RECORD OF DECISION

DECLARATION

Midwest Manufacturing/North Farm Site

Kellogg, Iowa

•10258979

SUPEKFUM) KKCOKDS

Prepared By:

U.S. Environmental Protection Agency

Region VII

Kansas City, Kansas

September 1988

Record of DecisionNorth 7ara Operable Unit

Declaration

SITE KAU£ AND LOCATION

Midwest Manufacturing/North Farm Superfund Site. North Farr.Operable Unit; Kellogg, Iowa.

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial actionfor the North Farm Operable Unit of the Midwest Manufacturing/North Farm Superfund site located in Kellogg, Iowa. The responseaction for the Midwest Plant site portion of the Midwest Manu-facturing/North Farm Superfund site will be addressed inanother decision as a separate operable unit. This decisiondocument was developed in accordance with the ComprehensiveEnvironmental Response, Compensation and Liability Act (CERCLA),as amended by the Superfund Amendments Reauthorization Act (SARA)of 1986 and, to the extent practicable, the National ContingencyPlan. The selection of the preferred remedial alternative isbased on the information contained in the Administrative Recordfor this site. The attached index identifies the items thatcomprise the Administrative Record. Also attached is a letter ofconcurrence from the State of Iowa for the preferred remedialalternative. A copy of this letter has been included in theAdministrative Record for this subsite.

DESCRIPTION OF SELECTED RZMEDY

The North Farm Operable Unit is one of two subsites withinthe Midwest Manufacturing/North Farm Superfund site. This sirehas been divided into two operable units; the North Farm site andthe Midwest Plant site. This decision document addresses thecontaminants located at the North Farm Operable Unit. A separatedecision document will address the contaminants at the MidwestPlant site.

The selected remedy provides for the excavation of thecontaminated soil within and around the disposal cell whichcontains cadmium concentration levels exceeding the health-basedaction level of 13 milligrams/kilogram (mg/kg). The contaminatedsoil will be treated using stabilization technology to achievelevels, in accordance with the Best Demonstrated AvailableTechnologies. The treated soils will be disposed in a RCRASubtitle C disposal facility. The excavated area will bebackfilled and graded with clean soil to support a vegetativecover.

DECLARATION

Consistent with the Comprehensive Environmental Response,Compensation and Liability Act of 1980, as amended, I havedetermined that the selected remedy described above, is cost-effective, protective of human health and the environment andutilizes permanent solutions and alternate treatment technologieste-the msiximum extent practicable. The remedy selection procedureof the selected remedial action complies with the provisions ofCERCLA and the National Contingency Plan, 40 CFR Section 300.

<rtor/is KayRegional Administrator

Date

RECORD OF DECISION

DECISION SUMARY

Midwest Manufacturing/North Farm Site

Kellogg, Iowa

Prepared By:

U.S. Environmental Protection Agency

Region VII

Kansas City, Kansas

September 1988

TABLE OF CONTENTS

Section Page

I. Introduction 1

II. Site Name, Location and Description 1

III. Site History 2

IV. CoEimunity Relations 3

V. Site Characteristics 4

VI. Summary of Site Risks 4

VII. Potentially Applicable or Relevantand Appropriate Requirements 8

VIII.Description of Alternatives 9

IX. Susunary of the Comparative Analysisof Alternatives 12

X. The Selected Remedy 17

XI. Rationale for Preference 18

XII. Statutory Determination 18

DECISION SUBXARYXIDWEST XANUTACTURING/HORTH 7AR» SCPERFUND SITE

K3RTH 7ARM BUBSITEKZLLOG3, IOWA

I. IKTRODDCTION

The purpose of this document is to describe the remedy that theU.S. Environmental Protection Agency (EPA) has selected toimplement at the North Farm subsite of the Midwest Manufacturing/North Farm Site. This document also describes the decision-makingprocedures that were followed in selecting the preferred remedialaction.

This remedial action has been selected to remedy an environmentalproblem which could potentially affect the health of theresidents who may choose to livfi at the Site in the future. As itis only part of the whole action, this is referred to as an"operable unit" remedial action. Operable units must beconsistent with the final remedy for a site and must be cost-effective with the site-wide remedy. In this instance, this isthe final remedy selection for the North Farm subsite.

The North Farm operable unit was combined with the Midwest Plantsite and proposed for the Superfund National Priorities List(NPL) in September, 1985. The Site became final on the NPL inMay, 1986. The NPL is EPA's list of the top priority hazardouswaste sites that are eligible for Federal money under theSuperfund program.

II. SITE NAME, LOCATION AND DESCRIPTION

Approximately 600 people live in Kellogg, Iowa, which is locatedin Jasper County, approximately 42 miles east of Des Moines (SeeFigure l). The North Farm subsite is located in a rural settingapproximately 2 miles north and 1/2 mile east of Kellogg. Theland usage near the Site is mainly agricultural with pasture landon and around the Site. The closest residence to the North Famsubsite is approximately 1 mile. The North Farm subsite consistsof an unlined disposal cell in which electroplating wastes weredisposed. The disposal cell contains approximately 200 cubicyards of soil contaminated with electroplating wastes.

The disposal cell is located on the lower slope of a rolling hilladjacent to the valley of Bear Creek. Bear Creek is anintermittent stream located 500 feet east of the site. The siteis approximately 50 feet higher than Bear Creek. Bear Creekflows to the south-southwest of the site for approximately 2miles and discharges into Coon Creek. Coon Creek continues toflow south for approximately 1/2 mile and discharges into theNorth Skunk River which runs south of Kellogg (See Figure 2).

SITS LOCATION

The surveyed legal description of the North Farr subsite is asfollows:: A parcel of land located in the south half of Section 12and the North half of Section 13 all in Township 80 North, Range18 West of the Fifth Principal Meridian, Jasper County, Iowa.The Nor*:h Farm subsite can more particularly be described asfollows:

Commencing at the Southwest Corner of Section 12, Township 80North, Range 18 West of the Fifth Principal Meridian, JasperCounty, Iowa;

Thence on an assumed bearing of North 90 degrees 00' 00'" East,2,637.99 Feet along the south line of said Section 12;

Thence South 01 degrees 00' 50flWest, 2.78 Feet to the point ofbeginning;

Thence North 83 degrees 29' 35'' East, 189.07 Feet;

Thence North 03 degrees 13' 16'' East 202.22 Feet;

Thence South 83 degrees 21' 40'' West, 196.99 Feet;

Thence South 01 degrees 00' 50'' West, 200.58 Feet to the pointof beginning containing .882 acres more or less.

III. SITE HISTORY

Smith Jones, owner of the Midwest plant subsite, is reported tohave engaged in electroplating special order stamped metalpieces.. This process involved the use of various heavy netals tocoat m«inufactured products. Cadmium was used prior to 1979,nickel was used until 1980, and zinc was used from 1980 to 1981.All electroplating operations ceased in June, 1981.

In 1977, a wastewater treatment plant was brought on-line toprevent pollutants from being directly discharged into the NorthSkunk River. The wastewater discharged from the plant was treatedwith lime and permanganate to precipitate the heavy metals fromthe waste stream. A polymer was then added to coagulate thesolids. The resulting solids were temporarily stored in a tankfrom which they were periodically removed and placed into adisposal cell.

