PB96-964301
EPA/ROD/R07-96/082
August 1996
EPA Superfund
Record of Decision:
Cherokee County Superfund Site,
Cherokee County, KS
7/29/1996
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RECORD OF DECISION
GALENA RESIDENTIAL SOILS, OPERABLE UNIT #07
GALENA SUBSITE
CHEROKEE COUNTY SUPERFUND SITE
CHEROKEE COUNTY, KANSAS
Prepared by:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION VII
KANSAS CITY, KANSAS
JULY 1996
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RECORD OF DECISION
DECLARATION
SITE NAME AND LOCATION
Galena Residential Soils, Operable Unit #07
Galena Subsite, Cherokee County Superfund Site
Cherokee County, Kansas
T?
This decision document presents the selected remedial action
for the mining wastes at Operable Unit #07 of the Galena Subsite,
which is part of the Cherokee County Superfund Site in Cherokee
County, Kansas. This decision was\ chosen in accordance with the
Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA) , as amended by the Superfund Amendments and
Reauthorization Act (SARA) , and, to the extent practicable, the
National Contingency Plan (NCP) . The State of Kansas and the
local community concur with the selected remedy. This decision
is based on the Administrative Record for this Site. The
Administrative Record file is located in the following
information repositories:
Galena Public Library U.S. Environmental Protection Agency
Municipal Building Region VII Docket Room
315 West 7th Street 726 Minnesota Avenue
Galena, Kansas Kansas City, Kansas
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from
this Site, if not addressed by implementing the response action
selected in this Record of Decision (ROD) , may present an
imminent and substantial endangerment to public health, welfare,
or the environment .
DESCRIPTION OF THE SELECTED REMEDY
The U.S. Environmental Protection Agency (EPA) believes the
selected remedy appropriately addresses the principal current and
future risks to human health and the environment. The selected
remedy includes actions for residential soils impacted by mining
wastes and includes the following components:
Excavation and disposal of residential soils impacted
by mining wastes;
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Health education for the general community and medical
professionals;
Institutional controls to guide future development in
residential areas impacted by mining wastes;
Treatability studies to evaluate the effectiveness of
phosphate stabilization as a future alternative; and
Operation and maintenance of all remedy aspects
including, but not limited to, health education,
institutional controls, and long-term monitoring.
The Cherokee County Superfund Site is divided into several
operable units that address different areas, impacted media, and
risks within the six subsites that comprise the Site. This
remedy is specifically tailored to the impacted residential soils
in the Galena area, designated as Operable Unit If 07. Additional
media such as groundwater and surface water, as well as other
types of impacts such as ecological, are or will be addressed by
the other Cherokee County operable'units.
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 (or resource
recovery) technologies to the maximum extent practicable.
However, because treatment of the principal threats of the Site
was not found to be practicable, this remedy does not satisfy the
statutory preference for treatment as a principal element.
Treatment may prove viable in the future pending completion of
phosphate stabilization treatability studies.
Because this remedy will result in hazardous substances
remaining on the Site above health based levels, a review will be
conducted within five years after commencement of the remedial
action to ensure that the remedy continues to provide adequate
protection of human health and the environment.
Dennis Grams, P.E. Date
Regional Administrator
U.S. EPA, Region VII
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RECORD OF DECISION
DECISION SUMMARY
GALENA RESIDENTIAL SOILS, OPERABLE UNIT #07
GALENA SUBSITE
CHEROKEE COUNTY SUPERFUND SITE
CHEROKEE COUNTY, KANSAS
Prepared by:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION VII
KANSAS CITY, KANSAS
JULY 1996
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TABLE OF CONTENTS
SECTION PAGE
1.0 Background 1
2.0 Community Participation 1
3.0 Scope and Role of Operable Units 2
4.0 Summary of Site Risks 3
5.0 Remedial Action Objectives 3
6.0 Description of the Alternatives 4
7.0 Evaluation of the Selected Remedy and Comparison of
Alternatives 5
7.1 Overall Protection of Human Health and the
Environment . 6
7.2 Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs) 6
7.3 Long-Term Effectiveness and Permanence 7
7.4 Reduction in Toxicity, Mobility, or Volume Through
Treatment 7
7.5 Implementability 7
7.6 Short-Term Effectiveness ... 8
7.7 Cost 8
7.8 State/Community Acceptance 9
8.0 Description of the Selected Remedy 9
9.0 Statutory Determinations 14
10.0 Documentation of Significant Changes 16
Figure 1 - Cherokee County Superfund Site
Figure 2 - Galena Residential Soils, OU-7
Table 1 - Applicable Relevant or Appropriate Requirements
Table 2 - Cost Summary
At tachment
Responsiveness Summary
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DECISION SUMMARY
1.0 Background
The Cherokee County Superfund Site is located in the
southeast corner of the State of Kansas and is part of the Tri-
State Mining District. The Tri-State District is an inactive
lead and zinc mining area that encompasses approximately 500
square miles in southeastern Kansas, northeastern Oklahoma, and
southwestern Missouri. The Tri-State District was one of the
most productive lead and zinc mining areas in the United States
and was mined from the late 1800s to the early 1970s. The
District produced more than 500 million tons of mining wastes.
Approximately 100 million tons of wastes remain in the area at
the present time. The primary contaminants of concern that are
present in the mining wastes include lead, zinc, and cadmium.
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The U.S. Environmental Protection Agency (EPA) placed the
Cherokee County Superfund site on the National Priorities List
(NPL) in 1983 pursuant to Section 105 of the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA),
42 U.S.C. §9605. The site encompasses about 115 square miles in
southeastern Kansas, including the towns of Galena, Baxter
Springs, Treece, and Riverton. EPA separated the Cherokee County
Site into six subsites to expedite the field investigations and
remediation of the contaminant sources. The six subsites are
designated as Galena, Baxter Springs, Treece, Badger, Lawton, and
Waco (Figure 1).
The Galena subsite is the largest of the six subsites which
make up the Cherokee County Superfund Site and consists of an
approximate 25 square mile area. This Record of Decision (ROD)
is focussed on Operable Unit #07 (OU-7) of the Galena subsite.
OU-7 encompasses the mining impacted residential areas of Galena
and is depicted on Figure 2.
The Galena subsite has been contaminated with hazardous
substances as a result of the mining, milling, and smelting of
lead and zinc ores. Hazardous substances including lead, zinc,
and cadmium are found in residential soils and mining wastes
within the subsite and more specifically within OU-7.
2.0 Community Participation
EPA provided the Proposed Plan and supporting documents in
the Administrative Record file for public review and comment with
regard to the preferred remedial alternative. In order to
provide the community with an opportunity to submit written or
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oral comments, EPA established a public comment period from May
13, 1996, to June 11, 1996 and conducted a public meeting on May
28, 1996 at the Galena City Hall. At this meeting,
representatives from EPA, the Kansas Department of Health and
Environment (KDHE), the Cherokee County Health Department, and
the Agency for Toxic Substances and Disease Registry (ATSDR)
answered questions about the remedial alternatives under
consideration. Responses to the comments received during the
public comment period are included in the Responsiveness Summary,
which is part of this ROD. The decision for this operable unit
is based on the information contained in the Administrative
Record file which is located in the repositories discussed in the
earlier ROD Declaration section.
3.0 Scope and Role of Operable Units
The six subsites were initially divided into seven operable
units consisting of the following: OU-1, Alternate Water Supply
(Galena Subsite); OU-2, Spring River; OU-3, Baxter Springs; OU-4,
Treece; OU-5, Groundwater/Surface -Water (Galena Subsite); OU-6,
Badger, Lawton, and Waco; and OU-7; Galena Residential Soils
(Galena Subsite). OU-2 and OU-4 have subsequently been
eliminated as they are encompassed by actions at the other
operable units and thus no longer require a separate approach.
With regard to the Galena Subsite, EPA initiated the first
response in 1984 which consisted of a Remedial Investigation and
Feasibility Study (RI/FS). Subsequent remedial actions at the
Galena Subsite were selected in two RODs issued in 1987 and 1989.
The 1987 ROD required installation of a public water supply for
approximately 400 subsite residences and the -1989 ROD required
remediation of the groundwater and surface water as follows:
• Selective placement of surface mine wastes to reduce
human exposure and migration of contaminants into
groundwater and surface streams;
• Surface water diversions to prevent stream capture by
mine shafts and subsidences;
• Surface recontouring to reduce surface water
infiltration and ponding; and
• Inspection of wells penetrating the Roubidoux aquifer,
and plugging or lining of these wells as necessary to
protect the deep aquifer.
EPA implemented the remedial actions for the public water
supply and the groundwater/surface water cleanup using Superfund
monies. The public water supply and groundwater/surface water
cleanups are complete and have been designated as OU-1 and OU-5,
respectively, as discussed above. These operable units were
conducted as EPA lead actions.
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This ROD addresses the final operable unit of the Galena
Subsite (OU-7) and is concerned with soil remedial activities in
residential areas impacted by mining wastes. An RI/FS was
recently completed by Sverdrup Environmental in May 1996 as an
EPA lead action. The Proposed Plan was issued in June 1996 and
Remedial Design/Remedial Action (RD/RA) will begin in the fall of
1996 as an EPA lead effort. EPA will receive funds for a small
portion of the OU-7 work from one responsible party that is
currently in bankruptcy proceedings. At this time, EPA does not
intend to pursue enforcement actions against other potentially
responsible parties (PRPs) for the OU-7 effort.
The two remaining operable units requiring future action at
the Cherokee County Site are OU-3, Baxter Springs/Treece, and OU-
6, Badger, Lawton, and Waco. The RI/FS for OU-3 is complete and
a ROD is forthcoming. OU-6 is at the pre-RI/FS stage. The OU-3
work to date has been conducted by PRPs and it is anticipated
that the remaining activities will also be PRP actions. It is
also anticipated that the OU-6 effort will be PRP lead.
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Although OU-1 and OU-5 are completed as discussed above, EPA
is currently pursuing cost recovery for this work. The PRPs are
an overlapping group that are also involved in portions of the
other Cherokee County operable units as well as the adjacent
Jasper County, Missouri work. As mentioned above, one PRP is
currently in bankruptcy proceedings.
4.0 Summary of Site Risks
Lead is the only demonstrated human health risk at the OU-7
Site. However, cadmium has the potential to create an
unacceptable risk resulting from the ingestion of vegetables.
Vegetables have been demonstrated to readily uptake cadmium and
thus pose a potential health threat. Numerous studies conducted
in the Tri-State Mining District have indicated that several
media are negatively impacted by metals as a result of past
mining, milling, and smelting practices. Residents of Galena,
Kansas have demonstrated blood lead levels that are statistically
significantly elevated above typical background ranges from
control groups established in the local area (Neosho and Goodman,
Missouri). Levels of lead in Galena soils were also
statistically significantly higher than control area soils.
5.0 Remedial Action Objectives
A single Remedial Action Objective (RAO) was developed
during the RI/FS process to address the unacceptable risks
associated with exposure to contaminated residential soils. The
RAO is a goal for remediation that can be addressed through
either reduction of exposures and/or reduction of contaminants.
The RAO developed for OU-7 consists of the following: reduce
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public exposure, and particularly children's exposure, to
residential soils with elevated lead and cadmium resulting from
past mining, milling, and smelting activities.
The RAO was developed from the extensive amount of site
specific information obtained during various phases of work
conducted at the Cherokee County Site as well as the entire Tri-
State Mining District. The OU-7 RI/FS provided site
characterization information detailing the nature and extent of
soil contamination, the transport and exposure pathways of the
contaminants, and the detailed physical properties and nature of
the impacted media and metals contaminants. The Administrative
Record file for OU-7 contains the information upon which this
decision is based.
The RAO is designed to prevent direct human contact with the
wastes and thus eliminates inhalation, ingestion, or dermal
absorption of the site specific contaminants of concern. The
elimination of the direct contact threat will ensure that the
human health risks are reduced or 'eliminated. Specifically, the
RAO is designed to prevent elevated blood lead levels greater
than 10.0 micrograms per deciliter(ug/dl) for more than five
percent of the child population. Currently, approximately 10.5%
of children age 6-71 months have blood lead levels greater than
10 ug/dl as based on a 1995 ATSDR exposure study in Galena.
6.0 Description of the Alternatives
Two alternatives were developed to address the RAO in the
RI/FS process and they were analyzed based on the nine criteria
for remedy selection as specified in the NCP. These two
alternatives consisted of Phosphate Stabilization with
Institutional Controls (designated as Alternative 2 in the RI/FS)
and Excavation and Disposal with Health Education and
Institutional Controls (designated as Alternative 3 in the
RI/FS). The No Action Alternative was designated as Alternative
1.
Alternative 2, Phosphate Stabilization with Institutional
Controls, consists of treating contaminated soils with phosphate
to reduce the bioavailability of lead and cadmium. Phosphate
stabilization binds metals so they are not absorbed into the body
when ingested. Institutional controls would also be established
to regulate construction of new homes in contaminated areas.
Phosphate stabilization requires additional studies to
demonstrate its effectiveness at reducing the bioavailability of
lead and cadmium in Cherokee County soils. Treatability studies
would thus be required before this treatment alternative could be
implemented. These studies would consist of laboratory chemical
tests of actual site soils, bioavailability tests using live
species, and actual field test plots for evaluating the methods
and means of applying the phosphate.
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Alternative 3, Excavation and Disposal with Health Education
and Institutional Controls, consists of the removal of
contaminated soils, placement of excavated soils into dry mine
shafts or depression/mine waste areas located on the Cherokee
County Site, replacement of the contaminated soils with clean
fill soils, and revegetation of the excavated/filled yards. In
addition, a health education program would be established to
inform residents of the hazards associated with contaminated
soils and to monitor the blood lead levels of children.
Institutional
controls would also be established, at the local level, to
regulate the construction of new homes in contaminated areas.
The selected remedy is a combination of the two alternatives
described above. Under the selected approach, excavation and
disposal of contaminated soils will initially begin at the most
impacted residential yards and progress to lesser impacted areas.
Phosphate treatability studies will be conducted concurrently in
order to determine if phosphate treatment is a future viable
option. If phosphate treatment is proposed as a result of the
treatability studies, the public, State, and additional EPA
entities (laboratories, headquarters, work groups etc.) will be
provided with the opportunity to evaluate and comment on the new
approach. If phosphate treatment is deemed appropriate,
excavation/disposal will be discontinued and phosphate
stabilization initiated. However, excavation and disposal will
continue if phosphate stabilization is not demonstrated to be a
viable option as a result of the treatability studies. Health
education and institutional controls are also a remedy component,
to varying degrees, under both options. The selected remedy is
described in detail in Section 8 below.
7.0 Evaluation of the Selected Remedy and Comparison of
Alternatives
The National Contingency Plan (NCP), 40 C.F.R. Section 300
et seq., requires EPA to evaluate selected remedial alternatives
against nine criteria. A selected, or preferred alternative must
satisfy all nine criteria before it can be implemented. The
first step is to ensure that the selected remedy satisfies the
threshold criteria. The two threshold criteria are overall
protection of public health and the environment and compliance
with applicable or relevant and appropriate requirements (ARARs).
In general, alternatives that do not satisfy these two criteria
are rejected and not evaluated further. However, compliance with
ARARs may be "waived" if site-specific circumstances warrant such
a "waiver" as described in Section 300.430(f) (1) (ii) (C) of the
NCP, 40 C.F.R. § 300.430(f) (1) (ii) (C) .
The second step is to compare the selected remedy against a
set of balancing criteria. The NCP establishes five balancing
criteria which include: long-term effectiveness and permanence;
reduction in toxicity, mobility, or volume achieved through
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treatment; implementability; short-term effectiveness; and cost.
The third and final step is to evaluate the selected remedy on
the basis of modifying criteria. The two modifying criteria are
state and community acceptance. The local community and the
State of Kansas have accepted and concurred with the selected
remedy.
7.1 Overall Protection of Human Health and the Environment
This criterion addresses whether a remedy provides adequate
protection and describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment, engineering
controls, or institutional controls.
