Public Comment Period for Proposed Final Remedy and Permit Modification

INTRODUCTION

The U.S. Environmental Protection Agency (EPA) Region 7 invites the public to comment on the Proposed Final Remedy (Proposed Final Corrective Measures) and draft Permit Modifications for the John Deere Waterloo Works – Drivetrain Operations facility, 400 Westfield Avenue, Waterloo, Iowa.

PROPOSED FINAL REMEDY

The Proposed Final Remedy will consist of a combination of existing interim and ongoing cleanup actions, as well as newly implemented cleanup actions. 

• Continue to remove free product through passive recovery systems to control releases of contamination to groundwater.
• Treat groundwater contaminated with chlorinated volatile organic compounds (VOCs) by the use of soil vapor extraction, in-well air stripping or enhanced in-situ bioremediation, or a combination thereof, to reduce contamination to below final cleanup standards in groundwater.
• Continue monitored natural attenuation (MNA) through the use of an extensive monitoring well network to reduce contaminant concentrations in groundwater by natural chemical, biological and physical attenuation processes to below final cleanup standards.
• Contain the groundwater contaminant plume on site by pumping of existing production wells. This will ensure contaminants do not migrate off-facility by slowing down groundwater movement and allowing natural attenuation processes to continue.
• Long-term monitoring will be conducted to ensure no off-site migration of contamination is occuring; to track progress of MNA and hydraulic containment; and to confirm that contaminant concentrations in groundwater are reduced to below final cleanup standards for a period of at least three years.

• Continued use of engineered controls in the form of asphalt/concrete pavement or vegetated soil caps to stabilize and mitigate exposure to contaminated soil through direct contact.

• The Proposed Final Remedy also includes land use restrictions, using institutional controls that will prohibit residential development, prohibit potable groundwater use, and require prior notification or assessment/mitigation for vapor intrusion at newly constructed buildings on the facility.
• A soil management plan will also be required to direct the appropriate management of excavated soil/materials with prior EPA notification.

EPA encourages the public to review this Proposed Final Remedy, draft Permit Modifications, and the Administrative Record, which contains documents supporting the Proposed Final Remedy.

The public comment period will run from May 7, 2019, through June 21, 2019.

Written comments on the Proposed Final Remedy must be mailed or emailed no later than June 21, 2019, and sent to:

Lisa Messinger
Project Manager
EPA Region 7 (LCARD/ROAG)
11201 Renner Boulevard
Lenexa, KS 66219
Or by email at messinger.lisa@epa.gov

BACKGROUND

The 290-acre facility is bordered by River Road and the Cedar River on the north and Westfield Avenue on the south. The facility was originally established as the Waterloo Gasoline and Traction Engine Company in 1893. Deere and Company of Moline, Illinois, acquired the facility in 1918 and has operated it since that time. In June 1991, EPA issued a federal Resource Conservation and Recovery Act (RCRA) Hazardous Waste Management Permit to John Deere Waterloo Works, which allowed for the operation of a hazardous waste storage facility at the site. Since the issuance of the permit, all the previous permitted units have been either reclassified as Clean Water Act facilities or cleaned and closed under RCRA.

In 2006 the permit was renewed for the remaining corrective action activities for identified Solid Waste Management Units (SWMUs) and Areas of Contamination (AOCs).  It contained a cleanup plan to address SWMU 19A and Southeast AOC-1, which included keeping the AOC covered with a barrier, such as paved parking and driving areas and buildings themselves. This remedy was enforced as part of John Deere's renewal permit and the imposition of an environmental covenant. This restriction required that, in the future, if it should be deemed necessary to remove the cover for any reason, EPA will be notified before removal occurs and have an opportunity to oversee removal activities to ensure worker safety and that contaminated material is properly managed. This remedy remains in place as part of the permit, in addition to the Proposed Final Remedy.

CONTAMINANTS

Environmental investigations have identified widespread metals, semi-volatile organic compounds (SVOCs), and volatile organic compounds (VOCs) in groundwater, as well as specific areas with chlorinated VOCs, petroleum hydrocarbons, and Aroclor in groundwater as the primary risk drivers. Petroleum hydrocarbons or Aroclor [a polychlorinated biphenyl (PCB) mixture] are present in the soil and groundwater at SWMUs 7 and 8, and AOCs 2 and 4. The facility also currently utilizes engineering controls in the form of soil/vegetated berm covers and concrete/asphalt pavement to stabilize contaminated soil at the berms, and to mitigate direct contact exposure with soils at SWMU 22 and AOC 2 where Aroclor, cyanide, metals and SVOCs are the main risk drivers.

FOR MORE INFORMATION

The Administrative Record is available for public review during normal business hours at the following locations:

Waterloo Public Library
415 Commercial Street
Waterloo, IA 50701
Phone: 319-291-4480

EPA Region 7 Records Center
11201 Renner Boulevard
Lenexa, KS 66219
Phone: 1-800-223-0425

Iowa Department of Natural Resources
502 E. 9th Street
Des Moines, IA 50319
Phone: 515-725-8200

Iowa Department of Natural Resources
Field Office #1
909 W. Main, Suite 4
Manchester, IA 52057
Phone: 563-927-2640

A public hearing has not been scheduled but will be held if there is sufficient public interest. Requests for a public hearing must be made in writing to Lisa Messinger at the address listed above and must state the nature of issues to be raised at the hearing. EPA will evaluate any request and hold a formal hearing if EPA determines that a hearing will contribute to the decision-making process by clarifying significant issues affecting the remedy.

After consideration of all comments received, EPA will make a Final Permit Modification and Remedy Decision. If the decision is made to select a Final Remedy that is substantially unchanged from the Proposed Final Remedy, EPA will notify all persons submitting comments or requesting a notice of the final decision. If the Proposed Final Remedy is substantially changed, EPA will issue another public notice indicating the changes.

Individuals may write to Lisa Messinger to join the mailing list. Joining the mailing list will allow an individual to receive any updated information directly throughout the permitting process.

If you have questions or want to receive further information, please contact: