Five-Year Review Report Island Chemical Corp.A^irgin Islands Chemical Corp, Superfund Site EPA ID: V1D980651095 St Croix, US Virgin Islands SDMS Document ililllll 103674 r.'. i-'-.'„..- 4fpy, x^s. .•• . r * " * ' * < > * " *«H«,i,*f Prepared by: United States Environmental Protection Agency Region 2 New York, New York March 2009 Table of Contents Executive Summary iii Five-Year Review Summary Form iv I. Introduction 1 II. Site Chronology • 1 III. Background 2 Physical Characteristics Geology/Hydrogeology Land and Resource Use History of Contamination Initial Response Basis for Taking Action IV. Remedial Actions 4 Remedy Selection Remedy Implementation Institutional Controls System Operations/Operation Maintenance Remedy Costs V. Five-Year Review Process 8 Administrative Components Community Involvement Document Review Data Reviewf Site Inspection Interviews Institution Control Verifications & Effectiveness VI. Technical Assessment 11 Question A: Is the remedy functioning as intended by the decision documents? Question B: Are the exposure assumptioas, toxicity data, cleanup levels, md remedial action objectives (RAOs) us«J at the time of the remedy still valid? Question C: Has any other information come to light that could call into question the protect iveness o f the remedy? -1- VII. Recommendations and Follow-up Actions 12 VIII. Protectiveness Statcnient(s) 12 IX. Next Review 13 Tables Table 1 - Chronology of Site Events 14 Table 2 - Documents Reviewed 15 Table 3 - List of Acronyms Used In Thfe Document 16 -11- EXECUTIVE SUMMARY rhis is the first five-year review tor the Island Chemical Corp./Virgin Islands Chemical Corp. Supertlmd site. Six iu*eas of potential concern were investigated during the initial assessment and the subsequent Remedkil Investigation (Rl), along with the nature and extent of soil and groundwater contamination, and potential oft-Site sediment contamination. Based on the data colltxted, only the Alx»ve Ground Storage Tank Area (AST) and Former Process Pit (FPP) areas were determined to rt^iuire remediation. Contaminants of concern (COC) at the Site included ethylbenzene and xylene in si>iis and groundwater at the AST Area and chlorotbrm in groundwater at the FPP area. Currently, this site has no hazardous substances, associated with the National Priorities List (NPL) release, remaining above levels that would prevent unlimited use and unrestricted exposure. The remedy is considered to be complete and is protective of human health and the environment. -in- Five-Year Review Summary Form SITE IDENTIFICATION Site Name (from WastsLAN): Island Chemical Corp.A/irgin Island Chemical Corp. EPA ID (from WasteLAN): VID980651095 Region: 2 State: USVI City/County: Estate Bethlehem, St. Croix SITE STATUS NPLS^tUs: BRnal I D Delet«i D Othw (specify) Remediation Status (choose all that apply): • Under Construction D Operating Complete MulMple OUs? D YES • NO Construction completion date: 3/2004 Has sit© been put into reuse? D YES D NO • N/A (site reuse has not been determined) REVIEW STATUS Lead agency: • EPA • State D Tribe D Other Federal Agency Author name: Caroline Kwan Author title: Remedial Project Manager Author affiliation: EPA Review period: 3/2004 to 3/2009 Date(s) of site inspection: Typo of review: DPost-SARA DPre-SARA Q NPL-Removat only D Non-NPL Remedial /tetion Site D NPL State/Tribe- lead D Regional Disaetion • Policy Review numt>er: • 1 (first) D 2 (second) D 3 (third) a Otha-(specify) Triggering action: D Actual RA Onsite Construction D Actual RA Start • Construction Completion D Previous Five-Year Review Report g Other (specify) . Triggering action date (ftvm Wa^^JKN): March 24. 2004 Due date (five years after triggering action date): March 24,2009 Does the report include recommendation(s) and follow- up action(s)? D yes • no Acres in use or suitable for use: restricted: unrestricted; 3.5 -IV- Five-Year Review Summary Form (continued) Recommendalions and Folluw-Up Actions There are no recommendations or follow-up actions. Post Remediation Monitoring has been completed at the site. The PRPs have demonstrated in their certification of completion and their tmal post remediation monitoring report that the site pertbmiance stjmdards have been achieved. Cleanup goals have been reached at both areas of the site which were subject to remediation. Further EPA has determined that the cleanup goals achieved are protective of all reasonably anticipated site uses and exposures. Protectiveness Statement Remedial action objectives have been achieved so that