PB96-964201
EPA/ROD/R06-96/099
March 1997
EPA Superfund
Record of Decision:
RSR Corporation,
Operable Unit 4, Dallas, TX
2/28/1996
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RECORD OF DECISION
RSR CORPORATION SUPERFUND SITE
OPERABLE UNIT NO. 4 - SMELTER FACILITY
DALLAS, TEXAS
Prepared by:
U. 8. Environmental Protection Agency
Region 6
Dallas, Texas
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RECORD OF DECISION
CONCURRENCE DOCUMENTATION
FOR THE
RSR CORPORATION 8UPERFUND SITE
OPERABLE UNIT NO. 4 - SMELTER FACILITY
Ann D. Schober
Sit* Remedial Project Manager
Chief
Texas* Section
William if. Honker, Chief
Arkansas, Oklahoma and Texas Branch
Mark Peycke, CJiief
Litigation and Enforcement Branch
Oftdce of Regional Counsel
Phillips/ Deputy/foirector
Superfund Division
Myron &. Knudson, P.B., Director
Superfund Division
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DECLARATION FOR THE RECORD OF DECISION
RSR CORPORATION 8UPBRFUND SITE
OPERABLE UNIT NO. 4 - SMELTER FACILITY
DALLAS, TEXAS
Statutory Preference for Treatment as a Principal Element
is Met and Five-Year Review is Required
SITE NAME AND LOCATION
RSR Corporation Superfund Site, Operable Unit (OU) No. 4
Dallas, Dallas County, Texas
STATEMENT OF BASIS AND PURPOSE
The United States Environmental Protection Agency (EPA) presents
its decision in this Record of Decision (ROD) for Operable Unit
(OU) No. 4, the location of the former secondary lead smelter, of
the RSR Corporation Superfund Site (RSR Site). EPA's decision is
in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA or Superfund), 42 U.S.C.
§ 9601 et seg., and, to the extent practicable, the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP), 40
C.F.R. Part 300. The decision is based on materials and documents
EPA relied on or considered that are contained in the
Administrative Record for OU No. 4. The Administrative Record for
OU No. 4 is available for public review at three repositories, one
of which is located in west Dallas within the RSR site and near OU
No. 4. EPA bases this decision on the results of a remedial
investigation, feasibility study, and human health risk assessment
conducted at OU No. 4.
The State of Texas, through the Texas Natural Resource Conservation
Commission (TNRCC), concurs with EPA's selected remedy for OU No.
4 of the RSR Site.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances, as defined
in Section 101(14) of CERCLA, 42 U.S.C. § 9601(14), and further
defined in Section 302.4 of the NCP, 40 C.F.R. § 302.4, from the
RSR Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
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DESCRIPTION OF THE REMEDY
Operable Unit No. 4 is one of five operable units of the RSR Site.
This OU includes the smelter facility property where the secondary
lead smelting operations formerly were conducted. The ground water
portion of OU No. 4 is deferred and will be addressed as part of OU
No. 5 of the RSR site. The selected remedy for OU No. 4 will
address contamination of the secondary lead smelter facility.
The major components of the selected remedy include:
Demolition of site buildings and off-site disposal;
Demolition of the smelter stack and off-site disposal;
Excavation of the concrete foundations and contaminated
soil and off-site disposal.
Arsenic, cadmium, antimony and lead, the primary contaminants of
concern at OU No. 4, are hazardous substances, as defined in
Section 101(14) of CERCLA, 42 U.S.C. § 9601(14), and further
defined in Section 302.4 of the NCP, 40 C.F.R. § 302.4.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment to the maximum extent
practicable and satisfies the statutory preference for remedies
that employ treatment that reduces toxicity, mobility, or volume as
a principal element.
Because future land use may be limited to industrial use, five-year
reviews may be necessary at OU No. 4 of the RSR Site.
SIGNATURE AND AGENCY ACCEPTANCE OF THE REMEDY
A: StaWfey Mdiburg
Deputy Regional Administrator
U.S. EPA - Region 6
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DECISION SUMMARY
RSR CORPORATION 8UPBRFUND SITE
OPERABLE UNIT NO. 4—SMELTBR FACILITY
DALLAS, TEXAS
TABLE OF CONTENTS
TITLE PAGE
I. Site Name, Location, and Description 1
II. Site History and Enforcement Activities ... .1
III. Highlights of Community Participation 3
IV. Scope and Role of Operable Units 4
V. Site Characteristics 5
VI. Summary of Site Risks 17
VII. Remedial Action Goals 25
VIII. Description of Alternatives 27
IX. Summary of Comparative Analysis 34
X. Selected Remedy 40
XI. Statutory Authority Findings and Conclusions
of Law 41
XII. Documentation of Significant Changes 43
LIST OF TABLES AND FIGURES
TABLES
Table 1 Chemicals of Potential Concern
Table 2 Exposure Assumptions
Table 3 Toxicity Values - Noncancer Effects
Table 4 Toxicity Values - Cancer Effects
Table 5 Summary of Risks
Table 6 Uncertainties Associated with Human Health Risks
Table 7 POTW Pretreatment Standard Exceedances Analysis
Table 8 TCLP Exceedance Analysis
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FIGURES
Figure 1 Vicinity Map
Figure 2 Site Topography
Figure 3 Registered Well & Surface Water Intake
Figure 4 Residual Dust Sample Locations
Figure 5 Stormwater Sample Locations
Figure 6 Stormwater Sediment Sample Locations
Figure 7 Subsurface Soil Sample Locations
Figure 8 Ground water Monitoring Well Sample Locations
APPENDIX
A. Responsiveness Summary
B. Adult Lead Cleanup Level
C. ARARs Evaluation
D. Revised Cost Estimates
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DECISION SUMMARY
HSR CORPORATION 8UPBRFUND SITE
OPERABLE UNIT NO. 4 - SMELTER FACILITY
RECORD OF DECISION
I. SITE NAME, LOCATION, AND DESCRIPTION
The United States Environmental Protection Agency (EPA) is
addressing the release or threat of release of hazardous substances
at the former smelter facility, Operable Unit (OU) No. 4 of the RSR
Corporation Superfund Site (RSR Site) under the authority provided
in the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), 42 U.S.C. § 9601 et sea, (also known as
Superfund) and consistent with the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), 40 C.F.R. Part 300.
The RSR Site is located in west Dallas, Texas and encompasses an
area approximately 13.6 square miles in size. The RSR Site is very
diverse and includes large single and multi-family residential
neighborhoods, multi-family public housing areas and some
industrial, commercial and retail establishments. The population
in this area is approximately 17,000.
For approximately 50 years, a secondary lead smelting facility,
located at the southeast corner of the intersection of North
Westmoreland Rd. and Singleton Blvd., recycled used batteries and
other lead-bearing materials into pure lead, lead alloys, and other
lead products. This smelter property, known as OU No. 4, is
approximately 6.5 acres in size and contains several inactive
structures. Other industrial property related to the smelter, the
former battery wrecking facility, referred to as OU No. 5, is
located on the southwest corner of the Westmoreland Road and
Singleton Boulevard intersection. The smelter operations ceased in
1984.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
EPA has obtained information indicating that OU No. 4 is the
location at the RSR Site where secondary lead smelting operations
were conducted from the early 1930s until 1984. The basic inputs
into the smelting process were lead scrap and lead from used car
batteries. In the first step of the smelting process the batteries
were disassembled at the battery wrecking facility (OU No. 5),
using hammer-mills to break the batteries into small pieces. The
lead posts and grids were then sent across the street to smelter
facility (OU No. 4) to produce soft pure lead or specialty alloys.
In the refining process alloy elements, such as antimony, arsenic,
and cadmium, were added as necessary to produce the desired
product.
An extensive review of available historical information concerning
the smelter's operation indicates that from approximately 1934
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until 1971, the lead smelting facility was operated by Murph
Metals, Inc. or its predecessors. In 1971, RSR Corporation
acquired the lead smelting operation and operated under the name
Murph Metals. The smelter continued to operate under the RSR
Corporation until the acquisition of the smelter facility and the
battery wrecking facility in May 1984 by the current owner, Murmur
Corporation (Murmur). In 1984, the City of Dallas declined to
renew the smelter/s operating permit. This decision was based on
the smelter's historic operational practices and changes in the
City's zoning ordinance restrictions. As a result, the smelter
closed in 1984 and has not been operated since that time.
During 1984 and 1985, TNRCC (formerly the Texas Water Commission)
conducted inspections on the smelter and battery wrecking
facilities and identified several violations that involved the
treatment, storage or disposal of hazardous wastes. In 1986, TNRCC
approved a closure plan to be implemented by Murmur for portions of
the battery wrecking facility located at OU No. 5. However, Murmur
was unable to obtain certification by TNRCC of final closure, due
to a dispute between Murmur and its contractor. In June of 1991
the State of Texas referred the case regarding the closure to the
Superfund program for assessment. Immediately following this
referral, TNRCC began receiving complaints from residents alleging
that slag and battery chips were disposed of on their properties.
In 1991, EPA began soil sampling in west Dallas to determine the
presence of soil lead contamination. The results indicated that
contamination existed in some residential areas near the smelter
(OU No. 1) where fallout of contamination from the smelter stack
occurred and where battery chips or slag was used as fill in
residential yards and driveways. Consequently, EPA initiated an
emergency removal action in the residential areas consisting of
removal and offsite disposal of contaminated soil and debris in
excess of removal action cleanup levels. This removal action in
the residential area (OU No. 1) was completed in June of 1994.
In 1993, EPA initiated remedial investigations of the smelter and
related properties (OU Nos. 4 and 5) and alleged smelter waste
disposal areas (OU No. 3). In addition, an investigation of and
removal action at OU No. 2, the public housing residential area,
was then initiated by the Dallas Housing Authority under EPA
oversight pursuant to a CERCLA administrative order.
On May 10, 1993, EPA proposed the RSR Site to the National
Priorities List (NPL) of Superfund sites (58 Fed. Reg. 27,507).
The proposed listing was based on the soil exposure pathway.
A field investigation was conducted in the Spring of 1994
concurrently on OU Nos. 4 and 5. During this investigation three
areas of immediate concern were identified. More than 500 waste
drums, 73 uncontained residual waste/debris piles and approximately
50 laboratory containers were found on OU Nos. 4 and 5. In July
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1994, EPA authorized the preparation of an Engineering
Evaluation/Cost Analysis (EE/CA) report to support the conduct of
a non-time-critical removal action to abate the immediate threat to
human health and environment posed by the presence of these
material at OU Nos. 4 and 5. A 30-day public comment period on
the proposed removal action as described in the EE/CA report was
initiated on September 16, 1994. The proposed removal entailed
removal and offsite treatment and disposal of all drums, residual
waste/debris piles and laboratory containers. On December 22,
1994, the Action Memorandum authorizing this removal action was
signed. EPA commenced site activities for the non-time-critical
removal action on Nay 30, 1995 and completed these activities by
July 14, 1995.
On September 29, 1995, the RSR Corporation Superfund Site was
finalized on the NPL (60 Fed. Reg. 50435).
EPA has notified parties who are potentially responsible (PRPs) for
contamination at OU No. 4 and provided them the opportunity to
perform or finance the RI/FS. Since the PRPs declined to perform
or finance these response actions, EPA performed these activities
with funding from the Hazardous Substance Superfund (Fund). As
other PRPs are identified, EPA will provide them notice of their
potential liability and the opportunity to perform or finance
future response actions at the site, including the remedial action
for OU No. 4.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
EPA has performed public participation activities for OU No. 4 as
required in CERCLA Section 113(k), 42 U.S.C. § 9613(k), and Section
117, 42 U.S.C. S 9617. The Remedial Investigation Report,
Feasibility Study, Baseline Human Health Risk Assessment Report and
the Proposed Plan for OU No. 4 of the RSR Site were released to the
public on May 10, 1995. On or before May 10, 1995, EPA made
available to the public these documents as well as other documents
and information EPA relied on or considered in selecting
Alternative No. 4 - Decontaminate and Dismantle
Buildings/Structures and Dispose Offsite; Excavate Soils and
Dispose Offsite. These documents were contained in an
Administrative Record File for OU No. 4 (or draft Administrative
Record) available for review at 3 locations; the West Dallas Public
Library located at the RSR Site, the EPA Region 6 library in
Dallas, and the TNRCC library in Austin, Texas. The notice of the
availability of the Proposed Plan and the Administrative Record
File was published in The Dallas Morning News on May 9, 1995. The
public comment period commenced on May 10, 1995 and ended on July
12, 1995. EPA conducted a public meeting on May 23, 1995 to
receive public comments from the community. EPA's responses to all
comments received during the public comment period are included in
the Responsiveness Summary, which is included as Appendix A to this
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ROD.
This Record of Decision (ROD) presents EPA's selected remedial
alternative for OU No. 4 of the RSR Site in Dallas, Texas that will
provide protection of human health and the environment in
accordance with CERCLA and consistent with the NCP. This decision
is based on the Administrative Record for OU No. 4.
IV. SCOPE AND ROLE OF OPERABLE UNITS
There are five Operable Units (OUs) of the RSR site, which are
distinct geographical areas that are illustrated in Figure 1 and
described below:
OU No. 1 - Private residential areas potentially impacted by
historical operations of the smelter;
OU No. 2 - The Dallas Housing Authority's public housing
development located northeast of the smelter facility;
OU No. 3 - Former landfills and smelter waste disposal areas
located at three different sites within west Dallas;
OU No. 4 - The smelter facility;
OU No. 5 - Former battery wrecking facility and other industrial
tracts of land associated with the smelter and located across
Westmoreland Road from the smelter facility.
This ROD addresses only OU No. 4, the location of the former
smelter facility, which currently is owned by Murmur. This area
consists of the smelter facility, stack, and a number of other
buildings that served as warehouses, repair shops, a laboratory,
offices, storage facilities, docks, and lunch and locker rooms for
employees. OU No. 5 is the location of smelter-related activities,
such as the battery breaking operation and several disposal areas.
Because the nature of some of the former operations and wastes at
OU Nos. 4 and 5 are similar, EPA conducted certain studies of the
two OUs simultaneously.
Final Records of Decisions for OU Nos. 1 and 2 were issued on May
9, 1995. EPA is currently completing a Remedial Investigation at
OU No. 3. Proposed Plans outlining recommended Superfund response
actions for OU No. 3 and OU No. 5 of the RSR Site will be released
at a later date.
This ROD for OU No. 4, is EPA's final decision to address the
contamination associated with all of the onsite buildings,
structures and equipment, soils, and sediments. Potential
ingest ion, dermal contact and inhalation of materials present on OU
No. 4 contaminated with lead, arsenic, cadmium and antimony in
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RESIDENTIAL PROPERTY (OU NO. 1) BOUNDARY
DALLAS HOUSING AUTHORITY (DHA) PROPERTY IOU NO. 2)
SLAQ PILES (OU NO. 31, SITES 1, 3, AND 4
MURMUR/RSR SMELTER-TRACT 1 (OU NO. 4)
OTHER MURMER/RSR INDUSTRIAL PROPERTY (OU NO. 5)
RSR/OU4-5/65698D06.DGN/ERAQAPP
FIGURE 1
VICINITY MAP
OPERABLE UNITS (OU) NOS.1,2,3,4 & 5
RSR CORPORATION SUPERFUND SITE
DALLAS, TEXAS
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excess of remedial goals (described fully in Section VII.) pose
unacceptable risks to human health and the environment. The
purpose of the selected response action is to prevent current or
future exposure to the contaminated materials at OU No. 4.
V. 8ITB CHARACTERISTICS
This section presents an overview of the characteristics of OU No.
4, the former smelter facility (also referred to herein as the
site). First a summary of the site soils, geology, hydrogeology,
ground water, topography, surface water, climate and land use is
discussed* Following is a detailed description of the pertinent
site features, such as all of the onsite buildings and structures.
Finally, a discussion of the findings of the field investigation is
included in the nature and extent section. Note, that all of this
information can be found in greater detail in the Remedial
Investigation Report and supporting Technical Memorandums, which
are all part of the Administrative Record for Operable Unit No. 4.
A. Soils
The USDA Soil Conservation Service (SCS), identified the Trinity-
Frio soils as the major soil type at OU No. 4. Trinity-Frio soils
are floodplain soils, poorly drained, clayey, with low permeability
(less than 0.06 in/hr) and high water capacity. Because they are
primarily found in flat, low-lying areas, runoff and the potential
for these soils to erode is minimal.
The specific soil complex on OU No. 4 is the Houston Black-Urban
Complex. This complex consists of deep, moderately well drained,
nearly level and gently sloping soils and areas of Urban Land. The
Smelter Complex on OU No. 4 would fall under the classification of
Urban Land typical of areas characterized by disturbed soil and
fill material that have greatly altered the natural soil type.
B. Regional Geology
In the vicinity of the OU No. 4 site, the predominant geologic
units are of the Upper Cretaceous Age. The formations consist of
(in descending order) the Austin Chalk Formation, the Eagle Ford
Shale Formation, the Woodbine Formation, and the Grayson Marl and
Main Street Limestone Formation. The geologic units making up the
Cretaceous system in north-central Texas form a southeastward-
thickening wedge extending into the East Texas Embayment. This
sedimentary wedge ranges in thickness from zero in the west to
nearly 7500 feet in the southeast. Regional dip is to the east and
southeast at 15 to 40 feet per mile but increases as much as 300
feet per mile on the flanks of the Preston anticline, located in
Grayson County, north of Dallas.
Geologic maps of the surface soils indicate the OU No. 4 site is
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situated at the bottom of the surface expression of the contact
between the top of the Eagle Ford Shale Formation and the overlying
Austin Chalk. As documented by logs of deep veils in the area, the
full thickness of the Eagle Ford Shale Formation, which overlies
the Woodbine Formation, is present beneath the OU No. 4 site.
The Eagle Ford Shale Formation is composed primarily of dark shales
with occasional thin stratas of sandstone, limestone, and
bentonite. The Eagle Ford Shale Formation has two members, the
Arcadia Park being the upper, and the Britton being the lower
member. The upper beds of the Arcadia Park member are present in
the surface soils at the OU No. 4 site. The Arcadia Park is
described as a basal blue clay twenty (20) feet thick; overlain by
one to three feet of thin limestone flags; overlain by an uppermost
part of some seventy-five (75) feet of blue shale with calcareous
concretions of various size, which is unconformable overlain by the
Austin Chalk. The underlying Britton member is typically 250-300
feet thick and consists mostly of blue clay/shale. The Eagle Ford
Shale Formation is commonly referred to as an aquitard overlying
the Woodbine Formation.
C. Site Geology
Beneath the OU No. 4 site, Quaternary alluvial deposits vary in
thickness from a few feet in the southeast corner to over 30 feet
in the northwest corner.
The RI included drilling of soil and geoprobe borings in the fill
and alluvial deposits beneath the site. The soil borings were
drilled to a depth of up to 37 feet, to a point where the Eagle
Ford shale was encountered, while the geoprobe borings generally
encountered resistance in the deposits great enough to refuse the
probe at 13 feet below ground surface (bgs) or less.
Each boring encountered clays or silty clays, with occasional silt
or sand. The top of the Eagle Ford, sometimes seen as a weathered
shale, was encountered at elevations ranging from 405 feet mean sea
level (MSL) to 433 feet MSL across the site.
D. Hydrogeology
In north-central Texas, the two most important water-bearing
stratigraphic units are the Woodbine Group, a minor aquifer, and
the Trinity Group, a major aquifer. A major aquifer is defined as
one which yields large quantities of water in a comparatively large
area of the State, and a minor aquifer is defined as one which
yields large quantities of water in small areas, or relatively
small quantities of water in large areas of the State. Both
aquifers provide municipal, domestic, industrial, and some
irrigation supplies to the north-central portion of the State. It
should be noted that water for Dallas residents is provided by the
City of Dallas water system, which draws its water from surface
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reservoirs many miles from the OU No. 4 site.
The Woodbine Aquifer is of Upper Cretaceous age and is composed of
sand and sandstone. The nearest outcrop of the Woodbine Formation
to the RSR site is in far northwestern Dallas County and eastern
Tarrant County, a minimum of 10 miles from the OU No. 4 site.
Groundwater flow within the Woodbine is generally to the east. In
the vicinity of the RSR site, the depth to the Woodbine from the
ground surface is approximately 200 to 250 feet.
The Trinity Group Aquifer is comprised of Lower Cretaceous age
formations (the Paluxy, Glen Rose, Twin Mountains, and Antlers)
which are older and encountered at greater depths than the Woodbine
and other geologic units present within the RSR site. These
geologic units were .deposited in fluvial, deltaic, and shallow
marine depositional environments, and are typically comprised of
sands interbedded with clays, limestone, dolomite, gravel,
conglomerates, and evaporates (the latter are present in the upper
Glen Rose). Outcrops of Trinity Group formations are found in
Parker County, approximately 60 miles west of Dallas County.
Within the RSR site, the depth to the Trinity Aquifer from the
ground surface is approximately 1,300 to 1,500 feet to the Paluxy
formation and approximately 2,500 feet to the Twin Mountains
Formation.
The Quaternary alluvial deposits also contain small amounts of
water in this area, although they are not classified as a minor or
major aquifer by the State. The shallow groundwater in the
vicinity of OU No. 4 is not generally considered a water supply
aquifer due to its overall low yield and slightly saline quality.
According to a RCRA Facility Assessment completed by the TWC (now
TNRCC) for the Smelter Facility in 1988, the alluvial system was
not believed to be hydraulically connected to the deeper Woodbine
aquifer due to the presence of the 3 00-foot-thick Eagle Ford shale
beneath the site. Groundwater was generally encountered at depths
of 5 to 10 feet below ground surface in the RI monitoring wells
installed to depths of up to 24 feet (completed at the base of the
alluvial materials overlaying the Eagle Ford).
E. Groundwater Quality
In the Dallas area, the general quality of groundwater from the
Trinity Aquifer ranges from 500 to 3,000 mg/1 total dissolved
solids (TDS), which indicates fresh to slightly saline water.
Sulfate and chloride concentrations do not exceed secondary
drinking water standards of 300 mg/1. Increasingly poor quality
(high TDS) water from this aquifer in parts of the Dallas-Ft. Worth
area in recent years has been attributed to over-pumpage of the
aquifer.
Only the lower part of the Woodbine Aquifer (i.e., the upper sand
unit at a depth of 730 to 830 feet) is considered to be suitable
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for development due to high iron concentrations in the rest of the
aquifer. In the Dallas area, groundwater from various units of the
Woodbine Aquifer is in the 1,000 to 3,000 mg/1 range for TDS
(slightly saline), and sulfate concentrations generally exceed
TNRCC's recommended drinking water limit of 300 mg/1 (30 TAG
S 290.113). Wells completed on or near the outcrop tend to produce
groundwater of a higher quality. The primary uses of water derived
from the Woodbine are for domestic livestock and public supply.
However, due to (1) an increasing dependance on surface water for
public supplies, (2) historically large withdrawals of water from
the Woodbine, and (3) low permeabilities of the Woodbine's water-
bearing zones, this aquifer is no longer used as a primary source
of drinking water for Dallas County, and is not used by the City of
Dallas.
The primary source of recharge for both the Trinity and Woodbine
Aquifers is considered to be precipitation on outcrop surfaces.
Recharge from streams flowing across the outcrop, and surface-water
seepage from lakes, streams, and ponds are considered secondary
sources. No primary recharge areas are located within five miles
of OU No. 4. As stated previously, the outcrop surfaces for the
Woodbine and Trinity Formations are located a minimum distance of
10 miles to the west of OU No. 4.
The water contained in the Quaternary alluvial deposits is a result
of surface infiltration from runoff and likely interacts directly
with surface water features in the area.
F. Topography
The RSR Site is located on the margin between the Blackland Prairie
and the Eastern Cross Timbers physiographic provinces. The RSR
Site topography is characterized by low, flat to gently undulating
surfaces. A majority of the RSR Site is located on a floodplain
terrace of the Trinity River. The northern and western edges of
the RSR Site are bounded by the Trinity River levee. The OU No. 4
site slopes to the west with surface drainage mainly towards
Westmoreland Road. A majority of the OU No. 4 site is paved, which
promotes surface runoff. The topographic relief across the OU No.
4 site is approximately 15 feet with a dip to the northwest. See
Figure 2.
6. Surface Water
The Trinity River and its tributaries, and Fishtrap Lake in the
Dallas Housing Authority area (OU No. 2), are the only major
surface water bodies in the vicinity of OU No. 4, as shown in
Figure 3. The West Fork flows east-northeast from Grand Prairie
(500 to 1,000 feet from the western edge of OU No. 1) before
joining the Elm Fork to form the main channel. From the confluence
of the West and Elm Forks, the Trinity River flows east and then
south (approximately 4500 feet north of OU No. 4 at its closest
8
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WESTMORELAND ROAD
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LEGEND
A SURFACE WATER INTAKES
• REGISTERED GROUNDWATER WELLS
E3 SURFACE WATER GAGING STATIONS
RSH/OU4-5/11V133H I/I V133COy.DGN
FIGURE ~
REGISTERED WELL AND
SURFACE WATER INTAKE LOCATIONS
OPERABLE UNITS NUMBERS 4 & 5
RSR CORPORATION SUPERFUND SITE
DALLAS, TEXAS
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point). A surface drainage channel (approximately 3500 feet
northwest of OU No. 4) empties into the Old West Fork channel,
which joins the Trinity River at a pumping station between
Westmoreland and Hampton Roads.
The Texas Water Code specifies all segments of the Trinity River
Basin for recreational use. None of the river segments are
specified for domestic water supply.
H. Climate
The climate in Dallas County is temperate to hot. During the
winter, cold surges of air cause the moderate temperature to drop,
thereby producing cool winters with occasional snow. Rainfall
throughout the County is relatively consistent throughout the year,
with a slight increase usually in the spring. Wind direction is
primarily from the south-southeast. In the DFW area, the average
annual windspeed for 1992 was 9.9 miles per hour (mph).
I. Land Use and Zoning
The smelter and its support facilities are all located on land
designated as OU No. 4. Areas surrounding OU No. 4 comprise a
mixture of residential, commercial, and industrial facilities.
Based on the 1994 City of Dallas, zoning map, OU No. 4 is currently
zoned as Industrial Manufacturing (IK). IN zoning for the City of
Dallas includes, industrial, wholesale distribution and storage,
and support office and retail uses. The surrounding land, which
comprises OU No. 1 of the RSR site, is zoned primarily for single-
family residential, multi-family residential, light and heavy
industrial uses and, to a lesser extent, commercial and retail.
The reasonably anticipated future land use of OU No. 4 is
commercial/industrial based on the past and current zoning map for
this area.
J. On-Site Buildings and Structures
OU No. 4 has numerous structures onsite as shown on Figure 2. Note
that all of the buildings and the stack have concrete floors,
assumed to be one foot thick. In addition all of OU No. 4 is
covered by concrete pavement, with exception of approximately 1
acre in the northeast area, which is unpaved. Based on the field
investigation observations there are numerous floor drains and
sumps located throughout the smelter facility.
The structures present on OU No. 4 include the smelter facility,
associated bag houses and stack, batch house, hog storage building
and several other support buildings for such needs as office space,
showers, storage areas, laboratory needs, and vehicle support. The
following sections briefly describe the construction and present
physical condition of each building based on a visual review of the
structures by a structural engineer in March and April 1994 during
-------
the RI field activities. The structural survey Technical
Memorandum, dated March 1995, is contained in the Administrative
Record for OU No. 4.
1. Smelter Facility
The Smelter Facility building appears to have been constructed in
stages over a period of many years. The exterior is clad with
uninsulated metal siding and roofing. Large pieces of machinery
and equipment support structures are found throughout the building
interior and in some locations just outside the building. Several
hazards associated with falling roof beams, panels and light
fixtures, the inadequacy of overhead walkways, and the weakness of
conveyor supports have been observed. Numerous small holes in the
roof and large areas of damage caused by rust and corrosion on the
underside of the roof are also present. It appears the roof beams
were weakened and structural connections at or near the roof may
have deteriorated, indicating that one or more of the roof beams
could fail.
2. Smelter Stack
The Smelter Stack is approximately 300 feet tall. The stack
consists of two cylindrical structures, one within the other. The
outer structure is cast-in-place concrete and the inner structure
is masonry that may contain asbestos. The two structures are
connected by metal straps that encircle the masonry at intervals of
10 to 20 feet and are attached to the interior side of the concrete
structure. The straps are about 3 inches wide and 1/4-inch thick.
Based on visual observations during the RI, it appears that the
straps between the concrete and the masonry cylinders have started
to rust. If the straps continue to rust, the masonry will no
longer be braced by the concrete. The structural engineer noted
that if the masonry was not internally reinforced, it could sway
and crack if subjected to sufficient lateral loads (for example,
high winds).
3. Batch House
The Batch House is a pre-engineered metal building with concrete
floors and concrete bin walls approximately 10 feet in height and
is connected to the smelter facility. This building was used for
storage of contaminated soil during EPA's soil removal activities
for OU No. 1 of the RSR Site. No significant structural damage
associated with this building has been observed; however, prevalent
cosmetic damage is apparent. Some concrete walls were found to be
gouged and some metal walls are bent, but the columns are intact
and there is little evidence of rust in the building.
10
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4. Hoa Storage Building
The Hog Storage Building is a pre-engineered metal building that
appears to have undergone expansion at some time. This building
was used for storage of finished product from the smelter, this
building shows signs of cosmetic damage but no significant
structural damage. Based on a review of historical aerial
photographs, the structure is more than 15 years old and is near ing
the end of the usual 20- to 30-year design life for metal
buildings.
5. Former Cafe Building
The exterior walls of the Former Cafe are constructed of masonry.
There are steel columns and beams that support the steel truss
joists on which the metal roof deck rests. This building is
experiencing a number of structural problems. The fascia of the
Former Cafe is separating from the masonry walls and falling to the
ground. The steel connections for the fascia showed significant
rust. There is ceiling damage that may contribute to the
deterioration of the steel roof deck and the roofing material above
it.
6. Office/Cafeteria/Laboratory Complex
This building is constructed of masonry and appears to be in
reasonably sound condition except for rust on the roof deck
surrounding an opening in the roof. This opening allows
precipitation to enter the building and cause further
deterioration.
7. Bath House
The Bath House is a masonry structure with a wooden roof deck.
Observations made during the RI, indicate that the flat wooden roof
deck has rotted and weakened due to water damage and parts of the
roof have caved in.
8. Vehicle Maintenance Building
The Vehicle Maintenance Building is a partially-enclosed masonry
structure partially covered with metal sheeting and a flat roof.
This building is a former self-serve car wash with approximately
eight bays. The masonry wall on the north side of the building
shows evidence of significant structural distress. The fascia of
this structure has deteriorated and parts of it have been removed
or have fallen away.
9. Former Gas Station
The Former Gas Station is constructed of masonry. The fascia is
beginning to pull away from the masonry wall and there are large
stains and mildew on the plaster ceilings inside the building which
indicate roof leaks. The east corner of the building has been
11
-------
seriously damaged. The fascia support structure associated with
the building is exposed and deteriorating.
10. Underground Storage Tanks (USTs)
There are two 10,000 gallon USTs known to be present on OU No. 4.
These USTs are located southeast of the Former Gas Station
building. State tank registration forms indicate that no
information is known about these two USTs, but also identifies a
third UST to be present on the OU No. 4 site that was not found
during the RI field work. The USTs were reported to have last been
used in 1983 and the date of installation is not known. Reportedly
all three tanks were emptied and purged in August 1989.
During a file review, a separate UST was noted on a RSR Corporation
construction map dated 1982. The location of this tank is between
the Bath House and Hog Storage Building. This is the only site map
to be located that indicates the presence of a fourth UST. There
are no visible signs of an UST on the pavement surface in the area
indicated on the construction map. It is not known if this fourth
tank has been removed or was abandoned in-place.
K. Nature and Extent of Contamination
As part of the RI, all potential sources and areas of contamination
were investigated. These areas included all of the surfaces and
floors of the buildings, structures and equipment, residual and
process piles, the surface and subsurface soils, the stormwater
mnoff and sediments located in the floor drains and sumps, the
USTs and the ground water. Samples were collected and analyzed
from each of these areas to evaluate the nature and extent of
contamination. Migration to the subsurface soils and the ground
water was also investigated through exploratory borings and the
installation of ground water monitoring wells.
A summary of the findings of the RI and the non-time critical
removal action is provided in the discussions below, however as
stated previously, all of this information can be found in detail
in the Remedial Investigation Report and supporting Technical
Memorandums, which are all part of the Administrative Record for OU
No. 4.
1. Buildings and Structures Results
One-hundred and eighty-five bulk samples of building materials were
analyzed for the presence of asbestos. Nonfriable asbestos was
detected in materials located in all of the onsite buildings and
stack with the exception of the Former Gas Station where no
asbestos containing materials was identified. The only detected
friable asbestos was approximately one cubic yard of soil debris in
the Smelter Stack, and three linear feet of pipe insulation and
three mudded pipe joints in the Hog Storage Building. Under
present conditions, mobilization of asbestos that is present within
12
-------
these structures could be caused by human activities, but is
considered unlikely. However, should these structures fail due to
structural instability, asbestos could be released.
Supplemental dust sampling was necessary to confirm contamination
on all OU No. 4 buildings, as described in the Proposed Plan. In
May 1995, three dust samples from each process-related building
(e.g. Smelter Facility, Batch House, Hog Storage Building) and two
dust samples from each non-process-related buildings (all other
buildings) were collected using a high-volume dust sampler and
analyzed for the Total Analyte List (TAL) metals. In addition,*
during the field investigation in the spring of 1994, eighty-six X--
ray Fluorescence (XRF) readings on building surfaces (e.g. walls
and floors) were taken on the process-related buildings.
The dust samples collected as part of the supplemental sampling
indicated, arsenic concentrations ranging from 17 parts per million
(ppm) to 22,300 ppm, cadmium ranging from 12 ppm to 1,270 ppm and
lead ranging from 1,170 ppm to 311,000 ppm. Antimony
concentrations were as high as 11,400 ppm. Figure 4 shows the
sampling locations and results for lead, cadmium and arsenic.
