superfund proposed plan, red panther chemical …may 12, 2019 · red panther facility this...

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U.S. ENVIRONMENTAL PROTECTION AGENCY

SUPERFUND PROPOSED PLAN RED PANTHER CHEMICAL COMPANY SITE

Clarksdale, Coahoma County, Mississippi May 2019 INTRODUCTION

The U.S. Environmental Protection Agency (EPA) seeks public review and comments on the proposed no further action remedy presented in this Proposed Plan for the Red Panther Chemical Company Superfund Site (the Site). The EPA is the lead agency on this Site and is supported by the Mississippi Department of Environmental Quality (MDEQ).

The Site is located at 1201 Normandy Avenue in a mixed commercial-residential area of Clarksdale, Coahoma County, Mississippi. The Site includes, but is not limited to, the 6.5-acre former Red Panther Facility (RPF) property and the 18th Street neighborhood located to the west of the RPF property. A pesticide formulation plant was operated at the RPF from 1949 to 1996. The plant formulated liquid and powdered herbicides, insecticides, and fungicides, including products containing toxaphene, aldrin, arsenic, dieldrin, and dichlorodiphenyltrichloroethane (DDT).

Red Panther Chemical Company Site

COMMUNITY INVOLVEMENT OPPORTUNITIES

Public Comment Period Dates: May 12, 2019 to June 12, 2019

Response to Public Comments The EPA will provide a written summary of

significant comments, and new relevant information submitted during the public comment period and will respond to each issue

in the Record of Decision.

Public Meeting

May 21, 2019 @ 3:00 PM Mississippi State University – Extension

503 E 2nd Street Clarksdale, Mississippi

EPA Contacts

Michael Taylor, Remedial Project Manager (404)562-8762 or [email protected]

O r L a T o n y a S p e n c e r

Community Involvement Coordinator (404) 562-8463 or Toll-free (800) 435-9234

[email protected] _____________

By mail: U.S. EPA Atlanta Federal Center

Superfund Remedial Branch Attention: Michael Taylor

61 Forsyth Street, S.W. Atlanta, Georgia 30303

mailto:%[email protected]

mailto:[email protected]

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Red Panther Facility

This Proposed Plan was developed in compliance with the requirements of Section 117(a) of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and Section 300.430(f)(2) of the National Contingency Plan (NCP). The Proposed Plan presents a summary of soil and groundwater investigations. These documents and other Site documents which provide support for the proposed no further action remedy, including the Action Memorandum, are available in the Administrative Record located in the Information Repository at Carnegie Public Library, 114 Delta Avenue, Clarksdale, MS 38614, and the EPA Region 4 Records Center located at 61 Forsyth Street, S.W., Atlanta, Georgia.

The EPA will accept public comments from May 12, 2019 through June12, 2019, and the EPA will extend the public comment period if requested by the public during that period. Comments may be submitted by mail, email, or by phone (see contact information on the first page). EPA will conduct a public meeting during the public comment period at

or near the Site. The EPA, in consultation with the MDEQ, may modify the no further action remedy presented in this Proposed Plan based on new information or public comments received during the public comment period. Therefore, the public is encouraged to review and comment on the no further action remedy in this Proposed Plan.

SITE BACKGROUND

The Red Panther Chemical Company Site (CERCLIS identification number MSD000272385) is currently managed as one Site by the EPA Superfund Program.

RPF began operations in 1949 as a pesticide production plant. The plant formulated liquid and powdered herbicides, insecticides, and fungicides, including products containing toxaphene, aldrin, arsenic, dieldrin, and DDT. The facility reportedly did not manufacture any active ingredients; instead, it received technical products from basic manufacturers for either further formulation or repackaging.

The Red Panther Chemical Company acquired the RPF in 1979. Previous owners of the facility include Coahoma Chemical Company, Riverside Chemical Company, and MFC Services. Wastewater and solvents containing pesticide and solvent residues were generated from the cleaning of equipment.

Contamination at the RPF is believed to have originated from numerous spills during loading and unloading operations, contaminated wastewater releases, and from spills and leaking underground piping in the tank farm area.