The selected remedy, a combination of Alternatives 2 and 3,
will provide protection of human health by remediating current
residential yards situated on or near mining, milling, or
smelting wastes if these yards exceed health based action levels.
Residents will also be protected through the implementation of
health education and institutional controls which will
educate/inform the community and health professionals on
preventing/assessing exposures and prohibit building on soils or
mine wastes which exhibit elevated metals concentrations. This
would achieve the RAO by preventing direct human contact with,
ingestion, and/or inhalation of the site specific metals
contaminants and also reduce blood lead levels.
7.2 Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
Section 121(d) of CERCLA, as amended by the Superfund
Amendments and Reauthorization Act (SARA), requires that all
remedial actions comply with ARARs under federal and state
environmental laws. The selected remedy must comply with the
ARARs or justification for a waiver must be provided. ARARs are
classified by the following three categories: chemical-specific;
action-specific; and location-specific. Chemical-specific ARARs
are risk based ambient concentration limits for site specific
contaminants, action-specific ARARs are technology based
restrictions determined by the type of site specific remedial
alternative contemplated, and location-specific ARARs are based
upon the actual site location with respect to the selected
alternative and site contaminants.
The applicable ARARs for the OU-7 selected alternative are
depicted on Table 1. EPA and KDHE have determined that chemical-
specific ARARs are not available, but EPA and state guidance will
be utilized for effectiveness evaluations of the selected
alternative. The selected remedy, which is a combination of
Alternatives 2 and 3, satisfies all applicable ARARs.
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7.3 Long-Term Effectiveness and Permanence
This criterion addresses residual risk and the ability of a
remedy to maintain protection of human health and the environment
over time, after remedial action goals have been completed.
Factors that are considered include both the magnitude of
residual risk remaining after implementation as well as the
adequacy and reliability of controls used to manage treatment
residuals or untreated wastes.
The selected remedy will provide permanent, effective long-
term protection of human health by eliminating human exposure to
the impacted residential soils through excavation and replacement
of the upper one foot of contaminated materials. The
implementation and maintenance of institutional controls (ICs)
and a health education program, in addition to clean soil
backfill at the surface, will provide permanence and long-term
effectiveness for impacted soils that remain in place at depth.
If deemed feasible by ongoing treatability studies, phosphate
stabilization of metals impacted stalls would also be a permanent,
effective long-term solution. Phosphate stabilization would also
include some degree of ongoing ICs and health education, although
at a reduced level from the strictly excavation approach.
7.4 Reduction in Toxicity, Mobility, or Volume Through Treatment
This criterion addresses the degree to which a remedy
employs recycling or treatment to reduce toxicity, mobility, or
volume of the contaminants present at the Site. This also
includes how treatment is used to address the principal threats
posed by the Site.
The initial phase of the selected remedy does not utilize
treatment technologies to reduce toxicity or volume of the
wastes, but will, however, reduce the mobility of contaminants by
capping lower impacted soils with clean backfill material. The
second phase of the remedy, if deemed viable, will utilize
treatment to reduce toxicity and mobility of wastes, but not
volume. The possible second phase consisting of phosphate
stabilization must undergo several initial treatability studies,
and comment by several entities, prior to implementation.
7.5 Implementability
This criterion addresses the technical and administrative
feasibility of the selected remedy, including the availability of
materials and services. The difficulty of undertaking additional
action, if necessary, is also assessed.
The selected remedy is anticipated to be fully
implementable. Excavation and disposal involves standard earth
moving, capping, and construction techniques commonly employed.
ICs and health education are commonly used at Superfund mining
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sites due to the unusually large volume of wastes requiring
cleanup and the large areas contaminated by past mining
practices. EPA will assist in implementation of the ICs and
health education program by providing advice to local
communities, the Cherokee County Health Department, and KDHE.
The phosphate stabilization component of the selected remedy
is not currently implementable. The selected remedy, as a whole,
is fully implementable since phosphate treatment is only an .
option to be exercised in the future if deemed appropriate.
Phosphate treatability studies will be ongoing as the
conventional excavation and backfilling are being implemented.
7.6 Short-Term Effectiveness
This criterion addresses the period of time needed to
achieve the remedial action, and any adverse impacts to human
health and the environment that may be posed during
implementation of the remedy.
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It is anticipated that the proposed remedial action would be
completed in approximately 1.5 to 2.0 years followed by continued
long-term operation and maintenance. Any potential short-term
risk to workers, the communities, and the environment would be
readily preventable.
The selected remedy has minor short-term risks associated
with the respective proposed actions, such as increased exposure
to workers performing the remedial action. However, it is
anticipated that all short-term risks associated with the
alternatives can be reduced through construction controls in
order to prevent harm.
7.7 Cost
This criterion addresses the direct and indirect capital
cost of the proposed remedy. Operation and maintenance costs
incurred over the life of the project, as well as present worth
costs, are also evaluated.
A detailed cost analysis of the selected remedy is provided
in the RI/FS and Proposed Plan which are contained in the
Administrative Record file. The alternative is estimated to cost
approximately $6.15 million. Annual operation and maintenance
(O&M) is estimated to cost $89,500 per year. These costs exclude
the phosphate treatment component.
Costs for phosphate stabilization, as a component of
excavation and disposal, represent a cost reduction and range
from $2.0 million to $4.0 million, depending on the number of
yards excavated prior to the completion of successful
treatability studies. Another factor in the cost range is the
type of phosphate application method determined to be feasible.
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The selected remedy is less expensive than Alternative 3
(excavation) since it allows for the possible implementation of
phosphate stabilization which will reduce the level of ongoing
ICs and health education. Alternative 2 (phosphate treatment) is
less expensive than the selected remedy, however; this treatment
method is currently not implementable. Alternative 1 (no action)
was the least expensive alternative but is not protective. The
selected remedy, a combination of Alternatives 2 and 3, provides
the optimum cost and technology balance. A cost summary is
provided in Table 2.
7.8 State/Community Acceptance
This criteria addresses the state/community preferences or
concerns about the selected remedy. EPA is the lead Agency and
has coordinated all site activities with KDHE and the local
community throughout this project. KDHE has stated that it
concurs with the selected remedy; a copy of the KDHE concurrence
letter is attached. Community acceptance of the selected remedy
was evaluated following a public meeting held at 7:00 pm on May
28, 1996, at the Galena City Hall,'Galena, Kansas. The results
of this evaluation are presented in the attached Responsiveness
Summary.
8.0 Description of the Selected Remedy
The selected remedy is a combination of Alternatives 2 and 3
as discussed above. The components of the selected remedy are
described below.
Excavation/Disposal Component
The selected remedy consists of excavation of residential
yards with soil lead concentrations greater than 800 parts per
million (ppm) or cadmium concentrations greater than 75 ppm in
addition to a health education program and implementation of ICs.
Concentration values greater than 800 ppm lead or 75 ppm cadmium
in yard soils will trigger the excavation activities which will
continue until a cleanup level of 500 ppm lead or 25 ppm cadmium
is achieved or until a maximum excavation depth of one foot is
achieved. Additionally, garden soils exceeding 500 ppm lead or
75 ppm cadmium will be removed to mitigate the risks associated
with the consumption of impacted garden vegetables. Excavations
will be initially conducted in yards with the highest
concentrations above 800 ppm lead and progress to the lower
impacted areas.
Yards will be excavated to a maximum depth of one foot while
gardens will be excavated to a depth of two feet. Raised bed
gardens may also be established depending on home owners wishes.
If yard soils at a depth of one foot exceed 1,500 ppm lead, a
geotextile warning barrier (plastic mesh) will be placed in the
excavation prior to backfilling. Replacement soil meeting a
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criteria of 240 ppm lead and 25 ppm cadmium will be used for yard
and garden backfill material. This criteria is the State of
Missouri any-use soil levels and is also acceptable to the State
of Kansas.
EPA estimates that 500 yards and 60 gardens will require
remedial action. A limited amount of additional sampling will be
conducted as excavations proceed in order to identify additional
yards exceeding 800 ppm lead or 75 ppm cadmium. It should be
noted that all past residential excavations conducted under the
removal program were triggered by elevated soil lead values, in
no instances has cadmium been a trigger constituent for
excavations. The greatest concern with regard to cadmium is the
potential uptake in garden vegetables. The general site area is
fairly well characterized as a result of recently completed
studies. Yards will be seeded or sodded at the completion of
backfilling based on home owner input. The excavated soils will
be placed in dry mine shafts located in various locations within
the Cherokee County Site.
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Health Education Component '
The health education component will be targeted to the local
community and health professionals in order to reduce and treat
exposures that could potentially cause adverse health effects.
The educational components will address the risks associated with
interior paint and dust, consumption of garden vegetables, and
residual levels of lead and cadmium in soils below 800 ppm and 75
ppm, respectively. This program will be coordinated between EPA,
KDHE, ATSDR, and the Cherokee County Health Department. The
health program will include, but is not limited to, the
following: child blood lead screening; professional educational
seminars; community education; and the use of screening
equipment. Education will also deal with concerns related to the
consumption of vegetables from impacted gardens.
Child blood lead screening will serve to monitor and assess
the effectiveness of the cleanup. Children less than seven years
of age are the primary target group for the negative effects of
elevated blood lead values. Blood lead screening conducted
during and after implementation of the remedy, in comparison with
historic pre-remedy values and frequencies, will serve to provide
an evaluation of the effectiveness of the remedy. The ultimate
goal of the remedy is to reduce blood lead levels in children.
This screening will continue during the operation and maintenance
(O&M) period to provide a measure of the continued effectiveness
and long-term permanence of the remedy. Five year reviews will
also provide a comprehensive evaluation of the remedy while O&M
reports will be provided annually.
Professional educational seminars will be held to guide
physicians or medical workers through the diagnosis, treatment,
and surveillance of illnesses in people, especially children,
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exposed to heavy metals. Annual professional education is needed
to maintain an adequate level of awareness among medical
professionals about the local contaminants and to provide updates
regarding new therapies or treatment regimens.
Community education will occur on a variety of levels such
as through local school districts, Lamaze and pre-natal groups,
hospital birthing centers, scouting groups, or other groups.
These organizations will allow the distribution of information on
risks and sources of lead exposure to the local community.
Equipment is needed for the enhancement of environmental
assessment capabilities and to assist in the removal of possible
indoor dust contaminants. A high efficiency particulate vacuum
cleaner (HEPAVAC) will be supplied to the local health department
in order to allow properly trained individuals to reduce the
levels of lead dust in certain residences. The Cherokee County
Health Department will continue to utilize an x-ray fluorescence
(XRF) spectrophotometer to perform indoor assessments of lead in
paint and dust and perform removal of indoor dust contaminants
using the HEPAVAC.
The educational components will address the potential health
effects of consuming garden vegetables grown in contaminated
soils. Residents will be advised against raising vegetables in
contaminated soils and will be encouraged to grow vegetables in
raised bed gardens containing clean soils and to thoroughly wash
all vegetables.
EPA or ATSDR will fund the health education component during
implementation of the remedy and for one year after remedy
completion. The State will assume O&M responsibilities following
the one year period after completion, when the remedy is deemed
operational and functional. O&M components are described below.
Institutional Controls Component
EPA and the State of Kansas will work closely with local
governments to establish ICs to guide future residential
development in lead contaminated areas. The ICs will be
implemented under the authority of local governments and are
required for the excavation/disposal remedy, as well as for a
potential phosphate stabilization approach, in order to prevent
children's exposure to unacceptable levels of lead resulting from
future residential development.
ICs will include, but are not limited to, the following:
zoning restrictions and long-term zoning plans; special building
codes; health ordinances covering construction of residential
homes; and deed restrictions. Residential development ICs may
include, but are not limited to, the following actions prior to
construction: soil sampling; excavation; phosphate treatment;
capping; and obtaining permits. The future construction ICs
11
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would only apply to projects where there is potential to impact
child receptors such as day-care centers, parks, schools, and
residences (homes, apartments, trailers). Industrial and
commercial development is not subject to ICs because exposure to
contaminated soils under these scenarios does not provide an
unacceptable human health risk.
ICs will also apply to the long-term soil disposal areas
which include the following: dry mine shafts; subsidence areas;
and surficial mine waste areas. EPA and the State will also work
with local governments to establish procedures and areas to
dispose of lead contaminated soils excavated from areas of new
residential development. Given the relatively large number of
open shafts in the area, this should not be a major issue.
However, if phosphate stabilization is demonstrated as viable or
capping is utilized, the need for available disposal areas will
lessen or become unnecessary.
Phosphate Stabilization Component
\
Treatability studies will be conducted concurrently as the
excavation and disposal activities progress. Treatability
studies are estimated to require approximately one year to
complete and are necessary in order to determine the viability of
utilizing phosphate treatment as a future alternative to
excavation. If the studies indicate that phosphate stabilization
is viable, the excavation and disposal component will be
discontinued and phosphate treatment will be utilized as the
remedial approach. The public, State, and additional EPA
entities (laboratories, headquarters, work groups etc.) will be
provided with an opportunity to evaluate and comment on the
phosphate treatment approach prior to switching to this remedial
method of cleanup. If phosphate treatment is not deemed
effective, excavation and disposal will continue until all
applicable yards are remediated.
The treatability studies will consist of laboratory bench-
scale studies followed by bioavailability and field tests. If
deemed appropriate, phosphate treatment will utilize 500 ppm lead
as an action level in order to reduce the reliance on ICs and
health education during long-term O&M. The effectiveness of
phosphate stabilization will be evaluated by continuing a blood
lead monitoring program for children under seven years old and by
performing ongoing chemical tests on treated soils. Initially,
the blood lead monitoring will measure the effectiveness of the
remedy and determine if it is operational and functional. Once
the RAO has been achieved, the blood lead monitoring will become
part of the ongoing O&M process and will also be evaluated during
the five year review processes to ensure effectiveness and
permanence of the remedy.
12
-------
Operation and Maintenance Component
The O&M program will address soil disposal areas, health
education, ICs, and monitoring. Specifically, the O&M program
will maintain and assess all soil disposal areas (mine shafts,
subsidence areas, and areas of surficial mine wastes) and will
also ensure and evaluate the implementation of ICs and health
education.
Disposal area maintenance activities may include monitoring
and correction of erosional problems, grading/seeding, and
provision of access. The O&M program will also establish and
maintain new areas for ongoing soil disposal as the local need
arises.
Additional O&M activities include implementation and
evaluation of a monitoring program to ascertain the effectiveness
of the remedy. The monitoring program will assess reductions in
blood lead concentrations of certain children in the areas where
cleanup occurs and will include soil chemistry monitoring if the
phosphate remedy is exercised. The current blood lead screening
program is performed by the Cherokee County Health Department and
is supported by ATSDR. This program may be modified a's necessary
during and after implementation of the remedy. Initial
monitoring will be useful to assist in the determination that the
remedial action objective and the remedial design have been
achieved. Later, the O&M program will use the monitoring data to
assist in determining long-term effectiveness and permanence of
the selected remedy.
The O&M program will ensure the implementation of ICs and
assess effectiveness. ICs will be implemented at the local level
and include such items as deed restrictions, special building
codes, ordinances, and zoning restrictions designed to prevent
future exposure to, and disturbance of, mining wastes and
preserve the integrity of the remedy.
The continuation of the health education program is a
component of O&M and includes such actions as providing
educational materials, seminars, and other such activities. The
education program will continue to reduce residual risks by the
provision of educational materials. The current program may be
modified as necessary during and after implementation of the
remedy.
O&M reports will evaluate and ensure the continued
effectiveness of all remedy aspects. These reports will be
completed annually by the State and provided to EPA. EPA will
perform O&M tasks during implementation of the selected remedy
and for one year after remedy completion. The State will assume
O&M responsibilities after the one year period from completion,
13
-------
when the remedy is anticipated to be deemed operational and
functional. Specific O&M components may be modified in order to
achieve the intent in the most effective and efficient manner.
Five-Year Review Component
A five-year review is required at sites where contamination
remains above health based criteria. The review will be
conducted in accordance with applicable guidance and Section 121®
of CERCLA, 42 U.S.C. §9621(c), as amended. The five-year review
of the selected remedy will be conducted to ensure that the
remedy is effective and accomplishes the goals of the remedial
action and will include a review of ICs, health education,
disposal areas, and all analytical data.
