISSOURIAN ON AUGUST 18, 1989, AND IN
THE CAPE GIRARDEAU NEWS GUARDIAN ON AUGUST 23, 1989.
FACT SHEETS WERE ALSO MAILED TO RESIDENTS, LOCAL OFFICIALS AND THE MEDIA ANNOUNCING THE
AVAILABILITY OF DOCUMENTS, THE PUBLIC COMMENT PERIOD AND THE PUBLIC MEETING.
THE PUBLIC COMMENT PERIOD WAS HELD FROM AUGUST 18, 1989, THROUGH SEPTEMBER 18, 1989. A PUBLIC
MEETING WAS HELD IN CAPE GIRARDEAU ON SEPTEMBER 5, 1989. AT THE MEETING, REPRESENTATIVES FROM
EPA, THE AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY (ATSDR) AND THE MISSOURI DEPARTMENT OF
NATURAL RESOURCES (MDNR) PROVIDED INFORMATION ON THE SITE AND DISCUSSED THE REMEDIAL
ALTERNATIVES UNDER CONSIDERATION. DURING AN EXTENSION OF THE COMMENT PERIOD, THE EPA COMMUNITY
RELATIONS STAFF CONDUCTED INTERVIEWS WITH CONCERNED CITIZENS.
4.0 SUMMARY OF PUBLIC COMMENTS AND AGENCY RESPONSES
THIS SECTION PROVIDES A SUMMARY OF COMMENTS RECEIVED FROM THE COMMUNITY, INCLUDING THE PRPS, AND
PRESENTS THE AGENCY'S RESPONSE. STATEMENTS MADE AT THE PUBLIC MEETING ARE SUMMARIZED FIRST WITH
EPA'S RESPONSES TO THE STATEMENTS. WRITTEN COMMENTS RECEIVED BY EPA AND THE AGENCY'S RESPONSES
ARE PROVIDED NEXT.
COMMENTS RECEIVED AT PUBLIC MEETING
A. A COMMENTOR ASKED WHY INFORMATION REGARDING THE FEBRUARY AND MARCH SAMPLING HAD NOT BEEN
PROVIDED BY THE AGENCY. THE COMMENTOR NOTED THAT WHEN HER WELL WAS SAMPLED IN 1987, SHE
RECEIVED INFORMATION IN THE MAIL. THE COMMENTOR EXPLAINED THAT IN FEBRUARY AND MARCH A
FIELD CREW WAS ON HER FARM, LOCATED IMMEDIATELY NORTH OF THE SITE.
EPA RESPONSE: THE REMEDIAL INVESTIGATION FIELD ACTIVITIES CONDUCTED BY EPA IN FEBRUARY AND
MARCH OF 1989 DID NOT INCLUDE ANY SAMPLING OR OTHER FIELD ACTIVITIES ON THE COMMENTOR'S
PROPERTY, LOCATED NORTH OF THE KEM-PEST SITE. FIELD ACTIVITIES WERE CONDUCTED BY EPA ON THE
NORTHERN PORTION OF THE KEM-PEST SITE; NO FIELD ACTIVITIES WERE CONDUCTED NORTH OF THE SITE
PROPERTY BOUNDARY. INFORMATION OBTAINED DURING THE FIELD ACTIVITIES, INCLUDING SAMPLE RESULTS,
ARE PROVIDED IN THE REMEDIAL INVESTIGATION REPORT, AVAILABLE FOR REVIEW AT THE CAPE GIRARDEAU
PUBLIC LIBRARY.
B. A COMMENTOR ASKED WHERE PUBLIC COMMENTS SHOULD BE SUBMITTED.
EPA RESPONSE: THE COMMENTOR WAS PROVIDED THE NAME AND MAILING ADDRESS OF THE EPA CONTACT. THE
COMMENTOR WAS ALSO INFORMED OF THE TOLL FREE NUMBER ON THE BACK OF THE FACT SHEET.
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C. THE CAPE GIRARDEAU PRESIDING COUNTY COMMISSIONER STATED THAT A WEEK WAS NOT ENOUGH TIME FOR
RESIDENTS TO COMMENT. THE COMMISSIONER EMPHASIZED THAT IF THE RESIDENTS HAVE COMMENTS TO
MAKE, THE AGENCY SHOULD LISTEN.
EPA RESPONSE: ON AUGUST 18, 1989, THE AGENCY ISSUED A PUBLIC NOTICE IN THE SOUTHEAST MISSOURIAN
ANNOUNCING THE START OF A 21-DAY PUBLIC COMMENT PERIOD. THE PUBLIC NOTICE WAS AGAIN PUBLISHED
ON AUGUST 23, 1989, IN THE CAPE GIRARDEAU NEWS GUARDIAN. THE PUBLIC NOTICES ALSO PROVIDED
INFORMATION REGARDING THE PUBLIC MEETING ON SEPTEMBER 5, AND THE AVAILABILITY OF EPA REPORTS AT
THE LOCAL LIBRARY.
PRIOR TO PUBLICATION OF THE TWO PUBLIC NOTICES, THE COUNTY COMMISSIONER'S OFFICE AND OTHER
COUNTY AND CITY OFFICES WERE NOTIFIED OF THE PUBLIC COMMENT PERIOD.
FACT SHEETS WERE ALSO SENT TO RESIDENTS, LOCAL OFFICIALS AND THE MEDIA ANNOUNCING THE PUBLIC
COMMENT PERIOD, THE PUBLIC MEETING AND THE AVAILABILITY OF DOCUMENTS AT THE LIBRARY.
NEVERTHELESS, IN RESPONSE TO THE COUNTY COMMISSIONER'S CONCERN REGARDING THE OPPORTUNITY FOR
RESIDENTS TO SUBMIT COMMENTS, THE EPA EXTENDED THE PUBLIC COMMENT PERIOD FROM SEPTEMBER 8 TO
SEPTEMBER 18. IN ADDITION, EPA COMMUNITY RELATIONS STAFF MET WITH AREA RESIDENTS IN CAPE
GIRARDEAU TO LISTEN TO AND RECEIVE ORAL OR WRITTEN COMMENTS.
WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
A. A LOCAL RESIDENT EXPRESSED SUPPORT FOR THE PREFERRED ALTERNATIVE. THE COMMENTOR ALSO
EXPRESSED CONCERN REGARDING LONG-TERM HEALTH EFFECTS TO CURRENT AND FORMER AREA RESIDENTS.
THE COMMENTOR NOTED THAT SEVERAL FAMILIES OBTAINED WATER FROM A SHALLOW WELL AT A HOUSE
WHICH HAD BEEN LOCATED DIRECTLY ACROSS FROM THE SITE; THE HOUSE WAS DEMOLISHED SEVERAL YEARS
AGO.
EPA RESPONSE: REMEDIAL ACTION AT THE SITE IS BEING IMPLEMENTED THROUGH A SERIES OF OPERABLE
UNITS, OR DISCRETE RESPONSE ACTIONS. THIS FIRST OPERABLE UNIT ADDRESSED THE THREATS POSED BY
CONTAMINATED SOILS AND SEDIMENTS. OPERABLE UNITS ADDRESSING GROUND WATER AND THE FORMULATION
BUILDING WILL BE INITIATED SOON. A RISK ASSESSMENT WILL BE CONDUCTED TO EVALUATE THE POTENTIAL
THREATS POSED BY GROUND WATER. EPA WILL PROVIDE THE RESULTS OF THIS EVALUATION WHEN COMPLETED.
THE AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY (ATSDR) IS ALSO CONDUCTING A HEALTH
ASSESSMENT TO ASSESS IMPACTS ON PUBLIC HEALTH. THIS HEALTH ASSESSMENT WILL INCLUDE A
DETERMINATION REGARDING THE NEED FOR FOLLOW-UP HEALTH EFFECTS STUDIES OF EXPOSED POPULATIONS.
ATSDR WILL BE ASKED TO CONTACT THE COMMENTOR REGARDING THE HEALTH ASSESSMENT CONCLUSIONS.
B. A FORMER RESIDENT EXPRESSED SUPPORT FOR THE PREFERRED ALTERNATIVE. THE COMMENTOR ALSO
EXPRESSED CONCERN REGARDING THE LACK OF HEALTH ASSESSMENTS FOR PERSONS WHO HAVE LIVED IN THE
VICINITY OF THE SITE. THE COMMENTOR NOTED THAT ON NUMEROUS OCCASIONS CHILDREN WERE SEEN
PLAYING AT THE LAGOON AND, ON AT LEAST ONE OCCASION, A CHILD WAS SEEN IN THE LAGOON.
EPA RESPONSE: AS DISCUSSED IN THE PREVIOUS RESPONSE, A RISK ASSESSMENT ADDRESSING GROUND WATER
AND A HEALTH ASSESSMENT WILL BE COMPLETED FOR THE SITE. ATSDR WILL BE ASKED TO CONTACT THE
COMMENTOR REGARDING THE HEALTH ASSESSMENT CONCLUSIONS.
C. AN EXTENSIVE COMMENT PACKAGE WAS SUBMITTED BY THE POTENTIALLY RESPONSIBLE PARTIES. THIS
COMMENT PACKAGE IDENTIFIED SEVERAL AREAS OF CONCERN. DUE TO THE LENGTH AND DETAIL OF THE
PRPS' COMMENTS AND THE RESPONSES PROVIDED BY THE AGENCY, THE SUMMARY OF COMMENTS AND
RESPONSES ARE PROVIDED AS AN ATTACHMENT TO THIS DOCUMENT. THE ENTIRE (PRP) COMMENT PACKAGE
AND THE AGENCY'S RESPONSE TO EACH COMMENT ARE PROVIDED IN A SEPARATE DOCUMENT WHICH IS
AVAILABLE FOR REVIEW IN THE ADMINISTRATIVE RECORD LOCATED AT THE CAPE GIRARDEAU PUBLIC
LIBRARY.
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PRP COMMENT LETTER DATED 9/12/89
A. THE EXCAVATION AND OFF-SITE DISPOSAL OF SOILS AND SEDIMENTS IS NOT COST-EFFECTIVE.
* EPA MUST SELECT EXCAVATION/CAPPING REMEDY BECAUSE THE OUFS
INDICATES IT IS EXPECTED TO ACHIEVE THE HEALTH-BASED GOALS AT A
COST OF $1.1 MILLION WHICH IS SIGNIFICANTLY LESS EXPENSIVE.
EPA RESPONSE TO A:
THE EPA HAS DEVELOPED NINE EVALUATION CRITERIA TO ADDRESS CERCLA STATUTORY REQUIREMENTS AND
TECHNICAL, COST, AND INSTITUTIONAL CONSIDERATIONS. THE EVALUATION CRITERIA SERVE AS THE BASIS
FOR CONDUCTING THE DETAILED ANALYSES OF ALTERNATIVES DURING THE OUFS AND FOR SUBSEQUENTLY
SELECTING AN APPROPRIATE REMEDY.
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT AND COMPLIANCE WITH APPLICABLE OR
RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS) ARE THRESHOLD CRITERIA THAT MUST BE SATISFIED IN
ORDER FOR AN ALTERNATIVE TO BE ELIGIBLE FOR SELECTION. LONG-TERM EFFECTIVENESS AND PERMANENCE,
REDUCTION OF TOXICITY, MOBILITY, OR VOLUME, SHORT-TERM EFFECTIVENESS, IMPLEMENTABILITY, AND COST
ARE THE PRIMARY BALANCING FACTORS USED TO EVALUATE THE MAJOR TRADE-OFFS BETWEEN THE
ALTERNATIVES.
AS STATED IN THE OUFS, ALL THE ALTERNATIVES, WITH THE EXCEPTION OF NO ACTION, WOULD ATTAIN
HEALTH-BASED GOALS. HOWEVER, BASED UPON AN EVALUATION OF THE RELATIVE PERFORMANCE OF EACH
ALTERNATIVE WITH RESPECT TO THE PRIMARY BALANCING CRITERIA, AND CONSIDERATION OF COMMENTS
RECEIVED DURING THE PUBLIC COMMENT PERIOD, BOTH EPA AND THE STATE OF MISSOURI DETERMINED THAT
EXCAVATION AND OFFSITE LANDFILL WAS THE MOST APPROPRIATE REMEDY FOR CONTAMINATED SOIL AND
SEDIMENT AT THE KEM-PEST SITE.