In November 1985, a fire burned down one warehouse on site. Contamination may have migrated off the subject property due to runoff from the firefighting effort. During the investigation and cleanup after the fire, 382 old fiber drums were discovered in the crawlspace below the burned warehouse. Ninety-five of the

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drums contained trace residues of technical grade dieldrin, requiring disposal at a Resource Conservation and Recovery Act (RCRA) Subtitle C hazardous waste facility.

REGULATORY AND ENFORCEMENT HISTORY

In 1980 Red Panther filed for a Resource Conservation and Recovery Act hazardous waste management activity notification and Part A application for storage of wastewater and used solvents. In November 1984 the Mississippi Bureau of Pollution Control (MBPC) granted the facility a RCRA Part B permit to store wastewater and spent solvents at the facility. In 1990 MBPC submitted a Preliminary Assessment Reassessment to EPA. In January 1991 the Mississippi Department of Environmental Quality (MDEQ) prepared a Site Screening Investigation that included the results of soil and groundwater samples from the site. On January 30, 1992 MDEQ submitted a Site Investigation Prioritization to EPA Region 4. MDEQ referred the Site to EPA in 1999, after completion of several site assessments. In 1999 EPA tasked a contractor under the Superfund Technical Assessment and Response Team (START) Contract to conduct soil sampling of the drainage ditch to the east of the property, the former facility leaching field and septic tank. Removal Action On September 4, 2001, EPA entered an Administrative Order on Consent for Removal Action (AOC #1) with 23 parties for the performance of a removal action at the RPF. EPA subsequently issued an Action Memorandum documenting approval of the removal action on September 6, 2001. The AOC#1 parties conducted the time-critical removal action starting on or about November 11, 2002. The AOC #1 identified surface soil constituents of concern for arsenic, toxaphene,

dieldrin and total chlorinated pesticides. The subsurface constituents were identified as arsenic, toxaphene, and dieldrin. The removal work was conducted in two phases. Phase I involved excavation of the site drainage ditch along the property boundary and Route 49 followed by soil disposal of the excavated material. Phase II included the preparation of the work plan and removal of the remaining tasks in the AOC #1 that addressed surface soil removal around the plant operations area and loading dock. Removal actions and demobilization were completed at the RPF on or about July 29, 2005. More than 7,400 tons of contaminated soils were taken offsite to commercial waste treatment and/or disposal facilities as part of the removal action.

For more information, please see the documents in the Administrative Record for the Site located at the

Information Repository and the EPA Region 4 Records Center

The Site Information Repository is located at: Carnegie Public Library

114 Delta Avenue Clarksdale, MS 38614 Phone 662-624-4461

Hours: Monday to Thursday from 9 am to 5:30 pm Friday from 9 am to 5 pm

Saturday & Sunday Closed

AND is also located at: EPA Region 4 Superfund Records Center located

at:

Atlanta Federal Center 61 Forsyth Street SW

Atlanta, Georgia 30303 (800) 435-9234

Hours: Mon-Fri 8:00 am-4:30 pm

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Approximately 117 tons of tank sludges from eight aboveground storage tanks were also removed and properly disposed. A full report for the AOC#1 removal work was submitted to EPA in October 2005 and EPA approved the final report in January 2006.

EPA conducted a Removal Site Evaluation of the nearby 18th Street neighborhood in 2005. A total of 31 composite soil samples were collected within the neighborhood. These samples were analyzed for pesticides, aluminum, arsenic, iron, and other metals.

In 2007 an EPA START contractor conducted a Site Investigation. Groundwater samples were collected from newly installed wells and from the municipal well. The temporary wells detected some elevated levels of pesticides and metals. The municipal wells did not identify any site constituents.

