THE VOGEL PAINT AND WAX COMPANY SITE MAURICE, IOWA

RECORD OF DECISION

. . FOR

THE VOGEL PAINT AND WAX COMPANY SITE

MAURICE, IOWA

Prepared by:

IOWA DEPARTMENT OF NATURAL RESOURCES

September 14, 1989

TD # IE '? '

? • Q

40260801

SUPERFUM) RECORDS

DECLARATION FOR THE RECORD OP DECISION

1.0 Site Name and Location

Vogel Paint and Wax company; Maurice, Iowa

1.1 Statement of Basis and Purpose

This decision document presents the selected remedial action forthe Vogel Paint and Wax Company site, in Sioux County, Iowa, whichwas chosen in accordance with the requirements of the ComprehensiveEnvironmental Response, Compensation, and Liability Act of 1980(CERCLA), as amended by the Superfund Amendments andReauthorization Act of 1986 (SARA) and, to the extent practicable,the National Oil and Hazardous Substances Pollution ContingencyPlan (NCP) . This decision document explains; the factual and legalbasis for selecting the remedy for this site. :

The Iowa Department of Natural Resources concurs with the selectedremedy. The information supporting this remedial action decisionis contained in the administrative record for this site.

1.2 Assessment of the Site

Actual or threatened releases of hazardous substances from thissite, if not addressed by implementing the response action selectedin this Record of .-Decision (ROD), may present an imminent andsubstantial threat to public health, welfare, or the environment.

1.3 Description of the Selected Remedy

The selected remedy consists of activities involving soil andgroundwater cleanup. Contaminated soils will be excavated andsolid and liquid waste will be separated for off-site incineration,recycling, or disposal. An estimated 3000 cubic yards ofcontaminated soils will be treated using a bioremediation processin a fully contained surface impoundment, unit. If additionaltesting shows bioremediation to be infeasible due to high metallevels, on-site thermal treatment will be implemented in its place.Treated soil will be stabilized if necessary to prevent leachingof metals, placed back into the excavation and covered.Groundwater will be pumped and air stripped with discharge to thenearby stream. Losses of volatile organics to the atmosphere inboth the soil and groundwater actions will be controlled by carbonadsorption, if necessary. Health-based standards for groundwaterand leaching standards for soils have been established. Inaddition, the site is currently listed on the State Abandoned orUncontrolled Sites Registry (SAUSR). Substantial change ortransfer of property on this registry is prohibited without writtenapproval of the Director of the Iowa Department of NaturalResources. The selected remedy is believed to be capable of

achieving the cleanup standards which would constitute final actionfor this site.

1.4 Declaration of Statutory Determinations

The selected remedy is protective of h u m a n heal th and theenvironment, complies with Federal and State requirements that arelegally applicable or relevant and appropriate to the remedialaction and is cost-effective. This remedy utilizes permanentsolutions and al ternat ive t reatment (or resource recovery)technologies to the maximum extent practicable, and it satisfiesthe statutory preference for remedies that employ treatment thatreduce toxicity, mobility, or volume as their principal element.Because this remedy will result in hazardous substances (belowhealth-based s tandards) remaining on site, a review will beconducted within five years of commencement of remedial action toensure that the remedy continues to provide adequate protection ofhuman health and the environment.

ttORRIS KAY, REGIONAL ADMINISTRATOR DATEENVIRONMENTAL PROTECTION AGENCY, REGION VII

ALLAN STOKES, ADMINISTRATOR "°DATEIOWA DNR, ENVIRONMENTAL PROTECTION DIV,.

DECISION SUMMARY FOR THE RECORD OF DECISION

2.0 Site Name. Location, and Description

The Vogel Paint and Wax Company (VPW) is located about twomiles south and a mile west of the town of Maurice, in SiouxCounty, Iowa. Figure 1 shows the general site location.

The site's legal address is: NW 1/4, Sec. 29, Township 94,Range 45 west.

2.1 Site History and Enforcement Activities

The site is located in a rural area on the uplands of the WestBranch Floyd River. Adjacent land uses are primarily for cropland.The one-eighth section owned by VPW is partially used for cropland.An unnamed intermittent stream flows to the northeast through thenorthwest portion of the VPW one-eighth section and discharges tothe West Branch Floyd River about a mile away. (See Figures 2 and3.) The West Branch Floyd River is classified for protection ofwildlife, aquatic life, and secondary body contact (e.g., wading).

A surficial sand and gravel aquifer and Dakota sandstone bedrockaquifer underlie the site. The sand and gravel aquifer suppliesnearby private wells and the Southern Sioux County Rural WaterSystem located about a mile and a half southeast of the site.Wells in the surficial aquifer are typically less than 50 feetdeep. The Dakota sandstone is the primary bedrock aquifer in theregion. Dakota wells are typically 250 to 450 feet deep. Thesurficial aquifer has been identified as the primary route ofcontaminant migration from the site. Ground water has been foundto flow in a southerly to southeasterly direction which isdifferent from the surface topography.

The closest communities are Maurice (1980 population of 288)located about two miles to the north-northeast of the site andStruble (1980 population of 59) located about two and a half milessouth of the site. The Southern Sioux County Rural Water Systemserves approximately 3200 people. Private rural residences existwithin about a quarter mile northwest and southwest of the site.Figure 2 is a map of the vicinity.

The site itself consists of an approximate two acre disposal areawhich has been covered with clay. Monitoring wells are the onlysite structures. Figure 3 is a site map.

Prior to its use for waste disposal, the northern half of the sitecontained a gravel pit and the remainder of the site was tilled foragricultural purposes. In 1971 Vogel Paint and Wax Company, Inc.

N W

1"=13Miles

F I G U R E 1LOCATION MAP

3a

F I G U R E 2VICINITY MAP

3b

533150

K E Y

A l u l t i r l i ) f i l l

1 J 2 0 C r i i H t i l i r I l i T i l i i i i

o »_ S l l i B « n < i r j

lilirnlltiil S t r u m

4 0 0 4 0 0 8 0 0

S c o I e : 1 I n c h « 4 0 0 F e e t

F I G U R E 3SITE MAP

3c

(VPW) of Orange City, Iowa began using the site for waste disposal.Paint sludge, resins, solvents and other paint manufacturing wasteswere disposed of at the site until 1979. Such disposal was notprohibited at that time. The disposal area, encompasses about twoacres of the 80-acre tract owned by VPW. (See Figure 3.) Liquidwastes were dumped into twelve or more trenches eight to twelvefeet in depth. The trenches were left open for an extended periodof time to allow volatilization of solvents. Filled or partiallyfilled drums and other debris were then dumped on top of the liquidwastes, and the trenches were covered with one to two feet of soil.Solid wastes such as wooden pallets and packing materials weredisposed of in the former gravel pit after several feet of clayeysilt soil was placed on the floor of the pit.

Data from company records indicate that approximately 43,000gallons of aliphatic and aromatic hydrocarbons-have been buried atthe site, primarily including toluene, xylene, ethylbenzene, methylethyl ketone, and mineral spirits. An estimated 6,000 pounds ofmercury, lead, zinc and chromium have been disposed of at the site.