From approximately 1977 to 1978, solids containing highconcentrations of cadmium, nickel and zinc were disposed into anunlined cell located at the North Farm subsite. This unlined ceilhas no soil cap to limit infiltration of water and does not havea leachate collection system. It also lacks run-on and run-offcontrol or other engineering features which would contain orprevent the release cf hazardcuc sutstances.

In 1982, soil sampling was conducted at the North Fans suxsite bvEcology and Environment (EiE) on behalf of the U.S. EPA. Thepurpose of the soil sampling was to evaluate the potential forcontaminant migration resulting from previous waste disposalpractices. Three soil samples were collected from the locationsshown in Figure 3. The three samples were analyzed for particlesize distribution and cation exchange capacity (CEC). The CEC forthe throe samples were 6.5, 11.7 and 10.2 milliequivalents per100 grans of soil. Sand percentages in these samples were 34%,32% and 23%. It was concluded by the USEPA that additional datawas deeiaed necessary to evaluate contaminant migration. In April1983 th« North Farm subsite was again investigated by E & E onbehalf of the U.S. EPA. Eight soil samples were collecteddownsiope from the disposal cell. A background sample wascollected approximately 200 yards west of the Site. The samples,excluding the background sample, were composited from hand augercuttings, taken from the surface depth of 4 feet. The sampleswere analyzed for priority pollutant metals and pH. In general,the metal concentrations detected north and east (dovnslope) ofthe trench (sample numbers AQ2701, AQ2702 and AQ2707) were higherthan those detected in other sampling locations. It wasconcluded that the higher concentrations in these samplesindicated that some soil contamination had occurred via surfacerun-off.

ZN70RCBKENT ACTIVITIES

The Special Notice procedure of Section 122(e)(l) of CERCLA wasfollowed regarding the Remedial Investigation/Feasibility study(RI/FS) phase of this project. No Potential Responsible Partymade a good faith offer to undertake or finance the RI/FS.Consequently, EPA proceeded to initiate the RI/FS.

IV. COMMUNITY RELATIONS

An announcement was mailed to the parties listed in the communityrelations plan. This announcement notified the parties of theavailability of the Administrative Record, Proposed Plan andother pertinent documents used by the Agency to select thepreferred remedy. These parties were also informed that EPA wouldrequest comments from the general public beginning September 8,1988 until September 29, 1988 on all of the remedial alternativesas set forth in the FS.

A public meeting was held on September 21, 1988 in Kellogg, Iowato receive comments from the public regarding all of theremediation alternatives detailed in the FS report. Aresponsiveness summary of the public's comments received duringthe public comment period, including the public meeting, isattached to this Record of Decision. The Administrative Recordfor this Site has been available for public review at the Nevtr-Publi:: Library ir. Newton, Iowa; the Kellogg Public Library ir.Kellogg, Iowa; and the New Brotherhood Building ir. Xar.sas CityKansas. The administrative record includes all documents, sue.-.as the Proposed Plan, the RI/FS reports and other relevant

material considered in developing the remedial alternatives fcrthis Site;. All community relations activities have been inconfcrmarice with the requirements of Section 117 of CERCLA andthe National Contingency Plan, 40 CFR Section 300.

V. 8I B CHARACTERISTICS

In March 1988, EPA conducted a RI in order to identify the types,quantities and locations of the contaminants in and around thedisposal cell. The results of the RI are summarized as follows:

1. Onsite surface soils are contaminated with variouslevels of heavy metals such as calcium, cadmium and manganese.

2. The contaminated soil within the disposal cellcontains various levels of heavy metals such as cadmium, nickel,zinc, sodium, cyanide and calcium. This material also failed theEP Toxicity test for cadmium.

3. Approximately 200 cubic yards of contaminated soilcontaining cadmium above the health based action level of 13ng/kg established for cadmium are believed to be present at theSite.

4. According to the Public Health Evaluation (PHE),cadmium bioaccumulates in mammals, particularly in the kidney andliver. Sub-chronic and chronic exposure to cadmium is associatedwith a number of noncarcinogenic but toxic effects, includingkidney damage in humans and experimental animals. Non-carcinogenic toxic effects may result from incidentalingestion of soil, ground water or other media. The USEPAconsiders cadmium a carcinogen only when inhaled.

5. The ground water beneath the site appears to be aperched water table that has no hydraulic continuity with theBear Creek alluvium.

6. The contaminant concentration measured in theground vater was at or near the action level of 18microgreims/liter (ug/1) for cadmium and 7700 ug/1 for manganese.

Table numbers 1 through 4 present the type and concentration of thehazardous substances detected in and around the disposal cell.Also, Figure 4 presents the lateral and vertical extent of thesecontaminants.

VI. SUMXARY 07 SITE RISKS

As part of the RI report, a baseline Public Health Evaluation(PHE) was conducted. This examination considers the potentialthreat to human health and the environment in the absence of anyremedial action under both current and future use scenarios. Itprovides the basis fcr determining if a remedial acticr, isnecessary. Cadr.iur. and manganese were identified as thechemicals of concern for the grcu.id water media. Cadr.iu- an-

cyanide were identified as the chemicals of concern fcr thecontaminated soil media. The criteria for selecting thechemicals of concern are as follows:

1. The degree of the toxicity and quantity of thehazardous substance found in the contaminant migration media;

2. Environmental fate and transport mechanisms of thechemical within the specific environmental media;

3. The potential human exposure pathways and theextent of actual or expected exposure;

4. Population at risk;

5. Extent of expected harm and the likelihood of suchharm occurring; and

6. Acceptable levels of exposure based upon regulatoryand toxicological information.

Under current land use conditions no one is currently beingexposed to the contaminants of concern via the migrationpathways;. Therefore, elevated health risks associated withcontaminant exposure are not present. However, under a future usescenario, it is anticipated that the migration pathways, soil andground water, will be activated. The activation of thesemigration pathways will serve to elevate the potential risks foradverse health effects in local residents. The exposure scenariosidentified for future land use conditions are:

1. Ingestion of ground water;

2. Direct contact with surface soils; and

3. Ingestion of vegetables grown in contaminated soil.

The major conclusions of the PHE are as follows:

1. It is unlikely that the direct contact withcontaminated soils by future on-site residents would lead toadverse health effects.

2. Cadmium will leach from the waste material whensubjected to the EP Toxicity test. As cadmium leaches from thewaste material it will deposit itself into the ground water. Thelikelihood of future residents installing a drinking water wellat the site is low. This is because the expected yield from thewell would be from 0 gpm to 1 gpm which is an insufficient amountto support residential needs. However, if such a scenario were tooccur, then under a maximum exposure scenario, individuals whowould drink this water may experience adverse health effects.

2. Under plausible maximum conditions, adverse heait'r.conditions could result fcr future residents if they ingested

vegetables grown on the contaminated soil at the site.

Table 5 presents the contaminants of concern including theirconcentration level and health based action level per exposurepathway. The health based action level is the contaminantconcentration level above which adverse health effects may beexperienced by persons exposed to the contaminant.