In June of 2010, the START contractor also conducted an Air Deposition Study in the areas surrounding the former facility. In 2010, START identified the presence of surface soil pesticides at certain residences as described in the report. Further assessment of the data determined, that the only contaminant of potential concern (COPC) within the 18th Street neighborhood, warranting additional investigation, was dieldrin. Dieldrin was present at one residential property above its residential soil screening level (SSL) of 340 micrograms per kilogram (ug/kg). There were four residential properties with dieldrin detected at levels above the background level of 52 (ug/kg), but below the EPA screening value.

EPA placed the Site on the National Priority List of sites in 2011.

Remedial Investigation

On September 26, 2016 EPA entered into an additional Administrative Settlement Agreement and Order on Consent for the Focused Remedial Investigation/Feasibility Study (AOC#2) with a

group of Potentially Responsible Parties (PRP group) based on the results of the site investigations conducted from 2005 to 2010. The purpose of the focused Remedial Investigation was to determine the nature and extent of contamination and any threat to the public health, welfare, or environment caused by the release or threatened release of hazardous substances, pollutants or contaminants at or from the Site.

During September 2017 and January 2018, the PRP group conducted the focused RI, with EPA oversight. The main objectives of the focused RI were to:

• Determine if pesticides are present in groundwater beneath the RPF at levels of concern and to assess what further action, if any, is warranted with respect to human health.

• Determine if unacceptable pesticide impacts from historic RPF operations are present at the Industrial Property, the storm sewer drainage ditch, and residential properties, and to assess what further action, if any, is warranted with respect to human health and ecological risk.

The focused RI consisted of the following field activities:

• Three monitoring wells were installed on the RPF property. Continuous soil cores were collected, and analytical soil samples were collected form each boring. The soil samples and groundwater samples collected from the monitoring wells were analyzed for pesticides at an offsite laboratory.

• Soil samples were collected at each of the five residential properties in the 18th Street neighborhood identified during the EPA’s 2010 Removal Assessment Investigation. The soil samples collected from the residential neighborhood were analyzed for pesticides.

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• Soils samples were collected from the Industrial Property and were analyzed for pesticides.

• Sediment samples were collected from the storm sewer drainage ditch outfall and were analyzed for pesticides.

Site Geology

Clarksdale is in the northwestern portion of the State of Mississippi within the Mississippi Delta physiographic province. The stratigraphic units in this part of the state include, in descending order; the Mississippi River alluvium, Cook Mountain Formation, Sparta Sand, Zilpha Clay and Winona Sand, Tallahatta Formation, and the Wilcox Group.

The alluvium directly underlies the property, dips gently to the south, and is exposed at the surface over its entire area of occurrence. The alluvium ranges from less than 50 feet to more than 200 feet thick, with an average thickness of 140 feet. The alluvium generally consists of three layers: a discontinuous silty clay layer, a middle sand layer, and a lower gravel layer.

The Mississippi River Valley alluvial aquifer is a water table aquifer located along the western boundary of Mississippi and underlies the property. Generally, recharge is from the direct infiltration of rainfall into the aquifer, and water moves to the south and towards streams in the area. Some water moves into the underlying Sparta and Cockfield aquifers, which sub crop below the alluvium in the area.

The Cook Mountain Formation acts as a confining unit throughout most of Mississippi; however, near the property the confining layer is not present. The alluvial and underlying Sparta aquifers are indirectly in contact with one another. Regionally, water in the Sparta flows from east to west. Water bearing sands within the Sparta, many 100 feet or more in thickness, are separated by varying thicknesses of clay. The Zilpha and Winona confining layer, consisting primarily of clay,

retards the movement of water from the overlying Sparta Sand into the underlying Meridian Upper Wilcox aquifer.

Conceptual Site Model

There are three potential areas of concern at the site to determine if unacceptable pesticide impacts from historic RPF operations are present at the Industrial Property, the storm sewer drainage ditch, and residential properties.

The 18th Street Neighborhood Soil The Red Panther facility had air emission stacks; therefore, the potential for air deposition within the 18th Street Neighborhood existed during the Site’s operational period.

Storm water runoff is another potential migration pathway for pesticides flowing from the RPF to the 18th Street Neighborhood; however, there exists an elevated street and railroad line which act as a surface water drainage divide between the RPF and the neighborhood.

