PB99-964402
EPA541-R99-047
1999
EPA Superfund
Record of Decision;
Jacobs Smelter Site OU 1
Stockton, UT
7/29/1999
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RECORD OF DECISION
OPERABLE UNIT!-RESIDENTIALSOILS
JA COBS SMELTER SUPERFUND SITE
STOCKTON, UTAH
The U.S. Environmental Protection Agency (EPA), with the concurrence of the Utah Department
of Environmental Quality (UDEQ), presents this Record of Decision (ROD) for the Residential
Soils Operable Unit (OU1) of the Jacobs Smelter Superfund Site in Stockton, Utah. Residential
soils include those in residential yards, vacant lots, and unpaved streets and alleys located within
the town boundaries of Stockton and not previously addressed during the EPA emergency
response. The ROD is based on the Administrative Record for OU1. The ROD presents a brief
summary of the Remedial Investigation/Focused Feasibility Study (RI/FFS), actual and potential
risks to human health and the environment, and the Selected Remedy. EPA and UDEQ followed
the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as
amended, the National Contingency Plan (NCP), and appropriate policy and guidance in
preparation of the ROD. The three purposes of the ROD are to:
1. Certify that the remedy selection process was carried out in accordance with CERCLA
and the NCP.
2. Outline the engineering components and remediation requirements of the Selected
Remedy.
3. Provide the public with a consolidated source of information about the site history, site
characteristics, and risk posed by the conditions of OU1, as well as a summary of the
remedial alternatives considered, their evaluation, the rationale behind the Selected
Remedy, and the agencies' consideration of, and responses to, comments received.
The ROD is organized into three sections.
1. The Declaration functions as an abstract for the key information contained in the ROD
and is the section of the ROD signed by the EPA Assistant Regional Administrator and the
UDEQ Director.
2. The Decision Summary provides an overview of the OU1 characteristics, the
alternatives evaluated, and the analysis of those alternatives. It also identifies the Selected
Remedy and explains how the remedy fulfills statutory and regulatory requirements.
3. The Responsiveness Summary addresses public comments received on the Proposed
Plan, the RI/FFS, and other information in the Administrative Record.
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DECLARATION
Statutory preference for treatment as a principle element is not completely met and five-
year review is required.
SITE NAME AND LOCATION
Operable Unit 1 - Residential Soils
Jacobs Smelter Superfund Site
Stockton, Utah
STATEMENT OF BASIS AND PURPOSE
This decision document presents the Selected Remedy for OU1 within the Jacobs Smelter
Superfund Site. EPA, with the concurrence of UDEQ, selected the remedy in accordance with
CERCLA and the NCP.
This decision document is based on the Administrative Record for OU1. The Administrative
Record is available for review at the Tooele Public Library, located at 47 E. Vine Street, Tooele,
Utah. The State of Utah concurs with the Selected Remedy, as indicated by signature. UDEQ is
the lead agency for the Jacobs Smelter Site.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the Site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and substantial
endangerment to the public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The Selected Remedy for OU1 is Excavation and Off-Site Disposal. The major components of
the Selected Remedy include:
Excavation of soils within OU1 exhibiting (1) mean surface lead concentrations greater
than 500 ppm, (2) mean subsurface lead concentrations greater than 800 ppm, or (3) mean
surface arsenic concentrations greater than 100 ppm - to a maximum depth of eighteen
inches.
Pretreatment and off-site landfill disposal of contaminated soil classified as hazardous
waste in accordance with Resource Conservation and Recovery Act (RCRA) Subtitle C.
Off-site landfill disposal of contaminated soil not classified as hazardous waste in
accordance with RCRA Subtitle D.
Record of Decision - Declaration
Jacobs Smelter Superfund Site
Operable Unit 1
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Replacement of up to twelve inches of clean backfill, six inches of topsoil, and re-
landscaping of aifected properties. Properties will be returned to as close to original
condition as possible.
• Interior cleaning of affected homes to remove any contaminated dust.
Implementation of formal institutional controls to prevent exposure to any contamination
remaining below eighteen inches or below existing structure.
STATUTORY DETERMINATIONS
The Selected Remedy is protective of human health and the environment. It complies with
Federal and State requirements that are legally applicable or relevant and appropriate to the
remedial action and is cost effective. The remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable. However, because complete treatment
of wastes was not found to be the most appropriate alternative, the remedy does not fully satisfy
the statutory preference for remedies that employ treatment that reduces the toxicity, mobility, or
volume as a principle element.
Because the remedy will result in hazardous substances remaining on-site below eighteen inches,
the remedy will be continually reviewed beginning five years after commencement of remedial
action to ensure the remedy continues to provide adequate protection of human health and the
environment.
DATA CERTIFICATION CHECKLIST
The following information is included in the Decision Summary of this ROD. Additional
information can be found in the Administrative Record for this site.
Contaminants of concern (COCs) and their respective concentrations
• Baseline risk presented by the COCs
Cleanup levels established for COCs and the basis for the levels
Current and future land use assumptions used in the baseline risk assessment and the ROD
Land use that will be available at the Site as result of the Selected Remedy
Estimated capital, operation and maintenance (O&M), and total present worth costs;
discount rate; and the number of years over which the remedy cost estimates are projected
Decisive factors that led to selecting the remedy
Record of Decision - Declaration
Jacobs Smelter Superfund Site
Operable Unit 1
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Max H. Dodson
Assistant Regional Administrator
U.S. Environmental Protection Agency
Region VIIl
Date
me R. Nielson^"
Executive Director
Utah Department of Environmental Quality
Date
Record of Decision - Declaration
Jacobs Smelter Superfund Site
Operable Unit ]
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DECISION SUMMAR Y
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DECISION SUMMARY
TABLE OF CONTENTS
Section
1
2
3
4
5
6
7
8
9
10
11
Appendix A
Appendix B
Title
Site Location and Description
Site History and Enforcement Activities
Highlights of Community Participation
Scope and Role of Operable Unit within
Site Strategy
Summary of Site (OU1) Characteristics
Summary of Site (OU1) Risks
Remedial Alternatives
Summary of the Comparison of Alternatives
Excavation and Off-site Disposal -
The Selected Remedy
Statutory Determinations
Explanation of Significant Changes
Detailed Analysis of ARARs
Detailed Cost Summary of the Selected Remedy
1
5
8
9
10
13
27
39
44
48
50
Record of Decision - Decision Summary
Jacobs Smelter Superfund Site
Operable Unit 1
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DECISION SUMMARY
LIST OF FIGURES
Figure Number Description
1-1 Site Vicinity Map 2
1-2 Site Map 3
2-1 Known Smelter Locations 7
5-l Site Conceptual Model 12
6-l Surface Isopleth Map 15
6-2 2-6" Isopleth Map 16
6-3 6-12" Isopleth Map 17
6-4 12-18" Isopleth Map - 18
6-5 Arsenic Risk Assessment Zones 22
6-6 Properties Subject to Remediation 26
Record of Decision - Decision Summary
Jacobs Smelter Superfund Site
Operable Unit 1
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DECISION SUMMARY
LIST OF TABLES
Table Number Description page
6-1 Data Summary 19
6-2 Arsenic Hazard Quotients 21
6-3 Arsenic Cancer Risks 23
6-4 Action Levels 25
7-1 Technology Screening Matrix 28
8-1 Comparative Analysis of Alternatives 42
8-2 Summary of Remedial Alternative Costs 43
Record of Decision- Decision Summary
Jacobs Smelter Superfund Site
Operable Unit 1
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1.0 SITE LOCATION AND DESCRIPTION
The Jacobs Smelter Site (UT0002391472) is located in and around Stockton, Utah,
approximately 25 miles southwest of Salt Lake City, Utah and five miles south of Tooele, Utah
(Figure 1-1). Approximate site boundaries are shown in Figure 1-2. The Site is bounded by the
Stockton Bar (a gravel hill) to the north, Rush Lake to the west, and the Oquirrh Mountains to
the east. The entire site is referred to as "Jacobs Smelter," taken from the name of a former
smelting operation located in Stockton, Utah. To date, reports of up to nine former smelters
within the site boundaries have been documented. The Jacobs Smelter was just one of these
historic smelters; however, the entire Superfimd site was named Jacobs Smelter as a matter of
convenience.
The area surrounding Stockton is generally open grassland and is used primarily for grazing.
The topography of the area is gently sloping from east to west towards Rush Lake. Several single
family dwellings and farms exist in the area. The town of Stockton is mostly residential, with only
a few small businesses. Approximately 500 persons reside within a four mile radius in and around
Stockton. Due to its location, the area is prime for growth and residential development.
Rush Lake is the dominant surface water feature in the area. The lake is freshwater and is
recharged primarily through ground water flow and several springs which empty into the lake.
Discharge from the lake is through evaporation and ground water loss to the north. Water quality
in the lake is generally good. Water levels in the lake have fluctuated greatly over the years, with
the lake size changing drastically. Evidence suggests the lake is currently at a high stand, but for
much of the century prior to the 1980s the lake was much smaller. Soldier Creek flows west from
the Oquirrh Mountains and serves as the source of drinking water for Stockton. The creek is now
ephemeral in its lower reaches, but at one time (prior to being tapped as a water source), surface
flow in the creek likely reached all the way to Rush Lake during wet years.
The risks posed by the Site derive from mining activity which occurred primarily in the 1860's and
1870's. Mining wastes in the form of heavy metal contaminated soil, mill tailings, and smelter
wastes are known to exist at several locations within the site boundaries. The primary
contaminants are lead and arsenic. Little visible evidence exists of the former mining operations.
There are currently three operable units at the Site. Operable Unit One (OU1) addresses
residential soil contamination within the town of Stockton, attributable primarily to the former
Jacobs Smelter. Operable Unit Two (OU2) addresses soil and sediment contamination outside the
town of Stockton (attributable primarily to the other smelters and mining operations), ground
water, and potential ecological impacts. Operable Unit Three (OU3) addresses soil
contamination on Union Pacific Property, also attributable primarily to the Jacobs Smelter.
An emergency response to address several areas of residential contamination in Stockton was
commenced in March 1999. This decision document is directed at resolving soil contamination in
Record of Decision - Decision Summary
Jacobs Smelter Superfimd Site
Operable Unit 1
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FIGURE 1-1
VICINITY MAP
JACOBS SMELTER STOCKTON, UTAH
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the residential area of Stockton which will remain after completion of the emergency response.
This is a final record of decision (ROD) and there were no interim RODs. The Utah Department
of Environmental Quality (UDEQ) is the lead agency for the Site under a cooperative agreement
with the United States Environmental Protection Agency (EPA).
Record of Decision - Decision Summary
Jacobs Smelter Superfund Site
Operable Unit 1
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2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1 SITE HISTORY
The Rush Lake/Stockton area was first settled in 1855 by the U.S. Army on a military reservation
called Camp Floyd. The camp was soon abandoned. During the Civil .War, the camp was
reoccupied by California calvary volunteers and renamed Camp Relief.
In April 1864, volunteer soldiers discovered silver ore east of Stockton and organized the first
mining district. The area around the military reservation became the base for small scale milling
and smelting activities. The town of Stockton was laid out in 1864 and contained over 400
inhabitants by 1866. Several small smelting furnaces were built in the area, operated a short time
with marginal results, and then were shut down. The exact locations of most of these furnaces
remain unknown.
In 1869, the U.S. government sold Camp Relief. Mining in the area was beginning to expand and
smelting processes were improved. By 1873, the Lincoln-Argent, Tucson, Bolivia, Silver King,
St. Patrick, Quandary, Great Basin, Great Central, Our Fritz, and Flora-Temple-First National
mines were in operation. Later mines included the National-Honerine, Ben Harrison-New
Stockton, Calumet, Galena King, Muerbrook, Muscatine, Salvation-Hercules, and the Tiptop.
The largest smelter in the Stockton area was the Waterman Smelting Works, which opened in
1871 on the northern shore of Rush Lake, about Vs. mile west of Stockton. This smelter was
owned by I.S. Waterman and operated through 1886. The smelter reportedly produced a total of
approximately 3,300 tons of flue dust and nearly 15,000 tons of smelter slag.
In 1872, the Jacobs Smelter (aka Jack Smelter), owned by Lilly, Leisenring & Company, began
operation within the town limits of Stockton. The smelter processed ore from the Ophir Mining
District, located ten miles south of Stockton, in three vertical blast furnaces. By 1880, each of
these furnaces could reduce 25 tons of ore per day, resulting in 19.5 tons of smelter slag and flue
dust per day. In 1879, the Great Basin Concentrator was constructed adjacent to the Jacobs
Smelter and by 1880 was milling 100 tons of ore per day with approximately 80 tons of mill
tailings produced as waste.
The Chicago Smelter opened in 1873 on the eastern shore of Rush Lake at Slagtown, two miles
south of Stockton, -within the boundary of the former military reservation. It was built by the
Chicago Silver Mining Company, a British firm that also operated two nearby mines. The smelter
operated sporadically through 1880. The Carson & Buzzo Smelter was located about V* mile
south of the Chicago Smelter, also on the shore of Rush Lake. The production rate of these
smelters is unknown.