The estimated quantities of materials delivered to the site are:

Solvents 43,000 gallons

Lead 3,900 pounds

Mercury 7 pounds

Zinc 1,500 pounds

Chromium 600 pounds

Assuming that two-thirds of the solvents were poured into thetrenches, and 60 percent was released to the atmosphere byvolatilization, approximately 11,500 gallons of free solvents wouldremain in the trenches to potentially enter the soil andgroundwater.

In the Spring of 1979 the State of Iowa received complaints ofpaint waste disposal at the VPW site about 1.5 miles north of aproposed rural water district well field. The State conductedinitial ̂ .investigations at the site in 1979. In late 1979 VPWinitiated additional investigations at the State's request. Thesite was placed on the National Priorities List (NPL) in 1984.Since 1979 VPW has conducted numerous investigations in cooperationwith the State. The Remedial Investigation and Feasibility Studywere conducted in accordance with a Consent Order between VPW andthe Iowa Department of Natural Resources (DNR) effective June 1987_._

2.2 Highlights of Community Participation

The Remedial Investigation and Feasibility Study Reports and theProposed Plan for the Vogel site were released to the public forcomment on August 10, 1989. These two documents were madeavailable to the public in both the administrative record and aninformation repository maintained at DNR Records Center, 5th Floor,Wallace Building, 900 -East Grand, Des Moines, Iowa, and in theOrange City Public Library.

The notice of availability for these two documents was publishedin the Sioux City Journal on August 1C), 1989. A public commentperiod on the documents was held from August 10, 1989 to August 31,1989. In addition, a public meeting was held on August 21, 1989.At this meeting, representatives from DNR, EPA, and Vogel Paint andWax Company answered questions ,about problems at the site and theremedial alternatives under consideration. A response to thecomments received during this period is included in theResponsiveness Summary, which is part of this ROD.

2.3 Scope and Role of Response Actions Within Site Strategy

The selected response actions independently address two affectedmedia, i.e., solid waste/soil and groundwater. The solid waste andcontaminated soils in the disposal area are a source ofcontaminants leaching into groundwater. Wastes were covered withclay in 1984 and pose no threat due to direct contact. The cleanupobjective for solid waste/soils is to reduce migration ofcontaminants into groundwater by removal and/or treatment of thesource, i.e., the contaminated soils/solid waste.

Contaminated groundwater is a potential threat to current andfuture drinking water supplies. To a lesser degree, otherenvironmental risks could result from the eventual discharge ofcontaminated groundwater to surface streams. The cleanup objectivefor groundwater will be. to reduce contaminants in groundwater toestablished health-based standards for drinking water.

The response actions selected in this ROD address all principalthreats posed by this site and are intended to constitute finalactions for the site.

2.4 Summary of Site Characteristics

A wide variety of contaminants have been detected in various mediaat the site; including several potential carcinogens. Table 1summarizes contaminants found in groundwater, surface water, andsoil. Groundwater contaminants are limited to well-defined plumeswhich do not appear to be expanding. Figures 4-7 show contaminantplume configurations. The ground water flow is likely to be in anortherly direction in the upper sand unit. In the lower sand andgravel unit, ground water flows in an easterly direction north of

ALTERNATIVE GW-3:NO ACTION - GROUNDWATER

Capital Cost: $30,000Annual O&M Costs: $4,600 (30 yrs.)PW costs: $101,000Months to Implement: 0

As with the soil "no action" alternative, this alternative isrequired in the Superfund program to establish a baseline forcomparison. Under this alternative no "additional" action wouldbe taken regarding groundwater. However, current activitiesincluding monthly removal of floating hydrocarbons and quarterlygroundwater sampling would be continued indefinitely. The listingon the State Abandoned and Uncontrolled Sites Registry couldprevent future withdrawals of groundwater from the site. The sitecould be reactivated if monitoring results indicated migration ofcontaminants from the site.

2.7 Summary of Comparative Analysis of Alternatives

Table 3 summarizes the comparison of alternatives against the nineevaluation criteria which are discussed in more detail below.

Overall Protection; No immediate threat has been identified, theextent of groundwater contamination does not appear to beexpanding, monitoring will be required of all alternatives,institutional controls are in place, and direct contact withcontaminated soils is not a threat. Therefore, all of thealternatives would provide adequate protection to human health andthe environment. All of the alternatives, except the "no action"alternatives, accomplish this by reducing the amounts ofcontaminants through treatment or removal. The "no action"alternatives provide a much lesser degree of overall protectionbecause much larger amounts of contaminants would remain on site.Alternative GW-2 involving in-situ bioremediation may have asomewhat lower degree of overall protection because the level ofeffectiveness is uncertain. The proposed alternatives wouldsignificantly reduce the source of contaminants and levels ofcontaminants in groundwater to below health-based standards fordrinking-water.

Compliance with ARARS: All alternatives, except the "no action"alternatives, should meet their respective applicable or relevantand appropriate requirements of Federal and State environmentallaws. The groundwater "no action" alternative would not meetgroundwater cleanup standards. Alternatives S-2 and S-3 involvingon-site soil disposal should be able to meet federal land disposalrequirements ("Land Ban") by treatment of wastes to health-basedlevels.

15

TABLE 3

SUMMARY EVALUATION OP REMEDIAL ALTERNATIVES

SOIL ALTERNATIVES

Alternative

S-1S-2S-3S-4

Long-termEffectiveness

HighHighHigh ,Low ?.

Reduction ofT,M & V

HighHigh .HighLow

Short-termEffectiveness

MediumMediumMedium

High

Implementability

HighHigh ,

MediumHigh

Present WorthCost (Dollars)

6,390,0002.060,0001,385,000

2,500

Compliancewith ARARs

YesYes.Yesto

OverallProtection

HighHighHighLow

StateAcceptance

V •• V

YesYes

—

CommunityAcceptance

...Yes

; Yes

—

GROUNDWATER ALTERNATIVES

Alternative

GW-1GW-2GW-3

Long-termEffectiveness

HighMedium

Low

Reduction ofT.M& V

HighMedium

Low

Short-termEffectiveness

MediumMedium

High

Implementability

HighMedium

High

Present WorthCost (Dollars)

466,000624,000101,000

Compliancewith ARARs

YesYesto

OverallProtection

HighMedium

Low

StateAcceptance

!Yes

CommunityAcceptance

! Yes

KEY:

Alternative DescriptionS-1S-2

S-3

S-4GW-1GW-2GW-3

Excavation and Off-Site IncinerationExcavation, (On-Site Storage), On-Site Thermal Treatment,

(Stabilization), On-Site DisposalExcavation, (On-Site Storage), On-Site Bioremediation, •

(Stabilization), On-Site DisposalNo-Action and Institutional ControlsPumping, Air Stripping, and Discharge to Surface WaterIn-Situ BioremediationNo-Action, Institutional Controls, and Long-Term Monitoring

direction south of the disposal area (See Figure 8.) Since Marchof 1984, two wells have been used to remove floating hydrocarbons.This activity has reduced the thickness of the floating hydrocarbonlayer from 12.4 to 1.7 feet.