Groundwater

Sources of potential impacts to groundwater include spills during materials handling operations, contaminated wastewater releases to the ground surface and onsite septic tank, and from spills or leaking underground piping in the tank farm area.

There is currently no completed exposure pathway to potentially impacted groundwater. Municipal water is provided to the City’s residents and the water supply wells in the area are installed to depths of 600 to 1,000 ft. below the ground surface.

Storm Water Ditch

Previous operations at the facility included the discharge of wastewater directly to an offsite ditch. In addition, runoff from the RPF potentially transported contaminants to the storm water ditch.

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The human health exposure pathway, as outlined in Figure 1 and 2 of the Conceptual Site Model, may occur through direct contact with potentially contaminated sediments in the drainage ditch.

Ecological exposure pathways are most likely associated with benthic macroinvertebrates, fish, and insectivorous and piscivorous birds and mammals. The Conceptual Site Model, in Figure 3, outlines the potential receptors. Contaminated sediments in the drainage ditch could also represent a potential ongoing source of contaminants to the Sunflower River.

Fate and Transport

Contaminant presence at the RPF is believed to be a result of operational activities by the Red Panther Chemical Company in the production of crop protection chemicals for the cotton industry from 1949 to 1978. During this period, typical pesticide and herbicide products were formulated and packaged for sale or repackaged for sale. During routine facility operations these chemicals were released to the environment. Results of sampling by EPA and others have shown that contamination occurred on the RPF in shallow onsite soils, the septic tank leach field, and localized storm water drainage ditches flowing to the east and west of the RPF.

The COPCs within the Site, as defined by the RI, are dieldrin within the 18th Street neighborhood and chlorinated pesticides at the vacant industrial parcel and drainage ditch. Dieldrin and other chlorinated pesticides are persistent in the environment as they were designed to adhere to soil particles and plants and do not degrade significantly over time. These qualities made them ideal for providing long-term protection for crops. Dieldrin tends to be more mobile in soil, surface water, and groundwater than the other chlorinated pesticides identified at the Site. Dieldrin was widely used in termiticides including for residential structures at the time the 18th Street neighborhood was constructed and thereafter.

The soil type encountered at the RPF is heavy clay which limits infiltration and potential migration of contaminants. The soil type found at the residential parcels sampled in the 18th Street neighborhood was a loamy topsoil. The soil within the drainage ditch sampling area was a heavy clay like that at the RPF with any topsoil scoured away by discharge from the storm sewer outlet. The soil type identified at the vacant Industrial Property was also a clay.

The heavy clay soils beneath the RPF extend from a few feet below ground surface to 50 to 60 feet in depth, as observed during the installation of the three monitoring wells at the RPF. The clay material has very low permeability which limits infiltration of pesticide contaminants to the aquifer.

Summary of the Focused RI

Groundwater at RPF

Three samples were collected from the three monitoring wells on the RFP property and analyzed for pesticides. These monitoring wells extend to a depth of 60 to 70 feet below ground surface. The groundwater results were less than three times background comparison of the reference well RP-TW-04. The dieldrin background comparison value of 0.15 ug/L was determined in accordance with the statement of work. The well concentration and the results for dieldrin were five times lower than the 10-05 tap water screening level. No further action is recommended for the groundwater.

RPF

Soil samples were collected every five feet during the drilling operations and submitted for analysis pending the groundwater results. Since one of the three monitoring wells, MW-7, indicated an analyte, dieldrin, the soil sample was analyzed for Target Compound List (TCL) pesticides. The soil sample results were compared to the Industrial RSLs. The results were below the Industrial screening level.

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The 18th Street Neighborhood Soil

Soil samples were collected at five residential properties. Each yard was divided into front side and back yard samples. Each sample was a composite soil sample of the area. The soil samples were collected from surface to six inches deep and from six to twelve inches deep. There was also a foundation soil composite sample collected at these same depths. The sample results were analyzed for dieldrin and compared to the 10-05 residential screening level of 340 ug/kg. All samples were below the screening level except for two foundation samples.