human health and the environment are protected under all reasonably anticipated site uses and exposure. No fiirther five-year reviews are required by Section 121(c) of CERCLA, EPA regulations or EPA policies. I. Introduction This first five-year review for the Island Chemical Corp./Virgin Islands Chemical Corp. (VICHEM) Super&nd site, was conducted by United States Environmental Protection Agency (EPA) Remedial Project Manager (RPM) Caroline Kwan. The five-year review was conducts! in accordance with the Comprehensive Five-Year Review Guidance, OSWER Directive 9355.7- 03B-P (June 2001). The purpose of five-year reviews Is to ensure that implemented remedies protect public health and the environment and function as intended by the decision documents. This document will become part of the site file. In the Remedial Design/Remedial Action (RD/RA) Consent Decree, the PRPs agreed to perform the RD/RA specified in the ROD. On a voluntary basis, the PRPs had been operating the soil vapor extraction/air sparging (SVE/AS) system in the AST Area (which was consistent with the requirements of the ROD) since 200!, and an extensive network of nwnitoring wells was already in place. A formal remedial design pfiase was, therefore, not required by the Consent Decree, except in the event EPA detennined that supplemental activities were required to achieve performance standards. The following are all elements of the requirai remedial action: • Remedial Element I; Soil Vapor Extraction/Air Sparging (SVE/AS) tor the AST Area; • Remalial Element II: Monitored Natural Attenuation (MNA) for the FPP Area; and, • Reinerfial Element III: Institutional Controls. EPA conducted the Pre-Final Inspection of remedial instruction activiti« in March 2004. Remedial construction activities were considered cotnplete during this inspection. Because the completion of the remedy will not leave hazardous substances, pollutants, or contaminants on site above levels that allow for unlimited use and unrestricted exposure, a policy five-year review (rather than a statutory five-year review) is required. In accordance with the Section 1.3.2 of the five-year review guidance, a policy five-year review is triggered by the constmction complete This five-year review provides background information, covers the site history, discusses past data- collection efforts along with information collected in the past five years, and reevaluates risk and remedy protectiveness based on updated assumptions. This five-year review evaluat«l the remedial action and found that the implemented remedies protect human health and the environment. II. Site Chronology Table I (attache!) suinmarizes the site-related events from discovery to post remediation monitoring. -1- III. Background i^hysical Characteristics The VICHEM Site is located on Plot 13Q of Estate Bethlehem Middle Works in the south-central portion of St. Croix in the U.S. Virgin Islands. Plot 13Q is bordered to the north and east by an intemiittent stream. The River Gut, which originates north of the Site, drains to the Caribbean Sea. Site Geology/Hydrogeology The site lithology consists of fill material tirom ground surface to approximately 10 feet betaw ground surface (fogs), underlain by 80 feet of brown and gray clay-rich alluvial sediments. Local lenses of permeable gravel and sand are located at approximately 30 to 40 tbgs. Underlying the alluvium is the white to light brown and gray, lime-rich, stiff clay of the Kinphill Formation. The site contains two water bearing zones; the shallow alluvium from 0 to 50 tbgs and the deep alluvium from 50 to 100 fogs. Depth to water varies from 10 to 30 fogs depending on annual precipitation cycles (the wet season typically extends from August throuj^ November). Groundwater flow is south - .southeasterly with a horizontal gradient of approximately 0.002 - 0.014 ft/ft in the shallow alluvium and 0.003 - 0.014 ft/ft in the deep alluvium. A downward vertical gradient of approximately 0.005 - 0.11 fl/ft exists between the two zones. Monitoring wells screened in the shallow zone typically do not show a response to off-site pumping, while wells screened in the deep zone show significant response. Based on this difference, it is believed an aquitard exists between the shallow and deep alluvium that prevents contaminant migiation. Land and Resource Use Land use surrounding the VICHEM Site includes a mix of commercial and industrial purposes and the Site is zoned as 1-2 (Light Industry). History of Conlumination Charles 11. Steffey, Inc. (CHS, Inc.) purchased the VICHEM Site in 1968. At some point prior to 1969, CHS, Inc. changed its name to CHS Holding Corporation (CHS). From 1968 to 1982, the Site was used for the manufacture and blending of a variety of pharmaceutical products. By the end of 1982, the facility was pennanently closed. CHS retains ownership of the Site. Between 1984 and 1991, .several investigations were conducted at the Site by EPA and a former tenant, Island Clicmical Company, which was later acquired by Berlex. This investigative work identified six areas of potential environmental concern: • Laboratory and Warehouse Building; • Above ground storage tank (AST) area; • Former process pit (FPP) area; • Losing dock/former laboratory pit area; • Soil beneath concrete pad near ASTs; • Concrete storage pad. On May 31, 1990, EPA filal a Notice of Comprehensive Environmental Response Compensation, and Liability Act (CERCLA) lien on the Site property pursuant to Section 107(1) of CERCLA, 42 U.S.C. § 9607(1), to secure payment for the costs incurred in the performance of the removal action at the Site. On September 29, 1994, EPA entered into an Administrative Order on Consent (AOC), Index No. II CERCLA-94-0401, with Berlex and Island Chemical Company; Pierrel S.p. A, a subsidiary of Pharmacia &Upjohn (P&U) and also a former tenant at the Site, was added as a res|x>ndent to the AOC in April 1999. The AOC, pursuant to Section 106(a) of the CERCLA, as amended, 42 U.S.C. '9606(a), required the pwformance of a Remedial Investigation/Feasibility Study (RI/FS) at the Site. The priinary objectives of the Rl were to: 1) collect the data needed to characterize the nature and extent of contamination and adequately support human health and ecological baseline risk . assessmmts and 2) provide a basis on which a subsequent remedial action plan would be recommended. All six areas of potential concern were investigated during the iiiitial a.ssessment and the subsequent Ri, along with the nature and extent of soil and groundwater contamination, and potential ofF-Site sediment contamination. Based on the data collected, only the AST and FPP areas were determined to require remediation. EPA added the VICHEM Site to the National Priorities List (NPL) on June 17, 1996. initial Response During initial stages of site ass^isment, both EPA and Berlex ajnducted response activities including soil excavation with on-Site treatment or ofF-Site disposal, drum removals, and off-Site disposal of AST contents. Between September 1989 and October 1991, EPA conducted a removal action at the Site. At that time, the laboratory/warehouse building was found to contain approximately 400 drums (some extremely deteriorated), leaking cylinders of chlorine ajid hydrogen chloride, and over 800 containers of laboratory reagents that included sodium metal, potassium cyanide, and ethyl ether. EPA removed 354 drums containing 14,720 gallons of various chemicals and 8,061 pounds of lab pack chemicals from the laboratory/warehouse building and disposed of these materials ofF-Site. Basis for Taking Action Contammmits of concern at the Site as detennined in the RI included ethylbenzene and xylene, in soils and groundwater at the AST Area and chlorotbrm in groundwater at the FPP area. The risk assessment determined that the Site posed potential threats to human health and the environment through ingestion associated with contaminated soil £ind groundwater. -3- IV. Remedial Actions Remedy Selection As part of the RI/FS, the PRPs implemented a field Pilot Test of SVE/AS in February 2000. Following successful completion of the Pitot Test, and with the approval of EPA and the Virgin Islands Department of Planning and Natural Resources (VIDPNR), a SVE/AS s}^tem tor the AST Area was placed in continuous operation in June 2001 by the PRPs. A chain link fence was installed in spring 2000 along the property line to secure the area fi"om unauthorized access, and in the spring of 2002, the PRPs demolished the site buildings rod removed and disptised/recycled all of the tanks and related equipment. On August 14, 2002, the Regional Administrator signed a Record of Decision (ROD) selecting the tbltawing remedy: • SVE/AS to treat contaminated groundwater, saturated soil, and uasaturated soil at the .A.ST source area; • MNA to address low-level residual contamination in groundwater at the FPP area and downgradient areas; and • Institutional controls (in the fonn of existing VIDPNR well permitting laws and regulations) to limit the pumping of groundwater at the Site to