In general, no significant surface water contamination has beendetected and soil contamination is concentrated in the two acredisposal area. Currently there are no populations at risk.However, contaminated groundwater is a potential threat to currentand future drinking water supplies.

N

5 3 3 2 5 0 . 0 0

, 400 4 0 0 8 0 0

S C A L E : 1 ' * 4 0 0 '

F I G U R E 4E T H Y L B E N Z E N E ISOCONCENTRATION MAP (1-18-89)

6a

N

5 3 3 2 5 0 . 0 0 0

4 0 0

S C A L E : 1 ' « 4 0 0 '

FIGURE 5MEK ISOCONCENTRATION MAP (1-18-89)

6b

N

5 3 3 2 5 0 . 0 0 0

4 0 0

S C A L E : I ' = 4 0 0 '

F I G U R E 6T O L U E N E ISOCONCENTRATION MAP (1-18-89)

6c

lO".

7

i

5 3 3 2 5 0 . 0 0 t y _

y

N

ri 1

4 0 0 4 0 0

S C A L E : 1 ' « 4 0 0 '

FIGURE 7XYLENE ISOCONCENTRATION HAP (1-18-89)

6d

N

5 3 3 2

4 0 0

S C A L E : 1 ' * 4 0 0 '

FIGURE 8GROUNDWATER FLOW MAP (1-17-89)

6e

TABLE 1

CONCENTRATION VALUES IN VARIOUS ENVIRONMENTAL KEDIA

Groundweter(pgn)

Chemical Range

Arsenic(PC)Beryl t iun(PC)CadmiumCh ran inn III

Lead

Mercury

NickelZinc

Surface Water(pern)

Soil*(mg/kflj

NA0.02-0.02BOL-0.07BDL-0.08

BOL-0.32

BOL-0.11

NABDL-0.24

Bis(2-Ethylhexyl)Phthalate

Di butylPhthalate

AcetoneBenzerte(PC)Chloroform(PC)

NA

NABOL-0.28BOL-0.11NA

Dichloro-methane(PC)

1,2-Dichloro-propane(PC)

EthylbenzeneMethyl Ethyl

KetoneMethyl Isobutyl

KetoneTolueneTrichtoro-

ethylene(PC)Xylenes

BDL-0.42

BOL-0.07BOL-67

BOL-120

BOL-0.62BDL-37

BOL-0.01BOL-260

Mean

NA0.020.020.001

0.007

0.0005

NA0.07

NA

NA0.130.05NA

0.21

0.035.2

3.7

0.313.8

0.00620

Range

NANABOL-BDLBOL-0.012

BOL-0.026

BDL-BOL

NA0.03-0.04

NA

NANANANA

MA

NABOL-0.0036

BOL-0.037

NABOL-O.OOU

NABOL-0.013

Mean Range

NANABOLO.OM

0.009

BOL

NA0.02

NA

NAHANANA

NA

NA0.0006

0.006

NA0.0002

NA0.002

4.8-12.1NA0.2-6.44.9-21,000(44)5.2-41,000(140)BOL-65(0.04)10.3-25.915.5-12,000

1.7-6.6

BOL-0.30BOL-0.370.1-8.0BOL-0.007

BOL-0.14

NABOL-976

BOL-0.51

BDL-D.87BOL-1711

BOL-0.059BOL-704

Mean

7.6NA1.11240(14.8)4600.0(26.6)4.4(0.07)14.8826.0(44.3)

3.4

0.300.121.20.006

0.04

NA90

0.51

0.32145

0.0457

NA * Not AvailableBDL * Below Detection LimitPC * Potential Carcinogen* Mean soil values for Chromium, Lead, Mercury and Zinc are skewed dm; to five of thirty-one nanples.Values shown in parentheses do not include results from these five samples, and are as follows::Chromium - 9,400 me/kg; Lead - 28,300 mg/kg; Mercury - 21.6 hg/kg; and Zinc - 4,900 og/kg.

2.5 Summary of Site Risks

The U.S. Public Health Service Agency for Toxic Substances andDisease Registry conducted a Health Assessment for the VPW site.They concluded that the condition of the site does not pose animmediate public health threat. The site is covered and locatedin a rural area. Because of these conditions, direct exposure tocontaminants does not occur. However, the potential for off-sitemigration of contaminants into the groundwater may lead to a futurepublic health threat.

An Endangerment Assessment was conducted as part of the remedialinvestigations. This Endangerment Assessment provided a baselinerisk assessment to assist in the development of remedialalternatives. It concluded that there is no potential forsignificant exposure to contaminants via soil, surface water, orair. Exposure pathways have been identified via groundwater takenfrom the two residential wells just west of the site; however, whencontaminants have been detected in these two wells, theconcentrations have been below health-based drinking waterstandards and no increasing trend has been observed. Volatileorganic contaminants have been observed at the site boundary atconcentrations which do not pose a significant threat to publichealth or the environment. However, Cadmium, Methyl Ethyl Ketone,Ethylbenzene, and Xylenes (all non-carcinogens) have been detectedwithin the area of groundwater contamination at concentrations highenough to pose a subchronic and/or chronic risk to humans if theywere to ingest this water. Benzene, a carcinogen, has also beendetected in site groundwater.

Potential risks from drinking contaminated groundwater werecalculated in the Endangerroent Assessment and are summarized inTable 2. These hazards were based upon consumption of meancontaminant concentrations found in on-site monitoring wells,except for benzene in which case the maximum level found was used.Therefore, the potential hazards presented in Table 2 do notrepresent current exposure to any person. As stated previously,no significant off-site hazard has been identified? however, thepotential for migration of contaminant in groundwater does existwhich could impact a drinking water supply in the future.

TABLE 2

Chemical

SUMMARY OP POTENTIAL HAZARDS PROMCONSUMPTION OP CONTAMINATED GROUNDWATER

EDI RfD HQ CPF ELC

Cadmium

Chromium

Lead

Mercury

BenzeneEthylbenzene

Methyl EthylKetone

Toluene

Xylenes

5.8X10"

11.6x10

8.7x10

1.5x10

3.2x10"22.6x10

21.2X10

20.3X10

86.4x10

-5

•5

•2

-2

-2

-2

2.9X10"

1.00

2.0

11.6x10-5

1.40X10"3 6.21X10"1

2.00X10"3 7.25X10'3

5.00x10-2

5.00x10-2

4.52

4 .23

3.00X10'1 6.77X10"1

1.00x10-2

5.2X10"2 1.7X10'4

86.4

Hazard IndexTotal Excess Lifetime Cancer Risk-

EDI - Estimated Daily IntakeRfD - Reference DoseHQ - Hazard QuotientCPF - Cancer Potency FactorELC - Excess Lifetime Cancer Risk

•98.5•1.7x10"

NOTE: See text for description of these parameters

Reference doses (RfDs) have been developed by EPA for indicatingthe potential for adverse health effects from exposure to chemicalsexhibiting noncarcinogenic effects. RfDs, which are expressed inunits of mg/kg-day, are estimates of lifetime daily exposure levelsfor humans, including sensitive individuals, that are not likelyto be without an appreciable risk of adverse health effects.Estimated intakes of chemicals from environmental media (e.g., theamount of a chemical ingested from contaminated drinking water) canbe compared to the RfD. RfDs are derived from humanepidemiological studies or animal studies to which uncertaintyfactors have been applied (e.g., to account for the use of animaldata to predict effects on humans). These uncertainty factors helpensure that the RfDs will not underestimate the potential foradverse noncarcinogenic effects to occur.