RISK CHARACTERIZATION

Health-based action levels were developed for each of thecontaminants of concern via each exposure pathway. These actionlevels vere developed using the procedures outlined in "TheSuperfund Public Health Evaluation Manual", OSWER DirectiveNumber 9285.4-1, October, 1986 and " The Superfund ExposureAssessment Manual", OSWER Directive Number 9285.5-1, October,1987. Ba.sed upon this data in conjunction with the standards ofother p«;rtinent Federal and State environmental laws, appropriateresponse actions can be developed per migration pathway. Resultsof the RI and PHE discussion indicate that no response action forground water would be necessary in order to protect the publichealth amd the environment. Also, the RI data and the FSestablished an action level of 13 mg/kg for cadmium in the soil.The following discussion presents the basis for theseconclusions.

GROUND VATER

As is shown on Table 5, an action level of 7700 ug/1was developed for manganese. This value is 5600 ug/1greater than the highest concentration level measured at theSite. Also, manganese received a Hazard Index score which wasless than 1. A Hazard Index score of less than 1 indicates thatthe contaminant does not pose a health risk at its presentconcentration level. Finally, Table 6 presents the groundwater quality criteria developed under other Federalenvironmental laws. The only criteria exceeded by manganese isthe Maximum Contaminant Level (MCL) standard developed under theSafe Drinking Water Act. However, this MCL represents a secondarystandard which is established for aesthetic quality only. Adversehealth effects in humans would not be expected if this standardis exceeded. Therefore, it is believed that manganese does notrepresent a potential human health threat at its currentconcentration level.

It is determined that no action needs be taken to protect groundwater with respect to cadmium. This decision is based on thefollowing factors. Cadmium received a hazard index score equal tcone, which indicates that it represents a marginal risk to humanswho may ingest cadmium contaminated water. As is shown in Table6, the action level for cadmium is 18 ug/1. This, in turn, is 1ug/1 less than the highest tstal concentration level found at tu.eSite. It is not considered that this differential is significant,in vie1* of the fact that this level was attained only in onesample, while the balance of t.w.e sa-plss were s;gr.ifica.-.tly

lower.

In addition, the sample which exceeded the 13 ug/1 action levelwas not filtered prior to analysis, so that the analyticalresults represent the total cadmium present in the ground water.None of the filtered samples, which represent the dissolvedcadmium concentration in the ground water, exceeded the actionlevel. It is believed that the filtered sample provides a bettermodel of drinking water. Monitoring wells, are typically of adifferent type of construction than wells constructed fordrinking water. Consequently, Monitoring wells usually produce agreater amount of sediment mixed with the water than is the casefor a drinking water wells. Contaminants have a tendency toattach themselves to the sediment. This causes the contaminantconcentration measured in an unfiltered (total) sample to begreater than that of a filtered sample. Therefore, the unfilteredcontaminant concentration measured in a drinking water well wouldbe similar to that measured in a filtered sample collected from amonitoring well. Cadmium, therefore, would not represent apotential human health threat at its current concentration level.

Finally, the water beneath the Site has been identified inSection 3.1 of the RI as being a perched water table. Such a unitis expected to be recharged only from precipitation, and wouldnot be hydraulically connected to the Bear Creek alluvium. Inaddition, a drinking water well located in this water table wouldonly produce from 0 to 1 gallons per minute (gpm). This amountis significantly below most residential needs. Therefore, it isunlikely that such a drinking water well would be installed inthis water table. Furthermore, at the present time, there are noknown users of this ground water. Based upon the low yield, thelikelihood that the unit would never be used for any purpose, thelow potential for human health risks, a ground water responseaction is unnecessary.

BOIL

A health-based action level of 13 mg/kg was established forcadmium present in the soil. This action level represents theconcentration of cadmium that could be left in the soil at theNorth Farm subsite without presenting adverse risks to humanhealth. The following soil exposure pathways were evaluated: 1)ingestion of contaminated soil 2) dermal contact with thecontaminated soil and 3) the root uptake of cadmium by vegetablesand subsequent ingestion of these vegetables. Action levels weredeveloped for each of these exposure pathways. The action leveldeveloped for the ingestion of vegetables grown on contaminatedsoil was found to be the most conservative. Thus, the healthbased action level for cadmium present in the soil at the NorthFarm subsite is 13 mg/kg. Section 2 and Appendix A of theFeasibility Study Report contain a more detailed discussion ofhow this action level was developed.

VII. POTENTIALLY XPPLICXBL2 OR RZLZVANT AND APPROPRIAT2RZO.UIRZXZNTS

Section 121(d) of CERCLA provides that the remedial actionselected must require, at the completion of the remedial action,a level or standard of control which at least attains the legallyapplicable or relevant and appropriate standards, requirements,criteria, or limitations of any Federal environmental laws or any-more stringent State environmental or facility siting laws. Avariety of Federal environmental laws were reviewed as to legalapplicability or relevance and appropriateness to the remedialalternatives under consideration at this Site. These lawsincluded the Toxics Substances Control Act, the Safe DrinkingWater Act, the Clean Air Act, the Clean Water Act, and the SolidWaste Disposal Act. Of these Federal environmental laws, onlythe Resource Conservation and Recovery Act (RCRA), as amended,and Hazardous and Solid Waste Amendments (HSWA) of 1984, whichare parts of the Solid Waste Disposal Act, were found to bepotentially applicable or relevant and appropriate to theseremedial alternatives. Review of various State environmentallaws and regulations, including those pertaining to solid andhazardous waste management, indicate that the Federalenvironmental laws are at least as or are more stringent thanState Law.

The RCRA, as amended by HSWA of 1984, regulates the generation,transportation, treatment, storage and disposal of definedhazardous waste. Hazardous wastes are defined in 40 CFR Part 261in two basic ways, which are 1) by the characteristics of thewaste a.nd 2) by specific listing of the waste as a hazardouswaste. The waste at the North Farm subsite could be classifiedas RCRA hazardous waste both on the basis of its characteristics,in that it failed the EP Toxicity Test for cadmium, and as alisted hazardous waste, in that the wastes present at the Siteare wastewater treatment sludges from electroplating operations(F006) .. Since the wastes were deposited at the site prior to theeffective date of these regulations, the RCRA hazardous wasteregulatory requirements would not be applicable if the wastes areleft undisturbed at the Site. However, if some action is takenwhich amounts to generation of hazardous waste, such asexcavation of the waste under Alternatives 4 and 5, RCRA'sregulatory requirements would be applicable. Furthermore, eventhough they are not legally applicable to the response action,various aspects of the RCRA hazardous waste managementrequirements may be relevant and appropriate to the responseaction.

The principle components of RCRA's hazardous waste managementregulations which might be applicable or relevant and appropriateto the response alternatives considered at this site are asfollows:

A. RCRA Landfill Closure Standards The RCRA hazardousvasts management progra- requires that, upon closure, hazard:-;waste management facilities be closed in a manner that (1)

minimizes; the need for further maintenance and controls; (2)minimizes or eliminates, to the extent necessary to protect hur.ar.health arid the environment, post-closure escape of contarir.ar.tsto the ground or surface waters or the atmosphere, and (3)complies with specific closure and post-closure requirements.

Closure and post-closure requirements for landfills include (1)covering the landfill with a final covering which meets certainrequirements; (2) long-term maintenance of the cover; (3) andlong-tenn ground water monitoring. Corrective action may berequired if the water contaminant levels exceed a health-basedaction level. Land use and deed restrictions may be placed onthe property for an indefinite period of time.

If the contaminant concentrations remaining at the site uponclosure are below health based action levels, long-term operationand maintenance, ground water monitoring, and access or deedrestrictions may not be required under this option.