No further action is recommended for the residential parcels in the 18th Street Neighborhood. The open yard and ditch samples were below the screening levels and the foundation samples are determined to be related to termiticide use around the foundation.

Storm Water Ditch (Drainage Ditch and Outfall)

Sediment samples were collected from the upper portion of the storm water drainage ditch. There were twelve borings along four transects in relation to the surface flow from the outfall. The samples were extending from 25, 50, 75 and 100 feet downgradient of the outfall. These samples were collected from surface to a depth of six inches below surface. Two composite samples were collected from the borings and analyzed for (TCL) pesticides.

The analytical results indicate all drainage ditch sample results were below human health and refinement-level ecological risk-based criteria. The refinement ecological screening values are considered appropriate for assessment use in the ditch due to the developed (urbanized/industrial) nature of the local environment and the purpose of the ditch (storm water conveyance). Because the screening values were not exceeded, no further action is recommended for the drainage ditch.

Industrial Property

The industrial property (IP) was divided into an upper northern (IP-1) and lower southern half (IP-2). Each IP sample included four soil borings to a depth of twelve inches and then composited. The samples were analyzed for TCL pesticides.

Analytical results were compared to the residential screening levels as well as the ecological screening values in Table 4-2 of the Final RI Report dated October 2018. The initial composite samples demonstrated exceedances of the Ecological screening values for 4,4’-DDD, 4,4’-DDT, dieldrin, endrin and/or endrin ketone. Individual aliquots were then analyzed for TCL pesticides. The concentrations for 4,4’-DDD and 4,4’-DDT, dieldrin, endrin and endrin ketones did not exceed the screening level for the Industrial Relevant Screening Level (RSL). All sample results were well below the Residential RSL.

The TCL pesticide-related ecological risk was examined for bird and mammal exposure to the IP soils. No appreciable risk from pesticides was identified for these receptors.

Toxaphene did not exceed the ecological screening value in the two composite samples. It was present greater than the residential RSL in two individual aliquot samples. None of the samples exceeded the Industrial RSL.

No further action is recommended for the IP.

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Conceptual Site Model

Figure 1

Figure 2

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Figure 3

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SCOPE AND ROLE

Red Panther Facility – Removal Action (AOC#1)

The following actions and sampling investigations addressed the prior site risks.

Starting in November 2002 through July 2005 more than 7,400 tons of contaminated soils were excavated from the Red Panther Facility and disposed offsite. Also, tank sludges from eight above ground storage tanks were also removed from the facility.

Focused Remedial Investigation

In 2017-2018 additional samples were collected from the 18th Street neighborhood, drainage ditch outfall, Industrial Property, RPF Property, and groundwater.

Based on the removal action conducted at the RPF and the results of the human health and ecological risks evaluation conducted as part of the focused RI, there are no unacceptable carcinogenic risk, non-cancer health hazards or ecological risks from exposure to soil, sediment, surface water or groundwater associated with the 18th Street neighborhood, drainage ditch outfall, Industrial Property, or RPF Property.

SUMMARY OF SITE RISKS

A Human Health Risk Assessment and Ecological Risk assessment was completed in June 2018. A summary of the results are as follows:

Drainage Ditch Sediment Samples were collected

Sediment Sample Locations

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Human Health Summary

18th Street Neighborhood Risk characterization was performed at five residential properties located within the neighborhood west of the RPF. These residential surface soil samples were composited at each property from the front, back, and side yards, and from ditches, where they existed. All samples were analyzed for dieldrin. The sample results were compared to EPA health protective screening levels that are based on both carcinogenic and non-carcinogenic endpoints. The resultant risks to residential receptors from the soil data were all less than or within the EPA target risk range. Therefore, no further evaluation is required for the 18th Street Neighborhood.