Potential concern for noncarcinogenic effects of a singlecontaminant in a single medium is expressed as the hazard quotient(HQ) (or the ratio of the estimated intake derived from thecontaminant concentration in a given medium to the contaminant'sreference dose). By adding the HQs for all contaminants within amedium or across all media to which a given population mayreasonably be exposed, the Hazard Index (HI) can be generated TheHI provides a useful reference point for gauging the potentialsignificance of multiple contaminant exposures within a singlemedium or across media. HI values less than one are acceptable.

Cancer potency factors (CPFs) have been developed by EPA'sCarcinogenic Assessment Group for estimating excess lifetime cancerrisks associated with exposure to potentially carcinogenicchemicals. CPFs, which are expressed in units of (mg/kg-day)"1,are multiplied by the estimated intake of a potential carcinogen,in mg/kg-day, to provide an upper-bound estimate of the excesslifetime cancer risk associated with exposure at that intake level.The term "upper bound" reflects the conservative estimate of therisks calculated from the CPF. Use of this approach makesunderestimation of the actual cancer risk highly unlikely. Cancerpotency factors are derived from the results of humanepidemiological studies or chronic animal bioassays to whichanimal-to-human extrapolation and uncertainty factors have beenapplied.

Excess lifetime cancer risks are determined by multiplying theintake level with the cancer potency factor. These risks areprobabilities that are generally expressed in scientific notation(e.g., IxlO"6) . An. excess lifetime cancer risk of IxlO"6 indicatesthat, as a plausible upper bound, an individual has a one in onemillion chance of developing cancer as a result of site-relatedexposure to a carcinogen over a 70-year lifetime under the specificexposure conditions at a site.

This site has not been found to currently pose any significantenvironmental risks. Contaminants have not migrated far. Low

10

levels of contaminants have occasionally been detected in theadjacent intermittent stream. There are no critical habitats orendangered species affected by site contaminants.

Actual or threatened releases of hazardous substances from thissite, if not addressed by implementing the response action selectedin this ROD, however, present an imminent and substantialendangerment to public health, welfare, or the environment.

2.6 Description of Alternatives

Soil and Groundwater remedial alternatives have been evaluatedseparately. One soil and one groundwater alternative have beenchosen to constitute complete remedial action for the site.

The alternatives for soil and groundwater cleanup which have beenevaluated are listed below. The "S: refers to soil alternativesand the "GW" refers to groundwater.

o Alternative S-l: Excavation and Off-site Incineration andDisposal

o Alternative S-2: Excavation, On-Site Thermal Treatment,Soil Stabilization (if needed), and On-Site Disposal

o Alternative S-3: Excavation, On-Site Bioremediation, SoilStabilization (if needed), and On-SiteDisposal

o Alternative S-4: No Action - Soils

o Alternative GW-1: Pumping, Air Stripping, and Discharge toSurface Water

o Alternative GW-2: In-Situ Bioremediation

o Alternative GW-3: No Action - Groundwater

Common Elements; All of the soil alternatives except the "NoAction" alternative include excavation of about 3,000 cubic yardsof contaminated soils. Temporary on-site storage of excavatedmaterials would be utilized, if necessary. Waste material otherthan soil (e.g, drums and debris) would be isolated,decontaminated, and shipped to a municipal landfill for disposalif it can be rendered non-hazardous, otherwise it would be disposedof in a hazardous rwaste landfill or incinerated off-site. Inaddition, free liquids in the excavation would be removed andstored in temporary tanks prior to ultimate off-site treatment byincineration or recycling. All groundwater alternatives includemonitoring to ensure contaminants are not moving off-site. Dustcontrol and/or air monitoring would be conducted for all on-siteactivities in which the potential for release of contaminants to

11

air exists. All alternatives also include listing of the site onthe State Abandoned or Uncontrolled Sites Registry which hasalready been done. A listing on this registry is filed with thecounty recorder and requires the owner to obtain written approvalfrom the Director of DNR prior to selling or substantially changingthe site. Other previous actions which are common to allalternatives include the two feet thick clay cover placed on thewaste disposal area and continued floating hydrocarbon removal.

ALTERNATIVE S-lEXCAVATION AND OFF-SITE DISPOSAL

Capital Cost: $6,390,000Annual Operation and Maintenance (O&M) Cost: 0Present Worth (PW) Cost: $6,390,000Months to Implement: 2

The contaminated soil would be excavated, transported to andincinerated at an approved incineration facility as regulated by40 CFR Part 264. Metals in ash resulting from incineration wouldbe stabilized if necessary prior to final disposal. Clean soilwould be used to backfill the excavation and the area would berevegetated. With this alternative, all contaminants would beremoved and there would be no need for long-term maintenance.

ALTERNATIVE S-2;EXCAVATION, ON-SITE THERMAL TREATMENT(STABILIZATION), AND ON-SITE DISPOSAL

Capital Cost: $2,045,000Annual O&M Cost: $1,000 (30 yrs.)PW Cost: $2,060,000Months to Implement: 1-3

Low temperature thermal treatment of contaminated soil would beused to drive off volatile organic compounds by mixing of excavatedsoils in a rotary kiln at temperatures of 600-800° F. The organiccontaminants in the hot exhaust from this process would bedestroyed by an afterburner. This process would not treat metalsin the soil and the residual soil may require stabilization (e.g.,mixing with lime or cement) to prevent leaching of metals togroundwater. Treated, stabilized soil would be redeposited in theexcavation, covered with clean soil, and revegetated. Treatmentstandards to be met 'prior to disposal would be at health-basedlevels. For metals* the levels are based on Extraction ProcedureToxicity standards. For organic compounds, the levels are basedon Toxicity Characteristic Leaching Procedure standards, with alimit of 100 ppm total organic hydrocarbons. Operation andmaintenance of this site would be minimal efforts involvingperiodic site inspections and repairing any erosional damage.

12

ALTERNATIVE S-3:(STABILIZATION), AND ON-SITE DISPOSAL

Capital Cost: $1,370,000Annual O&M Costs: $1,000 (30 years)PW Cost: $1,385,000Months to Implement: 6-12

This alternative is the same as Alternative S-2, except thatbioremediation of soils vould be utilized instead of thermaltreatment. Bioremediation of soils would involve a fully containedsurface impoundment system complying with minimum technologystandards using conventional soil management practices (e.g.,nutrient addition and soil aeration) to enhance microbialdegradation and volatilization of organic contaminants. The systemwould be designed to contain and treat soil leachate andvolatilized contaminants. The treatment system would be about oneacre in size consisting of a double-lined treatment bed, leachatecollection system, groundwater monitoring, and a modified plastic-film greenhouse cover. Leachate would recycled back to thetreatment area. Excess leachate would be collected for off-sitetreatment (e.g., municipal wastewater treatment plant). Vaporswould pass through activated carbon to absorb organics prior torelease. Spent activated carbon would be regenerated, i£ possible,or sent to an approved landfill.