A total of at least nine smelting/milling operations are reported to have existed in the Stockton
area, including the four mentioned here. Over the ensuing century, nearly all traces of these
Record of Decision - Decision Summary
Jacobs Smelter Superfund Site
Operable Unit ]
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operations have vanished. Buried timbers, stained soils, and some foundations are virtually all of
the physical evidence that remain. Homes were built upon a portion of the former Jacobs Smelter
location. Much of the slag produced was likely reprocessed in other smelters located in Tooele or
in the Salt Lake Valley. Through historical research and direct observation, the exact locations
of the Jacobs, Waterman, Chicago, & Carson & Buzzo Smelters have been verified. The
locations of other unnamed operations can only be speculated based upon sampling of soils to test
for the presence of heavy metals: A map showing the probable locations of smelting/milling
operations is shown in Figure 2-1.
In 1995, the area was added to the Comprehensive Environmental Response, Compensation, and
Liability Information System (CERCLIS) under the name Stockton Smelters. A PA/SI was
completed in December 1998 and the name of the entire site was changed to Jacobs Smelter.
Based upon a removal assessment conducted in late 1998, an emergency response action was
initiated in March 1999 to address soil contamination of residential properties located in Stockton.
A Remedial Investigation/Focused Feasibility Study (RI/FFS) for OU1 was completed in June
1999. An Rl for OU2 is currently underway. The site was proposed for the National Priorities
List on July 22, 1999.
2.2 ENFORCEMENT ACTIVITIES
EPA initiated a potentially responsible party (PRP) search when removal assessment activities
began in late 1998. Due to the fact that nearly 100 years had passed since mining activity last
occurred in the Stockton area, it was considered improbable that a viable responsible party still
existed. Within OU1, it was considered even more unlikely because residences had been built
upon the site of the former Jacobs Smelter. This assumption proved true. At the time of this
ROD, none of the companies which operated mills or smelters within the site boundaries still
existed or could be traced to current operating parties. EPA is continuing to search for any viable
PRPs. Pursuant to EPA's policy of not considering residential home owners liable for
contamination located on private residential property, residents were not considered PRPs.
During removal assessment activities, contaminated soils were discovered on Union Pacific
property (railroad right of way) on the western edge of Stockton. EPA notified Union Pacific on
April 26, 1999 requesting a time critical removal be performed to address the contamination.
The area was designated as OU3. EPA and Union Pacific are negotiating the terms of the
response through an Administrative Order on Consent (AOC). Under the terms of the AOC,
Union Pacific was to cover the area of contamination located on the railroad property with twelve
inches of clean soil and fence the area. This work is scheduled to be completed durine summer
1999.
During sampling for the OU1 RI/FFS, contamination was found east of the Stockton town limits.
Much of this land is owned by Kennecott. This land is being addressed under OU2.
Record of Decision
Jacobs Smelter Superfund Site
Operable Unit One
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FIGURE 2-1
PROBABLE SMELTING/MILLING
LOCATIONS
STOCKTON, UTAH
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3.0 HIGHLIGHTS OF COMMUNITY PARTICIPA TION
Public participation for OU1 began during emergency response activities. In late 1998, two
public meetings were held. The first meeting occurred before removal assessment sampling
occurred and the second was held after results were received. Attendance at both meetings was
excellent, with nearly 50% of the town population attending. At the second meeting, residents
were informed of the sampling results for their yards, and the activities which would likely ensue.
Residents who did not attend were mailed their results and contacted separately. Also at the
second meeting, representatives from both the EPA Superfund remedial program and UDEQ
addressed the attendees and described the upcoming remedial process, including possible proposal
to the National Priority List.
Upon commencement of the OU1 RI/FFS in January, 1999, a community forum meeting was
instituted. This meeting occurs in Stockton monthly, and involves the town mayor, city and
county officials, representatives from EPA and UDEQ, and a few citizens. The purpose of the
meeting is to keep information flow frequent and timely. This meeting will continue through the
completion of the remedial action(s).
The Administrative Record (AR) and information repository for both the emergency response and
GUI were established in April 1999. The AR is located in the Tooele Library, five miles north of
Stockton in Tooele. A notice advertising the availability of the AR was published in the Tooele
Transcript- Bulletin on April 29, 1999. An additional information repository for important
documents was established in the town hall of Stockton for easier accessibility. Documents were
added to both collections as they were produced.
A Community Involvement Plan, highlighting activities and opportunities for public participation,
was developed by EPA and UDEQ in early 1999. The plan is based on numerous interviews with
Stockton residents and government officials.
The proposed plan for OU1 was released for public comment by UDEQ on May 27, 1999. A
public meeting for comment on the proposed plan was conducted on June 9, 1999 and the public
comment period ran through July 15, 1999. Any comments submitted, as well as EPA and
UDEQ responses to those comments, can be found in the responsiveness summary section of this
document.
EPA proposed the Site for inclusion on the National Priorites List on July 22, 1999. The public
comment period for this action will run for 60 days.
This decision document presents the selected remedial action for OU1, chosen in accordance with
CERCLA, as amended by SARA, and the National Contingency Plan (NCP). The decision for
this operable unit was based on the Administrative Record.
Record of Decision
Jacobs Smelter Superfund Site
Operable Unit One
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4.0 SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY
GUI addresses the residential soils within the town of Stockton. Work within OU1 will include
both the emergency response and the remedial action detailed in this ROD. OU2 addresses
contaminated soils and sediments outside the town of Stockton, potentially contaminated ground
water across the entire site, and potential ecological impacts of the entire site. OU3 addresses
contaminated soil located on Union Pacific property
The purpose of the emergency response and the planned remedial action at OU1 is two-fold.
First, the direct exposure to contaminated soils must be addressed. Second, contaminated soil
could serve as a potential source of ground water contamination and removal of this source would
be consistent with any ground water remedy which may be required under OU2.
An RI for OU2 is underway. Investigations for this RI are planned to take at least two years. An
emergency removal is currently being conducted by Union Pacific for OU3 and is scheduled to be
complete this year. The OU3 removal will entail covering the contaminated area of the railroad
property with twelve inches of clean fill and restricting access.
Record of Decision
Jacobs Smelter Superfvnd Site
Operable Unit One
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5.0 SUMMARY OF SITE (OU1) CHARACTERISTICS
5.1 PHYSICAL CHARACTERISTICS
The Jacobs Smelter Site is located in the Rush Valley. Rush Valley is bounded on the east by the
Oquirrh Mountains, to the north by the Stockton Bar, and to the west by the Stansbury
Mountains. The western flank of the Oquirrh Mountains is home to several mines which served
as the primary source of ore for the smelters and mills in Stockton. This mining area is known as
the Rush Valley Mining District.
Elevation at the Site ranges from approximately 5000 to 5120 feet above mean sea level.
Precipitation in the area averages about 18.5" per year and the average annual temperature is
about 50 degrees Fahrenheit. The area is frequently dry, dusty, and windy. Native vegetation
consists primarily of short to medium grasses and small shrubs such as sagebrush. The condition
of residential yards and lots varies throughout the town, but exposed soil is common and
vegetative cover is often sparse. Many roads, driveways, and alleys are unpaved. Drinking water
is obtained through a municipal system which uses flow in Soldier Creek as the sole source.
OU1 is roughly delineated by the town boundary of Stockton (shown in Figure 1-2). The area of
OU1 is estimated at approximately 150-175 acres. Approximately 500 persons reside in and
around Stockton. Within OU1, land use is almost completely residential and is anticipated to
remain residential. Lots within OU1 range in size from approximately .1 acres to 1 acre. Most
lots within OU1 contain single family dwellings, but a few small businesses and vacant lots exist
as well.
The Jacobs Smelter was located in the northeastern corner of Stockton, on a topographic high
relative to the town. At least two haul roads from the mines accessed the smelter location. At its
peak, the operation processed approximately 100 tons of ore per day. Both milling and smelting
operations were conducted. The processes were primitive and metals recovery was probably
fairly poor, suggesting a great deal of residual metal contamination is likely.
Drainage in the vicinity of town is generally to the west/southwest, towards Rush Lake.
Anecdotal evidence suggests at least one settling pond was located down gradient of the Jacobs
Smelter, and possibly others. Wastes from the smelter were likely deposited in the settling
pond(s) and flowed west toward Rush Lake. Heavy precipitation events would have likely caused
the ponds to overflow. The gradient on the western edge of town is more gentle, and settling of
wastes likely would have occurred here as flow velocities decreased. The construction of the
Union Pacific railroad tracks on the edge of town in the 1940s may have exacerbated the ponding
and settling effects here also.
A rail loading terminal (Stockton Lead Company) and smaller unnamed smelting/milling
operations also existed in GUI. These smaller operations probably added to the contamination
coming from the Jacobs Smelter and led to isolated areas of contamination around the town.
Record of Decision ~~ " ~~~ " —
Jacobs Smelter Superfund Site
Operable Unit One
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Soil sampling in town confirmed the anecdotal evidence and showed a number of residential
properties and vacant areas within town contain elevated levels of lead, arsenic, and other heavy
metals. In general, soil contamination was found at high levels in the vicinity of the former
smelter and immediately down gradient. A discrete area of contamination also existed farther
down gradient of the smelter location, along a general flow path to the west. A few isolated
areas of contamination were also discovered. Nature and extent of the contamination are
discussed in detail in Section 6 of this ROD.
Residential yards and vacant areas may have been impacted in two primary ways. First, early
existing yards may have been contaminated directly with runoff from the smelter location, both
during and after its period of operation. Second, after the smelter's period of operation,
structures were built directly on top of contaminated soil and contaminated fill may have been
used as fill material in the Stockton area. In either case, numerous lots in OU1 contain soil with
elevated levels of arsenic and lead and conditions are such that exposure and migration is likely.
The site conceptual model is shown in Figure 5-1.
In addition to residential soil samples, other testing was performed during the removal assessment
andRI/FFS:
Interior dust was sampled for heavy metals in several homes. Only a few homes showed
elevated levels of lead in interior dust and there was no significant correlation of exterior
soil lead levels with interior dust lead levels.
The drinking water in several homes was tested for the presence of heavy metal
contamination. None of these samples showed any contaminant levels of concern.
Several homes were tested for the presence of lead based paint. Only a few exterior
samples showed elevated levels.
Twenty six residents (including sixteen children) were tested for blood lead and urinary
arsenic. The testing indicated no elevated levels of lead in blood and only one instance of
elevated arsenic in urine. This lone arsenic result was later attributed to consumption of
seafood, which is often high in organic, non-toxic arsenic. In general, the relatively small
number of participants in the study makes it difficult to draw many conclusions. The study
does indicate that there are currently no elevated blood leads among the individuals tested.
The blood lead monitoring is further discussed in both the Biomonitoring Investigation
Report (ISSI, 1999a) and the Baseline Human Health Risk Assessment (ISSI, 1999b).
Further information relating to site characterization can be found the RI/FFS Report (URSGWC
1999) and Section 6 of this ROD.
5.2 LAND USE
Current land use in OU1 is nearly completely residential. Future land use for the entire operable
unit, including properties with small businesses and vacant lots, was considered residential. This
decision was based on current zoning and conversations with local officials and residents.
Record of Decision ~~ ~ " ~
Jacobs Smelter Superfund Site
Operable Unit One
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6.0 SUMMARY OF SITE (OU1) RISKS
6.1 CONTAMINANTS OF CONCERN
Contaminants of concern (COCs) are a subset of all contaminants that individually present
relatively high human health or environmental risks. The COCs identified by UDEQ and EPA for
OU1 are arsenic and lead. While other heavy metals are present at elevated levels in site soils, the
levels of these metals were not considered harmful to human health. Human toxicity information
is available for both COCs.
Based on the site conceptual model (Figure 5-1), EPA and UDEQ agree that ingestion of arsenic
and lead contaminated soils presents the primary health threatening exposure pathway and
presents an immediate and unacceptable risk to current and future residents of the Site.
6.2 NATURE OF CONTAMINATION
EPA and UDEQ identified contaminated soils as the principle threat waste for OU1. No low level
threat wastes were identified. Speciation tests were performed on site soils to determine which
forms of arsenic and lead were present. Certain types of heavy metal compounds are more
available for uptake into the human body. Also, certain types dissolve more easily in water, and
as such, are more available for dissolution into ground water or surface water.
The most common lead-bearing particles at the Site (i.e. those which were observed most often)
were iron oxide and iron sulfate, accounting for an average of about 39% and 28% of all lead-
bearing particles respectively. However, because the concentration of lead in these forms was
relatively low, they accounted for only about 7% of the total lead mass. The form of particle
which contributed the majority of the lead mass was cerussite, also known as lead carbonate. This
form contained approximately 73% of the lead mass. Lead carbonate is considered extremely
bioavailable for uptake into the human body.
The most common arsenic-bearing forms were also iron oxide and iron sulfate. However, the
form of particle which contributed the majority of the arsenic mass was lead arsenic oxide', which
is also very bioavailable.
The physical characteristics of the site soils also tended to increase the bioavailability of the
COCs. In general, lead and arsenic were found in particles which were extremely small (i.e. less
than 50-100 micrometers) and separated from the surrounding soils. These small, liberated
particles are often assumed to be more likely to adhere to the hands and be ingested and/or be
transported into the home. They are also more readily digested in the stomach than larger
particles. All samples collected during the removal assessment were sieved to 250 micrometers
to screen out larger particles.
Record of Decision ,y
Jacobs Smelter Superftmd Site
Operable Unit One
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6.3 EXTENT OF CONTAMINATION
During the removal assessment, samples were collected from nearly every yard or vacant lot in
Stockton. In general, the yards were divided into two zones, and six sample locations were
identified for each zone. At each sample location, a composite sample was taken from each of the
following depths: 0-2", 2-6", 6-12", and 12-18". Samples were analyzed quickly using X-Ray
Flourescence (XRF), and values for each depth were averaged for the lot or yard. Sampling
continued until lots or yards below the screening levels (400 ppm lead) were repeatedly
encountered or the town limits were reached. Sampling performed for the RI/FFS following the
same general scheme with minor deviations. With only minor exceptions, data collected in
support of the RI/FFS and removal assessment were considered usable.
Arsenic and lead soil contamination was documented in a large portion of OU1. Figures 6-1
through 6-4 show lead concentration isopleth maps of OU1 for 0-2", 2-6", 6-12", and 12-18" and
the exact boundaries of OU1. These figures are based upon sampling performed both during the
removal assessment and in support of the RI/FFS. Soil lead concentrations ranged from a high of
approximately 23,000 parts per million (ppm) near the former smelter location to below 500 ppm
in several areas. Nearly the entire area exhibited soil lead concentrations above background
levels. As seen from the figures, contamination generally decreased slightly with depth on an area
basis. However, there are instances where this did not occur and contaminant concentrations at
depth were higher than those found at the surface. This was particularly evident at the location of
the former smelter and mill, where isolated pockets of mill tailings up to six feet deep were
located. These tailings contained lead levels as high as 150,000 ppm. This area of high
concentrations was removed during the emergency response.
Arsenic concentrations are strongly correlated with lead concentrations. The extent of
contamination for arsenic roughly mimics those shown for lead in Figures 6-1 through 6-4.
Arsenic concentrations ranged from a high of over 1800 ppm to a low of approximately 20 ppm at
several areas around the Site. However, it should be noted that high lead concentrations tend to
"mask" arsenic when a sample is analyzed using XRF. Because of this and the strong correlation
between arsenic and lead concentrations, the highest arsenic concentrations were likely
underestimated. This was corrected by using a mathematical correlation. A summary of data
collected in support of the removal assessment (a total of 242 samples for each COC) is presented
in Table 6-1.
Record of Decision 14
Jacobs Smelter Superfund Site
Operable Unit One
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Table 6-1
Concentrations of COCs in Soil
Data Summary
coc
Arsenic
Lead
Depth
0-2"
2-6"
6-12"
12-18"
0-2"
2-6"
•6-12"
12-18"
Maximum
Concentration
(ppm)
1150
1837
1065
1306
23,000
22,517
22,000
21,950
Minimum
Concentration
(ppm)
22
20
22
22
12
108
48
14
Average
Concentration
(ppm)
100
112
110
104
1,607
1,906
1,812
1,763
Except in the area of the former smelter, no samples were taken below eighteen inches. Previous
risk and remediation evaluations for similar sites have shown that, in a residential setting,
contamination below this depth presents little risk and is impractical to remediate. This is further
explained below.
6.4 RISKS FROM LEAD
Excess exposure to lead can result in a wide variety of adverse effects in humans. Chronic low-
level exposure is usually of greater concern for young children than older children or adults. For a
variety of reasons, children are at risk of several neurological effects when excessively exposed to
lead. These effects are subtle and difficult to detect. Common measurement endpoints include
intelligence, attention span, hand-eye coordination, etc. Most studies observe effects in such tests
at blood lead levels of 20-30 micrograms per deciliter of blood, though some have reported
effects at levels below 10 micrograms per deciliter. Additionally, some effects on pregnancy and
fetal development have been associated with elevated blood lead levels.
After a thorough review of all the data, EPA identified 10 micrograms per deciliter as the
concentration level at which effects begin to occur which warrant avoidance. Further, EPA set a
goal that there should be no more than a 5% chance that a child will have a blood lead value
Record of Decision
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19
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above that level (USEPA 1991). Likewise, the Centers for Disease Control (CDC) has
established a guideline of 10 micrograms per deciliter in preschool children which is believed to
prevent or minimize lead-associated cognitive deficits (CDC 1991).
In a residential scenario, it is EPA's policy to evaluate lead risk with the residential yard as the
exposure unit and resident children as the most sensitive receptor. Soil lead levels protective of
resident children are considered protective of any other exposed population, such as resident
adults or workers exposed to soil. The mean soil lead concentration within the yard is considered
the exposure point concentration, because within the yard a child has the greatest incidence of
contact with soil. The primary exposure pathway is through incidental or direct ingestion of soil
or dust particles (i.e. from the hands or objects). Other pathways, such as inhalation of airborne
particles or consumption of vegetables grown in contaminated soil, may contribute to exposure
but represent only a negligible fraction when compared to incidental or direct ingestion.
Using data collected for each property in OU1 and modeling risk using the Integrated Exposure,
Uptake, and Biokinetic Model (IEUBK), the Baseline Human Health Risk Assessment (BRA)
concluded that after the emergency response is complete, approximately 114 properties will still
contain lead levels which could put resident children at excessive risk (i.e. > 5%) of having blood
lead levels greater than 10 micrograms per deciliter. Site specific or regional information was
used for input to the model to the greatest extent practical and only residential land use was
considered for all properties. Again, the only site-specific exposure pathway evaluated was
incidental or direct ingestion, though the model accounts for other sources of lead uptake such as
diet.
The depth to which lead contaminated soils present an unacceptable risk to residents is not strictly
defined. Surface soils (0-2") present the greatest risk because these soils are most frequently
contacted. However, it is generally acknowledged that soils below the surface also pose some
risk, as these soils may be contacted or brought to the surface when digging or performing other
intrusive activities. In general, the deeper the soil, the less likely someone may disturb or
encounter it, and hence less risk. Previous risk management evaluations at similar sites have
recommended 12-18" as the depth to which action may be warranted. Remediation to these
depths is generally considered protective of normal residential activities such as gardening and
landscaping. Based upon this standard, contamination above 18" is considered a primary threat
waste and contamination below 18" is considered a low-level threat waste. As stated previously,
sampling in OU1 indicated contamination to a depth of at least eighteen inches. Residential
properties remediated during the emergency response were excavated to a depth of eighteen
inches.
6.5 RISKS FROM ARSENIC
As with lead, the primary exposure route for arsenic in soils is through incidental or direct
ingestion. Excess exposure to arsenic is known to cause a variety of adverse health effects in
humans.
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Noncancer Effects
Oral exposure to high doses of arsenic produces effects such as nausea, vomiting, diarrhea, injury
to blood vessels, kidney damage, and liver damage. The most diagnostic sign of chronic arsenic
exposure is an unusual pattern of skin abnormalities, including dark and white spots and a pattern
of small "corns," especially on the palms and soles of the feet (ATSDR 1991).
The risk of noncancer health effects from a chemical is expressed as its Hazard Quotient (HQ). If
the value of the HQ is equal to or less than one, it is accepted that there is no significant risk of
noncancer health effects. If the value of the HQ is greater than one, a significant risk of
noncancer health effects may exist, with the likelihood increasing as the HQ increases. To
evaluate risks from arsenic, the BRA broke the Site into eight zones, roughly corresponding to
neighborhood blocks. These zones are shown in Figure 6-5. The exposure point concentration
was considered as the 95% upper confidence limit on the arithmetic mean for each zone. As '
shown in Table 6-2 below, only one zone exhibited an HQ for arsenic greater than one for a
reasonably maximally exposed resident.
Table 6-2
Arsenic Hazard Quotients for OTJ1
for a Reasonably Maximally Exposed (RME) Resident
Zone
1
2
3
4
5
6
7
8
ALL ZONES
RMBHQ
.4
2
.3
.4
.4
1
1
.3
.6
Cancer Effects
Cancer risk is described as the probability that an exposed person would develop cancer before
age 70 as a result of exposure to site related contamination. EPA generally considers a risk below
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21
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Jacobs Smelter
Study Zones
Legend
UtfH
OUBoundvy
Sources
<; m
~*. *rK0<>
-------
1 x 10-* (i.e. one in a million) to be negligible, and risks above 1 x 10 •* (i.e. one in ten thousand)
to require some sort of intervention. Risks between 1 x 10"4 and 1 x 10"6 usually do not require
action, but this is evaluated on a case by case basis.
The BRA concluded that three zones within OU1 exceed the 1 x 10"4 standard for arsenic lifetime
cancer risk. Table 6-3 summarizes the BRA's findings.
Table 6-3
Arsenic Cancer Risks for OU1
for a Reasonably Maximally Exposed (RME)
Resident
Zone
1
::. ' :' : •':-••': vy'-^vi; '••::";'"?
i,vv'- :'.i&:"r---< ..y
3
4
5
6
7
8
ALL ZONES
Lifetime RME
Cancer Risk
8xl(T5
p;4i^i^:i":j
7xlO"s
8 x 10'5
8 x 10-5
2XW4
2x10-*
6 x 1CT5
IxlCT4
6.6 ECOLOGICAL RISK
Ecological risk was not specifically evaluated for OU1 due to the residential setting. In such a
setting, risks to residents will generally exceed any ecological risks, and as such, any remediation
required to abate human health risks will also abate any ecological risks. Ecological risk for the
entire site will be evaluated under OU2.
6.7GROUND WATER
Because the citizens of Stockton receive drinking water from a municipal system taking water
from Soldier Creek, ground water was not evaluated as a pathway for the BRA or investigated
during the RI/FFS for OU1. However, ground water is present beneath the site and soil
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contamination may serve as a source of ground water contamination. Future users of ground
water may be at risk if the ground water is impacted. As such, ground water contamination must
be considered as a potential risk. This pathway will be further evaluated under OU2, but at a
minimum, any remedy selected for OU1 should be consistent with ground water cleanup should it
be required in the future.
6.8 REMEDIAL A CJJON OBJECTIVES
The risks discussed above provide the basis for EPA's determination that the contaminated soils
in OU1 present an imminent and substantial endangerment to public health and that remedial
action is warranted. The nature of these risks, coupled with the current and future residential land
use within OU1, lead to five Remedial Action Objectives (RAOs). In accordance with the NCP,
EPA and UDEQ determined that the RAOs for OU1 are:
• Reduce risks from exposure to lead contaminated soil such that no child
has more than a 5% chance of exceeding a blood lead level of 10
micrograms per deciliter.
• Reduce risks from exposure to arsenic contaminated soil such that no
person has greater than a 1 x 10-4 chance of contracting cancer.
• Clean the site up to levels that allow for residential use.
• Remove as much contamination as practicable which could serve as source
of contamination to ground water.
• Prevent the occurrence and spread of windblown contamination.
To achieve these objectives, it is crucial to develop media specific cleanup levels which will result
in attainment. For OU1, these cleanup levels were arrived at through the use of health-based
goals.
Using the same formulas and models used to evaluate risk, EPA developed a range of preliminary
remediation goals (PRGs). These PRGs recommended a range of soil concentrations for the
COCs which would equate to risk to residents at or below acceptable levels. These ranges were
identified as 370-500 ppm for lead and 1.2-117 ppm for arsenic.
EPA and UDEQ then evaluated these PRGs, along with other risk management factors at OU1
(such as uncertainty in the risk calculations and the physical setting of the Site), and selected 500
ppm as the action level for lead and 100 ppm as the action level for arsenic. All residential yards
or vacant lots which contain mean (i.e. average) surface soil concentrations in excess of the action
levels, even those inside of zones identified as not presenting excessive risk in the BRA, will be
subject to remediation. This distinction is important, as risk for arsenic was evaluated on a "zone"
basis as opposed-to a "yard" basis. Applying the arsenic action level to each individual yard or lot
adds an extra level of protectiveness. Additionally, yards with mean subsurface soil lead
concentrations greater than 800 ppm will also be subject to remediation. These action levels are
summarized in Table 6-4.
Record of Decision 24
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Table 6-4
Surface Soil Action Levels for OUI
Contaminant
Arsenic
Lead
Action
Level
100 ppm
500 ppm
(surface)
800 ppm
(subsurface)
Comparison of the action levels with mean soil concentrations in individual properties within OUI
indicates approximately 122 properties will be subject to remediation. This figure does not
include 29 parcels with mean soil lead concentrations greater than 3,000 ppm which were
remediated during the emergency response. Of the 122 properties, only one exceeds the action
level for arsenic but does not exceed the action level for lead. All properties which may be
subject to remediation, including those addressed during the emergency response, are shown in
Figure 6-6. The exact number of properties may change slightly as a result of further sampling
during remedial design. Additionally, contaminated areas located outside of distinct properties
(such as dirt streets, alleys, and right of ways) are also subject to remediation.
Again, it is important to note that the mean soil lead concentration within a yard or lot is the
critical figure (the 95% UCL on the mean is not considered when evaluating lead risk, as
statistical uncertainty is already accounted for in the IEUBK model). This is important for two
reasons. First, it is assumed that over the life of a child (roughly 0-7 years), the child will have an
equal chance of contacting/ingesting soil across the yard, as opposed to being focused on one
area. Therefore, if the mean soil concentration for the entire yard is below the action level for
lead but certain areas of the yard are not, the property is not considered to present excessive risk
and is generally not subject to remediation. However, during the emergency response, EPA
evaluated special circumstances where this is the case, such as localized areas of highly elevated
concentrations (i.e. greater than 3000 ppm) where children frequent (i.e. play areas). These
circumstances were addressed as necessary during the emergency response. Second, in only one
instance does a lot exhibit a mean arsenic concentration exceeding 100 ppm but does not exhibit a
mean lead level exceeding 500 ppm. Therefore, with only one exception, mean soil lead
concentrations are the "driver" and mitigation of lead risk will also serve to mitigate arsenic risk.
