PB96-964421
EPA/ROD/R08-96/131
November 1997
EPA Superfund
Record of Decision:
Petrochem/Recycling Corporation/Ekotek Plant
Salt Lake City, UT
9/27/1996
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VIM
999 18th STREET - SUITE 500
DENVER, COLORADO 80202-2466
I lillll I:
331874
BTAR
n•rcfr-KCisioN PUBLIC DOCUMENT
D FOIA EXEMPT/CLAIM
D WORK PERFORMED DOCUMENT
CONTRACTS —
D FILE PLAN * '
D KEYWORD
Petrochem/Ekotek Inc. Superfund Site
Record of Decision
September 1996
Printed on Recycled Paper
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TABLE OF CONTENTS
List of Acronyms ii-1
The glossary of Terms iii-1
Tables iv-1
Figures v-1
1.0 Declaration for the Record of Decision ..1-1
1.1 Site Name and Location 1-1
1.2 Statement of Basis and Purpose 1-1
1.3 Assessment of Site 1-1
1.4 Description of the Selected Remedy .1-1
1.5 Statutory Determinations 1-3
2.0 Site Summary 2-1
2.1 Site Name, Location, and Description
2-1
2.2 Current and Past Use of the Site
and Adjacent Land Use 2-1
2.3 Natural Resources 2-2
2.4 General Surface Water and Ground Water
Resources 2-3
3.0 Site History and Enforcement Activities..3-1
3.1 Operational History 3-1
3.2 History of Site Investigations 3-1
3.3 History of CERCLA Enforcement 3-2
3.4 History of RCRA Enforcement 3-4
4.0 Highlights of Community Participation....4-1
4.1 Community Relations Plan 4-1
4.2 Technical Assistance Grant 4-1
4 . 3 Outreach Program 4-1
4.4 Information Repositories 4-2
5.0 Scope and Role of Operable Units 5-1
6.0 Summary of Site Characteristics 6-1
6.1 Extent of Contamination in Affected
Media 6-1
7.0 Summary of Site Risks 7-1
7.1 Human Health Risks 7-1
7.2 Summary of Environmental Risks 7-8
8.0 Description of Remedial Alternatives 8-1
8.1 Remedial Action Objectives 8-1
8.2 Background Considerations 8-2
8.3 Hot Spot Areas and Preliminary
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Remediation Goals 8-3
8.4 ARARS 8-5
8.5 Intrinsic Remediation/Attenuation
of Ground Water 8 - 7
8.6 Features Common to All Remedial
Alternatives 8-10
8.7 Contingency Measures 8-12
8.8 Description of Past Actions 8-14
8.9 Description of Alternatives 8-15
9.0 Summary of the Comparative Analysis of
Alternatives 9-1
9.1 Detailed Analysis of Alternatives...9-4
10.0 Selected Site Remedy 10-1
10.1 Components of the Selected Site
Remedy 10-1
10.2 Cost of the Selected Remedy 10-15
11.0 Documentation of Significant Changes 11-1
11.1 Selection of New Remedy 11-1
12 .0 Statutory Determinations. 12-1
12.l Protection of Human Health and the
Environment 12-1
12 .2 Compl iance with ARARs .....12-2
12.3 Cost Effectiveness.. 12-3
12.4 Utilization of Permanent Solutions
and Alternative Treatment Technologies
(or Resource Recovery Technologies) to
the Maximum Extent Practicable 12-3
12.5 Preference for Treatment as a
Principal Element 12-4
12.6 EPA's Selection of the Remedy 12-5
13.0 Responsiveness Summary... ..13-1
13 .1 Public Meeting Transcript 13-1
13.2 Response to Comments on the
Proposed Plan for Petrochem/Ekotek
Superfund Site July 1995 13'-2
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List of Acronyms
AOC - Administrative Order on Consent
ARARs - Applicable or Relevant and Appropriate Requirements
BRA - Baseline Risk Assessment
CERCLA - Comprehensive Environmental Response, Compensation, and
Liability Act of 1980
COC - Chemical of Concern
CTE - Central Tendency Exposure
EPA - Environmental Protection Agency
ESRC - Ekotek Site Remediation Committee
FS - Feasibility Study
HRS - Hazard Ranking System
LNAPL - Light, Non-Aqueous Phase Liquids
MCLs - Maximum Contaminant Levels
MCLGs - Maximum Contaminant Level Goals
NCP - National Contingency Plan
NPL - National Priorities List
PAH - PolyCyclic Aromatic Hydrocarbons
PCB - Polychlorinated Biphenyl
ppb - parts per billion
ppm - parts per million
PRG - Preliminary Remediation Goals
PRP - Potentially Responsible Party
POTWs - Publicly Owned Treatment Works
PWC - Present Worth Cost
RA - Remedial Action
RAO - Remedial Action Objectives
RCRA - Resource Conservation and Recovery Act
RD - Remedial Design
RI - Remedial Investigation
RME - Reasonable Maximum Exposure
ROD - Record of Decision
SARA - Superfund Amendments and Reauthorization Act of 1986
TBC - To be considered
THE - Total Extractable Hydrocarbons
TPH - Total Petroleum Hydrocarbon
TSCA - Toxic Substances Control Act
UDEQ - Utah Department of Environmental Quality
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The glossary of Terms
Administrative Order on Consent (AOC)s - A legal agreement between
EPA and one or more potentially responsible parties whereby the
potentially responsible party or parties agree to perform or pay
the cost of site investigations or cleanup.
Administrative Record: A file established and maintained by the
lead agency that contains all the documents used by EPA to make a
decision on the selection of a remedial action. The
administrative record is available for public review and a copy
is established at or near the site, usually at one of the
information repositories.
Alternative: A cleanup option for reducing site risk by limiting
or eliminating the exposure pathway by reducing, removal,
containment or treatment of the contamination.
Applicable Requirements: Those cleanup standards, standards or
control, and other substantive requirements, criteria or
limitations promulgated under federal environmental or state
environmental or facility siting laws that specifically address a
hazardous substance, pollutant, contaminant, remedial action,
location, or other circumstance found at a CERCLA site. Only
those state standards that are identified by a state in a timely
manner and are more stringent than federal requirements may be
applicable.
Aquifer: A geologic formation, group of formations, or part of a
formation capable of yielding a significant amount of ground
water to wells or springs.
Baseline Risk Assessment (BRA): A study used by EPA to evaluate
the potential risks to human health if nothing is done to
remediate a site or eliminate the risks. The BRA considers
current use and hypothetical future use of the site.
Capital Costs: The costs of items such as buildings, equipment,
engineering, and construction. Construction costs include labor,
equipment and material costs.
CERCLA: The Comprehensive Environmental Response, Compensation,
and Liability Act of 1980, as amended by the Superfund Amendments
and Reauthorization Act of 1986.
Chemicals of Concern: The most prevalent and toxic site-related
chemicals identified and released at a Site.
Compliance Boundary: The boundary at the Petrochem/Ekotek Site
where chemical-specific remediation levels and performance
standards must be met. Not necessarily equivalent to the
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physical ownership or site boundary, but rather defined by the
nature and extent of the contamination at the site.
Contingency Measures: Measures that detail the action to be
taken in response to a remedy component failure.
Excess Lifetime Cancer Risk: The incremental probability of an
individual developing cancer over a lifetime as a result of
exposure to a potential carcinogen. A cancer risk of 1 X 10~6 is
one additional case of cancer (over background levels) per
million people exposed (a one in a million chance of having
cancer) . The NCP specifies the 1 X 10"4 to 1 X ICf6 risk level as
a "target range" within which to manage risk at Superfund sites.
Exposure: Contact of a chemical with the outer boundary of a
human (skin, nose, mouth, skin punctures and lesions) to include
dermal, ingestion and inhalation exposures.
Exposure Parameter: Factors such as body weight, breathing rate,
or time/activity that may be needed to quantify (calculate) human
exposure to a contaminant.
Exposure Pathway: The course a hazardous substance (including
chemicals of concern) takes from a source to a receptor. An
exposure pathway describes a unique mechanism by which an
individual or population is exposed to chemicals or physical
agents at or originating from a site. Exposure pathway includes
a source or release from a source, an exposure point, and an
exposure route.
Exposure Point: A geographical location of potential contact
between a receptor and a chemical or physical agent, e.g., an
industrial worker ingesting soil containing PCBs.
Exposure Point Concentration: Concentration at the point where
receptors may be exposed.
Exposure Route: The way a chemical or physical agent comes in
contact with a receptor, that is, inhalation, ingestion, dermal
contact, e.g., ingestion of vinyl chloride in the ground water by
a hypothetical future industrial worker.
Exposure Setting: A combination of potential land uses and
exposure routes that describe the ways by which a specific type
of receptor can contact contaminants, for example, residential
setting, occupational setting, recreational setting.
Feasibility Study (FS): A study undertaken to develop and
evaluate options for remedial action. The FS emphasizes analysis
of alternatives and is generally performed concurrently and in an
interactive fashion with the remedial investigation (RI), using
data gathered during the RI. The study results are published in
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a report referred to as the Feasibility Study.
Fund or Trust Fund: The Hazardous Substance Superfund
established by Section 9507 of the Internal Revenue Code of 1986.
Ground Water: As defined by Section 101(12) of CERCLA, water in
a saturated zone or stratum beneath the surface of land or water.
Hazard Ranking System (HRS): The method used by EPA to evaluate
the relative potential of hazardous substance releases to cause
health or safety problems, or ecological or environmental damage.
Hydrogeologic: Relating to the science of hydrogeology, which
studies the interactions of ground water and geologic formations.
Intake: The measure of exposure expressed as the mass of a
chemical that crosses an outer boundary of a human or the
chemical per unit body weight per unit time, i.e., milligrams of
chemical per kilogram of body weight per day.
Institutional Controls: Rules, regulations, laws, or covenants
that may be necessary to assure the effectiveness of a cleanup
alternative. Examples of institutional controls include, but are
not limited to, deed restrictions, water use restrictions, zoning
controls, and access restrictions.
Light, Non-Aqueous Phase Liquids (LNAPL): A group of compounds
which are lighter than water. When released to the environment,
they often form a "plume" which floats on top of the ground
water. Includes or may include, hazardous substances or
contaminants, as the primary material or trapped within a matrix.
Maximum Contaminant Levels (MCLs): Standards established under
the Safe Drinking Water Act, which identify the highest allowable
levels of contaminants in drinking water sources. MCLs are often
used to determine when remedial action would be appropriate to
address a release of hazardous substances.
National Contingency Plan (NCP): The EPA's regulations governing
all cleanups under the Superfund program. Published at 40 CFR
Part 300.
National Priorities List (NPL): The list, compiled by EPA
pursuant to CERCLA Section 105, of uncontrolled hazardous
substance released within the United States that are priorities
for long-term remedial evaluation and response.
Offsite: The area located outside of the physical boundaries of
the Petrochem/Ekotek site.
Onsite: The area within the physical boundaries of the
Petrochem/Ekotek site.
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Operation and Maintenance: Measures required to maintain the
effectiveness of the selected remedy including the cost of
operating labor, maintenance, materials, energy, disposal, and
administrative activities.
Parts per billion (ppb)/parts per million (ppm) : Units commonly
used to express concentrations of contaminants. For example, one
ounce of trichloroethylene (TCE) in one million ounces of water
is one ppm; one ounce of TCE in one billion ounces of water is
one ppb.
Performance Standards: The standards, specified by EPA, that the
remedy must meet. For treatment, these standards are
concentrations that the treatment must achieve for identified
contaminants. For disposal, these standards define the
concentrations of wastes to be removed (in volume). For
containment, these standards are the concentrations of wastes
that are monitored at the containment boundaries to ensure the
integrity of the containment system.
Polycyclic Aromatic Hydrocarbons (PAH): A class of organic
(carbon-based) compounds which are associated with manufacturing
and petrochemical wastes.
Polychlorinated Biphenyl (PCB): A class of organic (carbon-
based) compounds which are widely found mixed with transformer
oils. PCBs have been identified as a cancer-causing agent, or
carcinogen.
Potentially Responsible Party (PRP): An individual or company
(such as owners, operators, transporters, or generators of
hazardous waste) potentially responsible for, or contributing to,
the contamination problems at a Superfund site, pursuant to
CERCLA.
Preliminary Remediation Goals (PRGs): The goals set during the
development of the feasibility study for the chemicals of concern
at a site. These goals can be derived from policy, regulations,
risk-based science, technology, or to-be-considered guidance or
criteria. These goals become performance standards when
presented in the Record of Decision.
Present Worth Cost (PWC): An analysis of the current value of
all costs. Also known as Net Present Worth, the PWC is
calculated based on a 30-year time period and a predetermined
interest rate.
Proposed Plan: A document that summarizes EPA's preferred
cleanup strategy, the rationale for the preference, and all of
the alternatives presented in the detailed analysis of the
feasibility study. The Proposed Plan solicits review and comment
on all alternatives under consideration.
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Publicly Owned Treatment Works (POTW): A municipal or local
facility that collects, manages, and treats wastewater.
Reasonable Maximum Exposure (RME): The RME is the highest
exposure that is reasonably expected to occur at a site. It is
the product of a few upper-bound exposure parameters with
primarily average or typical exposure parameters so that the
result represents an exposure that is both protective and
plausible, exposure point concentration and exposure frequency
and duration, that is a mixture of distributions (averages, 95th
percentile, etc.) to reflect a 90th percentile.
Receptor: Any organism (such as humans, terrestrials, wildlife,
or aquatic) potentially exposed to chemicals of concern.
Record of Decision (ROD): A public document that explains the
remedial action plan for a Superfund site. A ROD serves four
functions:
• It certifies that the remedy selection process was
carried out in accordance with CERCLA and with the
NCP
• It describes the technical parameters of the
remedy, specifying the treatment, engineering, and
institutional components, as well as remediation
goals
• It provides the public with a consolidated source
of information about the site and the chosen
remedy, including the rationale behind the
selection
• The ROD also provides the framework for the
transition into the next phase of the remedial
process, Remedial Design (RD)
Relevant and Appropriate Requirements: Those cleanup standards,
standards of control, and other substantive requirements,
criteria or limitations promulgated under federal environmental
or state environmental or facility siting laws that, while not
"applicable" to a hazardous substance, pollutant, contaminant,
remedial action, location or other circumstance at a CERCLA site,
address problems or situations sufficiently similar to those
encountered at the CERCLA site that their use is well suited to a
particular site. Only those state standards more stringent than
federal requirements may be considered relevant and appropriate.
All state standards must be identified in a timely manner.
Remedial Action (RA) or Remedy: Those actions consistent with a
permanent remedy taken instead of, or in addition to, a removal
action in the event of release or threatened release of a
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hazardous substance into the environment to prevent or minimize
the release of hazardous substances so that they do not migrate
to cause substantial danger to present or future public health or
welfare or the environment.
Remedial Action Objectives (RAOs): Objectives developed by EPA
at individual Superfund sites that, in connection with chemical-
specific remediation goals and performance standards, define
acceptable levels of risk.
Remedial Design (RD): The technical analysis and procedures
which follow the selection of remedy for a site and result in a
detailed set of plans and specifications for implementation of
the remedial action.
Remedial Investigation (RI): A study undertaken to determine the
nature and extent of the problem presented by a release of
hazardous substances at a Site. The RI emphasizes data
collection and site characterization, and is generally performed
concurrently and in an interactive fashion with the feasibility
study. The RI includes sampling and monitoring, as necessary,
and the gathering of sufficient information to determine the
necessity for remedial action and to support the risk assessment
evaluation of remedial alternatives.
Resource Conservation and Recovery Act (RCRA): A Federal law
that requires safe and secure procedures to be used in treating,
transporting, storing and disposing of hazardous wastes.
Respondent: Identifies the party entering into an Administrative
Order on Consent (AOC or Consent Order) with EPA.
Subtitle C: A program under RCRA that regulates the management
of hazardous waste from the time it is generated until its
ultimate disposal.
Subtitle D: A program under RCRA that regulates the management
of solid waste.
Superfund Amendments and Reauthorization Act of 1986 (SARA):
Amendments to CERCLA, enacted on October 17, 1986.
Total Extractable Hydrocarbons (TEH)s A measure of the amount of
petroleum-based contaminants present.
Total Petroleum Hydrocarbon (TPH): A measure of the amount of
petroleum-based contaminants present.
Toxic Substances Control Act (TSCA): A Federal law which
regulates the manufacture, processing, import, distribution, use,
and disposal of toxic substances.
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Vertical Migration: The ability of media such as water, to move
vertically upwards or downwards through various subsurface
strata.
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Tables
2.3.1A Observed Species/Evaluated Species
2.3.IB Vegetation Species Observed
4.3 Fact Sheets for Petrochem/Ekotek Site
6.1.1.1A Summary Statistics Table for Onsite Surface Soils
6.1.1.IB Summary Statistics Table for Reference Surface
Soils
6.1.1.1C Summary Statistics Table for Onsite Subsurface
Soils
6.1.1.3 Soil/Buried Debris Exceedance Areas and Volume
6.1.2.3. Calculated Partitioning of Chemicals From Free
Phase Hydrocarbon to Water
6.1.3.2A Summary Statistics Table for Onsite Groundwater
for 1st, 2nd and 3rd Quarters Sampling
6.1.3.2B Summary Statistics Table for Groundwater COCs
During 4th, 5th and 6th Quarter Sampling
6.1.3.2C Summary Statistics Table for Groundwater COCs From
October 1994 Through August 1995
7.1.4A Noncarcinogenic Risks for Each COC and Scenario
7.1.4B Carcinogenic Risks for Each COC and Scenario
7.1.5 Exposure Assumptions and Potential Effect on
Exposure Assessment
7.2.2 Summary of Ecological Risk Assessment
8.4 Federal and State ARARs and TBCs for all the
Alternatives
8.9 Petrochem/Ekotek Superfund Site, Soil Components
of the Alternatives
10.1.2 Selected Remedy Performance Standards
10.1.3 Federal and State ARARs and TBCs for the Selected
Remedy
10.2 Costs of Selected Remedy
10.2A Costs of Contingency Ground Water Arsenic
Treatment for Selected Remedy
10.2B Costs of Contingency Ground Water Containment for
Selected Remedy
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Figures
2-1 Petrochem/Ekotek and Vicinity Location Map
2-2 Site Areas
6.1A West Sample Location Map
6.IB East Sample Location Map
6.1.1.3A Exceedance Areas 0-1 Feet Depth
6.1.1.3B Exceedance Areas 1-5 Feet Depth
6.1.1.3C Exceedance Areas > 5 Feet Depth
6.1.2.2 LNAPL Plume Petrochem/Ekotek Site
6.1.3.2 Groundwater Plume Petrochem/Ekotek Site
8.4.2 Petrochem/Ekotek UST Locations
8.9.2.1 Alternative No. 2
8.9.3.1 Alternative No. 3
8.9.4.1 Alternative No. 4
8.9.5.1 Alternative No. 5
8.9.6.1 Alternative No. 6
8.9.7.1 Alternative No. 7 & 8
8.9.9.1 Alternative No. 9
8.9.10.1 Alternative No. 10
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Section 1.0
Declaration of the Record of Decision
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Section 1.0
DECLARATION FOR THE RECORD OF DECISION
1.1 Site Name and Location
Petrochem Recycling Corporation/Ekotek, Inc. Site
Salt Lake County,
Salt Lake City, Utah.
1.2 STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action (RA)
for the Petrochem/Ekotek Site (the Site), which was chosen in
accordance with the requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) and, to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This decision document'explains the
basis and the purpose of the selected remedy for this Site.
The Utah Department of Environmental Quality (UDEQ) does not
concur with the selected remedy to the U.S. Environmental
Protection Agency (EPA). The information supporting EPA's
remedial action decision is contained in the administrative
record for this Site.
1.3 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 ROD, may present a current or potential threat
to public health, welfare, or the environment.
1.4 DESCRIPTION OF THE SELECTED REMEDY
The Site has been investigated as one operable unit with special
emphasis on the contamination within the soils (to include buried
debris) and the ground water (to include the LNAPL). A removal
action was conducted in 1989 to remove sources of contamination
at the Site (e.g., approximately 60 aboveground tanks, 1200 drums
and 1500 smaller containers, three surface impoundments, an
underground drain field, numerous piles and pits of waste
material, underground tanks, incineration furnaces, and
contaminated soils). The response actions described in this ROD
will permanently address the principal threats at the Site
through treatment of the LNAPL to reduce the toxicity, mobility,
and volume of contaminants. Intrinsic remediation/attenuation
will reduce the contaminants within the ground water to the
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concentrations specified by the remediation performance
standards. Soils exceeding the soil hot spot criteria will be
excavated and disposed in a TSCA, hazardous or solid waste
landfill. The low-level contaminated soils will remain onsite
underneath a 42-inch soil cap.
The major components of the selected remedy include the
following:
o Excavation of surface soils exceeding the soil hot spots
criteria and appropriate off-site disposal in a TSCA,
hazardous waste, or solid waste permitted landfill;
o Partial excavation of the buried debris for appropriate off-
site disposal of debris and soils containing PCBs and
saturated with light non-aqueous phase liquid (LNAPL) in a
TSCA, hazardous waste, or solid waste permitted landfill;
o Consolidation of soils exceeding the soil performance
standards and remaining buried debris under a 42-inch
onsite soil cap;
o Direct excavation of LNAPL with recovered LNAPL being
incinerated offsite and saturated soils being disposed
offsite;
o The ground water component is containment via intrinsic
bioremediation which allows natural attenuation through
biodegradation, dispersion, dilution, and adsorption to
reduce contaminants in the ground water to concentrations
protective of human health in a timeframe comparable to that
which could be achieved through active restoration which has
been determined to be within 10 years. The selection of
intrinsic remediation includes monitoring and pilot studies
to determine whether biodegradation of vinyl chloride is
occurring and, if so, at what rate.
Two contingencies have been developed to address offsite
migration or the ineffectiveness of the intrinsic remediation
alternative. The containment contingency shall be implemented if
offsite migration of the organic plume occurs or if the
effectiveness of intrinsic remediation is not demonstrated. The
arsenic contingency shall be implemented if arsenic exceeds the
MCL of 0.05 mg/1 within the plume or concentrations above the MCL
migrate beyond the compliance boundary.
The major components of the containment contingency include the
following:
o Placement and installation of wells at the compliance
boundary.
o Ground water extraction and discharge to POTW.
o Pretreatment component onsite (e.g., UV oxidation) if
required by permit prior to discharge to POTW.
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The major components of the arsenic contingency include the
following:
o Placement/installation of wells at the compliance
boundary.
o Ground water extraction and discharge to POTW.
o Pretreatment component onsite (e.g., activated alumina
adsorption) if required by permit prior to discharge to
POTW.
The soils and groundwater are to be remediated as a single
operable unit for the Site.
1.5 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 (or justifies a waiver of any Federal and State
applicable or relevant and appropriate requirements that will not
be met), and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
practicable extent. Principal elements of the remedy satisfy the
statutory preference for remedies that employ treatment to reduce
toxicity, mobility, or volume.
Because this remedy contains the contaminated soils underneath a
42-inch cap suitable for redevelopment for industrial use, but
not for unlimited use, and because the groundwater may have
residual hazardous substances above action levels (MCLs or
proposed MCLs) during the implementation of the remedy, ruling
out unlimited use of onsite ground water during the remediation
of the ground water, a review of soils and groundwater will be
conducted no less often than every five years after initiation of
the remedial action for each medium to ensure that the remedy
continues to provide adequate protection of human health and the
environment.
Max H. Dodson Date
Assistant Regional Administrator
U.S. Environmental Protection Agency, Region VIII
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Section 2.0
Site Summary
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Section 2.0
Site Summary
2.1 Site Name, Location, and Description
The Petrochem/Ekotek Site (the Site) is located in Township 1
North, Range 1 West, Section 23, and occupies approximately seven
acres in an industrial corridor in the northern section of Salt
Lake City, Utah (see Figure 2-1).
The Site is bordered on the north by an auto dismantler/
recycler, and on the west, east and south by
industrial/commercial properties. A residential district with
approximately 50 homes is located to the south within 500 feet of
the Site. The Salt Lake City Planning Commission Master Plan for
the area of the site designates the land use as heavy industrial.
Interstate Highway 15 is located to the west and the Wasatch
Mountains are located to the east of the Site.
2.2 Current and Past Use of the Site
and Adjacent Land Use
Three oil refining and related facilities are located near the
Site, one less than a quarter mile to the south and two less than
two miles north of the Site. An EPA Superfund Site, Rose Park
Sludge Pit, is located approximately 1,500 feet southwest of the
Site. Utah Metal Works is located 1,000 feet south of the Site.
The Utah Metal Works is a metal reclaiming / recycling facility
that formerly processed transformers, containing polychlorinated
biphenyl (PCBs), for salvage.
The property is divided by a railroad right-of-way into
eastern and western portions which are enclosed by 6-foot (ft)
chain link security fence. A security company provides daily
walk-through and drive-by security. The property was operated as
a used oil refinery and oil reclaiming/recycling facility from
1953 through 1988. The majority of the site operations occurred
on the western portion of the property. The northwestern portion
of the property, north of the main warehouse, contained the
majority of the equipment used for oil refining, reclaiming, and
recycling, including approximately 60 aboveground tanks, ranging
in capacity from less than 1,000 to 90,000 gallons. The tanks
and associated equipment and materials were removed from this
area between August 1989 and March 1991, during a removal action
conducted by the Ekotek Site Remediation Committee (ESRC) under
United States Environmental Protection Agency (EPA) oversight.
This area, referred to herein as the former tank farm/processing
area, is currently covered by a geosynthetic liner. Storm water
runoff from the area, which exhibits a gentle westward sloping
surfaces, is collected in two surface impoundments. An onsite
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collection and treatment system provides ongoing control of storm
water runoff. Storm water is discharged to the Salt Lake City
Water Reclamation Plant, under a discharge permit. There are no
natural, permanent, or ephemeral surface water streams at or
adjacent to the site. Hobo Warm Springs is located approximately
1000 feet to the northwest of the Site. Hobo Warm Springs drains
to the north into the Jordan River via man-made canals. South
of the former tank farm/processing area in the western portion of
the site are several buildings consisting of the main warehouse,
command post, offices, lab, and a metal-sided storage shed. See
Figure 2-2 for visual reference.
The eastern portion of the property is primarily open, with
buildings located around the perimeter and a concrete loading
ramp located near the center. Sludge piles formerly located on
the site were disposed during the removal action with the
exception of approximately 125 tons of filter cake sludge
stockpiled in the metal warehouse on the eastern portion of the
site. Four underground storage tanks (USTs) were formerly
located on the property. One (UST #2), containing diesel and
solvents (i.e., TCE and PCE), was located just north of a small
framed building on the east side of the railroad spur; during
Phase II, the wood framed building immediately south of former
UST #2 was removed to facilitate investigation of the UST.
Another (UST #1) was located south of a former house in the
southeastern corner of the property. A third UST (UST#4) was
removed from the south end of the main warehouse, and consisted
of three 55-gallon drums. UST#3 was removed from the
northwestern corner of the eastern portion of the site.
2.3 Natural Resources
2.3.1 Evaluation of Threatened and Endangered Species
The site has undergone disturbance, including grading, importing
of fill, and building construction. As a result, it contains
little suitable habitats for native flora and fauna. Identified
species at the site consist primarily of introduced species such
as a rock dove (pigeon). A few native species that have adapted
to urban habitats were observed at the site. Table 2.3.1A lists
the observed species at the Petrochem/Ekotek site.
Approximately 25 percent of the site is vegetated, and the
vegetation is typical of disturbed areas. Observed vegetation
species at the Petrochem/Ekotek site are listed on Table 2.3.IB.
2.3.2 Evaluation of Wetland Areas
Wetlands do not exist on the Petrochem/Ekotek site.
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2.4 General Surface Water and Ground Water Resources
2.4.1 Surface Water Resources
There are no natural, permanent, or ephemeral surface water
streams at or near the site.
2.4.2 Ground Water Resources
The regional information indicates that sediments become finer-
grained to the west, from mostly gravel with interbedded sand
deposits, to mostly sand with interbedded clay and gravels, to
mostly fine-grained deposits with interbedded sand, as one moves
from the Wasatch Mountain front toward the center of the Salt
Lake basin. The unconfined, predominantly gravel aquifer beneath
the Petrochem/Ekotek property becomes a confined aquifer to the
west, as it dips below the predominantly fine-grained lake
sediments. Wells identified as part of a regional well survey,
located less than one mile to the west of the Petrochem/Ekotek
property, exhibit artesian conditions indicative of a confined
aquifer. Ground water is encountered beneath the property at a
depth of 15 to 20 ft below the ground surface (bgs). The
horizontal hydraulic gradient at the Site is relatively flat.
The observed limits of the contaminant plume underlying the Site
include areas to the west and northwest of the Site within
several hundred feet of the property boundary. The compliance
boundary which delineates the extent of the contaminated ground
water plume shall be verified during the remedial design of the
response action. A ground water flow direction to the northwest
in the vicinity of the site is consistent with the findings of
Hely, et al. (1971). Ground water in deeper wells at the site is
warmer and higher in electrical conductance than shallow ground
water, indicating that the aquifer may be recharged in part by
deeper geothermal water from the Warm Springs fault zone. The
ground water beneath the site is between 19.8 and 20.8 °C at
depths between 60 and 160 feet below the ground surface. The
greater specific gravity of the deeper water limits vertical
mixing of the shallower ground water with deeper ground water.
2.4.2.1 Ground Water Well Survey
An inventory of wells located within one mile of the
Petrochem/Ekotek Site was conducted by reviewing well records and
water rights applications filed with the Utah Division of Water
Rights at the Utah Department of Natural Resources. Of the 19
wells investigated, it is important to note that none of these
wells are currently being used for domestic drinking water
purposes. Only one well is currently used for watering stock.
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Section 3.0
Site History and Enforcement Activities
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Section 3.0
Site History and Enforcement Activities
3.1 Operational History
The Site was originally owned and operated as an oil refinery by
0. C. Allen Oil Company, from 1953 to 1968. In 1968, Flinco,
Inc. purchased the facility and operated the refinery until 1978.
During that time Flinco changed its name to Bonus International
Corp. In 1978 Axel Johnson, Inc., acquired the facility and
operated it through its Delaware-based subsidiary, Ekotek, Inc.
At this time, Ekotek, Inc. converted the Site into a hazardous
waste storage and treatment, and petroleum recycling facility.
Steven Self and Steve Miller purchased the site from Axel
Johnson, Inc. in 1981 and reincorporated as Ekotek Incorporated,
a Utah corporation. From 1980 to 1987, the facility operated
under Resource Conservation and Recovery Act' (RCRA) interim
status, and received a hazardous waste storage permit in July
1987 for a limited number of these activities. Ekotek, Inc.
declared bankruptcy in November of 1987. Petrochem Recycling
Corp. leased the facility in 1987 from Ekotek, Inc. and continued
operations until February 1988. The Ekotek bankruptcy estate
released the property (Parcel Numbers 0823407001 and 0823407002)
pursuant to state statute, Utah Code Annotated Section 59-2-1336.