THE SELECTED REMEDY PROVIDES A HIGHER DEGREE OF LONG-TERM EFFECTIVENESS AND PERMANENCE THAN THE
CAPPING ALTERNATIVE. THE SELECTED REMEDY WOULD NOT REQUIRE LONG-TERM MANAGEMENT OR
INSTITUTIONAL CONTROLS AT THE SITE. A RCRA-PERMITTED HAZARDOUS WASTE FACILITY WOULD PROVIDE MORE
SECURE, LONG-TERM CONTAINMENT THROUGH A DOUBLE LINER SYSTEM, LEACHATE DETECTION AND COLLECTION
SYSTEM AND MONITORING PROGRAMS. IN COMPARISON, CAPPING PROVIDES A LESSER DEGREE OF LONG-TERM
EFFECTIVENESS AND PERMANENCE. THIS OPTION WOULD REQUIRE LONG-TERM MAINTENANCE AND MONITORING AT
THE SITE. LAND USE AND GROUND WATER USE RESTRICTIONS FOR THE LIFE OF THE ALTERNATIVE WOULD BE
REQUIRED. MOREOVER, CAPPING DOES NOT ADDRESS POTENTIAL THREATS POSED BY CONTAMINATED SUBSURFACE
SOILS TO GROUND WATER; THE POTENTIAL FOR FUTURE RELEASE AND EXPOSURE WOULD HAVE TO BE
CONSIDERED.
THE SELECTED REMEDY REDUCES BOTH THE VOLUME AND MOBILITY OF CONTAMINATED MATERIAL LOCATED AT THE
SITE. THE CONTAMINATED SOIL AND SEDIMENT REMOVED FROM THE SITE WOULD BE EFFECTIVELY CONTAINED
AT THE OFFSITE FACILITY MEETING RCRA DESIGN AND OPERATING REQUIREMENTS INCLUDING DOUBLE LINER,
LEACHATE DETECTION AND COLLECTION SYSTEM, AND MONITORING. CAPPING, ON THE OTHER HAND, DOES NOT
REDUCE THE VOLUME OF CONTAMINATED MATERIAL ON THE SITE. THE MOBILITY OF CONTAMINANTS IN THE
SUBSURFACE SOILS WOULD REMAIN A CONCERN.
THE SELECTED REMEDY IS MORE EFFECTIVE THAN THE CAPPING ALTERNATIVE IN THE SHORT-TERM, REQUIRING
7-9 MONTHS TO IMPLEMENT AS COMPARED TO A YEAR FOR CAPPING.
THE SELECTED REMEDY HAS FEWER TECHNICAL DIFFICULTIES ASSOCIATED WITH IMPLEMENTATION. IN
ADDITION, THE SELECTED REMEDY WOULD NOT PRESENT ANY SIGNIFICANT PROBLEMS IF FUTURE REMEDIAL
ACTIONS WERE REQUIRED. THE CAPPING ALTERNATIVE, IN COMPARISON, WOULD BE MORE DIFFICULT TO
IMPLEMENT. CONSTRUCTION OF THE CAP AROUND THE BUILDING WOULD BE TECHNICALLY COMPLEX. THE CAP
WOULD ALSO MAKE IT MORE DIFFICULT TO IMPLEMENT ADDITIONAL REMEDIAL ACTIONS, IF REQUIRED.
THE SELECTED REMEDY IS COST-EFFECTIVE WHEN THE OVERALL RELATIONSHIP BETWEEN COST AND
EFFECTIVENESS IS COMPARED TO THE COST/EFFECTIVENESS RELATIONSHIP OF CAPPING. AS DESCRIBED
ABOVE, THE SELECTED ALTERNATIVE PROVIDES A HIGHER DEGREE OF LONG-TERM EFFECTIVENESS AND
PERMANENCE, SHORT-TERM EFFECTIVENESS AND TECHNICAL FEASIBILITY, AND PROVIDES FOR A REDUCTION OF
-------
MOBILITY AND VOLUME.
THE SELECTED REMEDY WAS SUPPORTED BY THE STATE OF MISSOURI. THE STATE INDICATED THAT CAPPING
WAS THE LEAST PREFERRED ALTERNATIVE DUE TO CONCERNS REGARDING THE POTENTIAL IMPACT OF
CONTAMINATED SUBSURFACE SOIL ON THE GROUND WATER.
DURING THE PUBLIC COMMENT PERIOD, THE AGENCY RECEIVED TWO WRITTEN COMMENTS FROM AREA RESIDENTS.
BOTH COMMENTS EXPRESSED SUPPORT FOR THE OFFSITE HAZARDOUS LANDFILL ALTERNATIVE.
BASED ON AN EVALUATION OF THE RELATIVE PERFORMANCE OF EACH ALTERNATIVE WITH RESPECT TO THE
EVALUATION CRITERIA, AND CONSIDERATION OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
FROM THE STATE OF MISSOURI AND THE COMMUNITY, EXCAVATION AND OFFSITE LANDFILL IS THE MOST
APPROPRIATE REMEDY FOR CONTAMINATED SOIL AND SEDIMENT AT THE KEM-PEST SITE.
B. THE REMEDY PROPOSED BY EPA IS UNREASONABLE, ARBITRARY AND CAPRICIOUS BECAUSE IT DOES NOT
CONSIDER RELEVANT DATA.
1. OUFS OVERESTIMATES ALLEGED HEALTH AND ENVIRONMENTAL EFFECTS
OF PESTICIDES BECAUSE IT ASSUMES FUTURE RESIDENTIAL USE.
2. OUFS UNREASONABLY ASSUMES THAT THE SOILS AND SEDIMENTS
ARE A RCRA HAZARDOUS WASTE.
3. OUFS DOES NOT CONSIDER BACKGROUND LEVELS OF PESTICIDES IN
AGRICULTURAL AND RESIDENTIAL AREAS, PESTICIDE LEVELS IN
SOILS WHEN APPLIED ACCORDING TO ACCEPTED PRACTICES, OR
THE RATE AT WHICH THE PESTICIDES NATURALLY DEGRADE.