B. RCRA Minimum Technology Requirements (MTRs) The RCRAhazardous waste management regulations also impose specificrequirements on new hazardous waste management facilities, newunits at existing facilities, and on replacements of existingunits. These requirements would include installation of doubleliners and a leachate collection system.

C. RCRA Land Ban Disposal Regulations (LBDRs). TheHazardous and Solid Waste Act of 1984 amended RCRA to imposerestrictions on the land disposal of hazardous wastes. Forpurposes of these land disposal regulations, land disposal isdefined as "any placement of such hazardous wastes in a landfill,surface impoundment, ... ." EPA has promulgated regulationsestablishing the conditions under which certain listed hazardouswastes, including F006 listed wastes, could continue to be landdisposed after August 8, 1988. These conditions includetreatment of the wastes to levels achievable by the BestDemonstrated Available Technologies(BDAT). For F006nonwastewaters, the identified BDAT is stabilization toimmobilize the constituents. The BDAT treatment standard isexpressed as constituent concentration levels in a ToxicityCharacteristic Leaching Procedure (TCLP) extract to reflectwhether immobilization has been optimized. The BDAT treatmentstandard for F006 nonwastewaters is as follows:

Constituent Treatment StandardCadmium .066 milligrams/liter(mg/1)Total Chromium 5.2 mg/1Lead .51 mg/1Nickel .32 mg/1Silver .072 mg/1

VIII.DESCRIPTION 07 ALTERNATIVES

During the FS , five remedial alternatives were developed basedUDCT. screening tachnolocies frcz three riajcr Gate-cries:

10

biological, chemical and physical treatment. Four processoptions were identified as being able to attain the clean upstandards specified in the potential Applicable or Relevant andAppropriate Requirements (ARAR) section of the FS report. Theseprocess options were used to develop the remedial alternativeswhich are described in detail in the FS. Each of these fivealternatives is summarized below.

Alternative i4_t_ MO Action

Under this alternative, no specific action would be taken tocontrol the migration of the contaminants at the Site.Institutional controls, such as deed and access restrictions,would be implemented and are included in the evaluation of thisalternative. The "no action" alternative is considered as partof the remedial action evaluation at every Superfund site. Thisalternative acts as a baseline in the risk assessment analysis inevaluating the potential threat to human health in the absence ofany remedial action. The "no action" alternative is consideredto be appropriate only when there is no increased risk to humanhealth or the environment as a result of past waste managementactivities.

Alternative 12; RCRA Cap vith Ground Water Monitoring

Under Alternative 2, a cap meeting the RCRA closure requirements,40 CFR Part 264 Subparts G and N, would be placed over thesurface of the disposal cell. The purpose of the cap is both tominimize infiltration of surface waters through the wastes and tominimize potential for direct contact with the wastes.

Because the waste was placed in the disposal cell prior to theeffective date of the regulations defining the waste as a RCRAhazardous waste (November 19, 1980) and the waste is not beingdisturbed, the RCRA closure requirements are not legallyapplicable to this remedial alternative. However, they areconsidered to be relevant and appropriate requirements for thisalternative. Therefore, in addition to the RCRA cap, thisalternative would include periodic ground water monitoring toprovides information on ground water quality. Institutionalcontrols, including access and deed restrictions, would beutilizcsd for an indefinite period of time. Although notspecifically a part of this option, corrective action may benecessary in the future if the contaminant levels in the groundwater «xceed appropriate action levels.

Alternative 1 H Boil Cap with Ground Water Monitoring

This alternative is similar to Alternative 2 except that a five-foot thick soil cap would be placed over the disposal cell ratherthan a RCRA cap. The soil cap would serve the same purpose asthe RCRA cap in reducing infiltration of surface waters andminimizing potential direct ccr.ta^t with the wastes. A five-fr:tthickness was selected for this alternative on the basis of thefreeze-thaw cycles in the locale of the Site. This alternative

also includes ground water monitoring and the use of access anddeed restrictions for an indefinite period of tine. As withAlternative 2, future corrective action is a possibility ifcontaminant levels increase in the ground water, but is not aspecific part of this alternative.

As discussed above for Alternative 2, while not legallyapplicable to this remedial alternative, the RCRA LandfillClosure Standards are considered to be relevant and appropriaterequirements for remediation scenarios relying solely on cappingtechnology to contain the hazardous substances. To the extentth« soil cap does not satisfy the RCRA closure requirements, thisalternative would not comply with identified relevant andappropriate requirements as identified by the Agency.

Alternative 1 4; Excavation. Solidification and Radisposal ofExisting r>ftn»»»-inatad Katarial with ground Watar Monitoring

Alternative 4 provides for the excavation of the contaminatedsoil within and around the disposal cell which contains cadmiumconcentration levels exceeding a health based action level of 13ng/kg. Cadmium concentrations in soil at levels below thehealth-based action level do not pose a risk to human health orthe environment. In order to achieve a cost-effective remedialaction, only soil contaminated at levels which would present apublic health or an environmental threat will be removed.Approximately 200 cubic yards of contaminated soil above thehealth based action level is believed to be present at the Site.The excavated soil would be treated using stabilizationtechnology to achieve compliance with the BDAT treatment standardfor F005 nonwastewaters. After treatment, the excavated soilwould be placed back into the existing disposal cell.

RCRA as amended by the HSWA established new minimum technologyrequirements (MTRs) for land disposal units. If new landfills orsurface impoundments are constructed, or if replacements orlateral expansions of existing landfills or surface impoundmentsare used, they must satisfy these minimum technical requirements.Replacement occurs if a unit is emptied and reused. Reuse occursif original waste is removed from a unit and a different wasteeither treated or untreated from other units is put into theunit. If a waste is removed from a unit, treated, and put backinto the same unit, replacement does not occur. Therefore, theMTRs would not be applicable to this remediation scenario.However, the Agency has identified these standards as being bothrelevant and appropriate to this alternative. The followingcomponents of the MTRs would be incorporated into thisalternative: 1) double liners and 2) a leachate collection syste-to be installed into the existing disposal cell.

RCRA's Landfill Closure Requirements (LCRs) would also beapplicable tc this remedial alternative. Therefore, a surfacecap which meets the specif icaticr. of RCRA would be placed everthe disposal cell, ground water r.cr.itorir.g would be conducted 2tscheduled intervals and access ar.d deed restrictions wou.d be

Corrective action, which aay also be necessary in th scontaminant levels in the ground water exceed an appropriateaction level, is not specifically a part of this remedialalternative.

Alt«n:ativ« 5; Excavation, Solidification, and Offsite Disposalof Copti.ainat«d Materials

This alternative provides for the excavation of the contaminatedsoil within and around the disposal cell which contains cadmiumconcentration exceeding a health-based action level of 13 mg/kg.As with Alternative 4, above, it is estimated that 200 cubicy-a-rds of contaminated soil would be excavated under thisalternative. The excavated soil will be treated to achieve theBOAT standard using stabilization technology and transported off-site for disposal in a RCRA regulated facility. The treatmentprocess may be conducted either on- or off-site. The excavatedarea would be backfilled and graded with clean soil to support avegetative cover.

This alternative represents RCRA's Landfill Clean Closure Optionas defined in 40 CFR Part 264, Subpart N. A leachate collectionsystem would not be installed prior to backfilling the disposalcell with clean soil and a RCRA cap would not be placed over thedisposal cell. No post-closure care, such as long term groundwater monitoring and access or deed restrictions would berequired.