Delinquent County taxes attributed to the property have not been
paid. Ownership of the Site is uncertain at present following
the bankruptcy proceedings of Ekotek Incorporated, the owner of
the Site in 1989. A transfer of title to the property to either
the county or a potential purchaser may occur as a result of a
final tax sale. The tax sale must be initiated within four and a
half years after the initial date of the delinquent taxes.
3.2 History of Site Investigations
In 1980, Ekotek, Inc. filed a RCRA Part A permit application and
achieved Interim Status. A RCRA Part B permit was issued in 1987
to Ekotek, Inc. Site operations were shut down in February 1988,
after the issuance to Petrochem Recycling Corporation of a Notice
of Violation by the Utah Bureau of Solid and Hazardous Waste and
by the Bureau of Air Quality. In November 1988, Region VIII EPA
Emergency Response Branch initiated a removal action at the site.
An Administrative Order on Consent (AOC) for Emergency Surface
Removal (Docket CERCLA-VIII-89-25, Removal AOC) was issued to 27
Potentially Responsible Parties (PRPs) to undertake actions to
clean up the site on August 2, 1989. These PRPs operate as
members of a voluntary association termed the Ekotek Site
Remediation Committee (ESRC). On October 25, 1989, an
Administrative Order for Emergency Surface Removal EPA Docket No.
CERCLA-VIII-90-04 (RCRA-VIII-7003-90-02)(Unilateral Order) was
issued by EPA to 14 PRPs ordering compliance with the Consent
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Order and participation in work conducted at the site. The
Unilateral Order became effective on November 8, 1989.
Sources of contamination at the site included approximately 60
aboveground tanks, 1200 drums and 1500 smaller containers, three
surface impoundments, an underground drain field, numerous piles
and pits of waste material, underground tanks, incineration
furnaces, and contaminated soils. Contaminants associated with
on-site sources include a wide range of organic substances such
as chlorinated solvents and other volatile organic compounds,
polynuclear aromatic hydrocarbons, phthalates, pesticides,
Aroclor 1260, dioxin and furans. Heavy metals are also present
in on-site sources.
As part of the emergency response, the ESRC removed surface and
underground storage tanks, containers, contaminated sludges,
pooled liquids, and processing equipment from the Site,
EPA began site assessment field operations in November 1989, at
which time all contaminant sources discussed above were present
on-site. Based on the contaminants and potential risks
associated with the Site, the EPA placed it on the National
Priorities List (NPL) on October 14, 1992. An Administrative
Order on Consent (AOC) for the performance of the Remedial
Investigation/Feasibility Study (RI/FS) was signed in July 1992
(Docket No. CERCLA (106) VIII-92-21). Members of the ESRC are
Respondents for the RI/FS AOC. The Phase I field investigation
was undertaken from December 1992 to March 1993 and Phase II
investigations were conducted from August to October 1993. A
final RI report was issued in July 1994 and the final FS report
was issued in January 1995. Two addenda to the FS were submitted
on February 24, 1995 and April 7, 1995. The results of the RI/FS
are discussed in sections 5.0, 6.0, and 7.0.
3.3 History of CERCLA Enforcement
3.3.1 PRP Search
EPA issued "Notice of Potential Liability" and "CERCLA 104(e)
information request" letters to 47 Potentially Responsible
Parties (PRPs) for the Removal Action on December 22, 1988.
Follow-up letters were sent to seven of the 47 PRPs on January
20, 1989. EPA issued 104(e) information request letters to an
additional 32 PRPs on September 26, 1989 and to 468 PRPs on
February 12, 1991.
EPA issued general notice letters and a published waste-in list
on November 23, 1993 to initiate a de minimis settlement offer to
eligible parties. The 104(e) data base and waste-in list was
updated in response to the November 23, 1993-settlement offer
package. The waste-in list was republished on March 25, 1994 and
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again on April 5, 1994. The April 5, 1994-waste-in list is the
EPA's most current list and contains 588 PRPs. Shortly
thereafter, ESRC identified additional PRPs numbering more than
500 parties.
3.3.2 De minimis Settlements
EPA offered de minimis settlements to all generator PRPs whose
volume was less than 100,000 gallons and did not contain PCBs.
The purpose of the settlement was to allow small volume parties
to cash-out their liability to the United States arising from
activities related to the Petrochem/Ekotek site thereby reducing
the settlor's transaction costs at the site. The estimated total
site response cost for the settlement was derived from the past
cost at the site, EPA's estimation of the future response action,
and operation and maintenance (O&M) at the site for 30 years.
EPA's estimation of the future response action, and O&M at the
site for 30 years was based upon the first two quarters of data
from the remedial investigation (i.e., pre-ROD) and is thoroughly
documented in a report titled the Preliminary Identification of
Remedial Alternatives (PIRA). Petrochem/Ekotek1s past cost (to
include monies spent on the removal action and RI/FS) totaled
approximately $12 million. The remedial action was estimated in
the PIRA to be approximately $43 million and the O&M was
estimated to be approximately $14 million which computed to an
estimated total site response cost of $69 million.
EPA has entered into de minimis settlements with a total of 411
settlors (including inability to pay settlors) with an associated
volume of 2,078,584 gallons and total settlement payments of
$8,591,065.91. The money from EPA's de minimis settlements have
been placed into a special account dedicated to the
Petrochem/Ekotek Site.
3.3.3 Other Settlements
ESRC engaged in litigation with the PRPs at the site for purposes
of recovering the committee's costs. The case was filed in the
U.S. District Court for the District of Utah as Ekotek Site PRP
Committee V. Self, et al., Case No. 2:95-CV-0154K. ESRC has been
successful in reaching settlements with all but approximately 100
parties remaining in their private law suit. In addition, ESRC
has recently identified an additional 1200 parties for
settlement, not previously named in their law suit.
3.3.4 Cost Recovery
ESRC, as respondents to the Administrative Order on Consent for
Emergency Surface Removal, EPA Docket No. CERCLA-VIII-89-25
(Removal AOC) and the RI/FS AOC, Docket Number CERCLA-VIII-92-21,
has paid $1,645,536 to EPA for reimbursement of EPA's past costs
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incurred in connection with the AOCs as of July 15, 1992.
A demand for costs of $1,054,478.88 incurred by EPA under the
Removal AOC over the period of October 1, 1980 through December
31, 1992 was sent to ESRC on July 21, 1993. These costs were
adjusted to $935,822.71 on August 31, 1993. These costs were
disputed by ESRC and were litigated in a suit brought by EPA
against ESRC. In settlement of the litigation, ESRC will pay
approximately 89%' of costs demanded.
An updated demand for costs of $20,270.07 incurred under the
Removal AOC for calendar year 1993 was sent to ESRC on August 24,
1994. The demand was later withdrawn. Additional costs
(approximately $22,000) incurred by EPA in connection with the
Removal AOC in calendar year 1994 were also identified.
An updated demand for EPA costs of $417,970.40 incurred under the
RI/FS AOC over the period of October 1, 1980 through December 31,
1992 was sent to ESRC on July 28, 1993. These costs were paid by
ESRC on September 7, 1993.
A second demand for EPA costs of $416,636.39 was sent to ESRC on
August 19, 1994. These costs were incurred under the remedial
RI/FS AOC for calendar year 1993 and were paid by ESRC on October
5, 1994.
A third demand for costs of $773,380.65 incurred under the RI/FS
AOC for calendar year 1994 was issued to ESRC via a billing dated
August 11, 1994. This billing was subsequently amended on
October 24, 1995 and again on November 22, 1995. ESRC paid
$492,255.12 plus interest for a total of $494,385.30 on January
24, 1996.
These past costs are EPA's administrative cost of providing
oversight of the AOCs, and include providing funds to UDEQ and
the Community Technical Assistance Grant for purposes of
participating in the Superfund process.
3.4 History of RCRA Enforcement
Steven Self and Steve Miller purchased the site from Axel
Johnson, Inc. and operated the site under the name of Ekotek
Incorporated, a Utah corporation, from 1981 to 1987, as a waste
oil recycling facility. Their operations of the facility lead to
an indictment by the United States on 12 counts of conspiracy,
falsifying records, receiving waste outside of the permit,
violation of Clean Water Act, and mail fraud. Steve Miller
pleaded guilty to three counts and was sentenced to perform 1,000
hours of community service. Steven Self was tried by a jury in
the U.S. District Court of Utah and was found guilty of six
counts and was sentenced to six months in a halfway house and six
months of home, confinement. The U.S. 10th Circuit Court of
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Appeals reversed all but two of the convictions involving the
illegal storage of hazardous waste and the falsifying of records
regarding receipt and disposal of PCB contaminated natural gas
condensate.
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Section 4.0
Highlights of Corimunity Participation
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Section 4.0
Highlights of .Community Participation
EPA implemented a community involvement program to keep the
community informed about the Petrochem/Ekotek Site, and to
provide an opportunity for citizens to participate in the
Superfund process.
4.1 Community Relations Plan
The Petrochem/Ekotek Community Relations Plan was published on
December 11, 1992. The community interviews were conducted
February 4 through 6, 1992.
4.2 Technical Assistance Grant
SARA provides that technical assistance grants may be awarded to
groups who may be affected by a Superfund site. The purpose of
these grants is to foster informed public involvement in
decisions related to a site by providing funds for a particular
group to hire independent technical advisors.
A Technical Assistance Grant was awarded to the Capital Hill
Neighborhood Council (CHNC) on September 16, 1992. This grant is
being used to fund reviews and analyses by technical experts.
4.3 Outreach Program
Six fact sheets were released to the public regarding a variety
of subjects from January 1990 to October 1993. Table 4.3 lists
the titles, dates of release, and brief descriptions of each of
the fact sheets.
The RI/FS and the Proposed Plan for the Petrochem/Ekotek Site
were released to the public for comment on July 3, 1995. These
two documents were made available to the public in the
Administrative Record.
The notice of availability for the RI/FS report, the Proposed
Plan, and other documents in the administrative record was
published in the Salt Lake City Tribune and the Deseret News on
July 10, 1995. That notice also opened the public comment
period, which ran from July 10, 1995 through August 9, 1995. A
request to extend the public comment period to September 8, 1995
was granted and a notice announcing that extension was published
in the Salt Lake City Tribune and the Deseret News on August 7,
1995. An announcement of the second extension of the public
comment period were published on September 14, 1995 in the Salt
Lake City Tribune and the Deseret News, extending the comment
period to October 23, 1995.
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In addition, a public meeting was held on July 26, 1995 at Utah
Department of Environmental Quality (UDEQ) in Salt Lake City. At
this meeting, the public was invited to provide comments on the
Proposed Plan and to ask questions of the EPA and UDEQ
representatives about the Site and the remedial alternatives
under consideration. A response to the comments received during
the public comment period is included in the responsiveness
summary which is part of this Record of Decision (ROD). This
decision document presents the selected remedial action for the
Petrochem/Ekotek Site in Salt Lake City, Utah, chosen in
accordance with CERCLA, as amended by SARA, and the NCP. The
remedial action decision for this site is based on documents in
the Administrative Record.
4.4 Information Repositories
The Administrative Record is maintained at two locations: at the
Marriott Library in Salt Lake City, Utah and the EPA Region VIII
Superfund Records Center in Denver, Colorado.
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Section 5.0
Scope and Role of Operable Units
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Section 5.0
Scope and Role of Operable Units
The potential risks posed by conditions at the Site include
exposure to contaminated soil and groundwater. The remedy
addresses the risks as a single operable unit for the Site. The
ground water component is containment via intrinsic
bioremediation which allows natural attenuation through
biodegradation, dispersion, dilution, and adsorption to reduce
contaminants in the ground water to concentrations protective of
human health in a timeframe comparable to that which could be
achieved through active restoration. The selection of intrinsic
remediation includes monitoring and pilot studies to determine
whether biodegradation of vinyl chloride is occurring and, if so,
at what rate. The soils and LNAPL components include:
o Excavation of surface soils exceeding the soil hot spots
criteria and appropriate offsite disposal in a TSCA,
hazardous waste, or solid waste landfill;
o Partial excavation of the buried debris for appropriate
offsite disposal of debris and soils containing PCBs and
saturated with light non-aqueous phase liquid (LNAPL) in a
TSCA, hazardous waste, or solid waste landfill;
o Consolidation of soils exceeding the soil performance
standards and remaining buried debris under a 42-inch
onsite soil cap;
o Direct excavation of LNAPL with recovered LNAPL being
incinerated offsite and saturated soils being disposed
offsite.
This response eliminates future exposure to contaminated soils
through removal and offsite disposal of the soils that exceed the
hot spot criteria; prevents exposure to soils within EPA's
acceptable risk range for industrial use; prevents partitioning
of contaminants from LNAPL to the ground water; prevents further
contaminant migration in the ground water; and treats ground
water via intrinsic remediation/natural attenuation. This remedy
is considered the final response action for this site and is
described in further detail in Section 10.0. The selected remedy
is consistent with, and incorporates all past response actions
for the Site taken in conjunction with the Emergency Surface
Removal AOC.
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Section 6.0
Summary of Site Characteristics
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Section 6.0
Summary of Site Characteristics
This section provides an overview of the Petrochem/Ekotek Site's
contamination, including the source, nature and extent,
concentrations, and volumes of contamination. Actual routes of
exposure and exposure pathways are discussed in Section 7.0. A
general overview of the Petrochem/Ekotek Site is presented in
Section 2.0.
6.1 Extent of Contamination in Affected Media
Releases of hazardous substances at the Site occurred during the
operation of the site primarily due to disposal practices and
spills. On-site sources were found to be poorly contained,
leaking, and unlined. The known primary source materials (tanks,
drums, containers, filter cake piles, and liquids, as described
in Section 2.0 above) were removed from the site during the
Emergency Surface Removal Action. The ground surface in the area
where the processing equipment and tank farms were located was
covered on an interim basis in February 1992 with a geosynthetic
liner held in place with sand bags. The liner was placed to
minimize infiltration and to prevent contamination of storm water
runoff from the site. All storm water collected on the
geosynthetic liner is presently treated and discharged under a
permit to the sewer system.
Figures 6. 1A and 6.IB identify the location of all soil sampling
and the location of all monitoring wells and Geoprobe samples.
6.1.1 Soils
The site was divided into areas, based on similar types of
chemicals, knowledge of past uses and operations, associated
impacts, and geography. These areas will be used to describe the
nature arid extent of contamination of the soils. However, the
site was not divided into these subareas for the quantitative or
qualitative portions of the risk assessment.
6.1.1.1 Background
To evaluate metal detections in soil, a statistical comparison
was made between onsite surface soil and offsite reference
(background) samples. This comparison was conducted using the
Mann-Whitney statistical test, and was used to eliminate some
metals as chemicals of concern (COCs)(CDM, 1994). Results of the
analysis indicated that only beryllium concentrations were
significantly higher in onsite than in offsite soil samples and
thus beryllium was retained as a COC. Arsenic, cadmium,
chromium, copper, lead, manganese, nickel, vanadium, and zinc
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were eliminated as COCs in surface soils when compared to their
respective reference concentrations because of low detection
frequencies.
The Phase I and II surface and subsurface soil data was divided
into separate categories depending on location for the evaluation
of risk. These categories were onsite surface and subsurface
samples, offsite surface reference samples, and all other surface
and subsurface samples. Offsite samples that may have been
impacted by the site could not be considered reference locations.
Only soil samples collected inside the fence were considered for
developing the exposure point concentration. Analytical data
were validated by RUST E&I.