Record of Decision
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25
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!
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7.0 REMEDIAL ALTERNATIVES
7. l DESCRIPTION OFALTERNA TIVES
This section describes the alternatives UDEQ and EPA believe are technically implementable and
potentially able to meet the remedial action objectives for the Site. These alternatives were
arrived at through a systematic screening process during the RI/FFS. In the FFS, many remedial
alternatives were screened and those that were most reasonable were retained and investigated in
detail. Using this systematic comparison, the ROD continues the evaluation and documents the
decision making process. The numbering system for the alternatives discussed in this ROD (i.e.
Alternative One, Alternative Two, etc.) is taken from the numbering of alternatives in the FFS.
All of the remedial technologies initially considered in the FFS are identified in Table 7-1.
However, only those technologies which were retained as part of the alternative development
process are described in detail in this ROD. The alternatives are:
Alternative 1: No Action
It is required by law that EPA evaluate the consequences of taking no action. This evaluation is
intended to provide decision makers and the public a basis upon which all of the remedy
alternatives may be compared. Alternative 1 would involve no remedial action beyond the
emergency response being conducted by EPA.
Alternative 2: Soil Cover with Institutional Controls
This alternative includes placing a six inch soil cover (topsoil quality) over a geotextile membrane
on all properties identified for remediation. This would involve: (1) removing and replanting
affected vegetation; (2) raising, terracing, or protecting paved sidewalks, curbs, driveways,
streets, and foundations that would be buried by an increase of six inches in adjacent soil
elevations; (3) implementing institutional controls and maintenance requirements to prevent or
control breaching of the soil cover and exposure to underlying soils; and (4) cleaning affected
homes to remove contaminated interior dust.
Alternative 3: Excavation, Soil Washing, and Reuse
This alternative involves excavation and treatment of approximately 150,000 tons of contaminated
soil from properties identified for remediation. Excavation would occur to a depth at which
average concentrations are less than 500 ppm or to a maximum depth of eighteen inches.
Excavated soils would be treated using a soil washing device to achieve action levels of 500 ppm
lead and 100 ppm arsenic. Treated soils would be amended as necessary, returned to the
excavated area, and revegetated as close to prior condition as possible. An additional 2,000 tons
of clean soil will be required to account for cobbles and metals removed during washing.
Treatment residuals may be recycled or disposed of in a suitable landfill based upon classification
Record of Decision 27
Jacobs Smelter Superfund Site
Operable Unit One
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Soil cover
Soil cap
In-situ chemical
stabilization
Excavation and
removal
Low
Low
^™^——
Medium
• —•
High
Easy
_^^_*«>«<
'Difficult
•-™.^B—•—•
Easy
Difficult
Difficult
Difficult
Moderate
Low
Medium
Medium
Medium
High
High
Medium
Notes:
k Includes excavation prior to use of listed technology
O&M Operation and maintenance
Low
Yes
No
No
Yes
Has not been used extensively
for residential properties
Not feasible for residential
properties
Not feasible for residential
properties
Cati be combined with
stabilization for highly
contaminated soils
Can be combined with chemical
separation for soil reuse
Can be combined with soil
washing
Can be combined with
excavation and removal
Stabilization easier and less
costly for same end result
-------
of the soil as hazardous or nonhazardous in accordance with Subtitle C of the Resource
Conservation and Recovery Act (RCRA). Institutional controls would be implemented to
prevent exposure to contamination remaining below eighteen inches or below existing homes.
Affected homes would be cleaned to remove contaminated interior dust.
Alternative 4: Excavation and Off-Site Disposal
This alternative involves excavation and disposal of approximately 150,000 tons of contaminated
soil from all identified properties. Excavated soil would be disposed of in a suitable landfill based
upon classification of the soil as hazardous or nonhazardous in accordance with Subtitle C of the
Resource Conservation and Recovery Act (RCRA). Soil classified as hazardous would be
solidified or stabilized using flyash or cement. Twelve inches of imported clean soil backfill and
six inches of clean topsoil would be replaced on excavated areas. The areas will be revegetated as
close to original condition as possible. Institutional controls would be implemented to prevent
exposure to contamination remaining below eighteen inches. Affected homes would be cleaned to
remove contaminated interior dust,
7,2 DETAILED ANALYSIS CRITERIA
To facilitate a complete and systematic screening (Section 7.3), each of the four alternatives
discussed in this Record of Decision is evaluated against nine criteria as set forth in the National
Contingency Plan (NCP). Of these nine criteria, the first two are considered "threshold factors"
which must be satisfactorily met in order for a remedy to be considered for implementation. The
next five criteria are considered "primary balancing factors" and are the primary criteria upon
which the analysis is based. Finally, the last two criteria (State and Community Acceptance) are
considered "modifying factors."
Threshold Factors
J. Overall Protection of Human Health and Environment
Evaluation of the overall protectiveness of an alternative focuses on whether a specific
alternative achieves adequate protection and how site risks are eliminated, reduced, or
controlled. This evaluation also allows for consideration of whether an alternative poses
any unacceptable short-term impacts.
2. Compliance-with ARARs
Laws, regulations, and ordinances from the federal, state, and local governments may be
applicable or relevant and appropriate for many matters affecting the implementation of a
remedy. These laws, regulations, and ordinances are generally referred to by EPA as
ARARs (Applicable or Relevant and Appropriate Requirements). The chemical, location,
and action specific ARARs are discussed along with any other appropriate criteria,
Record of Decision 29
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advisories, and guidance as they apply to each alternative.
Primary Balancing Factors
3. Long-Term Effectiveness and Permanence
This evaluation criterion involves consideration of potential risks that may remain after the
site has been remediated and the ability of a remedy to maintain reliable protection of
human health and the environment over time.
4, Reduction ofToxicity, Mobility, or Volume of Contaminants
There is a statutory preference for remedies that permanently or significantly reduce the
health hazards (toxicity), movement of contaminants (mobility), and quantity (volume) of
contaminants.
5. Short-Term Effectiveness
The focus of this criterion is the protection of the community, environment, and the
workers during remediation and the duration of the remediation.
6. Implementability
This criterion establishes the practical aspect of implementing an alternative.
7. Cost
The cost (capital, operation, and maintenance) of an alternative is an important, practical
criterion in evaluating potential remedies.
Modifying Factors
8. and 9. State and Community Acceptance
Community acceptance is addressed through means of a public meeting, an open public
comment period, and ongoing community participation activities. The State may concur,
oppose, or have no comment regarding the decision. These factors will be discussed only
in Section 8, Summary of the Comparison of Alternatives.
Record of Decision 3 0
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7.3 DETAILED ANALYSIS OFALTERNA WVES
7.3.1 Alternative 1-No Action
Overall Protection of Human Health and the Environment
If Alternative 1 is implemented, the human health risk at OU1 will remain as is for all properties,
except the 29 properties remediated during the EPA emergency response. As discussed in
Section 6 of this ROD, EPA has determined the existing situation presents unacceptable health
risks to residents. Therefore, Alternative 1 does not meet the threshold criterion for protection
of human health.
Alternative 1 provides no added protection of the environment. However, due to the residential
setting and lack of natural habitat, ecological risk was not specifically evaluated for OU1. Site-
wide ecological risk will be further evaluated under OU2.
Compliance with ARARs
A detailed description of ARARs identified for OU1 is given in Appendix A. The only chemical-
specific ARARs for GUI relate to the concentration of contaminants in air. It is unclear if
ambient conditions would cause exceedances of these ARARs, but it is possible. Therefore, the
threshold criterion for compliance with ARARs may not be met under Alternative 1. The
location-specific and action-specific ARARs identified in Appendix A are not applicable for this
alternative because no remedial action is involved.
Long-term Effectiveness and Permanence
The source of exposure is not removed or isolated under Alternative 1 and none of the risk to
human health would be mitigated. Although risk is being reduced by the emergency response, the
BRA indicates that the remaining risk to children will still exceed the standards discussed in
Section 6 . Therefore, Alternative 1 does not meet the threshold criterion for long-term
effectiveness and permanence.
Reduction of Toxicitv. Mobility, or Volume through Treatment
Alternative 1 contains no provision for treatment and provides no reduction of toxicity, mobility,
or volume of the contamination. Therefore, Alternative 1 does not satisfy the statutory preference
for treatment.
Short-term Effectiveness
Implementing Alternative 1 would not increase the short-term risk to the community from a remedial
action. Because there would be no remediation under Alternative 1, there is no risk to OU1
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remediation workers and no time is required to implement the alternative. The environmental impacts
under Alternative 1 remain unchanged from existing conditions. Due to these factors, Alternative 1
is considered fully effective in the short-term.
Implementability
No construction or action would be required to implement Alternative 1, making it very easy to
implement. Also, because monitoring of effectiveness is not required, it would be unnecessary to
obtain approval from other agencies, and no equipment, specialists, materials, technologies, or
services are required.
By definition, there are no capital or O&M costs associated with Alternative 1.
7.5.2 Alternative 2 - Soil Cover With Institutional Controls
Overall Protection of Human Health and the Environment
A soil cover would greatly reduce direct contact, ingestion, and inhalation of the contaminants
and, therefore, would reduce human health risk to acceptable levels. The soil cover and
vegetation layer also reduces the spread of contamination into the environment through erosion
and deposition. However, all of the contaminated soil is left in place and may become exposed if
the cover is breached through excavation, erosion, or construction below the cover layer. Six
inches of cover is generally not considered protective for normal residential activities such as
gardening and landscaping. Therefore, the alternative is very dependent on institutional controls
and only marginally satisfies the threshold criterion for protection of human health.
Alternative 2 provides some protection of the environment. However, due to the residential
setting and lack of natural habitat, ecological risk was not specifically evaluated for OU1. Site-
wide ecological risk will be further evaluated under OU2.
Compliance with ARARs
Alternative 2 would meet chemical-specific air quality ARARs unless a breach in the cover
occurs. It is unclear if a breach would cause exceedances of these ARARs, but it is possible.
Institutional controls would be implemented to ensure breaches are minimized and do not cause
exceedances of air quality ARARs. Monitoring for attainment of chemical-specifc air quality
ARARs would be conducted during construction. Attainment of action-specific (such as those for
dust suppression) and location-specific ARARs would also be required during construction.
Therefore, the threshold criterion for compliance with ARARs is met by Alternative 2.
Record of Decision 52
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Long-term Effectiveness and Permanence
Alternative 2 relies on a six inch soil cover and a geotextile to provide a barrier between the
potential receptors, especially small children, and the existing lead- and arsenic-contaminated soil.
However, all of the contaminated soil remains in place, leaving residual contamination below the
6-inch depth of the cover.
Institutional controls, such as environmental easements and town ordinances, would be
implemented to prevent exposure to contamination below the existing cover of clean soil.
However, this cover could easily be breached during normal residential activities such as
gardening and landscaping, making institutional controls difficult to enforce and a limitation to
property owners. In addition, garden vegetables with roots extending below the geotextile might
contain high levels of lead or arsenic contamination, though this pathway was considered
incomplete (i.e. doesn't present any significant risk) in the BRA. Therefore, a public education
campaign may also be required to prevent new residents from inadvertently breaching the integrity
of the soil cover and creating new exposure pathways. If contaminated soil is exposed in an
excavation, the homeowner may be responsible for its disposal in a hazardous waste landfill.
Reduction of Toxicitv. Mobility, or Volume through Treatment
In the soil cover alternative, no treatment process is used; therefore, no contamination is
destroyed or treated. Alternative 2 provides no reduction of either toxicity or volume, but does
reduce the mobility of the contaminants to wind and water erosion by isolating the contamination.
However, since no treatment is used, Alternative 2 does not satisfy the statutory preference for
treatment.
Short-term Effectiveness
No residents would be relocated during implementation of Alternative 2, but house interiors would
be cleaned after remediation is completed. When required, Level C protection for construction
workers would be implemented to prevent inhalation or ingestion of lead- or arsenic-contaminated
soil and dust. Dust generated during construction could create an environmental impact, but State
and Occupational Safety and Health Administration (OSHA) regulations governing dust suppression
would be enforced. The time required to implement Alternative 2 is estimated at approximately one
and a half years.
Implementability
Standard soil excavation, hauling, backfilling, and grading techniques are used during construction
of Alternative 2. Tree and shrub clearing and grubbing, geotextile placement, cover soil placement
and grading, and revegetation contractors can be acquired locally without the need for highly
specialized remediation personnel. The construction equipment, specialists, materials,
technologies, services, and capacities needed are readily available from several Utah vendors.
Record of Decision 33
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Approximately 45,500 tons of soil would be required for the six inch soil cover. Soil excavated
below the geotextile in planting trees and shrubs during post-remediation landscaping, estimated
at approximately 1,000 cubic yards, would be hauled to a hazardous waste landfill.