High concentrations of heavy metals may prohibit use of thisprocess. A trial run treatability study would be necessary priorto implementation. If small quantities of soils are identified ascontaining high levels of heavy metals which are incompatible withbioremediation, these soils would be isolated for off-sitetreatment and/or disposal at an approved hazardous waste disposalfacility. If high concentrations of heavy metals pose excessiverestrictions on the use of bioremediation, Alternative S-2utilizing thermal treatment of soils would be implemented in itsplace.

ALTERNATIVE S-4:NO ACTION - SOILS

Capital Cost: $2,500Annual O&M Cost: 0PW Cost: $2,500Months to Implement: 0

The Superfund program requires that the "no action" alternative beevaluated at every site to establish a baseline for comparison.Under this alternative no "additional" action would be takenregarding soils. Previous covering of the disposal area with twofeet of clay and listing of the site on the State Abandoned orUncontrolled Sites Registry are actions which have already been

13

implemented. This alternative does include the minor cost ofplacing a fence around the site.

ALTERNATIVE GW-1:PUMPING, AIR STRIPPING, AND DISCHARGE TO SURFACE WATER

Capital Cost: $320,000Annual O&M Costs: $53,600 (3 yrs.)PW Cost: $466,000Months to Implement: 36+

Contaminated groundwater would be removed by pumping from one ormore wells. This well (or wells) would be located and sized todraw water from the entire area of groundwater contaminationthereby preventing any off-site migration of groundwatercontaminants. A pumping test would be conducted during theremedial design to determine aquifer characteristics. Thisinformation would be used to design the pumping system, i.e.,number and location of wells, pumping rates, and gradient controls.The pumped water would be run through an air stripper to remove inexcess of 95% of the volatile organic contaminants. Air strippingis a well-established process in which water is cascaded througha column packed with an inert media (e.g., plastic balls) and airis forced through the column in a counter direction. Volatileorganics are stripped from the water and included in the airdischarged from the top of the column. Carbon adsorption would beused to remove contaminants in the air discharged from an airstripper, if necessary to meet air quality standards. Treatedwater, meeting water quality standards, from the air stripper wouldbe discharged to the nearby unnamed stream. If water from the airstripper does not meet water quality standards, additionaltreatment would be provided, as necessary.. The need for additionaltreatment, however, is not anticipated. Pumping and treatmentwould continue as long as necessary to reduce contaminant levelsto established cleanup levels.

ALTERNATIVE GW-2:IN-SITU BIOREMEDIATION

In-situ bioremediation of groundwater involves enhancing thenatural biodegradation process by means such as nutrient injection,aeration, and introduction of cultured bacterial strains. Naturalbiological activity is capable of degrading organic contaminantsto innocuous compounds. Such a process would involve carefulmonitoring and control of conditions to enhance biogradation untilcontaminant levels are reduced to established cleanup levels. Thisalternative would not address metals in groundwater. However,existing levels of metals are largely in compliance with health-based drinking water standards.

14

Long-Term Effectiveness and Permanence; Alternative S-l wouldremove all contaminated soil and wastes from the site for treatmentand disposal, thereby eliminating long-term risks at the VPW siteand minimizing off-site risks. Alternative S-2 and S-3 would bothprovide a high degree of long-term effectiveness by eliminatingmost volatile organic contaminants and stabilizing residual soils,if necessary, to prevent leaching of metals which will not beremoved by treatment.

The "no action" alternatives S-4 and GW-3 provide the leastassurance of long-term effectiveness and permanence since allcontaminants will remain on-site with only minimal control (i.e.,floating hydrocarbon removal).

Alternative GW-1 would provide- a high degree of long-termeffectiveness and permanence by removal of groundwatercontaminants. Successful in-situ bioremediation, Alternative GW-2, could also be very effective; however, it is not able to addressmetals in groundwater and its ability to achieve low concentrationsis uncertain.

Reduction of Toxicity. Mobility, or Volume of Contaminants ThroughTreatment; Alternatives S-3 and GW-2 involving bioremediation andS-l involving incineration offer the greatest potential forreduction of contaminants through treatment. However, AlternativeGW-2 has a high degree of uncertainty as to its ultimateeffectiveness.

The "no action" alternatives S-4 and GW-3 rank very low withrespect to this criterion. However, the "no action" alternativefor groundwater (GW-3) would provide some reduction in contaminantvolume through continued floating hydrocarbon recovery.

Alternatives S-2 and S-3, on-site thermal treatment of soils andon-site bioremediation and GW-1, air stripping of groundwater,would greatly reduce volume of contaminants on-site but would betransferring contaminants to the air. Air emissions would bemitigated by carbon adsorption or use of an afterburner for thermaltreatment if necessary to meet air quality standards. Spent carbonwould either be landfilled in which case the mobility of thecontaminants would be greatly reduced, or regenerated(incinerated), in which case the volume of contaminants would begreatly reduced. An afterburner would destroy most organiccontaminants.

None of the soil alternatives are capable of reducing the volumeor toxicity of metals. However, Alternatives S-l, S-2 and S-3would reduce the mobility of metals through stabilization, ifnecessary.

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Short-Term Effectiveness; All of the active soil alternatives canbe completed in a relatively short period of time with off-siteincineration/disposal, Alternative S-l, taking the least time andon-site bioremediation taking the most time. These three soilalternatives all involve excavation of soils and wastes which wouldcreate potential for worker exposure, dust, and volatization ofcontaminants into the air. The off-site Alternative (S-l) wouldhave a significant short-term risk due to transportation.Alternatives S-2 and S-3 would have potential for short-term airemissions during treatment. However, such emissions would bemitigated by engineered controls, if necessary to meet air qualitystandards.

Groundwater Alternative GW-l would likely prove more effectiveduring the short-term than Alternative GW-2 because pumping wouldprovide a positive control thus preventing contaminant movement.Since no immediate risks exist and groundwater contamination doesnot appear to be expanding at present, any difference in those twoalternatives regarding short-term effectiveness in removinggroundwater contaminants is not significant. Alternative GW-l,involving pumping and air stripping may,, however pose short-termrisks due to discharge of contaminants to the air and surfacewater. Those risks would be mitigated by carbon adsorption of airemissions and/or additional water treatment, if necessary, toprevent significant risks to human health or the environment.

The "no action" alternatives (S-4 and GW-3) accomplish little inthe short-term. On the other hand, no immediate risk has beenidentified and the "no action" alternatives will not create anyshort-term risks during implementation; therefore, short-termeffectiveness is high.

Implementabi1itv; The "no action" alternatives (S-4 and GW-3) areobviously the easiest to implement. Of the remaining soil-relatedalternatives, off-site treatment/disposal (Alternative S-l) wouldbe the easiest to implement, followed by one-site thermal treatment(Alternative S-2). Alternative S-3 would be the most difficult toimplement since additional testing would be required and designconsiderations would be most involved.

Of the two active groundwater related alternatives, AlternativeGW-l, would be the easiest to implement.. In-situ bioremediationof groundwater has many potential implementability problems.