Summary statistics were developed for the onsite surface soils,
reference surface soils, and onsite subsurface soils. The
frequency of detection, the range of detections, mean, standard
deviation, and the upper 95% one-sided confidence limit on the
mean were estimated. The exposure point concentration was chosen
as the lesser of the maximum detection and the upper 95% one-
sided confidence limit on the mean. This exposure point
concentration was compared to the toxicity/concentration
screening criteria during the selection of COCs and is used in
quantitative risk analysis equations for those chemicals which
will be retained as COCs to determine chronic daily intake (GDI).
Summary statistical tables for onsite surface soils, reference
surface soils, and onsite subsurface soils are shown in Tables
6.1.1.1A, 6.1.1.IB, and 6.1.1.1C, respectively.
6.1.1.2 Nature and Extent of Contamination
A general summary of the nature and extent of impacts to the site
soils follows:
• The former tank farm/processing area comprises the northern
part of the western portion of the property, from the main
warehouse building north to the maximum extent of site
impacts, and from Chicago Street east to the former railroad
spur (Figure 2-1). In the former tank farm/processing area,
non-fuel volatile organics were uncommon, and were not
detected at concentrations higher than 2.85 parts per
million (ppm). Benzene, toluene, ethylbenzene, and xylene
(BTEX) were observed in shallow soil at concentrations up to
64 ppm. Hydrocarbon impacts were evident from widespread
total extractable hydrocarbons (TEH) detections up to 65,000
ppm. Semivolatile organic compounds were detected up to
56.4 ppm, but decreased with depth. PCBs were detected up
to 92 ppm (historical data showed concentrations up to 150
ppm). Dieldrin was the only pesticide detected, up to a
maximum of 0.02 ppm. Metal detections were of the same
order of magnitude as detections in the offsite reference
samples. Arsenic, beryllium, and thallium were detected at
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concentrations of up to 83.6, 0.896, and 45 ppm,
respectively, which is above maximum offsite concentrations
of 36.1, 0.39, and 36 ppm, respectively. Silver was
detected up to 15 ppm in surface soil, but was not detected
in offsite reference samples.
Four soil samples were collected, three at a depth of
15 ft and one at 5 ft, for Toxicity Characteristic
Leaching Procedure (TCLP) analysis of volatiles,
semivolatiles, PCBs, herbicides, and metals. The
samples were collected from heavily hydrocarbon-
impacted soil within and immediately adjacent to (south
of) the former tank farm/processing area, to determine
if the oily soil is leachable. The sample locations
were chosen to represent the tank farm, and were taken
from heavily-impacted areas as indicated by Phase I and
previous (pre-RI) sample results.
TCLP results indicate that the soil is not hazardous by
the characteristic of toxicity under the Resource
Conservation and Recovery Act (RCRA) regulations.
Based on visual observation of stained soils and light
non-aqueous phase liquid (floating oil)(LNAPL), soil
contamination is this area extends from the ground
surface to the water table in the central and western
part of the area, and only to a depth of about 5 ft in
the eastern part. The lateral extent of impacts to
surface soil has been defined by the samples off-
property to the north, which show concentrations of TEH
in surface soil of 4,100 to 8,370 ppm in the adjacent
auto wrecking yard. These samples have been assumed to
represent the northern limit of site impacts. Samples
collected further to the north did not show evidence of
impacts. The LNAPL which is present below the tank
farm area extends to the north and has likely
contaminated subsurface soils immediately above the
water table in this area.
During drilling and trenching activities, debris,
including what appears to be a subsurface concrete
slab, was encountered in the eastern part of the former
tank farm/processing area. The apparent slab is
approximately 120 by 60 ft and was encountered at a
depth of approximately 4 ft (Figure 2-2) . The soils
beneath the slab have not been characterized with
respect to constituents and concentrations.
The area east of the main warehouse includes the area east
of (behind) the main warehouse building, extending to the
former railroad spur (Figure 2-2) herein referred to as the
"debris area." This area generally coincides with a former
acid sludge neutralization mixing area, which later was
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filled with rubble and debris. In this area, a trench was
excavated to investigate the potential for impacts due to
former sludge mixing activities. A variety of debris was
uncovered including concrete, wood, rubber tires, metal, and
bricks, indicating dumping. Impacts were observed to a
depth of approximately 6 ft. Visible hydrocarbons in the
soil were tarry, viscous and appeared different from oil
observed elsewhere in the former tank farm, pointing to a
separate source (such as sludge mixing). Volatiles were
detected at trace concentrations. BTEX constituents were
observed in shallow soil at concentrations up to 37 ppm.
TEH was noted up to 103,000 ppm. Semivolatile compounds
were detected at concentrations up to 60.5 ppm. PCBs were
detected up to 6.36 ppm. Antimony and mercury were detected
at concentrations of 14 and 0.6 ppm, respectively, above
maximum offsite levels of 12.1 and 0.291 ppm, respectively.
Lead was detected in two samples at' 1,260 and 3,880 ppm,
compared to a maximum offsite concentration of 1,150 ppm.
The main warehouse and buildings area comprises the main
warehouse building and parking lot and the remainder of the
western portion of the property (Figure 2-2). In this area,
TEH was detected at levels up to 1,600 ppm, primarily in the
parking lot west of the main warehouse (a value of 19,450
ppm at the extreme southwestern corner of the property
appears spurious due to duplicate sample results of 49 ppm).
Detections of BTEX constituents were less than 0.5 ppm.
Semivolatiles were detected in surface soil up to 33.4 ppm,
and decreased with depth. Aldrin and dieldrin were detected
up to 0.08 ppm, respectively. Because of the potential for
soil impacts beneath the main warehouse building, these
soils, although not sampled during the RI, have been
considered as potentially requiring remediation in the FS.
The former underground storage tank (UST) #2 area includes
the area in the southern part of the property impacted by
the former diesel UST (Figure 2-2) . Impacts from tank
leakage/spillage were revealed by trenching. The area of
impacted soil is limited at the surface, but increases in
size with depth, and appears to extend to the water table.
TEH was detected up to 14,500 ppm and semivolatiles were
detected up to 63 ppm. BTEX concentrations were less than 5
ppm. PCBs were not detected. Metals concentrations were
within the range of concentrations for offsite reference
samples with the exception of beryllium detected at 0.45
ppm, above the maximum offsite concentration of 0.39 ppm.
The area northeast of the metal warehouse is the area at the
northeastern edge of the property (Figure 2-2). In this
area, TEH (140,000 ppm) found at the surface decreases with
depth to nondetect at 5 ft. Of the BTEX constituents, only
xylenes were detected at a trace concentration of 0.005 ppm.
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PCBs were not detected. Arsenic, beryllium and lead
concentrations up to 372, 1.11, and 1,170 ppm, respectively,
was above maximum offsite reference sample concentrations of
36.1, 0.39, and 1,150 ppm, respectively. These impacts
appear to be related to former sludge storage in this area.
Soil impacts from organics are estimated to extend to a
depth of approximately 3 ft. Detections of beryllium,
arsenic, and lead in 10-ft depth samples at
concentrations above that observed in the offsite
reference samples suggest inorganic impacts to a depth
of 10 ft. In the one sample where arsenic and lead
detections were greater than offsite detections, a
collocated sample at the same depth as the original
sample indicated concentrations of arsenic and lead
were an order of magnitude less than offsite detections
(i.e., 4.29 and 10.6, respectively). This is less than
the maximum offsite concentrations for arsenic and lead
as described above.
The concrete loading ramp area includes the impacts around
the elevated concrete loading ramp in the center of the
eastern part of the property (Figure 2-2) . In this area,
TEH up to 160,000 ppm at the surface decreases to nondetect
at a depth of 5 ft. BTEX detections were limited to trace
concentrations of less than 0.01 ppm. PCBs were detected in
soils north of the ramp, up to 1.65 ppm. Beryllium,
mercury, copper and lead were detected at concentrations
above those observed in offsite reference samples.
Beryllium was detected up to 1.31 ppm, greater than the
maximum offsite concentration of 0.39 ppm. Mercury was
detected up to 0.496 ppm, above the offsite maximum of 0.291
ppm. Copper was detected up to 1', 080 ppm, above the maximum
reference sample concentration of 300 ppm. Lead was
detected up to 1,910 ppm, as compared to the maximum offsite
reference sample concentration of 1,150 ppm. Impacts appear
to be related to former sludge storage in this area.
The remaining area of the site with soil impacts consists of
an oily soil area northeast of former UST #2 where the old
south tank farm area was located; a small area south of the
concrete loading ramp and near the eastern boundary; and
areas near the southern boundary. Trenching indicates the
oily soil area is very localized and extends from a depth of
approximately 1.5 to 3.5 ft. TEH was detected in this soil
at a concentration of 203,000 ppm. BTEX concentrations were
less than 3 ppm. This soil is believed to be associated
with the former southern tank farm, which consisted of
several aboveground tanks. In the soil south of the
concrete loading ramp and near the eastern boundary, TEH was
detected at levels up to 4,540 ppm in surface soil, but was
not detected in subsurface soil in this area. BTEX
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concentrations were less than 0.1 ppm. Metals
concentrations were within the range of concentrations
observed offsite with the exception of beryllium and silver
detected at concentrations of up to 1.15 and 1.42 ppm,
respectively.
At a few locations near the southern boundary of the
property, arsenic, beryllium, chromium, vanadium, and
silver were detected in surface soil at greater
concentrations than those observed in offsite reference
soils. Arsenic was detected at concentrations up to
237 ppm, beryllium at concentrations up to 0.698 ppm,
chromium at concentrations up to 57.1 ppm, vanadium at
concentrations up to 33.6 ppm, and silver at
concentrations up to 2.47 ppm.
Dioxins/furans were not analyzed for in any of the
Phase I or II surface soils data collected at the
Petrochem/Ekotek site. Therefore, Field Investigation
Team (FIT) data collected onsite for dioxins/furans by
Ecology and Environment (E&E) in 1989 (E&E 1990) were
used to represent surface soil data for the site. FIT
collected ten onsite surface samples that were analyzed
for dioxins/furans. Three of ten samples collected
were located in lime, waste, or sludge piles that have
since been removed and were not considered in
developing the exposure point concentration. The
remaining seven samples collected at the site were used
to develop the exposure point concentration. The
dioxins/furan data were validated by FIT.
The RI (see plate 4-11) data shows detections of PCBs in
the following samples: S-l, S-35, S-39, and S-40 in the tank
farm; S-21, S-45, and S-46 located near the metal-sided
large shed; and W-13 south of the metal-sided large shed.
In addition, figure 4-3 of the RI report shows a detection
of PCS at depth (down to 5') in the buried debris area in
trench BT2, sampling point 01.
6.1.1.3 Volume Estimates
The COCs in the soils contributing to the risk of the site, for
both the future industrial and future residential scenarios,
include noncarcinogenic and carcinogenic constituents. The
noncarcinogenic constituents include aldrin, antimony, beryllium,
dieldrin and thallium (as chloride). The carcinogenic
constituents include aldrin, benz(a)anthracene, benzo(a)pyrene,
benzo(b)fluoranthene, benzo(k)fluoranthene, beryllium,
dibenz(a,h)anthracene, dieldrin, indeno(1,2,3-c,d)pyrene, PCBs,
2,3,7,8-TCDD(TEF) and HxCDD.
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Localized areas that contain elevated COG concentrations above an
excess cancer risk of ICf4 or hazard indexes greater than one for
the industrial worker in the future have been identified as "hot
spots." The soil COC preliminary remediation goals used to
identify "hot spots" are provided below:
o Benzo(a)anthracene - 780 mg/kg
o Benzo(a)pyrene - 78 mg/kg
o Benzo(b)fluoranthene - 780 mg/kg
o Dibenz(a,h)anthracene - 78 mg/kg
o Indeno(1,2,3-c,d)pyrene - 780 mg/kg
o PCBs - 15 mg/kg
2,3,7,8-TCDD(TEF) - 0.186 ug/kg
o Thallium- 160 mg/kg
Based on these levels, estimates for risk-based hot spot areas
and volumes were developed. The areas containing known risk-
based hot spot soil cover 700 square yards (SY) with a
corresponding volume of 200 cubic yards (CY). Areas of known
"total petroleum hydrocarbons (TPH) hot spots" ("TPH hot spot" is
defined as exceedances of TPH of 100,000 ppm) include the volume
beneath the metal warehouse on the northeast portion of the site
(to a depth of 1 ft)(40 CY) and near the concrete loading ramp on
the eastern portion of the site (90 CY), as shown on Figure
6.1.1.3A. Soils beneath the Main Warehouse building (to the
water table) (2970 CY) were assumed to exceed the hot spot
criteria rendering a site total of 3300 CY of hot spot removal.
Localized areas that contain COC concentrations above an excess
cancer risk of 10~6 or hazard indexes greater than one (i.e.,
Preliminary Remediation Goals (PRGs)) for the industrial worker
in the future have been identified. The soil COC preliminary
remediation goals used to identify soil PRG exceedance areas are
provided below:
o Benzo(a)anthracene - 7.8 mg/kg
o Benzo(a)pyrene - 0.78 mg/kg
o Benzo(b)fluoranthene - 7.8 mg/kg
o Dibenz(a,h)anthracene - 0.78 mg/kg
o Indeno(1,2,3-c,d)pyrene - 7.8 mg/kg
o PCBs - 0.15 mg/kg
2,3,7,8-TCDD(TEF) - 0.00186 ug/kg
o Thallium- 160 mg/kg
Based on these levels, estimates of areas and volumes for soils
that exceed the PRGs were developed and are shown on Figures
6.1.1.3A, 6.1.1.3B, 6.1.1.3C and are listed on Table 6.1.1.3.
6.1.2 LNAPL
6.1.2.1 Nature and Extent of Contamination
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Free-phase oil exists on the water table at the site. The extent
of the floating oil below the former tank farm/processing area
was estimated during the RI by CH2M Hill in 1992. CH2M Hill
drilled ten wells (e.g., CH-1 through CH-10) during the
investigation of the floating product. Phase I and II drilling
and well installation indicates that light non-aqueous phase
liquid (LNAPL) extends to the north beneath the adjacent salvage
yard property. The groundwater plume also extends to the west
off the physical boundaries of Petrochem/Ekotek property. The
greatest thickness of oil appears to assume a generally north-
south orientation. Although oil was detected during drilling of
well W4a, and a sheen of oil was observed in the well casing at
W4a in Phase I, the sheen was not observed in September 1993.
The majority of the oil is located directly beneath the former
tank farm, based on the thickness measurements performed during
Phase I and II field program. The oil plume is defined on the
northwest by wells W-7 and CH-8, to the west by wells CH-9 and
CH-10, to the south by well W-3, MW-8, and W-6, and to the
southeast by well CH-3. Temporary Phase I Geoprobe points (GP-1,
GP-2, GP-3) and Phase II Geoprobe points (GP-35, GP-36, GP-37,
GP-38, GP-39) indicate the extent of oil on the northeast.
Figure 6.1.2.2 delineates the extent of the LNAPL plume.
6.1.2.2 Volume Estimates
The oil was sampled and a pilot test was performed to determine
the effectiveness of hydraulic removal (RUST E&I, 1993b). That
report estimated a total volume of oil present at the water table
of approximately 10,000 gallons, and forms the basis for the
development of the alternatives presented later.
The Floating Product Investigation Report, dated March 1992,
developed by CH2M Hill on behalf of EPA provides a rough estimate
of 22,000 gallons of LNAPL. Thus, the volumes may be adjusted in
the field to reflect the removal of the LNAPL at the approximate
percentages delineated in each of the alternatives. The affected
volume of soils immediately adjacent to the LNAPL, expected to be
saturated with LNAPL, is estimated to be 3,000 cubic yards.
Figure 6.1.2.2 shows the extent of the LNAPL plume.
