United States Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460 March 201 2

Office of Solid Waste and Emergency Response 

# Support Document for the Revised National Priorities List Final Rule – Chemfax, Inc.

# Support Document for the Revised National Priorities List Final Rule Chemfax, Inc. March 2012

Site Assessment and Reme dy Decisions Branch Office of Superfund Remediati on and Technology Innovation Office of Solid Waste and Emergency Response U.S. Environmental Protection Agency Washington, DC 20460Chemfax, Inc. NPL Listing Support Document M arch 2012



## Table of Contents

Table of Contents

.............................................................................................................................. ....... ii

Executive Summary

.............................................................................................................................. ..... iv

Introduction

.............................................................................................................................. ................... v Background of the NPL

.............................................................................................................................. v Development of the NPL ............................................................................................................................ v Hazard Ranking System ............................................................................................................................ v i
Other Mechanisms for Listing ................................................................................................................. vii
Organization of this Document ................................................................................................................ vii
Glossary

............................................................................................................................. ...................... viii

1. List of Commenters and Correspondence ................................................................................... 1

2. Site Description

.............................................................................................................................. 1

3. Summary of Comments ................................................................................................................. 4

3.1 Support for Listing ..................................................................................................................... 4

3.2 Late Comments ........................................................................................................................... 4

3.3 Eligibility of Process Releases .................................................................................................... 5

3.4 Releases Below Regulatory Limits ............................................................................................. 6

3.5 Response Actions/Current Conditions ...................................................................................... 7

3.6 Other Pathways Not Scored ....................................................................................................... 9

3.7 Consideration of Costs .............................................................................................................. 10

3.8 Deletion

.............................................................................................................................. ........ 10

3.9 Other Contaminants Not Scored ............................................................................................. 11

3.10 Source Characterization – Additional Sources ...................................................................... 11

3.11 Effect of Removal on Sources .................................................................................................. 15

3.12 Likelihood of Release: Observed Release ............................................................................... 17 3.12.1 Data Quality and Reliability ............................................................................................... 19 3.12.2 Single Sample ..................................................................................................................... 20 3.12.3 Effect of Removal on Release ............................................................................................. 21 3.12.4 Observed Release: Attribution ............................................................................................ 22

3.13 Site Score

.............................................................................................................................. ...... 23

iiChemfax, Inc. NPL Listing Support Document M arch 2012

iii 4. Conclusion

.............................................................................................................................. ... 26

Attachment A – Pollution Report #5 and Final

Attachment B – OSWER Directive # 9345.1-25, April 4, 1997, Revision to OSWER NPL Policy “The Revised Hazard Ranking System: Evaluating Sites After Waste Removals,” Publication No. 9345.1-03FS, October 1991

Attachment C – Figure illustrating areas excavated as pa rt of the time-critical removal actionChemfax, Inc. NPL Listing Support Document M arch 2012



## Executive Summary

Section 105(a)(8)(B) of CERCLA, as amended by SARA, requires that the EPA prepare a list of national priorities among the known releases or threatened re leases of hazardous substances, pollutants, or contaminants throughout the United States. An origin al National Priorities List (NPL) was promulgated on September 8, 1983 (48 FR 40658). CERCLA requires that the EPA update the list at least annually.

This document provides responses to public comments received on the Chemfax, Inc. site, proposed on June 23, 1993 (58 FR 34018). This site is being added to the NPL based on an evaluation under the EPA’s Hazard Ranking System (HRS) in a final rule published in the Federal Register in March 2012.

ivChemfax, Inc. NPL Listing Support Document M arch 2012



## Introduction

This document explains the rationale for adding the Chemfa x, Inc. site in Gulfport, Mississippi, to the National Priorities List (NPL) of uncontrolled hazardous waste sites and also provides the responses to public comments received on this site. The EPA proposed th is site on June 23, 1993 (58 FR 34018). This site is being added to the NPL based on an evaluation under the Hazard Ranking System (HRS) in a final rule published in the Federal Register in March 2012.


### Background of the NPL

In 1980, Congress enacted the Comprehensive Enviro nmental Response, Compensation, and Liability Act (CERCLA), 42 U.S.C. Sections 9601 et seq . in response to the dangers of uncontrolled hazardous waste sites. CERCLA was amended on October 17, 1986, by the Supe rfund Amendments and Reauthorization Act (SARA), Public Law No. 99-499, stat., 1613 et seq. To implement CERCLA, the EPA promulgated the revised National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300, on July 16, 1982 (47 FR 31180), pursuant to CERCLA Section 105 and Executiv e Order 12316 (46 FR 42237, August 20, 1981). The NCP, further revised by the EPA on September 16, 1985 (50 FR 37624) and November 20, 1985 (50 FR 47912), sets forth guidelines and procedures needed to respond under CERCLA to releases and threatened releases of hazardous substances, pollutants, or contaminants. On Ma rch 8, 1990 (55 FR 8666), th e EPA further revised the NCP in response to SARA.

Section 105(a)(8)(A) of CERCLA, as amended by SARA, requires that the NCP include

criteria for determining priorities among releases or threatened releases throughout the United States for the purpose of taking remedial action and, to the extent practicable, take into account the potential urgency of such action, for the purpose of taking removal action.

Removal action involves cleanup or other actions that ar e taken in response to emergency conditions or on a short-term or temporary basis (CERCLA Section 101). Re medial action is generally long-term in nature and involves response actions that are consistent with a permanent remedy for a release (CERCLA Section 101). Criteria for placing sites on the NPL, which makes them elig ible for remedial actions financed by the Trust Fund established under CERCLA, were included in the HRS. The EPA promulgated the HRS as Appendix A of the NCP (47 FR 31219, July 16, 1982). On December 14, 199 0 (56 FR 51532), the EPA promulgated revisions to the HRS in response to SARA, and established the effect ive date for the HRS revisions as March 15, 1991.

Section 105(a)(8)(B) of CERCLA, as amended, requires that the statutory criteria provided by the HRS be used to prepare a list of national priorities among the known rel eases or threatened releases of hazardous substances, pollutants, or contaminants throughout the United States. Th e list, which is Appendix B of the NCP, is the NPL.

An original NPL of 406 sites was promulgated on Septem ber 8, 1983 (48 FR 40658). At that time, an HRS score of 28.50 was established as the cutoff for listing because it yielded an initial NPL of at least 400 sites, as suggested by CERCLA. The NPL has been expanded several times since then, most recently on September 16, 2011 (76 FR 57662). The Agency also has published a numbe r of proposed rulemakings to add sites to the NPL. The most recent proposal was on September 16, 2011 (76 FR 57702).


### Development of the NPL

The primary purpose of the NPL is stated in the legi slative history of CERCLA (Report of the Committee on Environment and Public Works, Senate Repor t No. 96-848, 96th Cong., 2d Sess. 60 [1980]).

vChemfax, Inc. NPL Listing Support Document M arch 2012

The priority list serves primarily informational purposes, identifying for the States and the public those facilities and sites or other releases which app ear to warrant remedial actions. Inclusion of a facility or site on the list does not in itself reflect a judgment of the activities of its owner or operator, it does not require those persons to un dertake any action, nor does it assign liability to any person. Subsequent government actions will be necessary in order to do so, and these actions will be attended by all appropr iate procedural safeguards.

The NPL, therefore, is primarily an informational and mana gement tool. The identification of a site for the NPL is intended primarily to guide the EPA in determining which sites warrant further investigation to assess the nature and extent of the human health and environmental risks associated with the site and to determine what CERCLAfinanced remedial action(s), if any, may be appropriate. The NPL also serves to notify the public of sites the EPA believes warrant further investigation. Finally, listing a site may, to the extent potentially responsible parties are identifiable at the time of listing, serve as notice to su ch parties that the Agency may initiate CERCLA-financed remedial action.

CERCLA Section 105(a)(8)(B) directs the EPA to list pr iority sites among the known releases or threatened release of hazardous substances, pollutants, or cont aminants, and Section 105(a)(8)(A) directs the EPA to consider certain enumerated and othe r appropriate factors in doing so. Thus, as a matter of policy, the EPA has the discretion not to use CERCLA to respond to certain types of releases. Where other authorities exist, placing sites on the NPL for possible remedial action under CERCL A may not be appropriate. Therefore, the EPA has chosen not to place certain types of sites on the NPL even though CERCLA does not exclude such action. If, however, the Agency later determines that sites not liste d as a matter of policy are not being properly responded to, the Agency may consider placing them on the NPL.


### Hazard Ranking System

The HRS is the principal mechanism the EPA uses to place uncontrolled waste sites on the NPL. It is a numerically based screening system that uses information from initial, limited investigations -- the preliminary assessment and site inspection -- to assess the relative potentia l of sites to pose a threat to human health or the environment. HRS scores, however, do not determine th e sequence in which the EPA funds remedial response actions, because the information collected to develop HRS sco res is not sufficient in itself to determine either the extent of contamination or the appropriate response for a particular site. Moreover, the sites with the highest scores do not necessarily come to the Agency's attention first, so that addressing sites strictly on the basis of ranking would in some cases require stopping work at s ites where it was already underway. Thus, the EPA relies on further, more detailed studies in the remedial inves tigation/feasibility study that typically follows listing.

The HRS uses a structured value analysis approach to scoring sites. This approach assigns numerical values to factors that relate to or indicate risk, based on conditions at the site. The factors are grouped into three categories. Each category has a maximum value. The categories are:

• likelihood that a site has released or has the potential to release hazardous substances into the environment;

• characteristics of the waste (toxicity and waste quantity); and

• people or sensitive environments (targets) affected by the release.

Under the HRS, four pathways can be scored for one or more threats as identified below:

• Ground Water Migration (S gw ) - drinking water

viChemfax, Inc. NPL Listing Support Document M arch 2012

• Surface Water Migration (S sw ) The following threats are evaluated for two separate migration components, overland/flood migration and ground water to surface water. - drinking water - human food chain - sensitive environments

• Soil Exposure (S s ) - resident population - nearby population - sensitive environments

• Air Migration (S a ) - population - sensitive environments

After scores are calculated for one or more pathways acco rding to prescribed guidelines, they are combined using the following root-mean-square equation to determine the overall site score (S), which ranges from 0 to 100 :



### 4 S + S + S + S = S 2

a 2

s 2

sw 2 gw

If all pathway scores are low, the HRS score is low. Howe ver, the HRS score can be relatively high even if only one pathway score is high. This is an important requirement for HRS scoring because some extremely dangerous sites pose threats through only one pathway. For exampl e, buried leaking drums of hazardous substances can contaminate drinking water wells, but -- if the drums ar e buried deep enough and the substances not very volatile -- not surface water or air.


### Other Mechanisms for Listing

There are two mechanisms other than the HRS by whic h sites can be placed on the NPL. The first of these mechanisms, authorized by the NCP at 40 CFR 300.425(c)(2 ), allows each State and Territory to designate one site as its highest priority regardless of score. Th e last mechanism, authorized by the NCP at 40 CFR 300.425(c)(3), allows listing a site if it meets the following three requirements:

• Agency for Toxic Substances and Disease Registry (ATSDR) of the U.S. Public Health Service has issued a health advisory that recommends di ssociation of individuals from the release;

• EPA determines the site poses a significant threat to public health; and

• EPA anticipates it will be more cost-effective to use its remedial authority than to use its emergency removal authority to respond to the site.


### Organization of this Document

The following section contains the EPA responses to site-specific public comments received on the proposal of the Chemfax, Inc. site on June 23, 1993 (58 FR 34018). The site discussion begins with a list of commenters, followed by a site description, a summary of comment s, and Agency responses to each comment. A concluding statement indicates the effect of the comments on the HRS score for the site.

viiChemfax, Inc. NPL Listing Support Document M arch 2012

viii 

### Glossary

The following acronyms and abbreviations are used throughout the text:

Agency U.S. Environmental Protection Agency
ASBOQAM Analytical Support Branch Operations and Quality Assurance Manual
ATSDR Agency for Toxic Substances and Disease Registry
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980, 42 U.S.C. Sections 9601 et seq ., also known as Superfund
CFR Code of Federal Regulations
CLP EPA Contract Laboratory Program
CRQL Contract-Required Quantitation Limit
D.C. Cir U.S. Court of Appeals for the District of Columbia Circuit

DL Detection Limit
EISOPQAM Engineering Support Branch Standard Oper ating Procedures and Quality Assurance Manual

EPA U.S. Environmental Protection Agency, also USEPA
ESD EPA Region 4 Environmental Services Division

FR Federal Register
FS Feasibility study
HAZCLEAN HAZCLEAN Environmental Consultants, Inc.
HRS Hazard Ranking System, Appendix A of the NCP
HWQ Hazardous waste quantity
NCP National Oil and Hazardous Substances Pollutio n Contingency Plan, 40 C.F.R. Part 300

NPL National Priorities List, Appendix B of the NCP
OSWER USEPA’s Office of Solid Waste and Emergency Response
RCRA Resource Conservation and Recovery Act

RI Remedial Investigation
RI/FS Remedial Investigation/Feasibility Study
ROD Record of Decision
SARA Superfund Amendments and Reauthorization Act
SQL Sample Quantitation Limit
SSI Screening Site Inspection
SWPPP Stormwater Pollution Prevention Plan
SVOC Semi-volatile organic compound
VOC Volatile organic compoundChemfax, Inc. NPL Listing Support Document March 2012



## 1. List of Commenters and Correspondence

NPL-U15-3-7-L1-R4 Comment submitted by E. Corbin McGriff, Jr., Ph.D., P.E., HAZCLEAN Environmental Consultants, Inc. on behalf of Chemfax, Inc., with attached comments from Chemfax, Inc., on February 18, 1994.