IX. SUMMARY OP THE COMPARATIVE ANALYSIS OP ALTERNATIVES

Section 121 (b)(1) of CERCLA provides that the President shallselect a "remedial action that is protective of human health andthe environment....and utilizes permanent solutions....to themaximum extent practicable." Section 121 (b)(l) further providesthat remedial actions which include treatment measures topermanently and significantly reduce the mobility of thehazardous substances, pollutants, and contaminants are preferredover remedial actions which do not include such treatmentmeasures. Section 121(b)(2) provides that a remedial action whichmeets these criteria may be selected whether or not such remedialaction has been achieved in practice at any other facility orsite that has similar characteristics. Thus, each of thealternatives listed in section 7 of this document was evaluatedusing the criteria listed below. Table 4 summarizes theevaluation criteria versus the proposed remedial alternatives.

1. PROTECTION p_f HUMAN HEALTH AND THE ENVIRONMENT

Protection of human health and the environment pertains to howrisks are eliminated, reduced, or controlled through treatment,engineering controls, or institutional controls. All of thealternatives evaluated in the FS would provide some degree ofprotection to the public health and the environment. However,the degree of protection and perr.arence of the protectiveness

vary between the alternatives.

The "No Action" alternative is considered as part of the remedialaction at every Superfund site. It serves as a baseline in therisk assessment analysis in evaluating the potential threat tohuman health in the absence of any remedial action. Thisalternative would rely upon institutional controls, such as deedand access restrictions, to minimize human contact with thecontaminants. However, no affirmative steps would be taken toprevent such contact or to reduce the migration of contaminantsoff-site.

Alternatives 2 and 3 would provide a a greater degree ofprotection to the human health and the environment by takingaffirmative action to reduce the potential for contact with thecontaminated soils and reducing migration of contaminants byminimizing surface water infiltration through the wastes. Overthe long term, the degree of protection to human heath and theenvironment would depend largely on the quality of maintenanceprovided for the cap.

Alternative 4, by providing treatment to reduce the mobility ofthe contaminants and other affirmative controls, would provide ahigher degree of protection than would alternatives 1, 2, or 3,which also involve leaving contaminants on-site above the 13mg/kg health-based action level for cadmium. Long-term groundwater monitoring and maintenance would be necessary to maintainthe reliability of this alternative.

The excavation and off-site disposal of the contaminated soilunder Alternative 5 would provide the highest degree ofprotection for human health in that all contaminants in the soilabove h«alth-based standards would be removed from the site. •

2. COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATEREQUIREMENTS

Alternatives 2, 4, and 5 would achieve all applicable or relevar.tand appropriate requirements, whereas alternatives 1 and 3 wouldnot.

3. REDUCTION Of TOXICITY. MOBILITY OR VOLUME

Section 121(b) of CERCLA states that remedial actions involvingtreatment, which permanently and significantly reduce the volume,mobility or toxicity of hazardous materials, are to be preferredover those not involving such treatment. This evaluation criteriarelates to the ability of a remedial alternative to control oreliminate risks caused by the mobility, toxicity or volume of ahazardous waste.

Alternative nunber 1 would have no direct impact on the toxicity.volume or mobility of the hazardous substances at the North F^r-subsite. Alternatives nunier 2 and 2 propose to rely solely or.capping technology to

toxicity, or volume of the hazardous substances si.-cecontaminants would remain at their current levels. However, themobility of the contaminants would be minimized by the reducingthe flow of ground water flow through the waste, but the leachir.cof the contaminants into the ground water would continue.However, this would be at a reduced rate compared to what wouldbe expected under the "No Action" scenario. The amount of waterthat would filter through the wastes would be a function of thecap's integrity. As the cap erodes with time, the amount ofwater flowing through the the cap which could generate leachatewill increase. Thus, the potential for ground water contaminationwill increase. The RCRA cap would provide a greater degree ofprotection against the infiltration of the water through thewaste than what could be expected from the soil cap.

Alternative number 4 would use stabilization treatment technologyto reduce the mobility of cadmium in the soil. This alternativeproposes; using stabilization technology in conjuntion with a RCRAcap, liner and leachate collection system. This alternative woulddo nothing to reduce the toxicity or volume of the hazardoussubstances at the Site. However, it would provide the greatestdegree of protection against contaminant migration when comparedto the other alternatives which proposed on site wastemanagement. Also, stabilization technology has been identified asthe BOAT for treating wastewater sludges generated fromelectroplating operations (see the Land Ban Disposal Regulationsof August 8, 1988). Assuming current site conditions do notchange iipreciably, stabilization can be expected to be a long-term solution in retarding the mobility of the contaminants.

Alternative number 5 proposes to use stabilization treatmenttechnology to reduce the mobility of the contaminants. Thistreatment technology will not reduce the toxicity or volume ofthis waste. However,this is not a critical factor for thisAlternative since the waste is being transported off-site fordisposal.

4. SHORT-TERM EFFECTIVENESS

Short-term effectiveness involves the period of time needed tcachieve protection and any adverse impacts on human health andthe environment that may be posed during the construction andimplementation period until clean up goals are achieved.

Of the Alternatives evaluated, in-place containment of thecontaminated soils, as proposed in alternatives number 2 and 3would provide the highest degree of short-term protection. Short-term protection is high because the implementation of in placecontainment does not involve excavation or other soil disturbingactivities which could potentially affect site workers. Also,short term risks would remain at current levels for Alternative1 since no soil disturbing activities would occur.

15

Alternatives involving excavation and subsequent treatment of thecontaminated soils, as proposed in Alternatives 4 and 5, wouldprovide increased opportunity for exposure to contaminants bysite workers. Worker exposure could potentially occur throughdirect contact, ingestion or inhalation of contaminated soilparticles. Since this Site is in a rural setting, the surroundingcommunity would be at too great a distance to be affected byairborne contaminants. Measures could be implemented which wouldeliminate the potential for worker exposure during soildisturbing and handling activities. These measures include use ofprotective clothing, appropriate breathing apparatus andeffective dust control.

5. LONG-TERM EFFECTIVENESS AKD PERMANENCE

Long-term effectiveness and permanence refers to the ability of aremedy to maintain reliable protection of human health and theenvironment over time once clean up goals have been met.

Alternative 1 is not a permanent remedy. It would not beeffective over the long-term in protecting public health. Underthis alternative, the contaminants would not be inhibited fromleaching into the ground water and migrating from the Site.Finally,, this alternative would not prevent human exposure viadirect contact.

The use of capping technology as proposed in Alternatives 2 and3 would serve to minimize the risk of human exposure via directcontact. However, the degree of effectiveness in protectinghumans from exposure is a function of the cap's integrity.Overtime both the RCRA cap and the soil cap will erode. As thecap erodes, the degree of protectiveness will continue todecline. Also, as the cap erodes the amount of water able tofilter through the waste will increase. This will cause leachateto be generated which will increase the potential for thecontaminants to migrate into the ground water. Furthermore, a capwill require long-term maintainence and portions of it will needto be replaced in the future. A soil cap is not expected to lastas long as the RCRA cap. Thus, the degree of protectivesnessafforded by a soil cap is not as great as that of a RCRA cap.Finally, the use of access restrictions as is proposed in bothAlternatives 2 and 3 will minimize the likelihood of the cap fror.being disturbed.