The XRF data from the process related buildings walls and concrete
floors also indicated extensive contamination from lead, cadmium
and arsenic. In the Smelter Facility maximum concentrations
detected were 143,466 ppm, 6,310 ppm and 23,847 ppm of lead,
cadmium and arsenic, respectively. The Batch House XRF data showed
maximum concentrations of 90,133 ppm, 4,612 ppm and 12,080 ppm of
lead, cadmium and arsenic, respectively. The concentrations
detected using XRF in the Hog Storage building for lead, cadmium
and arsenic were as high as 60,165 ppm, 455 ppm and 7,218 ppm,
respectively.
One dust sample was collected from loose material from the floor of
the inner stack and the concentration of lead, cadmium and arsenic
was 29,000 ppm, 190 ppm and 39,000 ppm, respectively. Antimony was
reported at an estimated concentration of 11,700 ppm in a dust
sample near the stack. Two samples of the brick lining and
residual material on that lining were also collected at a height of
approximately 25 feet and 160 feet. At the 25 foot height in the
stack, total lead, cadmium and arsenic was detected at 44,000 ppm,
870 ppm and 140,000 ppm, respectively. The concentrations detected
at the 160 foot height were slightly less. The samples collected
for Toxicity Characteristic Leaching Procedure (TCLP) analysis
indicated both lead and arsenic concentrations exceeded the
criteria for definition of a hazardous waste by the characteristic
of toxicity (i.e. 5.0 ppm for both lead and arsenic).
Other samples of residual materials in and around the buildings and
structures were also collected. These included samples of
diatomaceous earth, refractory brick, and dust. The results of
these samples were used to support the non-time critical removal
13
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WESTMORELAND ROAD
-------
action conducted in June and July 1995 (described fully in Section
V.K.6). The lead concentrations present in these materials were as
high as 287,000 ppm, while maximum arsenic and cadmium
concentrations were 120,000 ppm and 43,000 ppm, respectively. The
maximum antimony detected in the residual material was an estimated
60,000 ppm. Note, there are several areas within the equipment
/piping located in the smelter facility that contain residual
material that were not addressed as part of the non-time-critical
removal action.
As stated previously in Section V.J.2 all of the onsite buildings,
structures and equipment are in advanced stages of disrepair and
deterioration. This combined with the elevated concentrations of
lead, cadmium and arsenic present on and within the buildings,
structures and equipment surfaces give rise to potential releases
or migration of contamination. Precipitation and/or high winds
could cause re-suspension of the depositions on the buildings,
structures and equipment surfaces as fugitive dust. Inadvertent
human activities could also potentially cause the re-suspension of
these depositions. Subsequent transfer of the contamination by air
or stormwater runoff is also likely.
2. Stormwater and Sediment Results
Stormwater runoff samples were also collected from OU No. 4 to
determine the nature and extent of affected stormwater. Figure 5
illustrates the surface drainage flow direction and the elevated
concentrations of lead, cadmium and arsenic detected in the
samples. Dissolved concentrations of detected metals were
relatively low. However, the total metal concentration of lead,
cadmium and arsenic were higher and were 2.09 ppm, 0.255 ppm and
0.067 ppm, respectively.
Although dissolved metal concentrations were lower than total
concentrations, stormwater appears to be a potential transport
medium for metals associated with surface soil, sediments, and
residual materials on pavement and structure surfaces. Metals
associated with these materials are likely entrained within
stormwater runoff as suspended solids, transferred downgradient and
redeposited as sediment at locations where stormwater is allowed to
pond.
Eleven sediment samples from various locations were collected both
inside and outside of OU No. 4 structures. Some of the samples
were collected from manmade structures such as trench drains,
spalled concrete, sumps and the smelter kettle basin. All samples
exhibited elevated levels of lead, cadmium and arsenic. Lead
levels were as high as 75,600 ppm, cadmium and arsenic levels were
as high as 506 ppm and 4,450 ppm, respectively. See Figure 6.
The sediment results indicated a widespread distribution of site-
related contaminants associated with affected sediments in runoff
14
-------
33
58
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WESTMORELAND ROAD
-------
WESTMORELAND ROAD
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across the site. Sediments likely represent a continuous source
for potential offsite migration via re-entrainment in stormwater
runoff. Re-suspension of exposed, surface sediment depositions as
fugitive dust could also occur due to high winds or inadvertent
human activities.
3. Surface Soils (0-2 feet) Results
Six surface soil samples were collected from the unpaved, exposed
area in the northeast portion of OU No. 4. All the samples
exhibited elevated concentrations of lead, cadmium and arsenic.
Detected levels of lead were as high as 83,100 ppm, while cadmium
and arsenic concentrations were as high as 760 ppm and 5,090 ppm,
respectively.
These results indicate a widespread distribution of site-related
contaminants associated with affected surface soils in the
northeast unpaved area that was probably attributable to process
waste staging/disposal activities. The surface soils likely
represent a continuous source for potential offsite migration via
re-entrainment in stormwater runoff. Re-suspension of soil as
fugitive dust could also occur due to high winds or inadvertent
human activities.
4. Subsurface Soils (greater than 2 feet) Results
Subsurface soil samples at various depths across OU No. 4 were
collected and analyzed to determine the vertical extent of soils
contamination from past smelting operations. The locations of soil
and geoprobe borings from which subsurface samples were collected
as well as the detected lead, cadmium and arsenic concentrations
are presented in Figure 7. The highest concentrations of lead,
cadmium and arsenic were detected in the shallowest subsurface soil
horizon of 2 to 5 feet below ground surface (bgs). Maximum metal
concentrations within this soil horizon are 26,700 ppm, 9.1 ppm,
and 175 ppm for lead, cadmium and arsenic, respectively. However,
the distribution within this soil horizon was highly variable, with
the concentrations for lead ranging from 4.4 ppm to 26,700 ppm.
There was no apparent pattern to the observed areal distribution of
metals contamination in the subsurface. This variability may be
due to a combination of factors including the construction
activities during the operational years of the smelter facility
that affected the original deposition of stack emissions.
Volatile organic compounds and some semi-volatile organic compounds
were detected in the subsurface soils only in the northwest area of
OU No. 4 and are thought to be associated with the Underground
Storage Tanks in that area.
Subsurface soils potentially represent a source of contamination
migration via entrainment or dissolution by infiltrated
15
-------
WESTMORELAND ROAD
-------
precipitation and subsequent vertical percolation to the shallow
alluvial deposits.
5. Ground water Investigation Results
The Eagle Ford Group (shale with occasional thin stratum of
sandstone, limestone and bentonite) overlies the Woodbine Aquifer,
and outcrops in the vicinity of OU Nos. 4 and 5. These formations
dip to the east and OU Nos. 4 and 5 are situated over the top of
the Eagle Ford shale, near the unconformable boundary between the
Eagle Ford and the overlying Austin Chalk. As a result the full
thickness of the Eagle Ford Group (200 - 250 feet) is expected to
be present beneath OU Nos. 4 and 5.
The soil borings drilled on OU Nos. 4 and 5 generally encountered
fill material and alluvial material consisting of clays, silts, or
sands to a depth of 10 to 25 feet bgs, at which depth of the
sometimes weathered Eagle Ford shale was encountered. During the
RI investigation, shallow ground water monitoring wells were
installed at seven locations across OU No. 4. These monitoring
wells were completed to depths of 12.3 to 25.7 feet bgs. Ground
water elevations and samples were collected from these monitoring
wells at two separate events in May 1994 and in June 1994. A
supplemental ground water investigation was also conducted to
enhance the characterization of the shallow alluvial aquifer in
June 1995 (after the issuance of the Proposed Plan). This
investigation involved collecting another round of ground water
samples from each monitoring well and performing slug tests on each
well to estimate in-situ hydraulic conductivity of the water
bearing strata.
The ground water elevations during the May 1994 sampling event
indicated a northwest-trending gradient. Lead was detected in a
range of 1.2 parts per billion (ppb) to 2,250 ppb, while
concentrations of arsenic ranged from Non-Detect (ND) to 77 ppb.
While the results from the second round of sampling in June 1994
indicated significantly lower lead concentrations, ranging from ND
to 646 ppb. Cadmium was not detected in either round of sampling.
The lower second round concentrations coincide with a lower level
of Total Suspended Solids (TSS) compared to the previous round,
suggesting that the majority of the metals contamination is
associated with particulate material. See Figure 8.
The results from supplemental ground water investigation in
June/July of 1995 indicated lower lead and arsenic concentrations
than previous sampling events. The results from the slug tests
indicated that the monitoring wells demonstrated relatively low
yield, with the majority of the wells bailed dry during purging
activities. The yield estimated from the water level changes
documented during the slug tests, and based on that data, the
expected yield for the shallow alluvial aquifer appears to be
16
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DALLAS. TEXAS
-------
significantly less that 1 gallon per minute at most locations. In
addition, this yield could not be maintained at any one location
for any period of time, since most wells were purged dry in a
relatively short time period.
6. Non-time critical removal action
EPA commenced the removal action at OU Nos. 4 and 5 on Hay 30, 1995
and completed all work by July 14, 1995. Waste materials present
at 90 residual/debris piles and drum locations were remediated
during the removal. This included more than 600 drums of waste
material, and more than 60 containers of waste laboratory
chemicals. This resulted in a total of over 740 cubic yards of
consolidated waste being manifested to a hazardous waste landfill
for stabilization or encapsulation; 1700 gallons of hazardous
liquids manifested to an incineration facility; 20 cubic yards of
debris sent to a class I nonhazardous landfill; more than 15,500
gallons of collected rainwater and drummed monitoring well water
permitted for discharge into the sanitary sewer system; 22 lab
packs of chemicals manifested to an incineration facility; one box
of medical waste sent to a medical incineration facility; and 11
gas cylinders and 8 lead/acid batteries recycled. All of the
materials were removed from OU Nos. 4 and 5 and disposed in
accordance with the requirements specified in EPA's Action
Memorandum, dated December 22, 1994.
As part of the removal action, testing of the surfaces once a
residual waste/debris pile was removed was performed to document
the concentration of the surfaces following removal. This testing
was performed using a field portable Spectrace 9000 x-ray
fluorescence (XRF) instrument. The lead concentrations on the OU
No. 4 surfaces following removal ranged from 3050 ppm to 175,681
ppm, arsenic concentrations ranged from 801 ppm to 51,077 ppm and
cadmium ranged from 84 ppm to 7,407 ppm. These results indicate
elevated levels of lead, arsenic and cadmium are still present on
the concrete floors of the buildings, structures and equipment.
VI. SUMMARY OF SITE RISKS
A. Risk Assessment Description
An evaluation of the potential risks to human health and the
environment from OU No. 4 contaminants was conducted as part of the
baseline risk assessment. The risk assessment was conducted as
part of the RI. The baseline risk assessment is an analysis of the
potential adverse human health effects (both current and future)
resulting from exposures of humans to hazardous substances present
on OU No. 4. By definition, a baseline risk assessment evaluates
risks that may exist under the no-action alternative (that is, in
the absence of any remedial actions to control or mitigate
releases). The baseline risk assessment provides the basis for
17
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taking the remedial action and indicates the exposure pathways that
need to be addressed by the remedial action*
The Summary of Site Risks section of the ROD summarizes the results
of the baseline risk assessment. Calculations and a more detailed
analysis may be found in the baseline Human Health Risk Assessment
and Ecological Risk Assessment reports for OU No. 4, contained in
the Administrative Record for OU No. 4.
B. Human Health Risks
The baseline risk assessment was divided into two parts: the human
health evaluation and the ecological evaluation. The baseline risk
assessment for the human health risks was based on Reasonable
Maximum Exposure (RME). The human health evaluation considered all
contaminated media, such as the buildings, structures and equipment
surfaces (residual materials), sediments (located in the floor
drains, sumps as part of the concrete pads) and the soils. The
baseline risk assessment assumed that the reasonably anticipated
future land use of OU No. 4 would be commercial/industrial, based
on the City of Dallas current zoning map. Therefore, the potential
risk to the following populations that most likely to be exposed at
OU No. 4 are:
o Current and Future onsite trespassers
o Future Commercial/Industrial Worker
Note, there is visual evidence of trespass (e.g. graffiti, etc.) at
OU No. 4, despite fences, and warning signs. Furthermore, the
reasonably anticipated future use of the OU No. 4 site is
commercial/industrial, based on the current zoning map for the City
of Dallas. The risk assessment conducted at OU No. 4 of the RSR
site was done in accordance with EPA guidance, specifically the
Risk Assessment Guidance for Superfund: Volume I: Human Health
Evaluation Manual (Part Al (Interim Final. EPA/540/1-89/002.
p^9^m^r 1989) . The major components of the baseline risk
assessment are: identification of contaminants of concern, exposure
assessment, toxicity assessment, and risk characterization.
Highlights of the findings for the major components of the risk
assessment for the site are summarized below.
C. Identification of Chemicals of Potential Concern
The samples collected as part of the field investigation and
analyzed through the Contract Laboratory Program (CLP) were used in
the risk assessment to estimate risks to human receptors at OU No.
4. This includes data for soil, sediments and residual piles.
Ground water results were not used quantitatively in the risk
assessment (see rationale in Section D. Exposure Assessment).
Concentrations of metals detected in surface soil samples were
compared to regional background soil concentrations. Metals were
18
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evaluated to determine potential chemicals of concern (COPCs) for
use in the HHRA. The COPCs identified for the site are listed in
Table 1.
D. Exposure Assessment
The objective of the exposure assessment is to estimate the type,
magnitude, frequency, duration and route of exposure of the
contaminants of concern. The contaminant sources are as a result
of past operations are soil, sediment and residual materials in the
buildings that contain the COPCs. The COPCs are released through
physical/chemical processes that include, leaching, precipitation-
induced runoff, wind entrainment or direct contact.
Shallow ground water in the area of OU No. 4 is not being used as
a potable water supply, nor is it expected to be used as a water
supply, therefore, ingestion of ground water is not considered a
complete pathway for purposes of this risk assessment. Drinking
water is provided by the City of Dallas through a series of surface
water reservoirs. The nearest public supply well is about 3,750
feet east of the intersection of Westmoreland Road and Singleton
Boulevard. This City of Dallas well is capped and no longer used
as a public water supply. The well is approximately 2,540 feet
deep. The following exposure scenarios and pathways were
quantitatively evaluated in the HHRA:
• Current and Future Onsite Trespassers (children and
adults) — Incidental ingestion of soil and residual
dust, inhalation of resuspended particulate, and
dermal contact with soil and residual building
materials.
• Future Commercial/Industrial Worker— Incidental
ingestion of soil and residual dust, inhalation of
resuspended particulate, and dermal contact with soil
and residual building materials.
Exposure scenarios were evaluated using standard EPA default
exposure parameters for average (typical) and Reasonable Maximum
Exposure (RNE) conditions. RME is defined as the "highest exposure
that is reasonably expected to occur at a site. The intent of the
RME is to estimate a conservative exposure case. Trespasser and
commercial exposure scenarios evaluated in the HHRA used standard
EPA default exposure parameters for average (typical) and RME
scenarios. These parameters are presented in Table 2.
At the present time, EPA does not have an approved model for
estimating blood-lead levels in adults that are exposed to
environmental sources of lead. Consequently, for this HHRA, lead
exposure to adults (trespasser and commercial/industrial worker
scenarios) was estimated using a screening-level model developed by
Bowers et al. (1994). This model uses a biokinetic slope factor
19
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Table |
Chemicals of Potential Concern
RSR Corporation Superfund Site
Operable Unit No. 4
COPC
Medium
Surface
Soil
Residual
Piles
Metals
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
DEN10016C1C.WPS
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Table "2-
Exposure Assumptions
RSR Corporation Superfund Site
Operable Unit No. 4
Daily SoU fofestioa Rate (mf/day)
Duly Inhalation Rate (nrYday)
Exposure Duration (yean)
Body Weight (kg)
Avenging Time— Noncancer
(year.)
Averaging Time—Cancer (yean)
Trespasser -Child
Typical
Exposure
50
20
52
10
43
10
70
Marinra
Expoore
100
20
52
10
43
10
70
Trespasser-Adult
Topical
Exposure
50
20
52
10
70
10
70
Reasonable
Maximum
Exposure
100
20
52
10
70
10
70
Owimeraal/lBdasfiial-
Adutt
Typical
Exposure
25
20
250
9
70
9
70
Exposure
50
20
250
25
70
25
70
Sources: EPA, 19S9a; EPA, 1989b; EPA, 1991a; and EPA, 1992*.
DEN10016C1B.WP5/2
-------
derived from the work of Pocock et al. (1983), who measured blood-
lead levels in over 7,000 middle-aged men in 24 British towns, to
estimate blood-lead levels of adults exposed to environmental
sources of lead. The study yielded a biokinetic slope factor of
0.375 M9/dL blood-lead per iig/day lead uptake. Blood-lead results
from the Bowers model for the adult exposure scenarios were
compared to the OSHA "permissible11 blood-lead level of 40 pg/dL.
OSHA specifies that lead-exposed workers with blood-lead levels
above 40 pg/dL require further medical monitoring or workplace
intervention. For the purposes of this HHRA, 40 pg/dL was used as
a screening-level permissible blood-lead level for adults.
E. Toxicity Assessment
The toxicity assessment involves identifying the COPCs which may
cause adverse health effects in exposed individuals. The toxicity
assessment seeks to develop a reasonable appraisal of the
associations between the degree of exposure to a chemical and the
possibility of adverse health effects. Whether or not a toxic
response occurs depends on the chemical and physical properties of
the toxic agent, the degree of exposure to the agent, and the
susceptibility of an individual to the particular effect. To
characterize the toxicity of a particular chemical, the type of
effect it can produce and how much is needed to produce that effect
must be known.
For purposes of the risk assessment, health effects are divided
into two categories; noncancer and cancer effects. Noncancer
health effects include a variety of toxicological end points and
may include effects on specific organs or systems, such as the
kidney, liver, nervous system and lungs. There are two categories
of noncancer health effects, acute or subchronic, which are short-
term, and chronic, which are long-term. Some chemical exposures
that result in, or are suspected in the development of cancer and
are referred to as carcinogens. EPA/s carcinogen classification
scheme, using a weight of evidence approach to determine the
likelihood of a chemical/s carcinogenic potential in humans, is
described below.
20
-------
Category Meaning Basis
A Known human Sufficient evidence of increased cancer
carcinogen incidence in exposed humans.
Bl Probable human Sufficient evidence of increased cancer
carcinogen incidence in animals, with suggestive
evidence from studies of exposed humans.
B2 Probable human Sufficient evidence of increased cancer
+-carcinogen incidence in animals, but lack of data
or insufficient data from humans.
C Possible human Suggestive evidence of carcinogenicity
carcinogen in animals.
D Cannot be No evidence or inadequate evidence of
evaluated cancer in animals or humans.
E Noncarcinogen Evidence of noncarcinogenicity
or humans.
Toxicity values are quantitative expressions of the dose-response
relationship for a chemical and are expressed as cancer slope
factors and noncancer reference doses, both of which are specific
to the route of exposure. The chronic reference doses (RfDs),
which are expressed in terms of mg/kg-day are presented in Table 3
for the chemicals of concern for the OU No. 4 site. The dose-
response relationship for cancer effects is expressed as a cancer
slope factor (SF), which is the upper-bound estimate of the
probability of a response per unit intake of a chemical over a
lifetime. The SFs for the chemicals of concern at the OU No. 4
site are described in Table 4 and are expressed as the inverse of
mg/kg-day.
F. Human Health Risk Characterization
The risk of cancer from exposure to a chemical is described in
terms of the probability that an individual exposed for his or her
entire lifetime will develop cancer by age 70. For carcinogens,
risks are estimated as the incremental probability of an individual
developing cancer over a lifetime as a result of exposure to the
carcinogen. Excess lifetime cancer risk is calculated from the
following equation:
Risk = CDI x SF
where:
risk = a unit less probability (e.g., 2 X 10-5) of an individual
developing cancer;
21
-------
Table 3
Toxicity Values -Noncancer Health Effects
RSR Corporation Superfund Site
Operable Unit No. 4
Chemical
Systemic Toxicity (mg/kg/day)
Critical Effect
Chronic Reference Dose (RfD)
Oral
Source
Inhalation (b)
Source
Inorganics
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium (food)
Cadmium (water)
Chromium III
Chromium VI
Cobalt
Copper
Lead
Manganese (food)
Manganese (water)
Mercury
Nickel (soluble salts)
Selenium
Silver
Tudlium(e)
Vanadium
Zinc
-
Blood glucose, cholesterol
Keratosis, hyperpigmentation
Increased blood pressure
Organ changes, decreased
body weight
Proteinuria
Proteinuria
None observed
Increase in tissue chromium
connection
-
Gastrointestinal irritation
-
CNS
CNS
CNS, kidney
Decreased body /organ weight
fair/nail loss, dermatitis
Argyria
ncreased SCOT (liver),
increased serum LDH
blood), alopecia (hair)
Renal
Anemia
2.9
0.0004
0.0003
0.07
0.005
0.001
0.0005
1
0.005
-
0.037
(c)
0.14
0.005
0.0003
0.02
0.005
0.005
0.00008
0.007
0.3
ECAO
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
-
HEAST
_
IRIS
IRIS
HEAST
IRIS
IRIS
IRIS
IRIS
HEAST
IRIS
-
-
-
0.00014
—
-
—
-
—
-
-
-
0.000014
0.000014
0.000086
—
-
-
-
-
-
-
-
HEAST
•—
-
-
-
—
-
-
-
IRIS
IRIS
HEAST
-
-
-
—
—
HEAST = Health Effects Assessment Summary Tables (1994).
IRIS - Integrated Risk Information System (1994).
— as Information not available.
CNS » Central Nervous System.
(a) Derived from subchronic inhalation reference concentration (Rf€).
t>) Derived from chronic inhalation reference concentration (Rf€).
C) EPA work group considered it inappropriate to develop an RfD for inorganic lead.
d) Toxicity values correspond to nitrite.
e) Toxicity values correspond to thallium chloride.
DEN10016C2A.WP5/1
. ^T»i5as^^=^^ -•'
-------
Chemical
Table *
Toxicity Values -Cancer Health Effects
RSR Corporation Superfund Site
Operable Unit No. 4 Page 1 of 2
Carcinogenic Potency (mg/kg/day)4
Tumor Site
Weight of
Eridencc-
Source
Oral Slope
Factor
Source
Inhalation
Slope
Factor11
Source
Inorganics
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium HI
Chromium VI
Cobalt
Copper
Lead
Manganese
Mercury
Nickel (refinery dust)
Selenium
Silver
Thallium
-
-
Lung
-
Lung, Bone
Lung
Lung
-
-
Kidney
-
-
Respiratory System
-
„-
-
-
D
A
D
B2
Bl
D
A
-
D
B2
D
D
A
D
D
D
-
DWHA'
IRIS
DWHA0
IRIS
IRIS
DWHA*
IRIS
-
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
DWHA'
-
-
1.75
-
4.3
-
-
-
-
-
-
-
-
-
-
-
-
_
-
EPA4
—
IRIS
-
—
-
—
-
—
-
-
-
-
-
-
..
—
15
—
8.4
6.3
-
42
—
-
—
-
-
0.84
-
-
-
IRIS
—
IRIS
IRIS
-
IRIS
—
-
-
-
-
IRIS
-
-
-
DEN10016C2B.WP5
-------
Table 4-
Toxicity Values-Cancer Health Effects
RSR Corporation Superfund Site
Operable Unit No. 4
Chemical
Vanadium
Zinc
Page 2 of 2
Carcinogenic Potency (mg/kg/day)4
Tumor Site
-
-
Weight of
Evidence!*
-
D
Source
-
IRIS
Oral Slope
Factor Source
_ ..
- -
Inhalation
Slope
Factor1* Source
— ~
_ ..
HEAST - Health Effects Assessment Summary Tables.
IRIS = Integrated Risk Information System.
= Information not available.
'Weight of Evidence Groups: A is Human Carcinogen; B is Probable Human Carcinogen (Bl -limited evidence of carcinogenicity in humans,
B2-sufficient evidence of carcinogenicity in animals with inadequate or lack of evidence in humans); C is Possible human Carcinogen; D is Not
Classifiable as to Human Carcinogenicity.
bDerived from unit risk factor assuming an inhalation rate of 20 mVday and a 70 kg bodyweight.
cDrinking Water Health Advisory. USEPA Office of Drinking Water. April 1992.
dArsenic oral slope factor from: Special Report on Ingested Inorganic Arsenic, July 1988, EPA/625/3-87/013.
•Drinking Water Health Advisory. USEPA Office of Drinking Water. January 1987.
DEN10016C2B.WP5
-------
GDI = chronic daily intake averaged over 70 years (mg/kg-day); and
SF » slope-factor, expressed as (mg/kg-day)-1
These risks are probabilities that are generally expressed in
scientific notation (e.g., 1 x 10-6). An excess lifetime cancer
risk of 1 x 10-6 indicates that, as a reasonable maximum estimate,
an individual has a 1 in 1,000,000 chance of developing cancer as
a result of site-related exposure to a carcinogen over a 70-year
lifetime under the specific exposure conditions at a site.
The potential for noncarcinogenic effects is evaluated by comparing
an exposure level over a specified time period (e.g., lifetime)
with a reference dose derived for a similar exposure period. The
ratio of exposure to tbxicity is called the hazard quotient. By
adding the hazard quotients for all contaminants of concern which
affect the same target organ (e.g., liver) within a medium or
across all media to which a given population may reasonably be
exposed, the Hazard Index (HI) can be generated.
The HQ is calculated as follows:
Non-cancer HQ = E/RfD
where:
E = Daily Intake (either chronic or sub-chronic)
RfD = reference dose; and
E and RfD are expressed in the same units and represent the same
exposure period (e.g., chronic, subchronic, or short-term).
A summary of risks across all exposure pathways and exposure
scenarios evaluated in the OU No. 4 risk assessment is included in
Table 5. According to the assumptions used in this evaluation,
most of the total cancer risks and noncancer risks exceed EPA's
acceptable risk range of 1 x 10-4 to 1 x 10-6 for carcinogens and
a HI greater than one for noncarcinogens. These criteria are the
"points of departure91 for risk management decisions as described in
the NCP.
In the OU No. 4 risk assessment, among all receptor groups,
incidental ingestion of soil and residual material contributes the
greatest percentage of the overall risk (90 percent on average)
compared to the other pathways. Ninety-nine percent of the cancer
risk from this pathway may be attributable to arsenic. Similarly,
for noncancer risks, ingestion of arsenic is the greatest
contributor to the total HI (67 percent), however, antimony and
cadmium also had HI/s greater than one.
Risk from exposure to lead in soil within OU No. 4 was evaluated
for adult trespassers and workers. Children who trespass were not
22
-------
Table ?>
Summary of Risks
RSR Corporation Superfund Site
Operable Unit No. 4
Exposure
Scenario
Trespasser
Worker
(Process)
Worker
(Nonprocess)
Adult
(Typical)
Risk*
3 x lO'3
8 x lO"3
5 x 10-s
HIb
63
150
1.7
Adult
(RME)
Risk*
6 x lO'3
4 x lO'2
3 x IQr4
HI"
130
340
3.4
Child
(Typical)
Risk*
5 x lO'3
NA
NA
HIb
100 ,
NA
NA
Child
(RME)
Risk*
1 x lO-2
NA
NA
HI"
210
NA
NA
NA = Not applicable for this scenario.
•Values shown have been adjusted to show one significant figure.
•"Values shown have been adjusted to show two significant figures.
DEN10016C71.WP5
-------
quantitatively evaluated for exposure to lead, due to the lack of
an appropriate model.
An EPA-derived or accepted procedure for modeling adult exposure to
lead is currently unavailable; however, models have been proposed
for evaluating adult lead risks. For this risk assessment, adult
lead exposure was evaluated by calculating a blood-lead level for
trespassers, and both future process- and nonprocess-related
workers using a model developed by Bowers, et al. (1994). The
results of the model predict that the blood-lead levels for these
receptors range from 6 pg/dL (trespasser) to 78 /Ag/dL (future
nonprocess-related worker) based on geometric mean concentrations
of lead for each exposure area. The predicted blood-lead levels
for the future process-related worker is 56 /*g/dL. For comparison,
the OSHA "permissible11 blood-lead level is 40 j*g/dL. Predicted
blood-lead levels for workers exceed the OSHA benchmark.
6. Uncertainties Associated with Human Health Risk Calculations
Within the Superfund process, baseline quantitative risk
assessments are performed in order to provide risk managers with a
numerical representation of the severity of contamination present
at a site, as well as to provide an indication of the potential for
adverse public health effects. There are many inherent and imposed
uncertainties in the risk assessment methodologies. Table 6
summarizes the uncertainty and the potential bias in the risk
estimates.
H. Ecological Risks
An ecological risk assessment (ERA), was also conducted for OU No.
4 environment to quantitatively determine the actual or potential
effects to plants and animals onsite. The ERA was conducted as a
part of the RI in order to evaluate if the COPCs from the smelter
facility pose a risk to the environment in the absence of remedial
action. A summary is provided in the following paragraphs.
OU No. 4 includes a very small (less than 1.2 acre) terrestrial
habitat in the northeast corner of the facility. The remaining
area of OU No. 4 is covered by asphalt and occupied by various
structures. An investigation was first conducted to determine the
occurring ecological receptor populations. It was noted that
opportunistic mammals (rats and house mice) occupied the buildings,
along with pigeons. The terrestrial ecology habitat was occupied
by hispid cotton rats, house mice, robins, grass species and
several cottonwood trees. A quantitative assessment of the
terrestrial habitat area risk was then conducted. The exposure and
risk to plants, soil invertebrates, mice and robins was determined
by a toxicity evaluation approach. This approach entailed the
evaluation of site exposure conditions by comparison of exposure
point concentrations to literature-derived toxicity values. This
is a conservative screening approach which serves to identify the
23
-------
Table &
Uncertainties Associated With Human Health Risk Estimations
RSR Corporation Superfund Site
Operable Unit No. 4
Page 1 of 2
Uncertainty Factor
I. ExpQSMrt Assessment
Exposure ass umptions
Use of applied dose to estimate risks
Population characteristics
Intake
Effects of Uncertainty
Comment
May under- or overestimate
risk
May over- or underestimate
risks
May over- or underestimate
risks
May underestimate risks
Assumptions regarding media
. intake, population
characteristics, and exposure
patterns may not characterize
exposures.
Assumes that the absorption of
the chemical is the same as it
was in the study that derived
the toxicity value. Assumes
that absorption is equivalent
across species (animal to
humans). Absorption may vary
with age and species.
Assumes weight, lifespan,
ingestion rate, etc., are
potentially representative for a
potentially exposed population.
Assumes all intake of COPC is
from the exposure medium
being evaluated (no relative
source contribution).
n. Toxirity Assessment
Slope factor
Toxkky values derived from animal
studies
Toxicity values derived primarily from
high doses; most exposures are at low
doses
May overestimate risks
May over- or underestimate
risks
May over- or underestimate
risks
Slope factors are upper
95th percent confidence limits
derived from a linearized
model. Considered unlikely to
underestimate risk.
Extrapolation from animal to
humans may induce error
because of differences in
pharmacokinetics, target
organs, and population
variability.
Assumes linear at low doses.
Tends to have conservative
exposure assumptions.
DEN10015EAC.WP5
-------
Table &
Uncertainties Associated With Human Health Risk Estimations
RSR Corporation Superfund Site
Operable Unit No. 4
Page 2 of 2
Uncertainty Factor
Effects of Uncertainty
Comment
n. Toxitity Assessment (Continued)
Toxicifty values
Toxicky values derived from
homogeneous animal populations
Not all chemicals at the site have
toxicity values
May over- or underestimate
risks
May over- or underestimate
risks
May underestimate risks
Not all values represent the
same degree of certainty. All
are subject to change as new
evidence becomes available.
Human populations may have a
wide range of sensitivities to a
chemical.
These chemicals are not ad-
dressed quantitatively.
m. Risk Estimation
Estimation of risks across exposure
routes
Cancer risk estimates— no threshold as-
sumed
Cancer risk estimate— low dose linearity
Adult lead exposure quantified using
Bower, et al. (1994)
May under- or overestimate
risk
May overestimate risks
May overestimate risks
May under- or overestimate
risk
Some exposure routes have
greater uncertainty associated
with their risk estimates than
others.
Possibility that some thresholds
do exist.
Response at low doses is not
known.
Model used has not been
formally adopted for use by
EPA to assess adult lead
exposure. Until the model is
validated, the results should be
viewed as uncertain.
-------
predominant COPCs contributing to site ecological risk.
COPCs for the terrestrial habitat area were selected by a frequency
of detection and background concentration screen. All analytes
detected (>1%) were retained for further analysis. The maximum-
observed concentration was then compared to appropriate area-wide
background concentrations for COPC determination. Results of the
background comparison indicated that the occurrence of aluminum,
barium, beryllium, silver and vanadium were below background and
were therefore excluded from further evaluation within the ERA. In
addition, common elements of calcium, iron, magnesium, potassium
and sodium were also excluded from the analysis.
A reasonable maximum exposure (RME) point concentration was derived
from the results of the surface soils analysis of the terrestrial
habitat area. The derived 95% upper confidence limit (95% UCL) of
the chemical analysis results was used as the exposure point
concentration for all potential COPCs with the exception of
selenium, in which the maximum observed concentration was more
appropriate (since the maximum was below the 95% UCL).
For the determination of risk to plants and invertebrates, the soil
RME values were compared directly to literature-derived toxicity
values. For the determination of risk to mammals and birds, the
RME values were first evaluated to determine exposure dose. This
was achieved by a quantitative/ conservative evaluation of dose
received by the organism through the direct uptake of COPCs through
incidental soil ingestion, added to the dose received by the
ingestion of contaminated food sources (ie. plants and
invertebrates). These dose calculations were based upon
conservative bioaccumulation assumptions. The derived cumulative
dose received by the target receptor (small mammal and bird) was
then compared to literature derived dietary no observed adverse
effect levels (NOAELs) and lowest adverse effect levels (LOAELs)
for the determination of a risk range.
The quantitative evaluation of risk was conducted by a hazard
quotient method. The derived dose (for small mammals and birds)
was divided by the appropriate the NOAEL and the LOAEL, while the
RME soils concentration was divided by the appropriate literature-
derived protective level for plants and soil invertebrates. If the
resulting quotient was greater than 5, the analyte was considered
a final COPC for that receptor.