EPA RESPONSE TO B-l:
THE PUBLIC HEALTH EVALUATION ADDRESSES THE POTENTIAL IMPACTS ON HUMAN HEALTH ASSOCIATED WITH THE
SITE UNDER THE NO-ACTION ALTERNATIVE. EVALUATION OF THE NO-ACTION ALTERNATIVE IS REQUIRED BY THE
NATIONAL CONTINGENCY PLAN. THE NO-ACTION ALTERNATIVE ASSUMES THAT NO REMEDIAL ACTIONS AND NO
LAND USE RESTRICTIONS WOULD BE APPLIED TO THE SITE.
AN EXPOSURE ASSESSMENT, A COMPONENT OF THE PUBLIC HEALTH EVALUATION, WAS CONDUCTED TO IDENTIFY
THE POTENTIAL PATHWAYS BY WHICH HUMAN POPULATIONS COULD BE EXPOSED TO CONTAMINANTS. IN
IDENTIFYING POTENTIAL PATHWAYS OF EXPOSURE, BOTH CURRENT AND FUTURE LAND USE WAS CONSIDERED.
FUTURE RESIDENTIAL USE WAS EVALUATED IN ORDER TO PROVIDE AN UPPER BOUND ON EXPOSURE AND RISK
ESTIMATES FOR SOILS AND SEDIMENTS FROM FUTURE USE OF THE SITE.
RESIDENTIAL USE OF THE SITE MAY BE LESS LIKELY TO OCCUR THAN INDUSTRIAL USE GIVEN THE AREA IS
ZONED FOR INDUSTRIAL USE AND OTHER INSTITUTIONAL CONTROLS RESTRICTING LAND USE MAY BE AVAILABLE.
HOWEVER, FUTURE RESIDENTIAL USE REPRESENTS A REASONABLE MAXIMUM EXPOSURE SCENARIO.
A REVIEW OF PAST AND PRESENT LAND USE IN THE IMMEDIATE VICINITY INDICATED THAT RESIDENTIAL USE
IS A PRIMARY USE OF LAND IN THE AREA. OVER A DOZEN RESIDENCES ARE CURRENTLY LOCATED WITHIN A
1000 FOOT RADIUS OF THE SITE. THE CLOSEST RESIDENCE IS WITHIN 500 FEET OF THE SITE. WITH
RESPECT TO PAST USE OF THE LAND, A HOME WAS LOCATED LESS THAN 300 FEET FROM THE SITE ENTRANCE
DURING THE PERIOD OF PLANT OPERATIONS.
IN ADDITION, THERE ARE LEGITIMATE CONCERNS REGARDING INSTITUTIONAL CONTROLS. ZONING CHANGES
COULD CONCEIVABLY OCCUR. IMPLEMENTATION, ENFORCEABILITY, RELIABILITY, AND LONG-TERM
EFFECTIVENESS ARE ADDITIONAL ISSUES RELATING TO THE USE OF INSTITUTIONAL CONTROLS.
EPA RESPONSE TO B-2:
EPA HAS DETERMINED THAT THE WASTES GENERATED AT THE KEM-PEST SITE ARE RCRA HAZARDOUS WASTES. AS
STATED IN THE PRPS' COMMENT, ALDRIN, DIELDRIN, HEPTACHLOR, CHLORDANE, DDT, LINDANE AND TOXAPHENE
ARE LISTED UNDER SECTION 261.33(F), COMMERCIAL CHEMICAL PRODUCTS. INFORMATION PROVIDED BY THE
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PRPS TO EPA IN THEIR NOTIFICATION OF HAZARDOUS WASTE SITE PURSUANT TO SECTION 103 OF CERCLA AND
THEIR RESPONSE TO EPA'S INFORMATION REQUEST UNDER SECTION 104(E) OF CERCLA STATED THAT SPILLS OF
COMMERCIAL CHEMICAL PRODUCTS WERE WASHED DOWN THE DRAIN OF THE FORMULATION BUILDING AND DISPOSED
OF IN THE LAGOON. ACCORDINGLY, THERE WAS DISPOSAL OF A RCRA HAZARDOUS WASTE IN THE LAGOON.
FURTHERMORE, ANY WASTES GENERATED FROM THE TREATMENT, STORAGE OR DISPOSAL OF A HAZARDOUS WASTE
IS A HAZARDOUS WASTE. NONE OF THE EXEMPTIONS OR EXCLUSIONS SET FORTH IN 40 CFR 261.3 OR 261.4
WERE FOUND TO BE APPLICABLE TO THE WASTES GENERATED AT THE KEM-PEST SITE.
EPA RESPONSE TO B-3:
THE SURFACE APPLICATION OF CHLORDANE AND HEPTACHLOR WAS USED EXTENSIVELY IN AGRICULTURE AND
AROUND THE HOME FOR CONTROLLING A VARIETY OF INSECTS UNTIL BANNED BY THE EPA IN THE MID-1970'S,
BASED ON EVIDENCE THAT THESE SUBSTANCES CAUSED TUMORS IN LABORATORY ANIMALS AND WERE PERSISTENT
IN THE ENVIRONMENT. DUE TO THE PRESENCE OF ELEVATED LEVELS OF CHLORDANE IN AIR SAMPLES INSIDE
THE HOME, AND CONTINUED CONCERN WITH HEALTH EFFECTS, THE AGENCY RECENTLY BANNED THE FURTHER
SALE, DISTRIBUTION AND COMMERCIAL APPLICATION OF THE PESTICIDES CHLORDANE AND HEPTACHLOR FOR
TERMITE CONTROL.
THE PESTICIDES AT THE KEM-PEST SITE ARE VERY PERSISTENT IN SOILS AND ARE EXPECTED TO DEGRADE
VERY SLOWLY, THUS THE OVERALL RISKS ARE NOT EXPECTED TO BE SIGNIFICANTLY AFFECTED BECAUSE OF
DEGRADATION. DEGRADATION RATES CAN WIDELY VARY FROM ONE LOCATION TO ANOTHER AND ARE AFFECTED BY
A WIDE RANGE OF VARIABLES SUCH AS SOIL TYPE, SOIL TEMPERATURE, SOIL MOISTURE, PRECIPITATION,
SOIL MICROORGANISMS AND PERCENT SUNSHINE. FOR EXAMPLE, TABLE 1 IN EXHIBIT 6 OF THE COMMENTS
INDICATES THAT HOUSES #5 AND #6 (BOTH LOCATED ON CLAY SOILS IN THE PIEDMONT REGION OF NORTH
CAROLINA) PRESUMABLY EACH HAD 378 LITERS OF CHLORDANE (TERMIDE) APPLIED IN 1979 AND
APPROXIMATELY FOUR YEARS LATER THE RESIDUES IN SOIL (AT 0-10 CM) WERE VERY DIFFERENT AT THE TWO
SITES, 1,890 PPM FOR #5 AND 852 PPM FOR #6. THUS, THERE IS MUCH UNCERTAINTY ASSOCIATED WITH
USING DEGRADATION RATES FROM AREAS WITH DIFFERENT SOIL TYPES, ETC., THAN THE KEM-PEST SITE.