Cost Component
As discussed above, a detailed cost analysis of this remedy
is provided in the RI/FS and Proposed Plan. The selected remedy
is estimated to cost approximately $6.15 million (capital cost)
with an annual O&M cost of $89,500; assuming that phosphate
treatment is not utilized. The cost ranges from $2.0 million to
$4.0 million if phosphate treatment becomes a viable remedial
option.
9.0 Statutory Determinations
Under its legal authority, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, Section 121 of CERCLA establishes several other
statutory requirements and preferences. These specify that when
complete, the selected remedial action for the Site must comply
with applicable or relevant and appropriate environmental
standards established under federal and state environmental laws,
unless a statutory waiver is justified. The selected remedy also
must be cost effective and utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Finally, the
statute includes a preference for remedies that employ treatment
that permanently and significantly reduces the volume, toxicity,
or mobility of hazardous wastes as their principal element. The
following discusses how the selected remedy meets these statutory
requirements.
Protection of Human Health and the Environment
The selected remedy will protect human health and the
environment by achieving the RAO through a combination of
engineering measures, health education, and ICs. Existing human
health risks due to potential lead and cadmium exposure from
soils and mine wastes will be reduced by remediating residential
yards/gardens situated on or near mine wastes. Future risks to
14
-------
human health will be reduced by implementation of institutional
controls that will control residential construction on soils or
mine wastes with contaminant levels in excess of health based
levels. Health education will also reduce future human health
risks.
Attainment of Applicable or Relevent and Appropriate
Requirements of Environmental Laws (ARARs)
The selected remedy complies with the applicable or relevant
and appropriate chemical-, action-, and location-specific ARARs.
The remedy specific ARARs are described in Table 1 and
categorized as either applicable, relevant, or appropriate.
Compliance with ARARs is required of the selected remedy unless a
waiver of an ARAR is justified. No waiver is required for the
selected remedy.
Chemical-specific ARARs are associated with the site
specific contaminants of concern, which are lead and cadmium.
There are no federal or state applicable relevant or appropriate
requirements that pertain to these1contaminants in soil. EPA has
identified guidance and other criteria to be considered during
implementation of the remedy as identified on Table 1.
Location-specific ARARs are based on the location of the
Site and the effect of hazardous substances on the environment.
The selected remedy will attain location-specific ARARs for
endangered species, archeological areas, and historic
preservation as identified on Table 1.
Action-specific ARARs are based on activities and
technologies to be implemented at the Site. The selected remedy
will attain the action-specific ARARs identified on Table 1.
Cost Effectiveness
The selected remedy is cost effective because it will
provide overall effectiveness proportional to its costs. The
selected remedy is the least expensive remedy that is protective
of human health and the environment and complies with ARARs.
Although Alternatives 1 and 2 are less costly than the selected
remedy, the No Action Alternative (Alternative 1) is not
protective and the treatment component of Phosphate Stabilization
with ICs (Alternative 2) is not currently implementable.
Alternative 3, Excavation and Disposal with Health Education and
ICs, is the most expensive alternative since it does not include
a provision for phosphate treatment and relies more heavily on
long-term health education and ICs. The selected remedy provides
the greatest cost effectiveness and protectiveness.
15
-------
Utilization of Permanent Solutions and Alternative
Treatment Technology (or Resource Recovery Technologies)
to the Maximum Extent Practicable
The selected remedy represents the maximum extent to which
permanent solutions and treatment technologies can be utilized in
a cost effective manner for this remedial action. The
remediation of residential yards on or near mine wastes with
contamination above health-based levels will permanently
eliminate risk to children who live in such residences. The
evaluation, and possible subsequent use, of phosphate
stabilization represents the use of an alternative treatment
technology to the maximum extent practicable.
Preference for Treatment as a Principal Element
The selected remedy effectively reduces risks through a
combination of engineering measures, institutional controls, and
health education and thus does not initially satisfy the
statutory preference for treatment1 as a principal element.
However, treatment may become an option depending on the results
of ongoing phosphate stabilization treatability studies.
10.0 Documentation of Significant Changes
There are no significant changes from the proposed plan in
this ROD.
16
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CHEROKEE COUNTY
SITE BOUNDARY
KANSAS
OKLAHOMA
SUBSITE LEGEND:
V WACO AREA
2. LAWTONAREA
3. BADGER AREA
' GALENA SUBSITE
5. BAXTER SPRINGS AREA
5. TREECEAHEA
FIGURE 1
SITE LOCATION
CHEROKEE CO.. KANSAS
GALENA SUBSITE
-------
?rft'% °f i*
•;! *T\— • \
» i -—n oo
" : '«/
-------
TABLE 1
FEDERAL CHEMICAL SPECIFIC ARARS
Page 1 of 10
A. Applicable
Requirements
B. Relevant and
Appropriate
C. To Be
Considered
1. Agency for
Toxic Substances and
Disease Registry
(ATSDR) 1996
Health Study
2. EPA Revised
Interim Soil Lead
Guidance for
- CERCLA Sites and
RCRA Corrective
Action Facilities
Citations
RCRA
None
"Lead and
Cadmium Exposure
Study, Galena,
Kansas", January
1996
Office of Solid
Waste and
Emergency
Response (OSWER)
Directive 9355.4- 12,
July 14, 1994
-
Prerequisite
Solid Waste
Regulations
Bivel Amendments
Evaluates the health
of young children
due to current site
exposures.
Establishes screening
levels for lead in soil
for residential land
use, describes
development of site-
specific preliminary
remediation goals,
and describes a plan
for soil-lead cleanup
at CERCLA sites
Requirement
LDR
TCLP
Recommends
environmental
exposures in the
site area be
reduced. This
includes reductions
in soil, dust and
paint.
This guidance
recommends using
the EPA Integrated
Exposure Uptake
Biokinetic Model
(IEUBK) on a site-
sp^ific basis to
assist in developing
cleanup goals.
-------
TABLE 1
FEDERAL CHEMICAL SPECIFIC ARARS
Page 2 of 10
3. EPA Strategy
for Reducing Lead
Exposures
4. Soil-Lead
Contamination
Health Consultation
5. Cherokee County
Health Screenings
and Evaluations
Citations
EPA, February 21,
1991
\
Agency for Toxic
Substances and
Disease Registry
(ATSDR), prepared
by Denise Jordan-
Izaguirre, April 8,
1995
Ongoing health
screenings which
include blood tests
and comprehensive
in home evaluations
by the local
Cherokee County
Health Department.
Prerequisite
Presents a strategy to
reduce lead exposure,
particularly to young
children.
Removal of
contaminated soils.
Evaluates health of
young children due to
current site
exposures. Evaluates
living conditions and
other risk factors for
increased lead
exposure.
Requirement
The strategy was
developed to
reduce lead
exposure to the
greatest extent
posssible. Goals of
the strategy are to
1) significantly
reduce the
incidence above 10
ug Pb/dl blood in
children; and 2)
reduce the amount
of lead introduced
into the
environment.
Lead in soil
appears to be
responsible for
blood-lead levels in
children increasing
above background.
Recommends
exposure to lead in
soil be reduced.
Recommends
exposure to lead
contaminated soil
and other risk
factors be reduced.
Emphasizes the
need for lead
education.
-------
TABLE 1
STATE CHEMCIAL SPECIFIC ARARS
Page 3 of 10
A. Applicable
Requirements
B. Relevant And
Appropriate
C To Be
Considered
I.Kansas Interim
Remedial
Guidelines for Soil
Citation
None
None
None
KDHE, Bureau of
Environmental
Remediation, Draft
Version dated
November 1994
Prerequisite
Establishes Interim
Remedial Guidelines
for soil to help
Remedial Project
Manager make
scientific and health
based remedial
decisions in absence
of other health risk
data or models
Requirement
This guidance
recommends using
400 mg/kg for lead in
residential areas and
1000 mg/kg for lead
in industrial areas.