NPL-U15-3-7-L2-R4 Comment submitted by G.E. Estes, Jr., of Estes and Estes, P.A., Attorneys at Law on behalf of Chemfax, Inc. on June 20, 1994. 

## 2. Site Description

The Chemfax, Inc. site (the Site; the Chemfax site) is composed of contaminant releases from identified sources on the Chemfax, Inc. facility property, and includ es at promulgation two sources identified in the HRS documentation record at proposal and three sources identif ied by Chemfax in its comments. The Chemfax facility is an inactive and abandoned 11-acre facility located in an industrial section of Harrison County just north of Gulfport, Mississippi. The facility manufactured synthetic hydrocarbon resins and waxes from 1955 until 1995. The primary operation was a paraffin blending process in wh ich different grades of paraffin wax were heated to a liquid state, blended and then cooled with water. The c ooling water reportedly did not come into contact with the wax; however, samples collected from a cooling water pond during a 1988 sampling investigation at the facility contained a number of volatile and semi-volatile organic compounds. A 1990 sampling investigation also documented an area of contaminated soil at the facility in which volatile and semi-volatile organic compounds were detected. This area of contaminated soil was locate d a few hundred feet to the north and northwest of the cooling pond.

The Site was proposed to the NPL on June 23, 1993 (58 FR 34018). The cooling water pond was designated as Source 1 and the area of contaminated soil north and northwest of the cooling water pond was designated as Source 2 in the HRS documentation record at proposal. During the 1990 sampling investigation, air samples were collected upwind and downwind of the cooling water pond and an observed release to air was documented based on these samples. Sources and air sample locations are shown in Figure 1 . The hazardous substances found in the observed release samples were benzene, toluene, ethyl benzene, styrene, total xylenes and naphthalene. In addition, the benzene and styrene concentrations were above HRS-designated health-based benchmarks for air, and workers were scored as exposed to these contaminant levels. At some point betw een the June 1993 proposal of the Site and January 1994, Chemfax backfilled the cooling pond with soil. Chemfax submitted comments on the proposed listing in February 1994 and June 1994, afte r the closure of the comment period for the proposal of the Site to the NPL.

As discussed in Reference 3, page 8 of the HRS docum entation record at promulgation, the EPA conducted field work for a Remedial Investigation (RI) and Supplemen tal Ground Water Characteriza tion in January 1995 and March 1999, respectively. The RI report was finalized in January 1996 and the Feasibility Study (FS), which included a baseline risk assessment for human health , was finalized in April 2000. An FS Addendum was completed in June 2000 to address additional issues.

As part of the Feasibility Study, the EPA conducted a site visit in December 1998. As described in Reference 3, page 8 of the HRS documentation record at promulgation, this site visit revealed that the Site was easily accessible to trespassers, many drums were stored on-site a nd the buildings were occupied by transients. The Site was therefore assessed under Superfund’s removal authorit y. Based on the available data, the EPA conducted a time-critical removal at the Chemfax facility from July 1999 to December 1999, as detailed in Attachment A to this support document. The purpose of this removal w as to address imminent threats posed by the Site.

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During the removal, approximately 195 tons of drummed contaminated soils; 52,258 gallons of hazardous waste from above-ground storage tanks; additional contaminated soils from around the tank farms; and a number of buried drums of waste paraffin, wax and oil were removed.

The EPA published a Record of Decision (ROD) in 2002. The ROD, provided as Reference 3 of the HRS documentation record at promulgation, selected remedial actions necessary to provide a more comprehensive and permanent remedy to address the rema ining threats posed by the Site to human health. The major components of the remedy outlined in the ROD include:

• Excavation of contaminated soils and sedim ents from areas exceeding cleanup standards;

• Backfilling of excavated areas with clean soil;

• Off-site disposal of excavated soils and sediments at an approved facility;

• Extraction of contaminated ground water, treatment by physical and/or chemical means and discharge to surface water;

• Continuation of ground water remediati on until performance standards are met;

• Institutional controls to restrict land use during remediation;

• Control of fugitive dust emissions and surface water runoff during remediation.

In 2009, Environmental Management Services, Inc. conduc ted a Site Characterization sampling investigation at the Site on behalf of the Mississippi Department of E nvironmental Quality (MDEQ) and the EPA to determine Site conditions following the removal action. The Site Ch aracterization is provided as Reference 4 of the HRS documentation record at promulgation. This investigation characterized the extent of contaminants in soils and ground water, developed aquifer characterization data and compared the results to those of previous investigations. The results of this investigation re vealed remaining contamination with volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs) documented in soil and shallow ground water at the Site. The Site Characterization also indicated that the deeper, confined aquife rs are currently used for drinking water in the area. As a result of the data obtai ned, the 2002 ROD ground water remedy is being amended from a pump-and-treat option to a monitored natural a ttenuation option. As part of community involvement during development of the ROD amendment, the EPA Region 4 and an MDEQ representative conducted community interviews in the adjacent Turkey Creek community in August 2011 and held a Proposed Plan public meeting in Gulfport in October 2011. The public’s verb al comments are included in the Administrative Record and in the amended ROD, which is currently in review . No written comments were re ceived. EPA is now adding the Site to the NPL to effectuate the ROD so that the remaining contamination can be properly addressed.

The following illustrates a timeline of si gnificant events related to the Site:

• 1955: Chemfax facility operations began

• 1990: Expanded Site Inspection, including Air Sampling Study, conducted

• 1990, November 7: Facility inspected by the Missi ssippi Department of Environmental Quality

• 1993, June 23: Site proposed to NPL

• 1993, August 23: Public comment period on proposal ended

• 1994, January 26: Between June 19 93 and this date, Chemfax conduc ted “abatement” on cooling pond

• 1994, February 18: Chemfax subm itted comments through HAZCLEAN

• 1994, June 20: Chemfax submitted comment s through Estes and Estes, P.A.

• 1995: Chemfax facility operations ended

• 1996: Remedial Investigation completed

• 1999, March: Supplemental Groundwat er Characterization conducted

• 1999, July to December: EPA ti me-critical removal conducted

3Chemfax, Inc. NPL Listing Support Document March 2012

• 2000: Feasibility Study, including baseline risk assessment, completed

• 2002: Record of Decision published

• 2009: Site Characterization investigation conducted

• 2011: Public interviews and public meeting held

• 2012: ROD amendment in review 

## 3. Summary of Comments

On December 6, 2011, the State of Mississippi sent a le tter concurring that the HRS score for the Chemfax site qualifies the Site for NPL listing.

On February 18, 1994, Chemfax along with HAZCLE AN Environmental Consultants, Inc. (HAZCLEAN) submitted comments that opposed the listing of the Chemfax site. On June 20, 1994, Mr. G.E. Estes, Jr. of Estes and Estes, P.A., Attorneys at Law (Mr. Estes), on behalf of Chemfax, submitted comments that opposed the listing of the Chemfax site. In both sets of comments, Ch emfax urged the EPA to remove the Site from further consideration for listing and, in the February 1994 comment s, Chemfax stated that it would greatly appreciate the EPA’s assistance in its goals of “securing control of envi ronmental issues and avoidance of being placed on the NPL.”

Chemfax stated in its June 1994 comments that it ha d discovered “evidence of fundamental errors, serious irregularities and inconsistencies in the scoring” of the Site that should be considered by the EPA. Chemfaxspecifically contended that key data points used in scoring reflected a minor spill and plant processes (thencurrent operating conditions). Chemfax, also in June 1994, asserted that without the use of data obtained from the 1990 sampling during the time the spill occurred and durin g plant processes, further CERCLA-financed remedial action would not be needed. Chemfax did not, however, specify factor values that would be affected in the scoring due to these “fundamental errors, serious irregularities and inconsistencies.”

Chemfax identified in its February 1994 comments th at it had conducted certain “abatement” activities (apparently between August 1993 and Ja nuary 1994), specifically, filling in of the cooling pond. Chemfax asserted that if these activities were reflected in the Site score, the score “would drop below action threshold levels.”


### 3.1 Support for Listing

Comment : The State of Mississippi Department of Environmental Quality commented on December 6, 2011 that, after review of the HRS score and the EPA RI, it concurs th at the Site score qualifies the Site for placement on the NPL.

Response : The Chemfax, Inc. site is being added to the NPL. Listing makes a site eligible for remedial actions under CERCLA, and the Site will be examined to determine what response, if any, is appropriate. Actual funding may not necessarily be undertaken in the precise orde r of HRS scores, however, and upon more detailed investigation may not be necessary at all in some cases. The need for Superfund monies will be determined for remedial activities on a site-by-site basis, taking into account the NPL ranking, State priorities, further site investigation, other response alterna tives and other factors as appropriate. Work will not stop at some sites to begin work at other, higher scoring sites added to the NPL more recently.



### 3.2 Late Comments

Comment : Chemfax submitted two sets of comments, both of wh ich were submitted after the close of the public comment period for the proposed listing, August 23, 1 993 (58 FR 34018). Chemfax acknowledged that it made no

4Chemfax, Inc. NPL Listing Support Document March 2012

submission during the actual comment period, and stated in its February 1994 comments submission that the lateness of the comments was due to an “incomplete unders tanding” of Superfund protocol rather than lack of concern about environmental or health issues. Chemfax st ated in its comment submission on June 20, 1994, that the EPA had not yet responded to its initial submi ssion of comments [in February 1994], and expressed its assumption that the EPA would consider both submissions.

Response : All of Chemfax’s comments on the proposed listing ar e addressed in this support document. Consistent with CERCLA, the Agency has in place an orderly pro cedure for identifying sites where releases of hazardous substances addressed under CERCLA have occurred or may o ccur, placing those sites on the NPL, evaluating the nature and extent of the threat at the site, responding to the threat and deleting sites from the NPL. This process encourages and relies on the participation of the public, including potentially responsible parties. The opportunity for public comment occurs during the 60-day period that typically follows a site's proposal. As identified most recently in the Federal Register (76 FR 57706, September 16, 2011) as well as at the time this site was proposed (58 FR 34018, June 23, 1993), the Agency is not required to consider late comments, and as a matter of policy does not allow late comments to delay a listing decision. However, responses are provided to late comments to the extent practicable. All late comments received on the Ch emfax, Inc. proposed listing (i.e., both of Chemfax’s submissions) were, in fact, considered and are discussed in this response.


### 3.3 Eligibility of Process Releases

Comment : In its June 1994 comment submission, Chemfa x included a number of comments questioning the eligibility of process operations unde r CERCLA. Chemfax stated that:

• Included in the HRS scoring were “three (and argua bly four) data points” that Chemfax asserted were samples that were contaminated by the facility process operations

• A spill of raw material of approximately a liter of feedstock occurred during the air sampling event, the quantity of which was sufficient to affect the air sample results, allegedly invalidating the results

• These data points are not eligible under CERCLA for HRS/NPL purposes — process operations specifically permitted under statutes other than CERCLA are not appropriately addressed under CERCLA, as CERCLA is remedial in nature and w as intended to address uncontrolled or the threat of uncontrolled releases.