The soil cover alternative is made more difficult to implement due to the difficulty in adjusting the
height of structures and paved areas, especially basements, window wells, driveways, sidewalks,
and patio slabs, to maintain positive drainage. Also, if additional remediation were required after
construction of Alternative 2 is complete, the new remedial action would destroy the original
remedy. Annual monitoring would be required to give notice of any failure of the remedy before
significant exposure occurs. Intensive coordination with local agencies will be required to provide
the necessary institutional controls and annual monitoring will require a significant commitment of
State resources.
Cost
The costs to implement Alternative 2 are estimated at $6,219,912 for capital costs and $561,962
for 30 years of O&M, which includes annual monitoring, maintenance and reporting costs of
$19,378. The capital cost includes purchase and placement of 1.3 million square feet of geotextile
at a cost of $0.50 per square foot. These capital and O&M costs combine for a total present
worth cost of $6,453,000.
7.3.3 Alternative 3 - Excavation, Soil Washing, and Reuse
Overall Protection of Human Health and the Environment
Excavation and removal of contaminated soil from each residential property would automatically
reduce the risk of direct contact, inhalation, or ingestion of the contaminated soil and, therefore,
reduce human health risk. Soil washing and chemical extraction would further reduce the
potential for migration and future direct contact, ingestion, and inhalation of the contaminants
because the heavy metals are entirely treated or recycled. The eighteen inches of clean soil
backfill and vegetation layer would also reduce the spread of contamination into the environment
through wind and water erosion. Therefore, Alternative 3 meets the threshold criterion for
protection of human health.
Alternative 3 provides a high degree of protection of the environment. However, due to the
residential setting and lack of natural habitat, ecological risk was not specifically evaluated for
OU1. Site-wide ecological risk will be further evaluated under OU2.
Compliance with ARARs
Alternative 3 would meet chemical-specific air quality ARARs because contamination would be
covered by eighteen inches of clean fill and not exposed to wind. Monitoring for attainment of
chemical-specific air quality ARARs would be conducted during construction. Attainment of
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action-specific (such as those for dust suppression) and location-specific ARARs would also be
required during construction. Therefore, the threshold criterion for compliance with ARARs is
met by Alternative 3.
Long-term Effectiveness and Permanence
Alternative 3 would provide a high degree of long-term effectiveness and permanence.
Excavation and treatment of all contaminated soils would minimize the chance of future exposure
to the heavy metals. The only residual risk from lead- and arsenic-contaminated soil in Alternative
3 would come from the contamination remaining below eighteen inches. However, eighteen
inches of clean backfill is considered protective of normal residential activities. Minimal
institutional controls would be required to prevent exposure to residual contamination remaining
below eighteen inches, such as those occurring during significant construction or excavations.
Few restrictions would be placed on property owners and the institutional controls would be fairly
easy to enforce provided resources remain available.
Contamination would be treated and disposed or recycled, making the possibility of future
migration of contaminants minimal.
Reduction of Toxicitv. Mobility, or Volume through Treatment
Alternative 3 satisfies statutory preference for treatment of the contaminated soil. The treatment
process extracts lead and arsenic from soil by separating the uncontaminated coarse fraction of
the soils from the contaminated fine fraction by soil sizing and washing. The fine fraction is then
treated with chemicals to transfer the contaminants to the residual water. This water is then
further treated through precipitation to remove the metals. The amount of soil treated is
estimated at" 140,000 tons. This process reduces the toxicity, mobility, and volume of the
contaminated soil to a maximum residual of 2,000 tons of metal precipitates to be reprocessed or
sold. The treatment process is irreversible and the washed soils, less the coarse gravel fraction,
would be reused as a major part of the backfill for the excavated yards of Stockton.
Short-term Effectiveness
No residents would be relocated during implementation of Alternative 3, but house interiors
would be cleaned after remediation is completed. When required, Level C protection for
construction workers would be implemented to prevent inhalation or ingestion of lead- or arsenic-
contaminated soil and dust. Dust generated during construction could create an environmental
impact, but State and Occupational Safety and Health Administration (OSHA) regulations
governing dust suppression would be enforced. The time required to implement Alternative 3 is
estimated at approximately one and a half years.
Implementabilitv
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Standard soil excavation, hauling, backfilling, and grading techniques are used to excavate, haul,
backfill, and grade the soils for Alternative 3. The construction equipment, specialists, materials,
technologies, services, and capacities needed for this portion of the alternative are readily
available from several Utah vendors. However, the soil washing and metals separation
technologies required for this alternative are not readily available and require specialized vendors.
If additional remediation is required after construction of Alternative 3 is complete, the new
remedial action would not impact the original remedy. Also, some minor coordination with local
agencies would be required to provide the necessary institutional controls. Some coordination
with state and federal agencies would also be required to obtain approval of a suitable soil
washing/metals separation process for the lead- and arsenic-contaminated soil. Disposal of some
soil excavated for the planting of trees and shrubs during post-remediation landscaping in a
hazardous waste landfill or TCLP testing and stabilization/fixation of this soil may be required
unless the soil washing/metals separation equipment remains at the site until this work is
completed.
Cost
The costs to implement Alternative 3 are estimated at $52,383,000 for capital costs and $141,270
for 30 years of O&M. This O&M cost includes only an annual report, at $4,709 per year,
documenting compliance with institutional controls in Stockton. These capital and O&M costs
combine for a total present worth cost of $52,445,000.
7.3.4 Alternative 4 - Excavation and Off-Site Disposal
Overall protection of Human Health and the Environment
Excavation and disposal of contaminated soil from each residential property would automatically
reduce the risk of direct contact, inhalation, or ingestion of the contaminated soil and, therefore,
reduce human health risk. Soil stabilization and landfill disposal would further reduce the
potential for migration and future direct contact, ingestion, and inhalation of the contaminants
because the heavy metals are partially treated and entirely disposed of in an appropriate landfill.
The clean soil backfill and vegetation layer would also reduce the spread of contamination into the
environment through wind and water erosion. Therefore, Alternative 4 meets the threshold
criterion of protection of human health and the environment.
Alternative 4 provides a high degree of protection of the environment. However, due to the
residential setting and lack of natural habitat, ecological risk was not specifically evaluated for
OU1. Site-wide ecological risk will be further evaluated under OU2.
Compliance with ARARs
Alternative 4 would meet chemical-specific air quality ARARs because contamination would be
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covered by eighteen inches of clean fill and not exposed to wind. Monitoring for attainment of
chemical-specifc air quality ARARs would be conducted during construction. Attainment of
action-specific (such as those for dust suppression and land disposal restrictions) and location-
specific ARARs would also be required during construction. Therefore, the threshold criterion
for compliance with ARARs is met by Alternative 4.
Long-term Effectiveness and Permanence
Excavation and disposal of contamination in an appropriate landfill provides a high level of long-
term effectiveness and permanence. Stabilization of soils classified as hazardous under
Alternative 4 should be very successful because the results of the geotechnical testing (Appendix
C of the RI) indicate that the percentage of sand and gravel (soil particles with a diameter greater
than 0.074 millimeters) in OU1 soils is approximately 100 percent. Soil pH averages 8.7 for 19
samples, with a range from 8.0 to 9.3. The average total organic carbon content is approximately
30,000 mg/kg, with a range from 14,000 to 65,000 mg/kg from 20 geotechnical samples. The
ranges of values are confirmed by the parameters found in the Tooele County soil survey
discussed in Section 2.4 of the RI. These parameters make the likelihood of success for
stabilization very high.
The only residual risk from lead- and arsenic-contaminated soil in Alternative 4 would come from
the contamination remaining below eighteen inches. However, eighteen inches of clean backfill is
considered protective of normal residential activities. Minimal institutional controls would be
required to prevent exposure to residual contamination remaining below eighteen inches. Few
restrictions would be placed on property owners and the institutional controls would be fairly easy
to enforce provided resources remain available.
Reduction of Toxicitv. Mobility, or Volume through Treatment
In Alternative 4, no treatment process is used for soils which are classified as nonhazardous under
RCRA Subtitle C. Therefore, no contamination would be destroyed or treated for this fraction of
the excavated soils, which is about 114,000 tons. However, soils with a TCLP lead level greater
than 5 mg/L would be stabilized with flyash or cement before disposal. These stabilization
materials reduce both mobility and toxicity of contaminants in the excavated soil, but increase the
volume by less than 10 percent. The amount that would be treated is estimated at 36,000 tons
before treatment.
Alternative 4 provides no reduction of volume for any of the excavated soils, but further reduces
the mobility of the contaminants by placing the soil in a permitted RCRA-solid or -hazardous
waste facility. For those soils that are stabilized, the volume would increase slightly, but the
treatment process is irreversible and the treatment residuals that remain would be contained in a
RCRA landfill. Therefore, Alternative 4 does not satisfy statutory preference for treatment for all
of the excavated soil, but does partially satisfy the requirement.
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Short-term Effectiveness
No residents will be relocated during implementation of Alternative 4, but house interiors would
be cleaned after remediation is completed. When required, Level C protection for construction
workers would be implemented to prevent inhalation or ingestion of lead- or arsenic-contaminated
soil and dust. Dust generated during construction could create an environmental impact, but
State and Occupational Safety and Health Administration (OSHA) regulations governing dust
suppression would be enforced. The time required to implement Alternative 4 is estimated at
approximately one and a half years.
Implementability
Excavation and off-site disposal is a relatively simple process with proven procedures. It is a
labor-intensive practice with little potential for further automation. Standard soil excavating,
hauling, backfilling, and grading techniques are used in Alternative 4. The construction
equipment, specialists, materials, technologies, services, and capacities needed are readily
available from several Utah vendors. Soil excavated for the planting of trees and shrubs during
post-remediation landscaping may be transported to a hazardous waste landfill for disposal, and
toxicity testing and stabilization/fixation of this soil may be required. Significant coordination
with local, state, and federal agencies will be required to obtain approval of a landfill suitable for
disposal of the contaminated soil.
If additional remediation were required after construction of Alternative 4 is complete, the new
remedial action would not destroy the original remedy. However, any soil removed from below a
depth of up to 18 inches in formerly contaminated properties or contaminated streets, alleys, and
public right of way should be tested for toxicity and sent to an appropriate landfill for disposal.
Some minor coordination with local agencies would be required to provide the necessary
institutional controls.
Capital costs are estimated at $13,627,649 for Alternative 4 and O&M costs are estimated at
$141,270. The annual O&M cost includes only an annual report, at $4,709 per year,
documenting compliance with institutional controls in Stockton. These capital and O&M costs
combine for a total present worth cost of $13,689,000.
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8.0 SUMMARY OF THE COMPARISON OFALTERNA TIVES
A comparative analysis is conducted to evaluate the relative performance of each alternative in
relation to each specific evaluation criterion. This is in contrast to the detailed analysis of
alternatives in Section 7, in which each alternative was analyzed independently without
consideration of other alternatives. The purpose of this comparative analysis is to identify the
advantages and disadvantages of each alternative relative to one another. Table 8-1 summarizing
the comparison is located at the end of this section.
Overall Protection of Human Health and the Environment
Alternative 1 provides no additional human health or environmental protection over that
accomplished by the EPA emergency response and does not provide a sufficient level of
protection to mitigate the risks described in Section 6. Alternative 2 provides slightly more
protection due to the addition of a six inch soil cover over the contaminated soil, but does not
reduce any existing soil lead or arsenic levels. Alternative 3 provides the greatest protection
because it removes contaminated soil to a depth of eighteen inches and treats 100 percent of the
excavated soil and produces only recyclable metals and clean, reusable soil. Alternative 4
provides equal human health protection to Alternative 3 because it removes contaminated soil to
an equal depth, but is less protective of the environment because only 25 percent of the soil is
treated and placed in a landfill, while the other 75 percent receives no treatment. However, the
percentage treated in Alternative 4 is the most highly contaminated portion, which contains much
more than 25 percent of the total contaminant mass. Due to the lack of natural habitat within
OU1, all remedies evaluated for OU1 are considered protective of the environment. Ecological
risk will be further evaluated under OU2. Alternatives 3 and 4 provide the highest level of
protection of the environment, Alternative 2 offers some added protection, and Alternative 1
offers no additional protection over current conditions.
Compliance with ARARs
All of the alternatives except Alternative 1 comply with ARARs.
Long-term Effectiveness and Permanence
Alternative 1 provides no means of mitigating risk over the long-term and is ineffective.
Alternative 2 provides a higher level of protection, though the institutional controls required to
make it effective and permanent over the long-term would be difficult to enforce and a burden to
property owners. Alternative 3 provides the greatest amount of long-term effectiveness and
permanence, because all excavated soils would be treated. Altervative 4 provides a similar
degree of long-term effectiveness and permanence as Alternative 3, with the exception that some
of the excavated soil would be placed untreated into a landfill which requires long-term
management.
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Reduction of Toxicity, Mobility, or Volume Through Treatment
Alternatives 1 and 2 provide no treatment and no reduction of toxicity or volume of the
contaminated soil, are reversible, and do not comply with the statutory preference for treatment.
However, Alternative 2 provides some reduction in mobility through reduction in erosion
potential by wind and water. Alternative 3 provides treatment of 100 percent of the excavated
contaminated soils, is irreversible, leaves only recyclable metals as residuals, and complies with
the EPA preference for treatment. Alternative 4 treats the most highly contaminated soil,
approximately 25 percent of the total quantity excavated; disposes of all of the excavated soil in a
RCRA-approved landfill; and is irreversible. However, Alternative 4 only partially complies with
the statutory preference for treatment.