Available records of used oil shipments accepted at the site
indicate that over the roughly 30 years of operation (late 1950s
to 1988) approximately 50,000,000 gallons of used oil was shipped
to the facility. Records also indicate that material was
accepted with the used oil, including solvent waste. Available
records show that approximately 335,000 gallons of solvent was
also shipped to the Site, including auto and paint waste,
cleaning liquid waste, methylene chloride, solvents and waste
solvents, used oil with solvent odor, carbon tetrachloride,
tetrachloroethylene, and 1,1,1-trichloroethane (TCA). The known
volume of solvents is approximately 1 percent of the used oil
total shipped to the site.
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6.1.2.3 Principal Threat Wastes
Since no source areas for solvents have been identified, the
possibility of the oil acting as a source to the ground water was
investigated. In March 1995, the Light Non-Aqueous Phase Liquid
(LNAPL) was re-analyzed for halogenated volatile constituents
(solvents) by purge and trap concentration (EPA Method 5030)
combined with gas chromatography (GO as described in EPA Method
8010. The LNAPL was also analyzed specifically for vinyl
chloride, 1,1,1-trichloroethane and tetrachloroethylene by mass
spectrometry using selective ion monitoring (SIM). Vinyl
chloride was detected at 480 ppb; 1,1,1-trichloroethane was
detected at 130 ppb; and tetrachloroethylene was detected at 410
ppb. Previous LNAPL analytical methods used detection limits of
10,000 ppb and found no detections because the limits were high.
The compounds that were detected in the LNAPL were evaluated as
to the likelihood that they would dissolve from the oil into the
ground water. Table 6.1.2.3 shows the results of the
partitioning exercise. The predicted concentrations show that
the maximum concentrations of vinyl chloride, 1,1,1-
trichloroethane and tetrachloroethylene have the potential to
partition into the ground water at concentrations of 110 ppb,
0.55 ppb and 1.2 ppb, respectively. Upon further review, EPA
derived a theoretical equilibrium partitioning of vinyl chloride
from LNAPL at the site to.ground water using the effective
solubility of vinyl chloride (VC) in water. Data from the March
1995 sampling event was used and the effective solubility of VC
in water was calculated using the simplifying assumptions of
Raoult's Law which relates the effective solubility to the mole
fraction of the compound in the mixture. The resulting
partitioning from LNAPL to ground water, although subject to
significant uncertainty, was close to the MCL of 2 ug/1. The
March 1995 sampling of the LNAPL is the only sampling event where
the detection limits were sufficiently low to detect the
concentrations of the chemicals of concern (COCs). More studies
would have to be completed to accurately describe the range of
the concentrations of the COCs within the LNAPL using the lower
detection limits, and to accurately estimate the mole fraction.
When the predicted concentrations in water are compared to the
actual concentrations in water, it is clear that most compounds
present in the LNAPL are not observed in ground water due to
their affinity for the residual organic phase. Compounds with
relatively high aqueous solubilities and low octanol-water
coefficients, such as benzene, have been detected in the past at
low concentrations. However, this partitioning exercise clearly
demonstrates that the LNAPL is a likely source material of the
vinyl chloride in the ground water. A source material is defined
as material that includes or contains hazardous substances,
pollutants or contaminants that act as a reservoir for migration
of contamination to ground water or acts as a source for direct
exposure. Because of the concentrations of the solvents within
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the LNAPL, the potential of the solvents to partition to the
ground water exists, and the significant risk to human health or
the environment should exposure occur, the plume and saturated
soils above the plume are considered principal threat wastes.
6.1.3 Ground Water
6.1.3.1 Background
Many of the chemicals identified as COCs in the human health BRA
are present in the Salt Lake City area, either as naturally-
occurring chemicals in soil and ground water, or as anthropogenic
chemicals caused by over a century of urban and industrial
development. As stated in EPA Risk Assessment Guidance for
Superfund (EPA, 1989) , "a comparison of sample concentrations
with background concentrations is useful for identifying the non-
site-related chemicals that are found at or near the site." The
BRA for human health considered soil background, and eliminated a
number of chemicals on the basis of statistical comparison of
site concentrations to offsite concentrations. However, the BRA
did not compare onsite concentrations of contaminants with
offsite concentrations within the ground water, on the basis that
an insufficient number of offsite reference samples existed to
make a meaningful statistical comparison to three quarters of
monitoring data. EPA believes that arsenic is a naturally-
occurring (background) constituent in ground water in the Salt
Lake area, however, the actual mean background concentration is
difficult to select based on variability in arsenic across the
region, but appears to be below the Maximum Contaminant Level
(MCL) of 0.05 mg/1. Arsenic has been detected above the MCL on
three occasions within the first three quarters of ground water
data in two site wells. EPA believes that the detections of
arsenic in the first three quarters may be partially attributed
to suspended matter in the samples, since the wells may have been
insufficiently developed prior to sampling. There was only one
exceedance of the MCL during the second three quarters on which
arsenic was detected at 0.051 mg/1 in W-l during the January 94
sampling episode.
There is evidence within the 104(e) data base that suggests that
PRPs sent waste containing arsenic to the site. However, since
there is insufficient data to conclude whether anthropogenic
contribution of arsenic is statistically significant, a
contingency has been developed that will address the migration of
arsenic from the site or the treatment of arsenic that exceeds
the MCL.
6.1.3.2 Nature and Extent of Contamination
Water quality has been determined from monitoring well sampling.
There are 75 wells and piezometers that were drilled, and
Geoprobe samples taken during the PA/SI and RI/FS. Ten wells
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were drilled to determine the nature and extent of the LNAPL
plume prior to the RI/FS. These wells are identified as CH-
wells. Eight (8) monitoring wells were developed prior to the
RI/FS. An additional 18 monitoring wells were developed during
the RI/FS to supplement the existing monitoring wells. Thirty-
nine (39) Geoprobe samples were taken during the course of the RI
to determine the extent of contamination on the eastern portion
of the Site. Thirteen (13) piezometers were drilled in January
1995 to supplement the FS work. The following discussion details
the results of the sampling and analysis during the RI/FS and
through August 1995.
During the first quarter, of 1993, concentrations of several
organic and inorganic compounds were detected in groundwater in
the wells sampled. The wells with the highest detected values
are those located in or near the former tank farm/processing
area. Consistent with previous data, wells' MW-7 and MW-6, as
shown in Figures 6.1A and 6.IB, had detections of volatile
organics, including vinyl chloride and benzene, above Maximum
Contaminant Levels (MCL). The total organic solvents decreased
from previous sampling episodes, while vinyl chloride levels
increased, suggesting possible ongoing degradation of the solvent
compounds to vinyl chloride. Isolated occurrences of metals
compounds above MCLs were observed in several wells. These
occurrences were unfiltered samples. Subsequent filtered metal
samples were less concentrated leading to the conclusion that the
construction of the wells may have disturbed the subsurface and
released suspended particulates containing arsenic. No PCB
compounds were detected in any of the groundwater samples. TEH
was indicated in areas within the floating oil plume and in well
W-l, which is locally impacted by diesel product.
Concentrations of several organic and inorganic compounds were
detected in groundwater in the wells sampled during second and
third quarter sampling in 1993. The wells with the highest
detected values are those located in or near the former tank
farm/processing area. Isolated occurrences of metals compounds
above MCLs were observed in a few wells. The metals' samples
were unfiltered and detections may be the result of suspended
particulate. No PCB compounds were detected in any of the
samples. TEH was previously reported in areas within the
floating oil plume; however, it was undetected during third
quarter sampling.
The results of Baseline Human Health Risk Assessment dated
August 2, 1994, developed by CDM Federal Programs Corporation on
behalf of EPA, were derived from three quarters of data collected
in 1993. The frequency of detection, range of detected
concentrations, mean, standard deviation, upper 95% one-sided
confidence limit, and exposure point concentrations from the
three quarters of ground water data are shown on Table 6.1.3.2A.
The vinyl chloride contamination is generally found in the
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shallow aquifer at depths of 40 feet below ground surface (bgs).
Other solvents, including cis 1,2-Dichloroethene can be found at
depths of 160 feet bgs. The COCs contributing to the risk of the
site, for both the industrial and residential future scenarios,
of the ground water include noncarcinogenic and carcinogenic
constituents. The noncarcinogenic constituents include antimony,
arsenic, beryllium, chloroform, cis-1,2-dichloroethene,
manganese, mercury, nickel, silver and thallium (as chloride).
The carcinogenic constituents include arsenic, benzene,
benzo(b)fluoranthene, beryllium, chloroform, and vinyl chloride.
The extent of the ground water contamination is shown on Figure
6.1.3.2 as defined by the level of risk under a residential
scenario and applicable, relevant, and appropriate regulations
(ARARs). The compliance boundary which delineates the present
extent of the contaminated ground water plume shall be verified
during remedial design of the response action.
The water quality data base has been expanded extensively since
the development of the Risk Assessment. Water quality data was
collected in January 1994 (4th Quarter), May 1994 (5th Quarter),
and August 1994 (6th Quarter). The 4th, 5th and 6th quarter data
were collected as part of the RI/FS. Table 6.1.3.2B lists the
detection frequencies, minimums and maximums (e.g., range of
detected concentrations), means and standard deviations for each
of the chemicals of concern detected in these quarters. A
comparison of the first three quarters (Table 6.1.3.2A) with the
next three quarters (Table 6.1.3.2B) shows that there is a
decrease in the mean concentration of antimony, arsenic, silver,
thallium, benzene, vinyl chloride and benzo(b)fluoranthene and an
increase in the mean concentration of beryllium, manganese,
mercury, nickel, chloroform, and cis-1,2-dichloroethene.
Additional water quality data were collected to develop a better
understanding of the hydrogeology and to determine the
effectiveness of intrinsic remediation as a remedial alternative
for ground water at the Site. Sampling occurred in different
wells during the months of October 1994, November 1994, December
1994, January 1995, February 1995, March 1995, May 1995, and
August 1995. Table 6.1.3.2C lists the detection frequencies,
minimums and maximums (range of detected concentrations), mean,
and standard deviation for arsenic and those organic chemicals
that have the potential to be intrinsically remediated. A
comparison of this data with the previous six quarters of data
shows that the levels of vinyl chloride and arsenic contamination
within the ground water plume have remained within the same order
of magnitude. However, the high detections of arsenic and vinyl
chloride that were detected in the first three quarters have not
been repeated in the subsequent sampling events.
Twelve piezometers were drilled in the early months of 1995 for
the specific purpose of determining whether biodegradation was
occurring and subsequently quantifying the biodegradation rate.
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The February 1995 sampling event of the offsite piezometer 12 (P-
12) shows 1,1,1-trichloroethane (TCA) at 788 ppb which is above
the MCL of 200 ppb. P-12 is lo.cated approximately 400 feet
northeast of the Site. Also, well W-4A exceeded the MCL for TCA
during that same sampling event. The MCL for TCA was not
exceeded in any of the wells in subsequent sampling events. The
TCA does not appear to be originating from the Site. Thus, it is
currently believed that it has an offsite source. The impact of
the TCA upon, and potential connection to, the Site will be
monitored during the Remedial Design (RD) and Remedial Action
(RA) .
6.1.3.3 Volume Estimates
The COCs contributing to the risk of the site, for the future
residential scenario, of the ground water include noncarcinogenic
and carcinogenic constituents. The noncarcinogenic constituents
include chloroform, cis-l,2-dichlorethene, antimony, arsenic,
beryllium, manganese, mercury, nickel, silver and thallium. The
carcinogenic constituents include benzene, chloroform, vinyl
chloride, benzo(b)fluoranthene, arsenic and beryllium.
The ground water preliminary remediation goals used to delineate
the contaminated ground water plume are provided below:
benzene - 0.005 mg/1
chloroform - 0.1 mg/1
cis-l,2-dichloroethene - 0.07 mg/1
vinyl chloride - 0.002 mg/1
benzo(b)fluoranthene - 0.0002 mg/1
antimony - 0.006 mg/1
arsenic - 0.05 mg/1
beryllium - 0.004 mg/1
manganese - 0.05 mg/1
mercury - 0.002 mg/1
nickel - 0.1 mg/1
silver - 0.05 mg/1
thallium - 0.002 mg/1
The volume of ground water historically impacted has been
estimated as approximately 17,000,000 gallons, assuming a maximum
depth of impact of 45 ft below the water table.
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Section 7.0
Summary of Site Risks
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Section 7.0
Summary of Site Risks
A Baseline Human Health Risk Assessment was developed and
finalized on August 2, 1994, by CDM Federal Programs Corporation
on behalf of EPA. An Ecological Risk Assessment for the Site was
developed and finalized in November 1994 by Woodward-Clyde on
behalf of the Ekotek Site Remediation Committee (ESRC). The
following describes the development and results of these studies.
Section 7.1 Human Health Risks
CERCLA and EPA guidance delineates the role of the baseline risk
assessment (BRA) in the Superfund remedy selection process. The
BRA is initiated to determine whether the contaminants of concern
at the site pose a current or potential risk to human health and
the environment in the absence of any remedial action. A site
conceptual model for the Petrochem/Ekotek site was developed and
included potential current and future exposure pathways.
Carcinogenic and noncarcinogenic cumulative risk resulting from
multiple contaminants, and/or multiple pathway exposure scenarios
were evaluated. Section 5.0 discusses the data that was used for
the quantification of the risk. In summary, the ground water
risk is quantified from three quarters of data collected during
the Remedial Investigation and the soils' risk is quantified from
two phases of soil sampling events performed as part of the
Remedial Investigation and soil data collected by FIT. All of
the data used for quantification was validated. The evaluation
of the risk involves the selection of the chemicals of concern;
identification of an exposure (to include receptor and pathway);
an assessment of the toxicity of the COCs; and a calculation of
the risk for each COC and exposure pathway typically referred to
as the risk characterization of the site.
7.1.1 Chemicals of Concern
COCs were selected from a list of all potentially site-related
chemicals using specific guidelines developed by Region VIII EPA
in the BRA. The list of potentially site-related chemicals
included chemicals detected at least once in any site-specific
sample from Phase I and Phase II of the RI. In addition,
dioxin/furan data from surface soil samples collected prior to
the RI by the field investigation team (FIT) were also included.
Selection criteria were as follows:
o Exceedance of background concentrations;
o Essential nutrients;
o Concentration and toxicity;
o Detection frequency;
o Mobility, persistence, and bioaccumulation;
o Exceedance of applicable or relevant and
7-1
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appropriate requirements (ARARs);
o Historical evidence; and
o Listed as a COC in more than one medium
COCs retained in surface soil under the future industrial
scenario were thallium, PCBs, delta-BHC, endosulfan sulfate,
endrin ketone, trichloroethene, benzo(a)pyrene,
benzo(b)fluoranthene, benzo(g,h,i)perylene, benz(a)anthracene,
dibenz(a,h)anthracene, dibenzofuran, indeno(1,2,3-c,d)pyrene, 2-
methylnaphthalene, naphthalene, phenanthrene, and TCDD (TEF,
cancer).
COCs retained in ground water were antimony, arsenic, beryllium,
manganese, mercury, nickel, silver, thallium, benzene,
chloroform, cis-1,2-dichloroethene, vinyl chloride,
benzo(b)fluoranthene, bis(2-chloroethyl)ether, 1,3-
dichlorobenzene, 2-methylnaphthalene, naphthalene, and
phenanthrene.
Chemicals that are not essential nutrients, and have no EPA-
established health-based criteria to be used for toxicity
screening, are included as COCs. Chemicals without EPA-
established health-based criteria will not be evaluated
quantitatively, but will be discussed qualitatively. This
includes delta-BHC, endosulfan sulfate, endrin ketone,
trichloroethene, bis(2-chloroethyl)ether, 1,3-dichlorobenzene,
dibenzofuran, benzo(g,h,i)perylene, 2-methylnaphthalene,
naphthalene, and phenanthrene.