Response : Releases from industrial facility process operations are not excluded from the purview of CERCLA. CERCLA applies to facilities generally, not being limited to facilities that are inactive, as can be seen from the statutory language in CERCLA Section 101(9). CERCLA S ection 105(a)(8)(B) directs the EPA to list on the NPL “releases” of hazardous substances, pollutants and contamin ants according to specific criteria set out in CERCLA Section 105(a)(8)(A). This section states that:

Criteria and priorities under this paragraph shall be based upon relative risk or danger to public health or welfare or the environment, in the judgment of the President, taking into account to the extent possible the population at risk, the hazard potential of the hazardous substances at such facilities, the potential for contamination of drinking water supplies, the potential for direct human contact, the potential for destru ction of sensitive ecosystems, the damage to natural resources which may affect the human food chain and which is associated with any release or threatened release, the contaminati on or potential contamination of the ambient air which is associated with the release or threaten ed release, State preparedness to assume State costs and responsibilities and other appropriate factors.

5Chemfax, Inc. NPL Listing Support Document March 2012

Further, CERCLA Section 101(14) defines a “hazardous substance” broadly by authorizing a list of hazardous substances under CERCLA Section 102 a nd by referencing several environmental statutes, such as the Clean Water Act, the Clean Air Act, the Solid Waste Di sposal Act (known and RCRA) and the Toxic Substances Control Act. Courts have found it sufficient for CERCLA regulation that a substance fall within any of the subsections of CERCLA 101(14). All HRS listings, in cluding this one, are based entirely on hazardous substances, pollutants or contaminants.

The definition of “release” in CERCLA Section 101(22) is as follows:

The term “release” means any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment (including the abandonment or discarding of barre ls, containers, and other closed receptacles containing any hazardous substance or pollutant or contaminant), but excludes (A) any release which results in exposure to persons solely with in a workplace, with respect to a claim which such persons may assert against the employer of such persons, (B) emissions from the engine exhaust of a motor vehicle, rolling stock, airc raft, vessel, or pipeline pumping station engine, (C) release of source, byproduct, or special nucl ear material from a nuclear incident. . ., and (D) the normal application of fertilizer.

As shown above, the definition exempt s certain releases from its scope, but it does not exempt process releases. Thus, process releases of hazardous substances ar e eligible for evaluation for HRS purposes.

This comment results in no change in the decision to place the Site on the NPL.


### 3.4 Releases Below Regulatory Limits

Comment : Chemfax made a number of comments about its facility being in compliance with applicable regulations, being within permit limits and not violating reportable quantities, implying that on this basis, the facility should not be addressed under CERCLA. Specifically:

• In February 1994, Chemfax related that its fac ility was inspected by the Mississippi Department of Environmental Quality (MDEQ) on November 7, 1990, and that the inspection revealed no violations of the Mississippi Hazardous Waste Management Regulations.

• Also in its February 1994 comments, Chemfax stated it was receiving assistance from its consultant “in air emissions and Stormwater Pollution Prevention Plan (SWPPP) development.”

• In its June 1994 comments, Chemfax maintained that the processing activities that were occurring at the time the EPA’s samples were being collected were “within the limits of their valid air emissions permit.”

• Also in its June 1994 comments, Chemfax alleged that the spill that occurred during the onsite sampling study was not of a “reportable” quantity.

• Chemfax pointed out in its February 1994 comments that “[l]evels of Toluene, Ethyl Benzene and Xylenes [in the air observed release] were below the benchmark of [the] EPA.”

Response : Releases of hazardous substances within regulator y limits are eligible for evaluation under CERCLA, including in listing of sites on the NPL utilizing the HR S. On July 16, 1982, when responding to public comments on the proposed (original) HRS (47 FR 31188), and agai n on September 8, 1983 (48 FR 40665), the Agency rejected the idea that releases within regulatory limits should not be considered "observed releases" under the HRS. As stated in 1982, "emission or effluent limits do not necessarily represent levels which cause no harm to

6Chemfax, Inc. NPL Listing Support Document March 2012

public health or the environment. These limitations are frequently established on the basis of economic impacts or achievability." In contrast, an observed release represen ts a 100-percent likelihood th at substances can migrate from the site (47 FR 31188, July 16, 1982). Releases (emissi ons or effluent streams) can also be reflected within the other factor category evaluations of the HRS, as discussed below.

That the release may have been Federally permitted or within State regulations also does not preclude listing. CERCLA Section 105(a)(8)(B) directs the EPA to list on the NPL "releases" of hazardous substances, pollutants and contaminants according to specific criteria set out in CERCLA Section 105(a)(8)(A). The definition of "release" in CERCLA Section 101(22) exempts certain releases from its scope, but it does not exempt Federally permitted or State regulated releases; thus, even if discha rges occur within the regulatory limits set by State law or those Federal laws enumerated in CERCLA Section 101(10) , so as to constitute "Federally permitted releases," the discharges may be considered releases under CERCLA a nd, if appropriate under the HRS, placed on the NPL. CERCLA exempts Federally permitted releases only from the notification (Section 103(a)) and cost-recovery (107(j)) sections of the statute; such releases remain subject to the other sections of the statute.

HRS Section 2.3 states that an observed release can be est ablished either by direct observation or by chemical analysis. An observed release by chemical analysis has occurred when a contaminant is measured significantly above background level if some portion of the release is attr ibutable to the site. Even though levels may be lower than regulatory limits, an observed rele ase has nevertheless occurred if th e measured levels are significantly higher than background levels. The HRS does, however, cons ider whether releases are above regulatory limits in evaluating target populations, increasing by a factor of 10 the weight assigned populations exposed to contaminants above the limits.

Of course, the observed release factor alone is not in tended to reflect the hazard presented by the particular release. Instead, the hazard of the site is approximate d by the total HRS score, which incorporates the observed release factors with other factors such as waste characteristics (including waste quantity, toxicity and mobility) and targets. This total HRS score reflects the hazard of th e site relative only to the other sites that have been scored. The actual degree of contamination and its eff ects are more fully determined during the Remedial Investigation that typically follows listing.

By the same rationale, regarding the “minor spill of raw ma terial,” whether or not a quantity of spilled material is sufficient to be reportable under Federal or State regulati ons is not germane to the establishment of an observed release under the HRS.

Regarding Chemfax’s comment that toluene, ethyl ben zene and xylene “were below the benchmark of [the] EPA,” these hazardous substances are three of the six subs tances that are part of the observed release to air established in the HRS documentation record at proposal. A pparently, Chemfax is referring to the fact that two of the other observed release substances are present at levels above HRS-specific health-based benchmark concentrations (cancer risk screening concentrations), but these three named substances are not. However, there is no requirement for contaminants to be present above HRS- specific health-based benchmark concentrations to be scored as part of an observed release. As explained in HRS Section 2.3, an observed release by chemical analysis is demonstrated by analytical evidence of a hazardous substance in the media signi ficantly above the background level, with some portion of the release being attributable to the Site.

This comment results in no change in the decision to place the Site on the NPL.


### 3.5 Response Action s/Current Conditions

Comment : In its February 1994 comments, Chemfax stated that “[i]f the air pathway has been effectively abated,” the score would “drop below action threshold levels.” Ch emfax pointed out that it had backfilled the cooling water pond (Source 1) with soil, and claimed that it had ther eby “eliminated the source of airborne contaminants,”

7Chemfax, Inc. NPL Listing Support Document March 2012

and additionally offered to collect new air sampling data to verify the pond “abatement.” Chemfax also commented that it had drained and backfilled another, separate pond - the holding pond, in accordance with instructions from the Mississippi Department of Natura l Resources, who had declared the liquid in that pond nonhazardous in 1982. Chemfax also stated that it was cons idering bioremediation of the soil “in an effort to remediate the source of the contaminants,” and that its contractor “HAZCLEAN is currently assisting Chemfax in air emissions...” In its June 1994 comments, Chemfax ma intained that aside from the data used for the HRS scoring (which it has addressed in other comments), the remain ing data relating to the Site suggest that no further remedial action or response is needed under Superfund, a nd that health and environmental risks associated with the Site are minimal.

Response : The Chemfax site has been appropriately evaluate d with respect to the response actions and current conditions. The Chemfax response actions and current conditions have been c onsidered, and the Site qualifies for listing based on the finding that further response act ions are called for to address unabated releases.

Removal actions are considered in the site scoring when no unacceptable risk remains at the site. In other words, the HRS scoring will only reflect removal actions if su fficient evidence is provided demonstrating that the removal actions left no unacceptable risk remaining. Att achment B to this support document is OSWER Directive # 9345.1-25, April 4, 1997, Revision to OSWER NPL Policy “The Revised Hazard Ranking System: Evaluating Sites After Waste Removals,” Publication No. 9345.1-03FS, October 1991. The stated purpose of the policy is as follows:

The purpose of this memorandum is to provide greater flexibility to the current National Priorities Listing (NPL) policy for evaluating the impact of completed removals on the Hazard Ranking System (HRS) score (Publication No 9345.1-03FS, October 1991). Flexibility is accomplished by allowing post-Site Inspection (“post-SI”) complete d removals to be considered in HRS scoring.

The policy states in relevant part:

Based on experiences in applying the current N PL policy, the Agency recognizes that some postSI removal actions can substantially address the threat to human health and environment and should be considered up to the time of NPL listing.

The “Implementation” section of the policy states that:

This consideration only applies where the Re gion has documentation (e.g. OSC Removal Site File containing responsible party work plans, sampling data, closeout assessment) that clearly demonstrates there is no remaining release or potential for a release that could cause adverse environmental or human health impacts (e.g., a ll releases have been dealt with such that hazardous substances are not present at potentially harmful levels). Otherwise, the removed waste should be counted in the HRS waste quantity value calculation.

Chemfax stated in its February 1994 comment submittal th rough Mr. Estes that it had backfilled the cooling pond with soil to grade level, apparently between the time of Site proposal and submittal of the comments. As previously discussed in section 2, Site Description, of this support docum ent, a time-critical removal action was conducted at the Chemfax facility from July to Decembe r 1999 to address imminent threats posed by the Site. Attachment A to this support document, “Pollution Re port #5 and Final,” for the time-critical removal action, provides information regarding this action. Attachment C to this support document is a figure illustrating areas excavated as part of this action. These are the response actions to be considered for the Chemfax site.

The 2000 baseline risk assessment (based on remedial i nvestigation data) identified soil contamination and ground water contamination as the risks posed by the Chemfax site. The baseline ri sk assessment took into

8Chemfax, Inc. NPL Listing Support Document March 2012

consideration the removal of waste and the areas of cont aminated soil excavated during the time-critical removal action. No ground water remediati on was conducted during the 1999 time-cr itical removal action, as shown in Attachment A. Attachments A and C indicate that Source 1 was not addressed as part of the time-critical removal action. Further, Chemfax provided no documentation to de monstrate reduction or elimination of risks posed by the Site after either response action. In addition, the re sults of the 2009 Site Characterization demonstrated that both soil and ground wate r contamination are still present at the Site.

Based on this information, the way in which the removal affects the evaluation of sources is described in section 3.11, Effect of Removal on Sources, of this support docume nt. How the removal, in conjunction with current Site conditions, impacts the evaluation of observed release is de tailed in section 3.12.3, Effect of Removal on Release, of this support document.

Regarding Chemfax’s comment about whether further res ponse is needed under Superfund, this is not a listing issue, and this determination is made in a separate ph ase of the Superfund process. As discussed above, such data gathered for the Chemfax site has identif ied risk that remains at the facility.

With respect to the other, separate pond that Chemfax st ated it drained and backfille d - the holding pond, this pond was not considered in the HRS scoring of the Site; its closure is therefore not relevant to the listing decision. Further, the proposed response activities, e.g., the bioremediation Chemfax me ntions, were not implemented, and as such were not considered in HRS scoring of the Site.

This comment results in no change in the decision to place the Site on the NPL.


### 3.6 Other Pathways Not Scored

Comment : In its June 1994 comments, Chemfax commented that the site was scored on a single pathway only.

Response : The HRS does not require scoring all four pathways, if scoring those pathways does not change the listing decision. For some sites, data for scoring a path way are unavailable, and obtaining these data would be time-consuming or costly. In other cases, data for scoring some pathways are available, but will only have a minimal effect on the site score. In still other cases, data on other pathways could substa ntially add to a site score, but would not affect the listing decision. The HRS is a screening model that uses limited resources to determine whether a site should be placed on the NPL for possible Superfund response. A subsequent stage of the Superfund process, the RI, characterizes conditions and h azards at the site more comprehensively.

The HRS is intended to be a "rough list" of prioritized hazardous sites; a "first step in a process--nothing more, nothing less" Eagle Picher Indus. v. EPA , 759 F.2d 922, 932 (D.C. Cir. 1985) (Eagle Picher II). It would be preferred to investigate each possible site completely and thoroughly prior to evaluating them for proposal for NPL, but the need for certainty before action must be reconciled with the need fo r inexpensive, expeditious procedures to identify potentially hazardous sites.