Short-term Effectiveness
Alternative 1 does not impact the community, workers, or the environment during remediation
because there is no remedial action. Therefore, this alternative has the least amount of short-term
impacts. Of the three other alternatives, Alternative 2 generates the least traffic, least dust, and
fewer impacts to the community and to workers because it involves no excavation. Therefore, it
has greater short-term effectiveness than either of the excavation alternatives (Alternatives 3 and
4). Alternative 3 has the potential for slightly more impact to the community and to remediation
workers than Alternative 4 because the soil washing operation will be done in the community,
whereas soil disposal in Alternative 4 will be done outside the community. If stabilization/fixation
of the Alternative 4 soils is accomplished at OU1, instead of at the landfill, it will still impact the
community less than Alternative 3 because fewer tons of soil will be treated and fewer truckloads
of soil will be double handled. The time required to complete the remedial action is
approximately the same for Alternatives 2, 3, and 4.
Implementability
Alternative 1 is the easiest alternative to implement technically because nothing will change from
the past emergency response conditions at OU1. Alternative 2 is the second most easily
implemented alternative technically because the necessary remediation equipment and personnel
are readily available in Utah. However, this alternative will be extremely difficult to implement
administratively because a strict, long-term health and compliance monitoring program is required
to maintain its protectiveness. Alternative 3 is the most difficult to implement technically because
the technology, services, specialized personnel, and equipment are not available in Utah or
neighboring states. Administratively, Alternative 3 should be the easiest to implement because the
soil is entirely treated and reused, reducing the concerns of regulatory agencies and requiring
considerably less long-term maintenance than Alternative 2. Alternative 4 is the third easiest
alternative technically, but second administratively, because it can be accomplished using locally
available personnel and equipment, it removes all of the contaminated soil from the community,
and it incorporates the same administrative maintenance requirements as Alternative 3. Additional
remediation will have dramatic impacts on Alternative 1 and Alternative 2 and will have less
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serious, but equivalent, impacts on Alternatives 3 and 4.
Cost
By definition, the capital and O&M costs for Alternative 1 are zero, making it the least costly.
The capital cost for Alternative 2 is the second least expensive, approximately $6 million, but the
long-term O&M costs are the highest at $562,000 for 30 years (see Table 11-2). Alternative 3
has by far the highest capital cost at approximately $52 million, and the same O&M costs as
Alternative 4—$141,000 for 30 years. Alternative 4 has capital costs 1/4 the comparable costs
for Alternative 3, approximately $13.5 million, making the present worth cost of Alternative 3
approximately $52.5 million and that of Alternative 4 approximately $14 million.
State Acceptance
The Utah Department of Environmental Quality is the lead agency for the Site and prefers
Alternative 4.
Community Acceptance
The community indicated acceptance Alternative 4 as the selected remedy during several town
forum meetings and the public meeting. No comments opposing the selected remedy were
received.
A summary of the comparative analysis for the threshold and balancing criteria using a number
ranking system is presented in Table 8-1. The table uses a number evaluation scale, with 1 being
the best and 4 being the worst. The numerical ranking shows Alternatives 3 and 4 rank similarly;
however, the cost of Alternative 4 is much lower than that of Alternative 4. A summary of costs'
for the four remedial alternatives is presented in Table 8-2.
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Table 8-1
Comparative Analysis of Alternatives
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OVERALL PROTECnVENESS
Human health
Environmental protection
4
4
3
3
1
1
1
2
COMPLIANCE WITH ARARS
Chemical-specific ARAR
Localion-speciGc ARAR
Action-specific ARAR
Other criteria/guidance
4
4
4
4
3
3
3
3
1
1
1
1
1
]
2
1
LONG-TERM EFFECTIVENESS AND PERMANENCE
Magnitude of residual
risk
Adequacy and reliability
decontrols
A
4
3
3
1
1
2
2
REDUCTION OF TOXIOTY, MOBILITY, VOLUME
Treatment process used
Amount destroyed or
treated
Reduction oftodcitv,
mobility, or volume
Irreversible treatment
Type and quantity or
residuals remaining after
treatment
Statutory preference for
treatment
4
4
4
4
4
4
4
4
3
3
4
4
1
1
1
1
1
1
2
2
2
2
3
2
SHORT-TERM EFFECTIVENESS
Community •protection
Worker protection
Environmental impacts
Time until action is
complete
IMPLEMENTABILrrY
Ability to construct and
operate
Ease of additional
remediation, if needed
Ability to mom tor
effectiveness
Ability to obtain approval
from other agencies
Availability of services
and capacities
Availability of equipment,
specialists, materials
Availability of technolow
COST
Capital
30-year O&M Cost
Present worth cost
RANKING TOTALS
1
1
1
1
1
1
1
4
1
1
1
1
1
1
73
2
2
2
2
2
4
4
3
2
2
2
2
4
2
81
4
4
4
2
4
3
2
1
4
4
4
4
2
4
60
3
3
3
2
3
3
2
2
2
2
2
3
2
3
60
-------
Table 8-2
Summary of Remedial Alternative Costs
Alternative
1 - No Action
2 - Soil Cover
with Institutional
Controls
3 - Excavation,
Soil Washing,
and Reuse
4 - Excavation
and Disposal
Total Capita}
Cost in 1999
Dollars
$0
$6,219,912
$52,383,447
$13,627,649
Estimated
Yearly O&M
Cost in 1999
Dollars
$0
$19,378
$4,709
$4,709
Duration
of O&M
NA
29 years
30 years
30 years
Total
O&M
Costs
$0
$581,340
$141,270
$141,270
Total O&M
Present
Worth Cost1
$0
$233,481
$61,451
$61,451
Total Cost
in 1999
Dollars'
$0
$6,453,393
$52,444,898
$13,689,100
1. A discount rate of 5% and an inflation rate of 1.6-2.1% were used to calculate present worth (1999) O&M costs
Rates were taken from Economic Analysis Reference Guide. Army Military Construction (USAGE 1999)
2. Total costs accurate to within -30 to +50%.
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9.0 EXCA VATIONAND DISPOSAL - THE SELECTED REMEDY
9.1 DESIGNATION OF THE SELECTED REMEDY
Based upon the results of the systematic screening process described above, UDEQ and EPA
agree that Alternative 4, Excavation and Disposal, most completely satisfies the analysis criteria
and is designated as the selected remedy for OU1. While both Alternatives 3 and 4 score similarly
in the ranking process, only Alternative 4 is both sufficiently protective of human health and the
environment and cost-effective. Additionally, Alternative 4 is preferred by both the State of Utah
and the local community. This remedy has been used successfully at a number of similar lead sites
in Utah and throughout Region 8. The remedy will be considered complete when the following
four performance measures, or key components, are accomplished:
Excavate soils within OU1 exhibiting (1) mean surface lead concentrations greater
than 500 ppm, (2) mean subsurface lead concentrations greater than 800 ppm, or
(3) mean surface arsenic concentrations greater than 100 ppm. Excavation will
occur to a depth at which mean concentrations are below 500 ppm lead and 100
ppm arsenic or to a maximum depth of eighteen inches. Affected properties
include residential yards, vacant lots, rights of way, and unpaved streets and
sidewalks. Test excavated material for characterization as hazardous waste. If
material is classified as hazardous waste, treat off-site using fly-ash or cement
stabilization and dispose of in an off-site, RCRA Subtitle C landfill. If material is
classified non-hazardous waste, dispose of in an off-site, RCRA Subtitle D landfill.
Replace the excavated soil with up to twelve inches of clean backfill and six inches
of clean topsoil. Re-landscape affected properties.
• Clean the interior of affected properties to remove any previously contaminated
indoor dust.
1
• Develop and implement institutional controls to restrict exposure to residual
contamination below eighteen inches or below existing structures.
These four performance standards will ensure the RAOs are met by removing the principle
threat wastes (contamination above eighteen inches) and providing controls to protect against
exposure to any remaining low-level threat wastes (contamination below eighteen inches or
below existing structures). The remedy would be consistent with any ground water remedy
required under OU2, as removal of the contaminated soil to a depth of eighteen inches will
prevent migration of these contaminants to ground water. Contamination below eighteen
inches represents only a very small percentage of overall volume at the site, so protection of
ground water does not depend upon removal of this small percentage.
Record of Decision - Decision Summary 44
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9.2 IMPLEMENTATION OF THE REMEDY
The remedy will be implemented following remedial design activities. During design, each
affected property owner will be consulted regarding the current and post remedial condition of
their property. Affected properties are shown in Figure 6-6. Soil will not be removed from
below existing concrete or asphalt structures, such as improved driveways or sidewalks. Soils
will not be removed from below existing homes or from crawl spaces or basements. Wherever
dirt floors exist and contamination above the action levels is identified, these dirt floors will be
covered with a concrete slab to prevent exposure. Properties will be left in, or returned, to as
close to original condition as possible, except in the cases in which (1) the property owner desires
differently and there is no appreciable increase to the government in either costs or effort, and (2)
it is unsafe to return the property to original condition. Physical construction will be considered
complete when all properties and areas identified for remediation have been addressed and
returned to satisfactory condition. Property owners will receive an assurance that construction
and vegetation are warrantied for one year. Following construction, all homes affected by the
remediation will be thoroughly cleaned to remove any contaminated dust. The physical
construction involved in the remedial action is expected to take approximately one and a half
years.
During excavation, sampling will be conducted to identify properties with contamination above
500 ppm lead or 100 ppm arsenic remaining below eighteen inches or existing structures. Using
this information, a suitable Institutional Control Plan will be developed in conjunction with State
and local governments. The purpose of the institutional controls will be to restrict exposure to
residual contaminated soils below eighteen inches or below existing structures. UDEQ is
ultimately responsible for implementing this plan, though local governments may be the actual
implementing agency. At this time, it is considered too early to develop details of such a plan.
Sampling will be conducted in coordination with the selected landfill to determine which soils are
classified as hazardous waste under RCRA Subtitle C using the Toxicity Characteristic Leaching
Procedure and guidelines established in SW-846, Update Three (USEPA 1997). Based upon
previous sampling, it is estimated that less than 1% of the excavated soil will be classified as
hazarardous waste.
A detailed cost estimate for the selected remedy is given in Appendix B.
9.3 EXPECTED OUTCOMES OF THE REMEDY
Implementation of the remedy will allow for residential use within OU1. Future health risks due
to lead or arsenic in soils will be reduced to acceptable levels and the health of the community
with regards to these risks should improve. Property values are expected to increase as the
stigma of contamination is removed. New landscaping should also improve property values and
the overall appearance of Stockton. Residents will be able to conduct normal landscaping
activities without fear of contacting contamination.
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Institutional controls will impart a minor burden, as major excavation activities such as removing
driveways, adding basements, or other deep digging will require working with the appropriate
government agency and using management practices to protect against exposure.
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10.0 STATUTORY DETERMINATIONS
The selected remedy must satisfy requirements set forth in the National Contingency Plan (NCP),
40 CFR 300.430(f). In accordance with these requirements the selected remedy must:
Provide for the overall protection of human health and the environment and
comply with ARARs (unless specific ARARs are waived).
Be cost effective (meaning the costs are proportional to the overall effectiveness,
where overall effectiveness accounts for long-term effectiveness, short-term
effectiveness, and reduction in toxicity, mobility, and volume).
Use the to the maximum extent practicable permanent solutions employing
treatment and/or resource recovery technologies. This requirement is fulfilled by
selecting an alternative that satisfies the threshold criteria (overall protection of
human health and the environment, compliance with ARARs), provides the best
balance of the five balancing criteria (long-term effectiveness; short-term
effectiveness; and reduction in toxicity, mobility, or volume; implementability; and
cost) and considers preference for treatment as a principal element of the
remediation with a bias against off-site land disposal of untreated waste.
Based on these requirements and the following key considerations from the Detailed Analysis of
Alternatives, both EPA and UDEQ agree that Excavation and Off-site Disposal meets all
statutory requirements in the NCP except the preference for treatment:
The selected remedy will satisfy all ARARs as well as provide a high level of
protectiveness for human health and the environment.
The selected remedy provides a similar level of overall effectiveness as Alternative
3 at roughly 1/4 the cost. Alternatives 1 and 2 do not provide sufficient overall
protection or effectiveness.
Few effective treatment technologies exist for heavy metals and those that do are
not cost effective when compared to the selected remedy. The benefits gained for
OU1 through the use of treatment do not justify an additional expenditure of
roughly 39 million dollars. Additionally, under the selected remedy, all excavated
wastes which are classified as hazardous will be treated prior to land disposal,
resulting in partial attainment of the preference for treatment.
CERCLA Section 121(c) requires that five-year reviews be conducted if the remedial action
results in hazardous substances remaining on-site above levels that allow for unlimited use and
unrestricted exposure. The review evaluates whether a remedy continues to provide adequate
protection of human health and the environment. Because contamination above the action levels
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will be left in place below eighteen inches, five year reviews will be required for OUI to ensure
the institutional controls are functioning as intended.
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11.0EXPLANATION OF SIGNIFICANT CHANGES
No significant changes exist between the Proposed Plan and this ROD.
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REFERENCES
ATSDR. 1991. Agency for Toxic Substances and Disease Registry. lexicological profile for
arsenic. Atlanta, GA.