The stabilization of the contaminated soil in conjunction with aRCRA cap, a liner and a leachate collection system as proposed inAlternative 4, will provide the highest degree of protectivenessand reliability when compared to Alternative 1, 2 or 3 . The useof a RCRA cap in conjunction with stabilization treatment willsignificantly reduce the liklihocd for ground water contam-ination. If water should filter through the cap, then thestabilized waste should inhibit the generation of the leachate.The use of stabilization treatment will alsc significantly rei'_; =the potential for the contaminants to migrate from the Site.Furthermore, the use of a RCRA cap will ainimze the threat to the

human health via direct contact. Finally, assuming current Siteconditions do not change appreciably, stabilization technologyevaluated by itself, can be expected to be a long-tenr solutionwith a high degree of permanence.

Alternative 5 would provide the highest degree of protectivenessand reliability of all of the remedies evaluated in theFeasibility Study Report. This is the only Alternative that wouldcompletely eliminate all short or long-term risks to the publichealth or the environment. Also, post-closure care such as futurecorrective action, long-term ground water monitoring or accessand deed restrictions would be unnecessary under this alternative.

6. IMPLEMEKTABILITY

Implementation addresses the .technical and administrativefeasibility of a remedy, including the availability of materialsand services needed to implement the chosen solution.

The implementation criterion does not apply to the no actionalternative since no remedial measures would be taken.

The implementability of in-place containment as is proposed inAlternatives 2 and 3 is affected by technical considerations suchas availability of suitable cover materials (rock, clay, soil andseed for acclimated vegetation). The remedial design would takesite characteristics into account when developing the capblueprint. Both of these Alternatives propose using technologieswhich could be readily implemented at the Site.

Both Alternatives 4 and 5 have proposed the use of stabilizationtechnology to treat the contaminated soil. Stabilizationtechnology has been identified in the Land Ban DisposalRegulations of August 8, 1988, as being the BOAT for thetreatment of wastewater sludges generated from electroplatingoperations. Since this is a proven technology, no technicaldifficulties are expected regarding its implementation. Also,firms which maintain the equipment and the skilled workers neededto implement this technology are available in the greater DesMoines area. Some difficulty may be encountered in locating aRCRA Subtitle C Landfill operator to accept the treated waste asis proposed in Alternative 5. No other administrativedifficulties are expected regarding the implementation of thistechnology.

7. £211

CERCLA requires that the EPA select a cost-effective (not merelythe lowest cost) alternative that protects human health and theenvironment and meets other requirements of the law. Alternative2, 3 and 4 all have an initial carital cost which is lower thanthat for Alternative 5. However, the overall cost of each ofthese Alternatives, including long-tern operation and r.air.ter.ar.zeand gr::und water aonitcring, is at a level sir.ilar to that cfAlternative 5. Furthermore, since contaminants would be left cr.-

site, for Alternatives 2, 3, and 4, future corrective action is apossibility, which could increase the cost of each alternativeabove that for Alternative 5.

The 30-year present worth costs of each alternative is presentedin Table 7.

8. COMMUNITY ACCEPTANCE

This evaluation criteria addresses the concerns of the publicregarding acceptance of a particular remedy.

The comments received indicate that the public is concerned aboutthe costs of the proposed remedial Alternatives and who will paythese costs. In addition, the comments presented at the publicmeeting held on September 21, 1988 indicated that the public didnot perceive the Site as presenting any significant threat to thepublic health or the environemnt.

9. STATE ACCEPTANCE

The state acceptance criteria indicates whether, based on itsreview of the RI/FS and Proposed Plan, the State concurs with,opposes, or has no comment on the preferred alternative.

The State of Iowa informed the Agency in a letter dated August 8,1988 that it agreed with the EPA's selection of the preferredremedy for the North Farm subsite.

X. TEE SELECTED REMEDY

Based on the information available to evaluate the remedialoptions; against the previously described criteria, Alternative 5is selected as the preferred remedy for the North Farm subsite.This Alternative provides for the excavation of the contaminatedsoil within and around the disposal cell which contains cadmiumconcentration levels exceeding a health based action level of 13mg/kg. The development of this number is discussed in Section 2.3of the FS Study report and Section 6 of this document.Approximately 200 cubic yards of contaminated soil above thehealth-based action level of 13 mg/kg established for cadmium arebelieved to be present at the Site. The excavated soil will betreated using stabilization technology and stabilized to theextent that the leachate contaminant concentration, as measuredusing the Toxicity Characteristics Leaching Procedure, meets thestandards specified in the Land Ban Disposal Regulations ofAugust 8, 1988 for F006 nonwastewaters. These treatmentstandards are as follows:

Constituent Treatment StandardCadmium .066 mg/1Total Chromium 5.2 mg/1Lead .51 ng/1Nickel .32 ms/lSilver . 072 - = .. 1

Subsequent to treatment, the excavated soil would be disposedinto a permitted RCRA Subtitle C disposal facility. The treatmentprocess will be conducted either on or off-site. The excavatedarea would be backfilled and graded with clean soil to support avegetative cover. This Alternative represents RCRA's LandfillClean Closure Option as defined in 40 CFR Part 264, Subpart N.These provisions under RCRA provide that post-closure care suchas future corrective action, long-term ground water monitoring orland and deed restrictions are unnecessary.

XX- RATIONALE TOR FRKrZRZHCX

The selected remdedy is preferred over the other Alternativesbecause it provides the highest degree of protectiveness at acost only moderately higher than the other Alternatives. This isthe only Alternative evaluated that would completely eliminateall short and long-term risks to the public health and theenvironment. Furthermore, this is the only Alternative that wouldeliminate the need for post-closure care such as ground watermonitoring, or land and deed use restrictions. Also, this is theonly Alternative evaluated that would eliminate the possibilityfor future corrective action. Finally, this is the onlyAlternative evaluated that provides a permanent solution to thecontaminant problem at the Site.

The remedy selected for implementation at the North Farm subsite isconsistent with CERCLA, as amended by SARA and the NationalContingency Plan; 40 CFR Part 300.

XII. STATUTORY DETERMINATION

Based upon the available information, the selected remedysatisfies the remedy selection requirements under CERCLA, asamended and the National Contingency Plan. The selected remedy atthe Site is protective of public health and the environeinent,satisfied all applicable or relevant and appropriateenvironmental requirements and is cost effective. The PublicHealth Evaluation analysis has determined that treating soilswithin and around the disposal cell which contain cadmiumconcentration levels exceeding a health based action level of the13 mg/kg will adequately protect the public health forunrestricted use.

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GLOSSARY 07 TZRXfl

XRXRa - Applicable or Relevant and Appropriate Requirements refersto to the Federal and State requirements that a remedy selectedby EPA must attain. These requirements may vary from site tosite.

Ground lfat«r - Underground water that fills pores in soils oropening in rocks to the point of saturation. Groundvater is oftenused as a source of drinking water for municipal or domesticveils.Lcachatu - A liquid that has passed through wastes and containssome components of these wastes.

Solidification - A process used to reduce the mobility of liquidcontaminants by mixing it with a material such as cement kiln dustin order to increase the ability to handle the waste and make thesubstance less likely to leach.