-------
TABLE 1
FEDERAL LOCATION SPECIFIC ARARS
Page 4 of 10
A. Applicable
Requirements
1. Historic project
owned or controlled '
by a Federal Agency
2. Site within an area
where action may
cause irreparable
harm, loss, or
destruction of
artifacts.
3. Site located in
area of critical habitat
upon which
endangered or
threatened species
depend.
B. Relevant and
Appropriate
Requirement
C. To Be Considered
Citation
National Historic
Preservation Act: 16
U.S.C. 470, et.seq;
40 CFR §6.301, 36
CFR Part 800.
Archeological and
Historic Preservation
Act; 16 U.S.C. 469?
40 CFR 6.301.
Endangered Species
Act of 1973, 16
U.S.C. 1531-1543;
50 CFR Parts 17,
401, 40 CFR 6.302.
Federal Migratory
Bird Act; 16 U.S.C.
703-712.
None
None
Prerequisite
Property within areas
of the site is included
in or eligible for the
Naitonal Register of
Historic Places.
Property within areas
of the site contains
historical and
archaeological data.
Determiniation of the
presence of
endangered or
threatened species.
Requirement
The remedial
alternatives will be
designed to minimize
the effect on historic
landmarks.
The remedial
alternative will be
designed to minimize
the effect on
historical and
archaeological data.
The remedial
alternatives will be
designed to conserve
endangered or
thereatened species
and their habitat,
including
consultation with the
Department of
Interior if such areas
are affected.
-------
TABLE 1
STATE LOCATION SPECIFIC ARARS
Page 5 of 10
A. Applicable
Requirements
1 . State Endangered
Species or
Threatened Species
2. Kansas Historic
Preservation Act
B. Relevant and
Appropriate
Requirement
C. To Be Considered
Citation
Kansas Wildlife and
Parks
KSA 75-271 5-2725 •
None
None
Prerequisite
Determination of the
presence of
endangered or
threatened species.
Provides for
protection and
preservation of sites
and buildings listed
on the State and
Federal Historic
Registries.
Requirement
Remedial alternatives
will be designed to
conserve Kansas
endangered or
threatened species
and their habitat.
Remedial alternatives
will be designed to
minimize effect on
historic landmarks.
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TABLE 1 Page 6 of 10
CONTROLS FOR CONTAMINATED RESIDENTIAL SOILS
Control or Technology
Institutional Controls
Excavation & Disposal
Capping
Chemical Stabilization
Description
Public-health education and
access restrictions.
Physical removal and
disposal of impacted soils.
Creates a barrier for humans
and most weathering
elements.
Surficial chemical treatment
of soils to fixate lead to
reduce its bioavailability via
metallic complexing.
Screening Comment
Least expensive alternative,
excluding no action.
Waste is physically removed.
Waste remains but a barrier is
added.
Waste remains but
bioavailability is eliminated.
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TABLE 1 Page 7 of 10
FEDERAL ACTION SPECIFIC ARARs
Citation
Prerequisite
Requirement
A. Applicable
Requirements
1. Disposal of Solid Waste in mine
subsidences and voids.
Subtitle D of RCRA, Section 1008,
Section 400l.etseq.. 42 U.S.C. §6941,
et seq.
State or Regional Solid Waste Plans and
implementing federal and state
regulations to control disposal of solid
waste. The yard soils disposed in the
repository may not exhibit the toxicity
characteristic and therefore, are not
hazardous waste. However, these soils
are solid waste.
Contaminated residential soils will be
consolidated from yards throughout the
site. The disposal of this waste material
should be in accordance with regulated
solid waste management practices.
2. Disposal of Hazardous Waste in the
mine subsidences and voids.
Subtitle C of RCRA, Section 3001 et
seq.. 42 U.S.C. §6921, et seq.. and
implementing regulations at 40 C.F.R.
§261.4
RCRA provides an exclusion from
regulation as a hazardous waste the
mining waste generated from the
extraction, beneficiation and processing
of ores and minerals evenjf such wastes
may be characteristic hazardous wastes.
Such mining wastes may be excavated
from residential yards. If so, it is
excluded from regulation as a hazardous
waste under RCRA Subtitle C.
Residential yard soils may be
consolidated in the mining shafts and
subsidences as solid wastes if they are
mining wastes, such as chat. The area of
consolidation is not a RCRA regulated
hii/iirdous waste management unit.
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TABLE 1 Page 8 of 10
FEDERAL ACTION SPECIFIC ARARs
3. Disposal of Hazardous Waste in mine
subsidences and voids and Designation
as a Corrective Action Management Unit
(CAMU).
B. Relevant and Appropriate
Requirements
1 . NPDES Storm Water Discharge for
Permanent Repository.
2. Transportation of excavated soils.
C. To Be Considered
Citation
Subtitle C of RCRA, Section 3001 et
seq.. 42 U.S.C. JJ6921. et seq.. and
implementing regulations at 40 C.F.R.
Subpart S, Correction action for solid
waste management units and temporary
units, 40 C.F.R. §264.522
-
40 C.F.R. Part 122, § 122.26
DOT Hazardous Material Transportation
Regulation, 49 C.F.R. Parts 107. 171-
177
None
Prerequisite
RCRA defines Corrective Action
Management Units (CAMUs) to be
used in connection with implementing
remedial measures for corrective action
under RCRA or at Superfund sites.
Generally, a CAMU is used for
consolidation or placement of
remediation wastes within the
contaminated areas at the facility.
Placement of wastes in a CAMU does
not constitute land disposal of
hazardous waste and does not constitute
creation of a unit subject to minimum
technology requirements.
^
Establishes permitting process and
discharge regulations for storm water.
Regulates transportation of hazardous
wastes.
Requirement
The RCRA requirements of Subtitle C are
not applicable to the disposal of
residential yard soils. Residential yard
soils contaminated from smelter fall out
are not excluded from regulation under
the RCRA exclusion for extraction,
beneficiation and mineral processing.
Therefore, yard soils exhibiting a RCRA
toxicity characteristic would be regulated
under Subtitle C of RCRA. However,
because of the CAMU regulation, these
residential soils are remediation wastes
and may be disposed of without triggering
RCRA disposal requirements. The
remedial action will comply with the
requirements of the CAMU rule.
Required management of the disposal
areas where waste materials come into
contact with storm water.
Relevant and appropriate for the
excavation alternative which would
transport wastes on-site. However, off-
site disposal regulations would not apply.
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TABLE 1
STATE ACTION SPECIFIC ARARs
Page 9 of 10
A. Applicable Requirements
I. Ambient Air conservation Law, and
Restrictions of Participate Matter to the
Ambient Air Beyond the Premises of
Origin.
2. Kansas Solid Waste Management
U. Relevant and Appropriate
Requirements.
1 . Kansas Clean Water Law,
NPDES Storm Water Discharge for
Permanent Repository.
Citation
K. A. R. 28.19
K.A.R. 28.29, Part II
Kansas Water Pollution Control
Regulations, K.A.R. 28.16
Prerequisite
Requires that reasonable measures be
used to prevent particulate emissions
from leaving the premises. Also, sets
ambient air quality standards for a
number of air constituents.
State Solid Waste plans to control
disposal of solid waste.
Regulates the discharge of constituents
from any point source, including storm
water, to surface waters of the state.
Provides for maintenance and protection
of public health and aquatic life uses of
surface water and groundwater.
Requirement
Recommend that excavation of yard soils
or tilling of yards in treatment alternative
be handled in such a manner as to
control fugitive emission, such as use of
a water spray during excavation, tilling
or transportation. May be used in
monitoring ambient air quality during
implementation for lead and other
particulates.
Contaminated residential soils would be
consolidated from yards throughout the
Galena area. The disposal of this waste
material into on-site mining voids should
be in accordance with solid waste
management practices.
Required management of disposal areas
where waste materials come into contact
with storm water.
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TABLE 1
STATE ACTION SPECIFIC ARARS
Page 10 of 10
Citation
Prerequisite
Requirement
C. To Be Considered
Kansas Storm-water Regulations
Establishes permitting process and
discharge regulation for storm water. A
state permit would not be required
because the repository would be
conducted off-site, however, substantive
requirements of the storm-water controls
would be required.