prevent interference with the selected remedy and to also prevent human exposure to contaminated groundwater until EPA's Maximum Contaminant Levels (MGLs) are achieved. The ROD also sel«:ted groundwater pump and treat as a contingency remedy in the event that groundwater cleanup goals were not achieved in a reasonable time period. The cleanup goals tor soils in the AST Area were 6,500 ug/kg for ethylbenzene and 90,000 ug/kg tor xylene; these values were selected with consideration of commercial land use and impact to groundwater. The unrestricted residential soil cleanup goals are 5,700 ug/kg for ethylbenzene and 600,000 ug/kg for xylene. The post-excavation .sampling conduct^ by Oolder Associate! indicates that the maximum detected concentration of ethylbenzene In soils is 1,600 ug/kg at a depth of 8 feet and that the maximum detected concentration of xyloxe in soils is 1,3(K) ug/kg at a depth of 11 feet. Therefore, the concentrations of site-related contaminants remaining in soils are below the level that allows unrestricted residential land use. For groundwater, the cleanup goals were 700 /ig/L for ethylbenzene, 10,000 ^g/L for xylene, and 100 /ig/L for chloroform, respectively. All groundwater monitoring locations have been below the cleanup goals. -4- The following RAOs based on the human health risk assessment were required for the site: • Mitigate the toxicity, mobility, and/or volume of volatile organic compounds (VOCs) (ethylbenzene and xylene) in soils in the AST Area so as to minimize continued leaching to groundwater; • Mitigate the toxicity, mobility, and/or volume of VOCs (ethylbenzene and xylene) in groundwater in the AST Area and downgradient so as to achieve MCLs veground Storage Tank Area The selected remedy for groundwater contaminants in the AST Area is treatment via SVE/AS. The SVE/AS system was .shut down on November 3, 2003. Prior to system shut-down, COC, TEX, were below MCLs The MCLs for ethylbenzene and xylene are 700 parts per billion (ppb) and 10,000 ppb, respectively. Following shut-down, COC concentrations rebounded in .AST Area wells MW-1, MW-6, and AST-VMP-3D, but are currently showing decreasing trends. MW-1 Ethylbenzene concentrations in groundwater increased to above the MCL in Spring 2004, but then declined during subsequent sampling seasons. Currently concentrations arc below the MCL. Xylene concentrations increased to levels above the MCL from December 2003 through June -9- 2004 then declined to below the MCL in November 2005 and subsequent sampling events showed contaminant levels continued to remain below MCLs. .MW-6 Concentrations of ethylbenzene rebounded to levels above the MCL in December 2003, but have since shown a declining trend. Concentrations have been below the MCL since the March 2004 sampling event. Concentrations of xylene also rebounded post remedial shut-down, but have remained below the MCL since 2001. AST-VMP-3D Although concentrations of TEX rebounded slightly post system shut-down, ethylbenzene has remained below the MCL during the review period. Concentrations of xylene increased to levels above the MCL in December 2004, but Irnve subsequently decreased. Currently xylene concentrations are below the MCL. Subsequent sampling events showed contaminant levels continuetl to remain below MCI.S, Former Process Pit Area EPA selected monitored natural attenuation (MNA) as the remedy for FPP Area groundwater, and chloroform concentrations in ip-oundwater have decreased sharply since 1998 such that the cleanup goal has now been reached. From 1998 to June 2004, chloroform in MW-2, the source area of historically higliest concentrations, decreased from 2,400 ug/L to 13 ug/L. Chloroform concentrations in the FPP Area have been consistently below the cleanup goal since 2000. MW- 11, a downgradient well which had an increase in chloroform from 3J ug/L in 1998 to 40.4 ug/L in 2000, was below cleanup goals in 2004, indicating that chloroform has attenuated downgradient. Chloroform has not been detected in any of the AST Area wells, and methylene chloride (a potential degradation product of chlorofonn) was not detected above 1 ug/L in any FPP or AST wells up to June 2004. In the FPP area, annual pt)st remediation groundwater monitoring began in the 2nd quarter 2005. Three wells, MW-2, MW-7, and MW-ll, were monitored for chlorotbrm. Chlorofbnn ct)nccntrations have remained bclov? cleanup goals during three rounds of post remediation monitoring from 2005 to 2007 and have not migrated downgradient. The data are reported in the Final