COMMUNITY RELATIONS RESPONSIVENESS SUMMARY

MIDWEST MANU7ACTURING/NORTE 7XRM SUPER7UND SITE

NORTH FARM 8UBSITE

OLLOGG, IOWA

This Responsiveness Summary presents the responses of theUnited States Environmental Protection Agency (EPA) to thecomments received during the public comment period conducted aspart of the remedy selection process for the North Farm subsiteof the Midwest Manufacturing/North Farm Superfund site.

INTRODUCTION

On September 8, 1988, EPA announced the availability of itsProposed Plan for the remedial action at the North Farm subsiteof the Midwest Manufacturing/North Farm Superfund site. Noticeof the availability of the proposed plan and the administrativerecord upon which EPA intended to base its remedy selectiondecision was mailed to persons who had previously expressed aninterest in this site and published in the Newton Daily News.This notice also requested the public's comments on the proposedplan and indicated the period during which public commentsreceived by EPA would be considered in the decision-makingprocess. A fact sheet in which the various remedial alternativeswere described, including identification of a preferredalternative, was mailed with the notice.

A public meeting was held in Kellogg, Iowa, on September 21,1988, to receive comments. Copies of the proposed plan and factsheet were made available to persons attending the publicmeeting. A transcript was made of the public meeting. Thattranscript was consulted in preparation of this responsivenesssummary. Copies of the transcript are available with theadministrative records for public review.

PUBLIC COMMENTS

The comments received in on the Proposed Plan and EPA'sresponse to these comments are set forth below.

The EPA received a number of comments relating to the costof the remedial action alternatives considered for the Site.These comments generally fell into the following categories.

1. Is the proposed reaedial action cost-«ffective or arethere other remedial alternatives vhich might provide a acrecost-effactive remedial action at tie site?

CZSCLA requires the EPA select a ccst-effective alterative(net merely that alternative having the lowest cost) vhicr.prttects the human health and the environment, and meets theotr.er requirements of the law. Alternatives 2, 3, and 4 ail r.ave-

an initial captial cost which is lower than that for Alternative5. However, the overall cost of each of these alternatives,including long-term operation and maintenance and ground watermonitoring, is at a level similar to that of Alternative 5.Furthermore, since contaminants would be left on Site, forAlternatives 2, 3 and 4, future corrective action is apossibility which could increase the cost of each alternativeabove that for Alternative 5.

2.. Bom* persons questioned the manner in which the costestimates presented in the proposed plan were calculated, i.e.,vfettt cents are included in the estimates, were costs calculatedon a site-specific basis or using national averages, and what isthe potttntial rang* of the actual cost to implement thealternatives?

Cost projections were prepared on a site-specific basis foreach alternative and are based on capital costs and operation andmaintenance costs. The costs for operation and maintenance arebased on 1988 dollars and projected for a period of 30 years.The costs as presented at the public meeting were for actualcleanup costs and did not include costs for the RemedialInvestigation/Feasibility Study. The actual Site cleanup costsmay range from -30% to +50% variance between the cost estimatespresented at the public meeting and the actual costs which wouldbe incurred.

3. A number of comments were received regarding the issueof who pays for cleanup, including does EPA take intoconsideration who will pay for the remedy in selecting a remedialalternative, can EPA consider the economic impact on theresponsible parties or the community as a whole if EPA seeks tohave the responsible parties fund the response action, and canSuperfund pay for the site cleanup costs without seekingcost recovery from the responsible parties if those partiescannot afford to pay for the remedial costs and can EPA holdparties liable even though their disposal of hazardous wastewas proper, lawful, or specifically authorized by a regulatoryagency at the time?.

While the cost effectiveness of the remedial action is afactor considered in the remedy selection process, except forquestions of fund-balancing, i.e.. in circumstances where theSuperfund does not have sufficient monies available to fund aresponse action, the selection of the remedy does not considerwho will pay for the remedy. Since we are not presently in afund balancing situation, the question of who pays for the remedyis not a deciding factor in the remedy selection process.

Even though the question of who pays for the remedy is not adeciding factor in the remedy selection process, the number andnature cf the consents made on this subject indicates that it isthe key concern of the public. Therefore, some furtherexplanation of EPA's general policies and practices with reaarito use cf the Superfund and cost recovery seer: in :rder. Th =general policy of CERCLA is that the persons resp—.siiie fcr

creation of the problem are responsible for paying for remedy ir.2the problem; CERCLA provides that the persons who generated thewastes, arranged for disposal of the wastes and owned the site atwhich the wastes were disposed of are responsible for the costsof cleaning up the site. Liability for response costs underCERCLA do not depend upon compliance or noncompliance with pastregulatory requirements.

Under CERCLA's special notice procedure, the personsbe±leved to be responsible are given the opportunity to undertakeor finance the response action before the Superfund monies areused to do so. If the responsible parties are unwilling orunable to finance or implement the remedy, ZPA would considerspending Superfund monies to do so. When Superfund monies areused to finance the remedy, it is the policy of EPA to seekrecovery of those response costs from the responsible parties.It is the policy of EPA to seek full recovery of all responsecosts.

4. Will the coats regarding this Site be available to thepublic?

If the EPA undertakes the response action, then the cost ispublic information. If a private party undertakes the action,then ev«n the EPA may not know the costs.

5.. Will this work be up for public bid or has it alreadybeen contracted for?

If the EPA undertakes the work, two mechanisms would beavailable. One mechanism is to have the U.S. Army Corps ofEngineer manage the work. In this case, the Corps of Engineerswould go through their normal bid advertising and contractingprocedures via the Commerce Business Daily (CBD).

If the EPA retains responsibility for the project, then thework would be bid through the CBD or implemented through one ofthe Agency's Superfund contracts. To a certain extent, thosecontractors will try to use local labor and subcontractors ifthey are qualified and available.

«. What it the relationship of EPA with the leva Departmentof Natural Resources with respect to the cleanup of this Site?Did th«i State offer to pa; for the cleanup of the Site?

The Remedial Investigation Report, the Draft FeasibilityStudy, the Proposed Plan Document, and other pertinent documentsused tcs select the preferred remedy have been promptly sharedwith the Iowa Department of Natural Resources; EPA has consultedwith the Department on tha selection of this remedy from ^nor^the alternatives considered, as veil as all other major decisizr.sr.ade with respect to the Site. The Iowa Department of NaturalResources has not been called u;:~. tc assist in funding eitherthe Remedial Investigation or the cleanup, beyond therequirements imposed by CERCLA.

7. Hov vill th3 ccaaunity b* notified of 2?V j aaijczir-the raaecly to be implemented at the Sits? Till the EPA conductpublic aoeting in order to discuss the party or parties who willheld responsible for the cost of the cleanup?

Subsequent to the signing of the Record of Decision, thepublic will be given notice in the Newton Daily Nevs of theremedy selected.

No public meeting will be held to discuss the possibleliability of any party, although any lawsuit which might bebrought would, of course, be a matter of public record.

S. I* the purpose of the trust fund in the Superfundprograa to cleanup hatardous vaste sites/ and what is the sourceof the trust funds adainistered by Superfund?