7.1.2 Summary of Exposure Assessment
7.1.2.1 Current Exposure
No current exposure pathways were evaluated, since no significant
exposure to humans is occurring at the site. There are no wells
in the aquifer directly beneath the Site and the groundwater is
not used by residents or workers. Furthermore, access is limited
to those performing the RI/FS, and Site access is restricted by a
chain-link fence and periodic surveillance is conducted to
monitor onsite activity.
7.1.2.2 Potential Future Exposure
Potential pathways by which humans could be exposed to COCs at,
or originating from, the Petrochem/Ekotek site was identified and
selected for evaluation. Future industrial and residential
exposure scenarios were chosen for the site. The potential
receptors and pathways of exposure selected for evaluation were
as follows:
Industrial Worker:
o Ingestion of Surface Soil
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o Dermal Contact with Surface Soil
o Ingestion of Ground Water
o Inhalation of Fugitive Dust
Resident
o Ingestion of Surface Soil
o Dermal Contact with Surface Soil
o Ingestion of Ground Water
o Inhalation of Fugitive Dust
o Dermal Contact with Chemical in Ground Water
(Showering Scenario)
o Inhalation of Airborne Vapors in Ground Water
(Showering Scenario)
To evaluate exposures for each pathway, concentrations to which
individuals might be exposed were estimated based on site-
specific sampling data. An exposure point concentration was
determined for each of the chemicals detected in any one of the
multiple samples performed. The exposure point concentration was
chosen as the lesser of the maximum detection and the upper 95%
confidence limit on the mean. The approach used to estimate
exposure assumptions followed EPA Superfund Guidance (EPA, 1989a)
for risk assessments, in which EPA states that the risk
assessment should evaluate Reasonable Maximum Exposures (RMEs)
expected to occur. EPA states that the "intent of the RME is to
estimate a conservative exposure case that is still within the
range of possible exposures." For each exposure pathway, the
Central Tendency Exposure (CTE) pathway, using average values for
all exposure factors, was also estimated for comparison.
To estimate Chronic Daily Intakes (GDIs) for each pathway,
scenarios were developed based on estimates regarding the extent,
frequency, and duration of exposures. GDIs were estimated for
each selected exposure pathway. GDIs were then used to predict
the potential health risks associated with exposure to
carcinogens and the potential for adverse noncarcinogenic
effects.
7.1.3 Summary of Toxicity Assessment
EPA has developed a standardized risk assessment methodology that
can be used to evaluate potential carcinogenic risks and
noncarcinogenic hazards or effects. In accordance with this
guidance, toxicity values for carcinogenic and noncarcinogenic
effects associated with exposure were collected from EPA sources
(EPA 1993a, 1994). For carcinogens, the toxicity values are
cancer slope factors (SFs). For noncarcinogens, the toxicity
values are reference doses (RfDs).
Carcinogenic effects result in or are suspected to result in the
development of cancer. EPA assumes a nonthreshold mechanism for
carcinogens; that is any amount of exposure to a carcinogenic
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chemical that poses a potential for generating a carcinogenic
response in the exposed organism. EPA has developed a.
carcinogen-classification system using weight-of-evidence to
classify the likelihood that a chemical is a human carcinogen.
Chemicals are classified by EPA as:
A Human carcinogen
Bl Probable human carcinogen; limited human data
are available
B2 Probable human carcinogen; sufficient
evidence in animals and inadequate or no
evidence in humans
C Possible human carcinogen
D Not classifiable as to human carcinogenicity
E Evidence of noncarcinogenicity for humans
Noncarcinogenic or systemic effects include a variety of
toxicological end points and may include effects on specific
organs or systems, such as the kidney, liver, lungs, etc. EPA
believes that thresholds exist for noncarcinogenic effects.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day) ~l,
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The term "upper bound" reflects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
an underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to
chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of the lifetime
daily exposure levels for humans, including sensitive
individuals. Estimated intakes of chemicals from environmental
media (e.g., the amount of a chemical ingested from contaminated
drinking water) can be compared to the RfD. RfDs are derived
from human epidemiological studies or animal studies to which
uncertainty factors have been applied (e.g., to account for the
use of animal data to predict effects on humans). These
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uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse noncarcinogenic effects
to occur.
7.1.4 Summary of Risk Characterization
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 = GDI x SF
where:
Risk = A unitless probability of an individual developing
cancer (for example, one chance in 10,000 or
1 X 10"4)
GDI = Chronic daily intakes averaged over 70 years
(mg/kg-day)
SF = Slope factor (mg/kg-day)
-i
Risks are probabilities that are generally expressed in
exponential form (1 X 10~4) . An excess lifetime cancer risk of
1 X 10~6 indicates that as a reasonable maximum estimate, an
individual has a one-in-1 million additional chance of developing
cancer as a result of site-related exposure to a carcinogen over
a 70-year lifetime under specific exposure conditions at the
Petrochem/Ekotek Site.
EPA uses the general 1 X 10~4 to 1 X 10"6 risk range as a "target
range" within which the EPA strives to manage risks as part of a
Superfund cleanup. Although waste management strategies
achieving reductions in site risks anywhere within the risk range
may be deemed acceptable by the EPA risk manager, EPA has
expressed a preference for cleanups achieving the more protective
end of the range (for example, 1 X 10~6) . Furthermore, although
EPA generally uses 1 X 10 in making risk management decisions,
the upper boundary of the risk range is not a discrete line at 1
X 10" . A specific risk estimate less that 1 X 10~4 may be
considered unacceptable based on site-specific conditions,
including any remaining uncertainties about the nature and extent
of contamination and associated risks.
The potential for noncarcinogenic effects is evaluated by
comparing an exposure level over a specified time period (for
example, a lifetime) with a reference dose (RfD) derived for a
similar exposure period. The ratio of exposure to toxicity is
called a hazard quotient (HQ).
The HQ is calculated as follows:
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Noncancer HQ = CDI/RfD
where:
GDI = Chronic daily intakes averaged over the
exposure period (mg/kg-day)
RfD = Reference dose (mg/kg-day)
The GDI and RfD are expressed in the same units and represent the
same exposure period (that is, chronic, subchronic or short-
term) .
If the GDI (exposure) is greater than the RfD, the HQ will be
greater than one. An HQ greater than one indicates the potential
for an adverse noncarcinogenic health effect from exposure to the
chemical.
A Hazard Index (HI) is generated by adding the HQs for all COCs
that affect the same target organ or system (for example, the
liver or respiratory system) within a medium or across all media
to which a given population may reasonably be exposed. If the HI
for each toxic end point exceeds one, the potential for an
adverse noncarcinogenic health effect from exposure to the medium
is indicated.
A risk characterization based on the COC's exposure pathways and
toxicity values was presented in the BRA. Toxicity values for
COCs were combined with chemical exposure values to estimate
quantitative health risk and hazard estimates for exposure to
COCs at the Petrochem/Ekotek site. A summary of potential
hazards and risks for the Petrochem/Ekotek site are shown on
Table 7.1.4A for noncarcinogenic COCs and on Table 7.1.4B for
carcinogenic COCs.
For noncarcinogens, EPA assumes that there is a level of exposure
(i.e., the reference dose or RfD) below which it is unlikely that
any adverse health effects will occur. If the exposure, or
chronic daily intake (GDI) exceeds the RfD, i.e., if CDI/RfD is
greater than one, there may be concern for potential noncancer
hazards.
The overall HI estimated for the industrial worker reasonable
maximum exposure (RME) scenario is 7.4. The overall HI estimated
for the industrial worker GTE is 4.5. The overall HI estimated
for the residential ground water ingestion scenario exposure
(RME) is 26.6. The overall HI estimated for the residential GTE
scenario is 11.2. The chemicals that are the major contributors
to these noncarcinogenic hazards are arsenic and thallium in
ground water, as shown in Table 7.1.4A.
The overall potential cancer risk posed by the site to the
is •
7-6
industrial worker RME scenario is 3 X 10" , and for the GTE
-------
(which uses average values for all exposure factors) exposure
scenario, 4 X 1CT5. The chemicals that are the major
contributors to this cancer risk are arsenic and vinyl chloride
in groundwater and, to a lesser extent, PAHs and PCBs in soils.
The overall potential cancer risk estimated for the residential
RME scenario is 1 X 10"3, and for the CTE exposure scenario is
1 X 1CT4. The chemicals that are the major contributors to this
cancer risk are arsenic and vinyl chloride in the ground water
and, to a lesser extent, PAHs and PCBs in soils. Potential
cancer risk posed by residential use of ground water is slightly
higher, with 8 X ICf4 for the RME scenario and 1 X 10~4 for the
CTE scenario. The chemicals that are cited as the significant
contributors to these risks are arsenic and vinyl chloride in
ground water (Table 7.1.4B). These risk estimates are
conservative and likely overstates the potential impacts to human
health at the site, due to the use of the RME exposure and
uncertainties associated with chemical toxicity studies.
The total site risks and hazards using the RME exposure exceed
EPA's target range due to the potential for ground water
ingestion. However, for the industrial land use scenario, the
potential risks and hazards posed by site-wide surface soils (CTE
and RME scenarios) are within EPA's target risk range (ICf4 to
10"6, HI less than 1) .
The BRA indicates that potential human health risks exist based
on ingestion of ground water in the future, however, it is
important to note that the ground water ingestion pathway is not
currently complete. The risks identified are for future exposure
should no actions be taken to prevent such exposure. The ground
water beneath the site is recognized as a potential drinking
water resource by the State because it is hydraulically connected
to the primary drinking water source for Salt Lake City. The
site area is currently served by municipal water supplies so
there is no current exposure to the ground water beneath the
Site.
7.1.5 Uncertainty in the Risk Assessment
Quantitative evaluation of chemical exposures for a risk
assessment may be the greatest source of uncertainty in the risk
assessment. Uncertainties from different sources may be
compounded in the exposure assessment. To ensure that human
health is adequately protected, the exposure assessment
incorporates values that estimate potential exposures at the
maximum levels that are reasonably expected (RME exposure),
making the estimates conservative. For comparison, CTE exposure
is also evaluated. Table 7.1.5 shows the main areas of
uncertainty associated with the estimation of the chronic daily
intakes (GDIs) and whether the uncertainty would lead to an
overestimation and/or underestimation of the associated risks.
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There are many uncertainties associated with the use of
toxicological information in health risk assessments which are
related to uncertainties intrinsic to the science of toxicology.
Chief among these uncertainties is (1) the use of dose-response
information from high-dose studies to predict adverse health
effects at low doses; (2) the applicability of experimental
animal studies to predict accurate health effects in humans; (3)
the use of dose-response information from short-term exposure
studies to predict adverse health effects of long-term exposures;
(4) the use of toxicity values derived from homogenous animal
populations or healthy human populations to predict adverse
health effects in the general population which is likely to
contain sensitive individuals; (5) quality of the study (i.e.,
design and conduct of the study); and (6) the selection criteria
for the appropriate study in the development of toxicity values.
These and other uncertainties are limitations to the risk
assessment process which cannot be resolved quantitatively given
the current understanding of toxicology and human health and
using current risk assessment methodology. These uncertainties
are addressed in part by consistent application of conservative
assumptions regarding the toxic effects of chemicals, such as
uncertainty factors for RfDs and upper bound estimates for cancer
SFs. Such procedures are intended to protect public health and
are expected, in many cases, to overstate potential impacts on
human health.
The main uncertainty associated with risk characterization is
that some COCs retained in the BRA have no EPA-derived RfDs and
SFs. These chemicals are delta-BHC, endosulfan sulfate, endrin
ketone, trichloroethene, bis(2-chloroethyl)ether, 1,3-
dichlorobenzene, dibenzofuran, benzo(g,h,i)perylene, 2-.
methylnaphthalene, naphthalene, and phenanthrene. Because these
chemicals do not have numeric toxicity criteria, they are not
included in the estimation of quantitative risks. The
quantitative risks could be underestimated if these chemicals
have adverse effects associated with them. The quantitative risk
at the site may not be affected by excluding those chemicals
without EPA-derived toxicity criteria because of the presence of
arsenic, thallium, PCBs, vinyl chloride, and PAHs; these are the
greatest contributors to carcinogenic and noncarcinogenic risks
at the site. Another uncertainty associated with risk
characterization is summing across chemicals with different
mechanisms of action and different end points.
7.2 Summary of Environmental Risks
A baseline ecological risk assessment (ERA) was conducted to
evaluate potential risks to ecological receptors exposed to
chemicals detected in surface soils at the Petrochem/Ekotek site.
Site-specific data used in the preparation of the ERA included
surface soil data collected during the RI; tissue sample data of
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pigeons collected at the site; and direct biological observations
of the ecological habitats and site biota. Using these data, an
ecological conceptual site model was developed to identify how
and where chemicals are likely moving and what animals may be
exposed to site-related chemicals. Two groups of animals were
selected as representative of potential receptors: a
subpopulation of migratory birds that are Federally-protected and
found in the immediate vicinity of the site; and the Federally
protected peregrine falcon pair that between 1991 and 1994 nested
in a quarry near the site. Onsite migratory birds may be exposed
to chemicals in the soil through direct contact or incidental
ingestion of soil if onsite feeding occurs. The peregrine falcon
may be exposed to site-related chemicals by eating birds such as
pigeons that roost on the site and that may have accumulated soil
chemicals in their tissues; the peregrines are not directly
exposed to surface soil chemicals since they typically capture
their prey in flight.
7.2.1 Chemicals of Concern
Fifty-five chemicals were identified as ecological COCs for the
migratory birds, and two chemicals (thallium and dioxins/furans)
were identified as ecological COCs for the peregrine falcon,
using COC selection criteria agreed upon with EPA. The selected
sets of COCs were evaluated for possible risk to the ecological
receptors by comparing their concentrations in soil and pigeon
tissues to conservative toxicity reference values (TRVs) that
were based on toxicity values for each chemical compiled from the
readily available literature. Literature values for the COCs
were selected using two EPA-approved criteria - lowest toxicity
value for a bird species, or lowest toxicity value for any other
species if no bird data were available for that chemical.
7.2.2 Characterization of Risk
Potential risks to the migratory birds and peregrines were
characterized using a two-step process - a risk screening using
conservative assumptions, and a risk assessment of those COCs
that remained after the risk screening and required additional
evaluation using more representative site-specific exposure
assumptions. The screening conservatively assumed that the
migratory birds and pigeons feed only at the Petrochem/Ekotek
site (although it has been documented that feeding actually
occurs on spilled cereal grains at the adjacent railyard); that
the peregrines feed only on birds from the site (disregarding the
feeding range); that the exposure point concentration (EPC)
represents soil concentrations throughout the site; that 100
percent of the RME soil concentrations are bioavailable to the
birds; and that 11 percent of the diet of migratory birds is
soil. The risk screening indicated that onsite concentrations of
five chemicals, including benzo(a)pyrene (B(a)P), PCBs,
beryllium, thallium and dioxins/furans, exceeded their TRY doses
7-9
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for migratory birds. These five COCs were further evaluated.
The Screening also indicated that the COCs for peregrine falcons
were less than their TRVs and thus are unlikely to present a
substantial chronic or acute risk to the falcons.
The risk evaluation for the five COCs that exceeded the screening
levels using the conservative exposure assumptions was conducted
using a more representative assumption which was that soil
constitutes a lower percentage (6.8 percent) of diet in migratory
birds. With this minor adjustment, beryllium and PCBs were
eliminated as posing any potential substantial risk to migratory
birds (Table 7.2.2) .