For the Chemfax site, the Baseline Risk Assessment th at was completed in 2000 as part of the EPA RI/FS demonstrated that risks were present at the Site in the fo rm of soil and ground water. In addition, the 2009 Site Characterization documented remaining soil and ground water contamination.

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.

9Chemfax, Inc. NPL Listing Support Document March 2012



### 3.7 Consideration of Costs

Comment : In its June 1994 comment submission, Chemfa x commented that the EPA should consider its comments and remove the site from further NPL consider ation due to the costs involved, both potentially to Chemfax and to taxpayers.

Response : The costs potentially involved in taking action at this site under the Superfund program, such as those raised by the commenter, are not considered in the assess ment of whether a site belongs on the NPL. While discussed in NPL rules in the Federal Register , this discussion is by necessity only of a general nature. The cost discussion clearly states that including a site on the NPL does not cause the EPA necessarily to undertake remedial action, or that any action is required by, nor lia bility for site response costs assigned to, a private party (56 FR 21462, May 9, 1991). The cost discussion then ou tlines the Agency's percepti on of average potential costs per site that may occur in association with events generally following the proposed listing of a site. Any Agency actions that may impose costs on firms are made on a case-by-case basis independent of the listing decision. Also, responsible parties may bear some or all the costs of th e RI/FS and subsequent work, or the costs may be shared by the EPA and the States. Therefore, expenditures cite d by the commenter are associ ated with events that generally follow listing the site, not with the listing itself.

There can be both indirect, contingent co sts and benefits that can be associated with listing a site in that the costs or benefits may only possibly occur contingent on the listing decision. Among the benefits associated with listing a site on the NPL are increased health and environmenta l protection as a result of increased public awareness of potential hazards. Listing sites as national priority sites also may lead to States’ increased support for funding responses at particular sites. As a result of the add itional CERCLA remedies, there will be lower human exposure to high-risk chemicals and higher quality su rface water, ground water, soil and air.

This comment results in no change in the decision to place the Site on the NPL.



### 3.8 Deletion

Comment : In both sets of comments, Chemfax requested that the EPA consider “delisting” the site, using its authority under 40 CFR 300.425(e).

Response : Deletion is a separate stage in th e Superfund process and will be consid ered at the appropriate time, in accordance with the NCP.

The regulations governing deletion of sites from the NPL (40 CFR 300.425(e), as cited by the commenter) specify that:

EPA shall consult with the state on proposed de letions from the NPL prior to developing the notice of intent to delete. In making a determin ation to delete a release from the NPL, EPA shall consider, in consultation with the state, whet her any of the following criteria has been met:

(i) Responsible parties or other persons have implemented all appropriate response actions required; (ii) All appropriate Fund-financed response under CERCLA has been implemented, and no further response action by respons ible parties is appropriate; or (iii) The remedial investigation has shown that the release poses no significant threat to public health or the environment and, therefore, taking of remedial measures is not appropriate.

Deletion is a separate stage in the Superfund process and lo gically occurs after final listing on the NPL. Listing makes a site eligible for remedial action funding under CERCLA. A site is examined during the RI/FS phase of

10Chemfax, Inc. NPL Listing Support Document March 2012

the Superfund process to determine what response action, if any, is appropriate. After a period of public comment, the Agency responds to the threats identified in the RI/FS by issuing a Record of Decision (ROD), which selects the most appropriate remedial alternative. As discussed in section 2, Site Description, of this support document, the RI/FS and the ROD stages of the process have been conduc ted for the Site. The selected remedy is expected to be implemented during the Remedial Design/Remedial Action (RD/RA) phase. As detailed in the criteria listed above, the site may be deleted from the NPL when the Agen cy determines that no further response is appropriate.

This comment results in no change in the decision to place the Site on the NPL.



### 3.9 Other Contaminants Not Scored

Comment : Chemfax, in its June 1994 comment submission, made several comments denying its use of acetone and several other organic compounds at the facility, appearing to have the impression that one of the references to the HRS documentation record at proposal (Reference 14) associates these contaminants with the Chemfax facility. Chemfax observed that, while Reference 14 i ndicated that Chemfax had used acetone as a process material at some past time, neither Chemfax nor any prior facility occupant had actually used acetone. Chemfax further stated that none of the following had ever been u sed as or been a constituent of, any raw material used at the property: acetone, chloroform, tetrachloroethylene, cycl obutanol or tetramethyltetroxane. Chemfax speculated that a former occupant of the adjoining property to the south may at one time have used acetone and/or trichloroethylene.

Response : None of the substances denied as used by Chem fax (acetone, chloroform, tetrachloroethylene, cyclobutanol or tetramethyltetroxane) were used in sc oring the Site, therefore these comments have no impact on the listing decision.

These substances (acetone, chloroform, tetrachloroethylene , cyclobutanol and tetramethyltetroxane) are discussed in one location in Reference 14 of the HRS documentation r ecord at proposal as having been detected in an air sample collected upwind of a former lagoon located on the Chemfax facility. This lagoon was not a scored source at proposal, nor are the substances associated with any of the sources that were scored at proposal or those that are added in the HRS documentation record at promulgation. Neither are any of the substances part of the scored observed release to air. In fact, except for the mention in Reference 14 just cited, none of the substances is mentioned at all in the HRS documentation record either at proposal or at promulgation. Hence, any comments regarding their presence at the facility or possible use by a nother facility are not relevant to the HRS scoring or to the listing. However, if any of these substances is found to be associated with the Chemfax site during further investigation, it will be included in the evalua tion of possible risk and need for response.

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.



### 3.10 Source Characterizati on – Additional Sources

Comment : In its June 1994 comments, Chemfax commented that process-related sources contributed to the documented air release, stating that “process vapors were actually sampled...” Chemfax argued that the four key data points (three air samples and one soil sample) used in the scoring were reflective of process operations, which were operating within the limits of their valid air emissions permit, and a minor spill, as opposed to a release from Source 1, the cooling pond.

• Chemfax specifically commented that the quantity sp illed was “usually contained within the drip pan provided for that purpose,” but was sufficient to be de tected in the air sampling as contributing to the air release.

• Chemfax also stated that, at the time of sampling, an air release was likely occurring from molten resins being pumped through filters in the area.

11Chemfax, Inc. NPL Listing Support Document March 2012

• Chemfax stated that, while not foreseeing the results of the air study, it informed the EPA at the time of sampling of the proximity of the samples to the process area.

• Two other Chemfax representatives w ho were on-site at the time of the sampling study attested to the resin processing and the spill in the proximity of the sampling vessels.

Response : After review of Chemfax’s comments and the HR S documentation record at proposal, three sources have been added to the HRS documentation record at pr omulgation: Source 3, the spill of raw feedstock; Source 4, the drip pan; and Source 5, the molten resin processing operation.

The evaluation of the additional sources begins with the de finition of source, in HRS terms. HRS Section 1.1, Definitions , defines “source” as:

Any area where a hazardous substance has been deposited, stored, disposed, or placed, plus those soils that have become contaminated from migration of a hazardous substance. Sources do not include those volumes of air, ground wate r, surface water, or surface water sediments that have become contaminated by migrati on, except: in the case of either a ground water plume with no identified source or contaminated surface water sediments with no identified source, the plume or contaminated sediments may be considered a source.

The instructions for characterizing sources are pr ovided in HRS Section 2.2 and its subsections.

HRS Section 2.2.1, Identify sources , states, “[f]or the three migration pathways, identify the sources at the site that contain hazardous substances. Identify the migr ation pathway(s) to which each source applies.”

HRS Section 2.2.2, Identify hazardous substances associated with a source , states in relevant part:

For each of the three migration pathways, cons ider those hazardous substances documented in a source (for example, by sampling, labels, manifests, oral or written statements) to be associated with that source when evaluating each pathway.

HRS Section 2.2.3, Identify hazardous substan ces available to a pathway , states:

In evaluating each migration pathway, consider the following hazardous substances available to migrate from the sources at the site to the pathway:

• Air migration.

- Hazardous substances that meet the crit eria for an observed release to the atmosphere.

- All gaseous hazardous substances associated with a source with a gas containment factor value greater than 0 (see section 6.1.2.1.1).

In addition, HRS Section 6.1.2.1.1, Gas containment , and HRS Section 6.2, Waste characteristics , discuss the assignment of containment values for sources and the assign ment of the waste characteristics value for the air migration pathway.

In the HRS documentation record at promulgation, pages 17 through 25 provide the source characterization documentation for the newly added sources.

12Chemfax, Inc. NPL Listing Support Document March 2012

Source 3 — Spill of Raw Feedstock

In its comments, Chemfax referred to the spill as “the liter or so of raw feedstock that sometimes spills when a hose is disconnected that has not been properly purged, or when a valve is not properly closed when the charging process is begun.” Because Chemfax described this quantit y as “sufficient to be detected by the air sampling equipment,” the hazardous substances in the observed re lease can be associated w ith this source. These are benzene, toluene, ethyl benzene, styr ene, total xylenes and naphthalene.

As discussed on pages 17-18 of the HRS documentation reco rd at promulgation, Source 3 is documented to have a containment value greater than zero. It is unknown whether the area of the spill was addressed during the 1999 time-critical removal action. However, because of the nature of a spill, there are no containment features associated with it. The category of HRS Table 6-3, Gas C ontainment Factor Values, to which this corresponds is “All situations except those specifically listed below,” whic h receives a value of 10 and thus contaminants from it are not sufficiently contained to prevent their release to air.

Regarding hazardous waste quantity, the “liter” can be considered a conservative one-time hazardous wastestream quantity. One liter equals approximately 0.264 gallon, a nd next, to obtain the hazardous waste quantity value, HRS Section 6.2, Waste Characteristics, cited above, specifically subsection 6.2.2, Hazardous waste quantity, is applied. This subsection directs the user to evaluate hazardous waste quantity as specified in HRS Section 2.4.2. That section contains detailed instructions for assigning hazardous waste quantity values to each source at a site and Table 2-5, which provides the equations for use in this process. In accordance with HRS Table 2-5, one gallon can be converted to approxima tely 10 pounds. Therefore, 0.264 gall on equals an estimated 2.64 pounds. Using the equation provided in HRS Table 2-5 for Tier B, Hazardous Wastestream Quantity, W/5,000, this yields a source hazardous waste quantity value of 0.000528.

Source 4 — Drip Pan

Chemfax states that spills of raw feedstock are “usually contained within the drip pan provided for that purpose.” However, the use of the word “usually” suggests that feedstock also, at some frequency, spills outside of the drip pan; it is assumed that this has occurred at least once. On th is basis, the spill and the drip pan can be considered to be separate sources. (In effect, however, whether they are separate or combined has no impact on the Site score.) Chemfax’s reference to “sufficient to be detected by the ai r sampling equipment” also applies to the drip pan, and as such, the hazardous substances in the observed release can also be associated with this source. These are benzene, toluene, ethyl benzene, styr ene, total xylenes and naphthalene.

Pages 20-21 of the HRS documentation record at promulgation discusses the assignment of a non-zero containment value for this source. It is unknown whether the area including the drip pan was addressed during the 1999 time-critical removal action. However, because durin g its operational period the drip pan received spills from Chemfax’s operations area, it can be concluded that it was open, without cover, and based on Chemfax’s comments, was located in an open area in the vicinity of the air sampling stations. The category of HRS Table 6- 3, Gas Containment Factor Values, to which this corr esponds is “All situations except those specifically listed below,” which receives a value of 10 and thus contaminants from it are not sufficiently contained to prevent their release to air.

Because hazardous substances are associ ated with the source (with the spilled material, by virtue of Chemfax’s comments that it contributed to the air release), but no info rmation is available to indicate the frequency of spills entering the drip pan, the volume of the pan, or ot her waste quantity information, a source hazardous waste quantity value of unknown but gr eater than zero is assigned.

13Chemfax, Inc. NPL Listing Support Document March 2012

Source 5 — Molten Resin Processing Operation

In its comments above, Chemfax stated the following c oncerning the molten resin processing: “Also, at the time of sampling the process area was in use, and molten resi ns were being pumped through filters in the area.” Chemfax also attributed at least a portion of the observed release to air to this area, and stated:

Molten resins necessarily release considerably more vapor than resins and distillates at ambient temperatures. This, too, would invalidate air samp le data for the purposes of this evaluation.

The hazardous substances present in the observed release can be associated with this source as well. These are benzene, toluene, ethyl benzene, styr ene, total xylenes and naphthalene.

The assignment of a non-zero containment value for this source is discussed on pages 23-24 of the HRS documentation record at promulgation. Because the Site is no longer active, the molten resin processing area is no longer in operation. However, during its operational period, this processing area was located in the open, adjacent to the cooling pond, according to Ch emfax’s comments, and open to release “vapors” to the atmosphere. The category of HRS Table 6-3, Gas Containment Factor Values, to which this corresponds is “All situations except those specifically listed below,” which receives a value of 10 and thus contaminants from it are not sufficiently contained to prevent their release to air.

Although hazardous substances are associated with the source (by virtue of Chemfax’s comments that it contributed to the air release), no information is av ailable concerning hazardous waste quantity; therefore, a source hazardous waste quantity value of unknown but greater than zero is assigned.

Regarding Sources 3, 4 and 5, the newly added sources, Chemfax’s response action addressed only the cooling pond and holding pond, and no other areas. It is not cl ear whether the time-critical removal action specifically addressed the area where these sources were located; however , Attachment A, “Pollution Report #5 and Final,” documents that the Chemfax facility was inactive a nd abandoned as of the time-critical removal action. Notwithstanding, the air release had already occurred and was well documented – this release was clearly associated with Sources 3, 4 and 5 by Chemfax itself in its comments. The removal action did not address the risk already posed or the harm already done by this release. On this basis, Sources 3, 4 and 5 are evaluated in the HRS documentation record at promulgation.

As a result of the three added sources, no new hazar dous substances are added to the scoring. Regarding hazardous waste quantity, as detailed above, the source-sp ecific values are 0.000528, >0 and >0, respectively. Page 10 of the HRS documentation record at proposal shows that the source hazardous waste quantity of Source 1 is 444; as shown in section 3.11, Effect of Removal on Sources, of this support document, that value does not change after consideration of response actions. However, the same section of this support document shows that, after consideration of response actions, the source haza rdous waste quantity of Source 2 is >0. Combining the source hazardous waste quantity values of all five sources yields a value of 444.000528, as compared to the sum of the source hazardous waste quantity values at proposal of 444.02 that is shown on page 21 of the HRS documentation record at proposal. These two values, app lied to HRS Table 2-6 in accordance with HRS Section 6.2, cited above, and HRS Section 2.4.2.2, yield the same pathway hazardous waste quantity value of 100. Hence, there is no impact to the Site score related to the ad dition of these sources. A detailed discussion of the how these sources’ hazardous waste quantity values are incorporated into the Site score is pr ovided in section 3.14, Site Score, of this support document.

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.

14Chemfax, Inc. NPL Listing Support Document March 2012



### 3.11 Effect of Removal on Sources

Comment : Chemfax made a number of comments describing its “abatement” of the cooling pond, as previously mentioned in section 3.6, Response Actions/Current Conditions, of this support docum ent. Chemfax specifically describes having “backfilled the cooling water pond with so il to grade level and . . . seeded with rye grass.”

Response : Neither Chemfax’s response, nor th e time-critical removal action or the operating status of the facility impacts the scoring of the five sources. As discussed in this section and the section above, the response actions on these sources do not completely address the risk posed by the sources prior to the response actions.

To clarify the characterization of the sources, the HRS and the HRS documentation record at proposal provide the following information.

HRS Section 1.1, Definitions , defines “source” as:

Any area where a hazardous substance has been deposited, stored, disposed, or placed, plus those soils that have become contaminated from migration of a hazardous substance. Sources do not include those volumes of air, ground wate r, surface water, or surface water sediments that have become contaminated by migrati on, except: in the case of either a ground water plume with no identified source or contaminated surface water sediments with no identified source, the plume or contaminated sediments may be considered a source.

For Source 1, page 9 of the HRS documentation record at proposal contains the following source characterization information:

Number of the source: 1

Name and description of the source: Cooling pond: The water in this pond is used to cool paraffin wax after it is blended. The water does not come into contact with the wax. This pond has a clay bottom (Ref. 12, p. 11). The type of clay bottom is not documented. The cooling pond (source) is limited to the water placed in the pond.

Regarding Source 1, the cooling pond, the documentati on indicates that Chemfax’s response action did not eliminate all unacceptable risk associated with this source. The description of the response action is that Chemfax filled the pond in to grade with soil, with no statement identifying removal of any of its contents, and seeded the top. Further, as indicated in Attachment A, Pollution Report # 5 and Final, and Attachment C, the figure illustrating the time-critical removal action excavations, the time-critical removal action did not include removal of all contaminants associated with the cooling pond. As discussed in section 3.5, Response Actions/Current Conditions, of this support document, the contaminants remaining in this source may still pose a risk and the source is therefore still considered in the scoring for the Site.

HRS Table 6-3, Gas Containment Factor Values, is used to assign a containment value to Source 1. Because the response description above states that the pond was backf illed to grade, it is estimated that uncontaminated soil cover could be between 1 and 3 feet. Conservatively (i.e., to err on the side of a lower value), it is assumed that the soil could be heavily vegetated, given the inactive and abandoned status of the Site, but the cover soil type is unknown. This combination of conditions, applied to Table 6-3, results in a gas containment value of 7 for the air pathway and thus contaminants from it are not sufficien tly contained to prevent their release to air.

For the ground water pathway, HRS Table 3-2 is used to assign a ground water containment value. Page 9 of the HRS documentation record at proposal states that the cooling pond has a clay bottom of unknown type, but does

15Chemfax, Inc. NPL Listing Support Document March 2012

not specify a liner. Applying this information to the “Surface Impoundment” section of HRS Table 3-2 yields a ground water containment value of 10, and thus contaminants from it are not sufficiently contained to prevent their release to ground water. Since it cannot be conc luded that no unacceptable risk remains, the source hazardous waste quantity value is unchanged.

For Source 2, page 12 of the HRS documentation record at proposal contains the following source characterization information:

Number of the source: 2

Name and description of the source: Contaminated soil: An area of contaminated so il has been delineated on the site. (Ref. 12, Appendix F; 18, Appendix A).

Regarding Source 2, the delineated area of contaminated soil, this area is shown in a figure on page 15 of the HRS documentation record at proposal and on Figure 1 of this support document. There is no indication in Chemfax’s description of its response that any areas were addressed by Chemfax besides the cooling pond. Attachment C, the figure illustrating areas excavated during the time-critical removal action, indicates that only a small portion of the delineated area of contaminated soil designated as Source 2 was excavated. The balance of Source 2 remains at the facility. As discussed in section 3.6, Response Acti ons/Current Conditions, of th is support document, this source is therefore still considered in the scoring for th e Site because not all contam ination associated with the source has been addressed.

HRS Table 6-3, Gas Containment Factor Values, is used to assign a containment value to Source 2. Because the soil is documented to be contaminated at the surface (Ref erence 12 of the HRS documentation record at proposal), the category “All situations except those specifically listed below” applies; this receives an assigned value of 10, and thus contaminants from it are not sufficiently containe d to prevent their release to air. For the ground water pathway (since it has been indicated th at risk to ground water from the Site remains), HRS Table 3-2 is used to assign a ground water containment value. Page 12 of th e HRS documentation record at proposal provides a description of the contaminated soil source, and no indication is provided of a liner, nor would one be expected. This information, applied to the “All Sources” section of HRS Table 3-2, yields a ground water containment value of 10 and thus contaminants from it are not sufficiently contained to prevent their release to ground water.

The hazardous waste quantity value calculated in the HRS documentation record at proposal was based on an area of contaminated soil of approximately 34,596 square feet; this is based on the outlined area on the figure, excluding areas covered by pavement, build ings or other features. According to Attachment C, an estimated 70- by-50 foot area of this was excavated and removed. Howe ver, because the specific location and precision of this latter estimate is unknown, the area of Source 2 is considered as unknown but greater than zero.

This value is assigned as the source hazar dous waste quantity value for Source 2.

Regarding Sources 3, 4 and 5, the newly added sources, the containment values for these three sources are assigned in section 3.10, Source Characterization - Additiona l Sources, of this support document (namely, 10, 10 and 10), and the hazardous waste quantity values are estimate d in the same section (sp ecifically, 0.000528, >0 and >0).

This comment results in no change in the decision to place the Site on the NPL.

16Chemfax, Inc. NPL Listing Support Document March 2012



### 3.12 Likelihood of Release: Observed Release

Comment : Chemfax made a number of comments about the ob served release to air, questioning the quality and reliability of the data, alleging that the release was reliant on a single sample and arguing that without this sample the Site score would not qualify for the NPL.

Response : The observed release is appropriately documente d and supported with reliable analytical data.

The instructions for evaluating likelihood of release that are common to multiple pathways are provided in HRS Section 2.3. HRS Section 2.3, Likelihood of release , specifies that the user is to:

Establish an observed release either by dir ect observation of the release of a hazardous substance into the media being evaluated (for ex ample, surface water) or by chemical analysis of samples appropriate to the pathway being evaluated (see sections 3, 4 and 6). The minimum standard to establish an observed release by ch emical analysis is analytical evidence of a hazardous substance in the media significantly above the background level. Further, some portion of the release must be attributable to the site. Use the criteria in table 2-3 as the standard for determining analytical significance...

Table 2-3 Observed Release Criteria for Chemical analysis

Sample Measurement < Sample Quantitation Limit a

No observed release is established.

Sample Measurement ≥ Sample Quantitation Limit a

An observed release is established as follows:

• If the background concentration is not detected (or is less than the detection limit), an observed release is established when the sample measurement equals or exceeds the sample quantitation limit. a

• If the background concentration equals or exceeds the detection limit, an observed release is established when the sample measurement is 3 times or more above the background concentration.

a If the sample quantitation limit (SQL) cannot be established, determine if there is an observed release as follows:

• If the sample analysis was performed under the EPA Contract Laboratory Program, use the EPA contractrequired quantitation limit (CRQL) in place of the SQL.

• If the sample analysis is not performed under the EPA Contract Laboratory Program, use the detection limit (DL) in place of the SQL

For evaluating an observed release to air, HRS Section 6.1.1 provides the relevant instructions. HRS Section 6.1.1, Observed release , states the following:

Establish an observed release to the atmosphere by demonstrating that the site has released a hazardous substance to the atmosphere. Base this demonstration on either:

17Chemfax, Inc. NPL Listing Support Document March 2012

• Direct observation — a material (for example, particulate matter) that contains one or more hazardous substances has been seen entering the atmosphere directly. When evidence supports the inference of a release of a material that contains one or more hazardous substances by the site to the at mosphere, demonstrated adverse effects accumulated with that release may be used to establish an observed release.

• Chemical analysis — an analysis of air samples indicates that the concentration of ambient hazardous substance(s) has incr eased significantly above the background concentration for the site (see section 2.3). Some portion of the significant increase must be attributable to the site to establish the observed release.

If an observed release can be established, assign an observed release factor value of 550, enter this value in table 6-1, and proceed to section 6.1.3.

Page 17 of the HRS documentation record at proposal pr ovides the following information and concentrations for the background samples.