Po.st Remediation Report. Since post remcdiatbn monitoring showed wmpliance with cleanup goals, no further sampling of the monitoring wells is planned in the FPP Area. Site Inspection Site inspections were performed on Mtirch 4, 2009. -10- Inspection participants included: Caroline Kwan- EPA-RPM Dr. Nadine Noorhasan Director of DEP, VIDPNR Syed Syedali- VIDPNR Emanual Liburd- VIDPNR WiUiam Gierke- RPM, Pfizer, Inc. Steve Kemp- Pfizer, Inc. Allen Kane- GoMer Associates Wcs Jamison- CariWjean Hydro-Tech Inc. Institutional Co'ntrok Verification and Effectiveness There were no institutional controls implemented for this site and no follow-up activities associated with the institutional controls. V!. Technical Assessment Question A: Is the remedy functioning as intended by the decision documents? The Remedial Action Objectives include: 1.) mitigating the toxicity, mobility, and/or volume of ethylbenzene and xylene in the soils of the AST Area in order to minimize leaching potential and in the groundwater at and downgradient of the AST Area so as to reach MCLs; 2.) mitigating the toxicity, mobility, and/or volume of chtoroform in groundwater at and downgradient of the FPP area .so as to reach MCLs; and 3.) to restrict potable use of groundwater until MCLs are achieved. All recent groundwater data indicate that MCLs have been achieved at the site. The remedy has fiinctioned as intended and these remedial action objectives have been achieved. Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time of the remedy stUI valid? There are no changes ki the physical conditions of the site or site use? that would affect the protectiveness of the selected remedy. The exposure assumptions and the toxicity values that were used to estimate the potential risks and hazards to human health followed the general risk assessment practice at the time that the risk assessment was performed. Although the risk assessment process has been updated in recent years and specific parameters and toxicity values have changal, the risk assessment process that was used is still consistent with current practice and the need to implement a remedial action remains valid. Cleanup goals for soil remain valid. It should be noted that the cleanup goals for soils in the AST Area are 6,5(K) ug/kg for ethylbenzene and 90,000 ug/kg for xylene; these values were selected with consideration of amimercial land use and impact to groundwater. The unrestricted residential soil cleanup goals are 5,700 ug/kg for ethylbenzene and 600,000 ug/kg for .Kylene. The post-excavation sampling amducted by Colder Associate indicates that the maximum detected concentration of ethylbenzene in soils is 1,600 ug/lcg at a depth of 8 feet and the maximum detecttxl concentration of .xylene in .soil is 1,300 ug/kg at a depth of 11 feet. Therefore, the concentrations of site-related contaminants remaining in soils are betow the level that allows unrestricted land use. Cleanup goals for groundwater are MCLs. The evaluation of groundwater in this five-yeai- review focusetl on the ix)ssibility of vajxir intrusion if buildings were to be constructed at the site. Soil vapor intrusion was not evaluated in the original risk assessment. This pathway was evaluated for this Five-Year Review to detennine if vapor intrusion concerns are present. Since groundwater concentrations at all monitoring wells meet MCLs, the potential for vapor intrusion is not anticipated. Exceeding soil cleanup levels and meeting MCLs in groundwater COCs have achieved an unrestricted use and unlimited exposure determination for the site. As a result, no long-teim Institutional Controls (IC) or operatfon and maintenance activities are necessary. Question C: Has any other information come to light that could call into question the protectiveness of the remedy? No. Technical Assessment Summary Based upon the results of the five-year review, it is concluded that the reinedial action objectives have been achieved at the site. The concentrations of site-related contaminants remaining ki soils are below the levels that allow unrestricted land use. The data review showed that all monitoring wells at both the AST and FPP Areas meet MCLs. There are no further operation and maintenance activities associated with this .site. The PRPs will propaly seal all remaining monitoring wells and discontinue remedy c^imponents, as appropriate. There were no institutional controls implemented for this site and no follow-up activities a.ssociated with the institutional controls. VII. Recommendations and