Results indicate that numerous inorganic chemicals are present that
can cause risk to the birds, mammals and plants. Risk to
invertebrates was minimal. The RME concentration of lead (61,671
ppm), for example, was well above risk-based levels for bird,
mammal and plant receptors. The oa No. 4 site itself is severely
disturbed, and the occurring ecology is possibly more affected by
physical site disturbances which have created the occurring
ecological structure. These physical factors in conjunction with
24
-------
the site COPC occurrence pose a risk to the onsite ecology*
I. Risk Assessment Conclusions
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
to public health, welfare, or the environment.
VII. REMEDIAL ACTION GOALS
The results of the field investigation and engineering analyses
have identified the following contaminant source areas on OU No. 4
of the RSR site and the associated affected media:
Area of Concern Media
Onsite Buildings/Structures Dust, residual materials,
Smelter Stack/Equipment sediments, stormwater runoff
Soils
- Northeast unpaved area Surface soils (0-2 feet)
- Other soils beneath Subsurface soils (1 foot beneath
pavement pavement)
Principal threat wastes are those source materials considered to be
highly toxic or highly mobile that generally cannot be reliably
controlled and that present a significant risk to human health or
the environment should exposure occur. The principal threats at OU
No. 4 of the RSR site are the arsenic, cadmium and lead
contaminated dust and residual materials present on and within the
buildings, structures, and equipment, including the smelter stack.
These areas present the most significant risk at the site, due the
potential for exposure through direct contact, inhalation and
incidental ingestion of arsenic, cadmium, antimony and lead
contaminated materials. There is also a potential for increased
risk due to the migration of these contaminants, as evidenced by
the elevated concentrations of arsenic, cadmium and lead in the
sediment and stormwater.
Low level threats are those source materials that generally can be
reliably managed with little likelihood of migration and present a
low risk in the event of exposure. The low level threats at the
site are the contaminated soils in the unpaved northeast area and
the subsurface soils beneath the paved area. The arsenic, cadmium
and lead contamination present in these areas are less mobile and
have a reduced migration potential due to the chemical and physical
properties of the soils.
As stated previously, due to lack of additional ground water data
at the time EPA issued the Proposed Plan for OU No. 4 the ground
25
-------
water was not addressed in the proposal and therefore is not
included as part of this decision for OU No. 4. The ground water
portion of OU No.4 will be evaluated and addressed concurrently
with OU No. 5, which is located across the street from OU No. 4.
As discussed in the Section VI. SUMMARY OF SITE RISKS , the arsenic
contributed most significantly to the carcinogenic risk at the site
and cadmium and antimony contributed greatly to the noncarcinogenic
risk. Furthermore, lead concentrations are present at unacceptable
levels based on the modeling done in the risk assessment.
The remedial action objectives for OU No. 4 of the RSR site are to
minimize exposure to the arsenic, cadmium and lead present in the
buildings, structures, smelter stack and equipment and soils by
direct contact, inhalation and ingestion, and to reduce the
potential for migration of these contaminants. In order to meet
these remedial objectives, remedial action goals for arsenic,
cadmium, antimony and lead in the buildings, structures and
equipment and lead and arsenic present in the soils have been
established. For the purposes of this document, the remedial
action goals are the same as action levels. These action levels
are used as a "triggerN to initiate an action. The remedial action
goals are outlined below and again as cleanup goals in the Selected
Remedy Section of this document.
Remedial Action Goals or Cleanup levels:
Buildings. Structures, Smelter Stack & Equipment
o Eliminate the potential for incidental ingest ion, and/or
dermal contact with contamination with arsenic in excess
of 32.7 ppm, antimony in excess of 818 ppm, cadmium in
excess of 2,044 ppm and/or lead in excess of 2,000 ppm
by onsite and offsite receptors.
Area Soils fUo to 2 feet)
o Eliminate the potential for incidental ingestion, and/or
dermal contact with contamination with arsenic in excess
of 32.7 ppm and/or lead in excess of 2,000 ppm by onsite
and offsite receptors.
The action level for arsenic is based on the 1X10-5 risk, since the
1X10-6 level corresponds to a level lower than background. The
action levels for antimony and cadmium are based on reducing the
risk to 1X10-6. The action level for lead is based on input of
site specific data into the Adult Lead Exposure Model (See Appendix
B), which is the latest available model for estimating non-
residential lead exposure. The Adult Lead Exposure Model uses site
specific exposure parameters consistent with the risk assessment.
Since the time EPA issued the Proposed Plan for OU No. 4, this
model has been refined and utilized by EPA as the most current
26
-------
accepted method for evaluating adult exposures. Although the
remedial action level for lead is different than that included in
the Proposed Plan, this change will have a negligible impact on the
volume of soil to be remediated, since arsenic drives the majority
of the risk. Since the soils are co-contaminated with lead and
arsenic and the action level for arsenic is more restrictive than
the action level for lead, excavating the soils to achieve the
arsenic action level will likely result in lead concentrations
below the lead action level. Any visible battery chips and slag
encountered during soil excavation will be included as part of the
soil remediation.
By addressing the contamination associated with the buildings,
structures, equipment and soils, the associated OU No. 4 site
specific risks will be eliminated.
VIII. DESCRIPTION OF ALTERNATIVES
A Feasibility Study was conducted to develop and evaluate remedial
alternatives for OU No. 4 of the RSR site. This report is included
in the Administrative Record for OU No. 4. Remedial alternatives
were assembled from applicable technologies/process options and
were evaluated for effectiveness, implementability, and cost based
on best professional judgement. The alternatives selected for
detailed analysis were compared to the nine criteria required by
the NCP. As required by the NCP, the no action alternative was
also evaluated to serve as a point of comparison for the other
alternatives.
The remedial action goals or cleanup levels set forth above in
Section VII., are the concentration levels below which contaminated
media can be left onsite and managed for a future industrial land
use. The remedial alternatives described herein address the
contamination associated with the buildings, structures, equipment,
including the smelter stack and the soils.
1. Remedial Action Alternatives
The remedial action alternatives for OU No. 4 of RSR site are
presented below followed by a description of the common elements of
each alternative.
Alternative la: No Action
Alternative Ib: Limited Action
Alternative 2: In-place Decontamination of
Buildings/Structures
Cap contaminated soils in northeast area
27
-------
Alternative 3: Decontaminate/ Dismantle Buildings/ Structures
Dispose Offsite
Cap contaminated soils (areal extent)
Alternative 4: Decontaminate/ Dismantle Buildings/Structures
Dispose debris offsite
Excavate contaminated soils
Dispose soils offsite
Elements
All of the alternatives with the exception of Alternative Ib have
the following common elements: (1) all general requirements
associated with contractor mobilization and demobilization, bonds
and insurance, decontamination facilities, a health and safety
program, and a community relations program; (2) all general site
work such as repair of existing perimeter fence and sampling of
surface water. Alternatives 2, 3, and 4 also include a provision
for air monitoring during remediation. All of the alternatives
with the exception of Alternatives la and Ib involve
decontamination of the buildings, structures and equipment with
standard cleaning methods, such as steam cleaning or vacuum
dusting.
All costs and implementation times are estimates. The costs have
a degree of accuracy of +50% to -30% pursuant to the Guidance for
Conducting Remedial Investigations and Feasibility Studies Under
CERCLA - Interim Final. OSWER Directive 9955.3-01, October 1988.
A brief description of the alternatives evaluated to address the
contaminated media on OU No. 4 of the RSR site follows.
Alternative la - No Action
Major Components of Alternative las
Evaluation of the No Action alternative is required by the NCP, 40
C.F.R. §300.430(e) (3) (ii) (6) , and is used as a baseline against
which other alternatives are evaluated. Under this alternative, no
remedial action would be undertaken to treat, contain, or remove
contaminated media at OU No. 4. No institutional or operational
controls would be implemented to restrict access to OU No. 4 or to
restrict exposure to contaminants. Monitoring would not be a
component of this alternative. Under the No Action alternative,
remaining waste not remediated by the removal action would be left
in place in an uncontrolled state and potentially endanger human
health and the environment.
Treatment Components i
There are no treatment components under Alternative la.
Containment Components;
There are no containment components under Alternative la.
28
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General Components2
There is no time needed to implement Alternative la, since no
remedial action is undertaken. And the costs are provided below:
Capital Costs: $0
Annual Operation &
Maintenance: $0
Present Worth $0
Alternative Ib - Limited Action
Maior Components of Alternative Ib:
This alternative includes taking steps to have deed notices or a
land use restriction placed in the deed records of the OU No. 4
properties to warn potential buyers and lenders of the presence of
contamination. Such deed notices and land use restrictions may be
difficult to obtain and enforce and may meet with substantial
opposition from many different sources. In addition, this
alternative includes the repair of approximately 2,500 linear feet
of fencing, posting warning signs, and providing 24-hour-a-day
guard services. Stormwater samples would also be collected and
analyzed three times annually at four locations under this
alternative.
Treatment Components;
There are no treatment components for the contaminated media under
this Alternative Ib.
Containment Components;
There are also no containment components under Alternative Ib.
General Components:
The estimated time needed to implement Alternative Ib, is less than
1 year. The estimated costs for implementation of this alternative
are provided below:
Capital Costs: $ 62,147
Annual Operation &
Maintenance: $ 193,320
Present Worth: $ 3,033,949
Alternative 2 - In Place treatment of Buildings/Structures;
Capping of Soils
Major Components of Alternative 2:
This alternative includes in-situ (in place) decontamination of the
contaminated buildings and structures; removal, treatment, and
disposal of residual material (not addressed previously by the non-
time-critical removal action); removal and disposal of asbestos
materials (in accordance with 30 TAC S 330.136); containment of
soils in the northeast area; monitoring of stormwater; and leaving
29
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the buildings and structures and concrete pavements in place.
Decontamination of all masonry and non-metal roofing material has
limited effectiveness, since the contamination is most likely
embedded and difficult to remove. Therefore, under this
alternative it is assumed that only the Smelter Facility, the Batch
House and the Hog Storage buildings can be effectively
decontaminated because they are metal and that the remaining
buildings and the smelter stack cannot be effectively
decontaminated.
Prior to preforming any work, a complete structural investigation
would be need to be conducted on the buildings and structures.
For the purpose of estimating costs, it was assumed that shoring
and bracing would be necessary. This is due to the poor condition
of the buildings and structures. Without maintenance and
rehabilitation, it is considered that these buildings would be a
safety hazard during remediation activities.
Treatment Components;
The water generated as a result of decontamination activities (such
as steam cleaning) or dust suppression must be collected, sampled
and pretreated, if necessary, prior to discharge to the City of
Dallas' Publicly Owned Treatment Works (POTW). See Table 7. In
addition, any dust collected as part of decontamination activities
would be sampled prior to disposal to determine if hazardous.
Collected dust that does not pass TCLP requirements would then be
treated according prior to disposal.
The collected residual material (debris and dust) and sediment
would be containerized and transported offsite for solidification
/stabilization and disposal at a RCRA Subtitle C landfill, as
necessary. The results from the RI indicated that the residual
materials and sediments are RCRA characteristic wastes (See Table
8) and as such would require treatment prior to disposal.
Containment Components:
Under Alternative 2 the metals contaminated soils in the unpaved
northeast area would be capped with 2 feet of clean backfill or
soil.
General Components;
The estimated time needed to implement Alternative 2, is less than
1 year. The estimated costs for implementation of this alternative
are provided below:
Capital Costs: $ 3,092,997
Annual Operation &
Maintenance: $ 240,630
Present Worth: $ 6,782,070
30
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Table q
OU No. 4 POTW Pretreatment Standard Exceedance Analysis
RSR Corporation Superfund Site
Dallas, Texas
Metal
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Zinc
OU No. 4
Surface Water
Data*
(ppm)
0.612
, 0.073
0.013
0.038
1.496
0.0004
0.020
0.002
ND
0.225
POTW Pretreatment
Standards"
(ppm)
0.5
1
5
4
1.6
0.01
9.0
0.2
4.0
5.0
Exceeds
Standard
(Yes/No)
Yes
No
No
No
No
No
No
No
—
No
Total metals analysis.
•"Dallas City Code, Chapter 49 "Water and Wastewater", Section 49-42(a)(ll).
ND = not detected.
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Table 8
OU No. 4 TCLP Exceedance Analysis for
Residual Material, Sediment, and Soil
RSR Corporation Superfund Site
Dallas, Texas
Sample Number,
Type and Location
4-R004 DH01
Dust (Residual Material)
Smelter Facility
4-R102 DH01
Dust (Residual Material)
Outside Smelter-Near Stack
4-R103 DH01
Dust (Residual Material)
Outside Smelter-Near Bag
House
4-R104 DH01
Dust (Residual Material)
Hog Storage
4-R105 FH01
Filter Bags (Residual
Material)
Hog Storage
4-T101 DH01
Dust (Residual Material)
Inner Stack Brick @ 160*
4-T101 DH02
Dust (Residual Material)
Inner Stack Residue and
Brick @ 25'
4-P001 SD01 (Sediment)
TCLP
Metal
Cadmium
Lead
Cadmium
Lead
Cadmium
Lead
Lead
Arsenic
Cadmium
Lead
Arsenic
Lead
Arsenic
Cadmium
Lead
Mercury
Lead
OU No. 4
TCLP Data (ppm)
39.1
92.2
640.0
4,000.0
2.3
11.0
200.0
12.0
37.0
350.0
47.0
24.0
3,900.0
3.9
8.6
0.35
39.2
TCLP
Criteria* (ppm)
1
5
1
5
1
5
5
5
1
5
5
5
5
1
5
0.2
5
Notes:
OU No. 4 diatomaceous earth (filter aid), subsurface soil boring, and subsurface test pit (soil data)
TCLP sample data do not exceed TCLP criteria.
•Toxicity Characteristics Leaching Procedure (TCLP) Criteria.
40C.F.R. Part 261.
DEN10017207.WP5
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Alternative 3 - Decontaminate and Dismantle Buildings /structures
and Dispose Offsite; Capping of soils.
Major Components of Alternative 3
This alternative includes removal, treatment, and disposal of
residual material; removal and disposal of asbestos materials (in
accordance with 30 TAG $330.136); demolition and removal of the
buildings, structures, equipment, smelter stack and pavement
foundations, and decontamination (where possible) of demolition
debris; capping the areal extent of OU No. 4 with clean backfill
or soil; and periodic monitoring of the cap.
All of the buildings, structures and equipment would be sampled to
classify waste type for disposal. If the samples indicate that
portions are hazardous (i.e. TCLP characteristic), then appropriate
parts of the buildings, structures and equipment will undergo
controlled dismantling. Based on the RI results, the smelter stack
would require controlled dismantling. See Table S. Controlled
dismantling includes using sawing, drilling, backhoes, and piece-
by-piece dismantling and then decontamination. For those parts of
the buildings, structures and equipment that are not hazardous
(i.e. do not fail TCLP), conventional demolition may be utilized.
Debris would then be disposed of in accordance with waste
classification results and requirements. Standard dust suppression
methods would also be utilized during all dismantling and the
demolition. The dismantling of the stack should be conducted only
during favorable weather conditions.
Treatment Components s
The water generated as a result of decontamination activities (such
as steam cleaning) or dust suppression would be collected, sampled
and pretreated as necessary prior to discharge to the City of
Dallas' POTW. In addition, any dust collected as part of
decontamination or dust suppression activities would be sampled
prior disposal (i.e. TCLP characteristic). Collected dust that
does not pass TCLP requirements would then be treated accordingly
prior to disposal offsite.
Any collected residual material (debris and dust) and sediment that
is RCRA characteristic (i.e. fails TCLP) would require treatment,
such as, solidification /stabilization prior to disposal. The
results from the RI indicated that the residual material and
sediment are RCRA characteristic wastes (See Table 8) and as such
would require treatment prior to disposal offsite at a landfill.
Containment Components:
Under Alternative 3 the areal extent of OU No. 4 would be capped
with 2 feet of clean backfill (estimated 6,800 cubic yards),
following removal of all buildings and structures, including
pavement foundations.
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General Components:
The estimated time needed to implement Alternative 3, is less than
1 year. The estimated costs for implementation of this alternative
are provided below:
Capital Costs: $ 9,298,547
Annual Operation &
Maintenance: $ 31,200
Present Worth: $ 9,778,168
Alternative 4 - Decontaminate and Dismantle Buildings/Structures
and Dispose Offsite; Excavate soils and Dispose Offsite.
Major Components of Alternative 4
This alternative includes removal, treatment, and disposal of
residual material; removal and disposal of asbestos materials (in
accordance with 30 TAC $330.136); demolition and removal of the
buildings, structures, equipment, smelter stack and pavement
foundations; and decontamination (where possible) and disposal
off site of demolition debris; excavation of up to 1 foot of soil
beneath the pavement foundations that exceeds remedial goals;
excavation of up to 2 feet of soil in the northeast unpaved area
that exceeds remedial goals; disposal of soils offsite; and capping
and/or backfilling the areal extent of OU No. 4 with clean soil.
All of the buildings, structures, equipment, smelter stack and
pavement foundations would be sampled to classify waste type for
disposal. In addition, if the samples indicate that portions are
hazardous (i.e. TCLP characteristic), then appropriate parts of the
buildings, structures and equipment will undergo controlled
dismantling. Based on the RI results, the smelter stack would
require controlled dismantling (See Table 8) . Controlled
dismantling includes using sawing, drilling, backhoes, and piece-
by-piece dismantling and then decontamination. For those parts of
the buildings, structures and equipment that are not hazardous
(i.e. do not fail TCLP), conventional demolition may be utilized.
Debris would then be disposed of in accordance with waste
classification results and requirements. Standard dust suppression
methods would also be utilized during all dismantling and
demolition. The dismantling of the stack should be conducted only
during favorable weather conditions. Demolition debris would then
be characterized and disposed of offsite, accordingly as a
hazardous or nonhazardous waste.
This alternative includes the excavation the concrete pavements,
associated floor drains and sumps, and up to one foot of soil
beneath the pavement, that exceeds remedial goals defined in
Section VII. An estimated 10,100 cubic yards of soils underneath
the pavements would be excavated. Note, the depth of excavation is
a change from what was described in the Proposed Plan for OU No. 4.
The basis for this change is discussed in Section XII.
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DOCUMENTATION OF SIGNIFICANT CHANGES. In addition, an estimated
3,400 cubic yards of soil in the northeast area (up to 2 feet of
soil that exceed Remedial Action Goals) would be excavated and
disposed of in an appropriate landfill.
Treatment Components :
The results of the TCLP sampling of the inner stack (See Table 8)
indicate that the inner bricks are RCRA characteristic and
therefore the inner stack must be handled, treated and disposed of
accordingly.
The water generated as a result of decontamination activities (such
as steam cleaning) or dust suppression must be collected, sampled
and treated as necessary prior to discharge to the City of Dallas'
POTW. In addition, any dust collected as part of decontamination
activities would be sampled prior to disposal (i.e. TCLP
characteristic). Collected dust that does not pass TCLP
requirements would require treatment, such as
stabilization/solidification prior to offsite disposal at a
landfill.
Any collected residual material (debris and dust) and sediment that
is RCRA characteristic (i.e. fails TCLP) would require treatment,
such as, solidification/stabilization prior to disposal. The
results from the RI indicated that the residual material and
sediment are RCRA characteristic wastes (See Table 8) and as such
would require treatment prior to disposal offsite at a landfill.
Containment Components;
Under Alternative 4 the areal extent of OU No. 4 would be capped
with 2 feet of clean backfill (estimated 13,500 cubic yards),
following removal of all buildings, structures, equipment, smelter
stack and pavement foundations.
General Components:
The estimated time needed to implement Alternative 4, is less than
1 year. The estimated costs for implementation of this alternative
are provided below:
Capital Costs: $ 11,490,795
Annual Operation &
Maintenance: $ 0
Present Worth: $ 11,490,795
Alternate component:
Under the alternate component, all of the non-hazardous debris and
soil from OU No. 4 would be disposed of in the landfill located on
the southern portion of OU No. 5 of the RSR site. This alternate
component does not affect disposal of any hazardous wastes. Note,
that implementation of this component is subject to public comment
and would have to be included and accepted as part of the Proposed
Plan for OU No. 5, when issued. If after reviewing public comments
33
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EPA decides to accept this component as part of the remedy for OU
No. 5, EPA will then include this component in the Record of
Decision for OU No. 5. The revised estimated cost incorporating
this alternate component for OU No. 4 would be as follows:
Capital Costs: $ 9,229,883
Annual Operation &
Maintenance: $ o **
Present Worth: $ 9,229,883
** The annual operation and maintenance costs associated with the
landfill, would be included in the cost estimate for OU No. 5.
II. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The EPA uses nine criteria to evaluate alternatives for addressing
a Superfund site. These nine criteria are specified in the NCP, 40
C.F.R. S 300.430(e)(9) and (f)(1). The criteria are categorized
into three groups: threshold, primary balancing, and modifying.
The threshold criteria must be met in order for an alternative to
be eligible for selection. The primary balancing criteria are used
to weigh major tradeoffs among alternatives. The modifying
criteria are taken into account after state and public comments are
received on a Proposed Plan.
Mine Criteria
The nine criteria that EPA uses in evaluating the remedial
alternatives are as follows:
Threshold Criteria
Overall Protection! 9f ffuman Health and the Environment addresses
the way in which an alternative would reduce, eliminate, or control
the risks posed by the site to human health and the environment.
The methods used to achieve an adequate level of protection vary
but may include treatment and engineering controls. Total
elimination of risk is often impossible to achieve. However, a
remedy must minimize risks to assure that human health and the
environment are protected.
Compliance with "applicable or relevant and appropriate
requirements (ARARs)" assures that an alternative will meet all
related Federal, State, and local requirements.
Balancing Criteria
Long-term Effectiveness and Permanence addresses the ability of an
alternative to reliably provide long-term protection for human
health and the environment after the remediation goals have been
accomplished.
Reduction of Toxicity, Mobility. or Volume of Contaminants through
Treatment assesses how effectively an alternative will address the
34
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contamination at a site. Factors considered include the nature of
the treatment process; the amount of hazardous materials that will
be destroyed by the treatment process; how effectively the process
reduces the toxicity, mobility, or volume of waste; and the type
and quantity of contamination that will remain after treatment.
Short-term Effectiveness addresses the time it takes for remedy
implementation. Remedies often require several years for
implementation. A potential remedy is evaluated for the length of
time required for implementation and the potential impact on human
health and the environment during implementation.
Implementability addresses the ease with which an alternative can
be accomplished. Factors such as availability of materials and
services are considered.
Cost (including capital costs and projected long-term operation and
maintenance costs) is considered and compared to the benefit that
will result from implementing the alternative.
Modifying Criteria
State Acceptance allows the state where the site is located to
review the proposed plan and offer comments to the EPA. A state
may agree with, oppose, or have no comment on the proposed remedy.
Community Acceptance allows for a public comment period for
interested persons or organizations to comment on the proposed
remedy. EPA considers these comments in making its final remedy
selection. EPA addresses the public comments in a Responsiveness
Summary, which is included as part of the ROD.
Comparative Analysis
The following discussion provides the comparative analysis for each
remedial alternative for OU No. 4 against the nine criteria:
1. Overall Protection of Human Health and the Environment
Alternatives la and Ib do not protect human health and the
environment and do not achieve the remedial action goals defined
for OU No. 4. Alternative Ib is only marginally more protective
than la because it potentially reduces access to contamination, but
likewise does nothing to reduce contamination. These alternatives
do not reduce exposure of the public and environment to the
contaminated materials at OU No. 4. Exposure may actually increase
if the buildings, structures and equipment are left in place and
continue to deteriorate and collapse, resulting in further releases
of contamination into the environment.
Alternative 2 provides moderate protection of human health and the
environment. Some of the remedial action goals are achieved by
reducing the exposure to contamination associated with the
buildings, structures and equipment. However, there are
35
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limitations to eliminating some of contamination due to the poor
condition of the buildings and the limitations of the cleaning
methods (i.e. steam cleaning or vacuum dusting) on the masonry
buildings. Residual contamination is likely to remain in
inaccessible areas in the buildings, structures and equipment after
cleaning. This may result in releases of contamination through
stormvater runoff or as the buildings further deteriorate and/or
collapse. Contamination associated with the smelter stack would
remain in an uncontrolled state. Contaminants left onsite under
this alternative may be released causing unacceptable risk to human
health and the environment.
Alternative 3 provides a greater degree of protectiveness than
Alternative 2, since contamination in and on the buildings,
structures and equipment is eliminated by removal and offsite
disposal of the debris. As an added benefit, physical and safety
hazards associated with the buildings also are eliminated.
Remedial action goals are more fully achieved and exposure to the
contaminated soils is reduced, but not eliminated.
Alternative 4 provides the greatest degree of protectiveness, since
contaminated soil also is removed from the site thereby eliminating
the most sources of contamination on OU No. 4. Furthermore, future
industrial development and use of the property is possible after
implementation of this alternative. Remedial action goals for the
buildings, structures, equipment, and soils are achieved.
2. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
Alternatives la and Ib do not meet any of the ARARs that have been
identified for OU No. 4, such as federal and RCRA closure
requirements, specifically; 40 C.F.R. Part 264, Subparts B,C and D,
which establish minimum standards defining acceptable management of
hazardous wastes, State of Texas closure and remediation
requirements in the Texas Administrative Code (T.A.C.) (30 T.A.C.
S335.8), Risk Reduction Standard No. 3 (30 T.A.C. §335.562), and 40
C.F.R. Parts 122 and 125, which describe management practices of
stormwater runoff requirements and State risk reduction rules.
For Alternative 2, the following ARARs would generally be achieved;
however, some residual material may be left in place in an
uncontrolled state in inaccessible areas (i.e. smelter stack,
building roofs, etc.): state closure and remediation requirements
(30 T.A.C. S335.8) and Risk Reduction Standard No. 3 (30 T.A.C.
§335.8); and 40 C.F.R. Parts 122 and 125, which describe management
practices of stormwater runoff. However, potential releases from
residual contamination from the buildings, structures and equipment
may prevent compliance with certain ARARs like federal stormwater
management requirements, due to the limited effectiveness of in-
situ decontamination. Disposal of asbestos containing materials
36
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would meet 30 T.A.C. 330.136. This alternative would comply with
RCRA handling, transportation, treatment and disposal requirements
(30 T.A.C. 5335.11, §335.91, S335.508). State and federal
chemical-specific ARARs for air quality (30 T.A.C. Section 118.1,
30 T.A.C. Section 111.115, 40 C.F.R., §50.3 and 51.160) during
remedial action would also be met. Furthermore, all offsite
disposal would be at facilities in compliance with EPA's Offsite
Policy, specifically all hazardous substances, pollutants or
contaminants removed of f site pursuant to this action for treatment,
storage, or disposal shall be treated, stored, or disposed of at a
facility in compliance with RCRA, as determined by EPA, pursuant to
CERCLA Section 121(d)(3), 42 U.S.C. § 9621 (d) (3) , and the
following rule: "Amendment to the National Oil and Hazardous
Substances Pollution Contingency Plan; Procedures for Planning and
Implementing Off-Site Response Action: Final Rule.11 58 Fed. Reg.
49200 (September 22, 1993), and codified at 40 C.F.R. § 300.440.
All of the components of Alternatives 3 and 4 will meet all of the
ARARs identified for OU No. 4, including: State closure and
remediation requirements (30 T.A.C. §335.8) and Risk Reduction
Standard No. 3 (30 T.A.C. §335.8); and 40 C.F.R. Parts 122 and 125,
which describe management practices for stormwater runoff; disposal
of asbestos containing materials would meet 30 T.A.C. 330.136;
RCRA handling, transportation, treatment and disposal requirements
(30 T.A.C. §335.11, §335.91, §335.508); State and federal
chemical-specific ARARs for air quality (30 T.A.C. Section 118.1,
30 T.A.C. Section 111.115, 40 C.F.R., §50.3 and 51.160).
Furthermore, all disposal offsite would be at facilities in
compliance with EPA's Offsite Policy.
3. Long-term Effectiveness and Permanence
Since none of the contamination (remaining after the non-time
critical removal action) at OU No. 4 will be treated or removed,
long-term effectiveness and permanence will not be achieved under
Alternatives la and Ib.
Alternative 2 does not completely achieve long-term effectiveness
and permanence. Residual amounts of contamination associated with
inaccessible areas of the buildings, structures and equipment may
remain. Contamination associated with the smelter stack remains in
an uncontrolled state. Moderate long-term effectiveness and
permanence is achieved for the contaminated soils, since residual
risk is low. The cap will require long-term monitoring and
maintenance to be effective.
Alternative 3 has a higher degree of long-term effectiveness and
permanence than Alternative 2, since contamination associated with
the buildings, structures, and equipment is removed,
decontaminated as appropriate, and disposed of offsite. Moderate
long-term effectiveness and permanence is achieved for the
37
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contaminated soils, since residual risk is low. The cap will
require long-term monitoring and maintenance to be effective.
Alternative 4 provides the greatest degree of long-term
effectiveness and permanence since the activities will result in
the permanent elimination of the most sources of contamination at
OU No. 4, through removal, treatment as appropriate, and offsite
disposal of contaminant sources.
4. Reduction of Toxicity, Mobility or Volume Through
Treatment
Alternatives la and Ib provide no reduction in toxicity, mobility
or volume of contaminants through treatment.
Alternative 2 provides a reduction in the toxicity, mobility, and
volume of some of the contamination associated with the buildings,
structures and equipment through the cleaning and decontamination
process. This reduction will be achieved through the collection of
the decontamination process water or vacuum dust and subsequent
treatment, discharge or disposal. However, residual contamination
will remain in the buildings, structures and equipment. There is
also a reduction of toxicity and mobility from the removal of the
residual materials contained in the buildings, structures and
equipment; however, there may be an increase in volume, through the
treatment process (solidification/stabilization). The mobility of
contaminants in the soil is reduced, but the containment action
will not reduce the toxicity or volume.
Alternative 3 provides a slightly greater reduction of toxicity,
mobility, and volume than Alternative 2 by eliminating all of the
onsite contamination associated with the buildings, structures and
equipment.
Alternative 4 provides a similar level of reduction as Alternative
3.
5. Short-Tern Effectiveness
Alternatives la and Ib have minimal short term effectiveness for
the community, since no removal of contaminated media occurs under
this alternative. Short-term effectiveness is not achieved for
trespassers.
Under Alternative 2 short-term risk to the community may increase
during implementation. There is also a potential for exposures to
workers during the remedial action. However, all appropriate
regulations and safety measures will be instituted and strictly
followed.
Alternatives 3 and 4 also involve an increase of short-term risk to
the community during implementation as well as risk to remedial
38
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action workers during demolition activities. However, dust control
and other safety measures will be implemented to protect the
community and the workers.
6. XapleMntability
There is no action to implement under Alternatives la.
Implementation of some aspects of Alternative Ib, such as posting
warning signs and fencing are readily implementable. However, land
use and deed notification or restrictions may be difficult or
impossible to obtain and enforce.
Alternative 2 is implementable. The technical feasibility of
cleaning methods such as, steam cleaning or vacuum dusting,
landfilling, and soil containment is proven, and equipment,
personnel and resources generally are available. However,
implement ability of the steam cleaning of the buildings is a major
concern due to the safety hazards associated with the poor
condition of the structures that may not be resolved through the
preliminary shoring and bracing efforts. Also, the condition of
structures may ultimately prevent the removal of contaminants to
safe levels.
Alternative 3 is also readily implementable. The technical
feasibility of demolition of the structures, surface cleaning of
certain demolition debris, soil containment, landfilling, and
covering is proven, and equipment, personnel and other resources
generally are available. The physical conditions of the buildings
and structures would require the implementation of certain safety
measures during demolition.
The implementability of Alternative 4 is nearly identical to that
of Alternative 3. The technical feasibility of conducting the
excavation and disposal of the soils is also well understood and
readily available.
7. Cost
Alternative la is the least expensive of all the alternatives
evaluated, but does not meet any of the other evaluation criteria.
Alternative Ib has a relative low cost, but like Alternative Ib,
does not meet any of the other evaluation criteria. Alternative 2
is in the mid range compared to the other alternatives and meets
some of the other criteria. The cost of Alternative 3 is high,
relative to Alternatives la, Ib and 2, but meets most of the other
evaluation criteria. Alternative 4 is the most expensive, but
meets all of the other criteria.
8. State Acceptance
The TNRCC has reviewed copies of the RI, Risk Assessment, FS and
this Record of Decision and has provided technical support on all
39
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EPA efforts at OU No. 4. The TNRCC on behalf of the State of Texas
concurs with EPA's selected remedial action for the smelter
facility, OU No. 4, of the RSR site.
9. Community Acceptance
Comments were received from the community during the public comment
period which opened May 10, 1995, and closed July 12, 1995.
Generally, the public favored EPA's recommendation for OU No. 4.
All comments submitted have been addressed, and responses are
included in the Responsiveness Summary (Appendix A) to this ROD.
EPA carefully considered all comments in making the final decision
on the selected remedial action for OU No. 4. Although the ground
water portion was deferred, new information was received during the
public comment period regarding the ground water that resulted in
minor changes to the alternative 4, as described in the Proposed
Plan for OU No. 4. These changes are described in Section XII.
DOCUMENTATION OF SIGNIFICANT CHANGES.
X. THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the
detailed analysis using the nine criteria, and the public comments,
EPA has determined that Alternative 4 - Decontaminate and Dismantle
Buildings/Structures and Dispose Offsite; Excavate soils and
Dispose Offsite is the most appropriate remedy for OU No. 4 of the
RSR site.
The major components of this remedy include:
Removal, treatment and disposal of residual material
(estimated 540 cubic yards)
Demolition and decontamination of approximately 190,000
square feet of buildings/structures and equipment,
including concrete pavement floors and connected drains
and sumps (and associated sediments), plug and properly
abandon remaining open conduits not removed
Disposal of all building debris (estimated 8,900 cubic
yards) offsite at appropriate landfill facilities
Demolition of the smelter stack and disposal offsite at
a RCRA Subtitle C landfill (estimated 1300 cubic yards)
Excavation of 13,500 cubic yards of contaminated soil
and/or battery chips and lead slag and disposal offsite
(up to 1 foot beneath pavements and up to 2 feet in
unpaved northeast area in excess of Remedial Action
Goals)
Cap and/or backfill the areal extent of the site with 2
feet of clean soil
All activities will be in compliance with federal and State ARARs,
specifically those for RCRA closure and remediation, RCRA handling,
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transportation, treatment and disposal requirements, asbestos
disposal requirements, and State and federal chemical specific
ARARs for air quality during remediation. In addition, all offsite
disposal of material must in compliance with EPA's Offsite Policy
at the time of disposal.