Sample ID Date Start/Stop Time Sampling Inlet Height above Ground (inches) Reference(s)

CF-AT-01 5-31-90 8:38 am/12:35pm 26.75 39, p. 18 CF-AT-02 5-31-90 8:41am/12:37pm 26 39, p. 18

Sample ID Hazardous Substance Concentration (ppbv) Sample Quantitation Limit (ppbv) Reference(s)

CF-AT-01 Benzene ND 0.48u 14, p. 10; App. B, p. 4 Toluene 0.90 NA 14, p. 10; App. B, p. 4 Ethyl benzene 0.16J NA 14, p. 10; App. B, p. 4 Styrene 0.07J NA 14, p. 10; App. B, p. 4 Total xylenes ND 0.90u 14, p. 10; App. B, p. 4 Naphthalene ND 0.30u 14, p. 10; App. B, p. 5 CF-AT-02 Benzene ND 0.44u 14, p. 10; App. B, p. 6 Toluene ND 0.70u 14, p. 10; App. B, p. 6 Ethyl benzene 0.37 NA 14, p. 10; App. B, p. 6 Styrene ND 0.40u 14, p. 10; App. B, p. 6 Total xylenes ND 1.4u 14, p. 10; App. B, p. 6 Naphthalene 2.40 NA 14, p. 10; App. B, p. 7

Page 18 of the HRS documentation reco rd at proposal provides the following information on the observed release samples:

Sample ID Date Start/Stop Time Sampling Inlet Height above Ground (inches) Reference(s)

CF-AT-03 5-31-90 8:43 am/12:40pm 26.25 39, p. 18 CF-AT-04 5-31-90 8:45am/12:39pm 26 39, p. 18 CF-AT-05 5-31-90 8:52am/12:38pm 27.5 39, p. 18

18Chemfax, Inc. NPL Listing Support Document March 2012

Sample ID Hazardous Substance Concentration (ppbv) Sample Quantitation Limit (ppbv) Reference(s)

CF-AT-03 Benzene 14 0.48u/0.44u 14, p. 10; App. B, p. 2 Toluene 17 0.70u 14, p. 10; App. B, p. 2 Ethyl benzene 44 NA 14, p. 10; App. B, p. 2 Styrene 120 0.40u 14, p. 10; App. B, p. 2 Total xylenes 95 1.4u/0.90u 14, p. 10; App. B, p. 2 Naphthalene 12 0.30u 14, p. 10; App. B, p. 3 CF-AT-04 Benzene 18 0.48u/0.44u 14, p. 10; App. B, p. 1 Toluene 18 0.70u 14, p. 10; App. B, p. 1 Ethyl benzene 22 NA 14, p. 10; App. B, p. 1 Styrene 62 0.40u 14, p. 10; App. B, p. 1 Total xylenes 45 1.4u 14, p. 10; App. B, p. 1 Naphthalene 8.8 0.30u 14, p. 10; App. B, p. 8 CF-AT-05 Toluene 3.6 0.7u 14, p. 10; App. B, p. 9 Ethyl benzene 7.3 NA 14, p. 10; App. B, p. 9 Styrene 23 0.40u 14, p. 10; App. B, p. 9 Total xylenes 17 1.4u/0.9u 14, p. 10; App. B, p. 9

Chemfax’s specific comments are addressed in the following four subsections:

• 3.12.1 Data Quality and Reliability

• 3.12.2 Single Sample

• 3.12.3 Effect of Removal on Release

• 3.12.4 Observed Release: Attribution

3.12.1 Data Quality and Reliability

Comment : Chemfax questioned the quality and reliability of th e air data used in the HRS scoring, as provided in the report titled “Final Report Expanded Site Inspection, Chemfax, Inc., Gulfport, Harrison County, Mississippi, EPA ID No. MSD008154486 Volume II Air Study (TDD No. F4-8911-102, R-586-9-1-44) Revision 0, September 25, 1991,” prepared by NUS Corporation and used as Reference 14 in the HRS package at proposal. Chemfax alleged that the report expresses concerns over the validity of the air data, but does not “address the possibility of process interference in the analysis of data reliability. . .” The “concerns over the validity” of the air data involved substances found in upwind samples but not in downwind samples with respect to the cooling pond. Chemfax also stated that the report mistakenly dismissed those concerns, and that the data were not reproducible, by virtue of being “either erroneous or already abated.”

Response : The observed release is appropriately documented and supported with sufficient data of known and documented quality to meet HRS requirements. The possib ility of process interference was correctly considered.

Regarding the report expressing concern ove r the validity of the data, Chemfax has misinterpreted the statements in Reference 14 of the HRS documentation record at proposal. Reference 14 indicates that several substances were found in background samples but not in downwind samples indicating that these substances might have come from off-site sources. Reference 14 suggests that th is evidence weakens the abilit y for these substances to be used to identify an observed release, not that it casts doubt over the validity of the data in general. These substances include methylene chloride, 1,1,1-trichloroethane, trichloroethene, trans-1,3-dichloropropene,

19Chemfax, Inc. NPL Listing Support Document March 2012

cyclobutanol, methylpentane and ethylidenebicycloheptan e. However, none of these s ubstances was used in the HRS documentation record to identify an observed release. (As can be seen in the above excerpt from the HRS documentation record at proposal, these substances are not included in the background levels or release levels tables.) Reference 14 does not question the validity of identifying an observed release of other substances included in the sampling event, including those substances identified in the HRS documentation record at proposal (benzene, toluene, ethyl benzene, styrene, xylenes and naphthalene).

Regarding the possibility of interference in the data from other possible process sources, in fact it is acknowledged that there are other possible on-site sources, as also stated by Chemfax in its other comments, and three new sources have been added to the HRS documentation record at promul gation in response, as detailed in section 3.10, Source Characterization - Additional Sources, of this support document. Furthermore, the HRS does not require “clean” background levels. The HRS in Section 2. 3, as explained above, requires that to identify an observed release by chemical analysis, there must be a significant increase over background concentrations, not that the background be clean.

Regarding the analytical validity of the data and the a llegation that it is “erroneous,” the following information concerning quality assurance of sampling a nd analysis is provided to demonstrate that the analytical data resulting from the investigation are of known and documented quality.

• Air samples were analyzed by Contract Laboratory Program (CLP) analytical laboratory

• Laboratory analytical data were validated according to EPA Region 4 Environmental Services Division (ESD) laboratory data guidelines by ESD

• Laboratory analytical data sheets are provided as Reference 14, Appendix B

• Laboratory analyses and laboratory quality assurance procedures were in accordance with Analytical Support Branch Operations and Quality Assurance Manual (ASBOQAM), USEPA

• Detailed descriptions of air sampling equipmen t and methodology are provided as Reference 14, Appendix A

• Air Sampling Logbook is provided as Reference 39

• Sample collection, sample preservation and chain-of-custody procedures were in accordance with Engineering Support Branch Standard Opera ting Procedures and Quality Assurance Manual (EISOPQAM), USEPA.

Further, Chemfax has not provided any information or doc umentation to demonstrate that the analyses in question are not valid or reliable.

Regarding the allegation that the data are not reproducible , or are abated, the HRS does not require that a release be reproducible at a different time, only that an observed release has occurred. This issue is addressed in detail in section 3.12.3, Effect of Removal on Release, of this support document.

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.

3.12.2 Single Sample

Comment : Chemfax asserted in its June 1994 comments that the Site score was primarily based on a single sample: CF-AT-03, stating that other samples from the Site, such as surface water and sediment, while contaminated, were not unexpectedly so. It also argued that without sample CF-AT-03 the Site score would not qualify for the NPL.

Response : The observed release to air is appropriately identif ied in accordance with the HRS. The HRS requires that a single observed release has occurred to assign a score based on the presence of an observed release. In fact,

20Chemfax, Inc. NPL Listing Support Document March 2012

three observed release samples were identified. Thus, it is al so not correct that the Site score would not qualify for the NPL without that sample.

As shown above in the excerpts from HRS Sections 2.3 and 6.1.1, the HRS specifies how an observed release is to be established (i.e., by direct observation or chemical an alysis). Therefore, a single release sample is all that is required, if it meets the observed release criteria. In a ddition, HRS Section 6.1.1, as it describes the requirements for chemical analysis, states that “[s]ome portion of the significant increase . . .”, again indicating singularity. However, while only one observed release is required, ther e are actually three samples that meet the criteria for an observed release and document three observed releases (samples CF-AT-03, CF-AT-04 and CF-AT-05) in the HRS documentation record at proposal, as shown above in the excerpts from pages 17 and 18 of that document.

Regarding the commenter’s allegation that without this sa mple the Site score would not qualify for the NPL, this statement is not true. Under these conditions, the rema ining air samples, CF-AT-04 and CF-AT-05, would fulfill the purpose of documenting the observed release, and in addition, CF-AT-04 also contained Level I concentrations of three hazardous substances, thereby satisfying both of the conditions of CF-AT-03 in the scoring. The Level I concentrations and their effect on th e score are discussed further in section 3.14, Site Score, of this support document.

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.

3.12.3 Effect of Removal on Release

Comment : In its February 1994 submission, Chemfax stated th at “violation of the [benzene and styrene] from the pond were primary criteria for ‘listing’,” and the contamin ation has since been eliminated by abating the pond. Chemfax offered to have HAZCLEAN implement a new air sampling program, which would presumably show no release, calling the existing data “not reproduc ible, and therefore. . .already abated.”

Response : The observed release is correctly scored. Neither the pond “abatement” nor the time-critical removal action addressed the materials released prior to the remediation, the exposure to the release that had already occurred, and the risk posed by that release, regardless of whether the release was occurring at other times.

HRS Section 2.3, Likelihood of release , as shown above, states that the likelihood of release “is a measure of the likelihood that a waste has been [emphasis added] or will be released to the environment.” An observed release documents that the “Likelihood of release” is certain and at its maximum as it documents the release has occurred. HRS Section 6.1.1, Observed release , likewise shown above, instructs the scorer to “[e]stablish an observed release to the atmosphere by demonstrating that the site has released [emphasis added] a hazardous substance to the atmosphere.” As shown above in the excerpts from pages 17 and 18 of the HRS documentation record at proposal, the observed release criteria were met by th e sampling conducted on May 31, 1990. Therefore, the likelihood of release factor value for the air migration pathway is based on whether or not a release “has occurred” or its potential to occur, not on whether it is continuing to occur; no timeframe is specified. That the release is no longer occurring does not change that the cont amination migrated via air and posed a risk to anyone exposed to that release.

Even if new air sampling were to be conducted at the Site (as Chemfax offers in its comments), and such sampling did not duplicate the results of the original ai r sampling (i.e., did not show an observed release), this would not refute that the observed release to air did occur previously.

Thus, the removal actions do not result in a change in the Likelihood of release scoring, since the actions did not address the hazardous substances already released or the risk associated with them. Therefore, the Likelihood of release value remains the same (the maximum value of 550) at promulgation as at proposal.

21Chemfax, Inc. NPL Listing Support Document March 2012

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.

3.12.4 Observed Release: Attribution

Comment : Chemfax, in its June 1994 comment submissi on, made a number of comments challenging the association of the benzene in the air re lease to the cooling pond. Chemfax as serted that the evidence showed that the benzene in the air release actually came from process vapors rather than the cooling pond. Chemfax argued that, while the level of benzene in air sample CF-AT-03 was “180 times the permissible level,” the benzene level in the pond water was not correspondingly elevated. Chemfax also claimed that the pond’s effluent waters did not demonstrate sufficiently high benzene levels to support th at the benzene air release came from the pond, nor did the soil samples from around the pond. Chemfax alleged th at air samples not associated with the process area did not reflect “unpermissible” benzene levels in the pond.

Response : The release of the observed release substances, incl uding benzene, has been properly attributed to the Site , in accordance with the HRS.

HRS Section 2.3, Likelihood of release , states, in relevant part:

The minimum standard to establish an observed release by chemical analysis is analytical evidence of a hazardous substance in the medi a significantly above the background level. Further, some portion of the release must be attributable to the site

. [Emphasis added.]

HRS Section 6.1.1, Observed release , directs the user to:

Establish an observed release to the atmosphere by demonstrating that the site has released a hazardous substance to the atmosphere. Base this demonstration on either:

• Chemical analysis — an analysis of air samples indicates that the concentration of ambient hazardous substance(s) has incr eased significantly above the background concentration for the site (see section 2.3). Some portion of the significant increase must be attributable to the site to establish the observed release. [Emphasis added.]

Page 17 of the HRS documentation record at proposal, ex cerpted above, shows that no benzene was detected in either of the two background air samples documented as pa rt of the observed release. The other observed release substances, toluene, ethyl benzene, st yrene, total xylenes and naphthalene, we re largely not detected; a few were detected at very low levels. Page 18 of the HRS documen tation record at proposal, also excerpted above, shows that benzene, along with all of the remaining observed release substances, was detected in both CF-AT-03 and CF-AT-04 as part of the observed release, at levels meeting the “significant increase” criteria. In addition, toluene, ethyl benzene, styrene and total xyle nes also met the “significant increase” criteria in sample CF-AT-05.

In general, attribution is established in two steps. Firs t it is documented that the substances are associated with onsite sources, and second it is established that no other o ff-site sources caused the significant increase in hazardous substance concentrations.

For the first step, page 9 of the HRS documentation record at proposal shows that all of the observed release substances were found in Source 1 samples and therefore ar e associated with that source. Page 12 of the HRS documentation record at proposal shows that the observe d release substances naphthalene, styrene, xylenes and ethyl benzene were found in samples from and are associ ated with Source 2. For th e second step, the commenter did not identify any off-site sources as possible origins of the observed rel ease contaminants. In addition, that no concentrations or very low concentrations of the observe d release contaminants were present in either of the two

22Chemfax, Inc. NPL Listing Support Document March 2012

background samples demonstrates that the “significant in creases” in the release samples did not come from some other nearby (off-site) source.