WE AGREE THAT THE OSHA STANDARDS SHOULD HAVE BEEN IDENTIFIED AS ARARS FOR INHALATION EXPOSURES
TO WORKERS AND THAT THE ESTIMATED AIR CONCENTRATIONS ARE LESS THAN THE OSHA STANDARDS. HOWEVER,
THE PROPOSED REMEDIATION OF SURFACE SOILS IS BASED ON ESTIMATED RISKS FROM DIRECT CONTACT
EXPOSURES AND IS NOT DEPENDENT ON THE ESTIMATED RISKS FROM INHALATION EXPOSURES SINCE THESE
RISKS ARE LOWER. THUS, THE USE OF THE OSHA VALUES AS ARARS WOULD NOT AFFECT THE RESULTS OF THE
FEASIBILITY STUDY.
THE INTERIM GUIDELINE LEVELS RECOMMENDED BY THE NATIONAL ACADEMY OF SCIENCES ARE NOT ENFORCEABLE
CRITERIA FOR THE SITE AND ARE NOT AVAILABLE FOR ALL THE CHEMICALS OF CONCERN AT THE SITE, THUS
CLEANUP LEVELS WERE NOT DERIVED BASED ON THESE VALUES, BUT WERE DERIVED USING QUANTITATIVE RISK
ASSESSMENT METHODS.
C. THE REMEDY PROPOSED BY EPA IS UNREASONABLE, ARBITRARY AND CAPRICIOUS BECAUSE IT IS BASED
UPON INADEQUATE DATA.
1. THE METHOD USED TO DERIVE SUBSURFACE SOIL CLEANUP LEVELS HAS NOT BEEN DEMONSTRATED
TO BE APPLICABLE TO PESTICIDES.
2. THE RI CONTAINS DATA THAT HAVE NOT BEEN ADEQUATELY QUALITY ASSURED.
3. THE USE OF UNFILTERED WATER SAMPLES PROVIDES UNRELIABLE DATA.
4. THE REMEDIES ANALYZED IN THE OUFS CONTAIN INADEQUATE DESIGN AND COST ASSUMPTIONS.
5. THE RI CONTAINS UNSUBSTANTIATED SPECULATION TO THE SOURCE OF MATERIALS AT THE
SITE.
EPA RESPONSE TO C-l:
THE EXPOSURE PARAMETERS USED FOR THE MAXIMUM EXPOSURE SCENARIO ARE NOT UNREASONABLE FOR SOME
PORTIONS OF THE POPULATION, SUCH AS PERSONS WHO WORK AT HOME. ALTHOUGH SOME OF THESE PEOPLE MAY
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SPEND SEVERAL HOURS PER WEEK AWAY FROM HOME, OR EVEN SEVERAL DAYS PER YEAR, THE REDUCTION IN
LIFETIME DOSE WOULD BE QUITE SMALL. THE EXPOSURE PERIOD OF 30 YEARS REPRESENTS THE UPPER-BOUND
TIME (90TH PERCENTILE) AT ONE RESIDENCE AS CITED IN THE "EXPOSURE FACTORS HANDBOOK", EPA 1988.
THE "EXPOSURE FACTORS HANDBOOK" IS WIDELY USED AS A SOURCE FOR EXPOSURE PARAMETERS FOR RISK
ASSESSMENT.
THE HWANG VOLATILIZATION MODEL USED IN THE KEM-PEST PUBLIC HEALTH EVALUATION IS APPROPRIATE FOR
USE WITH CHEMICALS THAT HAVE LIMITED AQUEOUS SOLUBILITY AND A HIGH SOIL AFFINITY SUCH AS THE
PESTICIDES FOUND AT THIS SITE. THEREFORE, THE USE OF THIS MODEL TO ESTIMATE PESTICIDE
VOLATILIZATION IS APPROPRIATE. DR. HWANG, AUTHOR OF THE MODEL, IS A RECOGNIZED EXPERT IN THE
FIELD OF VOLATILIZATION. HE HAS DEVELOPED MANY MODELS FOR VOLATILIZATION THAT HAVE BEEN
RECOMMENDED FOR USE BY THE EPA. THE HWANG MODEL USED FOR THIS RISK ASSESSMENT WAS PRESENTED IN
A DOCUMENT THAT WAS SUBJECTED TO THE EPA'S PEER REVIEW POLICIES AND WAS APPROVED FOR
PUBLICATION.
EPA RESPONSE TO C-2:
AS NOTED IN THE RESPONSE TO THE COMMENT ON PAGE 4-1,LAST PARAGRAPH (ATTACHMENT B), "IT IS NOT
STANDARD PRACTICE TO INCLUDE DATA VALIDATION MEMORANDA IN THE RI REPORT. THE GUIDANCE FOR
CONDUCTING REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES UNDER CERCLA (EPA/540/G-89/004, PAGE
3-31) LISTS "ANALYTICAL DATA AND QA/QC EVALUATION RESULTS" AS AN APPROPRIATE APPENDIX FOR THE RI
REPORT. THE ANALYTICAL DATA AND QA/QC EVALUATION RESULTS FOR THE PHASE I RI ARE INCLUDED IN
APPENDIX G, VOLUME III, OF THE PHASE I RI REPORT. ALL DATA QUALIFIED AS A RESULT OF THE DATA
VALIDATION PROCEDURES ARE IDENTIFIED BY FLAGS IN THE TABLES AND THE FLAGS ARE DEFINED AT THE
BEGINNING OF THE APPENDIX. THE DATA QUALITY DISCUSSIONS AT THE BEGINNING OF EACH OF THE
SUBSECTIONS IN SECTION 4.0
OF THE PHASE I RI REPORT PROVIDE ADDITIONAL EXPLANATION OF THE RESULTS OF THE DATA VALIDATION.