CDC. 1991. Centers for Disease Control. Preventing lead poisoning in young children. A
statement by the CDC - October. U.S. Department of Health and Human Services. Public Health
Service.
ISSI Consulting Group, Inc. 1999a. Biomonitoring Investigation, Jacobs Smelter, Stockton,
Utah. Prepared for USEPA Region Vin, February.
ISSI Consulting Group, Inc. 1999b. Baseline Human Health Risk Assessment, Jacobs Smelter
Site, Stockton, Utah. Prepared for USEPA Region VUI, June.
URSGWC. 1999. URS Greiner Woodward Clyde. Remedial Investigation/Focused Feasibility
Study, Jacobs Smelter OU1, Stockton, Utah. Prepared for Utah Department of Environmental
Quality, May.
USAGE, 1999. U.S. Army Corps of Engineers. Economic Analysis Reference Guide, Army
Military Construction, April.
USEPA, 1991. U.S. Environmental Protection Agency, Office of Solid Waste and Emergency
Response. Human Health Evaluation Manual, Supplemental Guidance: "Standard Default
Exposure Factors." Washington, D.C. OSWER Directive 9355.0-30.
USEPA, 1997. Test Methods for Evaluating Solid Waste, Laboratory Manual, SW-846, 3rd
Edition, Update 3, June.
Record of Decision - Decision Summary
Jacobs Smelter Superfwd Site
Operable Unit 1
-------
APPENDIXA
DETAILED ANALYSIS orARARs
-------
-------
EVALUATION OFARARs
To assist with the selection and implementation of the selected remedy, an evaluation of state and
federal requirements was conducted to identify ARARs for OU1. The ARARs evaluation is a
two-part process to determine (1) whether a given requirement is applicable and, if it is not
applicable, then (2) whether it is both relevant and appropriate.
1. Applicable requirements are cleanup standards and environmental protection regulations per
federal or state law that specifically address a hazardous substance, contaminant, remedial action,
location, or other circumstance at a CERCLA site.
2. Relevant and appropriate requirements are cleanup standards and environmental protection
regulations per federal and state law that do not directly and fully address a specific hazardous
substance, contaminant, remedial action, location, or other circumstance at a CERCLA site, but
address problems or situations similar to those encountered at the CERCLA site.
CERCLA actions may have to comply with several types of requirements. For this reason,
ARARs are typically divided into three categories:
1. Chemical-specific ARARs are regulatory health or risk associated numerical values that
govern acceptable concentrations of a chemical in different matrices, such as air, water, or soil.
The most stringent standard should be used in the event a chemical has more than one '
requirement.
2. Action-specific ARARs are determined according to the specific technologies or activities
taking place under each alternative.
3. Location-specific ARARs are determined according to site-related characteristics such as
flood plains, wetlands, sensitive ecosystems and habitats, and historic places.
Additionally, "To Be Considered" Criteria (TBCs) are proposed standards, advisories, and
guidance developed by federal and state regulators that are intended to provide useful information
and recommendations but are not legally binding.
The following tables identify the chemical, action, and location-specific ARARs for OU1 as well
as TBC criteria used in evaluating and selecting the preferred alternative.
-------
Chemical-Specific ARARs
Clean Air Act
42 USC §7401-7642
Applicable
National Ambient Air Quality Standards
40CFRPart50
Applicable
Utah Air Conservation Act:
• Fugitive emissions and fugitive dust
• NAAQS standards
• Visible emissions standards
19-2 UCA
UAC R307-205
UAC R307-405
UAC R307-201
Applicable
Notes:
CER
UAC
UCA
USC
Code of Federal Regulations
Utah Administrative Code
Utah Constitution Amended
United States Code
l:\dt\wp\udcq\jmcobs\ffs\ruuJ\Uble8-l.doc
-------
specific ARARs
Atdoo
iolid and
hazardous
waste
definitions
Groundwater
protection
Must meet requirements of Utah
Groundwater Quality Protection Rules
(19-5UCA)
Contaminated soils left in place or
removed are defined in the
regulations.
Alternatives must be designed to be
protective of ground water;
• Residual contamination must not
represent a leaching threat to
groundwater.
• Treatment process discharges that
may impact groundwater must
meet groundwater quality
protection requirements.
UACR315-1
UACR3IS-2
UACR3I7-6
Applicable
Applies to all alternatives
Applicable
Applies to all alternatives
Air
missions
Construction
Quality
Assurance
(QA) Plan
Must meet requirements of Utah Air
Conservation Act (19-2 UCA):
• Fugitive emissions and fugitive dust
• NAAQS standards
• Visible emissions standards
Alternatives must be designed to be
protective of air quality and
minimize fugitive dust and
emissions.
UAC R307-205
UAC R307-405
UAC R307-20I
Construction QA program general
facility standards required of all waste
piles and landfills.
-Waste piles and landfills constructed
after 1992 must meet all design
criteria and specifications in the
permit.
•CQA officer must be a registered
professional engineer.
40CFR264.I9
UACR3I5-8-2.IO
Applicable
Applies to all alternatives
Relevant and
appropriate
One alternative leaves
contaminated soil in place
and covers it with clean soil.
Two other alternatives may
use temporary stockpile*.
General
closure
General requirements to be considered in
establishing cleanup standards under
Cldump and Risk-Based Closure
Standards Policy for CERCLA and UST
Sites.
Must establish risk-based cleanup
and closure standards at GUI for
remediation or removal of
contaminated soil to background
levels.
UAC R31 1-211
UACR315-10I
Applicable
Applies to the remedial
alternatives at OUI pursuant
to CERCLA.
Excavation Placement on or in land outside area of
contamination wilt trigger land disposal
requirements and restrictions.
Movement of excavated materials to new
location and placement in or on land will
trigger land disposal restrictions for the
evacuated waste or closure requirements
Tor the landfill in which the waste is
being placed.
Materials containing RCRA-
hazardous waste subject to land
disposal restrictions are placed in a
landfill. '
40CFR26g(SubpartD)
40CFR268(SubpartD)
UACR315-I3-1
Applicable
Applies to removal
alternatives.
I:\dt\wp\udeq\jacobs\rfs\final\table8-2.doc
-------
AclRn-Speclfic ARARs
• 'Aciloflf'*1
Locution
standards for
lazardouj
waste facilities
Operation and
maintenance
Surface water
control
Waste pile
storage
'niJc storage
Container
storage
IJFDES
standards
Waste
treatment
azardous
waste
Rcneralnr
•T,«* X ^i,^M&teSia^1^^^
Location ofnew disposal facilities must includ
geologic and hydrologic investigations.
30-yeor post-closure care to ensure that aile is
maintained and monitored.
'revent run-en nnd control and collect runoff
rom a 24-hour, 25-year storm (waste piles,
and treatment facilities, and landfills)
Wuslc temporarily placed in wast* pile lo use a
double-liner and locliule collection system
.iquid waste temporarily placed in a lank
luring treatment
Waste temporarily placed in a storage container
r roll-on, roll-off container during treatment or
n storage before shipment to a landfill.
Apply to discharge lo POTW or surface water
Treatment of restricted hazardous wastes prior
o land disposal must attain concenlration-
aseJ or technology-based treatment standards.
Requirements apply to all hazardous waste
emovedfromOUl.
Location ofnew dtspostl facilities must include
•Seismic safely Investigation
•Floodplaln determination
•Salt dome mid salt bed determination
•Underground mine and cave location
Land disposal closure.
RCRA-hazardotis waste treated, stored, or
disposed after the effective date of (he
requirements.
RCRA-hazardous, non-containerized
accumulation of solid, nonflammable hazardous
waste that is used for treatment or storage.
RCRA-hizardoui, accumulation of liquid
nonflammable hazardous waste in a tank that ii
used for treatment or storage.
RCRA-hazardous, containerized accumulation
f solid, nonflammable hazardous waste that is
sed for treatment or storage.
Treatment alternatives discharging water must
meet UPDES standards.
Wastes to be treated must be identifiable as
estricted hazardous waitej.
Contaminated icil muit be removed, not left in
lace
40 CFR 264.1 8
IMC 1U I5-8-2.9
40 CFR 256.310;
UACR315.8-I4.5
40CFR264.251(c),(d);
UACR315.8-l2.2(cXd)
40 CFR 264,273(c). (d);
UACR315-8.13.4(cXd)
40 CFR 2M.3IO(c). (d);
UACR315-8-14.2(cyd)
40 CFR 264.251;
UACR3I5-8-12
40 CFR 264,251;
MCR31 5-8-10
•10 CFR 264.251;
UACR3 15-8-9
JACR317-8
nCFR268(SubpartD);
UACR315-13
UACR3I5-5
,^^K|pg
Relevant and
approprittc
Applicable
Applicable
Applicable
Applicable
Applicable
Applicable
Applicable
Applicable
Oneillenulive leaves
contaminated soil in place
and covers it with clean
soil.
Applies to alternative that
leaves contaminated soil In
place and covers it with
clean soil.
Applies to removal
alternatives thai may use
temporary stockpiles.
Applies to removal
alternatives that may use
emporary stockpiles.
Applies to removal
alternatives that may use
tanks.
Applies to removal
alternatives that may use
onlainers.
One alternative uses water
bat must be treated and
eused for soil washing and
metal precipitation.
Applies to the removal
Itematives that treat soil.
Applies to the removal
Itematives that inat soil.
I:\dt\wp\udefl\jacobs\rfs\r.nf\mableJ.2.doc
-------
AcfifflTSpecific ARARs
Action t
Cap or cove
H^, §• <• R«4alfr!l'l|lPiIt:
Placement ofa cover over waste (e.g.,
closing a landfill, or closing a surface
impoundment or waste pile as a landfill,
or similar action) requires a cover design
and construction to:
• Provide long-term minimization
migration or liquids through the
capped nrea
• Function with minimum maintenance
• Promote drainage and minimize
erosion or abrasion of the cover
• Accommodate settling and
subsidence so that the cover's
integrity is maintained
• Have a permeability lesa than or
equal to the permeability of any
natural subsoils present
Restrict post-closure use of properly
as necessary to prevent damage to the
cover
Prevent run-on and runoff from
damaging cover
Protect and maintain surveyed
benchmarks used to locate waste
cells (landfills, waste piles)
Eliminate free liquids by removal or
solidification
Stabilize the find cover to provide
long-term minimization of filtration.
RCRA-hfl/ardous waste placed at
site after November 19, 1980, or
movement of hazardous waste from
une area of contamination or location
into another area of contamination
will make requirements applicable,
Capping without inch movement wil
not make requirement applicable, bu
lechnical requirement! are likely to
x relevant end appropriate.
40 CFR 264.310(a); UAC R3 1 5-8-1 4.5(8)
40 CFR 264.228(b); UAC R3 1 5-B-l 1 .S(a)
40 CFR 264. 1 1 7(c); UAC R31 5-8-7
40CFR264,228(»X2);UACR3I5-8.11.5(8X2)
40CFR26.228(aX2)«nd
40 CFR 254.258(b); UAC R3 1 5-8-1 1 ,5(»X2)
ndUACR3IS-8-I2.6(b)
0 CFR 264.310; UAC R3I5-8-14.5
Relevant and
appropriitt
One alternative leaves
contaminated toil in place
and covert it with ckan soil.
I:\dl\wp\udeq\jacobs\ffs\final\tabls8-2.doc
-------
tclficARARj
Soil trealmenUnd
reuse
Off-site management
of CERCLA wastes
;, •". r ' o.r«He••:'*$: **£
Removal or decontamination of ill
waste residues, contaminated
containment system components (e.g.,
liners, dikes), contaminated lubsoils,
and structures and equipment
contaminated with waste and leachate,
and management of them as hazardous
Applies 1o any remedial or removal
Bdion involving off-site transfer of any
hazardous »ubstance or contaminant
taken pureuanl to any CERCLA
May ipply to contiminiled toil, including sail from
excavation, Uten renirned to land.
EPA Regional Office will determine acceptability of any
facility selected for treatment, storage, or disposal of
CERCLA waste.
40 CPR 264.111;
40 CFR 264.178;
40 CFR 264.1 97;
40CFR264.228(aXI)
and
40 CFR 264.258;
UACR3I5-8-9.9
andUACR315-8-11.5
Applicable
Applies to the removal
alternatives that treat
soil.
that involves landfill
disposal of RCRA-
characterliUcwasii.
Notei:
CFR
UAC
UCA
Code of Federal Regulations
Utah Administrative Code
Utah Constitution Amended
I:\dt\wp\ud*q\jacoba\ffs\fin»l\table8-2.doc
-------
Location-Specific ARARS
National Historic Preservation Act
16 USC §470,40 CFR §6.301b
36 CFR Part 800
Applicable
Archaeological and Historic Preservation Act
16 USC §469
40 CFR 6.301(c)
Applicable
Notes:
CFR
USC
Code of Federal Regulations
United States Code
I:\dt\wp\udeq\jacobs\frs\final\table8-3.doc
-------
Criteria
Considered"
Soil lead levels
for children
Soil treatment
standards
Centers for Disease Control and
Prevention (CDC) guidance for
determining soil lead action levels
Prior to adoption by states of the Phase
IV soil treatment standards, other LDR
standards (including Phase IV) apply
(finalized May 26.1998).