7.2.3 Uncertainty in the Risk Assessment
In the uncertainty analysis, when three of the conservative
assumptions (fraction of soil in diet, chemical bioavailability,
and exposure duration) were made more representative of site
conditions, it was found that only B(a)P exceeded its long tern
TRY and therefore may present a substantial chronic risk to
onsite migratory birds. When a fourth exposure assumption (soil
exposure concentration) was changed from an EPC to an arithmetic
mean concentration, it was determined the B(a)P did not exceed
its long term TRV dose.
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Section 8.0
Description of Remedial Alternatives
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Section 8.0
Description of Remedial Alternatives
A Feasibility Study (FS) was conducted to develop and evaluate
remedial alternatives for soils (to include buried debris), LNAPL
and ground water. Several alternatives were assembled from the
applicable remedial technology process options and were screened
for their effectiveness, implementability and cost. The
alternatives passing this screening were then evaluated in
further detail based on the nine criteria required by the NCP.
This section provides a description of each alternative that was
retained for the detailed screening analyses in the FS. The no
further action alternative, required by the NCP, was evaluated
against the nine criteria to provide a point of comparison for
the other alternatives.
The selected remedy for the Site must adequately reduce or
eliminate the risks to human health and the environment. Actual
or threatened releases of hazardous substances from the Site, if
not addressed by the preferred alternative or other measures
considered, may present a current or potential threat to public
health, welfare, or the environment. The EPA has developed
chemical-specific cleanup goals for the Site. These objectives
and goals define acceptable levels of risks. The cleanup goals
include prevention of human exposure to contaminants and
prevention of offsite migration of contaminants in excess of the
cleanup goals. These goals were based on the results of the
Baseline Risk Assessment (BRA) and an evaluation of the
Applicable or Relevant and Appropriate Requirements (ARARs)
specified in Federal and State environmental laws and
regulations. Both the objectives and goals were analyzed to
identify the selected alternative. In addition, the EPA's
detailed analysis considered ten remedial alternatives, including
the "No Further Action" Alternative (#1). The EPA is required to
evaluate a no action alternative in order to provide a basis for
comparing the benefits of other alternatives.
Section 8.1 Remedial Action Objectives
Remedial Action Objectives (RAOs) are general descriptions of
goals for protecting human health and the environment at a site,
and are accomplished through remedial actions. If the goals have
already been satisfied, then no action is warranted. If the
goals are not being met, remedial actions may be required. RAOs
identify the media of concern, chemicals of potential concern,
acceptable contaminant levels or ranges of contaminant levels for
protecting human health and the environment, and exposure routes
and receptors.
In the development of the RAOs, the industrial workers' exposure
and residential ground water exposure were considered. The RAOs
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identified for the Petrochem/Ekotek Site are as follows:
Soils
• Protect industrial workers from direct dermal
contact or ingestion of onsite surface soils
containing COCs in excess of the PRGs; and
• Protect industrial workers from inhalation of
airborne particulate matter from onsite surface
soils containing COCs in excess of the Preliminary
Remediation Goals (PRGs).
Ground Water
• Protect human health from ingestion of onsite
ground water that contains chemicals that exceed
the PRGs; and
• Protect human health from dermal contact with and
inhalation of airborne vapors from onsite ground
water that contains chemicals that exceed the
PRGs.
Surface Water
• Protect water quality of surface water bodies
located northwest of the site from site-related
impacts.
Section 8.2 Background Considerations
Many of the chemicals identified as COCs in the human health BRA
are present in the Salt Lake City area, as naturally-occurring
chemicals either in soil and ground water, or as anthropogenic
chemicals caused by over a century of urban and industrial
development. As stated in EPA Risk Assessment Guidance for
Superfund (EPA, 1989), "a comparison of sample concentrations
with background concentrations is useful for identifying the non-
site-related chemicals that are found at or near the site." The
BRA for human health considered soil background, and eliminated a
number of chemicals on the basis of statistical comparison of
site concentrations to offsite concentrations. However, the BRA
did not compare onsite concentrations of contaminants within the
groundwater to offsite ground water, on the basis that an
insufficient number of offsite reference samples existed to make
a meaningful statistical comparison to three quarters of
monitoring data. EPA believes that arsenic is a naturally-
occurring (background) constituent in ground water in the Salt
Lake area, however, an actual mean background concentration is
difficult to select based on variability in arsenic across the
region, but appears to be below the Maximum Contaminant Level
(MCL) of 0.05 mg/1. Arsenic has been detected above the MCL on
three occasions within the first three quarters of ground water
data in two site wells. The arsenic detections in these quarters
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were from unfiltered samples. Filtered inorganic samples taken
after complete development of the wells show arsenic
concentrations below the MCL. EPA believes that the detections
of arsenic above the MCL in the first three quarters may be
attributed, in part, to suspended matter in the samples, since
the wells were insufficiently developed prior to sampling. There
was only one exceedance of the MCL during the second three
quarters on which arsenic was detected at 0.051 mg/1 in W-l
during the January 94 sampling episode.
There is evidence within the 104(e) data base that suggests that
PRPs sent waste containing arsenic to the site. Since there is
insufficient data to conclude whether the anthropogenic
contribution of arsenic is statistically significant, a
contingency has been developed that will address the migration of
arsenic from the site or the treatment of arsenic that exceeds
the MCL.
Section 8.3 Hot Spot Areas and Preliminary
Remediation Goals
8.3.1 Soil Hot Spots
The range of soils alternatives were developed to address the
remedial action objectives. Hot spots were identified as
localized areas that contain elevated COC concentrations above an
excess cancer risk of 10"4 or HI=1. The soil COC remediation
levels used to identify hot spots are provided below:
• Benzo(a)anthracene - 780 mg/kg;
• Benzo(a)pyrene - 78 mg/kg;
• Benzo(b)fluoranthene - 780 mg/kg;
• Dibenz(a,h)anthracene - 78 mg/kg;
• Indeno(1,2,3-c,d)pyrene - 780 mg/kg;
• PCBs - 15 mg/kg;
2,3,7,8-TCDD(TEF) - 0.186 ug/kg; and
• Thallium - 160 mg/kg
Based on these levels, estimates for risk-based hot spot areas
and volumes were developed. The areas containing hot spot soil
cover 700 square yards (sy) with a corresponding volume of 200
CY, as shown in Figure 6.1.1.3.A.
Soils that exceeded a total petroleum hydrocarbon (TPH) reading
of 100,000 ppm were also considered hot spot areas. Removal and
treatment of TPH hot spots addresses EPA concerns. Areas of
known TPH hot spots include the volume beneath the metal
warehouse on the northeast portion of the site (to a depth of 1
ft)(40 CY) and near the concrete loading ramp on the eastern
portion of the site (90 CY), as shown on Figure 6.1.1.3.A.
Soils beneath the Main Warehouse building (to the water table)
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and beneath the metal warehouse on the northeast portion of the
site (to a depth of 1 ft) were assumed to exceed the hot spot
criteria and may also be included as hot spot areas. Since this
is an assumed estimate not based on actual field data, this
volume will not be addressed by any of the remedial alternatives.
The total volume of soils identified as hot spot areas for the
site, to include an assumed volume, is 3300 CY. The remedial
alternatives only address the estimated hot spot volumes from
field data which is a total of 330 CY.
8.3.2 Soil Preliminary Remediation Goals (PRGs)
PRGs were developed for the COCs which were evaluated
quantitatively in the human health BRA, for surface soil under
the industrial scenario, in accordance with EPA guidance for PRG
development (EPA, 1991b). The PRGs for soil were developed by
considering the results of the BRA, background conditions, ARARs,
and analytical technology (i.e., detection limits).
Available analytical technology should be capable of detecting
the concentrations identified as PRGs. Therefore, analytical
technology was not a factor in the modification of the PRG
numbers.
Risk-based concentrations, toxicity values and exposure
parameters were used to calculate excess cancer risk levels of
10"6 and hazard quotients. The PRGs for soils are contaminant
levels that exceed the excess cancer risk level of 10~6 or exceed
the noncarcinogenic hazard index of one for an industrial
exposure.
The soil COC remediation levels used to identify PRGs are
provided below:
• Benzo(a)anthracene - 7.8 mg/kg;
• Benzo(a)pyrene - 0.78 mg/kg;
• Benzo(b)fluoranthene - 7.8 mg/kg;
• Dibenz(a,h)anthracene - 0.78 mg/kg;
• Indeno(1,2,3-c,d)pyrene - 7.8 mg/kg;
• PCBs - 0.15 mg/kg;
2,3,7,8-TCDD(TEF) - 1.86E-06 mg/kg; and
• Thallium - 160 mg/kg
8.3.3 Ground Water Remediation Goals (PRGs)
PRGs were developed for the COCs which were evaluated
quantitatively in the human health BRA, for ground water under
the residential scenario, in accordance with EPA guidance for PRG
development (EPA, 1991b). The PRGs for ground water were
developed by considering the results of the BRA, background
conditions, ARARs, and analytical technology (i.e., detection
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limits).
Arsenic is a ubiquitous background constituent in ground water in
the Salt Lake Valley. However, since the regional average
concentration is less than the MCL for arsenic for the shallow
aquifer, the MCL of 0.05 mg/1 was selected as the PRG.
The chemical-specific remediation standards are applicable to
site ground water. MCLs, promulgated under Federal and State
statutes, have been selected as PRGs for ground water. MCLs are
risk-based, and as stated in the NCP, "the MCL generally will be
the cleanup level where relevant and appropriate."
Available analytical technology should be capable of detecting
the concentrations identified as PRGs. Therefore, analytical
technology was not a factor in the modification and development
of the PRGs.
Risk-based concentrations, toxicity values and exposure
parameters were used to calculate excess cancer risk levels of
10~6 and hazard quotients. The PRGs for ground water are
contaminant levels that exceed the excess cancer risk level of
Id"6 or exceed the noncarcinogenic hazard index of one for a
residential exposure.
The ground water COC remediation levels used to identify PRGs are
provided below:
• benzene - 0.005 mg/1
• chloroform - 0.1 mg/1
• cis-1,2-dichloroethene - 0.07 mg/1
• vinyl chloride - 0.002 mg/1
• benzo(b)fluoranthene - 0.0002 mg/1
• antimony - 0.006 mg/1
• arsenic - 0.05 mg/1
• beryllium - 0.004 mg/1
• manganese - 0.05 mg/1
• mercury - 0.002 mg/1
• nickel - 0.1 mg/1
• silver - 0.05 mg/1
• thallium - 0.002 mg/1
The remediation goal for manganese is based on the Utah Secondary
MCLs for Drinking Water, Utah Administrative Code R309-103-3.
Section 8.4 ARARs
Section 121(d)(2) of CERCLA, 42 U.S.C. § 9621(d)(2), provides
that for "any hazardous substance, pollutant or contaminant that
will remain onsite . . . the remedial action selected . . . shall
require, at the completion of the remedial action, a level or
standard of control for such hazardous substance or pollutant or
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contaminant which at least attains such legally applicable or
relevant and appropriate standard, requirement, criteria, or
limitation." Thus, this section of CERCLA requires that
applicable and relevant and appropriate requirements (ARARs) be
identified and attained during the development and implementation
of remedial actions. For contaminants that will be transferred
offsite, Section 121(d)(3) of CERCLA requires that the transfer
be to a facility which is operating in compliance with applicable
federal and state laws. Offsite activities contemplated under
each alternative must comply with the Revised Procedures for
Implementing Offsite Response Actions, OSWER Directive 9834.11,
dated November 13, 1987 (the "Offsite Policy").
Onsite actions need comply only with the substantive aspects of
ARARs, not with the corresponding administrative requirements,
unless otherwise specified. Permit applications and other
administrative procedures such as administrative reviews and
reporting and record keeping requirements are not considered
ARARs for actions conducted entirely onsite. Offsite actions
must comply with all legally applicable requirements, both
substantive and administrative.
"Applicable" requirements are those cleanup standards, standards
of control, and other substantive environmental protection
requirements, criteria, or limitations promulgated under Federal '
or State law that specifically address a hazardous substance,
pollutant, contaminant, remedial action, location, or other
circumstance at a CERCLA site. State standards that are more
stringent than Federal requirements may be applicable.
Applicable requirements must be met to the full extent required
by the law, unless a waiver applies and is granted.
"Relevant and appropriate" requirements are those cleanup
standards, standards of control, and other substantive
environmental protection requirements, criteria, or limitations
promulgated under Federal or State law that, while not
"applicable" to a hazardous substance, pollutant, or contaminant
at a CERCLA site, address problems or situations sufficiently
similar to those encountered at the CERCLA site such that their
use is well suited to the particular site. State standards that
are more stringent than Federal requirements may be relevant and
appropriate.
EPA's guidance classifies ARARs into three types: chemical-
specific, action-specific, and location-specific requirements.
Chemical-specific requirements are health-, risk-, or technology-
based values that establish an acceptable amount or concentration
of a chemical that may be found in, or discharged to, the ambient
environment. Action-specific requirements are performance- or
activity-based requirements or limitations on actions taken with
respect to hazardous substances. Action-specific requirements
set controls on particular kinds of activities related to the
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management of hazardous substances, pollutants, or contaminants.
Location-specific requirements are restrictions placed on the
concentration of hazardous substances or the conduct of
activities solely because they occur in special locations.
While ARARS are promulgated, enforceable requirements, other
types of information may be useful for designing the remedial
action or necessary for determining what is protective of public
health or the environment. Nonpromulgated advisories or guidance
issued by the Federal or State government that provides useful
information is termed criteria "to be considered" (TBC). TBCs
will be considered along with ARARs in determining the necessary
levels of cleanups and are enforceable when selected as part of
the remedy.
The remedial alternatives' presented for detailed analysis in the
FS were assessed to determine whether they would attain
applicable or relevant and appropriate requirements under Federal
environmental and State environmental and facility siting laws or
provide grounds for invoking an ARARs waiver.
With the exception of the No Further Action Alternative, each of
the alternatives meets ARARs. Alternatives 4, 7, and 8 addressed
groundwater contamination with active treatment technologies.
The other alternatives relied upon intrinsic
remediation/attenuation and have contingency measures included
ensuring ARARs are met.
The list of ARARs pertinent to each of the alternatives
considered is presented in Table 8.4. Table 8.4 provides a
listing of each of the "chemical-," "action-," or "location-
specific" Federal and State requirements and a notation of
whether they are applicable or relevant and appropriate for each
of the alternatives.
A more detailed discussion of the ARARs and TBCs that apply to
the selected remedy is provided in Section 10 of this ROD.
Where two or more ARARs are pertinent to a particular hazardous
substance, pollutant or contaminant, media, or remedial action,
the more stringent shall apply. For those hazardous substances
for which an ARAR exists for a specific media, the ARAR is the
performance standard that must be met unless the risk-based
cleanup standard is more stringent.
Section 8.5 Intrinsic Remediation/Attenuation
of Ground Water
Studies were initiated during and after the completion of the FS
to collect data to determine whether anaerobic biological
activity is occurring at the site and to quantify the
biodegradation rate of the organic compounds, with emphasis on
vinyl chloride, in the shallow aquifer beneath the
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Petrochem/Ekotek site. The final FS and the Aquifer
Characterization Report (developed by RUST Environment &
Infrastructure on behalf of ESRC) detail the results from these
studies. The studies show that geochemical conditions are
generally favorable at the site, however, data were not collected
in these studies to demonstrate conclusively that vinyl chloride
is degrading to the less toxic constituents of ethane and ethene.