THE DATA VALIDATION MEMORANDA ARE A PART OF THE PUBLIC RECORD FOR THE KEM-PEST LABORATORIES SITE
AND ARE AVAILABLE UPON REQUEST FROM EPA REGION VII."
AS STATED ON PAGE 4-3 OF THE PHASE I RI REPORT WITH REGARD TO THE SUBSURFACE SOIL SAMPLES (AND
AGAIN ON PAGE 4-40 WITH REGARD TO THE SEDIMENT SAMPLES), "OVERALL CORRELATION BETWEEN THE
ORIGINAL SAMPLES, SPLITS AND DUPLICATES FOR THE SUBSURFACE SOIL IS NOT VERY GOOD. HOWEVER, THESE
DISCREPANCIES ARE CHARACTERISTIC OF ANALYTICAL RESULTS FOR SOIL SAMPLES AND ARE GENERALLY
ATTRIBUTED TO MEDIA EFFECTS. BECAUSE SOIL IS NOT HOMOGENEOUS AND BECAUSE MANY CONTAMINANTS
ADSORB STRONGLY TO SOIL PARTICLES, CONTAMINANTS ARE NOT UNIFORMLY DISTRIBUTED IN THIS MEDIUM."
THEREFORE, SUCH VARIABILITY IN ANALYTICAL RESULTS FROM SOIL SAMPLES IS TO BE EXPECTED AND SUCH
RESULTS ARE CONSIDERED ACCEPTABLE.
AS DISCUSSED ON PAGES 4-23 THROUGH 4-25 OF THE PHASE I RI REPORT, THE DECISION TO COLLECT A
SECOND ROUND OF GROUND WATER SAMPLES FOR PESTICIDES WAS BASED PRIMARILY ON THE FACT THAT:
1) THE TECHNICAL HOLDING TIME FOR THE SAMPLES WAS EXCEEDED BY 20 DAYS; AND
2) SINCE THE MATRIX SPIKE/MATRIX SPIKE DUPLICATE ANALYSES WERE UNSUCCESSFUL AND THE
SURROGATE WAS DILUTED OUT IN FIVE OF THE EIGHT SAMPLES, THERE WAS NOT AN ADEQUATE
MEASURE OF PRECISION AND ACCURACY ON THESE SAMPLES.
THE VARIABILITY BETWEEN THE UNFILTERED DUPLICATE AND THE ORIGINAL UNFILTERED SAMPLE FOR
MONITORING WELL MW-2 WAS DISCUSSED AS POSSIBLY PROVIDING EVIDENCE OF THE IMPACT OF THE EXCEEDED
HOLDING TIMES, AS INDICATED BY THIS QUOTE FROM PAGE 4-24 OF THE PHASE I RI: "THE CORRELATION
BETWEEN THE PESTICIDE ANALYTICAL RESULTS FOR THE UNFILTERED DUPLICATE SAMPLE FROM WELL MW-2 AND
THOSE FOR THE ORIGINAL UNFILTERED SAMPLE FROM THIS WELL (WHICH WAS ANALYZED WITH ANOTHER GROUP
OF SAMPLES FOR WHICH THE HOLDING TIME WAS NOT EXCEEDED) IS VERY POOR. THIS COULD BE THE RESULT
OF MATRIX EFFECTS SINCE A SIGNIFICANT AMOUNT OF SUSPENDED SEDIMENT WAS PRESENT IN THE WATER FROM
THIS WELL. HOWEVER, THE VERY LOW CONCENTRATIONS IDENTIFIED IN THE DUPLICATE COULD ALSO BE A
RESULT OF THE EXCEEDED HOLDING TIME. IF IT IS POSSIBLE THAT THE PESTICIDES HAVE DEGRADED OVER
TIME, THIS CALLS INTO QUESTION THE ANALYTICAL RESULTS FROM THE OFFSITE WELLS MW-7B AND MW-6A,
WHERE NO PESTICIDES WERE DETECTED. THEREFORE, IN ORDER TO ENSURE THAT VALID DATA ARE USED TO
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EVALUATE PESTICIDE PRESENCE AND POSSIBLE MIGRATION FROM THE SITE, A SECOND ROUND OF UNFILTERED
GROUND WATER SAMPLES WILL BE COLLECTED AND ANALYZED FOR PESTICIDES AND PCBS." HOWEVER, THE
VARIABILITY BETWEEN THE RESULTS OF THE ANALYSES OF THESE TWO SAMPLES WAS NOT THE PRIMARY
JUSTIFICATION FOR THE DECISION TO COLLECT A SECOND ROUND OF SAMPLES.
IT IS STANDARD PRACTICE TO USE ESTIMATED (J-FLAGGED) DATA FOR EVALUATING THE NATURE AND EXTENT
OF THE CONTAMINATION AND IN CONDUCTING THE RISK ASSESSMENT. THIS PRACTICE IS BASED UPON THE
FACT THAT DATA ARE GENERALLY FLAGGED AS ESTIMATED VALUES AS A RESULT OF MINOR DEVIATIONS FROM
LABORATORY PROTOCOL. MINOR DEVIATIONS INCLUDE SUCH THINGS AS SERIAL DILUTION, MATRIX SPIKE
RECOVERY OR DUPLICATE RELATIVE PERCENT DIFFERENCE BEING OUTSIDE CONTROL LIMITS. ANY MAJOR
DEVIATION FROM LABORATORY PROTOCOL WOULD RESULT IN DATA BEING INVALIDATED. THE MINOR DEVIATIONS
IDENTIFIED ABOVE RESULT IN ANALYTICAL CONCENTRATIONS THAT ARE GENERALLY WITHIN A SMALL RANGE OF
THE TRUE VALUES. AS DISCUSSED IN THE RESPONSES TO ATTACHMENT B, COMMENTS PAGE 4-34 - SECTION
4.3.2, SOIL SAMPLES FROM 0 TO 6 INCHES AND PAGE 4-44 - FIRST PARAGRAPH, THE CONCLUSIONS
REGARDING THE NATURE AND EXTENT OF THE CONTAMINATION CAN GENERALLY BE JUSTIFIED WITHOUT THE USE
OF J-FLAGGED DATA.