The estimated time for completion of this remedy is less than one
year and the estimated costs for this alternative are:
Capital Costs: $ 11,490,795
Annual Operation 6
Maintenance: $ 0
Present Worth: $ 11,490,795
The alternate component of Alternative 4, is preferred; however,
implementation of this component depends on public comment of the
OU No. 5 Proposed Plan. Under the alternate component, all of the
nonhazardous debris and soil resulting from the remedial action
would be sent to the landfill located on the southern portion of OU
No. 5 of the RSR site. If after considering public comment EPA
decides to accept this component, EPA will include it in the Record
of Decision for OU No. 5.
Remedial Action Goals
The purpose of this remedial action is to control risks posed by
direct contact, ingestion, and inhalation of the contaminated
buildings, structures, equipment (residual materials and dust) and
the contaminated soils. The results of the baseline risk
assessment indicate that existing conditions at the site pose an
excess lifetime cancer risk of 1X10-2 from ingestion of
contaminated residual materials and soil (by a child trespasser).
This risk relates primarily to arsenic, cadmium, antimony onsite.
Lead onsite was also determined to be present at unacceptable
levels. A model used to predict adult blood levels estimated
blood-lead levels for a future worker onsite in excess of those
limits established by OSHA. This remedy will address arsenic in
excess of 32.7, antimony in excess of 818 ppm, cadmium in excess of
2,044 ppm and lead in excess of 2,000 ppm present in or as part the
buildings, structures, equipment, including pavement floors, drains
and sumps, and the smelter stack. This remedy will also address
contaminated soils with arsenic in excess of 32.7 ppm and lead in
excess of 2,000 ppm up to a depth of 0 to 2 feet in the unpaved
northeast area and 0 to 1 foot in the area beneath the pavement and
foundations. The 2,000 ppm corresponds to the acceptable level, as
predicted by the Adult Lead Model (see Appendix B), the 32.7 ppm
corresponds to an excess cancer risk of the 1X10-5, and the levels
for antimony and cadmium correspond to an excess cancer risk of
1X10-6.
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XI. STATUTORY AUTHORITY FINDINGS AND CONCLUSIONS OF LAW
Pursuant to CERCLA, studies are conducted at NPL sites to
characterize the nature and extent of contamination associated with
a particular source of contamination and to determine the most
feasible cleanup approaches. At OU No. 4, EPA conducted a remedial
investigation, feasibility study, and risk assessment to determine
the nature and extent of site contamination.
The statutory determinations that are required for remedy selection
are in Section 121 of CERCLA, 42 U.S.C. S 9621. Under CERCLA, EPA
must select remedies that are protective of human health and the
environment, comply with ARARs (unless a statutory waiver is
justified), are cost effective, and utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. In addition,
CERCLA includes a preference for remedies that employ treatment
that permanently and significantly reduce the volume, toxicity, or
mobility of hazardous wastes as their principle element. The
following sections discuss how the selected remedy meets these
statutory requirements.
Protection 9^ ffmnan Health and the Environment
The selected remedy protects human health and the environment by
addressing releases or threats of releases of hazardous substances
through demolition, decontamination, treatment, as necessary, and
disposal of all of the contaminated buildings, structures and
equipment, pavements and smelter stack and excavation and disposal
of the contaminated soils. The entire OU No. 4 area would then be
capped with 2 feet of clean soil.
The selected remedy would eliminate the threat of exposure to the
lead, cadmium, arsenic and antimony present onsite through
ingestion, inhalation, and direct contact. The excess cancer risk
associated with these pathways is 1X10-2. By decontaminating and
removing all of the buildings, structures, equipment, pavements and
smelter stack and excavating the contaminated soil, the cancer
risks from exposure would be reduced to less than 1X10-6. This
level falls within the EPA's acceptable risk range of 10-4 to 10-6.
There are no short-term threats associated with the selected remedy
that cannot be readily controlled. In addition, no adverse cross-
media impacts are expected from the activities.
Compliance with Applicable or Relevant and Appropriate Requirements
The selected remedy would comply with ARARs. The complete ARARs
analysis, determinations and justification for ARARs for OU No. 4
of the RSR site are presented in Appendix C.
The following ARAR was omitted in the list in the Appendix, but is
applicable and must be complied with as part of the selected
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remedy; All disposal offsite would be at facilities in compliance
with EPA's Offsite Policy, specifically all hazardous substances,
pollutants or contaminants removed offsite pursuant to this action
for treatment, storage, or disposal shall be treated, stored, or
disposed of at a facility in compliance with RCRA, as determined by
EPA, pursuant to CERCLA Section 121(d)(3), 42 U.S.C. S 9621 (d)(3),
and the following rule: "Amendment to the National Oil and
Hazardous Substances Pollution Contingency Plan; Procedures for
Planning and Implementing Off-Site Response Action: Final Rule."
58 FR 49200 (September 22, 1993), and codified at 40 C.F.R. S
300.440.
Cost-Effectiveness
EPA believes that this remedy would provide the greatest reduction
of the risks to human health and the environment at an estimated
cost of $11,490,795. Therefore, the selected remedy provides an
overall effectiveness proportionate to its costs, such that it
represents a reasonable value for the money that will be spent.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
EPA believes the selected remedy represents the maximum extent to
which permanent solutions and treatment/resource recovery
technologies can be utilized in a cost-effective manner for the
types of materials and contaminants at OU No. 4 of the RSR site.
Of those alternatives that are protective of human health and the
environment and comply with ARARs, EPA has determined that the
selected remedy provides the best balance in considering long-term
effectiveness and permanence; reduction in toxicity, mobility, or
volume through treatment; short-term effectiveness;
implementability; and cost; as well as considering the statutory
preference for treatment as a principal element, and considering
State and community acceptance.
Preference for Treatment as a Principal Element
The selected remedy satisfies the statutory preference for
treatment as a principal element. Wherever possible, the selected
remedy utilizes treatment, such as steam cleaning, vacuum dusting
and stabilization/solidification as treatment methods.
Additionally, because hazardous substances may remain onsite above
health-based levels, five year reviews may be necessary at OU No.
4 of the RSR site.
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XXX • DOCUMENTATION OF SIGNIFICANT CHANGES
EPA issued the Proposed Plan for the RSR Corporation Superfund
site, Operable Unit No. 4 for public review and comments on Nay 10,
1995. In the Proposed Plan, EPA recommended the remedial action
under alternative no* 4 as the remedy that would best meet all nine
criteria and provides protection to human health and the
environment. EPA evaluated verbal comments, reviewed all written
comments and information submitted during the public comment
period. In addition, EPA has obtained additional data since Hay
1995 regarding the ground water and the contamination levels on the
support buildings at OU No. 4. Based on this review and
evaluation, EPA has determined that the following changes to the
alternative no. 4 proposal, as originally identified in the
Proposed Plan, are necessary:
!•) Change of maximum depth of excavation of contaminated
soil from 3 feet to 2 feet in the unpaved northeast area
and 1 foot underneath the pavement and foundations • The
basis for this change is the new information that was
received through the supplemental ground water sampling
that was conducted in June and July of 1995. The
results of the slug tests indicated that the shallow
alluvial deposits beneath the site are not a continuous
aquifer, and therefore do not meet the State of Texas
classification as a potential drinking water source.
Therefore, since the ground water does not present a
pathway for exposure to contaminants, excavation of up
to a maximum of 2 feet in the unpaved northeast area and
1 foot of soils beneath the pavements will minimize, if
not eliminate, potential for human health or
environmental exposure in the commercial or industrial
setting. Two feet of clean soil will then be placed
over the entire site.
2.) Eliminate the Underground Storage Tanks from the
selected remedy. EPA has eliminated this portion of
Alternative that was included in the Proposed Plan. EPA
will refer all information regarding the USTs to the
State of Texas to be handled under the State UST
program.
3.) Revise cost estimates for each alternative. The revised
cost estimates that incorporate the above changes for
each alternative are included in Appendix D. Note, the
cost estimate labeled Alternative 4a in the Appendix is
for Alternative 4, but incorporates the Alternate
Component, described above.
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RESPONSIVENESS SUMMARY
RSR CORPORATION SUPERFUND SITE
OPERABLE UNIT No. 4
APPENDIX A
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RESPONSIVENESS SUMMARY
RSR CORPORATION SUPERFUND SITE
OPERABLE UNIT No. 4
DALLAS, DALLAS COUNTY, TEXAS
INTRODUCTION
This Responsiveness Summary for the RSR Corporation Superfund
Site (RSR Site), Operable Unit (OU) No. 4, documents for the
Administrative Record public comments and issues raised during the
public comment period on the proposed plan for the smelter
facility. Pursuant to Section 117 of the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA or
Superfund), 42 U.S.C. § 9617, EPA considered all comments received
during the public comment period in making the final decision
contained in the Record of Decision (ROD) for OU No. 4.
OVERVIEW OF PUBLIC COMMENT PERIOD
The United States Environmental Protection Agency (EPA) issued
the proposed plan for OU No. 4 for public review and comments on
May 10, 1995. The initial thirty-day public comment period for the
proposed plan ended on June 12, 1995. At the request of a citizen,
EPA extended the public comment period to July 12,' 1995. EPA
conducted a public meeting on May 23, 1995, at the West Dallas
Multipurpose Center located at 2828 Fish Trap Road, in west Dallas,
Texas to provide information and answer questions about the
proposed plan and to receive public comments. A transcript of the
meeting was prepared and is available in the Administrative Record
for OU No. 4 located at the information repositories for the RSR
Site. This Responsiveness Summary contains EPA's responses to
verbal comments received during the public meeting and written
comments received during the comment period.
COMMENTS AND ISSUES RAISED DURING THE COMMENT PERIOD
1. Public Meeting, May 23, 1995, West Dallas Multipurpose Center
Comment: Will the EPA use the best and safest methods
available to take down the stack? Specifically, will the EPA
study and learn from the steel industry's experience in taking
down large stacks? Will EPA hire specialized contractors to
take down the stack rather than give the job to a general
purpose contractor? Will EPA make a commitment in the records
of decision to give the community, specifically Westmoreland
Heights Neighborhood Association, a chance to review and
comment on the qualification that would be required of the
contractors who demolish the stack before it's approved? Will
EPA monitor dust levels during demolition? Will EPA make sure
that work is done only during proper weather conditions? Is
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the stack built in two parts?
Response: Based on the information that EPA currently has
available, the smelter stack is approximately 300 feet tall
and consists of two cylindrical structures, one instead of the
other. The outer structure is cast in place concrete, while
the inner structure is masonry. EPA will require that the
best and safest available methods are used to take down the
stack. Prior to conducting any work, EPA will research and
gather information from other industries' experience on taking
down large stacks. In addition, EPA will ensure that the
plans for the removal of the stack require that it be done by
qualified contractors who have experience in this area. In
selecting a contractor EPA is required to follow specific
rules and regulations. These rules and regulations do not
allow for public review or comment regarding the hiring
decisions. However, EPA will make a commitment to the
community to keep them informed of the progress of the
project, including how and by whom the stack will be removed.
Air monitoring will be conducted during all demolition
activities and work on the stack will only occur during
favorable weather conditions.
Comment: Is there anything that the community should do to
protect themselves when the stack is being torn down? Are
there specific instructions that the community sliould follow?
Will this be done during peak hours, or while we're sleeping?
Will the area be blocked off where no traffic and the
residents are walking around? Should we keep the children
indoors? Should we wear masks and protective clothing? Are
we allowed to roam about?
Response: There are no specific instructions that the
community should follow during the demolition and removal of
buildings and the stack from the smelter facility. People
will not need to wear protective clothing or masks and can go
about their normal business. EPA will ensure that the
remedial activities will occur in a manner that is safe and
protective of the public. For example, during the remedial
action, dust suppression activities, such as wetting down
surfaces prior to demolition will be implemented, as well as
air monitoring to protect against offsite migration of
contamination.
Comment: After you tear down the smokestack, will it be
hauled off immediately, or will it be allowed to lay around?
Because you say you're going to wet it down and sooner or
later it's going to dry. After it's torn down, if it's left
there, then we're in more danger than we would be if it was
left standing.
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Response: EPA will require that the stack be removed from the
site for disposal as soon as possible. OU No. 4 is not a
large enough area to stockpile demolition debris, including
stack debris, for any significant period of time. Therefore,
construction sequences will require that demolition debris be
removed from the site as soon as possible to prevent
obstruction of other construction tasks. While debris is left
onsite awaiting removal and disposal, EPA will require that
protective measures be implemented to prevent migration of
contaminants.
Comment: How many barrels are in the smelter properties? How
do you plan on removing the barrels and keep anything from
leaking out of the corroded barrels?
Response: From May to July 1995, EPA conducted a non-time
critical removal action at OU Nos. 4 and 5 to remove
contaminants of more immediate concern. As part of the
removal action, EPA removed from the smelter properties over
600 drums and barrels. Materials inside the drums that were
compatible were consolidated in a tank truck prior to disposal
at an offsite facility. This procedure ensured that drums in
poor condition were not used for transportation. EPA also
implemented other procedures during the removal action to
prevent and contain spills during staging and consolidation
activities to minimize offsite migration. No drums remain on
the smelter property.
Comment: I know you are forging to demolish the smelter, but,
it seems that the community is being overlooked and EPA is
focusing on a building.
Response: EPA's initial cleanup activities were conducted in
the residential areas in west Dallas in order to resolve
smelter-related contamination problems in the areas where
people live. EPA collected thousands of samples and cleaned
up hundreds of private residences and high risk public areas
in west Dallas. Now that cleanup activities in the
residential areas are complete, EPA will focus on the smelter
properties (OU Nos. 4 and 5) . EPA's extensive investigations
show that the buildings at OU No. 4 are highly contaminated
and in poor condition causing releases or potential releases
of hazardous substances harmful to human health. To prevent
such releases, EPA has determined to demolish the buildings as
part of the remedial action for OU No. 4.
Comment: After you demolish that plant, two blocks from the
plant or one block from the plant, you've got as much
contamination on that side as we have at the plant. So the
question has to be why are you doing it? If you're doing it
for the same reason that the cleanup was done, it wasn't in
our behalf. The cleanup wasn't done in our safety. The
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cleanup was done for money, see, because you didn't do nothing
for us. Our houses is just as contaminated as they ever were
before it happened. And millions and millions have been
brought out of this neighborhood and have been spent on this
neighborhood. How much is it going to cost to clean the
smelter?
Response: Protection of human health and the environment is
EPA's main goal in addressing smelter-related contamination at
the RSR Site. EPA's first focus was to address smelter
contamination in the residential areas of west Dallas. EPA
collected thousands of samples in the residential areas of
west Dallas. In addition, extensive research and sampling was
performed to determine the safe level of lead for residential
areas, and 420 residential properties were cleaned up to the
safe level. The approximate total cost of all of these
activities in the residential areas was $15 million. As in
the residential areas of west Dallas, at OU No. 4, the smelter
property, EPA performed an extensive site-specific
investigation and assessment of risks to human health and the
environment from contaminants currently present at the smelter
property. EPA bases its decision as to how to cleanup OU No.
4 on the results of this investigation. EPA will now
concentrate its efforts on ensuring that the appropriate
cleanup is performed at OU No. 4 so that contamination from
this area will not pose a future risk to the community and the
land can be put to productive use. The estimated cost of the
cleanup at OU No. 4 is $11 million.
Comment: I'm going to want to find out who's getting the
contract, how the contract come about, how it was bidded on,
how did they receive the contract.
Response: If EPA conducts the cleanup of the smelter
facility, the awarding of the construction contract will
follow current federal contract award laws and regulations.
Generally, this consists of soliciting requests for proposals
submitted as sealed bids, which are all opened at a specified
time and date. The contract is then awarded to the lowest
bidder who provides the most technically and financially
feasible plan for conducting the work. All aspects of
awarding the construction contract are open to the public. If
the parties who are responsible for the contamination perform
the work, all non-confidential information submitted to EPA
for approval will be available to the public.
Comment: How did EPA distribute information about this
meeting tonight, and why is it that so many people didn't know
about it?
Response: Approximately two weeks in advance of the meeting,
EPA began notifying the public through various media of the
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issuance of the proposed plan for OU No. 4 and of the date and
time of the public meeting. EPA published a notice regarding
this meeting in the Dallas Morning News and mailed a post card
with the information to approximately 1,000 individuals and
companies on EPA's RSR Site mailing list. The mailing list
contains the names of all persons who have provided EPA their
names and addresses, and the list is constantly updated as new
names and addresses are provided. Anyone who wishes to be
added to the mailing list need only provide their address to
EPA so that they can receive future mailings. In addition,
following standard procedure, EPA provided notice to the
Technical Advisory Group (TAG) Technical Advisor, Dr. George
Njoku. EPA intends to follow similar procedures for
distributing information to and notifying the public of
important RSR Site events, proposals and decisions.
Comment: I'm concerned about the damage and the risk and the
exposures and what's really going to happen to us as a result
of this being done? Also, what is the future compensation for
any damages done to the people that's working up there to
remove or tear down that? What type of compensation is going
to be set up for them?
Response: Many safety measures will be implemented and
monitoring will be conducted during all cleanup and demolition
activities to ensure that the work is conducted in a safe
manner and that contamination does not migrate offsite and
cause exposure to citizens of west Dallas. The contractors
and site workers will also be required to follow rigid
procedures to protect themselves from contamination and
injury. Contractors will provide insurance that covers
accidents and injuries to the workers.
Comment: In the Super fund law or rule is no compensation
whatsoever given to anyone, moving someone that needs to be
moved out of their home, none of that is available to them if
the need arises?
Response: In certain limited circumstances EPA can
temporarily relocate persons or buy property. Such extreme
measures are only necessary when a site cannot be adequately
cleaned up without relocating the resident or destroying the
home. In the residential areas of the RSR Site temporary
relocation during the cleanup of residential yards was not
necessary since the work activities could be conducted in a
safe manner without causing a risk to the residents. In
addition, due to the nature and type of contamination in the
residential areas, it was not necessary to destroy homes to
achieve the cleanup goals established to protect human health.
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Comment: If you decide to tear that smokestack down and that
stuff gets to flying, I think those people within a mile
radius of that smelter should be moved out, just in case.
Response: At this time, we do not see a need for temporary
relocation during demolition activities. As previously
mentioned, all necessary measures will be used to ensure that
no contamination leaves OU No. 4, the smelter site, during
demolition and cleanup activities.
Comment: While they are doing the work over there, are you
going to be testing that air, monitoring that air, to see how
high it goes, or if it is getting outside? At what level
would you consider a risk?
Response: Air monitoring will be conducted to ensure that
demolition and other cleanup activities at OU No. 4 comply
with all State and Federal laws and regulations. Air monitors
will be installed onsite to detect whether any contaminants
leave the site. In addition, the City of Dallas has air
monitors at the Boys and Girls Club and Amila Earhart
Elementary School where continuous air sampling has been and
will continue to be conducted independent of the onsite air
monitoring. For example, during the demolition and cleanup
activities at the Dallas Housing Authority property (OU No.
2), measures to prevent air dispersion of contaminants were
implemented and the onsite air monitors as well as the City
air monitors did not detect unsafe levels of contaminants
during the activities. Likewise, during the demolition and
cleanup activities at the smelter property, measures to
prevent air contamination will be implemented and the air
quality regularly measured.
Comment: In awarding of the contract for this work to be
done, where will the contractors come from? How many people
in west Dallas will be able to go up there and get work?
We've got a lot of unemployment over here. Who can come up
there or go about getting signed up to be trained to help make
some of the $17 million that you're going to give this
contractor?
Response: Many aspects of cleaning up hazardous substances
require specialized skills, training and certification.
Generally, a contractor is hired that has experience with the
particular type of cleanup and who has hired employees or
provided employees with appropriate training. Awarding of the
cleanup contract for OU No. 4 will depend on who conducts the
remedial action. If the responsible parties conduct the
cleanup, they can choose any contractor they want as long as
the contractor is capable of doing the work in accordance with
EPA approved workplans. If EPA conducts the cleanup, the
contract would be advertised and awarded to the lowest bidder
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that is capable of conducting the cleanup. As with other work
conducted in west Dallas, local people are being hired when
possible. In the past EPA contractors have worked with the
West Dallas Neighborhood Development Corporation (WDNDC) to
hire minority subcontractors and local workers. EPA will
continue to work with WDNDC and the contractors to hire as
many local workers and subcontractors as possible.
Comment: I would like to know if you are going to use
dynamite to demolish the smelter? How are you going to get
that tall chimney?
Response: EPA generally intends not to use explosives to
demolish the smelter buildings or to bring down the stack.
The stack most likely will be demolished section by section
using a large crane. However, small amounts of explosives may
have to be used to break up the stack concrete so that it can
be removed in pieces. If small amounts of explosives are
used, it will be done in a controlled manner and in such a way
that contaminated dust will not migrate offsite.
Comment: How much dirt from the removal action is still
stored in the smelter?
Response: No dirt from the residential (OU No. 1) removal
action remains inside the building at OU No. 4. Soil from the
OU No. 1 removal action was temporarily stored in the smelter
building only until the classification of the soil was
determined allowing for offsite disposal. All residential
removal actions were completed and soils removed and disposed
of in approved landfills by June 1994.
Comment: Did anybody contact the insurance to see if there
was any money for the damage, if there were any for the
citizens and the neighborhood of this community?
Response: The Superfund statute gives EPA the authority and
funding to address environmental contamination. Superfund
does not allow EPA to provide compensation to individuals for
personal injury or health problems. EPA intends to use its
Superfund authority to the greatest extent possible to address
contamination related to the smelter facility. However, any
damage that may have been caused to citizens or the community
as a result of the smelter operation would have to be pursued
by the individual or community through different avenues.
Comment: How long will it take to bring the smokestack down
in your estimation?
Response: The remedial action will take approximately six
months to one year. This period is from the time the remedial
action starts to the time all demolition and removal
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activities are completed at the site. Before the remedial
action can begin, EPA has certain legal and technical
obligations to complete. For example, EPA must provide
parties who are potentially responsible for the contamination
the opportunity to finance or perform the action. In
addition, a remedial design must be conducted in order to more
specifically determine the details associated with each aspect
of the cleanup, including safety measures and measures to
prevent contamination from spreading during the activities.
These activities may take a significant period of time to
complete. However, EPA is committed to expediting these
necessary steps to ensure that the remedial action is underway
as soon as possible.
Comment: I noticed the barrels sitting on slat — on pallets.
Are those pallets deteriorated, too? So then you cannot put
a forklift under that to lift it to put it in another
container.
Response: Some of the pallets present at the smelter property
were deteriorated. However, those pallets were successfully
and safely removed from the smelter property during the non-
time critical removal action completed in July 1995.
Comment: Are you going to be as concerned about the asbestos
removal from the smelter building as you are about the lead?
Response: Asbestos will be removed from the smelter building
in accordance with all federal and state environmental and
safety rules before demolition activities begin.
Comment: Is the land going to be turned back to the owner?
Did EPA say cleared? We a long time ago asked that land at
that smelter be paved over, be paved completely with a five-
inch cement base covered, that there could not be and leakage
from under there ever to come up.
Response: The smelter property is currently owned by the
Murmur Corporation. EPA does not pwn any rights to the
property, and when the remedial action is complete, Murmur
will continue to own the property. The remedial action
outlined in the ROD for OU No. 4 specifies that the existing
buildings and pavements will be removed from the site, that
soils in excess of health-based cleanup levels will be removed
and that the entire site will be covered with two feet of
clean soil. Once the remedial action is completed, there will
not be a need to pave the site with five inches of cement to
prevent leakage of contamination. The cleanup activities in
the ROD will ensure adequate protection to human health and
the environment.
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Comment: I believe that the roofing made from asphalt and
paper and just like tar that was found on top of the projects
that was believed to be contaminated. And I believe that it
will hold the dust that comes through the air. So why not
cleanup or replace our roofs?
Response: Only 11 of 167 roofs in the DHA public housing area
(OU No. 2) were found to be contaminated to the extent that
they were classified as hazardous requiring cleanup. During
EPA's extensive sampling effort in the private residential
areas (OU No. 1) EPA tested lead levels from the drip line of
roofs. The results showed that even if contaminated dust was
trapped in the tar of residential roofs, the contamination was
not being released. In other words, the results would
indicate that lead dust is not falling from the roofs and
contaminating the soil or providing a pathway of exposure to
humans.
Comment: We like to request an extension of the public
comment period to around the end of June. We have several
neighborhood associations that we need to go to, to get their
input.
Response: The 30-day public comment period was extended an
additional 30 days to July 12, 1995.
Comment: Where are materials and the soil going to go?
Because citizens and communities are keeping a very keen eye
on this project right here. When will it be known where the
materials are going?
Response: All materials removed from the site will be
disposed of at appropriate permitted facilities designed to
handle the specific types of waste. Disposal facilities will
be selected by the contractor and approved by EPA. These
decisions will be made prior to the start of the remedial
action and will be available to the public.
Comment: EPA did insufficient testing on the antimony and
antimony is the marker that tells us if the lead come from the
lead smelter.
Response: EPA has tested for antimony as part of the
extensive home sampling (OU Nos. 1 and 2) conducted throughout
west Dallas and in the confirmation sampling conducted during
the removal action at the DHA site. However, EPA's sampling
in the residential areas was in accordance with proven
technical and scientific protocol, which concentrated on
detection of lead.
Comment: The county has built a $17 million detention
facility and emergency shelter as the crow flies within a half
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mile radius of the RSR vented lead smelter, on a hill. My
concern is that the kids that are in this detention facility,
the majority of the children at this emergency shelter are
children of color. Now, I'm not blaming the EPA for what the
county did. But I've also worked for the federal government;
and I don't trust the federal government, because I know they
lie. Okay? And I currently work for government now.
Response: There is no indication from EPA's and TNRCC's
extensive investigations in west Dallas, that persons located
at the detention facility are in danger of being exposed to
harmful levels of RSR smelter-related contamination. The
detention facility is located upwind of the former RSR smelter
and was built many years after the smelter permanently ceased
operations. Previous testing indicates that the lead levels
in the area of the detention facility are well below the
residential cleanup level of 500 ppm lead. Since smelter
operations permanently ceased in 1984 and the detention
facility is located upwind of the former smelter, there is
very little likelihood that smelter contamination will
contaminate the area in the future.
Comment: I know that the EPA wants to redevelop this area.
An I'm very much aware they're doing it because it's a drain
on the economy. So we're window dressing for all the world to
see on 1-30. You know, you people don't care. We do.
Response: EPA does not have control of redevelopment of the
smelter property. The property owner, Murmur, and potentially
the City of Dallas through zoning and other measures can
influence future redevelopment of the smelter property. EPA
has selected the remedial action set forth in the ROD for OU
No. 4 based on nine criteria that primarily focus on
protection of human health and the environment. An added
benefit to the selected remedial action is that the property
can be put to future productive use.
EPA's role in west Dallas is to address environmental
contamination in order to protect human health and the
environment and to keep the public aware of and involved in
the decision making. EPA has spent many years and many
millions of dollars fulfilling these responsibilities and
intends to continue its efforts to the full extent of its
authority.
Comment: Are any of you familiar with a little town called
Anderson Mill West in Cedar Park northwest of Austin? In 1990
they had a water tower that had been sandblasted which had
leaded paint in it. The question that I have is, why was that
neighborhood, which is predominantly white — lowered to 100
parts per million when they only had a water tower that had
been sandblasted? Why is it that we have to live under 500
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parts per million, when the city council have asked the EPA to
lower it to 250?
Response: EPA did not conduct the cleanup in Anderson Mill
West. The cleanup was conducted by the contractor who had
sandblasted the water tower and caused the contamination. The
contractor proposed a cleanup level of 100 ppm lead. The
Texas Air Control Board (predecessor to TNRCC) indicated that
a 500 ppm cleanup level was sufficient. However, the
contractor chose to cleanup to a lower level than 500 ppm.
Likewise, the Dallas City Council based the cleanup level of
250 ppm on a level used at another cleanup site where the
responsible parties decided to use a lower cleanup level than
was necessary.
EPA's cleanup level of 550 ppm is based on the extensive
sampling and investigation performed in the residential areas
of west Dallas. In addition, EPA performed a human health
risk assessment which examined site-specific conditions to
determine a safe lead level specific to persons living in west
Dallas. More information about the cleanup level in the
residential areas is available to the public in the
Administrative Record for OU No. 1 and the Administrative
Record for OU No. 2 located in the RSR Site information
repositories. Specifically, the RODs for OU Nos. 1 and 2
contain a summary of EPA's findings.
Comment: I heard you say a while ago that — I think you used
the word "confiscate" some of the money that you had spent.
And some of the people in the area have been trying for years
to receive money for their children. And you all do
everything you can do to keep from giving us any money.
Response: In order to perform the investigation and cleanup
activities at the RSR Site, EPA has spent money from the
Hazardous Substance Superfund, a fund made up in part by tax
dollars. The Superfund statute allows EPA to seek
reimbursement of funds it spends from parties that are
responsible for the contamination. EPA intends to pursue
responsible parties for reimbursement, and in addition, will
seek to have the responsible parties pay for or conduct the
cleanup at the smelter property. The Superfund statute does
not allow ElPA to compensate individuals for personal injury or
health problems. However, citizens may have recourse for such
harms under other laws.
Comment: We feel that the community as a whole got a bad deal
and we still feel like we/re getting shafted. And where is
RSR? Why isn't the City of Dallas responsible. They knew
they were there from day one. The city was aware that smelter
was there. They are, to me, just as responsible as RSR. At
the next meeting, we would like to have someone from the city
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present.
Response: EPA has been keeping the City of Dallas informed of
all activities at the RSR Site. EPA has many times attended
City Council meetings and other advisory group meetings to
provide the City information about the site and cleanup
activities. The City provided comments to the proposed
remedial action for OU No. 4. Those comments and EPA's
responses are below. In addition, EPA has notified the City
that it is potentially liable for two disposal areas (former
City landfills) where RSR smelter wastes were allegedly
disposed. EPA has invited the City of Dallas and specifically
notified certain City officials of public meetings including
this meeting. EPA will continue to invite City officials and
council members to participate in meetings with the public.
In addition, EPA has notified the RSR Corporation and a
related company, Quemetco Metals Limited, Inc., of their
potential liability at the RSR Site. EPA will continue to
pursue these companies as well as others potentially liable
for the contamination.
Comment: If the level of lead was really high, you as an
agency of — EPA, would you really, honestly, and truly tell
the people that there is danger?
Response: Yes, we would make this information available to
the public. EPA is obligated to provide as much information
as possible to the public and seek public input before making
final decisions. EPA has finalized the decision for OU No. 4
and will soon propose actions for the other areas. All of our
studies were made available to the public for review once they
were finalized.
Comment: How are you going to get back to the community on
the responses to the comments made tonight? Will it be in one
of those little booklets? I'd like to know, what is your
plans for future notification.
Response: This Responsiveness Summary containing EPA's
responses to questions and comments received during the public
comment period will be included in the ROD for OU No. 4. The
ROD is part of the Administrative Record for OU No. 4 and can
be reviewed at the RSR Site information repositories. The
comments and responses will also be attached to a summary of
the ROD for OU No. 4 called a Fact Sheet. Fact Sheets will be
mailed to all persons on the RSR Site mailing list and extra
copies will be available at the West Dallas Public Library and
at EPA's library. Prior to the start of the remedial action
at OU No. 4, the public will receive more specific information
about the cleanup. Additional public meetings may be held.
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2. City of Dallas Department of Environmental and Health
Services, letter dated June 12, 1995.
Comment: The City of Dallas Department of Environmental and
Health Services recommends that the EPA adopt Alternative 4 as
described in EPA's Proposed Plan for the site. We agree this
is the preferred remedial action alternative of those
presented to address contamination at the former RSR smelter
and concur that this alternative provides the most overall
protection to human health and the environment.
Response: As stated in the Proposed Plan, Alternative 4 is
EPA's recommended alternative. After evaluating all written
and public comments, EPA has selected Alternative 4 with some
slight modifications to address the contamination at OU No. 4.
Comment: While this plan is designed to address the
remediation of the RSR site itself, we are still concerned
with the EPA's decision to terminate the soil clean-up and
removal activities in residential and public areas. This
action implies that the source of contamination has been
eliminated. However, elevated blood lead levels continue to
plague children in the RSR area. While the source of the
contamination has not been clearly identified, it still
remains a continuing problem. We solicit your assistance in
identifying and eliminating all potential sources of lead
contamination affecting the health and safety of the residents
of West Dallas.
Response: EPA's decision that no further action is necessary
in the residential areas of west Dallas is supported by many
reports and studies contained in the Administrative Records
for OU Nos. 1 and 2 located in the information repositories.
EPA realizes that other sources of lead, such as lead paint,
remain in west Dallas and that, as in every large city in the
country, a small percentage of children in west Dallas
continue to have elevated blood lead levels. However, EPA's
authority under Superfund is limited to addressing lead
contamination associated with the former RSR smelter facility.
Studies conducted by EPA, the City and the State show that
removing more soil from residential properties will not solve
the lead problem if the lead contamination is associated with
other sources. Other local, State and federal authorities may
have jurisdiction to address these residual lead problems.
The ROD for OU No. 4 will allow EPA to address contamination
at the smelter. EPA is currently investigating other non-
residential areas that are potential sources of smelter
contamination (OU Nos. 3 and 5) .
While elevated blood lead levels have declined in the past
decade, EPA is concerned that elevated blood lead levels
continue to affect Dallas area children. The studies already
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completed show where joint actions, rather than more studies,
between Federal, State, and local authorities can further
reduce lead as a health threat. EPA stands ready to do all in
its authority to work with the City and other agencies to
eliminate lead as a public health threat.
3. From the Department of Health, Safety, and Environment of the
United Steelworkers of America, letter dated June 19, 1995.
Comment: We strongly support the proposal to demolish the
stack. While this procedure is not without risk, experience
in the steel industry demonstrates that the risk can be
controlled. Leaving the stack in place would leave the
residents of West Dallas subject to an ongoing risk. Our
experience is that demolition of large stacks can be
accomplished with reasonable protection of workers and the
public if proper precautions are taken. The USA's Department
of Health, Safety, and Environment will be happy to share its
experience with EPA and the community as the date of
demolition approaches.