Cost; Obviously the "no action" alternatives (S-4 and GW-3) haveby far the lowest costs. The off-site treatment disposal option(S-l) is the highest cost soil-related alternative. AlternativeS-3 has a significantly lower cost than the on-site thermaltreatment option, Alternative S-2. None of the soil-relatedalternatives have significant operation and maintenance costs.

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The initial costs of Alternative GW-1, involving pumping and air-stripping, is estimated to be slightly higher than for in-situbioremediation of groundwater (Alternative GW-3); however, muchlower operating costs are expected for Alternative GW-1 resultingin significantly lower overall (present worth) costs.

State Acceptance: The Iowa Department of Natural Resourcesauthored the proposed Plan and recommends the preferred alternativewithout comment.

Community Acceptance; Very little public comment was received.Several comments were received at the public meeting, none of whichexpressed dissatisfaction with the preferred alternative. AResponsiveness Summary addressing all comment received at thepublic meeting is attached.

2.8 Selected Remedy

The selected remedy is Alternative S-3 involving on-sitebioremediation of soils coupled with Alternative GW-1 involvingpumping and air stripping of groundwater.

The selected remedy will include the following ancillaryactivities:

o Continued listing and restrictions associated with the StateAbandoned or Uncontrolled Sites Registry until no furtherthreat remains.

o Continued floating hydrocarbon removal until no appreciableamounts can be recovered..

o Removal of the uncontaminated cover soil and temporary storageof the material in a protected area.

o Removal of solid waste material, other than contaminated soil(e.g., drums, paint cans, wooden pallets, paint solids,general trash), from the disposal trenches and temporarystorage in a protected area.

o Ultimate disposal of the solid waste material in a municipallandfall if the material is non-hazardous or can be made non-hazardous through decontamination. Ultimate disposal in ahazardous waste landfill, or off-site incineration of thismaterial may be warranted if the material is hazardous andcannot be made non-hazardous.

o Removal of free solvent liquids from the excavation andtemporary storage in tanks, and off-site recycling of thesolvent, if possible, or off-site incineration.

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o For "clean closure" soils must pass the EP Toxicity test forleachable metals (40 CFR 261.24), the TCLP test for leachableorganics (40 CFR 268.41) and shall not contain more than 100mg/kg of Total Organic Hydrocarbons prior to final placement.

o An air monitoring program approved by the DNR will beimplemented during all site work.

o Dust control will be provided during excavation.

Bioremediation of soils will involve a fully contained surfaceimpoundment system complying with minimum technology standardsusing conventional soil management practices (e.g., nutrientaddition and soil aeration) to enhance microbial degradation andvolatilization of organic contaminants. The system will bedesigned to contain and treat soil leachate and volatilizedcontaminants.

A system consists of a double lined treatment bed, a sand/gravellayer to serve as a leachate collection system with perforateddrainage pipe and a sump, and groundwater monitoring. If volatilecontaminants must be contained, the entire treatment bed will becovered by a modified plastic film greenhouse. An overhead sprayirrigation system will be installed to control moisture and usedas a means of distributing nutrients (see Figure 9).

The leachate will be recycled back to the treatment area via thespray irrigation system. Leachate in excess of acceptable limitswill be treated on-site or collected for off-site treatment.Vapors will be treated (i.e. carbon adsorption) and released. Thespent carbon would be regenerated if possible, or sent to anapproved landfill facility. Approximately one-acre of land willbe needed for treatment of 3000 cubic yards of soil.

High concentrations of heavy metals may prohibit use of thisprocess. Additional soil sampling and testing and a treatabilitystudy are necessary prior to implementation. If small quantitiesof soils are identified as containing high levels of heavy metalswhich are incompatible with bioremediation, these soils will beisolated and treated on-site using a stabilization process (e.g.lime, Portland cement or bentonite). Treated soil will beredeposited in the excavation and covered with clean soil.

If high concentrations of heavy metals pose excessive restrictionson the use of bioremediation, thermal treatment of soils would beimplemented in its place; in which case, ancillary activities wouldremain the same and the soil would then be treated using lowtemperature thermal treatment to drive off the volatile organiccompounds. The organic compounds in the off-gas would be destroyedusing an afterburner if ARARs for air emissions cannot be met. Themobile low temperature thermal treatment system developed by WESTONis designed to handle 15,000 Ib/hr of contaminated soil based on

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Contominoted SoilExcovotion

SoilScreening

!Oversized Moteriol.o Speciol Hondling

Solid PhoseTreotment

Soil Loyer

PerforatedDroin Pipe

SyntheticLiner

SprinklerSystem

Source: Evoca Corp.(revised)

SOLID PHASE BIODEGRADATION

FIGURE 9

19a

20% soil moisture and 1% (10,000 ppm) VOCs. The system iscomprised of three trailers that are a total of 120 feet long and8 feet wide. The total height of the trailers, with the equipmentassembled, is under 13.5 feet. As with bioremediation, thermaltreatment will not remove metals and residual soil will bestabilized, if necessary, prior to redeposition.

Contaminated groundwater would be removed by pumping from one ormore recovery wells. A pumping test will be conducted during theremedial design to determine aquifer characteristics. Thisinformation will be used to design the pumping system; i.e., numberand location of wells, pumping rates, and gradient controls. Thewell (or wells) would be located and sized to draw water from theentire contaminant plume thereby preventing any off-site migrationof groundwater contaminants. The pumped water would be treated byair stripping to remove greater than 95 percent of the volatileorganic contaminants. Carbon adsorption would be used to removecontaminants in the air discharged from an air stripper, ifnecessary. Treated water from the air stripper would be dischargedto the adjacent stream. Activated carbon used for air strippingoff-gas and water polishing prior to discharge would be regeneratedor disposed of in an approved landfill facility. Pumping andtreatment will be continued until groundwater ARARs are met. Agroundwater monitoring program, approved by the DNR, will beimplemented and criteria for ceasing remedial action based onmonitoring results will be developed.

Air modeling will be done to ensure that air emissions pose noacute or chronic health risks with risks from carcinogens less than10"6 and 1/100 threshold limit value (TLV) for non-carcinogens. Airemissions will be evaluated during pilot studies and an airmonitoring program acceptable to the DNR will be developed fornormal operation.

Some changes may be made to the selected remedy as a result of theremedial design and construction processes.

Estimated costs for the selected remedy are shown in Tables 4 and5.

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TABLE 4

ESTIMATED COST OF SOIL REKEDIATION

Direct Cost Items Basis Cost*

1. Removal of clean soil & staging $4/cy x 9,000 cy $ 36,0002. Excavation of solid waste, staging

and disposal $150/cy x 3,200 cy 480,0003. Free product removal, trans-

portation and incineration $0.50/gal x 5,000 gal 2,5004. Air monitoring 2,0005. Excavation & staging of

contaminated soil $5/cy x 3,000 cy 15,0006. Sampling & analysis of staged

soil 20,0007. Land & site development 10,0008. Construction of staging areas &

physical facilities for bioremediation 99,000(Thermal Treatment) (40,000)

9. Biological Treatment includingleachate disposal) $33/cy x 3,000 cy 100,000(Thermal Treatment) ($265/cy x 3,000 cy) (795,000)

""0. On-site stabilization $60/cy x 3,000 cy 180,0001. Backfill $4.5/cy X 3,200 cy 14,400

12. Clay Cap $15/cy x 6,450 cy 96,75013. Revegetation $l,250/ac x 2 ac 2.500

TOTAL DIRECT $1,058,150($1,694,150)

Indirect Cost Items

1. Engineering, design and treatability study $150,000(100,000)

2. Contingency $160.000(250.OOP)TOTAL INDIRECT $310,000(350,000)TOTAL CAPITAL COST $1,368,150(2,045,000)

O&M Cost Items $l,000/year for 30 years

TOTAL PRESENT WORTH COST $1,385,000(2,060,000)

Discount Rate = 5.00%

*NOTE: Cost for .Thermal treatment same as bioremediation except as shown inparentheses.