THE QUALITY OF THE KEM-PEST DATA FROM A LABORATORY PERSPECTIVE WAS VERY HIGH. THE DATA FOR THIS
SITE WHICH HAVE BEEN REPORTED WITH "J" QUALIFIERS AS ESTIMATED DATA WERE QUALIFIED EITHER
BECAUSE 1) THE REPORTED VALUES WERE BELOW THE LABORATORY'S CONTRACT REQUIRED QUANTITATION LIMIT
(CRQL) OR 2) QUALITY CONTROL REQUIREMENTS WERE NOT MET FOR INITIAL OR CONTINUING CALIBRATION
VERIFICATION. WITH REGARD TO THE SECOND REASON FOR QUALIFICATION, NO GROSS DEVIATIONS IN
INSTRUMENT SENSITIVITY OR ACCURACY OF CALIBRATION WERE OBSERVED. THUS, THESE DATA POINTS ARE
ACCEPTABLE IN A SEMIQUANTITATIVE SENSE.
A HIGH DEGREE OF VARIATION WAS NOTED FOR FIELD DUPLICATE RESULTS. LABORATORY DUPLICATE PRECISION
WAS EXCELLENT. THE LABORATORIES ANALYZED MATRIX SPIKE AND MATRIX SPIKE DUPLICATE SAMPLES FOR
EACH MATRIX AND ANALYSIS TYPE. THE RESULTS FOR THE SPIKING COMPOUNDS FOR SOME SAMPLE SETS COULD
NOT BE EVALUATED SINCE THE SPIKE AMOUNT WAS LOW RELATIVE TO ORIGINAL SAMPLE CONCENTRATION.
HOWEVER, FOR ANALYTES DETECTED IN THE SAMPLES WHICH WERE NOT SPIKING COMPOUNDS, DUPLICATE
PRECISION WAS EXCELLENT. THIS INDICATES THAT THE VARIANCE IN FIELD DUPLICATE RESULTS WAS MOST
LIKELY DUE TO NONHOMOGENEOUS SAMPLE MATRIX.
QUALIFICATION OF RESULTS IS PERFORMED USING GUIDELINES WHICH TRY TO COVER EVERY POSSIBLE DATA
USAGE. DEPENDING ON THE NATURE OF THE QA/QC OUTLIER(S) AND NUMBER OF OUTLIERS AFFECTING ANY
GIVEN DATA POINT, A RANGE OF QUANTITATIVE VARIABILITY MAY BE REPRESENTED BY A "J" QUALIFIER. THE
REPRESENTED VARIABILITY MAY OR MAY NOT BE SIGNIFICANT RELATIVE TO OTHER CONSIDERATIONS RELATED
TO DATA USAGE. IN THIS CASE, IT APPEARS THAT THE DEGREE OF VARIANCE REFERRED TO BY THE "J"
QUALIFIER FOR SAMPLE CONCENTRATIONS GREATER THAN THE CRQL IS SIGNIFICANTLY LESS THAN THE
VARIANCE OF CONTAMINANTS IN THE SOIL MATRIX. THE USE OF THESE CONCENTRATIONS TO REPRESENT
RANGES OF CONTAMINATION AS IN FIG.4-6A THROUGH 4-6B IS AN ACCEPTABLE USE OF ESTIMATED DATA.
DATA COLLECTED FOR THE KEM-PEST SITE WERE SUBJECT TO COMPLETE QA/QC: SAMPLE COLLECTION WAS
DOCUMENTED ON FIELD SHEETS; FIELD QC SAMPLES SUCH AS FIELD DUPLICATES AND EQUIPMENT RINSATES
WERE COLLECTED; SAMPLES WERE PROCESSED USING CHAIN-OF-CUSTODY DOCUMENTS; APPROVED LABORATORY
CALIBRATION AND ANALYTICAL PROCEDURES WERE DEFINED AND FOLLOWED; INTERNAL LABORATORY QUALITY
CONTROL WAS SATISFACTORILY PERFORMED; AND DATA WERE REVIEWED, VALIDATED AND REPORTED IN REGION
VII EPA FORMAT. IN ADDITION, ANALYSES WERE LARGELY CONDUCTED BY LABORATORIES PARTICIPATING IN
THE CONTRACT LABORATORY PROGRAM (CLP). CLP LABORATORIES ANALYZE PERFORMANCE EVALUATION EPA
AUDITS QUARTERLY AND ANNUALLY. THEY PERFORM INTERNAL QA/QC IN ACCORDANCE WITH THE CONTRACT
SPECIFIED REVISION OF THE "STATEMENT OF WORK FOR ORGANICS ANALYSIS - MULTI-MEDIA,
MULTI-CONCENTRATION."
THE COMMENTS OF PRPS STATE A CONCERN THAT THE "CUMULATIVE EFFECT (OF INADEQUATE QA/QC) IS
SUBSTANTIAL." THIS CONCERN IS UNFOUNDED.
EPA RESPONSE TO C-3:
AS DISCUSSED IN THE RESPONSES TO THE SPECIFIC COMMENTS INCLUDED IN ATTACHMENT C, IT IS STANDARD
PRACTICE TO ANALYZE UNFILTERED GROUND WATER AND TO USE SUCH RESULTS IN EVALUATING THE NATURE AND
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EXTENT OF THE CONTAMINATION AND IN CONDUCTING THE RISK ASSESSMENT. SINCE WATER FROM RURAL WELLS
IS OFTEN UNFILTERED, ANALYTICAL RESULTS FROM UNFILTERED SAMPLES PROVIDE A MORE REALISTIC BASIS
FOR RISK ASSESSMENT PURPOSES THAN DO FILTERED SAMPLES. THE AGENCY FOR TOXIC SUBSTANCES AND
DISEASE REGISTRY REQUESTS THE RESULTS OF ANALYSES OF UNFILTERED SAMPLES WHEN CONDUCTING HEALTH
ASSESSMENTS.