See Table 8-2 and next column.
The soil treatment standards are
effective only for soil:
(I) In states not authorized for the
LDR program
(2) In all states if the soil fails the
TCLP test for one or more metal
constituent (TC metal soil)
(3) In all states ifthe soil is
contaminated with a characteristic
mineral processing waste.
Because the soil treatment standards are less stringent then existing
federal requirements, they are generally not available in authorized states
unless raid until the states adopfthe standards. To the extent they do not
conflict with any independent state LDRs or treatment requirements, the
soil treatment standards are also available in slates in which EPA is
responsible for implementation of the LDR program as follows:
which EPA is responsible for implementing the IPR
CDC recommends that there should be no more than a 5 percent chance
that cllildren aged 0—3 years have blood lead levels higher Ihan 10
ug/dL.
jp its entirety. In these states, there we no authorized state
LDR requirements against which to assess the relative stringency of
the soil treatment standards. Therefore, as new HSWA
requirements in a non-authorized state, the soil treatment standards
01 e effective and implemented by EPA unless and until the slate
adopts and becomes authorized for the standards.
m giflles that are m\h™ 'Mtl to implement the LDR PfOBfflm but in
rili"h FrPA !« f«po"8'ble fof '«"pfcmentetion of the laid disposal
pstrielinn treatment ^IKtofo fm certflin w^6*- Soil treatment
standards are available for soil contaminated by tlw wastes for
which EPA is responsible for implementation of LDR treatment
standards, provided the state does not have a treatment standard in
state law that is more stringent than (he soil treatment standards.
For example, for TC metal wastes, EPA is responsible for
implementing the LDR treatment standards. Therefore, for TC
metal soil, the soil treatment standards are available. However,
many states have treatment standards for metals that are more
stringent than the soil treatment standards; in this case the more
stringent state treatment standards would control in lieu of the
Federal soil standards.
ffnil treatment standard for lead is 90 percent reduction
t ______ ;_ i«_-. *i*.:_t<»*il\ kul t HaU 4*iirr*nilt/ fia* a
whoever is less tth1F"ft °"t Utah currently has a
slnndard for lead pf S ppm (which was adonted from the LDR
fltt more stringent state treatment standard of 5
IP TC characterise |evel« of lead in contaminated soil
mi«s and until the tiftft adapted the soil treatment standards
"Preventing
Lead Poisoning
in Young
Cllildren"-CDC
40 CFR 268.49
TBC
TBC
Reference is CDC
published stotemuiit
dated October 1991
(I) If Utah adopts the
Phase IV soil treatment
standards before Die
OUI ROD is signed, the
Phase IV standards will
be applicable to the lead
disposal options instead
of the current Sing/L
TCLP standard.
[2) Soil contaminated
with TC metal wastes
must meet LDRs for
underlying hazardous
constituents in all states.
If a state becomes
authorized only for
Phase II and not for
Phase IV, the soil
standards for DO 12-
D043 in Phase IV (i.e.,
10 x UTS or 90 percent
reduction) will be
superseded at the time of
authorization by the
Phase II treatment
standards, which provide
no special standards for
contaminated soil.
-------
Criteria "To Be Considered"
Transportation
of hazardous
materials
Regulates (he manifesting and transport
of hazardous materials
Manifests and placarding of (rucks, shipping containers, or rail cars
required for shipment of all hazardous materials.
•49 CFR Parts
j 72—179,49
CFR Part 1387
-DOT-E8876
UACR31S-4
UACR3I5-6
One alternative involves
transportation of RCRA-
characteristic watte to an
off-site landfill.
Notes:
CDC
CLP
EPA
HSWA
Centers for Disease Control and Prevention
Contract Laboratory Program
U. S. Environmental Protection Agency
Hazardous and Solid Waste Act
LDR
TBC
TC
UTS
Land disposal restriction
Other criteria to be considered
Toxicity characteristic
Universal treatment standards
-------
-------
APPENDIXB
DETAILED COST ESTIMATE
FOR SELECTED REMEDY
-------
-------
JACOB SMELTER OU1
CAPITAL COST ESTIMATE
Alternative 4-Excavation with Disposal
Item
Number
1
2
3
4
5 '
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
Description
Mobilization
Truck Scale
Clear & Grub Concrete, Rock, Asphalt '
Clear and Grub Fences '
Clear and Grub Trees '
Remove soils 500 ppm - 1,500 ppm
Excavate Soil Aleys/Platted Roads
Excavate SoP Residential Lots
Excavate Sol inside ROW, Outside Pvmnt
Hand Excavate Soil inside Residential Lots '
Remove soils >1,500 ppm
Excavate Sofl Aleys/Platted Roads
Excavate Sol Residential Lots
Excavate Sol inside ROW. Outside Pvmnt
Hand Excavate Soil inside Residential Lots '
Stabilize SoB>1 500 ppm
Transport Soil from Aleys/Platted Roads
Transport Soil from Residential Lots
Transport Soil from ROW. Outside Pvmnt
Dispose SoN from Aleys/Platted Roads
Dispose Soil from Residential Lots
Dispose Soil from ROW. Outside Pvmnt
Dispose hazardous waste soil
Haul, Place Clean SoR to Alleys/Platted Roads
Haul, Place dean SoH to Residential Lots
Haul. Place Clean Soil toROW. Outside Pvmnt
Haul. Place Top SoB1
Construct Ditches AH Widths '
Haul, Place Road Base '
Asphaft Paving '
Storm Drain Culverts CMP & RCP '
UWty coordination-
Replace septic tank & teach field
Remove and replace fences '
Remove and Replace Fence Gates '
Trees (2-inch cafeer trees) '
Sod
Seeding
Landscaping, bedUnes. rock, mulching etc
Remove and replace sheds
Shrubs1
Remove & replace retaining waBs
Replace Irrigation Systems
Remove, corral and return livestock
Dispose of exterior items
Clean house nterior
Health & Safety Ambient Air Monitoring
Final Site Wide Clean-up
Demobilization
Units
LS
LS
Ton
LF
Each
Ton
Ton
Ton
Ton.
Ton
Ton
Ton
Ton
Ton
Ton
Ton
Ton
Ton
Ton
Ton
Ton
Ton
Ton
Ton
Ton
Ton
LF
Ton
SqFt
LF
Per House
Each
LF
Each
Each
SqFt
Acre
Per Lot
Each
Each
SqFt
Each
Per House
Per House
Per House
LS
LS
LS
Quantity
1
1
4,571
24,785
360
13,346
72,884
17,595
134
7,275
21,137
7.417
46
35,875
20,621
94,067
25,013
20,621
94,067
25,013
840
17,574
62,711
20,066
31,356
9,240
9.972
51.620
450
9C
9
24.785
180
45(
773,810
15
9t
45
90!
720
22
2
4;
9
nit Costs
$50,000
$40.000
$30
$4
$700
$5
$5
$5
$50
$5
$5
$5
$50
$50
$2
$2
$2
$20
$20
$20
$200
$10
$12
$1C
$2C
$5
$15
$5
$20
$3,OOC
$7,50C
$15
$2S
$350
$0.75
$2,00!
$5,00
$3,50
$4
$1
$4,50
$2.00
$1.50
$2,00
$20,00
$50,OC
$35,OC
Extension
$50,000
$40.000
$137,117
$99.140
$252.000
$66.728
$364,419
$87,977
$6.700
$36,375
$105,684
$37,086
$2.300
$1,793,750
$41241
$188.134
$50.025
$412.410
$1,881,335
$500,250
$168,000
$175.740
$752,534
$200,680
$627,112
$46^00
$149,575
$258,100
$9,000
$270.000
$67,500
$371,775
$45,000
$157,500
$580,358
$25,047
$450.(XX
$157,50"
$36,000
$72.000
$10129
$40,00
$64,000
$180,00
$20,00
$50,000
$35,00
Basis for Costs was Sharon Steel - Average of Phases 2,3 and 4.
Subtotal $11262.520
Unidentified Construction Costs (10%) $1,126252
Construction Management (10%) $1238.877
TOTAL $13,627,649
l:M3T\WP\Udeq\J«cot)VfcVin8iearthwDrtc Quantity tekeofljds
-------
JACOB SMELTER OU1
CAPITAL COST ESTIMATE
Assumptions Sheet
4* r\(£SlQCnTl3l Iot*C vurfrh TIir^n~n «»MI| i«u»«j *.&!..._... *. **_ ^^.^.
i subsurface soil lead values greater than 800 mg/kg will be remediated
dttiat half of the lot is greater than the action level and half is (ess than the action level,
4 All paved roads will not be remediated
«; AH ^ r03dS **" be dama9ed during material haufing and reconstructed with 6" base course and 4- asnhatt
5 All non^aved areas within the right-of^ay (ROW) wil, be remediated that have lead '
concentration contours covering the segment of roadi
6 All exposed areas on the residential lots will be remediate*.
All fences having a house structure have a fence which extends across the full width
or the back yard, extends half way up the side yards, and has 60 additional feet to connect
from the property line to the houstt =°nne«
8 AH vacant lots have no fences.
9 Four trees per lot having a house will be cleared and grubbed.
Rve 2-inch calibertrees are estimated for each lot having a house
10 10 bushes are estimated for planting at each lot having a house.
' lfcr'SSI,I?S,lT-!rl replace*nent' ^^ on **" *»«*«> footage of the lot minus 1500 sq ft
17 A,, f°rthe,house footPnnt- m"»« 700 sq ft (2ff x 35") for the driveway footprint
12 All vacant tots will be topsoiled and hydroseeded.
ift 1« °J *e lots with houses have irrigation systems that wffl be replaced.
10 1/3 of the lots have exterior items requiring disposal
i:\dt\wp\udeqyacobs\ffs\flnal\Earthwork Quantity Takeoff
-------
Capital costs
$13.627,649
IV-1
Net Present Cost of Construction, Operation, Maintenance, and Monitoring
Alternative 4-Excavation/Disposal Alternative
ill
nitoring costs
$4,709
$4,709
$4.709
$4,709
$4.709
$4,709
$4,709
$4.709
$4,709
$4.709
$4.709
ubtotal annual expenditures
$13.632.358
$4.709
$4.709
$4.709
$4.709
$4.709
$4,709
$4.709
$4,709
$4.709
$4.709
Inflation factor (1.6% to 2.1%)'
1.000
0.983
0.967
0.945
0.920
0.901
0.883
0.865
0.847
0.829
0.812
Discount factor (5%)b_
1.000
0.952
0.907
0.864
0.823
0.784
0.746
0.711
0.677
0.645
0.614
Present worth'
$13.632.358 $ 4.410
4.130
3,845
$ 3.565
$ 3.3261 $ 3.102
2.894
2.699
$ 2.518
2.349
Capital costs
Annual monitoring costs
$4.709
$4,709
$4,709
$4.709
$4,709
$4.709
$4.709
$4.709
$4.709
$4.709
ubtotali
alt
iditures
$4.709
$4.709
$4,709
$4.709
$4.709
$4.709
$4.709
$4.709
$4.709
iflatlon factor (1.6% to 2.1%)'
0.796
0.779
0.763
0.748
0.732
0.717
0.702
0.688
0.674
0.660
Dis
it factor (5%)"
0.585
0.557
0.530
0,505
0.481
0.458
0.436
0.416
0.396
0.377
Present
$_
JL191
$ 2.043
1,906
$ 1.778
1.659
1.547
1.346
1,256
1,171
Capital!
at monltorin
costs
$4.709
$4,709
$4.709^
$4.709
$4.709
$4.709
$4.709
$4.709
Subtotal i
idltu
$4,709
$4,709
$4.709
$4.709
$4,709
$4,709
$4,709
$4.709
$4,709
0.547
0.633
0.620
0.607
0.595
0.583
0.571
0.559
• See "Economic Analysis Reference Guide" for Inflation? Inflation factor - I/O ^Inflation rate)exponent"Year"
6 See "Economic Analyiis Reference Guide" for Discount Rate; DUcount factor - 1/0 +Discount rate)exponent"Year"
' Present worth *= Annual expenditures x Inflation factor x Discount factor
Asiumei that Year 0 is the year 2000
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TABLE IV-2
Oth«r Direct Charges (ODQ
10 copies. 25 paget per com
Labor Charm
Project management (PM)
PM labor rate
Hour
12
$148.45
$1.71
Mf-sitc labor
Assume 1 pawn, 3 days, 8
hr/day/cfaemistrate
Hour
24
$68.14
MF-site drafting/graphics
Assume 1 perron, 2 days, 8
hr/day/CADD operator rate
How
$61
MT-site support
Office clerical staff rate
Hour
Note
$712
URS
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RESPONSIVENESS SUMMAR Y
The proposed plan for Jacobs Smelter, Operable Unit 1, was issued for public comment on May
27, 1999. The comment period ran through July 15, 1999. No written comments were received
during the comment period. A public meeting for receiving comments on the proposed plan was
held June 9, 1999 at the Stockton Town Hall. All comments received during the meeting were
addressed directly. A copy of the transcript of the meeting can be found in the Administrative
Record.
Persons attending the monthly town forum meetings indicated acceptance of the proposed plan.
Minutes from these meetings can also be found in the Administrative Record.
No other comments on the proposed plan were received.
Record of Decision - Responsiveness Summary
Jacobs Smelter Superfund Site
Operable Unit 1
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