Industrial Property A quantitative risk assessment was conducted in accordance with the EPA risk assessment guidance and the EPA approved Work Plan utilizing the soil data collected at the Industrial Property during the Focused Remedial Investigation. Two Chemicals of Potential Concern (COPC), dieldrin and toxaphene, were identified based on the COPC screening procedure in the approved Work Plan. The estimated risks and hazards to these COPCs for the identified receptors under the current and future exposure scenarios were less than or within the EPA target risk range. Therefore, no Contaminants of Concern (COCs) were identified and no further evaluation is required for the Industrial Property.

Red Panther Facility A qualitative assessment of potential risk of exposure was conducted for the RPF. Removal actions were conducted at the RPF from 2002 until 2005 to address the presence of pesticides and arsenic. The activities associated with remediation included the excavation of impacted soil and replacement with clean backfill material (no detectable pesticide concentrations) and the

subsequent placement of gravel material on the ground surface.

The current assessment does conclude that the potential risks and hazards for the identified receptors under the current and future exposure scenarios to both surface and subsurface soils are less than or within the EPA target risk range. Therefore, no COCs were identified and no further action is required for the RPF.

Key findings at Industrial Property

Current Land Use

The receptor evaluated under the current land use scenario was the adolescent trespasser. As shown in the CSM (Figure 1), the complete exposure pathways for the adolescent trespasser are incidental ingestion and dermal contact with surface soil and inhalation of particulate matter generated from surface soil.

Adolescent Trespasser

The total estimated cumulative cancer risk for the adolescent trespasser exposed to surface soil at the Industrial Property is 3x10-07, which is less than or within the EPA target risk range. The estimated Hazard Index (HI) is 0.0006, which is significantly less than the EPA criteria value of 1.

Future Land Use

The receptors evaluated under the future land use scenario are the industrial worker, construction worker, and adolescent trespasser and the complete exposure pathways are shown in the future CSM (Figure 2). The complete exposure pathways for the industrial worker and adolescent trespasser are the same as the current land use scenario (ingestion and dermal contact with surface soil and inhalation of particulate matter generated from surface soil). The complete exposure pathways for the construction worker under the future land use scenario are incidental ingestion and dermal contact

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with soils and inhalation of particulate matter generated from soils. All soils (surface and subsurface soils) are generally considered to be available for contact under the construction worker scenario. Consistent with the data collected, pursuant to the approved Work Plan, only surface soil data is available for the Industrial Property. Therefore, the surface soil data was utilized to represent all soils under the construction worker scenario.

Industrial Worker

The soil exposure for the industrial worker in the future land use scenario is the same as the current land use scenario; therefore, the estimated risks and hazards are equivalent under the current and future land use scenarios. The total estimated cumulative cancer risk for the hypothetical industrial worker from exposure to surface soil is 3x10-06, which is within the EPA cancer risk range of 1x10-06 to 1x10-

04. The estimated HI is 0.003, which is significantly less than the EPA criteria value of 1.

Construction Worker

The total estimated cumulative cancer risk for the construction worker under the future land use scenario exposed to all soils is 3x10-07, which is less than the EPA cancer risk range of 1x10-06 to 1x10-

04. The estimated HI is 0.006, which is significantly less than the EPA criteria value of 1.

Adolescent Trespasser

The exposure pathways for the adolescent trespasser under the future land use scenario are identical to the current land use scenario; therefore, the estimated risks and hazards are equivalent under the current and future land use scenarios. The total estimated cumulative cancer risk for the adolescent trespasser exposed to surface soil at the Industrial Property is 3x10-07, which is less than the EPA cancer risk range of 1x10-06 to 1x10-04. The estimated HI is 0.0006, which is significantly less than the EPA criteria value of 1.

Key findings at RPF Much of the RPF areas have been excavated and subsequently backfilled with borrow material. The majority of the RPF surface area not covered by buildings has been replaced with the backfill. Therefore, the potential risks and hazards to receptors exposed to surface soil (industrial worker and adolescent trespassers) are less than or within the EPA target risk range. The excavation and backfill also occurred at depth in areas where contamination was identified during the removal action; the potential risks and hazards to the construction worker exposed to both surface and subsurface soils are also less than or within the EPA target risk range.