EPA RESPONSE TO C-4:
THE GENERAL RESPONSE TO COMMENTS IN ATTACHMENT D STATES: "AS STATED ON PAGES 4-5 AND 4-6 OF
THE SOIL AND SEDIMENT OPERABLE UNIT FEASIBILITY STUDY (OUFS), THE OUFS COST ESTIMATES ARE
ORDER-OF-MAGNITUDE LEVEL ESTIMATES, WHICH ARE DEFINED BY THE AMERICAN ASSOCIATION OF COST
ENGINEERS AS AN APPROXIMATE ESTIMATE MADE WITHOUT DETAILED ENGINEERING DATA. EXAMPLES INCLUDE
AN ESTIMATE FROM COST CAPACITY CURVES AND ESTIMATES USING SCALE-UP OR SCALE-DOWN FACTORS AND/OR
APPROXIMATE RATIO ESTIMATES. IT IS NORMALLY EXPECTED THAT AN ESTIMATE OF THIS TYPE WOULD BE
ACCURATE TO +50 PERCENT AND -30 PERCENT FOR GIVEN UNIT QUANTITIES. THE ACTUAL COST OF THE
PROJECT WOULD DEPEND ON THE FINAL SCOPE OF THE REMEDIAL ACTION, THE SCHEDULE OF IMPLEMENTATION,
ACTUAL LABOR AND MATERIAL COSTS AT THE TIME OF IMPLEMENTATION, COMPETITIVE MARKET CONDITIONS AND
OTHER VARIABLE FACTORS THAT MAY IMPACT THE PROJECT COSTS.
THIS APPROACH TO FEASIBILITY STUDY COSTS IS CONSISTENT WITH THE RI/FS GUIDANCE WHICH STATES ON
PAGE 6-12 THAT STUDY ESTIMATE COSTS MADE DURING THE FS ARE EXPECTED TO PROVIDE AN ACCURACY OF
+50 PERCENT TO -30 PERCENT.
IN ADDITION, THE PRIMARY PURPOSES OF COST ESTIMATES IN A FEASIBILITY STUDY ARE 1) TO PROVIDE A
BASIS FOR COMPARISON BETWEEN ALTERNATIVES AND TO DETERMINE A RELATIVE RANKING OF ALTERNATIVES ON
THE BASIS OF COSTS AND 2) TO PROVIDE A BASIS FOR EPA TO ALLOCATE FUNDING FOR REMEDIAL ACTION.
BASED ON THESE PURPOSES AND THE REQUIREMENTS FOR FEASIBILITY STUDY ESTIMATES STATED ON THE
PREVIOUS PAGE, THE COMMENTS ON THE FEASIBILITY STUDY COSTS IN SECTION D ARE GENERALLY
INAPPROPRIATE. MANY OF THE COMMENTS, INCLUDING THE COMMENTS ASSOCIATED WITH BORROW SOIL,
DECONTAMINATION, PROTECTIVE CLOTHING, MONITORING AND ONSITE TRANSPORTATION APPLY TO SEVERAL OR
ALL OF THE ALTERNATIVES SO THEY HAVE NO IMPACT ON THE RELATIVE RANKING OF THE ALTERNATIVES. THE
COMMENTS ALSO IMPLY THAT THE COST ESTIMATES ARE TOO CONSERVATIVE. HOWEVER, IF THE COST
ESTIMATES ARE TO SERVE AS A BASIS FOR ALLOCATING FUNDING FOR REMEDIAL ACTION, A CONSERVATIVE
ESTIMATE IS REQUIRED IN ORDER TO ENSURE THAT ADEQUATE FUNDS ARE MADE AVAILABLE. FOR INSTANCE,
SINCE THE OUFS IS BASED ON THE ASSUMPTION THAT EPA WOULD HIRE A CONTRACTOR TO PERFORM THE
REQUIRED SERVICES, IT COULD NOT BE ASSUMED THAT FILL, TOPSOIL, ETC., WOULD BE AVAILABLE FROM THE
SITE UNDER THOSE CIRCUMSTANCES.
A FEW ERRORS IN THE COSTS WERE IDENTIFIED. THESE ERRORS HAVE BEEN CORRECTED AND THE NEW COSTS
NOTED IN THE RESPONSE TO THE COMMENTS IN ATTACHMENT D; NONE OF THE CHANGES ALTERED THE RELATIVE
RANKING OF THE ALTERNATIVES.
EPA RESPONSE TO C-5:
AS STATED IN THE RESPONSE TO ALL COMMENTS IN ATTACHMENT E RELATING TO SECTION 4.0: "THE
OBJECTIVES OF THE PHASE I RI INCLUDED EVALUATING 1) THE SOURCES OF CONTAMINATION AND 2) THE
SPECIFIC CONTAMINANTS OF CONCERN. IN EVALUATING THE NATURE AND EXTENT OF THE CONTAMINATION,
CERTAIN ANOMALIES WERE NOTED IN RESULTS OF ANALYSES OF THE ENVIRONMENTAL SAMPLES. THESE
ANOMALIES INCLUDED 1) IDENTIFICATION OF CONTAMINANTS NOT CONSISTENT WITH EXISTING INFORMATION
RELATING TO SITE ACTIVITIES OR WITH THE RESULTS OF PREVIOUS INVESTIGATIONS AND 2) IDENTIFICATION
OF CONTAMINANTS IN AREAS WHERE CONTAMINATION WAS NOT ANTICIPATED, BASED ON EXISTING INFORMATION
RELATING TO SITE ACTIVITIES AND THE RESULTS OF PREVIOUS INVESTIGATIONS. THESE ANOMALIES ARE OF
CONCERN BECAUSE THEY MAY INDICATE THE EXISTENCE OF UNIDENTIFIED SOURCES OF PATHWAYS REQUIRING
FURTHER INVESTIGATION. THE 'SPECULATION' REFERENCED IN THE COMMENTS IN ATTACHMENT E REPRESENTS
AN ATTEMPT TO FIND A LOGICAL EXPLANATION FOR THESE ANOMALIES AND TO EVALUATE WHETHER OR NOT THEY
REQUIRE FURTHER INVESTIGATION. IN ALL CASES, THE WORDING OF THE DISCUSSIONS IN THE RI REPORT
MAKE IT CLEAR THAT THE ANALYSES ARE NOT STATEMENTS OF FACT."
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