Superfund was established by Congress as a trust fund underthe Comprehensive Environmental Response, Compensation andLiability Act. Money for Superfund in large part comes fromtaxes paid by companies which produce various chemicalsubstances, from costs (including fines and punitive damages)recovered from responsible parties, and, to a lesser, extent,from Government general revenue. The trust funds are to be usedif an immediate response is required, whether or not there is apossibility of recovery from responsible parties; or where noresponsible party with adequate funds to pay for investigationand cleanup can be found. If Superfund money is used for cleanuthen the EPA is bound by statute to attempt to recover thesemonies from responsible parties. These include waste generatorswaste haulers, landowners, etc.

9. Bow did EPA learn of the existence of this site? Howvas this Site selected for investigation and cleanup from thesites listed on the National Priorities List? Why vas there adelay between the identification of the Site and the initiationof response activities?

This Site came to the attention of EPA through the NationalPollution Discharge Elimination System (NPDES) program.

The National Priorities List ("NPL") establishes a syster. tdetermine the order in which hazardous waste sites listed aredealt with under the Superfund program. Each site isinvestigated and cleaned up in the order established as funds ar.resources become available. EPA undertook its investigation ofthis Site as soon as it was able to do so in light of itsranking, the contamination reported, the hazards involved, andthe funds available for investigation and cleanup.

10. In view of the leaching potential of the colloid.il da;encountered at the Sita, vhat has been discovered concerning thecovenant of the contamination into the surrounding araas? Hov

aany othnr »it»s on th« H7L have haiardous vaatts and soilcharacteristics aiailar to that found at tha North 7ara subsite?

The EPA's investigation has demonstrated that thecontaminants at the Site have not migrated far from the confinesof the disposal cell.

EPA does not have information available which would allow adetermination of how aany sites across the country have colloidalclay as part of the geologic structure.

— 11. If th« hazardous material if r*»ov«d to another site,how can th« public b« a»«ur«d that vuch action vill not craateanothar hazardous va»ta/Suparfund »ita?

First, the excavated soil will be treated usingstabilization technology, which has been identified in the Land-Ban Disposal Regulations dated August 8, 1988, as meeting theBest Demonstrated Available Technology standard for treatingsludges generated from electroplating operations. This willreduce the mobility of the hazardous substances in the wastematerial. Second, the treated waste will be deposited into anEPA-authorized landfill designed to accept hazardous wastes.This landfill will be equipped with double liners and a leachatecollection system. These engineering features in conjunctionwith the stabilization technology give the best assurance knowntoday that the contaminants will not migrate from the Site.

During the Public meeting several persons voiced theirconcern regarding EPA's intentions to remediate the North Far-subsite., These persons felt that requirement of CERCLA, whichrequires; the potential responsible parties (PRPs) to pay thecleanup costs, would place an economic hardship on both the PRPsand the community. Provided below are several of the majorcomments given by members of the community.

8tat« R(ipr«s«ntativ« D«nni» Black:

You know, we just came through a farm credit crisis in Iowa,we are in the midst of a drought. Farm production, needless tosay, isn't what was anticipated. And if, in fact, the cost of theremoval of 70 cubic yards would be $210,000, then I think we cansee another Iowa farmer biting the dust. I'm sure Mr. Brown doesnot have the money and we would see another bankruptcy.

We have in the case of Kellogg, a small community. Probably,I'm sure, the largest employer in the community would be Smith-Jones. And I would question very much whether their balance sheetwould allow them the encumbrance of this amount of money. Onceagain we are dealing with, I'm sure, future unemployment.

Now, those are the facts. These are the things that we haveto deal with. I understand full well that you folks representingEPA have rules that you are responsible for and have to carryout. But it bothers me very much to think that we are looking atsuch a cost for such a small site as was indicated by the lady,one of the smallest, and who pays the bill; the fanner, Smith-Jones? I just don't think it will happen that way.

Mayor Eva Banning:

I worked at this factory for 20 years and I never heardanyone around here comment on any of the —well, that dump siteout there, for years. In fact, I do not think I have ever heardanybody and we have already had this project out there with thelagoon that has cost over $500,000, and I can't see the companydown here being taken right now. And the farmers, just asRepresentative Black said, there is just too many people. Thisis all we have got here in this town. There is nothing else inthis town, only the elevator, and I see no reason why at thistime, nobody has said anything about this water and where itcomes from Bear Creek and down Coon Creek and on into SkunkRiver. I don't know where they are getting off saying all at oncethis here community has to be taken down the drain, because thatis what it is going to amount to.

We have already seen that some of it has went out ofhere, and there will be more if this keeps on. And I just can'tsee the factory and the community saying that this is going to bea very hazardous—it's going to be a hazardous project if itcosts way into the well, it will end up about a milliondollars, I imagine, before it is over with.

And I do not approve of the whole thing at all ur.til thir.- =get in better shape around here and through the country and forthe fanners and everybody. And I don't believe I have ever heardany fanner say anything about this here contamination. SomeoneBay speak up and.say they did, but I haven't never seen any andI've not heard any.

And that is the reason why I think we are biting off morethan we can chew now right here in the community. And the peopleare taxed now to pieces over this other deal. So, I'm afraid thaiif this comes to a standstill and we all have to give up whatwe've made, why, I think it's going to be a bad deal. That's it.

David S&adfton, Pr«sid«nt of Smith-Jon«» Kidw«»t Division

I could probably stay here all night and ask questions, butI would just like to make a couple of comments and clarify acouple of things.

First of all, I agree with Representative Black that we arenot scientist or engineers, so my argument is not what should wedo with that site. But I am doggoned surely convinced I want towalk away knowing who is going to be paying for that.

I think that there has been some misrepresentation ofnumbers, too, and you might be able to clarify this for me. Thenumber going around here tonight is $221,000 to clean up. I donot believe that includes the cost of the remedial investigationand the feasibility study, which numbers were given to me andcould be in the neighborhood of another quarter-million dollars.

Also not included in that cost is Site Number 2, which weare not discussing tonight for some other reasons, but could haveduplicaite or identical costs. So, we are looking at a total cost,if in fact the costs for the remedial investigation andfeasibility study are not included in that for the North Farmsite for in the neighborhood of half million dollars.

I've got some people here, friends and employees, that wouldlike to know who is going to pay for that.

And also, a comment was made by Mr. Shiel earlier thisevening that the party that created the problem should be the onethat would clean it up. as far as I am personally concerned, Iwork with EPA and IDEQ for ten years, on the water treatmentfacility and disposing of the sludge.

W<» did everything that we were supposed to do for both thoseAgencies, And as far as I am concerned, they are the ones thatcreated the sludge pond. They are the ones that suggested hoe wedo it, they approved our plans and we did it according to theirguidelines.

I guess the question I would have is what dc y:u anti-ipBie

the entire bill to be including the feasibility study, theremedieil investigation, over and above the $221,000 we aretalking about?

Gary Young, Pr«sid«nt of GMT Local 74:

Mr. Young provided the Agency with a written comment onbehalf of the Membership of GMP Local 74. Mr. Young expressedconcern that if Smith-Jones, Inc., is forced to pay for the cleanup of the North Farm subsite, the financial drain on the companywould threaten the security of the jobs it provides to thecommunity.

Coaununity Petition

The Agency received a petition signed by approximately 190members; of the community requesting that EPA 's Superfund prograrfinance the clean up of the North Farm subsite. It is assumedthat the concern of those signing the petition, which representapproximately thirty per cent of the community, are alsoconcerned with the economic effect on the community if its majoremployer is compelled to undertake or finance the cleanup.