Response: The selected remedial action will include
dismantling of the smelter stack. Details and procedures will
be included in the Remedial Design plans and specification
documents with input from experts in the field of stack
demolition. EPA welcomes input from all interested groups or
persons.
Comment: In the Records of Decision for Operable Units 1 and
2, USEPA declared that it will "seek reimbursement of the
money it spent from responsible parties for the site and not
from the citizens that were affected by RSR contamination."
The same principle must apply at OU 4. Clean-up costs should
be paid, to the extent possible, by those who caused the
contamination and not by the taxpayers.
Response: EPA will use all of its CERCLA authorities to
recover costs associated with cleanup of the RSR Site from all
liable parties.
Comment: We are disappointed that EPA has chosen to defer
selection of an appropriate method of ground-water
contamination until an unspecified time in the future. We
believe that this postponement is acceptable only in the
context of soil removal under Alternative 4. The other
alternatives would leave lead-contaminated soil in place as a
potential source of continuing ground-water contamination, and
therefore could not be adopted until the study of ground-water
has been completed. EPA should complete the investigation of
the threat to ground water and surface water posed by the RSR
Corporation site as rapidly as possible. Because of this gap,
any remedial action taken under this proposed plan cannot be
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considered the complete remedy for OU No. 4. EPA's future
decision regarding ground-water remediation comes within the
definition of "remedial action" and will require full public
participation pursuant to CERCLA §117(a). Thus, public
participation must be provided under any ground-water decision
scenario, even if EPA ultimately decides to take no remedial
action with respect to ground-water contamination.
Response: Since the date of the proposed plan for OU No. 4,
EPA has obtained adequate information regarding ground water
to form a basis for the selected remedial action in the ROD
for OU No. 4. Residents in the community are provided
drinking water from the City of Dallas water system and no
residential wells are located within a three-mile radius nor
is the shallow water used for any residential or commercial
needs. The State has concurred that the alluvial deposits
located under OU Nos. 4 and 5 are not potential drinking water
sources because of their extremely low yield. The ground
water issue will be presented to the public for comment in the
proposed plan for OU No. 5 scheduled to be issued in early
1996.
Comment: USEPA should finalize the listing of the RSR
Corporation site on the National Priorities List (NPL) as
quickly as possible.
Response: The RSR Corporation site was officially listed on
the National Priorities List and published in the Federal
Register on September 29, 1995. (60 Fed. Reg. 50435)
Comment: USEPA should evaluate the option of reclaiming
metals (lead, arsenic, cadmium) from contaminated soils and
other materials. The high (percent) levels of metals found in
some areas of soil and in some other materials (e.g., dust) at
the site should make resource recovery feasible. In addition,
removal of metals from the contaminated materials offers a
more complete and permanent solution than merely disposing of
them in a RCRA Subtitle C or D landfill. Likewise, USEPA
should consider the reclamation of steel from the many steel
buildings and process equipment on site.
Response: Process options, such as salvage or reuse of
building debris were considered in the Feasibility Study but
determined to not be feasible. These options were considered
in the initial development of alternatives and screened for
effectiveness, implementability and cost, as required by the
NCP. Options that did not meet the above criteria were
screened out and not carried through in the four alternatives
that went through detailed analysis. Based on the materials
present at the site and problems encountered at other sites
with reclamation, it was determined that reclamation of site
materials would not be feasible.
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Comment: We disagree with EPA's conclusion that both
"Alternatives 3 and 4 will meet all of the ARARs identified
for OU No. 4." RCRA closure requirements, which EPA agrees
are ARARs at OU 4, mandate total removal of all contaminated
materials, including soils, or post-closure care (here,
probably long-term ground-water monitoring). Neither
alternative fully meets these RCRA closure requirements.
Response: EPA disagrees. RCRA closure requirements are
ARARs, but only to the extent that they are applicable or
relevant and appropriate for this site. This does not mean
that all RCRA closure subparts are applicable. A complete
evaluation of potential ARARs for OU No. 4 of the RSR site is
contained in Appendix C of the ROD for OU No. 4. This
evaluation includes the list of ARARs, potentially affected
media, and their justification.
4. From United Steel Workers of America, Local 9121, District 36,
letter dated July 6, 1995.
Comment: We strongly support the proposal to demolish the
stack. If the stack is left in place, our main concern is
that the smelter property may be redeveloped after the site
has been cleaned up. We recommend that the stack is
demolished in a safe and qualified manner in which no risk
will be brought upon residents or their property.
Response: In the selected remedial action, the stack will be
demolished as part of the cleanup of the site. Precautions
will be followed to ensure the safety of site workers and the
general public and to ensure that stack contamination does not
migrate offsite during demolition activities.
Comment: We strongly feel that the clean up cost should be
covered by not only RSR Corporation, but also by RSR's parent
company, Quexco, Inc., of which Howard M. Meyers is the CEO.
Mr. Meyers is also the controlling shareholder and therefore,
a Potentially Responsible Party.
Response: EPA intends to pursue all potentially responsible
parties that contributed to the contamination associated with
the RSR smelter. EPA will attempt to recover all costs
associated with past, and future site activities, including
the remedial action for OU No. 4.
Comment: We do not agree with EPA/s decision to defer
selection of an appropriate method of ground-water
contamination until a future date. EPA should make an
immediate investigation of the threat to ground-water and
surface water posed by the RSR Corporation site as soon as
possible.
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Response: Since the date of the proposed plan for OU No* 4,
EPA has obtained adequate information regarding ground water
to form a basis for the selected remedial action in the ROD
for OU No. 4. Residents in the community are provided
drinking water from the City of Dallas water system and no
residential wells are located within a three-mile radius nor
is the shallow water used for any residential or commercial
needs. The State has concurred that the alluvial deposits
located under OU Nos. 4 and 5 are not potential drinking water
sources because of their extremely low yield. The ground
water issue will be presented to the public for comment in the
proposed plan for OU No. 5 scheduled to be issued in early
1996.
Comment: We strongly recommend that the EPA seriously
consider the option of reclaiming metals from contaminated
soils and other materials at the RSR site. Removal of the
contaminated materials would ensure a more complete and
permanent solution rather that disposing them into a landfill.
We do not believe that the EPA should consider treatment of
the soils with phosphate-based additives, with on-site
disposal.
Response: The lead concentrations in the soils are not high
enough for reclamation. Too much soil would remain as a by
product that would still need to be disposed of at a permitted
landfill. Therefore, it is not feasible to reclaim the
remaining lead from the site soils.
Comment: We strongly urge the EPA to quickly finalize the
listing of the West Dallas site on the National Priorities
List, and to hold RSR, Quexco, and Mr. Howard M. Meyers
responsible. It is time that the EPA stop protecting
Corporations such as these that show no concern for the
environment or the citizens in areas which their facilities
reside for the sake of greed. The EPA should demonstrate a
sincere concern and put forth a serious plan of action to
protect people's health and well-being, specifically in West
Dallas.
Response: The RSR Site was listed as final on the National
Priorities List on September 29, 1995 (60 Fed. Reg. 50435).
EPA has been concentrating its resources on addressing RSR
smelter-related contamination in the residential areas where
people live and the potential for exposure is greatest. EPA
is now focusing on completing the decision making for the
remaining operable units and on pursuing potentially
responsible parties. EPA intends to vigorously pursue all
potentially liable parties for which it has a legitimate legal
basis to pursue.
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5. From RSR Corporation, letter dated July 12, 1995.
Comment: The Baseline Human Health Risk Assessment
mischaracterizes the Risks Associated with OU No. 4.
The NCP requires EPA to conduct a "site specific baseline
risk assessment" to develop "reasonable maximum estimates of
exposure for both current land use conditions and potential
future land use conditions at each site." Thus, the
assessment must "characterize the current and potential
threats to human health and the environment that may be posed
by contaminants migrating to ground water or surface water,
releasing to air, leaching through soil, remaining in the
soil, and bio-accumulating in the food chain," in order to
"help establish acceptable exposure levels for use in
developing remedial alternatives in the FS (Feasibility
Study)."
EPA's Baseline Human Health Risk Assessment for the RSR
Site (hereinafter "Risk Assessment") purportedly shows that
the existing soils at OU No. 4 present unacceptable risks for
exposure to lead, cadmium, antimony, and arsenic to incidental
trespassers and to process and non-process workers. However,
as explained in the attached memorandum from Environ
Corporation, the Risk Assessment significantly overstate the
risks associated with these metals.
The central flaw in EPA's risk assessment is that it is
derived from inappropriate sampling data. The samples
analyzed were taken solely from the unpaved northeastern
corner of the Site (only seven soil samples) and the residual
waste/debris piles (only thirteen samples). No samples were
taken from paved areas of the Site. Moreover, the residual
waste/debris piles have either been, or will be, removed
pursuant to EPA's non-time-critical removal action. Thus, the
samples used to calculate EPA's Risk Assessment for actual
Site soil conditions unjustifiably overstates the risk
presented.
If EPA had based its assessment only on the data from the
available soil samples, the risks associated with the Site
would have been found to be well within the NCP's acceptable
exposure levels for systemic toxicants and known or suspected
carcinogens at Superfund sites. Had this been done, the
remedial analyses would focus on the only area of the Site—
its northeast corner— where actual soil risks are documented.
EPA's use of the sampling data from the residual
waste/debris piles subject to the non-time-critical removal
action to develop its Risk Assessment does not properly
characterize current and future site conditions, and thus is
inconsistent with the NCP. As such, it cannot be used to
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support excavation of all Site surficial soils as recommended
in EPA's preferred Alternative No. 4. The risk assessment
should be revised to rely solely on relevant — i.e., soil
sampling — data, and the chosen remedy revised accordingly.
Response: EPA conducted a site specific Human Health Risk
Assessment for OU No. 4 based on the results from the remedial
investigation. The risk from exposure to the very high
concentrations of lead, cadmium, antimony, and arsenic as they
existed at the time of the remedial investigation are indeed
unacceptable to current site trespassers and potential future
site workers if no action is taken. As the title states, this
is a "Baseline Human Health Risk Assessment" and is based on
the information gathered during the remedial investigation.
Although a recently completed non-time critical removal action
addressed waste/debris piles, extremely high levels of
contaminated dust and debris remain in the buildings, and
within site surfaces. Please refer to the After Action
Report, dated October 24, 1995, included in the Administrative
Record for OU No. 4. In addition, highly contaminated process
waste materials remain inside pipes, equipment and other areas
inside the secondary process buildings that were not addressed
as part of the non-time critical removal action. These
buildings are in serious states of deterioration causing
releases or potential releases of the contaminated materials.
Subsurface soil samples were collected from the paved areas
from nine locations during the installation of the site
monitoring wells. Concentrations from these samples were as
high as from the soil samples collected from the unpaved area.
In addition, the pavements themselves are contaminated, and
releases and potential releases of hazardous substances are
occurring from deterioration of the pavements and through the
drainage systems associated with the pavements.
Comment: EPA failed to consider containment of soils and the
reclamation of contaminated dusts and other materials in its
preferred remedial alternative.
EPA also erred in failing to consider, in developing its
proposed remedial alternative, the options of (a) containing
soils in the northeast corner of the Site (through a cap) and
(b) recycling lead contaminated soil and several other types
of recyclable materials. These failures were inconsistent
with the NCP and makes selection of Alternative No. 4
inappropriate and unlawful.
These alternative must "protect human health and the
environment by recycling waste, . . . and/or controlling risks
posed through each pathway by a site."
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The NCP further requires EPA to "develop one or more
innovative treatment technologies for further consideration if
those technologies offer the potential for comparable or
superior performance or implementability; fewer or lesser
adverse impacts than other available approaches; or lower
costs for similar levels or performance than demonstrated
treatment technologies."
Nowhere in the Feasibility Study has EPA undertaken an
evaluation of whether the risks posed by exposure to soils can
be adequately eliminated by containing (capping) exposed soils
in the northeast corner of the Site, or whether the materials
subject to the remedial action could appropriately be recycled
at less cost. To the contrary, EPA/s alternatives do not
evaluate the viability of capping exposed Site soils and all
include disposal of reclaimable material.
For example, Alternative No. 3 would require the
demolition of the existing concrete pavement, transportation
of the debris to a RCRA Subtitle D landfill, and the capping
of the Site with two feet of clean soil at a cost of $493,581.
Alternative No. 4 would essentially require all this plus the
excavation of all Site soils, their disposal in a class I
facility, and the capping of the Site with three feet of clean
soil at a cost of $4,063,081.
With regard to recycling, both Alternatives Nos. 3 and 4
provide for the cleanup, transport, solidification/
stabilization, and disposal in a Subtitle C facility of lead
contaminated dusts and demolition debris collected from the
existing structures at the Site at a cost of approximately
$929,031. They further require the steam cleaning, transport
and disposal of sheet metal debris from the vehicle
maintenance building at a cost of approximately $429.959.
EPA's failure to address capping is particularly
inexcusable in light of the data discussed at Number 1 (first
comment from RSR) above. Not only does that data not support
disturbing the already-capped areas, it is not even sufficient
to support excavation of the uncapped northeast corner.
EPA's failure to address the option of recycling also is
inconsistent with the NCP requirements that EPA use innovative
technologies that provide comparable (if not superior)
performance at lesser costs. A report recently prepared by
EPA specifically recommends the use of secondary lead smelters
to recycle a wide range of contaminated materials and debris
such as soils, demolition wastes, slag and dross, battery case
debris, lead paint, and dusts, and touts this innovative
technology as providing a "viable alternative to stabilization
and disposal for the treatment of wastes" at Superfund sites.
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EPA faces a very high, probably insurmountable, burden in
justifying its failure to address these issues. Without far
more attention than these issues have deserved, the Agency's
selection of Alternative 4, as presently described, is
inconsistent with the NCP.
Response: Consistent with the NCP, EPA developed a full range
of technologies and process options to address contamination
and risks posed at OU No. 4 of the RSR site. (See the
Feasibility Study for OU No. 4 included in the Administrative
Record for OU No. 4) . These options, which included many
innovative technologies, were screened against the criteria
established by the NCP, effectiveness, implementability and
cost. Only those options that met the above criteria were
carried forward for detailed analysis. Alternatives
considered for this site were also consistent with the
alternatives selected at other smelter sites throughout the
country. After reviewing alternatives evaluated at other
sites, alternatives relevant to the RSR smelter facility and
future land use considerations were evaluated to determine
which alternatives would be considered for this site. Based
on the materials present at the site and problems encountered
at other sites with reclamation and recycling, it was
determined that reclamation and/or recycling of site materials
would not be feasible. (See prior Responses to Comments
concerning reclamation and recycling). However, if materials
are encountered during the implementation of the remedial
action at OU No. 4 that are conducive to reclamation or
recycling (ie. whole batteries or battery parts), EPA will
consider recycling or reclamation as an offsite disposal
option.
EPA did consider various capping options for OU No. 4,
including the option in Alternative 3 where site contaminants
would be capped with two feet of clean fill. As discussed in
the Proposed Plan and Record of Decision for OU No. 4,
Alternative 3 did not meet as many of the goals and NCP
criteria as Alternative 4 for protection of human health and
the environment and was therefore not selected as the remedial
alternative for OU No. 4.
The suggestion that the concrete pads be left in place to
serve as a cap to site contaminants is also not feasible or
protective of human health and the environment. The concrete
pavements themselves are contaminated with very high
concentrations of hazardous substances that cannot be
adequately decontaminated. Please refer to the After Action
Report, dated October 24, 1995, which is included in the
Administrative Record. Additionally, several areas of the
concrete slab have deteriorated, particularly in the smelter
building, and are cracked or nonexistent. Based on the high
concentration of contaminants and the current condition of the
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pavements, EPA does not consider that any type of
decontamination, repair and long-term maintenance would ensure
that the pavements would serve as an adequate cap of site
contaminants. Furthermore, the concrete slab contains
numerous floor drains, sumps and other associated drainage
systems that contain and transport sediments contaminated with
high levels of lead, cadmium and arsenic. If left in place,
these floor drains and sumps could continue to serve as a
conduit for migration of contamination.
EPA can fully justify the selection in the ROD for OU No.
4 of a modified Alternative 4 as the remedial alternative that
is most protective of human health and the environment while
being cost effective. The selected remedy is consistent with
the NCP and meets all nine criteria that have to be evaluated
in the selection of a remedial action at Superfund sites.
Therefore, the selection of Alternative No. 4 to address site
contamination is appropriate, lawful, and consistent with the
NCP.
Potentially responsible parties ("PRPs") will be given
the opportunity to perform the remedial action for OU No. 4 so
long as their activities meet the requirements of the ROD and
the cleanup goals established for OU No. 4. There may be many
acceptable methods or combination of methods for the final
disposal of the contaminated site materials from OU No. 4 that
meet these requirements and goals. Therefore, whether EPA or
the PRPs perform the remedial action at OU No. 4, EPA will
consider available, lawful and acceptable methods, including
reclamation and recycling, for final disposal of OU No. 4
materials.
Comment: EPA's failure to list the RSR Site on the National
Priorities List precludes further response actions.
EPA proposed to list the Site on the NPL on May 10, 1993.
In the remaining two years, it has taken no further action.
RSR suspects this delay reflects the substantiality of
the concerns described in its comments on that proposed
listing. Instead of responding to those comments, EPA has
chosen to proceed through a series of its "non-time-critical
removal actions." On its face, this approach is unlawful
since removal actions only are to be used to mitigate
circumstances posing or threatening immediate harm, and none
is presented here.
It is hard to understand how a so-called non-time-
critical removal action in which the Agency evaluated various
alternatives to remove waste materials from the Site over a
several month time period and then began removal actions on a
non-critical time basis, is intended to mitigate circumstances
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posing or threatening immediate harm. The Agency's reliance
on its purported authorities under CERCLA Section 104(a) to
implement its removal action appears simply to be intended to
placate the surrounding community.
EPA's failure unlawfully denies RSR meaningful
opportunity to challenge EPA's actions through a final rule
listing the Site on the NPL. Whatever the Agency's authority
with regard to the non-time-critical removal action, it is
clear that EPA's failure to list the RSR Site on the NPL
prevents the Agency from taking further action to implement a
permanent remedy at the RSR Site. The NCP expressly provides
that "only those releases included on the NPL shall be
considered eligible for Fund-financed remedial action" No
further action to implement response actions at this Site —
even after the RI/FS is properly revised and an appropriate
remedial option identified — is permissible prior to a final
listing decision.
Response: The final NPL listing of the RSR Corporation
Superfund site was published in the Federal Register on
September 29, 1995. 60 Fed. Reg. 50435. The NPL listing is
based on an Administrative Record (sometimes referred to as
the NPL Docket) for the RSR Corp. Superfund Site. The record
contains responses to all public comments received on the
proposed 1isting.
Information EPA relied on or considered in making its
decision for the non-time-critical removal action for OU Nos.
4 and 5 is contained in the Administrative Record Non-Time
Critical Removal Action Operable Unit Nos. 4 and 5 available
for review at the RSR Site information repositories. EPA's
decision is set forth in an Action Memorandum dated December
22, 1994 and is supported by this Administrative Record.
Based in part on the human health risk assessment and the
remedial investigation for OU No. 4, EPA issued the Action
Memorandum for the non-time-critical removal action to address
the highly contaminated residual piles and the contaminated
liquids from several hundred barrels, some of which were
leaking and in very poor condition. In addition, EPA has
documented visible signs of trespass onto the OU No. 4
property, including graffiti, evidencing the real risk of
direct exposure by humans to dangerous site conditions. Since
the comprehensive remedial action for OU No. 4 would most
likely take several years to implement, EPA determined that
the non-time-critical removal action was appropriate to
address the highly contaminated materials.
EPA intends to use its full CERCLA authorities to ensure that
additional appropriate response actions are implemented at OU
No. 4.
23
-------
-------
ADULT LEAD CLEANUP MODEL
RSR CORPORATION SUPERFUND SITE
OPERABLE UNIT No. 4
APPENDIX B
-------
-------
Draft Region 6 Superfund Guidance
Adult Lead Cleanup Level
Basic Equations:
(PbBGMtarget - PbBo)
Cs = ------------------------------------------------
BKSF x (IRs x EFs x AFs + Ksd X IRd x EFd x AFd)
PbBGMtarget = PbB95thmaternal/GSDi1'645
PbB95thmaternal = PbB95thf etal/R
Input Parameters to the Model:
1. 95th Percentile PbB in fetus (PbB95thf etal)
The EPA and CDC recommend that no more than 5% likelihood that
a child would exceed 10 /ig/dL. For an industrial/commercial
setting, the exposed population could include pregnant women.
The recommended PbB95thfetal is 10 /-tg/dL.
2. Mean ratio of fetal to maternal PbB (R)
The relationship between fetal and maternal blood lead is
estimated to be 0.9 (Goyer 1990). The recommended "R value"
is 0.9.
3. Individual geometric standard deviation (GSDi)
A "typical" GSDi is 1.8.
4. Baseline blood lead value (PbBo)
The demographic composition of the site should be considered.
The geometric mean PbB values reported for women aged 20 - 49
years for African Americans was 2.2 /zg/dL, for Hispanics was
2.0 /zg/dL, and for whites was 1.7
Biokinetic slope factor (BKSF)
The recommended BKSF is 0.4 /ng/dL per tig/day.
Soil ingestion rate (IRs)
The recommended IRs is 0.025 g/day. This assumes that one-
half the "default" soil/dust ingestion rate of 0.05 g/day is
from soil.
-------
7. Dust ingestion rate (IRd)
The recommended IRd is 0.025 g/day. This assumes that one-
half the "default11 soil/dust ingestion rate of 0.05 g/day is
from dust.
8. Ratio of concentration in dust to that in soil (Ksd)
The Ksd can range from 0.2 to 1.0 with a "typical" value of
0.7.
9. Soil exposure frequency (EFs)
The "default" exposure frequency for an industrial setting is
250 days/year. This exposure frequency is based upon 5 work
days per week for 50 weeks/year. The recommended EFs is 250
days/year.
10. Dust exposure frequency (EFd)
The "default" exposure frequency for an industrial setting is
250 days/year. This exposure frequency is based upon 5 work
days per week for 50 weeks/year. The recommended EFd is 250
days/year.
11. Absolute absorption fraction of lead in soil (AFs)
The absorption fractions for adults range from 0.06 to 0.2.
The recommended AFs for most sites is 0.1. The source of lead
contamination should be considered in selecting the AFs value.
12. Absolute absorption fraction of lead in dust (AFd)
The absorption fractions for adults range from 0.06 to 0.2.
The recommended AFs for most sites is 0.1. The source of lead
contamination should be considered in selecting the AFs value.
-------
Model Parameter
95th Percentile PbB in fetus (jiig/dL)
R (Mean ratio of fetal to materal
PbB)
Individual geometric standard
deviation (GSDi)
Baselina blood lead value (PbBo)
(Mg/dL)
Biokinetic slope factor (BKSF)
(Mg/dL per p,g/day)
Soil ingestion rate (IRs) (mg/day)
Dust ingestion rate (IRd) (mg/day)
Ratio of concentration in dust to
that in soil (Ksd)
Soil ingestion frequency (EFs)
(days/year)
Dust ingestion frequency (EFd)
(days/year)
Absolute absortion fraction of lead
in soil (AFs)
Absolute absortion fraction of lead
in dust (AFd)
Resulting soil concentration (mg/kg)
Plausible
Range
5-15
0.8 - 1.0
1.6 - 2.0
1.6 - 2.2
0.3 - 0.5
10 - 25
10 - 25
0.2 - 1.0
100 - 350
100 - 350
0.06 - 0.2
0.06 - 0.2
"Typical"
Value
10
0.9
1.8
1.9
0.4
25
25
0.7
250
250
0.1
0.1
2/000
-------
Screening Level for Lead Program vl.OO
1.0 Starting the Program
To start the "Screening Level for Lead Program" (PRO), enter PRG at the DOS prompt
of the subdirectory containing the executable file (PRG.EXE).
2.0 Data Entry
Figure 1 illustrates an example Data Entry Screen for PRG.
Screening Leuel for Lead Program ul.
95th Percent ile PbB in fetus (PbB95 fetal) (ug/dL)
Mean ratio of fetal to maternal PbB (R)
Individual geometric standard deuiation (GSDi)
Baseline blood lead ualue (PbBO) (ug/dL)
Biokinetic slope factor (BKSF) (ug/dL per ug/day)
Soil ingest ion rate (IRs) (g/day)
Dust ingest ion rate (IRd) (g/day)
Ratio of concentration in dust to that in soil (Ksd)
Soil Exposure frequency (EFs) (days/yr)
Dust Exposure frequency (EFd) (days/yr)
Absolute absorption fraction of lead in soil (AFs)
Absolute absorption fraction of lead in dust (AFd)
1 TWO Till I^TTnfclO 1
(1) Enter all ualues aboue.
(2) To Calculate Screening Leuel for Lead: Press
(3) To Exit: Press Esc key.
00
0.9
1.7
1.9
0.4
0.01
0.01
0.2
250
250
0.06
0.06
PgDn or F5 key.
Figure 1. Example Data Entry Screen
When started initially, all data entry fields are zero. Some fields (such as GSDj, BKSF, and R) can
not be left as zero because division by zero is prohibited. Also, this program does not allow entry of
negative numbers in any field. After all values are entered, press either the PgDn key or the F5 key
to calculate the Screening Level for Lead (in ug/g).
3.0 Results
Figure 2 illustrates an example Results Screen.
-------
Results - Screening Leuel for Lead Program i
95th Percent ile PbB in fetus (PbB95 fetal) (ug/dL)
Mean ratio of fetal to maternal PbB (R)
Indiuidual geometric standard deuiation (GSDi)
Baseline blood lead ualue (PbBO) (ug/dL)
Biokinetic slope factor (BKSF) (ug/dL per ug/day)
Soil ingest ion rate (IRs) (g/day)
Dust ingest ion rate (IRd) (g/day)
Ratio of concentration in dust to that in soil (Ksd)
Soil Exposure frequency (EFs) (days/yr)
Dust Exposure frequency (EFd) (days/yr)
Absolute absorption fraction of lead in soil (AFs)
Absolute absorption fraction of lead in dust (AFd)
Screening Leuel for Lead (PRG) (ug/g): 13898
Select > Esc: Return to Data Entry F4:
;1.00
10
0.9
1.7
1.9
0.4
0.01
0.01
0.2
250
250
0.06
0.06
Saue F7: Print
Figure 2. Example Results Screen
The Results Screen can be printed or saved to a file. All data entry values are retained when returning
to the Data Entry Screen.
4.0 Equation Used for Calculation
The following equation is used to calculate The Screening Level for Lead:
Screening Level for Lead (PRG) (ug/g) =
(PbBQS fetal / (R • (GSD;)1'645)) - PbBO
BKSF • ((IRS • AFS • EFS / 365) + (K,, • IRd • AFd • EFd / 365))
-------
-------
ARARS EVALUATION
R8R CORPORATION SUPERFUND SITE
OPERABLE UNIT No. 4
APPENDIX C
26
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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 1 of 13
Requirement
Potentially Pertinent Media8
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
1 . Contaminant-Specific ARARs
Federal
Risk-based preliminary remediation goals
(PRGs) [Risk Assessment Guidance for
Superfund (RAGS), Part B]
National Contingency Plan
40 C.F.R. Part 300.430(d)
Baseline Human Health Risk Assessment
Office of Solid Waste and Emergency
Response (OSWER)
Directive 9355.4-12
July 14, 1994
EPA -Strategy for Reducing Lead
Exposures, October 3, 1990
X
X
X
X
X
X
X
X
TBC
Yes
TBC
TBC
Risk-based PRGs calculated using RAGS Part B are TBC for OU No. 4 and
OU No. 5.
Applicable to OU No. 4 and OU No. 5. Evaluates baseline human health risk
due to current and potential future site exposures, and establishes contaminant
levels in environmental media at the OUs for protection of public health.
The directive establishes soil cleanup levels for lead abatement for residential
areas. These levels are TBCs for OU No. 4 and OU No. 5.
TBC for OU No. 4 and OU No. 5. The strategy was developed to reduce lead
exposures to the greatest extent possible. Goals of the strategy are to:
(1) significantly reduce blood lead incidences above 10 ftg/dL in children and
(2) reduce the amount of lead introduced into the environment.
2. Action-Specific ARARs
Federal
40 CFR 268
Universal Treatment Standards (UTS)
40 C.F.R. Part 264
Subparts B, C, D and G
X
X
X
X
Yes
Yes
40 CFR Part 268 establishes restrictions on land disposal unless treatment
standards are met. Relevant and appropriate to both OU No. 4 and OU No. 5,
if the wastes are removed from the sites for subsequent disposal. Metals
wastes in soil that are hazardous by toxicity characteristic are exempt from this
rule. The UTS establish a concentration limit for 300 regulated constituents in
soil regardless of waste type.
Subparts B, C, and D establish minimum standards which define the acceptable
management of hazardous waste for owners and operators of facilities that
treat, store, or dispose of hazardous waste. Subpart G establishes standards for
closure and post-closure care for site design and operation. These requirements
are relevant and appropriate for wastes identified as RCRA hazardous wastes.
DEN 10017218. WPS
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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 2 of 13
Requirement
Potentially Pertinent Media"
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
2. Action-Specific ARARs (Continued)
Federal (Continued)
Subparts I and J
Subparts L and N
Subpart S
X
X
X
X
X
X
X
X
X
Yes
Yes
Yes
Subpart I sets operating and performance standards for container storage of
hazardous waste. Subpart J outlines similar standards, but applies to tanks
rather than containers. These requirements are relevant and appropriate for
RCRA hazardous wastes on OU No. 4 and OU No. 5 if containers are used
for onsite storage of liquids, soil, or other wastes as part of the remedial
action.
Subpart L sets design and operating requirements for the storage or treatment
of wastes in piles. If the waste piles are closed with wastes left in place,
Subpart L requirements are applicable and must be met. Subpart N establishes
construction, design, performance, closure, and operation requirements
pertaining to Subtitle C landfills. Subpart L and/or N are relevant and
appropriate for RCRA hazardous wastes on OU No. 4 and OU No. 5 if onsite
treatment, storage, or disposal in piles or Subtitle C landfills is included as
part of the remedial action.
The promulgated portion of Subpart S addresses the corrective action
management unit (CAMU) and temporary unit (TU) aspects of RCRA
corrective action. A CAMU is a contiguous area within a facility in which
remedial wastes generated during corrective action are managed. A CAMU
may include uncontaminated areas where necessary to achieve overall remedial
goals. Wastes may be moved from one CAMU to another within the facility
without triggering land disposal restrictions (LDRs). Wastes can also be
removed from the CAMU, treated in a unit, and returned to the CAMU
without triggering LDRs. A TU can be used to manage wastes for up to 1
year. TUs are not subject to the full permitting requirements of a fully
regulated RCRA unit and waste piles are not eligible for TUs. Subpart S
requirements are relevant and appropriate for RCRA hazardous wastes on OU
No. 4 and OU No. 5 if the remedial action requires wastes to be managed in
an onsite CAMU or TU.
DEN10017218.WP5
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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 3 of 13
Requirement
Potentially Pertinent Media8
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
2. Action-Specific ARARs (Continued)
Federal (Continued)
Subpart X (Miscellaneous Units)
40C.F.R. §761.60
(PCB Disposal)
40C.F.R. §761.65(c)(7)
(PCB Storage)
OSHA Worker Protection
40 C.F.R. § 300.38
X
X
X
X
X
X
X
X
Yes
Yes
No
Yes
Relates to "miscellaneous" units that treat, store, or dispose hazardous wastes.
Provides general performance standards for location, design, construction,
operation, monitoring, and closure/post-closure. This requirement is relevant
and appropriate for RCRA hazardous wastes on OU No. 4 and OU No. 5 if
the remedial action includes onsite treatment, storage, or disposal of waste in a
miscellaneous unit.
Serves as ARAR for disposal of affected materials containing concentrations of
PCBs, if affected materials are identified at OU No. 4 or OU No. 5. This
requirement is relevant and appropriate.
Serves as an ARAR only to extent that it authorizes storage of liquid PCBs in
containers meeting 29 C.F.R. § 1910.106 (OSHA Standards for Flammable
and Combustible Liquids); requires preparation and implementation of Spill
Prevention Control and Countermeasures plan. Not an ARAR since liquid
PCBs were not identified at either OU No. 4 or OU No. 5.
Applicable to OU No. 4 and OU No. 5 regarding protection of workers at site.
(29 C.F.R. 1910.120)
DEN10017218.WP5
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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 4 of 13
Requirement
Potentially Pertinent Media8
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
2. Action-Specific ARARs (Continued)
Federal (Continued)
Surface Mining Control and Reclamation
Act of 1977
25 GSC §§ 1201 et. see.: 30 C.F.R.
Parts 816.11, .95, .97, .100, and .102
X
<
X
Yes
The requirements include provisions for:
• .11 -Posting signs and markers for reclamation, including top soil
markers and perimeter markers.
• .95— Stabilization of all exposed surface areas to effectively control
erosion and air pollution attendant to erosion.
• .97 — Use of best technology currently available to minimize
disturbances and adverse impacts on fish, wildlife, and related
environmental values and achieve enhancement of such if possible.
• .100 -Contemporaneous reclamation including, but not limited to
backfilling, regrading, topsoil replacements and revegetation.
• .102— Achieve a post action slope not exceeding angle of repose or such
lesser slope as is necessary to achieve a minimum long-term static
safety factor of 1.3 and to prevent slides.
These requirements are relevant and appropriate to OU No. 4 and OU No. 5.
State
General Prohibitions
30 TAC § 330.5
Disposal of Special Wastes
30 TAC §330.136
X
X
No
Yes
The regulation prohibits disposal of lead acid storage batteries at municipal
solid waste landfills. This requirement is not an ARAR for OU No. 4 but is
relevant and appropriate for battery casings identified on OU No. 5.
Specifies that regulated asbestos-containing material (RACM) may be accepted
at a Type 1 or Type I-AE municipal solid waste landfill (MSWLF) provided
that the MSWLF facility has been authorized to accept RACM and complies
with the provisions of § 330.136. This requirement is applicable for OU No. 4
and OU No. 5.