Follow-Up Actions There aie no recommendations and follow-up actions associated with this five-year review. VIII. Protectiveness Statement Remedial action objectives have been achieved so that human health and the environment are protected under all reasonably anticipated site uses and exposures. No further five-year reviews are required by Section 121(c) of CERCLA, EPA regulations or EPA policies. •12- IX. Next Review This is the only five-year review tor the site. Additional five-year reviews are not necessary since the remedi^ion allows for unlimited use and unrestricted exposure. / / Appridved;^ ., Walter E. Mugdan, Director Date Emergency and Remedial Response Division -13- Table 1: Chronology of Site Events Event EPA and Island Chemical Corp. conduct preliminary site investigations. EPA conducts removal action at the site. EPA enters into an AOC with PRPs. VICHEM Site added to the NPL. PRPs conduct RI/FS. SVE system installed and functional at the site. EPA signs the ROD for the site. EPA enters into an "ability to pay" Consent Decree with landowner CHS EPA signs Consent Decree with the PRPs to perform RD/RA at the site. PRP pertbiats quarterly groundwater sampling at the AST and FPP areas at the site. Conf!rmator\' soil sampling in the AST Area by PRPs demonstrates that the contaminant levels were below cleimup goals. PRP submits Remedial Action Work Plan. EPA produces Superfijnd Preliminary Close Out Report. PRP performs semi-annual groundwater sampling at the AST and FPP areas at the site.. Post Remediatbn groundwater sampling at the AST and FPP areas at the site demonstrates that contaminant levels are below cleanup goals. Date(s) 1984-1991 1989-1991 1994 1996 1995-2001 2001-2003 2002 2003 2003 2002-2004 20(H 2004 2004 2004-2006 2005-2008 -14- Table 4: Documents, Data, and Information Reviewed in Completing the Five-year Review McLaren Hart, 1999. Draft Final Treatability Study Workplan, Virgin Island Chemical Site, May 1999. Golder Associates Inc. 2000. Revised Final Remedial Investigation Report, Volume 1 and Remedial Investigation Addendum, Virgin Island Chemical Site, St. Croix, USVI, submitted to the USEPA October 6, 2000. ^ • Golder Associates Inc. 2001. Feasibility Study Repwrt, Virgin Island Chemical Site, June 20, 2001. ERTEC, 2001. Operations, Maintenance and Monitoring Plan, Soil Vapor Extraction and Air Sparging Systems, VICHEM Site, St. Croix, USVI. February 2001. EPA. 2002. Record of Decision for Virgin Islands Chemical Site, St. Croix, USVI. EPA. August. ^ ^ EPA. 2003a. Consent Decree for Virgin Islands Chemical Site, St. Croix, USVI. EPA. September. EPA. 2003b. Statement of Work for Remedial Action Oversight, Virgin Islands Chemical Site, St. Croix, USVI. December. EPA. 2004. Superfund Preliminary Close Out Report, Island Chemical Corp. Superfimd Site, St. Croix, U.S. Virgin Islands, USEPA Region II, New York, New York, March 24, 2004. Golder Associates Inc. 2004. Remedial Action Report, Virgin Island Chemical Site, September 17,2004. Golder As.sociates Inc. 2008. Final Post Remediation Monitoring Report, Virgin Island Chemical Site, April 28, 2008. . EPA guidance for conducting five-year reviews and other guidance and regulations to determine if any new appUcable or relevant and appropriate requirements relating to the protectiveness of the remedy have been developed since EPA issued the ROD. -15- Table 7: Acronyms Used In this Document AOC AST CERCLA CHS CHS, Inc. COC EPA FFS 1 FPP FS MCL •u&^kg f^a/i \ MNA NPL 0«&M OSWER RA RAWP RD RI RI/FS RAO ROD RPM SVE/AS TCE Administrative Order on Consent Above Ground Storage Task Comprehensive Environmental Response Compensation, and Liability Act CHS Holding Corporation Charles H. Steffey, Inc. Contamiriation of Concern United States Environmental Protection Agency Focused Feasibility Study Former Process Pit Feasibility Study Maximum Contaminant Level Micrograms per Kilogram Micrograms per Liter Monitored Natural Attenuation National Priorities List Operation and Maintenance Office of Solid Waste and Emergency Response Remedial Action Remalial Action Work Plan Remedial Design Remedial Investigation Remedial Investigation/Feasibility Study Remedial Action Objectives Record of Decision Remedial Project Manager Soil Vapor Extractioa'Air Sparging trichloroethylene -16- Table 7: Aeronyms Used in this Document TEX VICHEM VIDPNR VOCs Total toluene, ethylbenzene & xylene Island Chemical Corp./Virgin Island Chemical Corp. Virgin Islands Department of Planning and Natural Resources Volatile Organic Compounds 17-