Ecological Risk Summary Sediment samples were collected from the upper end of the storm water ditch that had carried site storm runoff. Measured concentrations of pesticides in the sediments were below refinement levels of ecological concern, which are appropriate for assessment use in this type of developed environmental setting. Therefore, it is concluded that sediments in the storm water ditch likely do not pose site related risks to ecological receptors. The surface soil data obtained during the Focused Remedial Investigation was utilized to assess the potential ecological risk from pesticides at the vacant Industrial Property under the current and future industrial land use scenarios. The Contaminants of Potential Ecological Concern (COPECs) were identified based on the identified representative avian and mammalian receptors of concern. The potential for adverse ecological impacts was evaluated using EPA guidance and site-specific information. The uncertainties associated with the various assumptions used in the assessment were identified and their potential impact on the calculated risks discussed. The calculated Hazard Quotients (HQs) were low, utilizing fairly conservative assumptions. The low HQs coupled with the current conditions of the parcel and the anticipated future use of the parcel

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indicated that unacceptable risks from site related pesticides to ecological receptors of concern that might be exposed to the parcel were not present. Therefore, no further evaluation of ecological risk on the Industrial Property was warranted.

Key findings of Ecological Risk Assessment

For the storm water ditch, site-related COPECs were measured at concentrations below refinement screening values, which are appropriate for use in this type of environmental setting, and therefore no risk from sediments to ecological receptors in the ditch is anticipated.

For the industrial parcel, food chain models (FCM) were used to estimate Total Daily Doses (TDDs) of each COPEC to each of three representative receptors (raccoons, woodcocks and screech owls). HQs were calculated as the ratio of the TDD of a COPEC to both the No Observed Adverse Effects Level (NOAEL) and Lowest Observed Adverse Effect Level (LOAEL) Toxicity Reference Value (TRV) for each COPEC and each representative receptor within the Industrial Property exposure area. Consistent with EPA guidance, potential risk was considered present for an HQ exceeding 1.0 (indicating the estimated dose is greater than the TRV). Given the types of receptors and the environmental setting of the Industrial Property, LOAEL-based comparisons were believed to be most appropriate for decision making.

Only the Screech Owl had HQs >1 for the LOAEL endpoint risks, when factoring in expected home ranges of the animals assessed. These are for exposure to 4,4’DDE (HQ of 1.6) and toxaphene (also an HQ of 1.6). Some of the assumptions used in the assessment were conservative. Therefore, given these HQ results and the current conditions of the property and the anticipated future use of the property, it is concluded that unacceptable risks from site related pesticides to ecological receptors of concern that might be exposed were not likely present. Therefore, no further evaluation of

ecological risk on the Industrial Property is warranted.

SUMMARY OF THE PREFERRED ALTERNATIVE

The unacceptable risks to human health and the environment have been adequately addressed by the Removal Actions completed in 2002 through 2005. The Focused RI, including the human health and ecological risk assessments demonstrate that there are no unacceptable carcinogenic risks or other risks from exposure to media at the 18th Street neighborhood, drainage ditch outfall, Industrial Property, or RPF Property.

The EPA in consultation with the State may modify the proposed no further action remedy presented in this Plan based on new information or comments received during the public comment period.

STATE ACCEPTANCE

MDEQ has been actively involved in the development and review of the removal action, the Focused RI and subsequent groundwater sampling at the Site. The State has indicated support of the EPA proposed no further action for this Site.

COMMUNITY ACCEPTANCE

Community acceptance of the proposed no further action remedy will be evaluated after the public comment period ends. Comments received during the public comment period will be addressed and responses will be presented in the Responsiveness Summary which will be included in the Record of Decision (ROD).

COMMUNITY PARTICIPATION

The EPA seeks public review and comments on this Proposed Plan and on EPA’s proposed no further action remedy. The Information Repository and Administrative Record for the Red Panther Chemical Company Site are available at the Carnegie Public Library located at 114 Delta Avenue, Clarksdale, MS 38614. Electronic

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versions of this document are available from [email protected].

The EPA will accept public comments for at least 30 days and the comment period will be extended if requested by the public during the initial public comment period. Comments may be submitted by mail, email, or phone. EPA will provide a written summary of significant comments, and new relevant information submitted during the public comment period and will respond to each issue in the ROD.

EPA will conduct a public meeting during the public comment period at or near the site.

Please direct comments or questions to: Michael Taylor, Remedial Project Manager, at [email protected] (404) 562-8762, or to LaTonya Spencer, Community Involvement Coordinator, at [email protected] (404) 562-8463 or toll free at (800) 435-9234.




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GLOSSARY

Administrative Record (AR): Material documenting EPA's selection of cleanup remedies at Superfund Sites, a copy of which is placed in the Information Repository near the Site.

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA): A federal law (also known as Superfund) passed in 1980 and modified in 1986 by the Superfund Amendment and Reauthorization Act (SARA); the act created a trust fund, to investigate and cleanup abandoned or uncontrolled hazardous waste sites. The law authorizes the federal government to respond directly to releases of hazardous substances that may endanger public health or the environment. EPA is responsible for managing the Superfund.

Conceptual Site Model: A planning tool that organizes information that already is known about a site and identifies the additional information necessary to support decisions that will achieve the goals of the project.

Chemical of Potential Concern (COPCs): Those chemicals that are identified as a potential threat to human health or the environment and are evaluated further in the baseline risk assessment. Contaminants of Concern (COCs): Chemical constituents associated with a Superfund Site that have been released into the environment and pose a risk to human health. Dichlorodiphenyltrichlorethane (DDT):

Feasibility Study (FS): A study of the applicability or practicability of a proposed action or plan conducted after the Remedial Investigation to determine what alternatives or technologies could be applicable to clean up the site-specific COCs.

Groundwater: The supply of fresh water found beneath the Earth’s surface (usually in aquifers) which is often used for drinking water.

Information Repository: A library or other location where documents and data related to a Superfund project are placed to allow public access to the material.

In Situ: In its original place; unmoved unexcavated; remaining at the site or in the subsurface.

Natural Attenuation: The natural attenuation processes include a variety of physical, chemical, or biological processes that, under favorable conditions, act without human intervention to reduce the mass, toxicity, mobility, volume, or concentration of contaminants in soil or groundwater.

National Contingency Plan (NCP): The Federal Regulation that guides the Superfund program. The NCP was revised in February 1990.

National Priorities List (NPL): List of sites under EPA's Superfund program, which investigates and cleans up hazardous sites nationwide. Proposed Plan: A Superfund public participation fact sheet that summarizes the preferred cleanup strategy for a Superfund Site. Record of Decision (ROD): A public document that describes the rationale for the selection of a Superfund remedy. Remedial Investigation (RI): Part one of a two-part investigation conducted to fully assess the nature and extent of the release, or threat of release, of hazardous substances, pollutants, or contaminants, and to identify alternatives for cleanup. The Remedial Investigation gathers the necessary data to support the corresponding Feasibility Study.

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Superfund: The common name for the program operated under the legislative authority of the Comprehensive Environmental Response,

Compensation and Liability Act of 1980 (CERCLA), the federal law that mandates cleanup of abandoned hazardous waste sites.

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USE THIS SPACE TO WRITE YOUR COMMENTS

Your input on the Proposed Plan is important in helping EPA select a remedy for the Site. You may use the space below to write your comments, then fold and mail. A response to your comment will be included in the Responsiveness Summary.

Name ______________________ Address_________________________________________ City ____________ State ______ Zip ________

Michael Taylor, Remedial Project Manager U. S. EPA, Region 4 Superfund Remedial Branch Superfund Division 61 Forsyth St., SW Atlanta, GA 30303

P l a c e S t a m p H e r e

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Red Panther Chemical Company Site PUBLIC COMMENT SHEET

U. S. EPA, Region 4 Superfund Remedial Branch Superfund Division 61 Forsyth St., SW Atlanta, GA 30303

superfund proposed plan, red panther chemical …may 12, 2019 · red panther facility this...

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