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TABLE 5ESTIMATED COST OP GROUKDWATER REMEDIATION

Direct Cost Items Cost

1. Construction of recovery wells S 40,000

2. Installation of pumps 10,000

3. Construction of air stripper 110,000

4. Activated carbon disposal (air treatment) 3,000

5. Air monitoring 2,000

6. Monitoring well installation $ 20.000

TOTAL DIRECT $ 185,000

Indirect Cost Items

1. Engineering and Design (incl.treatability study) $ 80,000

2. Aquifer pump test 25,000

3. Contingency 30.OOP

TOTAL INDIRECT $ 135,000

TOTAL CAPITAL COST $ 320,000

O&M Cost Items

1. Power, operation and maintenance $50,000/year for 3 years

2. Groundwater monitoring $ 1,200/year for 3 years

3. Lab analyses $ 2,400/year for 3 years

TOTAL PRESENT WORTH COST $ 466,000Discount Rate = 5.00%

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The combination of Alternative S-3 for soils and GW-i forgroundwater, would provide a substantial risk reduction throughtreatment of contaminated soils and removal and air stripping ofcontaminated groundwater. The selected remedy ranks high withrespect to the nine evaluation criteria except for implementabilityof the soil remediation. If implementability of on-sitebioremediation of soils proves impractical, then Alternative s-2(on-site thermal treatment) will be utilized as the method forsoils remediation. Alternatives S-2 and S-3 are similar withregard to the evaluation criteria except for costs andimplementability.

Since no immediate risk has been identified, the risks (i.e., timeand development costs) of attempting to implement Alternative S-3 are justified. If Alternative S-3 proves impractical,Alternative S-2 will provide a well-proven technology as asubstitute.

2.9 Statutory Determinations

Under its legal authorities, EPA's primary responsibility atSuperfund sites is to undertake remedial actions that achieveadequate protection of human health and the environment. Inaddition, section 121 of CERCLA establishes several other statutoryrequirements and preferences. These specify that when complete,the selected remedial action for this site must comply withapplicable or relevant and appropriate environmental standardsestablished under Federal and State environmental laws unless astatutory waiver is justified. The selected remedy also must becost-effective and utilize permanent solutions and alternativetreatment technologies or resource recovery technologies to themaximum extent practicable. Finally, the statute includes apreference for remedies that employ treatment that permanently andsignificantly reduce the volume, toxicity, or mobility of hazardouswastes as their principal element. The following sections discusshow the selected remedy meets these statutory requirements.

Protection of Human Health and the Environment;

The selected remedy protects human health and the environment byremoving, destroying, and/or stabilizing all contaminants on thesite resulting in residual levels below health-based standards.This will be accomplished through biodegradation of volatileorganics in soil; stabilization of metals-contaminated soil, ifnecessary; covering the stabilized soil? and pumping and airstripping of groundwater-contaminated volatile organics; and carbonadsorption of the air stripper off-gas, if necessary.

The removal, treatment, and stabilization of contaminated soilswill eliminate the source of groundwater contaminants. Removal ofcontaminated groundwater will result in residual contaminant levelsbelow health-based standards. Currently there is no exposure to

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groundwater contaminants above health-based standards. However,the contaminant plume contains carcinogens at a level which wouldpresent a 1.7xlO"4 cancer risk if consumed on a regular basis andnon-carcinogens above lifetime health advisory levels. Remedialactions will result in residual groundwater contaminants posing acancer rate of 10"6 or less (within acceptable exposure, level ofbetween 10*4 and 10"6) and non-carcinogens below lifetime healthadvisory levels. There are no short-term threats or cross-mediaimpacts that cannot be readily controlled.

Compliance with Applicable or Relevant and AppropriateRequirements:

The selected remedy of excavation, on-site bioremediation,stabilization, groundwater extraction and air-stripping will complywith all applicable or relevant and appropriate chemical- andaction-specific requirements (ARARs). No location-specific ARARshave been identified. Tables 6 through 8 summarize all ARARs.

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TABLE 6

ARAR3 FOR SOIL REMEDIATION

ARAR COMPLIANCE

ACTION SPECIFIC

Excavation from uncontrolled waste disposaltrenches and subsequent placement of soilafter treatment (40 CFR Parts 264 & 268)

Waste pile storage of hazardous materials(not soil) to be decontaminated and non-hazardous materials (40 CFR Part 264,.ubpart L)

lank storage of liquid free productrecovered from waste disposal area(40 CFR Part 264, Subpart J)

DOT Hazardous Material Regulations(49 CFR, Subpart C)

IAC 567

Bioremediation treatment of soil(40 CFR 264, Subpart M)

Treatment of soil by stabilizationCFR 264, Subpart M) if metalconcentrations are too high

Thermal treatment of soil(40 CFR 265, Subpart P) ifbioremediation cannot be implemented

OSHA 29 CFR 1910 (Health and Safetyconsiderations for workers at siteduring remediation)

CHEMICAL SPECIFIC (see Table 8)

Placement of treated and/or excavatedsoils

Air emissions from excavating and treat-ment (Clean Air Act) (Risk from exposureto carcinogens less than 10"6 and 1/100for non-carcinogens)

Compliance

Compliance

Compliance

Off-site transport to complywith applicable Sections: 171,172, 173, 177 and 178

Compliance with Chapters 140 &141

Compliance with applicablesections

Compliance with applicable (40sections

Compliance with applicablesections

Compliance

Acceptable EP Toxicity and TCLPand Total Organic Hydrocarbonsbelow 100 mg/kg achieved

Compliance with applicablesections of State and FederalClean Air Act and 10"6 risk forTLV carcinogens and 1/100 TLVfor non-carcinogens

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TABLE 7

ARARS FOR GROPNDWATER REMEDIATION

ARARS

CHEMICAL SPECIFIC (see Table 8)

IGAL for all contaminants

SDWA MCLs for arsenic, cadmium,chromium, lead, and benzene

SDWA Proposed MCLs an MCLGsethyl-benzene, toluene, xylenes

Drinking water health advisorystandard for MEK

Treatment of groundwater by airstripping (Clean Air Act) (Riskfrom exposure to carcinogensless than 10-6, and 1/100 TLVfor non-carcinogens)

Discharge of treated groundwaterto receiving stream (Clean waterAct; substantive requirementsof NPDES program includingexisting and proposed Iowa WaterQuality Standards (Table 8)