Page 20 of the HRS documentation record at proposal states the following:

. . . The final report for the Site Screening Inspection (SSI) indicates that Chemfax used various solvents in its processing, these include: alkylated xylene and naphthalene (Ref. 18, pp. 7, 18). [Emphasis added.]

This passage supports that the substances found in the observed release, including benzene, are associated with processing operations at the facility. In addition, since the spill of raw feedstock, the drip pan and the molten resin processing operations have been added as sources, as detailed in section 3.10, Source Characterization - Additional Sources, of this support document, whether the benzene came from process are as or the pond, or some combination of these, is not inconsistent with the identi fication of an observed release. Chemfax stated that the observed release was contributed to by the process area of the Site. The locations of the observed release samples, i.e., adjacent to the cooling pond and the operational ar eas including the drip pan and the molten resin processing area, (see Figure 1 of this support document) also suppor ts that the significant incr ease in the observed release substances is attributable to the S ite, thus fulfilling the HRS requirement.

This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.



### 3.13 Site Score

Comment : Chemfax challenged the NPL-qualifying site score. In Exhibit A to its February 1994 comments, Chemfax alleged that if the air pathway had been eff ectively addressed [presumably by its pond “abatement”], “then the HRS Site Score would drop below action thr eshold levels” [presumably below the 28.50 score that qualifies a site for listing].

Response : The air pathway score and the HRS Site score are appropriately calculated in accordance with the HRS for the Chemfax site including when taking the removal actions into account.

Likelihood of Release

For Likelihood of release, as detailed in section 3.12.3, Effect of Removal on Release, Chemfax’s response action did not remove or otherwise remedy the release that had already occurred. That the release may no longer be occurring does not change that the contamination migrated vi a air, and that the released substances have not been addressed. Thus, the Likelihood of release value remains the same as in the HRS documentation record at proposal, 550, as explained above in section 3.12, Like lihood of Release: Observed Release, of this support document.

Waste Characteristics

The HRS waste characteristics category value is determined based on the instructions in HRS Section 6.2 and its subsections.

HRS Section 6.2, Waste characteristics , states to:

Evaluate the waste characteristics factor cate gory based on two factors: toxicity/mobility and hazardous waste quantity. Evaluate only those hazardous substances available to migrate from the sources at the site to the atmosphe re. Such hazardous substances include:

23Chemfax, Inc. NPL Listing Support Document March 2012

• Hazardous substances that meet the criteria for an observed release to the atmosphere.

• All gaseous hazardous substances associated with a source that has a gas containment factor value greater than 0. . .

• All particulate hazardous substances associat ed with a source that has a particulate containment factor value greater than 0. . .

* * * HRS Section 6.2.1.3, Calculation of toxicity/mobility factor value , specifies that the user is to:

Assign each hazardous substance a toxicity/mobility factor value from table 6-13, based on the values assigned to the hazardous substance for the toxicity and mobility factors. Use the hazardous substance with the highest toxicity/m obility factor value to assign the value to the toxicity/mobility factor for the air migration pathway. Enter this value in table 6-1.

* * * HRS Section 6.2.2, Hazardous waste quantity , states to:

Assign a hazardous waste quantity factor value for the air migration pathway as specified in section 2.4.2. Enter this value in table 6-1.

HRS Section 6.2.3, Calculation of waste charact eristics factor category value , specifies to:

Multiply the toxicity/mobility factor value and the hazardous waste quantity factor value, subject to a maximum product of 1 x 10 8 . Based on this product, assign a value from table 2-7 (section 2.4.3.1) to the waste characteristics fact or category. Enter this value in table 6-1.

Page 21 of the HRS documentation record at proposal explains how the HRS was applied at this site; it states the following:

Benzene, toluene, ethyl benzen e, styrene and have been assigned mobility values of 1.0 because they were found in observe release to air. Naphthalene was assigned a gas and particulate mobility value of 1 and 0.02 respectively b ecause naphthalene was also found in observed release to air (Ref. 1. Section 6.2.1.2). .Mercury was detected in the cooling pond, but not in observe release to air (Ref. 12, App.F, p.1; 42).

Toxicity/Mobility Factor Value: 2000

For Waste Characteristics, in accordan ce with HRS Section 6.2 shown above, all of the contaminants associated with Sources 1 and 2 remain eligible for scoring becau se these sources have non-zero gas containment (actually each source has a value of 10), as detailed in section 3. 11, Effect of Removal on Sources, of this support document and in the HRS documentation record at proposal . Because the observed releases identified in the HRS documentation record at proposal remain valid, as detaile d in section 3.12.3, Effect of Removal on Release, of this support document, the hazardous substances found in the release are also eligible to be scored for toxicity/mobility. All of the hazardous substances found in the observed release are assigned the maximum mobility value of 1, as directed by HRS Section 6.2.1.2, Mobility . Mercury, which was associated with the cooling pond (Source 1) by sampling, receives the maximum overall toxicity/mobility value of 2,000 among all the eligible hazardous substances. There were no comments received in opposition to the assignment of toxicity, mobility or combined toxicity/mobility values provided in the HRS documentation record at proposal.

24Chemfax, Inc. NPL Listing Support Document March 2012

Regarding hazardous waste quantity, because Sources 1 and 2 remain eligible for scoring, their hazardous waste quantity values as calculated in section 3.11, Effect of Re moval on Sources, of this support document are used in scoring. These values are 444 and >0, respectively. As calculated in section 3.10, Source Characterization - Additional Sources, of this support document, the sour ce hazardous waste quantity values for the newly added sources, Sources 3, 4 and 5, are 0.000528, >0 and >0, r espectively. Combining these five source hazardous waste quantity values results in a value of 444.000528. Applying th is value to HRS Table 2-6, this results in the same pathway hazardous waste quantity value of 100 as in the HRS documentation record at proposal.

Even if the sum of the source HWQ values were less th an 100, the pathway hazardous waste quantity value would remain 100, as required in HRS Section 2.4.2.2, which sp ecifies that, for a migration pathway, if the hazardous constituent quantity is not adequately de termined for one or more sources, and if any target for that pathway is subject to Level I or Level II concentrations, assign either the value from Table 2-6 or a value of 100, whichever is greater, as the hazardous waste quantity factor value for the pathway. As discussed in the subsection titled Targets immediately below, targets for the air pathway are subject to Level I concentrations; the hazardous waste quantity factor value for the pathway is 100. In combinati on with the toxicity/mobility value for mercury of 2,000, using HRS Table 2-7, this yields a Waste Characteristics factor category value of 18 , which is the same as was assigned in the HRS documentation record at proposal.

Targets

The HRS documentation record at proposal contained documentation of actual contamination at a target location (on-site) for the air pathway. Because an observed release was appropriately established (as demonstrated in section 3.12, Likelihood of Release: Observed Release, of this support document), and workers were exposed at contaminant levels above health-based benchmarks, the score for actual contamination (Level I) remains. The only Targets categories assigned non-zero values in the HR S documentation record at proposal were as follows:

Nearest Individual 50 Level I Population 590 Potential Population 12

As such, the values for nearest individual (50, based on presence of Level I targets), and Level I population, 590, remain the same as in the HRS documentation record at proposal. The population subject to potential contamination was not scored in the HRS documentation record at promulgation since the Level I population score is sufficient in magnitude to achieve a site score sufficient for NPL listing. The resulting value for Targets is 640 at promulgation.

Pathway Score

From HRS Section 6.4, Calculation of air migration pathway score :

Multiply the values for likelihood of release, wast e characteristics, and targets, and round the product to the nearest integer. Then divide by 82,500. Assign the resulting value, subject to a maximum value of 100, as the air migration pathway score (S a ).

(Likelihood of Release (550) x Waste Characteristics (18) x Targets (640)) / 82,500 = 76.80

Site Score

In HRS Section 2.1.1, Calculation of HRS site score , the following is specified:

25Chemfax, Inc. NPL Listing Support Document March 2012

26 Scores are first calculated for the individual pa thways as specified in sections 2 through 7 and then are combined for the site using the follo wing root-mean-square equation to determine the overall HRS site score, which ranges from 0 to 100:



### 4 S + S + S + S = S 2

a 2

s 2

sw 2 gw

Since the Air Pathway is the only pathway scored for th e Chemfax site, the resultant Site score is 38.40.

This comment results in no change in the decision to place the Site on the NPL.



### 4. Conclusion

The original HRS score for this Site was 39.12. Based on the above responses to comments, at promulgation the score is 38.40. The final scores for the Chemfax site are:

Ground Water: Not Scored Surface Water: Not Scored Soil Exposure: Not Scored Air Pathway: 76.80 HRS Score: 38.40

### ATTACHMENT A

Pollution Report #S and FinalII**~=_.,~_...** .- ..**!t1c~ =~**  

# .'.0

.. ----..:-= 

# 2 10 0011

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY POLLUTION REPORT #5 AND FINAL

Date: December 27, 1999

From: Roberta M. Runge. On-St:ene Coordinator USEPA Region IV

Subject: Chemfax, Harrison County, Gulfport, Miss.

To: Doug Lair, Branch Chief USCG Gulf Coast Strike Team Mississippi Department of Environmental Quality**r~----------** 

# __ POLREP No.: POLREP five (5) and FINAL 

### 10066098 

## "'

I. 

### GENERAL SITE INFORMATION

1111/11

# ~1I1**"IIIII~I** 11111

# ~~ 111/1 11/11

# ~/IIIII Site name: Chemfax Inc. Site address: ] 0045 Three Rivers Road City, county, state: Gulfport. HalTison County, Miss. CERCUS No.: 04JF Site rD:**MSD()O~ 1544~6**  

### Response Authority: CERCLA NPL Status: Not listed Incident Category: Time critical State Notification: MDEQ has been working with EPA for several years on remedial investigations concerning this site. Action Memorandum: Completed Start Date: July 12, 19l)l) Completion Date: Nov 24, 1':)99

BACKGROUND rNFORMATION



### A . Type of Facility

This Site is ap inactive and abandoned facility whit:h manufactured synthetit: hydrot:arbon resins and waxes from 1955 until 1995. The primary operation at the Site was a paraffin blending
process that involved the heating, blending, and cooling of different grades of paraffin wax. The Site currently consists of several buildings in disrepair, numerous above ground storag.e tanks and approximately 1000 drums of spent solvents, waste products, and manufacturing bi-products.



### B. Site Description

## 2 10 

## 0012

The Site is located on approximately 

### 11 acres of property zoned for industrial usage. It is situated approximately 

### 700 feet to the south of Bernard Bayou in a relatively flat area having a 2% slope over most of the property. All surface water drainage flows into a storm drain system located on the east side of the property. and inouted directly to the Bayou.

The area surrounding the Site is predominately industrial and l,;ommen::ial. The commercial businesses consist of various discount centers, factory outlets and gas stutions. The Site is within 0.25 miles of Interstate 10 which is the major traffic route across southern Mississippi.

The Site has unrestricted access, acts as a home for numerous vagrants and has large. quantities of highly flammable liquids stored in drums and tanks. A fire in one of the abandoned buildings on the Site would quickly spread to the tlammable liquids and could lead to un explosion. Additionally, the concentration of hazardous substances in the soil pose a significant health threat to persons entering the Site.



### Ill. RESPONSE INFORMATION

A. Actions Taken

A Removal Site Evaluation which involved the inventory, mapping and sampling of the tanks, drums and waste piles on the Site was conducted on January 

### 26- 27 •. 

### 1999. Eleven surface soil samples, two sediment samples and one water sample were collected, as well as samples from eighteen drums and five tanks. All samples were analyzed for volatile organic compounds. sem-volatile organic compounds, total cyanides, and target analyre list (TAL) metals. The contaminants on the Site were found to include benzene, toluene, ethylbenzene, xylene. styrene and methylene chloride as well as 

### a wide variety of polynuclear aromatic hydrocarbons, including anthrul.:ene, fluorene, methylnaphthalene, phenanthrene and pyrene. TAL metals on Site include arsenic and clu·omium.

Analytical data from the 1996 Remedial Investigation sumpling of monitoring wells indicate that benzene concentrations in ground water beneath the Sire exceed the Maximum Contaminant Level for drinking water.

On July 12, 1999 

### a time critical removal action was initiated. The main objective of the action was to remove all contaminated drummed soils (llJ4.lN tons) stockpiled by the**t~ll.:ility** owner, remove aU asbestos**(~O** cubic yards) from the process lines/boilers/buildings. and remove all hazardous waste 

### (0001, F003, F005) from above ground storage tanks (52,25X gallons). By taking these actions, the Emergency Response and Removal Branch, negated the immediate threat of exposure to hazardous wastes, improperly stored at the Site, to the 

### 101.:411 residents and the surrounding environment. All materials were transported to CERCLA approved off site dispos:lI facilities.