DEN 10017218. WP5
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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 5 of 13
Requirement
Potentially Pertinent Media"
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
2. Action-Specific ARARs (Continued)
State (Continued)
Closure and Remediation
Subchapter A
30 TAC § 335.8
Subpart S, Risk Reduction Standards
30 TAC §335.551
Subpart S, Risk Reduction Standard No. 3
30 TAC § 335.562
Shipping and Reporting Procedures
Applicable to Generators of Hazardous
Waste or Class I Waste and Primary
Exporters of Hazardous Waste
Subchapter A
30 TAC §335.10
Shipping Requirements for Transporters of
Hazardous Waste or Class I Waste
Subchapter A
30 TAC §335.11
X
X
X
X
X
X
X
X
X
X
X
Yes
Yes
Yes
Yes
Yes
These provisions apply to closure and remediation of facilities associated with
contamination resulting from unauthorized discharges, either as part of closure
or at any time before or after closure. The regulations also apply to
remediation of areas that are not otherwise designated as a facility but that
contain unauthorized discharges of industrial waste or municipal hazardous
waste. Section (a)(2) of this citation specifies that, for remediations performed
under the State Superfund program, media cleanup levels should be based on
future residential land use unless it is demonstrated that an alternative land use
is more appropriate. These requirements are relevant and appropriate for
RCRA hazardous wastes on OU No. 4.
Establishes procedures to demonstrate compliance with the risk reduction
standards for different types of contaminated media such as air, surface water,
groundwater, and soil, and for cross-media contamination pathways such as
soil-to-groundwater and soil-to-air. Requirements apply to closure and
remediation undertaken according to 30 TAC § 335.8. Numeric cleanup values
are based on which of the three risk reduction rules are appropriate. These
requirements are relevant and appropriate for surface soil on OU No. 4 and
OU No. 5.
Risk Reduction Standard No. 3 specifies that persons shall propose media
cleanup levels in accordance with the conditions stated. These requirements
are relevant and appropriate for OU No. 4 and OU No. 5 to perform closure
or remediation activities. Cleanup levels will be based on the CERCLA risk
assessments developed for OU No. 4 and OU No. 5.
Establishes requirements for manifesting shipments of hazardous waste to off-
site facilities. This requirement is relevant and appropriate to both OU No. 4
and OU No. 5 if hazardous or Class I wastes are shipped off-site to a
disposal/treatment facility.
Requirements specific to transporters of hazardous or class I wastes regarding
manifesting waste shipments. These requirements are relevant and appropriate
to any transporter who transports hazardous or class I wastes offsite from OU
No. 4 or OU No. 5.
DEN10017218.WP5
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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas
Page 6 of 13
Requirement
Potentially Pertinent Media8
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
2. Action-Specific ARARs (Continued)
State (Continued)
Shipping Requirements Applicable to
Owners or Operators of Storage,
Processing, or Disposal Facilities
Subchapter A, 30 TAC § 335.12
X
No
Requires owners or operators of storage, processing or disposal facilities to
comply with manifest requirements upon receipt of waste shipment. This
requirement is not an ARAR for OU NO. 4 or OU No. 5 because waste
shipments will not be received at the RSR Site.
Special Definitions for Recyclable
Materials and Nonhazardous Recyclable
Materials
Subchapter A, 30 TAC § 335.17
Yes
Specifies definition of recyclable materials including "scrap metal." This
requirement is applicable to OU No. 4 and OU No. 5 if materials (building
components, etc.) are to be recycled.
Requirements for Recyclable Materials and
Nonhazardous Recyclable Materials
Subchapter A
30 TAC § 335.24 (c) and (h)
X
Yes
Specifies that scrap metal is not subject to regulation under Subchapter B-I and
O of Chapter 335. Under § 335.24(h), the rule specifies that scrap metal, as
defined in Section (c) remains subject to the requirements of § 335.4 (relating
to General Prohibitions) and § 335.6 (relating to Notification Requirements).
Such waste may also be subject to the requirements of § 335.10 through
§ 335.15 of Title 30.
These requirements are relevant and appropriate to OU No. 4 and OU No. 5 if
materials are recycled.
Adoption of Appendices by Reference
Subchapter A
30 TAC § 335.29
Yes
Adopts appendices contained in 40 C.F.R. Part 261 by reference; this includes
Appendix I-IH, VII-X.
I - Representative Sampling Methods
II - Method 1311 Toxicity Characteristic Leaching Procedure
III - Chemical Analysis Test Methods
VII - Basis for Listing Hazardous Waste
VIII - Hazardous Constituents
IX - Wastes Excluded under § 260.20 and § 260.22
X - Method of Analysis for Chlorinated Dibenzo-p-dioxins and
Dibenzofurans.
These requirements are relevant and appropriate for OU No. 4 and OU No. 5
to determine which, if any, media are RCRA hazardous wastes. These
requirements are not applicable since much of the contaminated media was
disposed of prior to 1980. ^
DEN10017218.WP5
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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 7 of 13
Requirement
Potentially Pertinent Media8
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
2. Action-Specific ARARs (Continued)
State (Continued)
Hazardous Waste Management General
Provisions
Subchapter B
30TAC § 335.41
Standards Applicable to Generators of
Hazardous Wastes
Subchapter C
30 TAC § 335.61, §§ 335.65-335.70
Standards Applicable to Transporters of
Hazardous Waste
Subchapter D
30 TAC § 335.91
Applicability of Groundwater Monitoring
and Response
Subchapter F
30 TAC § 335.156
X
X
X
X
X
X
X
X
Yes
Yes
Yes
Yes
This subchapter implements a state hazardous waste program which controls
from point of generation to ultimate disposal those wastes listed in 40 C.F.R.
Part 261. These standards are relevant and appropriate for RCRA hazardous
wastes on OU No. 4 and OU No. 5.
This subchapter establishes standards for generators of hazardous waste. These
standards include: packaging, labeling, marking, placarding, accumulation
time, and record-keeping. Requirements for packaging, labeling, marking, and
placarding are relevant and appropriate for RCRA hazardous wastes on OU
No. 4andOU No. 5.
This subchapter establishes standards for transporters transporting hazardous
waste to offsite storage, processing, or disposal facilities. This subchapter does
not apply to onsite transportation of hazardous waste by generators or by
owners or operators of storage, processing, or disposal facilities.
Requirements of this subchapter are relevant and appropriate for RCRA
hazardous wastes on OU No. 4 or OU No. 5 that are sent offsite for disposal.
This section outlines the rules pertaining to groundwater monitoring and
response, which apply to owners and operators of facilities that process, store,
or dispose of hazardous waste. The owner or operator must satisfy the
requirements of § 335.156 (a)(2) for all wastes (or constituents thereof)
contained in any such waste management unit at the facility, regardless of the
time at which waste was placed in the units.
These requirements are relevant and appropriate for RCRA hazardous wastes
left in place or disposed on OU No. 4 and OU No. 5.
DEN10017218.WP5
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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 8 of 13
Requirement
Potentially Pertinent Media8
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
2. Action-Specific ARARs (Continued)
State (Continued)
Required programs
Subchapter F
30TAC § 335.157
Interim Standards for Owners and
Operators of Hazardous Waste Storage,
Processing, or Disposal Facilities
Subchapter E
30TAC § 335.111
Interim Standards for Owners and
Operators of Hazardous Waste Storage,
Processing, or Disposal Facilities-
Standards
Subchapter E
30 TAC §335.112
X
X
X
X
X
X
Yes
Yes
Yes
Requires owners and operators subject to 30 TAC § 335.156 to conduct a
monitoring and response program as follows:
(1) Whenever hazardous constituents from a regulated unit are detected at the
compliance point, the owner or operator must institute a compliance
monitoring program.
(2) Whenever the groundwater protection standard is exceeded, the owner or
operator must institute a corrective action program.
(3) Whenever hazardous constituents from a regulated unit exceed
concentration limits under § 335.160 in groundwater between the compliance
point and the downgradient facility boundary, the owner or operator must
institute a corrective action program, and
(4) In all other cases, the owner or operator must institute a detection
monitoring program.
These requirements are relevant and appropriate for RCRA hazardous wastes
left onsite at OU No. 4 and OU No. 5.
This Subchapter establishes minimum requirements that define the acceptable
management of hazardous waste prior to the issuance or denial of a hazardous
waste permit and until certification of final closure or, if the facility is subject
to post-closure requirements, until post-closure responsibilities are fulfilled.
These requirements are relevant and appropriate for RCRA hazardous wastes
on OU No. 4 and OU No. 5 if wastes are left onsite.
Adopts 40 C.F.R. Part 265, except as noted, by reference. This includes
Subparts B, C, D, E, F, G, H, I, J, K, L, M, N, O, P, Q, R, W, AA, and
BB.
These requirements are relevant and appropriate for RCRA hazardous wastes
on OU No. 4 and OU No. 5 if wastes are left onsite.
DEN10017218.WP5
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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 9 of 13
Requirement
Potentially Pertinent Media"
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
2. Action-Specific ARARs (Continued)
State (Continued)
Containment for Waste Piles
Subchapter E
30TAC § 335.120
Permitting Standards for Owners and
Operators of Hazardous Waste Storage
Processing or Disposal Facilities
Subchapter F
30 TAG § 335.151
Standards
Subchapter F
30TAC §335.152
Corrective Action for Solid Waste
Management Units
Subchapter F
30TAC §335.167(b)and(c)
Design and Operating Requirements
(Waste Piles)
Subchapter F
30TAC §335.170
Location Standards for Hazardous Waste
Storage, Processing, or Disposal
Subchapter G
30 TAC § 335.201 (a)(3)
X
X
X
X
X
X
X
X
X
X
X
Yes
Yes
Yes
Yes
Yes
Yes
Establishes requirements for hazardous leachate or run-off from a pile: 1) the
pile must be placed on an impermeable base, must include a run-on control
system and a run-off management system and 2) the pile must be managed
such that it must be protected from precipitation and run-on and no liquids or
wastes containing free liquids may be placed in the pile.
These requirements are relevant and appropriate for RCRA hazardous wastes
on OU No. 4 and OU No. 5 if waste piles are created during remediation.
Subchapter F includes the minimum standards of operation for all aspects of
the management and control of municipal hazardous waste and industrial solid
waste, including rules relating to the siting of hazardous waste facilities.
These standards are relevant and appropriate for RCRA hazardous wastes on
OU No. 4 and OU No. 5.
Adopts by reference the regulations contained in 40 C.F.R. Part 264, except as
noted in this section. These standards are relevant and appropriate for RCRA
hazardous wastes on OU No. 4 and OU No. 5.
Outlines requirements for corrective action at solid waste management units.
No solid waste management units have been identified at OU No. 4 or OU
No. 5. These standards are relevant and appropriate for RCRA hazardous
wastes on OU No. 4 and OU No. 5 that undergo a corrective action.
Establishes requirements for waste piles including: 1) a liner designed,
constructed, and installed to prevent any migration of wastes out of the pile
and 2) a leachate collection and removal system immediately above the liner
that is designed, constructed, maintained, and operated to collect and remove
leachate from the pile.
These requirements are relevant and appropriate for RCRA hazardous wastes
on OU No. 4 and OU No. 5 if waste piles are created during remediation.
This subchapter establishes minimum standards for the location of facilities
used for the storage, processing, and disposal of hazardous waste. The
requirements are relevant and appropriate for any facility built onsite to store,
process, or dispose of RCRA hazardous wastes.
DEN 10017218. WP5
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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 10 of 13
Requirement
Potentially Pertinent Media"
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
2. Action-Specific ARARs (Continued)
State (Continued)
Prohibition on Open Dumps
Subchapter I
30 TAC § 335.302
Hazardous Waste Generation, Facility, and
Disposal Fees System
Subchapter J
30 TAC § 335.321
Hazardous Substance Facilities Assessment
and Remediation
Subchapter K
30 TAC § 335.341 (b)(4)
Specific Air Emission Requirements for
Hazardous or Solid Waste Management
Facilities
Subchapter L
30 TAC § 335.367
Pre-Application Review and Permit
Procedures
Subchapter M
30 TAC § 335.391-335.393
Warning Signs for Contaminated Areas
Subchapter P
30 TAC § 335.441
X
X
X
X
X
X
>
X
X
X
X
X
X
X
No
No
Yes
Yes
No
Yes
Prohibits open dumping of industrial solid waste. Not an ARAR for OU No. 4
or OU No. 5, as all wastes will be handled according to ARARs.
Establishes an industrial solid waste and hazardous waste fee program which is
an administrative requirement. Administrative requirements are not ARARs.
Outlines the scope and requirements associated with the State Superfund
program, including: ranking of facilities (§ 335.343), delisting and
modifications (§ 335.344), removal actions and preliminary site investigations
(§ 335.346), general requirements for a remedial investigation/feasibility study
(§ 335.348), and general requirements for a remedial action (§ 335.349). The
requirements set forth in the rule are relevant and appropriate. However,
because the RSR Site is proposed for listing on EPA's National Priorities List
and is an EPA-lead Superfund site, the requirements are being met through the
CERCLA Rl/FS process.
Requires hazardous or solid waste management facilities to use the best
available control technology to control emission of air contaminants,
considering technical practicability and economic factors. Requires the
owner/operator to demonstrate that the facility or unit will not cause or
contribute to air pollution. These requirements are relevant and appropriate to
RCRA facilities constructed onsite at OU No. 4 and OU No. 5.
These requirements are administrative requirements. Administrative
requirements are not ARARs.
Provides standards and procedures for the placement of warning signs on
property contaminated with hazardous substances when such contamination
presents a danger to public health and safety. The requirements in Subchapter
P are relevant and appropriate for RCRA hazardous wastes on OU No. 4 and
OU No. 5.
DEN10017218.WP5
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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 11 of 13
Requirement
Potentially Pertinent Media8
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
2. Action-Specific ARARs (Continued)
State (Continued)
Pollution Prevention Source Reduction and
Waste Minimization
Subchapter Q
30 TAC § 335.473
Waste Classification and Waste Coding
Required
Subchapter R
30 TAC § 335.503
Hazardous Waste Determination
Subchapter R
30 TAC § 335.504
Class 1 Waste Determination
Subchapter R
30 TAC § 335.505
Class 2 Waste Determination
Subchapter R
30 TAC § 335.506
Class 3 Waste Determination
Subchapter R
30 TAC § 335.507
Classification of Specific Industrial Solid
Wastes
Subchapter R
30 TAC § 335.508(1)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
No
Yes
Yes
Yes
Yes
Yes
Yes
Applies to all large quantity generators, all generators other than large quantity
and conditionally exempt generators, and all persons subject to reporting
requirements under SARA 313 Title III. The RSR Site is not a large-quantity
generator. Therefore, these requirements are not ARARs for OU No. 4 or
OU No. 5.
These requirements specify the classification scheme and coding for all
industrial solid and municipal hazardous waste generated, stored, processed,
transported, or disposed of in the site. These requirements are relevant and
appropriate for all waste at OU No. 4 and OU No. 5.
Requires waste generator to determine if the waste is hazardous either as a
listed or characteristic waste according to 40 C.F.R. Part 261, Subpart D or
40 C.F.R. Part 261 Subpart C. These requirements are relevant and
appropriate for identifying RCRA hazardous waste at OU No. 4 and OU
No. 5.
Specifies the chemical/physical properties associated with a Class 1 non-
hazardous industrial solid waste. This requirement is relevant and appropriate
for OU No. 4 and OU No. 5 relative to waste determination procedures.
Requires determination of a Class 2 waste classification for industrial solid
waste that is neither a hazardous waste, a Class 1 waste, nor a Class 3 waste.
This requirement is relevant and appropriate for both OU No. 4 and OU
No. 5.
Specifies that industrial solid waste is a Class 3 waste if it is inert, essentially
insoluble, neither a Class 1 nor hazardous waste, and poses no threat to human
health and/or the environment. This requirement is relevant and appropriate for
OU No. 4 and OU No. 5.
Requires that industrial solid waste containing asbestos material identified as
Regulated Asbestos Containing Material (RACM), as defined in 40 C.F.R.
Part 61, shall be classified as Class 1 Waste. Applicable to both OU No. 4 and
OU No. 5 due to the presence of asbestos containing material.
DEN 10017218. WP5
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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 12 of 13
Requirement
Potentially Pertinent Media"
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
2. Action-Specific ARARs (Continued)
State (Continued)
TNRCC Demolition Debris Waste
February 23, 1994
X
TBC
In an interoffice memorandum, the TNRCC defines "demolition debris" and
establishes sampling recommendations based on 30 TAC § 335.509. The
TNRCC recommends that, prior to beginning demolition or dismantling
operations, generators of demolition debris waste take appropriate steps to:
1 . Identify the individual components/phases of the waste which have a
significant potential to be hazardous wastes (and, in the case of
industrial generators, Class 1 wastes);
2. Segregate, to the extent practical, those components/phases from the
remainder of the waste.
3. Perform any necessary sampling and analytical testing on those
components/phases to determine whether they are characteristically
hazardous as defined in 40 C.F.R. §§ 261.21 through 24 (and in the
case of generators of industrial waste, Class 1 as defined in 30 TAC
§ 335.505).
4. Manage those components/phases, as well as the remainder of the
wastes, according to standards appropriate to their classification.
If during the process of segregating hazardous or Class 1 components/phases
from the remainder of the waste, it is determined that the action may pose a
significant threat to human health and the environment, generators should use
appropriate discretion when deciding whether segregation is in the best interest
of protecting human health and the environment.
As nonpromulgated guidelines, these requirements are TBCs for OU No. 4 and
OU No. 5 if demolition is selected as part of the remedy.
DEN 10017218. WPS
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Table A-l
ARARs Evaluation for Soils, Buildings and Structures, and Residual Material - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Pqge 13 of 13
Requirement
Potentially Pertinent Media*
Soils
Buildings and
Structures
Residual
Material
ARAR?
Justification
2. Action-Specific ARARs (Continued)
State (Continued)
TNRCC Historically Contaminated Sites:
Industrial Versus Municipal Solid Waste
July 12, 1994
X
X
X
TBC
In an interoffice memorandum, TNRCC established requirements that, before
the final deposition of a waste is carried out, the site owner or operator must
accomplish at least the following:
1 . Waste type determination (municipal or industrial) and
2. Hazardous waste determination in accordance with 30 TAC § 335.62
Wastes from a presently inactive facility (generator) where previous industrial
activities occurred or industrial waste was generated, would be classified as
industrial waste.
As nonpromulgated guidelines, these requirements are TBCs for OU No. 4 and
OU No. 5.
3. Location-Specific ARARs
Federal
Coastal Zone Management Act
16 U.S.C. § 1451 et seq.
40 C.F.R. § 6.302(d)
40 C.F.R. § 264.18 (Location Standards)
X
X
X
X
X
X
No
No
Requires assessment of the impacts of activities on a coastal zone and the
conduct of activities in connection with a coastal zone in accordance with a
state approved Coastal Zone Management Plan. Activities at OU No. 4 or OU
No. 5 will not impact a coastal zone; therefore this requirement is not an
ARAR.
Relates to hazardous waste treatment, storage, or disposal facilities subject to
permitting. Requires that new units where treatment, storage, or disposal of
hazardous waste will be conducted be located greater than 200 feet from a fault
with displacement in Holocene time and that facilities located in 100-year
floodplains be designed, constructed, and operated to prevent washout of
hazardous waste from active portions of the facility. Since the site is not in a
100-year floodplain, this regulation is not an ARAR. The site is not within
200 feet of a fault, thus the provisions pertaining to faults are not ARARs.
Potentially Pertinent Media - In some cases, the evaluation of analytical results from these media is needed to determine whether a potential ARAR is applicable or relevant and
appropriate (see Appendix D for these evaluations). For example, many of the RCRA requirements are relevant and appropriate for RCRA hazardous waste. A potentially
pertinent medium may or may not be a RCRA characteristic hazardous waste, depending on its TCLP results.
DEN10017218.WP5
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Table A-2
Numeric Contaminant-Specific ARARs/TBCs for Soils,
Buildings and Structures,
and Residual Material OU No. 4
RSR Corporation Superfund Site
Dallas, Texas
Chemical
(1)
TBC
Industrial
(mg/kg)
Inorganics
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
818
32.7a
142,476
2,044
1,577
75,628
l,000b
.258,711
613
40,880
10,220
10,220
164
14,308
613,200
Notes:
(1) Preliminary Remediation Goals (PRO). Calculated based on
Human Health Evaluation Manual, Part B: Development of
Risk-Based Preliminary Remediation Goals. OSWER Directive
9285.7-01B.
TBC = To be considered.
The acceptable risk level for arsenic is set at IxlO5 since a risk
level of IxlO6 results in a PRO that is at or below background
levels of arsenic.
bEPA OSWER Directive 9355.4-12.
DEN1147.DOC
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Table A-3
ARARs for Surface Water - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 1 of 10
Requirement
ARAR?
Justification
1. Contaminant-Specific ARARS
Federal
Safe Drinking Water Act
40 U.S.C. 399
Primary Drinking Water Standards (MCL)
40 C.F.R. Part 141
Secondary Drinking Water Standards
40 C.F.R. Part 143
Maximum Contaminant Level Goals
(MCLG)
40 C.F.R. § 141.50
Federal Clean Water Act
Water Quality Criteria
40 C.F.R. Part 131 U.S. EPA
Quality Criteria for Water, 1976, 1980,
and 1986
Toxic Pollutant Effluent Standards
40 C.F.R. Part 129
Hazardous Substances
40 C.F.R. § 116.3 and 116.4
No
No
No
No
No
No
There is no direct contact between the source of contaminants and surface water at the
site. Surface waters around site are not designated for public and private water supply.
MCLs are not ARARs for surface water at OU No. 4 or OU No. 5.
Secondary standards are aesthetic rather than health based and therefore are not ARARs
as surface water is unlikely to be utilized as a source of drinking water.
Not presently considered an ARAR as MCLGs are set at levels that do not take into
account cost or feasibility and MCL's are fully protective of human health. See 52
Fed. Reg. 32499. Further, surface waters are not utilized as a source of drinking water.
These criteria (ambient water quality criteria) apply to water classified as a fisheries
resource. The intermittent streams on OU No. 5 are not classified as such and there are
no streams on OU No. 4. Therefore, not an ARAR or TBC for OU No. 4 or OU
No. 5.
Standards are applicable to point source discharges to navigable waters from specified
facilities that discharge aldrin/dieldrin, DDT, endrin, toxaphene, benzidine, PCB's. No
point source discharges to navigable waters are associated with OU No. 4 or OU No. 5.
Establishes reporting requirements for certain discharges of reportable quantities of
hazardous substances. Creates no substantive clean up requirement. Not an ARAR.
DEN10016F40.WP5/1
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Table A-3
ARARs for Surface Water - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 2 of 10
Requirement
ARAR?
Justification
1. Contaminant-Specific ARARS (Continued)
State
Pollution Prohibition
Texas Water Code
§26.121
Texas Surface Water Quality Standards
Aesthetics
30 TAC § 307.4(b)(l)
General Toxicity
30 TAC § 307.4(d)
Antidegradation
30 TAC § 307.5
Acute Toxicity
30 TAC § 307.6(b)(l)
No
No
No
No
No
Prohibits the discharge of wastes into or adjacent to any natural or artificial bodies of
surface water, inland or coastal, which in itself or in conjunction with any other
discharge or activity, causes or will cause pollution of the surface water. Not an ARAR
for OU No. 4 since discharges to surface water do not occur. May be relevant and
appropriate for OU No. 5 due to discharges to onsite drainages.
General prohibition of concentrations in surface water of taste and odor producing
substances which impart unpalatable flavor to food fish including shellfish, or otherwise
interfere with the reasonable use of the water in the state. Not an ARAR for OU No. 4
as no discharges to surface water occur; relevant and appropriate for OU No. 5 due to
discharges to onsite drainages.
Surface waters must not be toxic to man or to terrestrial or aquatic life. Not an ARAR
for OU No. 4 as no discharges to surface water occur; relevant and appropriate for OU
No. 5 due to discharges to onsite drainages.
Requires maintenance and protection of existing uses (baseline November 28, 1975)
when discharging wastewater. Not an ARAR for OU No. 4 as no discharges to surface
water occur; relevant and appropriate for OU No. 5 due to discharges to onsite
drainages.
Surface water must not be acutely toxic to aquatic life (except in small zones of initial
dilution at discharge points). This criteria applies to water classified as a fisheries
resource. The intermittent streams on OU No. 5 are not classified as such and there are
no streams on OU No. 4. Therefore, not an ARAR for OU No. 4 or OU No. 5.
DEN10016F40.WP5
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Table A-3
ARARs for Surface Water - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 3 of 10
Requirement
ARAR?
Justification
1. Contaminant-Specific ARARS (Continued)
State (Continued)
Chronic Toxicity
30 TAC § 307.6(b)(2)
Human Toxicity
30 TAC § 307.6(b)(3)
No
No
Surface water with designated or existing aquatic life uses shall not be chronically toxic
to aquatic life (except in mixing zones and below critical low-flow conditions). No
surface water bodies impacted by OU No. 4 or OU No. 5 have a designated or aquatic
life use; therefore the requirement is not an ARAR.
Surface water must be maintained to preclude adverse toxic effects on human health
resulting from contact recreation, consumption of aquatic organisms, or consumption of
drinking water after reasonable treatment. This regulation is not an ARAR to the
extent that it pertains to drinking water, as surface water in the area is not a potential
source of drinking water.
DENI0016F40.WP5
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Table A-3
ARARs for Surface Water - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 4 of 10
Requirement
ARAR?
Justification
1. Contaminant-Specific ARARS (Continued)
State (Continued)
Numerical Criteria for Toxics
30 TAC § 307.6(c)
LC50 Toxicity Criteria
30 TAC § 307.6(c)(8)
Yes
No
Numerical criteria are established for certain toxic materials. These criteria are TBC
for OU No. 4 and relevant and appropriate for OU No. 5.
Notes: (1) These numerical criteria are based on ambient water quality criteria
documents published by EPA. For some chemicals, EPA criteria have been
recalculated (in accordance with procedures in the EPA guidance document entitled
"Guideline for Deriving Site-Specific Water Quality Criteria") to eliminate the effects
of toxicity data for aquatic organisms which are not known to occur in Texas. 31 TAC
§ 307.6(c)(2).
(2) Numerical Acute Criteria apply to all surface water (except in small zones of initial
dilution at discharge points). Numerical chronic criteria apply to surface water with
designated or existing aquatic life uses (except inside mixing zones and below critical
low-flow conditions.
(3) Numerical Acute Criteria are applied as 24-hour averages. Numerical Chronic
criteria are applied as seven-day averages.
Concentrations of toxic materials for which no numerical criteria have been specified
must not exceed values which are chronically toxic to representative, sensitive aquatic
organisms, as determined from appropriate chronic toxicity data or calculated as 0.1 of
the median lethal concentration (LC50) for nonpersistent toxics (i.e., readily degrades,
half-life less than 96 hours), 0.05 of LC50 for nonbioaccumulative, persistent toxics,
and 0.01 of the completion of remediation. Not an ARAR for OU No. 4 since no
surface water sources are present or directly impacted; relevant and appropriate for OU
No. 5 due to discharges to onsite drainages.
DEN10016F40.WP5
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Table A-3
ARARs for Surface Water - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 5 of 10
Requirement
ARAR?
Justification
1. Contaminant-Specific ARARS (Continued)
State (Continued)
Site-Specific Uses and Criteria
30 TAC § 307.7(b)(5)
Oyster Waters
30 TAC § 307.7(b)(3)(B)(iii)
Standards of Chemical Quality
30 TAC § 290.103(1),(3)
Secondary Constituent Levels
30 TAC §290.113
Surface Water Media Specific
Concentration, Risk Reduction Standard
No. 2
30 TAC § 335.558
No
No
No
No
No
Basic uses such as navigation, agricultural water supply, and industrial water must be
maintained and protected for all surface water in which these uses can be achieved. Not
an ARAR for OU No. 4 since no surface water sources are present or directly
impacted; relevant and appropriate for OU No. 5 due to discharges to onsite drainages.
Oyster waters should be maintained so that concentrations of toxic materials do not
cause edible species of clams, oysters, and mussels to exceed accepted guidelines for
the protection of public health, including the U.S. Food and Drug Administration action
levels for molluscan shellfish. These criteria are not ARARs since no discharges to
oyster water occurs.
Specifies the maximum contaminant levels for inorganic and organic compounds that
apply to community and non-transient, non-community water systems. These values are
not ARARs for OU No. 4 and OU No. 5.
These secondary constituent level limits, based on aesthetic and organoleptic
considerations, are applicable to all public water systems. These levels are TBC for
OU No. 4 and OU No. 5.
To be applied after evaluation of 30 TAC § 307 and primary drinking water MCLs.
Relevant and appropriate for OU No. 5 due to discharges to onsite drainages; not an
ARAR for OU No. 4 since no discharges to surface water occur.
DEN10016F40.WP5
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Table A-3
ARARs for Surface Water - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas
Page 6 of 10
Requirement
ARAR?
Justification
2. Action-Specific ARARs
Federal
Federal Clean Water Act
National Pollutant Discharge Elimination
System, Section 402
No
A permit is not required for onsite CERCLA response actions. Provision establishes no
substantive cleanup requirement.
Stormwater Regulations
40 C.F.R. Parts 122, 125
Yes
NPDES permits are addressed relative to stormwater discharges associated with
industrial activity. These regulations require the development and implementation of a
stormwater pollution prevention plan or a stormwater best management plan.
Monitoring and reporting requirements for a variety of facilities are outlined. Runoff
from construction activities is an ARAR depending on the nature of the remedial action
selected. Relevant and appropriate if stormwater discharge occurs as a result of the
remedial action.
Pretreatment Standards
40 C.F.R. § 403.5
Yes
Prohibits discharge to a POTW of pollutants that "pass-through" (exit the POTW in
quantities or concentrations that violate the POTW's NPDES permit) or cause
"interference" (inhibits or disrupts the POTW, its treatment processes or operations, or
its sludge processes, use or disposal, thereby causing a violation of the POTW's
NPDES permit). Also prohibits introduction into a POTW of: (1) pollutants which
create a fire or explosion hazard, (2) pollutants which will cause corrosive structural
damage, (3) solid or viscous pollutants that will obstruct flow, (4) pollutants discharged
at a flow rate and/or concentration that will cause interference, and (5) heat that will
inhibit biological activity (never over 104°C). No point source discharges have been
documented. However, if a remedial action results in a point source discharge to a
POTW, then the requirements will be applicable to OU No. 4 or OU No. 5.
DEN10016F40.WP5
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Table A-3
ARARs for Surface Water - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 7 of 10
Requirement
ARAR?
Justification
2. Action-Specific ARARs (Continued)
State
Consolidated Permits
Standard Permit Conditions
30TAC § 305.125
Consolidated Permits
Subchapter O, Additional Conditions and
Procedures for Wastewater Discharge
Permits and Sewage Sludge Permits
Texas Water Quality Act, TCA, Water
Code, Title 2-State Water Commission
No
No
Yes
Specifies conditions applicable to all permits. A permit is not required for onsite
CERCLA response actions. The provisions establish no substantive cleanup
requirements.
Adopts by reference 40 CFR Part 122, Subpart C, Permit Conditions and Part 124,
Subpart D, Specific Procedures Applicable to NPDES Permits. A permit is not
required for onsite CERCLA response actions. The provisions establish no substantive
cleanup requirement.
Places reporting requirements on remedial activities which may cause an accidental spill
and discharge into the state waters. Whenever an accidental discharge or spill occurs at
or from any activity or facility which causes or may cause pollution, the individual
operating, in charge of, or responsible for the activity or facility shall notify the
TNRCC as soon as possible and not later than 24 hours after the occurrence.
Activities which are inherently or potentially capable of causing or resulting in the
spillage or accidental discharge of waste or other substances and which pose serious or
significant threats of pollution are subject to reasonable rules establishing safety and
preventative measures which the commission may adopt or issue. The safety and
preventative measures which may be required shall be commensurate with the potential
harm which could result from the escape of the waste or other substances. Applicable
to OU No. 4 and OU No. 5 during remediation.
DEN10016F40.WP5
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Table A-3
ARARs for Surface Water - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 8 of 10
Requirement
ARAR?
Justification
2. Action-Specific ARARs (Continued)
State (Continued)
General Provisions
30 TAC § 335.4
Yes
Regulates the collection, handling, storage, disposal, and processing of hazardous or
deleterious materials in the vicinity of, or adjacent to, state waters. Remedial actions
must be designed with adequate measures and controls to ensure that no person may
cause, suffer, allow, or permit the collection, handling, storage, processing, or disposal
of industrial solid waste or municipal hazardous waste in such a manner to cause:
• The discharge or imminent threat of discharge of industrial solid waste or
municipal hazardous waste into or adjacent to the waters in the state without
obtaining specific authorization for such a discharge from the TNRCC.
• The creation and maintenance of a nuisance; or
• The endangerment of the public health and welfare.
Relevant and appropriate to actions taken at OU No. 4 or OU No. 5.
3. Location-Specific ARARS
Federal
Fish and Wildlife Coordination Act
16 U.S.C. § 661 et seq.
16 U.S.C. § 742 a
16 U.S.C. § 2901
No
Requires consultation when a modification of a stream or other water body is proposed
or authorized and requires adequate provision for protection offish and wildlife
resources. Not an ARAR for OU No. 4 as no surface water bodies are impacted.
Relevant and appropriate for OU No. 5 due to onsite drainages.
DEN10016F40.WP5
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Table A-3
ARARs for Surface Water - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 9 of 10
Requirement
ARAR?
Justification
3. Location-Specific ARARS (Continued)
Federal (Continued)
Marine Protection, Research and
Sanctuaries Act
33 U.S.C. § 1401 (Title I)
40 C.F.R. Part 220
16 U.S.C. § 1431 et seq.
(Title III)
15 C.F.R. Parts 922-941
Clean Water Act § 404
33 U.S.C. § 1344
40 C.F.R. Parts 230, 231
Rivers and Harbors Act of 1899
33 U.S.C. § 403
33 C.F.R. Parts 320-322
Protection of Wetlands Executive Order
No. 11990
40 C.F.R. § 6.302(a)
and Appendix A
No
No
No
No
Title I requires permit for dumping of wastes in U.S. ocean waters which have been
transported from U.S. or from outside U.S. Activities at site will not include dumping
of wastes into the ocean; therefore, title I is not an ARAR. Title III requires
conservation and management of areas designated as National Marine Sanctuaries.