ACTION SPECIFIC

OSHA 29 CFR 1910 (Health andsafety considerations forworkers at site duringremediation)

COMPLIANCE

Remediation of groundwaterto IGAL can be achieved

Remediation of groundwater toMCLs can be achieved

Remediation of groundwater toMCLs/MCLGs can be achieved

Remediation of groundwater toMEK standard can be achieved

Compliance with applicablesections of State and FederalClean Air Act 10-6 risk forcarcinogens, and 1/100 TLVfor non-carcinogens

Compliance with applicablesections of State and FederalClean Water Act

Compliance

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TABLE 8

SUMMARY OF CHEMICAL SPECIFIC ARARs

Category Compound Maximum LimitingConcentration authority

Air Emmissions Carcinogens(Benzene)Non-Carcinogens

10 cancer riskCAA0.01TLV CAA

Grouhdwater ArsenicCadmium

Chromium

LeadBenzeneEthylbenzene

Methyl Ethyl KetoneToluene

Xylenes

1,2-DichloropropaneMethvlene Chloride

0.05 mg/10.005 mg/1

0.10 mg/1

0.005 mg/10.001 mg/10.7 mg/1

0.17 mg/12.0 mg/1

10.0 mg/1

0.0006 mg/10.050 mq/1

IGALProposed MCL/MCLG(SDWA)

IGAL & proposedMCL/MCLG (SDWA)

Proposed MCL (SDWA)IGALIGAL & ProposedMCL/MCLG (SDWA)

IGALIGAL & ProposedMCL/MCLG (SDWA)

IGAL & ProposedMCL/MCLG (SDWA)

IGALIGAL

Surface WaterDischarge

ArsenicCadmiumChromiumLeadBenzeneEthyl BenzeneTolueneMethyl Ethyl KetoneXvlenes

0.2 mg/10.015 mg/10.04 mg/10.03 mg/15.3 mg/1*32 mg/1*2.5 mg/1*

*

Proposed Chronic IWQCProposed Chronic IWQCProposed Chronic IWQCProposed Chronic IWQCCWA (freshwater acute)CWA (freshwater acuteProposed acute IWQCCWACWA

Soils Placement Metals

Organics

AcceptableEP Toxicity

AcceptableTCLP Test100 mg/kg TotalOrganicHydrocarbons

40 CFR 261.24

40 CFR 268.41

KEY:CAA - Clean Air Act/Iowa Proposed Air Toxic RulesIGAL -. Iowa Groundwater Action LevelsSDWA - Safe Drinking Water ActIWQC - Iowa Water Quality CriteriaCWA - Clean Water ActMCL - Maximum Contaminant LevelMCLG - Maximum Contaminant Level GoalTLV - Threshold Limit Values

*Treatment-based standard (i.e., 95% minimum removal likely to control)

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RESPONSIVENESS SUMMARY FOR THE RECORD OP DECISION

The Remedial Investigation and Feasibility Study Reports and theProposed Plan for the Vogel site were released to the public forcomment on August 10, 1989. These two documents were madeavailable to the public in both the administrative record and aninformation repository maintained at DNR Records Center, 5th Floor,Wallace Building, 900 East Grand,Des Moines, Iowa, and in theOrange City Public Library.

The notice of availability for these two documents was publishedin the Sioux City Journal on August 10, 1989. A public commentperiod on the documents was held from August 10, 1989 to August31 1989. In addition, after publication of notice a publicmeeting was held on August 21, 1989, at the Northwestern StateBank, Orange City, Iowa. At this meeting, representatives fromDNR, EPA, and Vogel Paint and Wax Company answered questions aboutproblems at the site and the remedial alternatives/- underconsideration.

No written comments were received. Several oral comments werereceived at the public meeting as discussed below.

1. Comment; Has the installation of any new well be Deniedbecause of groundwater contamination from the Vogel site?

Response; No.

2. CoTument; Is Superfund money going to be used for thiscleanup?

Response; Under a consent order with DNR, Vogel Paint andWax Company has paid for the costs to date and we anticipatethey will also fund the cleanup work. If for any reason thecompany is not able to, or refuses to continue to do so,Superfund monies would be available to implement the proposedcleanup work.

3. Comment; What quantity of groundwater will be pumped andtreated? Will this cause lowering of the groundwater therebycontaminating more soil and increasing the volume of soil tobe treated; as related to floating hydrocarbons, in^particular?

Response; Floating hydrocarbons have been significantlydecreased since removal of floating hydrocarbons was begun.In fact, a significant floating hydrocarbon layer was notdetected during, the latest sampling in July. In addition,the floating hydrocarbon layer has been detected in a sandand gravel formation which is confined above by a clay layer.This sand and gravel formation is under artesian pressure andas such pumping will reduce pressure without actually

30

dewatering the aquifer to a point, and it is not expected thatthis formation will be dewatered. Therefore, the expressedconcern should not be a significant problem. In the remedialdesign an aquifer pumping test will be conducted for use indetermining the size and location of recovery wells.

4. Comment; What is the plan for disposal of drums, pallets,and things like this?

Response; The intention is to make a basic classification ofhazardous and non-hazardous material. Non-hazardous materialwill be taken to a licensed sanitary landfill. Hazardousmaterial will be taken to a landfill which is licensed fortaking that type of hazardous waste.

5. Comment; Will any kind of special trucks or hauling equipmentbe necessary to transport this hazardous waste on publichighways?

Response; Yes, the hazardous waste would be regulated underthe Resource Conservation and Recovery Act which includesregulations for the transportation, storage, treatment anddisposal of hazardous waste. Also, Department ofTransportation and Department of Labor (OSHA) regulations mustbe met. Some liquid waste may be taken to the Vogel plant forrecycling.

6. Comment; Would the spent carbon from carbon adsorption usedin the air stripping be treated as a hazardous waste also?

Response; Yes.

7. Comment; What is the time frame for the proposed action?

Response; The intent is to begin remediation in theSpring of 1990, with completion in 3-5 years forgroundwater.

8. Comment; Have all the alternatives been proven to work?

Response; Yes, all have been tried and proven. Thebioremediation of soil and groundwater are less proven thanother alternatives. The type of chemicals at the site areconducive for soil bioreroediation. However, if it does notwork, the more proven thermal treatment technology will beimplemented. The groundwater pump and air strippingtechnology is very well proven.

9. Comment; If the bioremediation of soil doesn't work how longwill it take to implement another technology?

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Response; It is possible that clecinup could still begin asearly as next spring. The overall schedule would not besignificantly modified, if another technology for soiltreatment is implemented.

..... • . ." i',10. Comment; When the proposed remedial efforts are completed

will there be continued monitoring and further cleanup, ifnecessary?

Response; There are two levels of monitoring. At a minimum,groundwater samples will be collected and .analyzed and thenthat data evaluated every five years. Also, more frequentmonitoring may be required on a site-specific basis.Additional remedial action will be taken, if necessary.

SUMMARY

No comments were received which expressed dissatisfaction with theproposed alternatives. The lack of comments in general impliesacceptance by the community. Therefore, no changes to the ProposedPlan have been made based on community acceptance.

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