Remedial actions would use "Best
Management Practices" for land
disturbance including practices of
procedures that reduce the amount of soil
available for transport in accordance
with this Kansas regulation.
2. Siting of the subsidences and voids for
disposal, Kansas Hazardous Waste
Management regulations K.A.R. 28.31.
RCRA Hazardous Waste Program as
implemented by the State of Kansas
through its Hazardous Waste Program:
40 C.F.R. Section 264.14
40 C.F.R. Section 264.15
40 C.F.R. Section 264.18 (a) and (b);
10C.S.R. 25.7-264(l)(N)l.A.
40 C.F.R. Section 264.37
40 C.F.R. Section 264.55, 264.56;
10C.S.R. 25-7.264 (2)(D)
40C.F.R. Section 264.Ill
40 C.F.R. Section 264. II6;
10C.S.R. 25-7.264(2)(G)3
40 C.F.R. Section 264.118
40 C.F.R. Section 264.310
Security
General Inspection Requirements
Locations Standards
Arrangements with Local Authorities
Contingency Plan
Closure Performance Standard
Survey Plant/Deed Notice
Post-closure Plan
Closure and Post-closure Care
The RCRA regulation of remediation
wastes will be in accordance with the
CAMU rule as discussed above under
Federal Action-Specific ARARs. The
inclusion of the State of Kansas
Hazardous Waste Program regulations
will be considered during the remedial
design of the disposal areas consisting of
on-site mine subsidences and voids.
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TABLE 2
COST SUMMARY FOR EXCAVATION AND DISPOSAL
WITH HEALTH EDUCATION AND INSTITUTIONAL CONTROLS
Page 1 of 3
WORK ITEM
RESIDENTIAL YARD EXCAVATION
1. Mobilization
2. Property Access. Contaminant Assessment
3. Material Movement
(excavation, transport, backfill)
4. Post Cleanup Reports
Subtotal
MINE SHAFTS
1. Design(site I.D./access agreements)
2. Material Placement
3. Vegetative Cover/Shaft Erosion Controls
Subtotal
CONTINGENCIES (= 10% of subtotals)
TOTAL COSTS
OPERATION AND MAINTENANCE
1. O&M of Filled Mine Shafts
2. Health Education Activities, excludes first year
purchase of HEPAVAC (see Table 2)
3. Monitoring of Institutional Controls
TOTAL ANNUAL O&M
ESTIMATED
QUANTITY
500
500
500
^
83,000 cy
5 acres
ASSUMED TOTAL ES'
UNIT COST FOR
PRICE
$30,000 $30,000
$500 $250,000
$10,000 $5,000,000
$400 $200,000
$5.480,000
$5,000 $5,000
$1.20 $99,600
$2,000/acre $10,000
$114,600
$559,460
$6,154.060
$1,000
$78,500
$10,000
$89,500
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TABLE 2 Page 2 of 3
HEALTH EDUCATION FOR CHEROKEE COUNTY
WORK ITEM ESTIMATED COST
Initial Purchase of Equipment (HEPAVAC) $ 1.000
Annual maintenance of equipment (exist. XRF & new hepa.) $2,500
Educational material $7,000
Personnel and facility for blood lead screening (1 nurse & .5 tech) $65,000
Professional education $4,000
ANNUAL HEALTH EDUCATION COSTS $78,500
TOTAL FOR FIRST YEAR (includes initial equip, purchase) $79.500
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TABLE 2
COST ANALYSIS FOR PHOSPHATE STABILIZATION
ESTIMATED
QUANTITY
WORK ITEM
I. Mobilization/Demobilization
2. Treatability Studies
3. Residential Yard Sampling
4. Remedial Design
5. Phosphate Stabilization
(includes lawn restoration)
Subtotal
Contingencies (20% of subtotal)
TOTAL PHOSPHATE
STABILIZATION
ANNUAL OPERATION AND
MAINTENANCE
1. Soil Chemistry Monitoring 5 samples
2. Blood-Lead Monitoring (yrs. 1-5
only), also reduced health ed.
ASSUMED UNIT
PRICE
I $5.000
1 5200,000
100 residential yards S200
1 $50,000
700 residential yards $500 to $4,000
$1,000
$50,000
Page 3 of3
TOTAL EST. COST
S5.000
$200.000
$20,000
$50,000
$350,000 to
$2,800,000
$625,000 to
$3,075,000
$125,000 to
$615,000
$750,000 to
$3,690,000
$5,000
$40,000
TOTAL O&M
$45,000
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RESPONSIVENESS SUMMARY FOR THE RECORD OF DECISION
GALENA RESIDENTIAL SOILS, OU-7
CHEROKEE COUNTY, KANSAS
This responsiveness summary addresses comments received during the public meeting
conducted on May 28, 1996. No written comments were received during the public comment
period, May 13 - June 11, 1996. This portion of the ROD will provide a summary of the
commentors' major concerns followed by responses to those concerns. The questions,
comments, and responses are summarized below.
Question: Several citizens asked why the soil lead contamination is erratic. Why are some
yards contaminated above the cleanup level while adjacent properties may be below levels of
concern. Why are some yards cleaned up while adjacent yards are not addressed.
Response: There are a number of reasons why the lead contamination is erratically dispersed to
some degree. As a whole, the distribution is not erratic given the fact that the highest
concentrations in soil are located closest to the former smelter and in the downwind location.
With increasing distance from the smelter, the soil concentrations generally decrease, with some
exceptions, and they also are lower in the upwind direction as compared to the downwind
direction. While the complete distribution is somewhat predictable, there are areas where erratic
levels occur.
The erratic levels are a result of several factors which include the following: varying
wind conditions; importation of mine wastes and fill materials; moving or reworking native soils;
and locations of naturally occurring ore bearing bedrock units. These factors are discussed
below.
* Varying wind conditions are responsible for the deposition of air borne contaminants
into different locations over time. While the general location of wind deposited materials is
predictable, differences in wind conditions (direction and velocity over time) can vary, and
during these varible periods, materials are deposited in locations that would not be predicted
when evaluating the entire area. Another factor in this scenario is the variability of the smelting
process. Different grades and types of ore will produce varying emisssions with varying lead
content. Emissions are even varible over time as equipment is upgraded and modified. The
variability of wind processes in combination with varible smelter effluent concentrations
represent one reason for the somewhat erratic soil lead values.
* Importation of mine wastes and fill materials represent processes that introduce
variability into the natural system. As outside materials are brought into an area for a variety of
reasons (construction, landscaping, utility backfill), natural lead impacted soils are moved and
disturbed. When soils are moved, re-distributed, and combined with outside materials, the
concentration of lead is also modified. The surficial lead content may decrease if fill soils are
from clean areas and are mixed with native impacted soils or used as cover or grade material over
impacted areas. In other instances, native soils could be contaminated to a greater degree if
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outside soils contain mining wastes or have higher concentrations of lead than native soils and
are brought into an area. These factors contribute to soil lead concentration variability.
* Moving and reworking native soils without importing any outside material also is a
factor that contributes to lead concentration variability. Native soils are reworked for a variety of
reasons (construction, landscaping, drainage), and this re-distribution of native materials will
cause variability in lead content.
* Ore and mineral deposits are contained within bedrock units in a somewhat random
manner. While ore bodies and deposits are mappable, they are typically randomly oriented in a
spatial manner due to the natural processes that formed the minerals. Mineral bearing rocks may
be present at or near the surface in random fashion which serves to yield varying measurements
of lead from residential areas, especially in situations where a thin soil veneer is present. This is
yet another contributing factor to the heterogeneous distribution of lead, to some degree, in the
residential areas of Galena.
Question: Several citizens wanted to know if their .yards were targeted for cleanup, and if so,
when would their yards be addressed.
Answer: A soil cleanup trigger level of 800 parts per million (ppm) lead has been selected in
addition to a level of 75 ppm cadmium. In all instances to date, lead has been the primary driver
for initiating cleanup action. Yard concentration values greater than 800 ppm lead or 75 ppm
cadmium will trigger excavation activities that will continue until a cleanup level of 500 ppm
lead and 25 ppm cadmium is achieved or until a maximum excavation depth of one foot is
achieved. Additionally, garden soils exceeding 500 ppm lead and 75 ppm cadmium will be
removed to the same cleanup levels or until an excavation depth of two feet has been achieved.