Since there is no National Marine Sanctuary in or near the site, Title III is not an
ARAR.
Requires permit for the discharge of dredge or fill material into waters of the United
States including wetlands (see 33 C.F.R. § 328.3). Not an ARAR since no discharge of
dredge or fill material into waters of the U.S. is anticipated.
Prohibits the creation of any unauthorized obstruction or work in navigable waters that
affects such navigable waters without a permit. Even if navigable waters were present
at the site, a nationwide permit is available for CERCLA site activities [see 33 C.F.R.
§ 330.5(a)(20)]. Since there are no navigable waters at the RSR Site, this requirement
is not an ARAR.
Requires federal agencies to avoid, to the extent possible, the adverse impacts
associated with the destruction or loss of wetlands and to avoid support of new
construction in wetlands if a practical alternative exists. Wetlands have not been
identified at the RSR site; this provision is not an ARAR.
DEN10016F40.WP5
-------
Table A-3
ARARs for Surface Water - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 10 of 10
Requirement
ARAR?
Justification
3. Location-Specific ARARS (Continued)
Federal (Continued)
Floodplain Management Executive Order
No. 11988
40 C.F.R. § 6.302(b)
Wild and Scenic Rivers Act
16 U.S.C. § 1271 et seq.
40 C.F.R. § 6.302(e)
Coastal Zone Management Act
16 U.S.C. § 1451 et seq.
40 C.F.R. § 6.302(d)
No
No
No
Requires federal agencies to evaluate the potential effects of actions taken in a
floodplain and to avoid or minimize impacts associated with direct and indirect
development of a floodplain. Since the site is not within a 100-year floodplain, this
Order is not an ARAR.
Prohibits adverse effects on a scenic river. Since the site does not affect a scenic river,
this Act is not an ARAR.
Requires assessment of the impacts of activities on a coastal zone and the conducting of
activities in connection with a coastal zone in accordance with a state approved Coastal
Zone Management Plan. The Act is not applicable or relevant and appropriate as OU
No. 4 and OU No. 5 have no impact on coastal areas.
DEN10016F40.WP5
-------
Table A-4
Numeric Contaminant-Specific ARARs for Surface Water - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas
Chemical
(1)
NA/R&A
(mg/L)
(2)
NA/R&A
(mg/L)
(3)
NA/TBC
(mg/L)
Inorganics
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Di-n-butyl phthalate
Di-n-octyl phthalate
0.05a
l.a
0.01a
0.05a
0.005a
0.0000122b
0.01a
0.05a
0.025
0.0000122
0.014
0.000018
0.000144
0.61
0.0017
2.7
Notes:
NA/R&A = Not an ARAR or TBC for OU No. 4; Relevant and appropriate to OU No. 5.
TBC = To be considered.
(1) = Criteria in Water for Specific Toxic Materials -Human Health Protection.
Category A -Water and Fish. 30 TAC Section 307-6 Toxic Materials.
(2) = Criteria in Water for Specific Toxic Materials -Human Health Protection.
Category B- Fresh Water Fish Only. 30 TAC Section 307-6 Toxic Materials.
(3) = Ambient Water Quality Criteria for the protection of human health. 57 FR 60847.
December 22, 1992.
Indicates that the criteria for a specific parameter are for the dissolved portion in water. All other
criteria are for total recoverable concentrations.
Calculations are based on USFDA Action Levels for fish tissue concentrations.
Please Note: There are no contaminant-specific ARARs for OU No. 4 surface water.
DEN10017214.WP5
-------
Table A-6
ARARs for Air - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 1 of 6
Requirement
ARAR?
Justification
1. Contaminant-Specific
Federal
National (Primary and Secondary)
Ambient Air Quality Standards
(NAAQS)
40 C.F.R. Part 50
National Emission Standards for
Hazardous Air Pollutants
(NESHAPs)
40 C.F.R. Part 61
Subpart A
Fugitive Emissions Source
Standards
40 C.F.R. Part 61
Subpart V
Mercury Standards
40 C.F.R. Part 61
Subpart E
Yes
No
No
•!.
No
The NAAQS specify the maximum concentration of a federally regulated air pollutant (i.e., SO2,
paniculate matter (PM10), NO2, CO, ozone, and lead) in an area resulting from all sources of that
pollutant. No new construction or modification of a facility, structure or installation may emit an
amount of any criteria pollutant that will interfere with the attainment or maintenance of a NAAQS
(see 40 C.F.R. § 5 1 .160). For the federal NAAQS standards, all measurements of air quality are
corrected to a reference temperature of 25°C and to a reference pressure of 760mm Hg (1,013.2
millibars). 40 C.F.R. § 50.3.
These provisions regulate the emissions of specified "hazardous air pollutants" [listed in 40 C.F.R.
§ 6 1.01 (a)] that are emitted from particular sources or processes [listed in 40 C.F.R. Part 61].
Regulates specified equipment which are potential sources of fugitive emissions because they
contain or contact fluid which is at least 10% by weight a volatile hazardous air pollutant
("VHAP"- including benzene and vinyl chloride). This requirement is not an ARAR as no fluid
containing at least 10% by weight of a VHAP is present at the site.
These provisions apply to stationary sources that process mercury ore, and incinerate or dry
wastewater treatment plant sludge. The requirement is not an ARAR as no processing of mercury
ore and/or no incineration of wastewater treatment plant sludge will occur at the site.
DEN10016CC5.WP5
-------
Table A-6
ARARs for Air - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 2 of 6
Requirement
ARAR?
Justification
1 . Contaminant-Specific (Continued)
State
Asbestos Notification Fees
30TAC § 101.28
Particulates— Net Ground Level
30TAC § 111.155
SO2 Ground Level Concentration
30TAC § 112.7
Hydrogen Sulfide
30TAC § 112.31 & § 112.32
Sulfuric Acid
30TAC § 112.41
Inorganic Fluoride
30 TAC § 1 13.3(a)(2) and (a)(3)
Beryllium
30 TAC § 113.3(b)
Lead Emissions from smelting
facilities
No
Yes
No
No
No
No
Yes
No
The owner/operator of a demolition or renovation activity shall remit to the TACB a fee that is
based on the amount of asbestos subject to the NESHAPS. Based on the amount of asbestos
identified may not be an ARAR. However, if during demolition additional sources of asbestos are
identified, may become an ARAR.
Establishes the net ground level concentration (downwind at the property boundary minus upwind
measurements) of paniculate emissions from any source that must not be exceeded.
SO2 emissions from any source must not exceed a net ground level concentration (downwind at
property boundary minus upwind). Not in ARAR since no SO2 emissions are expected during or
after remediation.
Sets net ground level concentration limits for hydrogen sulfide. Not an ARAR since no hydrogen
sulfide emissions are expected during or after remediation.
Sets net ground level concentration limits for sulfuric acid. Not an ARAR since no sulfuric acid
emissions are expected during or after remediation.
Sets atmospheric and net ground level concentration limits for inorganic fluoride (as HF). Not an
ARAR since no HF emissions are expected during or after remediation.
Sets atmospheric and net ground level concentration limits for beryllium. Beryllium emissions
may be generated during or after remediation.
Rules relate to lead emissions from stationary sources in Dallas County. Sets standards for the
control of lead emissions in Dallas County. Not an ARAR because smelter emissions as a result of
an operating facility do not exist.
DEN10016CC5.WP5
-------
Table A-6
ARARs for Air - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 3 of 6
Requirement
ARAR?
Justification
2. Action-Specific
Federal
Prevention of Significant
Deterioration of Air Quality
42 U.S.C. § 7475
40C.F.R. § 52.21
Nonattainment Areas — LAER
42 U.S.C. § 172(b)(6) and § 173
New Source Performance Stan-
dard for Incinerators
40 C.F.R. Part 60
Subpart E
Hazardous Waste Incinerators
40 C.F.R. Part 264, Subpart O
No
No
No
No
These provisions impose various requirements (e.g. use of best available control technology) on
any new major stationary source of a federally regulated air pollutant in an area which has been
designated attainment or unclassifiable for that pollutant. A "major stationary source" is a source
listed in 40 C.F.R. § 52.21 which emits, or has the potential to emit, 100 tons per year of a
federally regulated air pollutant or any non-listed source that emits, or has the potential to emit,
250 tons per year of a federally regulated air pollutant. Activities at OU4 or OU5 are not expected
to constitute a major stationary source of any federally regulated air pollutant. The requirement is
not an ARAR.
A state's permit program under the federal Clean Air Act must require permits for the construction
and operation of new major stationary sources in NAAQS nonattainment areas. Such a permit may
be issued only if the proposed source complies with "lowest achievable emission rate"
requirements. Not an ARAR since activities at OU No. 4 or OU No. 5 do not constitute new
major stationary sources.
Sets a limit for particulate emissions of 0.18g/dscm (0.08 gr/dscf) corrected to 12% CO2. Not an
ARAR since the rule applies to furnaces burning municipal waste.
Not an ARAR since a hazardous waste incinerator is unlikely to be used at OU4 or OU5.
DEN10016CC5.WP5
-------
Table A-6
ARARs for Air - OU No. 4
RSR Corporation Super fund Site
Dallas, Texas Page 4 of 6
Requirement
ARAR?
Justification
2. Action-Specific (Continued)
State
Control of Air Pollution by Per-
mits for New Construction or
Modification
30 TAC § 116
Requirements for Specified
Sources
30 TAC § 111.111
Storage of Lead Containing
Materials
30 TAC § 113.82(a)and(b)
Transport of Materials
30 TAC § 11 3.84(1) and (2)
Yes
Yes
Yes
Yes
New non-exempt facilities which may emit air pollutants must obtain a construction permit or
special permit. To obtain such a permit, the owner or operator of the proposed facility must
provide for measuring emissions of significant air contaminants, and must demonstrate, among
other things, that the facility will utilize the "best available control technology, with consideration
given to the technical practicability and economic reasonableness of reducing or eliminating the
emissions from the facility." Applies during building decontamination or demolition activities.
May be relevant and appropriate.
Visible emissions shall not be permitted to exceed an opacity of 30% for any six-minute period
from any building, enclosed facility, or other structure. Applies during demolition or decontami-
nation of buildings, or any other activity that may generate visible emissions. Relevant and
appropriate for construction/demolition activities at OU No. 4 or OU No. 5.
No unenclosed storage of material containing more than 1% lead by weight. All paniculate matter
containing more than 1% lead by weight collected by air pollution control equipment shall be
stored in closed containers or in a structure under significant negative pressure to prevent emissions
to the atmosphere. Applies if lead content exceeds 1% by weight. Applicable to both OU No. 4
and OU No. 5.
All transport vehicles carrying materials containing more than 1% lead by weight must have
covered cargo compartments at all times on plant property except during loading and unloading,
when being washed, or inside a building. Each time a vehicle leaves a structure, all material
containing more than 1% lead by weight shall be removed from the wheels; if water is used, this
requirement is suspended during freezing weather. Applies if lead content exceeds 1% by weight.
Applicable to both OU No. 4 and OU No. 5.
DEN10016CC5.WP5
-------
Table A-6
ARARs for Air - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 5 of 6
Requirement
ARAR?
Justification
2. Action-Specific (Continued)
State (Continued)
Control of Fugitive Dust
30TAC § 11 3.91 (a), (b), (c)
Additional Measures to Reduce
Lead Emissions
30TAC § 113.92(1)
Control Requirements for Sur-
faces with Coatings Containing
Lead
30TAC § 111.135
Construction and Demolition
30TAC § 111.145
Yes
Yes
Yes
Yes
All plant roads shall be paved; parking areas and storage areas for materials containing more than
1% lead by weight shall be paved. Open unpaved areas must be vegetated or covered with rock or
crushed aggregate at least three inches deep. Applies if lead content exceeds 1% by weight.
Applicable to OU No. 4 and OU No. 5.
If they occur outside buildings, spills of dust containing more than 1% lead by weight shall be
dampened and cleaned up immediately. Applies if lead content exceeds 1% by weight. Applicable
to both OU No. 4 and OU No. 5.
Applies specifically to abrasive blasting of water storage tanks with coatings containing > 1% lead.
Specifies emission control requirements. Applies if abrasive blasting is used to decontaminate
structures. Relevant and appropriate for OU No. 4 and OU No. 5.
Applies to properties greater than one acre in size. No person may cause, suffer, allow, or permit
a structure, road, street, alley, or parking area to be constructed, altered, repaired or demolished
without taking the following precautions:
(1) Use of water or suitable oil or chemicals for control of dust during structure demolition
(2) Use of adequate methods such as wet sandblasting and enclosure of work areas during sand-
blasting of structures or other similar operations. Applies to activities associated with building
demolition; applicable to OU No. 4 and OU No. 5 if demolition activities occur.
DEN10016CC5.WP5
-------
Table A-6
ARARs for Air - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas
Requirement
ARAR?
Page 6 of 6
Justification
2. Location-Specific
State
General Application;
Proximity of New Construction to
Schools
30TAC § 116.111
No
Requires the TACB to consider, in issuing a permit for construction of a facility, any adverse
short-term or long-term side effects than an air contaminant or nuisance odor from the facility may
have on the individuals attending an elementary, junior high, or senior high school within 3,000
feet of the facility. May be TBC since a school is located within 3,000 feet of OU No. 4 facility.
DEN10016CC5.WP5
-------
Table A-7
Numeric Contaminant-Specific ARARs for Air - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 1 of 1
PM.o
Annual arithmetic mean
24-hour maximum
24 -hour average
3 -hour net average
concentration
1-hour net average
concentration
Lead
3 -month
Beryllium
30-day average
24-hour average
State(I)
Level la
(Mg/m3)
420
2003
4003
0.01
(ppm)
Level 2b
0*g/m3)
500
0.01
(ppm)
Federal(2)
Primary
(Mg/m3)
50
150C
1.5
0.01
(ppm)
Secondary
(Mg/m3)
50
150C
1.5
0.01
(ppm)
Notes:
(1)Control of Air Pollution Episodes. 30 TAC Section 118.1 (PM10, beryllium).
(2)National Ambient Air Quality Standards. 40 CFR § 50.3 and 51.160 (PM10, lead and beryllium).
(3)Ground level Concentrations. 30 TAC Section 111.155.
aThe concentration of any air contaminants is equal to or greater than the levels specified for Level 1 and in case of all air contaminants except
ozone, meteorological conditions conducive to high air contamination are predicted to continue for at least 12 hours.
bLevel 2 exists if the executive director determines that an emergency reduction of emissions must be initiated to prevent the presence in the
atmosphere of any of the air contaminants in the concentrations specified. These levels could cause significant harm to human health.
cMay not be exceeded more than once per year, all other NAAQS may never be exceeded.
DEN10016CC6.WP5
-------
Table A-8
Miscellaneous Location Standards - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas Page 1 of 2
Requirement
ARAR?
Justification
1 . Location-Specific
Federal
National Historic
Preservation Act
16 U.S.C. §470
40C.F.R. § 6.301(b)
36 C.F.R. Part 800
Archeological and Historic Preservation Act
16 U.S.C. § 469
40 C.F.R. § 6.301(c)
Historic Sites, Buildings, and Antiquities Act
15 U.S.C. $ 461 etseq.
40 C.F.R. § 6.301(a)
Endangered Species Act
16 U.S.C. § 1531 et seq.
50 C.F.R. Part 402
Wilderness Act
16 U.S.C. § 1131 et seq.
50 C.F.R. Part 35
No
No
No
No
No
Requires federal agencies to take into account the effect of any federally-assisted
undertaking or licensing on any district, site, building, structure, or object that is
included in or eligible for inclusion in the National Register of Historical Places.
There is no such district, site, building, structure, or object in or near the RSR Site;
therefore, the Act is not an ARAR.
Establishes procedures to provide for preservation of scientific, historical, and
archeological data which might be destroyed through alteration of terrain as a result
of a federal construction project or a federally licensed activity or program. If
scientific, historical, or archaeological artifacts are discovered at the Site, work in
the area of the Site affected by such discovery will be halted pending the
completion of any data recovery and preservation activities required pursuant to the
Act and its implementing regulations. No archeological or historical landmark is
documented to be present at the Site; therefore, this requirement is not an ARAR.
Requires federal agencies to consider the existence and location of landmarks on the
National Registry of Natural Landmarks to avoid undesirable impacts on such
landmarks. There is no such landmark that will be affected by the proposed
remedy; therefore, the Act is not an ARAR.
Requires that proposed action minimize impacts on endangered species within
critical habitats upon which endangered species depend, including consultation with
Department of Interior. No plant or animal endangered species of "critical habitat"
will be impacted by the proposed remedy at the Site; therefore, the Act is not an
ARAR.
Requires the administration of federally owned wilderness areas to leave them
unimpacted. There is no federally owned wilderness area that will be impacted by
the proposed remedy; therefore, the Act is not an ARAR.
DKNIOOIMX'K Wl'5
-------
Table A-8
Miscellaneous Location Standards - OU No. 4
RSR Corporation Superfund Site
Dallas, Texas
Requirement
ARAR?
Page
2 of 2
Justification
1 . Location-Specific (Continued)
Federal (Continued)
National Wildlife Refuge System
16 U.S.C. §§ 668dd, 668ee
50 C.F.R. Part 27
No
Restricts activities within a National Wildlife Refuge. The proposed remedy will
not affect a National Wildlife Refuge; therefore, these provisions are not ARARs.
State
Antiquities Code of Texas
TEX. NAT. RES. COD. ANN.,
CH. 191
No
Prohibits the taking, altering, damaging, destroying, or excavating of a state
archeological landmark without a contract or permit. No state archeological
landmark is documented to be present at the Site; therefore, the Code is not an
ARAR.
IM-NIOOHiCCR.WI'S
-------
REVISED COST ESTIMATES
RSR CORPORATION SUPERFUND SITE
OPERABLE UNIT No. 4
APPENDIX D
-------
-------
10/26/95
Revised Table B-1
Cost Estimate
Operable Unit No. 4
RSR Corporation Superfund Site
Dallas, Texas
(Accuracy Range: +50% / -30%)
..sost
ALTERNATIVE 1b: Institutional Controls; Long-Term Monitoring
CAPITAL COSTS:
GENERAL REQUIREMENTS:
General Sitework:
Institutional Controls:
Fix Existing Perimeter Fence
Long-Term Monitoring:
Survey Monitoring WeHs & Surface Water Sampling Locations
SUBTOTAL
CONTINGENCY
SUBTOTAL - CONSTRUCTION COST
PERMITTING & LEGAL
SERVICES DURING CONSTRUCTION
SUBTOTAL - IMPLEMENTATION COST
ENGINEERING & DESIGN COST
ANNUAL O&M COSTS:
Guard Service (24 Hours/Day, 7 Days/Week)
Long Term Monitoring: Sampling Events
SUBTOTAL
CONTINGENCY
PQfttiL *Anw*aJ<>-& M <&Wta -£tewwi#v*4&
10%
2,500
1
20%
5%
7%
6%
12
3
20%
LF
LS
MONTHS
EA
$43,889
$15.00
$2,000.00
$43,889
$52,666.67
$52,666.67
$52,666.67
$10,800.00
$10,500.00
$161,100
$4,389
$37,500
$2,000
$43,889
$8,778
$52,667
$2,633
$3,687
$58,987
$3,160
$129,600
$31,500
$161,100
$32,220
REfEftEKCE
Assumes 100% of existing fence needs repair
RSROU4M.XLS
Page 1
-------
10/26/95
Revised Table B-1
Cost Estimate
Operable Unit No. 4
RSR Corporation Superfund Site
Dallas, Texas
$$$tttiftft^^ i
(Accuracy Range: +50% / -30%)
D6S€f»?T*&NE QUANTITY UKiT $&$% TOTAL REFHRe*C£
; : <&8T
NET PRESENT VALUE:
YEARO
YEAR1
YEAR 2
YEAR 3
YEAR 4
YEARS
YEAR 6
YEAR 7
YEARS
YEAR 9
YEAR 10
YEAR 1 1
YEAR 12
YEAR 13
YEAR 14
YEAR 15
YEAR 16
YEAR 17
YEAR 18
YEAR 19
YEAR 20
YEAR 21
YEAR 22
YEAR 23
YEAR 24
YEAR 25
YEAR 26
YEAR 27
YEAR 28
YEAR 29
YEAR 30
«ET wB&mr muB&s^
$62,147
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
$193,320
«3«833«S48K
RSROU4M.XLS
Page 2
-------
10/26/95
Revised Table B-1
Cost Estimate
Operable Unit No. 4
RSR Corporation Superfund Site
Dallas, Texas
*f$t£rtiHftWXttW^
(Accuracy Range: +50% / -30%)
friiwrn^Tiwi «t»>mTY w& #m* TOW, *&&&&&
«OST
ALTERNATIVE 2: In-situ Treatment ofBldgs & Structures. Off site Treatment & Disposal
of Residual Mtls. Removal 8, Disposal of Asbestos Mtls. Containment of Metals-Contam
Soils in Unpaved Areas. LT Monitoring
CAPITAL COSTS:
GENERAL REQUIREMENTS:
General Sitework:
Perimeter Fence
Air Monitoring During Site Work
10%
2,500
1
Gather Residual Materials from Hog Storage Building & Equipment, and Steam Clea
Structural Inspection
Plug Sumps
Structural Modifications (Heavy Duty)
Gather Residual Mtls from Bldg by Hand & Place in 55 Gal Drums
55 Gallon Drums for Lead Dust
Gather Residual Mtls from Equip by Hand & Place in 55 Gal Drums
55 Gallon Drums for Lead Dust
Transport Drummed Mtls to RCRA Subtitle C Landfill
RCRA Subtitle C Landfill Stabilization & Tipping Fee
Steam Clean Building & Equipment 2 Times
32
1
11,990
11,990
17
5
17
9
9
11,990
LF
LS
n Building &
HRS
LS
SF
SF
DRUMS
CY
DRUMS
CY
CY
SF
$2,047,395
$15.00
$100,000.00
$204,739
$37,500
$100,000
Equipment (11 ,990 SF):
$100.00
$1,000.00
$8.80
$0.15
$200.00
$100.00
$200.00
$79.42
$225.00
$0.60
Gather Residual Materials from Smelter Facility & Adjacent Bag Houses & Equipment, and Steam Clean Buildinc
Structural Inspection
Plug Sumps
Structural Modifications (Heavy Duty)
Gather Residual Mtls from Bldg by Hand & Place in 55 Gal Drums >
55 Gallon Drums for Lead Dust
Gather Residual Mtls from Equip by Hand & Place in 55 Gal Drums
55 Gallon Drums for Lead Dust
Transport Drummed Mtls to RCRA Subtitle C Landfill
RCRA Subtitle C Landfill Stabilization & Tipping Fee
Steam Clean Building & Equipment 2 Times
64
1
37,259
37,259
53
508
1,865
522
522
37,259
Gather Residual Materials from Batch House & Equipment, and Steam Clean Buildin
Structural Inspection
Plug Sumps
Structural Modifications (Heavy Duty)
Gather Residual Mtls from Equip by Hand & Race in 55 Gal Drums
55 Gallon Drums for Lead Dust
Transport Drummed Mtls to RCRA Subtitle C Landfill
RCRA Subtitle C Landfill Stabilization & Tipping Fee
Steam Clean Structure 2 Times
Pump Water to Frac Tank, Test & Discharge :
Frac Tanks
Pumping
Sampling
Analysis
48
1
21,749
21,749
31
8
8
21,749
100
1
100
100
HRS
LS
SF
SF
DRUMS
CY
DRUMS
CY
CY
SF
g & Equipme
HRS
LS
SF
SF
DRUMS
CY
CY
SF
EA
LS
EA
EA
$100.00
$1,000.00
$8.80
$0.15
$200.00
$100.00
$200.00
$79.42
$225.00
$0.60
nt (21.749SF)
$100.00
$1,000.00
$8.80
$0.15
$200.00
$79.42
$225.00
$0.60
$1,140.00
$10,000.00
$70.00
$200.00
$3,200
$1,000
$105,530
$1,799
$3,400
$474
$3,400
$735
$2,083
$7,194
& Equipment <
$6,400
$1,000
$327,936
$5,589
$10,600
$50,792
$373,000
$41,477
$117,511
$22,355
$4,800
$1,000
$191,424
$3,262
$6,200
$670
$1,899
$13,049
$114,000
$10,000
$7,000
$20,000
Based on AccuVal 1 (800)852-9252
Assumes Level C Protection
ECHOS 33-19-0204 pg 382. Assume 500 miles
Based on costs from Jones & Neuse
ECHOS 33-17-0812 Pg. 374
37,259 SF):
Based on AccuVal 1(800)852-9252
Assumes Level C Protection
ECHOS 33-19-0204 pg 382, Assume 500 miles
Based on costs from Jones & Neuse
ECHOS 33-17-0812 Pg. 374
Based on AccuVal 1(800)852-9252
Assumes Level C Protection
ECHOS 33-19-0204 pg 382. Assume 500 miles
Based on costs from Jones & Neuse
ECHOS 33-17-0812 Pg. 374
RSROU4M.XLS
Page 3
-------
10/26/95
Revised Table B-1
Cost Estimate
Operable Unit No. 4
RSR Corporation Superfund Site
Dallas, Texas
ft$t£titir*WW^$^^ .
(Accuracy Range: -+-50% / -30%)
MMPPW, mm W M TO*
Asbestos Abatement:
Site Preparation
Cafe Building:
1'xr Floor Tile
Vehicle Maintenance Building:
1'x1' Floor Tile
Bath House Building:
Floor Tile Mastic
Cafeteria Building
Drywall Joint Compound
Floor Tile Mastic
Laboratory Complex Building:
Drywall Joint Compound
1'x1' Floor Tile
Floor Tile Mastic
Hog Storage Building:
Pipe Insulation
Mudded Pipe Fitting
Smelter Facility Building:
1'x1' Floor Tile
Floor Tile Mastic
Tar Backing on Insulation
Vibration Joint Cloth
Packaging & Handling
Transportation to Hazardous Landfill & Disposal
Metals Contaminated Soils:
Cap NE Area with 2' Thick Clean Material
SUBTOTAL
CONTINGENCY
SUBTOTAL - CONSTRUCTION COST
PERMITTING & LEGAL
SERVICES DURING CONSTRUCTION
SUBTOTAL - IMPLEMENTATION COST
ENGINEERING & DESIGN COST
ANNUAL O&M COSTS:
Guard Service (24 Hours/Day, 7 Days/Week)
Long Term Monitoring: Sampling Events
Site Inspection
SUBTOTAL
CONTINGENCY
TOTjftl+^
1
300
250
100
500
1,000
8,000
3,000
2,500
3
3
200
200
2,000
20
500
500
4,000
30%
5%
7%
6%
12
3
12
30%
LS
SF
SF
SF
SF
SF
SF
SF
SF
LF
EA
SF
SF
SF
SF
CY
CY
CY
MONTHS
EA
MONTHS
$10,000.00
$10.60
$10.60
$5.00
$5.00
$5.00
$5.00
$10.60
$5.00
$125.00
$50.00
$10.60
$5.00
$5.00
$5.00
$50.00
$79.00
$15.00
$2,047,395
$2,396,575
$2,396,575
$2,396,575
$10,800.00
$10,500.00
$2,000.00
--• ,
$185,100
$10,000
$3,180
$2,650
$500
$2,500
$5,000
$40,000
$31,800
$12,500
$375
$150
$2,120
$1,000
$10,000
$100
$25,000
$39,500
$60,000
$2,047,395
$614,218
$2,661,613
$119,829
$167,760
$2,949,202
$143,794
matmm
$129,600
$31,500
$24,000
$185,100
$55,530
mrmmx
Asbestos containing material
quantities were obtained from
CH2M HILL report dated July 1 2, 1 994.
Quantities came from survey
conducted by Nobis Engineering, Inc.
Based on costs from Jones & Neuse
Assumes only capping NE portion of property
Unit price includes cost of grading top soil
Based on cost of all on-site activities
Based on cost of all on-site activities
Based on cost of all on-site activities
RSROU4M.XLS
Page 4
-------
10/26/95
Revised Table B-1
Cost Estimate
Operable Unit No. 4
RSR Corporation Superfund Site
Dallas, Texas
JftftttttPtiW^^
(Accuracy Range: +50% / -30%)
&SS
-------
10/26/95
Revised Table B-1
Cost Estimate
Operable Unit No. 4
RSR Corporation Superfund Site
Dallas, Texas
ft$ft€0flp
-------
10/26/95
Revised Table B-1
Cost Estimate
Operable Unit No. 4
RSR Corporation Superfund Site
Dallas, Texas
tftttttiK^^ . i
(Accuracy Range: +50% / -30%)
Ds$<3e?iiitw* isyaNtrr* *m #m* w*k R^8Ma«Bi •
-. ' SOSt .. : •
Asbestos Abatement:
Site Preparation
Cafe Building:
1'x1' Floor Tile
Vehicle Maintenance Building:
1'x1' Floor Tile
Bath House Building:
Floor Tile Mastic
Cafeteria Building
Drywall Joint Compound
Floor Tile Mastic
Laboratory Complex Building:
Drywall Joint Compound
1'xr Floor Tile
Floor Tile Mastic
Hog Storage Building:
Pipe Insulation
Mudded Pipe Fitting
Smelter Facility Building:
1'x1' Floor Tile
Floor Tile Mastic
Tar Backing on Insulation
Vibration Joint Cloth
Packaging & Handling
Transportation to Hazardous Landfill & Disposal
Remove Hog Storage Building, Smelter Facility & Batch House:
Samples for Smelter Facility
Samples for Hog Storage Building
Samples for Batch House
TCLP Analysis
Controlled Dismantle of Hog Storage Building
Controlled Dismantle of Smelter Facility & Adjacent Bag Houses
Controlled Dismantle of Batch House
Steam Clean Sheet Metal Debris at Vehicle Maintenance Bldg
Transport Sheet Metal to Class I Waste Facility & Tipping Fee
Transport & Dispose of Equipment at Class II Waste Facility
Gate Fee for Truck at Class II Waste Facility
Pump Water to Frac Tank, Test & Discharge :
Frac Tanks
Pumping
Sampling
Analysis
Demolish Smelter Stack and Transport to RCRA Subtitle C Landfill:
Smelter Stack (300 ' High)
Transport Drummed Debris to RCRA Subtitle C Landfill
RCRA Subtitle C Landfill Stabilization & Tipping Fee
1
300
250
100
500
1,000
8,000
3,000
2,500
3
3
200
200
2,000
20
500
500
100
20
20
140
11,990
37,259
21,749
124,949
3,944
3,944
197
100
1
100
100
1
1,256
1,256
Demolish Remaining Structures and Transport Debris to Appropriate Facility:
Samples for Buildings (5 Buildings, 20 Samples Each)
TCLP Analysis
100
100
LS
SF
SF
SF
SF
SF
SF
SF
SF
LF
EA
SF
SF
SF
SF
CY
CY
EA
EA
EA
EA
SF
SF
SF
SF
CY
CY
Truck Loads
EA
LS
EA
EA
LS
CY
CY
EA
EA
$10,000.00
$10.60
$10.60
$5.00
$5.00
$5.00
$5.00
$10.60
$5.00
$125.00
$50.00
$10.60
$5.00
$5.00
$5.00
$50.00
$79.00
$70.00
$70.00
$70.00
$300.00
$20.00
$20.00
$20.00
$0.60
$90.00
$29.00
$14.00
$1,140:00
$10,000.00
$70.00
$200.00
$400,000
$79.42
$125.00
$70.00
$300.00
$10,000
$3,180
$2,650
$500
$2,500
$5,000
$40,000
$31,800
$12,500
$375
$150
$2,120
$1,000
$10,000
$100
$25,000
$39,500
$7,000
$1,400
$1,400
$42,000
$239,800
$745,180
$434,980
$74,969
$354,990
$114,386
$2,761
$114,000
$10,000
$7,000
$20,000
$400,000
$99,747
$157,000
$7,000
$30,000
Asbestos containing material
quantities were obtained from
CH2M HILL report dated July 1 2, 1 994.
Quantities came from survey
conducted by Nobis Engineering, Inc.