### IV 

# 2 10 0013

All above ground storage tanks were demolished and deconti.lIl1inated on Site. FoUowing completion of the tank demolition, the secondary containment areas around the tank farms were excavated to access buried process lines and l:omaminated soils. In the process of excavating the secondary containment areas, several facility dump sites were located including a drum disposal

area. The drum') contained waste paraffm and waxes as well as waste oils. In order to ensure that all dump sites had been located, an elet.:tromagnetic survey of the Site was conducted prior to demobilization of heavy equipment. No additional dump sites were located as a result of the
survey. All waste streatn<; were characterized and transported to CERCLA approved disposal facilities.

On November 16, 1999, 

### a Site walk through was conducted with personnel from the EPA remedial branch to ensure a smooth transition from removal activities to remedial i.H.:tivities. On the same date, the OSC and Community Relations Coordinator (CRC) provided 

### an invitation to local media representatives to view the progress on the Site and advise them of the transition 

### from

a removal action to a remedial action. Two television interviews and one new paper interview

were conducted at the Site. The OSC and CRC also participated in a well attended public meeting, the evening of the 16 th

, at the request of the remedial branch.

CONTRACTOR INFORMATION AND ESTIMATED COSTS

A. Contractor Information

CONTRACTOR DO NUMBER POP START/POP END**DOAMOU~T**

CMC 4006-F4-033 July 12, 1999 Nov 24, 1999 $ 

### I,OOO,()()O.OO

B. Estimated Costs

Extramural:

ERCS/ERRS $ X74, ';>46.31 START/USCG $ I 25,627.59

Total Estimated Extramural Costs: $ 1,000,573.90

Intramural:'

.

EPA Direct Costs 

### $ 17,500.00 EPA Indirect Costs 

### $ 34,000.00

TOT AL SITE COSTS $1,052,073.9()

# 2 '10 

# 001'4

Costs shown are not fmal. They are based on information currently available.



### V. DISPOSITION OF WASTES

Waste stream # Waste code Description Approx. Vol. Handling Disposal /Quantity Method Locatioll

#1 Non-haz. Soil**194J~9** tons Dump trul:k Pecan Grove SLF
#2 Asbestos 80 cubic yards Lined Roll-offs Pecilll GroveSLFasbestos l:ell



### #3 0001 F003 F005 PAH 52.258 gal. Vae.Trucks M&M/ Giant Cement



### #4 Non-haz. Waste solvents & resins 131 drums Lined RoU-offs Clean Management/ Omni S.E.
#5 Non-haz. Non-PCB
waste oil 3,000 gal. Vae. TruCks Clean Managementl International Petroleum

VI. ROSTER OF AGENCIES ASSISTING IN REMOVAL

Agency Contact Phone# Role

EPA Brian Farrier 404-562-8lJ52 RPM EPA Greg Luetseher 404()-562-Y677 Site Attorney

EPA Paula Walraven 404-562-8858 USCGIAA Implementation

EPA Annette Hill 404-562-8060 Cost Recoverv EPA Jeff Napier 404- 562 -8386 Contract Officer
EPA Houston Gillian 404-562-8591 Non-haz. Disposal EPA Jack Coward 404-562-8591 Haz. Disposal
EPA Rick Glaze 404-562-9554 Criminal Investigations USCG Marty Danuels 334-441-6706 USCG FOSe

# 2 10 0015

MDEQ Ken Whitten 601-Y61-5306 State Haz. Waste Division MDEQ Jerry Banks 601-961-5306 State Haz. Waste Division Harrison Co. Schools Henry Arledge 228-53Y-6500 Property Trustee

City of Gulfport William Small 228-868-5810 Mayor MDOT Judy Singletary 601-359-7573 Railroad Liaison



### ,.

### ATTACHMENT B

OSWER Directive #9345.1-25

April 4, 1997

### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460

- 

### APR'" 11 !997 .. '

OFF1CS OF SOLID WASTE AND EMERGENCY RESPCSSE

_ 

### OSWER Directive #**9345.1~25 ~jE:\I.QRANDllM** 
Revision to 

### OSWER ?,\PL Policy 

### "The Rc\ ised Hazard Ranking S)stcm: halu3ting' 

### Sl'BJECT: 

### Sites A fier Waste Removals" 

### Publication No. 

### 9345.I-03FS, October 1991­

SlCphen 

### D. Luftig.

# Direclo;ST~ 

# Lft:v FRO\I: 

### Office of 

### Emergency and 

### Remedial Response 

# 0

Director. Oftice of 

### Site Remediation and 

### Restoration TO: 

### Region I Director, Emergency and 

### Remedial Response Division

Region II 

### Director, Hazardous Waste Management Division

Regions 

### III, IX Director, Waste Management Division

Region 

### IV

. -, '\' ,::,. ," I:' ' ' 

### Director, Superfund Division

.. .

Regions 

### V, VI, VII

.. . :.:**~',,< ;'~'~'"'\'(>'-.** **:;-~",'** -,.', 

### Assistant Regional Administrator,

_.. '", ':: :.; "r r;:',': '::::-. :-:,,:',' 

### Office of Ecosystems Protection and Remediation. " • "

... _. .1 

### .**~~** '

..**~'" ~;~~~:~**  

### . .

• . - .,



### Region 

### VIII

.... ":

. ':'.

## '~"~**:';;~~',::~:~'~:~,,'.:'~;-"~~** " Director, Environmental Cleanup Office-.-**.".~~,,:;}: .\',,7~r.**  "af Sit,:> Ex,:;;:;;·



### Region X

'

....... ;:.: _:

..**~'** t....

...

. t**~::** .; •• t', •**.:_~** .;' .••
-
..... '.' 

### Purpose:



### Tre purpose of this memorandum is to pro\'ide gr p ' 

### '·er flexibility

## t~ the 

### current' Nation'at Priorities Listing (,1\PL) polic)' forevalu<lling the Impact of completed removals on the Hazard Ranking System 

### (HRS) score (Publication No. 

### 9345.I-03FS, October 1991). Flexibility is 

### accomplished by 

### allowing post-Site Inspection

### ("post~Sr') completed 

### removals to 

### be considered
in HRS scoring.

### The October \99\ NPL policy "The Revised Hazard Ranking System: Evaluating Sites { 

### A fler Waste Removals" (Publication No. 9345.1-03FS) established three requirements 

### for considering removal actions when scoring a 

### site using the 

### HRS. First, all 

### the waste subject to the 

### removal must be physically removed from the site. Second, 

### the removal action must have occurred prior to the SL (55FR 

### 51567, December 14, 1990). Third. 

### all waste removed must be 

### disposed or destroyed at a facility permitted under.the Resource Conservation and Recovery Act. Taxies Substances Control Act, or by the Nuclear Regulatory Commission.

Based**~n** 

### experiences in applying the CUlP'nt 

### NPL policy. the Agency recognizes that**~i)me** 

### post-51 removal actions can 

### substantially address the threat to human health and t.'I1\ironment 

### and should be considered up to the 

### time ofNPL listing. Therefore. as a 

### means 

### of encouraging early response actions, especially by 

### private parties, when set1ing priorities for the**~·PL.** 

### EPA (;m 

### now corlsidl?r certain 

### types ofpost-SI removal completions (removals completed**~~Il\-** 

### time b;'!I,:'re 

### the site 

### is**prop~)st'd** 

### to the**~PL)** 

### in prl?paring 

### l-lRS s(L)ring p3ckagcs. 

### Additionally, this post-SI consideration hereon modit1cs'the second of three requirenlcnts 

### cited in**th~** 

### October J 

### 991 NPL 

### policy.

ImpkIlH'ntion:**Thi~cOnsid~ratiQi.i;Qhly~ppJid;\\:here'the;Regionha:s:docuiiW,)t~ti9n(~,g.,QSC-RemoYalt.f**

# 'i;ii~~iijii;!ff~i!!~~i!i~i~i;E~iiii~ii? drops below 28.5 as a result of these changes, and if alfcost recovery activities have been --'< 

### addressed (a decision not to cost recover has been completed or final payment of outstanding oversight or response costs has been received) etc.), 

### the Region can proceed 

### with archiving the site from the Comprehensive Environmental Response, Compensation and Liability Information System (CERCUS). The attached 

### Post-Site Inspection Removal Site Example is provided to assist you in implementing this new reform.

In summary, the' Agency believes that trus 

### refonn would reduce EPA and private sector legal/transaction costs associated with the listing and subsequent deletion process. Most importantly) this ref0n11 bet1er reflects the Agency's priorities for listing only those sites adwlscly 

### im ' ,cting 

### human health and the**en\'iro'1;~)ent**

2

### If you have any questions regarding this rdonn. please contact Tim Gill. OfTice of Emergency and Remedial Response. at 003) 603·8856. 

### (
n,is 

### rCrOm) is not a rule, and does not create 

### any legal obligations. The extent to which
EPA applies 

### this policy 

### will depend on the facts 

### of each case.



## cc: EPA HQ OSWERIIO OSPSlBrownfields OERR t l0 

### OERR Center Directors
OSW:10 

### OGC10 OSRE.l0 OFFR010 OFFE 

### 10 

### EPA Regional Removal Managers EPA Regional**~PL** 

### Chiefs EP A Regional NPL Coordinators 

### EPA Regional Cost Recovery 

### Mangers EPA Regional Counsel

Association of State Terroritorial Solid Waste Officials I 

### Kris Hoellen

;·1

3

### Post·Sile Inspection Remora! Site Example

(

To illustrate the implementation of !his policy. consider a CERCUS site thaI is a candidate for the NPL because of !he threat it poses 10 ground water. The sile consists of leaking transformers and soils contaminated with polychlorinated biphenyls (PCBs) in 

### a 5.000 square 

### foot area at 

### a fonner storage facility. Targets include more than 3,000 people who receive drinking waler from ground
water wells within lh to I mile of the site.

In 1989. EPA conducted a Site Inspection (SI) at the facility to ga!her !he data necessary to prepare an HRS documentation record. Preliminary evaluations by EPA indicate lhatthe sile will score greater than 28.50 on the HRS (\3sed on the threat to ground water alone. AI!hough no release 10 ground water was dicco\"cred. the potential for a re!e;lse to Ihe local drinking waler aquifer is high and 

### Jnilny pevplc near the site use this aquifer.

In 1993. the PRP drained fluids containing PCBs from the transformers and hauled away the transformers and PCB-ct-.maining Ouids to an approved disposal facility. The soil was excavated to a Jt'pth t-.f arrroxim:uely 3 feet ,ind ar0"Jnd 1:'00 drums of PCB-Ct'fll,lnlinated $\'il were taken t\' an approved facility for the**di~p0sal** of PCBs. Post-remoyal soil sampling rcveakJ no PCBs. Current data show no PCB contamination in do\\ ngradient drinking water and monitoring wells \l,'ithin 'h mile of the site,

After the removal was completed. EPA developed a revised HRS score. Under EPA's original policy. the HRS score would still be greater lhan 28.50 because the response action occurred after the Sf. Under this revised policy, the site score

..... ould be reduced to 0 because !he Hazardous Waste Quantity value became 0 once all hazardous waste sources were physically removed from the site and disposed of at an appropriately penniued facility. The nondetection of PCBs during a resampling of the ground water monitoring well and drinking water wells within Ih mile downgradient of !he site ensured EPA that the PRP's response action removed a sufficient quantit)' of PCBs to restrict further contaminant migration. EPA began the procedures to archive the site from CERCUS.

4

### ATTACHMENT C



## Figure illustrating areas excavated

as part of time-critical removal action



# I·· ..•N



## lID 

# _17_

ifttH+ff 1INLIDlI_ 

# ! I 

# --_1llTc:It

o 150' JOO' 

# II..$" '-"-**~-- DCAVAl1llll**  "",uW;;:UUI&4 g"i'C"IOIiIloU.lU 1liI.&..... Flaure No. ". coUIIlY _1lCIIlII



# o**----~-=-.** 11 1""11**L~I** I II 

# J

O' •

. GulfIlOrt, Milllillllilllli Emergency Rellponse and
DRAINAGE DITCH Removal Branch Soil Excavations 2-8

. . C,_OM '

.. e4-..l_Pra**~l£mo** luly 12, 1999

- November 23, 1999'1-------1 

# I

11

- 5/00