Raised bed gardens may also be established depending upon home owners wishes.
The yards will be completed on a priority basis with the highest lead impacted yards
being completed initially, followed by systematically cleaning up ever lower concentration areas.
The work will be grouped in general areas of the highest levels in order to efficiently perform the
excavations and therefore, in some instances, lower concentration yards grouped in a high
concentration area, will be cleaned up first in order to more efficiently perform the work. The
work will thus not strictly be performed on a numerical basis but will also consider groupings of
high concentration yards. These groups may also contain lower level properties that will also be
addressed at the same time rather than returning to the same area at a later point in time.
Question: One citizen asked if the soil would be re-tested during excavation activitites.
Answer: The soil will be tested in several areas of the yards as excavations proceed. This is
necessary to determine the depth and area of excavations and to also determine the need to place
a geotextile warning barrier in the excavation prior to backfilling. The warning barrier will be
placed if soil lead levels are greater than 1,500 ppm after one foot of soil has been excavated.
The barrier is designed to be a warning during any future digging or excavation activities.
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Question: Some citizens asked about having their yards initially tested in the future.
Answer: We are compiling a list of people who would like to have their yards tested in the
future. EPA will evaluate the list in the fall when we are back in the area to perform additional
work. In some instances, it will not be necessary to test certain people who request testing since
they may be in an area that has been sufficiently characterized and determined to be an area with
lead levels below the cleanup criteria. In other instances, testing may be warranted and the
residents will be contacted by EPA to arrange for such testing. All individuals on the list will
receive a response. Additonally, when we are back working in Galena we will have a field office
with a telephone number for people to call. Citizens may also phone our Office of External
Programs, attention Hattie Thomas, at 1-800-223-0425 or 1-913-551-7003.
Question: Several questions regarding phosphate treatment were asked. The questions can be
summarized to include the following: does the treatment consist of pure phosphate; how does
the phosphate work or bind the lead; how will the phosphate be applied; and when will the
phosphate treatment begin.
Answer: Phosphate treatability studies are necessary in order to determine if this type of
treatment will work in Galena. The studies will be completed concurrently as excavations
proceed. The public, State of Kansas, and other EPA offices, laboratories, and personnel will be
provided with an opportunity to comment on the results of the phosphate treatability studies prior
to switching to this method if it is deemed viable. The following paragaraphs contain responses
to the various questions regarding phosphate treatment.
* The treatment does not consist of pure phosphate and it is not recommended that home
owners attempt to purchase and spread phosphate independently. The phosphate mixture
consists of additional compounds that may require special formulation based on site-specifc
chemistry of the local soils.
* In the laboratory, the phosphate compound chemically binds with the lead and
cadmium thus making these metals non-bioavailable. The metals are still present but may not be
uptaken by the body. Lead and cadmium that are not chemically treated are readily absorbed into
the body or bloodstream and are bioavailable. Phosphate stabilization will not physically remove
the lead and cadmium, as in an excavation scenario, but if the bioavailability studies prove
successful, the toxic metals will be changed to a non-toxic form which is relatively harmless.
* The optimum method of phosphate application is yet to be determined. Once the early
treatability studies successfully indicate that phosphate treatment of the site specific soils is a
viable option, application studies will begin. There are several potential methods of application
which include the following: dry granular spreading; wet mixture spraying; and wet or dry
methods applied after tilling or aerating the soil. The treatability studies will determine the
optimum method of phospate application and will include the varied placement of phosphate on
test plots in the Galena area.
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* The earliest point that the phosphate treatment method could potentially be
implemented is during the summer of 1997. There are several types of treatability tests that must
be completed, in addition to public, State, and additional EPA input, prior to the implementation
of a phosphate stabilization remedy. The possibility also exists that phosphate treatment may not
be demonstrated to be a viable option at the Galena site and excavations would simply continue.
Question: A citizen asked if the soils in the Operable Unit #05 (OU-5) area were going to be re-
tested in the future. An inquiry was also made regarding any prohibitions on residential
development in the OU-5 area.
Answer: Although this ROD addresses the actions for the impacted residential soils in Galena,
designated as Operable Unit # 07 (OU-7), an answer is provided since the entire site is
interrelated. EPA has no plans to perform additional sampling in the OU-5 area. Limited
additional sampling, primarily surface water and sediment, will be performed by the State of
Kansas as part of the Operation and Maintenance (O&M) activities for this operable unit.
The OU-5 area was cleaned up prior to the OU-7 work which was the focus of the recent
public meeting and this ROD. The OU-5 area was not cleaned up to the same action level as the
current OU-7 work. Most of the OU-5 area is rural/undeveloped and consists of outlying areas
around town. Institutional Controls are the primary method of dealing with future residential
development at the OU-5 area. Institutional Controls are implemented at the local level and
consist of items such as building codes, zoning restrictions, and building ordinances.
Question: A citizen made a statement that snakes were becoming a major problem in the local
area and questioned if the apparent increase in the snake population could be attributed to past
remedial actions.
Answer: The citizen was referring to past work conducted at OU-5 which consisted of several
hundred undeveloped acres. It is possible that the actions in OU-5 are related to the apparent
increase in the snake population, however; there is no conclusive evidence to indicate that the
snake population is truly increased or if the past actions would be related to such an increase.
There is currently not enough information to answer the question or to confirm that a problem
exists.
Question: A citizen asked if the yards that were cleaned up would be re-tested and if any follow
up blood testing of children would be performed.
Answer: The yards will not be re-tested after being excavated and backfilled. The excavation is
permanent and the backfill soils will be tested prior to use to ensure that they meet the criteria of
240 ppm lead and 25 ppm cadmium. If phosphate stabilization is used as a future remedy, some
yards will be re-tested to evaluate the long-term permanence aspects of the phosphate treatment
method. Long-term blood testing will continue under both an excavation/backfill or phosphate
stabilization remedial approach. Blood testing will be included in the health education
component of the long-term operation and maintenance period. Blood tests and in-home
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assessments are currently being performed by the Cherokee County Health Department. More
information may be obtained by contacting Deloris Mulnix at 316-429-3087.
Question: A citizen asked if EPA was going to advertise in the paper prior to initiating activities
in the fall so people would be aware of impending work and have a contact and phone number if
they wanted to inquire about their yards or request testing. The citizen also suggested that both
the Galena and Joplin newspapers be utilized since most people read one or the other.
Answer: EPA will establish a local field office when the work begins in the fall of 1996 as was
the case for the past work performed. There will be a local phone number and an EPA
representative in Galena as the work progresses. EPA will either advertise the initiation of the
field activities in both the Galena and Joplin newspapers (Galena Sentinel-Times and Joplin
Globe) or present this information at a Galena City Council Meeting which will also be
advertised in both newspapers.
Question: A citizen asked if vacant lots were going to be tested.
Answer: EPA currently has no plans to test or remediate vacant lots. The question of future
building of residential dwellings falls under the institutional controls aspect of the remedy. Local
institutional controls should be established in order to regulate construction in residential areas.
It is anticipated that these controls would provide or require some type of testing prior to
construction and may also include zoning restrictions or ordinances that would regulate or
restrict home construction in certain areas.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VII
726 MINNESOTA AVENUE
KANSAS CITY, KANSAS 66101
JUL 2 9 J996
MEMORANDUM
SUBJECT: Concurrence on Attached Record of Decision for the
Cherokee County Superfund Site
Cherokee County, KS
FROM: Michael J. Sanderson, D,
Superfund Division
TO: Dennis Grams, P.E.
Regional Administrator
\
Please review the attached Record of Decision (ROD) for the
cleanup of lead contaminated residential yard soils resulting
from mining and smelting activities in Cherokee County, Kansas
and provide your concurrence signature on the ROD. The Kansas
Department of Health and Environment has been involved in the
drafting of this document and has indicated its support for this
ROD.
If you have any questions regarding the ROD, please contact
me or Dave Drake, the project manager for this site, at extension
7626.
Attachment
RECYCLED
PAPER CONTAWS RECYCLED FIBERS
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