Based on costs from Jones & Neuse
Based on AccuVal 1(800)852-9252
Based on AccuVal 1(800)852-9252
Based on AccuVal 1(800)852-9252
Based on costs from Jones & Neuse
Based on costs from Jones & Neuse
Based on costs from Jones & Neuse
Based on AccuVal 1(800)852-9252
ECHOS 33-19-0204 pg 382, Assume 500 mites
Based on costs from Jones & Neuse
RSROU4M.XLS
Page 7
-------
10/26/95
Revised Table B-1
Cost Estimate
Operable Unit No. 4
RSR Corporation Superfund Site
Dallas, Texas
(Accuracy Range: +50% / -30%)
»i*wrm «««, VMT «pr W*
Controlled Dismantling of Roofs and Transport to RCRA C Facility:
Vehicle Maintenance Building
Bath House
Cafeteria
Laboratory
Gas Station
Transport Roof Debris to RCRA Subtitle C Landfill
RCRA Subtitle C Landfill Stabilization & Tipping Fee
Demolish Remainder of Buildings and Dispose of Debris in Appropriate Fa
Vehicle Maintenance Building
Bath House
Cafeteria
Laboratory
Gas Station
Transport Debris to Class 1 Waste Facility & Tipping Fee
Transport & Dispose of Equipment at Class II Waste Facility
Gate Fee for Truck at Class II Waste Facility
Transport Debris to RCRA Subtitle C Facility
Tipping Fee at RCRA Subtitle C Facility
Metals Contaminated Soils:
Demolish Concrete Pavements
Transport Debris to RCRA Subtitle D Landfill
RCRA Subtitle D Landfill Tipping Fee
Cap NE Area & Formerly Paved Areas with 2' Thick Clean Material
SUBTOTAL
CONTINGENCY
SUBTOTAL - CONSTRUCTION COST
PERMITTING & LEGAL
SERVICES DURING CONSTRUCTION
SUBTOTAL - IMPLEMENTATION COST
ENGINEERING & DESIGN COST
ANNUAL O&M COSTS:
Site Inspection
SUBTOTAL
CONTINGENCY
3,717
2,200
1,302
5,619
525
495
495
cilities:
3,717
2,200
1,302
5,619
525
247
198
10
49
49
7,900
1,317
66
9,300
30%
5%
7%
6%
12
30%
SF
SF
SF
SF
SF
CY
CY
SF
SF
SF
SF
SF
CY
CY
Truck Loads
CY
CY
SY
CY
Truck Loads
CY
MONTHS
$1.00
$1.00
$1.00
$1.00
$1.00
$79.42
$125.00
$14.00
$18.00
$18.00
$18.00
$18.00
$90.00
$29.00
$14.00
$79.42
$125.00
$15.00
$10.00
$143.00
$15.00
$6,244,150
$6,561,954
$6,561,954
$6,561,954
$2,000.00
$24,000
$3,717
$2,200
$1,302
$5,619
$525
$39,305
$61,866
$52,038
$39,600
$23,436
$101,142
$9,450
$22,272
$5,741
$139
$3,931
$6,187
$118,500
$13,167
$9,414
$139,500
$6,244,150
$1,873,245
$8,117,396
$328,098
$459,337
$8,904,830
$393,717
$24,000
$24,000
$7,200
RE*e*e*c£
Based on ECHOS 16-01-0308 pg 28
Based on ECHOS 16-01-0308 pg 28
Based on ECHOS 16-01-0308 pg 28
Based on ECHOS 16-01-0308 pg 28
Based on ECHOS 16-01-0308 pg 28
ECHOS 33-19-0204 pg 382, Assume 500 miles
Based on costs from Jones & Neuse
Based on AccuVal 1(800)852-9252
Based on AccuVal 1(800)852-9252
Based on AccuVal 1(800)852-9252
Based on AccuVal 1(800)852-9252
Based on AccuVal 1(800)852-9252
Based on costs from Jones & Neuse
Based on costs from Jones & Neuse
Based on costs from Jones & Neuse
ECHOS 33-19-0204 pg 382, Assume 500 miles
Based on costs from Jones & Neuse
Based on 95 MEANS 020-554-1900
Dallas Municipal Landfill (214)670-0977
Includes NE area and all areas that
were paved
Based on cost of all on-site activities
Based on cost of all on-site activities
Based on cost of all on-site activities
$3?<20&
RSROU4M.XLS
PageS
-------
10/26/95
Revised Table B-1
Cost Estimate
Operable Unit No. 4
RSR Corporation Superfund Site
Dallas, Texas
m$MmMm->$m:m
(Accuracy Range: +50% / -3
0%)
: fcissf^rm iqwANtiry vm *twf TW& n&mam
«OST •. .
NET PRESENT VALUE:
YEARO
YEAR1
YEAR 2
YEAR 3
YEAR 4 _^
YEARS
YEARS
YEAR?
YEARS
YEAR 9
YEAR 10
YEAR 1 1
YEAR 12
YEAR 13
YEAR 14
YEAR 15
YEAR 16
YEAR 17
YEAR 18
YEAR 19
YEAR 20
YEAR 21
YEAR 22
YEAR 23
YEAR 24
YEAR 25
YEAR 26
YEAR 27
YEAR 28
YEAR 29
YEAR 30
»^pft£SEfrrmuEtf^
$9,298,547
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
$31,200
m33*&»$
RSROU4M.XLS
Page 9
-------
10/26/95
Revised Table B-1
Cost Estimate
Operable Unit No. 4
RSR Corporation Superfund Site
Dallas, Texas
!i*i;«^
(Accuracy Range: +50% / -3
0%)
: &i$$*»»iiw entity vm wm WWM* *&mm%
: % «OSt •
ALTERNATIVE 4: Same as Alternative No. 3 and Includes Excavation & Disposal of
Metals-Contaminated Soils.
CAPITAL COSTS:
GENERAL REQUIREMENTS:
General Sitework:
Air Monitoring During Site Work
10%
1
Gather Residual Materials from Hog Storage Building & Equipment (11,990 SF):
Structural Inspection
Structural Modifications
Gather Residual Mtls from Bldg by Hand & Place in 55 Gal Drums
55 Gallon Drums for Lead Dust
Gather Residual MUs from Equip by Hand & Place in 55 Gal Drums
55 Gallon Drums for Lead Dust
Transport Drummed Mtls to RCRA Subtitle C Landfill
RCRA Subtitle C Landfill Stabilization & Tipping Fee
Gather Residual Materials from Smelter Facility & Adjacent Bag House
Structural Inspection
Structural Modifications
Gather Residual Mtls from Bldg by Hand & Place in 55 Gal Drums
55 Gallon Drums for Lead Dust
Gather Residual Mtls from Equip by Hand & Place in 55 Gal Drums
55 Gallon Drums for Lead Dust
Transport Drummed Mtls to RCRA Subtitle C Landfill
RCRA Subtitle C Landfill Stabilization & Tipping Fee
Gather Residual Materials from Batch House & Equipment (21,749 SF)
Structural Inspection
Structural Modifications
Gather Residual Mtls from Equip by Hand & Place in 55 Gal Drums
55 Gallon Drums for Lead Dust
Transport Drummed Mtls to RCRA Subtitle C Landfill
RCRA Subtitle C Landfill Stabilization & Tipping Fee
Dismantle Non-Supporting Equipment in Hog Storage Building, Steam
Dismantle Non-Supporting Equipment
Steam Clean Equipment 2 Times
Transport & Dispose of Equipment at Class II Waste Facility
Gate Fee for Truck at Class 1 1 Waste Facility
Dismantle Non-Supporting Equipment in Smelter Facility, Steam Clear
Dismantle Non-Supporting Equipment
Steam Clean Equipment 2 Times
Transport & Dispose of Equipment at Class II Waste Facility
Gate Fee for Truck at Class II Waste Facility
Asbestos Abatement:
Site Preparation
Cafe Building:
1'x1' Floor Tile
Vehicle Maintenance Building:
Vxr Floor Tile
Bath House Building:
Floor Tile Mastic
Cafeteria Building
Drywall Joint Compound
32
11,990
11,990
17
5
17
9
9
LS
MRS
SF
SF
DRUMS
CY
DRUMS
CY
CY
$7,858,595
$100,000.00
$100.00
$5.87
$0.15
$200.00
$100.00
$200.00
$79.42
$225.00
s & Equipment (37,259 SF):
64
37,259
37,259
53
508
1,865
522
522
48
21,749
21,749
31
8
8
Clean at VMB
10
5,000
10
1
at VMB & Ad
1,000
60,000
1,000
50
1
300
250
100
500
MRS
SF
SF
DRUMS
CY
DRUMS
CY
CY
MRS
SF
SF
DRUMS
CY
CY
& Haul to Cl
TONS
SF
TONS
Truck Loads
jacent Bag H
TONS
SF
TONS
Truck Loads
LS
SF
SF
SF
SF
$100.00
$5.87
$0.15
$200.00
$100.00
$200.00
$79.42
$225.00
$100.00
$5.87
$0.15
$200.00
$79.42
$225.00
ass II Waste Fa
$610:00
$0.60
$100.00
$14.00
ouses & Haul to
$610.00
$0.60
$100.00
$14.00
$10,000.00
$10.60
$10.60
$5.00
$5.00
$785,859
$100,000
$3,200
$70,353
$1,799
$3,400
$474
$3,400
$735
$2,083
$6,400
$218,624
$5,589
$10,600
$50,792
$373,000
$41,477
$117,511
$4,800
$127,616
$3,262
$6,200
$670
$1,899
:ility:
$6,100
$3,000
$1,000
$14
Based on AccuVal 1(800)852-9252
Assumes Level C Protection
ECHOS 33-1 9-0204 pg 382, Assume 500 miles
Based on costs from Jones & Neuse
Based on AccuVal 1(800)852-9252
Assumes Level C Protection
ECHOS 33-19-0204 pg 382, Assume 500 miles
Based on costs from Jones & Neuse
Based on AccuVal 1(800)852-9252
Assumes Level C Protection
ECHOS 33-19-0204 pg 382, Assume 500 miles
Based on costs from Jones & Neuse
Based on 95 MEANS 020-718-3600
ECHOS 33-17-0812 Pg. 374
Based on costs from Jones & Neuse
Class II Waste Facility:
$610,000
$36,000
$100,000
$700
$10,000
$3,180
$2,650
$500
$2,500
Based on 95 MEANS 020-718-3600
ECHOS 33-17-0812 Pg. 374
Based on costs from Jones & Neuse
Asbestos containing material
quantities were obtained from
CH2M HILL report dated July 1 2, 1 994.
Quantities came from survey
conducted by Nobis Engineering, Inc.
RSROU4M.XLS
Page 10
-------
10/26/95
Revised Table B-1
Cost Estimate
Operable Unit No. 4
RSR Corporation Superfund Site
Dallas, Texas
^<#«W)^
(Accuracy Range: +50% / -30%)
COST
Floor Tile Mastic
Laboratory Complex Building:
Drywall Joint Compound
1'x1' Floor Tile
Floor Tile Mastic
Hog Storage Building:
Pipe Insulation
Mudded Pipe Fitting
Smelter Facility Building:
1'x1' Floor Tile
Floor Tile Mastic
Tar Backing on Insulation
Vibration Joint Cloth
Packaging & Handling
Transportation to Hazardous Landfill & Disposal
Remove Hog Storage Building, Smelter Facility & Batch House:
Samples for Smelter Facility
Samples for Hog Storage Building
Samples for Batch House
TCLP Analysis
Controlled Dismantle of Hog Storage Building
Controlled Dismantle of Smelter Facility & Adjacent Bag Houses
Controlled Dismantle of Batch House
Steam Clean Sheet Metal Debris at Vehicle Maintenance Bldg
Transport Sheet Metal to Class I Waste Facility & Tipping Fee
Transport & Dispose of Equipment at Class II Waste Facility
Gate Fee for Truck at Class II Waste Facility
Pump Water to Frac Tank, Test & Discharge :
Frac Tanks
Pumping
Sampling
Analysis
Demolish Smelter Stack and Transport to RCRA Subtitle C Landfill:
Smelter Stack (300 ' High)
Transport Drummed Debris to RCRA Subtitle C Landfill
RCRA Subtitle C Landfill Stabilization & Tipping Fee
1,000
8,000
3,000
2,500
3
3
200
200
2,000
20
500
500
100
20
20
140
11,990
37,259
21,749
124,949
3,944
3,944
197
100
1
100
100
1
1,256
1,256
Demolish Remaining Structures and Transport Debris to Appropriate Facility:
Samples for Buildings (5 Buildings, 20 Samples Each)
TCLP Analysis
Controlled Dismantling of Roofs and Transport to RCRA C Facility:
Vehicle Maintenance Building
Bath House
Cafeteria
Laboratory
Gas Station
Transport Roof Debris to RCRA Subtitle C Landfill
RCRA Subtitle C Landfiif Stabilization & Tipping Fee
Demolish Remainder of Buildings and Dispose of Debris in Appropriate Fa
Vehicle Maintenance Building
Bath House
Cafeteria
Laboratory
Gas Station
Transport Debris to Class I Waste Facility & Tipping Fee
100
100
3,717
2,200
1,302
5,619
525
495
495
duties:
3,717
2,200
1,302
5,619
. 525
247
SF
SF
SF
SF
LF
EA
SF
SF
SF
SF
CY
CY
EA
EA
EA
EA
SF
SF
SF
SF
CY
CY
Truck Loads
EA
LS
EA
EA
LS
CY
CY
EA
EA
SF
SF
SF
SF
SF
CY
CY
SF
SF
SF
SF
SF
CY
$5.00
$5.00
$10.60
$5.00
$125.00
$50.00
$10.60
$5.00
$5.00
$5.00
$50.00
$79.00
$70.00
$70.00
$70.00
$300.00
$20.00
$20.00
$20.00
$0.60
$90.00
$29.00
$14.00
$1,140.00
$10,000.00
$70.00
$200.00
$400,000
$79.42
$125.00
'
$70.00
$300.00
$1.00
$1.00
$1.00
$1.00
$1.00
$79.42
$125.00
$14.00
$18.00
$18.00
$18.00
$18.00
$90.00
$5,000
$40,000
$31,800
$12,500
$375
$150
$2,120
$1,000
$10,000
$100
$25,000
$39,500
$7,000
$1,400
$1,400
$42,000
$239,800
$745,180
$434,980
$74,969
$354,990
$114,386
$2,761
$114,000
$10,000
$7,000
$20,000
$400,000
$99,747
$157,000
$7,000
$30,000
$3,717
$2,200
$1,302
$5,619
$525
$39,305
$61,866
$52,038
$39,600
$23,436
$101,142
$9,450
$22,272
REFE*e«C£
Based on costs from Jones & Neuse
Based on AccuVal 1(800)852-9252
Based on AccuVal 1 (800)852-9252
Based on AccuVal 1(800)852-9252
Based on costs from Jones & Neuse
Based on costs from Jones & Neuse
Based on costs from Jones & Neuse
Based on AccuVal 1(800)852-9252
ECHOS 33-19-0204 pg 382, Assume 500 miles
Based on costs from Jones & Neuse
Based on ECHOS 16-01-0308 pg 28
Based on ECHOS 16-01-0308 pg 28
Based on ECHOS 16-01-0308 pg 28
Based on ECHOS 16-01-0308 pg 28
Based on ECHOS 16-01-0308 pg 28
ECHOS 33-19-0204 pg 382, Assume 500 miles
Based on costs from Jones & Neuse
Based on AccuVal 1(800)852-9252
Based on AccuVal 1(800)852-9252
Based on AccuVal 1(800)852-9252
Based on AccuVal 1(800)852-9252
Based on AccuVal 1(800)852-9252
Based on costs from Jones & Neuse
RSROU4M.XLS
Page 11
-------
10/26/95
Revised Table B-1
Cost Estimate
Operable Unit No. 4
RSR Corporation Superfund Site
Dallas, Texas
;§i;;«^
(Accuracy Ran
&6$C**1W*
Transport & Dispose of Equipment at Class II Waste Facility
Gate Fee for Truck at Class II Waste Facility
Transport Debris to RCRA Subtitle C Facility
Tipping Fee at RCRA Subtitle C Facility
Metals Contaminated Soils:
Demolish Concrete Pavements
Transport Debris to RCRA Subtitle D Landfill
RCRA Subtitle D Landfill Tipping Fee
Excavate Metals Contaminated Soils 1' Deep in AH Areas Except NE Comer
Excavate Metals Contaminated Soils 2' Deep in NE Comer
Sample Excavated Materials
TCLP Analysis
TAL Metals Analysis
Transport Soils to Class I Waste Facility & Tipping Fee
Backfill All Areas Except NE Comer with 1' Thick Clean Material
Backfill NE Comer with 2' Thick Clean Matehal
SUBTOTAL
CONTINGENCY
SUBTOTAL - CONSTRUCTION COST
PERMITTING & LEGAL
SERVICES DURING CONSTRUCTION
SUBTOTAL - IMPLEMENTATION COST
ENGINEERING & DESIGN COST
ANNUAL O&M COSTS:
Site Control Cost
Site Monitoring Cost
SUBTOTAL
CONTINGENCY
TOTAL ~ AftttWrt & & M Cb$t$ - Alfcftitttftjr* 4-
I!M»^
ge: -«-50% / -30%)
<&St
198
10
49
49
7,900
1,317
66
10,100
3,400
100
100
100
13,500
12,120
4,080
30%
5%
7%
6%
1
1
30%
CY
Truck Loads
CY
CY
SY
CY
Truck Loads
CY
CY
EA
EA
EA
CY
CY
CY
LS
LS
$29.00
$14.00
$79.42
$125.00
$15.00
$10.00
$143.00
$5.00
$5.00
$70.00
$300.00
$300.00
$90.00
$15.00
$15.00
57,858,595
$7,081.232
$7,081,232
$7,081,232
$0.00
$0.00
$0
$5,741
$139
$3,931
$6,187
$118,500
$13,167
$9.414
$50,500
$17,000
$7,000
$30,000
$30,000
$1,215,000
$181,800
$61,200
$7,858,595
$2,357,578
$10,216,173
$354,062
$495,686
$11,065,921
$424,874
$0
$0
$0
$0
$<*
Based on costs from Jones & Neuse
Based on costs from Jones & Neuse
ECHOS 33-19-0204 pg 382, Assume 500 mites
Based on costs from Jones & Neuse
Based on 95 MEANS 020-554-1900
Dallas Municipal Landfill (214)670-0977
Based on costs from Jones & Neuse
Assumes backfill quantity is 20% greater than
excavated quantity.
Assumes backfill quantity is 20% greater than
excavated quantity.
Based on cost of all on-site activities
Based on cost of all on-site activities
Based on cost of all on-site activities
RSROU4M.XLS
Page 12
-------
10/26/95
Revised Table B-1
Cost Estimate
Operable Unit No. 4
RSR Corporation Superfund Site
Dallas, Texas
8$«tttitiNtt*tt^ . . .
(Accuracy Range: +50% 1 -30%)
&g$$*»>T$wi t^MtiT* &m #m* TOT^ wgittMafr
«*«Y
NET PRESENT VALUE:
YEARO
YEAR 1
YEAR 2
YEAR 3
YEAR 4
YEARS
YEARS
YEAR 7
YEARS
YEAR 9
YEAR 10
YEAR 11
YEAR 12
YEAR 13
YEAR 14
YEAR 15
YEAR 16
YEAR 17
YEAR 18
YEAR 19
YEAR 20
YEAR 21
YEAR 22
YEAR 23
YEAR 24
YEAR 25
YEAR 26
YEAR 27
YEAR 28
YEAR 29
YEAR 30
«ETPRESKtrrVAtue^5%^A«^maf{v«4 •
$11,490,795
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$*f<400
-------
10/26/95
RSROU4A4.XLS
CH2M HILL
RSR Corporation Superfund Site
PROJECT NO: 111431.FS.R4
PREPARED BY E.R.MEYER
#SR COBPORATiON SVPEBPUNQ S/H
(Ac
DESCRIPTION
ALTERNA TIVE 4A: Same as Alternative No. 4 Except Includes Disposal of Non-
Hazardous Waste at OU5 Landfill.
CAPITAL COSTS:
GENERAL REQUIREMENTS:
General Sitework:
Air Monitoring During Site Work
•-REMEDIA
curacy Rang<
QUANTITY
10%
1
r/o/voFo
*: +50% / -3
UNIT
LS
Gather Residual Materials from Hog Storage Building & Equipment (11,990 SF):
Structural Inspection
Structural Modifications
Gather Residual Mtls from Bldg by Hand & Place in 55 Gal Drums
55 Gallon Drums for Lead Dust
32
11,990
11,990
17
i
Gather Residual Mtls from Equip by Hand & Place in 55 Gal Drums
55 Gallon Drums for Lead Dust
Transport Drummed Mtls to RCRA Subtitle C Landfill
RCRA Subtitle C Landfill Stabilization & Tipping Fee
5
17
HRS
SF
SF
DRUMS
CY
DRUMS
9 CY
9 CY
V4(COMTtHG
0%)
$AJNIT
$6,022,048
$100,000.00
$100.00
$5.87
$0.15
$200.00
$100.00
$200.00
$79.42
$225.00
Gather Residual Materials from Smelter Facility & Adjacent Bag Houses & Equipment (37,259 SF):
Structural Inspection
Structural Modifications
Gather Residual Mtls from Bldg by Hand & Place in 55 Gal Drums
55 Gallon Drums for Lead Dust
64| MRS
37,259 SF
37,259 SF
53! DRUMS
Gather Residual Mtls from Equip by Hand & Place in 55 Gal Drums ;
55 Gallon Drums for Lead Dust
508i CY
1,865! DRUMS
! :
Transport Drummed Mtls to RCRA Subtitle C Landfill
RCRA Subtitle C Landfill Stabilization & Tipping Fee
522i CY
522! CY
Gather Residual Materials from Batch House & Equipment (21,749 SF):
Structural Inspection
Structural Modifications
Gather Residual Mtls from Equip by Hand & Place in 55 Gal Drums
55 Gallon Drums for Lead Dust
Transport Drummed Mtls to RCRA Subtitle C Landfill
RCRA Subtitle C Landfill Stabilization & Tipping Fee
48; MRS
21,749! SF
21,749| SF
31! DRUMS
8 CY
8! CY
$100.00
$5.87
$0.15
$200.00
$100.00
$200.00
$79.42
$225.00
$100.00
$5.87
$0.15
$200:00
$79.42
$225.00
€NCYALTERl
TOTAL
COST
$602,205
$100,000
$3,200
$70,353
$1,799
$3,400
$474
$3,400
$735
$2,083
$6,400
$218,624
$5,589
$10,600
$50,792
$373,000
$41 ,477
$117,511
$4,800
$127,616
$3,262
$6,200
$670
$1,899
VA77VE4AJ
REFERENCE
Based on AccuVal 1(800)852-9252
Assumes Level C Protection
ECHOS 33-19-0204 pg 382, Assume 500 miles
Based on costs from Jones & Neuse
Based on AccuVal 1(800)852-9252
Assumes Level C Protection
ECHOS 33-19-0204 pg 382, Assume 500 miles
Based on costs from Jones & Neuse
Based on AccuVal 1(800)852-9252
Assumes Level C Protection
ECHOS 33-19-0204 pg 382, Assume 500 miles
Based on costs from Jones & Neuse
Dismantle Non-Supporting Equipment in Hog Storage Building, Steam Clean at VMB & Haul to Class II Waste Facility:
Dismantle Non-Supporting Equipment
Steam Clean Equipment 2 Times
10; TONS $610.00
5,000 SF $0.60
Load Equipment onto Truck for Transport to OU5 Landfill
Transport Equipment Over to OU5 Landfill (1 mi round trip)
Unload Equipment on Truck & Place in OU5 Landfill
10! TONS
10 TONS
10' TONS
$6.21
$5.08
$6.21
$6,100
$3,000
$62
$51
$62
Based on 95 MEANS 020-718-3600
ECHOS 33-17-0812 Pg. 374
Based on MEANS Crew B-22
Based on MEANS Crew B-34D
Based on MEANS Crew B-22
Dismantle Non-Supporting Equipment in Smelter Facility, Steam Clean at VMB & Adjacent Bag Houses & Haul to Class II Waste Facility:
Dismantle Non-Supporting Equipment
Steam Clean Equipment 2 Times
1.000: TONS
60,000 SF
Load Equipment onto Truck for Transport to OU5 Landfill
Transport Equipment Over to OU5 Landfill (1 mi round trip)
Unload Equipment on Truck & Place in OU5 Landfill
1,000 TONS ]
1,000, TONS
1,000 TONS
$610.00
$0.60
$6.21
$5.08
$6.21
$610,000
$36,000
$6,209
$5,084
$6,209
Based on 95 MEANS 020-718-3600
ECHOS 33-1 7-081 2 Pg. 374
Based on MEANS Crew B-22
Based on MEANS Crew B-34D
Based on MEANS Crew B-22
Page 1
-------
10/26/95
RSROU4A4.XLS
CH2M HILL
RSR Corporation Superfund Site
PROJECT NO: 111431.FS.R4 [
PREPARED BY E.R.MEYER
RSR CORPORATION SUPERPUND SITE - REMEDIATION OP O
(Accuracy Range: +50% / -3
DESCRIPTION QUANTITY UNIT
Asbestos Abatement:
Site Preparation 1 LS
Cafe Building:
1'x 1' Floor Tile 300 SF
Vehicle Maintenance Building:
1'x 1' Floor Tile 250 SF
Bath House Building:
Floor Tile Mastic j 100 SF
Cafeteria Building
Drywall Joint Compound 500 SF
Floor Tile Mastic 1,000 SF
Laboratory Complex Building:
Drywall Joint Compound 8,000 SF
1'x 1' Floor Tile 3,000| SF
Floor Tile Mastic | 2,500 SF
Hog Storage Building:
Pipe Insulation 3 LF
Mudded Pipe Fitting ^ 3 EA
Smelter Facility Building:
1'x 1' Floor Tile 200 SF
Floor Tile Mastic 200 SF
Tar Backing on Insulation : 2,000] SF
Vibration Joint Cloth ; 20 SF
Packaging & Handling ; 500 CY
Transportation to Hazardous Landfill & Disposal 500 CY
'
Remove Hog Storage Building, Smelter Facility & Batch House:
Samples for Smelter Facility 100 EA
Samples for Hog Storage Building 20| EA
Samples for Batch House 20 EA
TCLP Analysis 140 E A
Controlled Dismantle of Hog Storage Building 11,990 SF
Controlled Dismantle of Smelter Facility & Adjacent Bag Houses 37,259; SF
Controlled Dismantle of Batch House 21,749j SF
Steam Clean Sheet Metal Debris at Vehicle Maintenance Bldg 124,9491 SF
Load Sheet Metal onto Truck for Transport to OU5 Landfill 7,889 CY
Transport Sheet Metal Over to OU5 Landfill (1 mi round trip) 197 Truck Loads
Unload Sheet Metal on Truck & Place in OU5 Landfill 7.8891 CY
Pump Water to Frac Tank, Test & Discharge :
Frac Tanks 100 EA
Pumping 1 LS
Sampling 100 EA
Analysis 10^ EA
Demolish Smelter Stack and Transport to RCRA Subtitle C Landfill:
Smelter Stack (300 ' High) 1 LS
Transport Drummed Debris to RCRA Subtitle C Landfill 1 ,256 CY
U4(CONTING
0%)
$/UNlT
$10,000.00
$10.60
$10.60
$5.00
$5.00
$5.00
$5.00
$10.60
$5.00
$125.00
$50.00
$10.60
$5.00
$5.00
$5.00
$50.00
$79.00
$70.00
$70.00
$70.00
$300.00
$20.00
$20.00
$20.00
$0-60
$3.03
$50.84
$4.26
$1,140.00
$10,000.00
$70.00
$200.00
$400,000
$79.42
RCRA Subtitle C Landfill Stabilization & Tipping Fee 1 ,256 CY j $125.00
J ~*
Demolish Remaining Structures and Transport Debris to Appropriate Facility:
Samples for Buildings (5 Buildings, 20 Samples Each) 100 EA
~TCLP Analysis ~" " " ~~ Tda "" I A"
$70.00
$300.00
ENCYALTERt
TOTAL
COST
$10,000
$3,180
$2,650
$500
$2,500
$5,000
$40,000
$31,800
$12,500
$375
$150
$2,120
$1,000
$10,000
$100
$25,000
$39,500
$7,000
$1,400
$1,400
$42,000
$239,800
$745,180
$434,980
$74,969
$23,901
$10,027
$33,598
$114,000
$10,000
$7,000
$20,000
$400,000
$99,747
$157,000
$7,000
$30,000
VAT/ME 4AJ
REFERENCE
Asbestos containing material
quantities were obtained from
CH2M HILL report dated July 12, 1994.
Quantities came from survey
conducted by Nobis Engineering, Inc.
Based on costs from Jones & Neuse
Based on AccuVal 1(800)852-9252
Based on AccuVal 1(800)852-9252
Based on AccuVal 1(800)852-9252
Based on MEANS Crew B-10O
Based on MEANS Crew B-34D
Based on MEANS Crew B-15
Based on AccuVal 1(800)852-9252
ECHOS 33-19-0204 pg 332 Assume 500 miles
Based on costs from Jones & Neuse
Page 2
-------
10/26/95
RSROU4A4.XLS
CH2M HILL !
RSR Corporation Superfund Site
PROJECT NO: 111431.FS.R4
PREPARED BY E.R.MEYER
RSR CORPORATION SVPERFUHD SITE - REMEDIATION OF O
(Accuracy Range: +50% / -3
DESCRIPTION QUANTITY UNIT
Controlled Dismantling of Roofs and Transport to RCRA C Facility:
Vehicle Maintenance Building 3,717 SF
Bath House 2,200 SF
Cafeteria 1,302 SF
Laboratory 5,619 SF
Gas Station 525 SF
Transport Roof Debris to RCRA Subtitle C Landfill 495 CY
RCRA Subtitle C Landfill Stabilization & Tipping Fee 495 CY
! i
Demolish Remainder of Buildings and Dispose of Debris in Appropriate Facilities:
Vehicle Maintenance Building 3,717 SF
Bath House 2,200 SF
Cafeteria I 1,302 SF
Laboratory i 5,619 SF
Gas Station 525i SF
Load Debris onto Truck for Transport to OU5 Landfill i 445 CY
Transport Debris Over to OU5 Landfill (1 mi round trip) 22 Truck Loads
Unload Debris on Truck & Place in OU5 Landfill 445 CY
Transport Debris to RCRA Subtitle C Facility : 49 CY
Tipping Fee at RCRA Subtitle C Facility ; 49 CY
Metals Contaminated Soils:
Demolish Concrete Pavements 7,900! SY
Load Concrete Pavements onto Truck for Transport to OU5 Landfill 1,317' CY
Transport Concrete Pavements Over to OU5 Landfill (1 mt round trip) 66! Truck Loads
Unload Concrete Pavements on Truck & Place in OU5 Landfill ! 1,317; CY
Excavate Metals Contaminated Soils 1' Deep in All Areas Except NE Corner 10,100: CY
Excavate Metals Contaminated Soils 2' Deep in NE Corner 3,400' CY
Sample Excavated Materials 100 EA
TCLP Analysis 100; EA
TAL Metals Analysis 100; EA
Load Metals Contaminated Soils onto Truck for Transport to OU5 Landfill 13,500; CY
Transport Metals Contaminated Soils Over to OU5 Landfill (1 mi round trip) 675: Truck Loads
Unload Metals Contaminated Soils on Truck & Place in OU5 Landfill 13.5001 CY
Backfill All Areas Except NE Corner with 1' Thick Clean Material 12,120 CY
Backfill NE Corner with 2' Thick Clean Material 4,080 CY
SUBTOTAL
CONTINGENCY 30%
SUBTOTAL - CONSTRUCTION COST
PERMITTING & LEGAL 5%
SERVICES DURING CONSTRUCTION 7%
SUBTOTAL - IMPLEMENTATION COST
ENGINEERING & DESIGN COST 6%
TOTAL - Capital Costs - Alternative 4A
ANNUAL O & ~M COSTS:
Site~Control Cost .--_--_._ ._ _. ._.__ _^.. ... . |
U4(CONTtNG
0%)
$/UNIT
$1.00
$1.00
$1.00
$1.00
$1.00
$79.42
$125.00
$14.00
$18.00
$18.00
$18.00
$18.00
$3.03
$50.84
$4.26
$79.42
$125.00
$15.00
$2.02
$33.89
$2.84
$5.00
$5.00
$70.00
$300.00
$300.00
$2.02
$3389
$284
$1500
$1500
$6,022,048
$7,784,556
$7,784,556
$7,784,556
I
$000 I
ENCYALTER
TOTAL
COST
$3,717
$2,200
$1,302
$5,619
$525
$39,305
$61,866
$52,038
$39,600
$23,436
$101,142
$9,450
$1,350
$1,132
$1,897
$3,931
$6,187
$118,500
$2,660
$2,231
$3,739
$50,500
$17,000
$7,000
$30,000
$30,000
$27,269
$22,878
$38,332
$181,800
$61,200
$6,022,048
$1,806,615
$7,828,663
$389,228
$544,919
$8,762,810
$467,073
$9,229,883
I
HATIVE4A)
REFERENCE
Based on ECHOS 16-01-0308 pg 28
Based on ECHOS 16-01-0308 pg 28
Based on ECHOS 16-01-0308 pg 28
Based on ECHOS 16-01-0308 pg 28
Based on ECHOS 16-01-0308 pg 28
ECHOS 33-19-0204 pg 382. Assume 500 miles
Based on costs from Jones & Neuse
Based on AccuVal 1(800)852-9252
Based on AccuVal 1(800)852-9252
Based on AccuVal 1(800)852-9252
Based on AccuVal 1(800)852-9252
Based on AccuVal 1(800)852-9252
Based on MEANS Crew B-10O
Based on MEANS Crew B-34D
Based on MEANS Crew B-15
ECHOS 33-19-0204 pg 382. Assume 500 miles
Based on costs from Jones & Neuse
Based on 95 MEANS 020-554-1900
Based on MEANS Crew B-10O
Based on MEANS Crew B-34D
Based on MEANS Crew B-15
Based on MEANS Crew B-10O
Based on MEANS Crew B-34D
Based on MEANS Crew B-15
Assumes backfill quantity is 20% greater
han excavated quantity.
Assumes backfill quantity is 20% greater
han excavated quantity.
Based on cost of all on-site activities
Based on cost of all on-site activities
3ased on cost of all on-site activities
~^- ------------
Page3
-------
10/26/95
RSROU4A4.XLS
CH2M HILL
RSR Corporation Superfund Site
PROJECT NO: 111431.FS.R4
PREPARED BY E.R.MEYER
RSR CORPORATION SUPERFUND SlTt
(Ac
DESCRIPTION
Site Monitoring Cost
SUBTOTAL
CONTINGENCY
TOTAL - Annual O & M Costs - Alternative 4A
l-REMEDIA
curacy Range
QUANTITY
1
30%
r/ONQFOi
>: -»-50% / -3(
UNIT
LS
J4(CONT1NG
D%)
$/UNJT
$0.00
$0
ZNCYALTERi
TOTAL
COST
$0
$0
$0
$0
VATIVE4A)
REFERENCE
Page 4
-------
10/26/95
RSROU4A4.XLS
CH2M HILL
RSR Corporation Superfund Site
PROJECT NO: 111431.FS.R4
PREPARED BY E.R.MEYER
RSR CORPORATION SUPERFUND StTt
(Ac
DESCRIPTION
NET PRESENT VALUE:
YEARO
YEAR1
YEAR 2
YEAR 3
YEAR 4
YEARS
YEAR 6
YEAR?
YEARS
YEAR 9
YEAR 10
YEAR 11
YEAR 12
YEAR 13
YEAR 14
YEAR 15
YEAR 16
YEAR 17
YEAR 18
I
*-REMEDtA
curacy Rang*
QUANTITY
T10NOFO
*: +50% / -3
UNIT
i
YEAR 19 :
YEAR 20
YEAR 21 i
YEAR 22
YEAR 23 !
YEAR 24
YEAR 25
YEAR 26
YEAR 27 !
YEAR 28
YEAR 29 ;
YEAR 30
NET PRESENT VALUE (i=5%) -Alternative 4A
J4(CONT1NG
D%)
$/UNlT
ENCYALTERl
TOTAL
COST
$9,229,883
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$9,229,883
NATIVE 4A)
REFERENCE
PageS
-------
-------
------- |