The Aquifer Characterization Report also showed that there is an
offsite plume of 1,1,1-trichloroethane (TCA) that is migrating
from the east to the north of the Petrochem/Ekotek site. It is
unknown at this time if the TCA is commingling with the
contaminants in the ground water beneath the Petrochem/Ekotek
site or if the TCA is degrading to more toxic constituents or if
the off-site plume is migrating on a course that bypasses the
Site without commingling with the on-site plume. A monitoring
program is included as a common feature of all the alternatives
to identify the impacts of this plume upon the remediation of the
onsite contaminated ground water at the Petrochem/Ekotek site.
For intrinsic remediation to be effective, the naturally-
occurring hydrogeochemical conditions at the site must allow the
rate of biodegradation to be faster than the rate of contaminant
migration.
To determine whether bioremediation is occurring or the rate at
which biodegradation is occurring at the site, the capacity of
the indigenous microorganisms to metabolize the contaminants must
be documented through field testing. The effectiveness of
intrinsic remediation must be proven with a site monitoring
program to confirm the progress of contaminant biodegradation.
Chemical analyses of contaminants, final electron acceptors,
and/or other reactants and products indicative of biodegradation
processes, need to be performed. Laboratory microcosm studies
can also be performed.
Three lines of evidence can be used to demonstrate that intrinsic
remediation of vinyl chloride is feasible at the Site. These
include (1) documenting the loss of vinyl chloride from field
samples, (2) providing evidence that the potential for vinyl
chloride biodegradation is actually realized in the field at the
site, and (3) conducting laboratory studies to confirm that vinyl
chloride biotransformation is possible in field samples. This
approach for evaluating intrinsic remediation follows the
recommendations of the Committee on In Situ Bioremediation under
the National Research Council (1993). Additional data collection
and studies shall be conducted to further substantiate vinyl
chloride intrinsic remediation at the site.
Previously collected data, including the data described in the
Aquifer Characterization Report, demonstrates that geochemical
conditions are generally favorable at the site for biodegradation
of organic compounds.
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In the vicinity of the LNAPL the redox potential measurements for
ground water (wells CH-3, MW-5, MW-6, and MW-7) range from -108
to -290 mV which indicated conditions are strongly reducing.
Such strongly reducing conditions are consistent with the large
source of organic materials from the LNAPL being available as
substrate for biological processes to deplete oxygen and create
anaerobic conditions. Furthermore, the installed cover at the
land surface above the region of LNAPL helps to foster anaerobic
conditions in the LNAPL region by eliminating the influx of
oxygen from infiltration of precipitation. The sealed land
surface helps to create anaerobic conditions in the underlying
ground water.
The low to highly negative values of the redox potential, the
lower values of nitrate-N, and the presence of sulfate and
organic carbons are indicative of anaerobic biological processes
that are typical of sulfate reduction and/or methanogenesis.
These latter conditions are favorable for reductive
dechlorination of chlorinated solvents including vinyl chloride.
Consequently, the redox potential and electron acceptor data at
the site are consistent with conditions known to be necessary for
vinyl chloride biodegradation.
Additional data collection is required as part of the intrinsic
remediation remedy to demonstrate quantitatively that vinyl
chloride is degrading to the less toxic constituents of ethane
and ethene. ESRC agreed to collect qualitative data to determine
whether ethane and ethene can be detected in the field and
initiated collection of this data in November 1995. If the
results of this data collection render detections of ethane and
ethene, further studies shall be initiated as part of the
intrinsic remediation remedy to quantify the rate of degradation
of vinyl chloride to ethane and ethene.
Discussions between EPA and ESRC have developed an approach at
the Petrochem site to quantify the degradation of vinyl chloride
to ethane and ethene through the use of a tracer test. The
tracer test involves the following steps:
(1) Develop a better 3-D picture of contaminant
distribution which would assist in the design and
implementation of a tracer test. The purpose is to
determine if there are layers of high vinyl chloride
concentration and to more accurately determine the
depth at which VC resides, especially in relation to
the geothermal water. This would involve sampling at
multiple depths within the aquifer, using an ultra-low
flow sampling pump, to sample discrete aquifer
intervals, coupled with downhole flow meter
measurements. This discrete sampling approach and flow
monitoring at various depths within the well would
define if there are zones or intervals of varying flow
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rate and contaminant distribution. The sampling method
would minimize any vertical flow in the borehole. The
suggested sampling and flow monitoring would be done
for a subset of existing wells. A number of two to
five has been suggested by ESRC, however, the quality
of the data will determine whether this number is
adequate.
(2) Perform a tracer test. The purpose of the test
would be to monitor the behavior of vinyl chloride
relative to a conservative tracer such as bromide. The
test would be completed using a tight horizontal and
vertical grid or array of temporary Geoprobe points so
that the exact flow direction and degree of
dispersion/mixing that are occurring in the area of the
plume can be defined. A conservative tracer would be
injected upgradient using an existing well. The tracer
test results would then be used to normalize the vinyl
chloride data, so that vinyl chloride breakdowns could
be accurately tracked.
A more specific work plan shall be developed by the Responsible
Parties performing the remedial design that will provide details
as to how the objective of quantifying the degradation rate of
vinyl chloride to ethane and ethene will be performed during
RD/RA. The description of the tracer test is provided in this
ROD to reflect the scope of the discussions conducted to date and
to use as an example of the level of effort required to quantify
the degradation of vinyl chloride. The objective of quantifying
the ethane and ethene shall be conducted to define the
degradation rate of vinyl chloride and associated remediation
periods supporting the selection of intrinsic remediation for the
ground water. The actual methods and details of how that
objective can be accomplished are evolving so that the specific
work plan may differ in the detail provided in this ROD.
If biodegradation of the vinyl chloride to ethane and ethene
cannot be quantified, or if the rates are inadequate to meet the
criteria specified in this ROD, as determined by EPA, then the
selection of intrinsic remediation as a remediation of the ground
water for the Petrochem/Ekotek site will be reevaluated by EPA
and modifications or initiation of contingency measures may be
deemed by EPA as necessary to be protective of human health and
the environment.
Section 8.6 Features Common to All Remedial Alternatives
Excluding the No Further Action Alternative, each alternative
includes the following common elements:
• Removal and Treatment of LNAPL: Oily liquid wastes will be
removed by direct excavation and pumping/skimming of
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liquids. The approximate volume of waste removed (and more
specifically, the approximate percentage) and treated varies
within the different alternatives; and is dependent upon the
actual field volume, feasibility and cost effectiveness of
removal in the field. The liquid waste will be removed for
offsite thermal destruction (wastes will be heated via
incineration until contaminants are destroyed) at a
permitted facility. Soils saturated with oily liquids will
either be thermally treated onsite (contaminants will be
heated until they evaporate, or are "desorbed," and
subsequently are destroyed), or disposed offsite in an
appropriate landfill. Each alternative can be implemented
in 3 years or less.
Performance and Compliance Monitoring: A performance and
compliance monitoring program will be developed for both the
soils (to include buried debris) and ground water (to
include LNAPL) media. A long-term ground water monitoring
plan will be developed to ensure that onsite contaminated
ground water is not migrating from the site (i.e., beyond
the compliance boundary) and to determine the impacts of the
off-site TCA plume upon the remediation of the onsite
contaminated ground water. The compliance boundary shall be
further del'ineated during the remedial design (RD) . The
frequency of the monitoring and contaminants to be monitored
will be determined during RD but will occur at least once
each year for 30 years or until the site contaminants meet
the performance standards or indefinitely if the remedy has
a containment component.
Tank Farm Components Removal: The liner, concrete wall and
slab, and two tanks (1,000 gallons each) will be removed
from the former tank farm area for disposal in a TSCA,
hazardous or solid waste permitted landfill. Approximately
600 CY of soils excavated during the tank removals will be
thermally desorbed with other soils onsite or disposed
offsite in either a TSCA, hazardous or solid waste landfill.
Building Demolition: Two or more of the existing buildings
on the site will be demolished because they are directly
above or partially above the LNAPL plume and debris area.
Demolition wastes will be removed from the site for
appropriate treatment and/or disposal.
Institutional Controls: Institutional controls are
nonengineering methods by which Federal, State, local
governments, or private parties can prevent or limit access
to or use of a site. Institutional controls for the
Petrochem/Ekotek Site shall include, but not be limited to,
zoning controls; onsite-access restrictions including, but
not limited to, fencing and warning signs; and well
restrictions. Offsite institutional controls shall serve as
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an additional measure of protection to enhance the
effectiveness of the selected remedy and to act as
preventive measures to preserve the implementability and
effectiveness of any of the selected remedy contingency
measures. Offsite institutional controls shall include, but
not be limited to, deed notices and restrictions, water use
restrictions, zoning controls, and well restrictions. These
controls must prohibit all on- and off-site activities on or
in the vicinity of the Petrochem/Ekotek site that would
interfere or be incompatible with or that would in any way
reduce or impair the effectiveness or protectiveness of the
selected sitewide remedy. All onsite and offsite
institutional controls shall be adequately administered,
maintained, and enforced.
• Five-Year Review: As specified in Section 121(c) of CERCLA,
as amended by SARA, and Section 300.430(f)(4)(ii) of the
NCP, EPA will review the remedy no less often than every 5
years after the initiation of the remedial action to assure
that human health and the environment are being protected by
the implemented remedy (this review will ensure that the
remedy is protective and that institutional controls
necessary to ensure protections are in place). An
additional purpose for the review is to evaluate whether the
performance standards specified in this ROD remain
protective of human health and the environment. In
accordance with CERCLA and EPA guidance, EPA will continue
the reviews if hazardous substances, pollutants, or
contaminants remain at the Petrochem/Ekotek Site.
Section 8.7 Contingency Measures
Two contingency measures have been developed to ensure the
protectiveness of the remedies.
8.7.1 Contingency Measure for Containment.
The contingency measures for containment addresses concerns
regarding the potential for either offsite migration of the
organic plume or the ineffectiveness of the intrinsic remediation
alternative or both. This contingency provides containment,
control and treatment of the dissolved ground water plume.
The contingency includes ground water extraction, treatment of
contaminated ground water (if necessary: the POTW may be capable
of accepting the untreated contaminated ground water), and
discharge to the POTW. This contingency includes the
placement/installation of wells at the compliance boundary for
the purposes of pumping the ground water at rates that would
ensure capture of the migrating plume and pretreatment, if
necessary, prior to discharge to the POTW. The exact locations
and number of the ground water wells will be determined during
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the remedial design of the selected remedy, as approved by EPA.
The suggested treatment component includes a UV oxidation system
which shall be located onsite, as described in alternative 8.
Other treatment technologies may be evaluated if the site
conditions trigger the implementation of the containment
contingency measure. Treatment standards will be dictated by the
requirements of the POTW.
The criteria for triggering implementation of the containment
contingency is either (a) a documented, consistent and verifiable
increase, as determined by EPA, in contaminant concentrations
exceeding the ground water PRGs at or beyond the compliance
boundary, which indicates that the remedy is not managing the
waste within the current extent of the contaminated plume or (b)
the documented ineffectiveness, as determined by EPA, of the
remedy to affect the specified reduction in contaminant mass.
The criteria will be further and more specifically developed and
described in the remedial design.
The estimated cost of this contingency measure ranges from
$200,000 to $3,400,000 for a range of operating time from 0 to 30
years. Based on available existing data, the measure would not
be triggered, so the operating time is 0 years. However, to
allow for the worst case situation of persistent offsite plume
movement, the costs for a 30-year operating time have also been
estimated.
8.7.2 Contingency Measure for Arsenic Remediation.
The contingency measure includes ground water extraction, water
treatment, if necessary, and discharge to the POTW. The
contingency measures for arsenic remediation addresses the
concern regarding the potential for exceedance of arsenic above
its MCL of 0.05 mg/1 within the plume or migration of ground
water above the MCL beyond the compliance boundary.
This contingency would be combined with all ground water
alternatives discussed in this ROD, with the exception of the No
Further Action alternative, if arsenic exceeds the MCL beyond the
compliance boundary. This contingency includes the
placement/installation of wells at the compliance boundary for
purposes of pumping the ground water at rates that would ensure
capture of the migrating plume and pretreat, if necessary, prior
to discharge to the POTW. The exact locations and number of the
ground water wells will be determined during the remedial design
of the selected remedy.
The contingency measure also applies within the plume when, as
determined by EPA, the exceedances of arsenic above the MCL are
demonstrated to be above natural background; the concentrations
and consistency of detections of arsenic above the MCL are
statistically significant; and the effectiveness and the cost of
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the pump and treat system justify the reduction of risk as
determined by EPA. The statistical method, to be approved by
EPA, which shall be employed to determine statistically
significant data will be developed as part of the Compliance
Monitoring Program during remedial design of the remedy.
Treatment shall be conducted on all contaminated ground water
that exceeds the requirements of the POTW. Treatment for
removing arsenic from groundwater uses activated alumina
adsorption (also known as gamma aluminum oxide, a porous
adsorbent with a moderately high surface area).
Treatment will occur onsite, although based on the existing site
POTW discharge permit, as an arsenic standard is not specified.
Inclusion of the onsite treatment component for arsenic, as part
of this contingency measure, allows for discharge to the POTW.
The criterion for triggering implementation of the contingency at
the compliance boundary is either (a) a documented, consistent
and verifiable increase, as determined by EPA, in contaminant
concentrations exceeding the MCL at or beyond the compliance
boundary, which indicates that the remedy is not managing the
waste within the current extent of the contaminated plume or (b)
exceedances of arsenic above the MCL within the plume are
demonstrated, as determined by EPA, to be above natural
background; the concentrations and consistency of detections of
arsenic above the MCL are statistically significant; and the
effectiveness and the cost of the pump and treat system justify
the reduction of risk as determined by EPA. The criteria will be
further and more specifically developed and described in the
remedial design.
The estimated cost of this alternative ranges from $300,000 to
$3,600,000 for a range of operating time from 0 to 30 years.
Based on site data available, the alternative would not be
triggered, so the operating time is 0 years. However, to allow
for the worst case situation of a statistically significant
occurrence of arsenic above the MCL, costs for the 30-year
operating time have also been estimated.
Section 8.8 Description of Past Actions
8.8.1 Emergency Removal Action
In August 1989, surface removal activities were initiated by the
ESRC in accordance with the AOC for Removal by the ESRC's
contractor Chemical Waste Management (CWM), with oversight by the
EPA's Emergency Response Branch. The removal activities included
removal of tanks, containers, sludges, and liquids; and storm
water management.
As an addendum to the AOC for Removal, USPCI (replacing CWM)
conducted the demolition and removal of the aboveground tanks,
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equipment, and facilities in the processing area, main tank farm,
and east tank farm, and continued storm water management. The
removal of pipe from the main tank farm began in June 1991 and
was completed on July 25, 1991; and the demolition of the tank
farms began in September 1991 and was completed in November 1991.
The ground surface in the area where the processing equipment and
tank farms were located was covered on an interim basis in
February 1992 with a geosynthetic liner held in place with sand
bags. The liner minimizes infiltration to prevent contamination
of storm water runoff from the site.
8.8.2 State Underground Storage Tank (UST) Removal
Three USTs were removed from the site by USPCI in September 1991
(USPCI, 1992). A site assessment and closure plan detailing the
removals was prepared by USPCI in January 1992. A fourth UST was
removed in March 1992. Figure 8.4.2 shows the locations of the
USTs removed.
Section 8.9 Description of Alternatives
A Feasibility Study (FS) was conducted to develop and evaluate
remedial alternatives for soils (to include buried debris area),
LNAPL, and contaminated groundwater at the Petrochem/Ekotek Site.
Remedial alternatives were assembled from applicable remedial
technology process options and were initially evaluated for
effectiveness, implementability, and cost. The alternatives
passing this screening were then evaluated based on nine criteria
required by the NCP. In addition to remedial alternatives, the
NCP requires that a no action alternative be considered at every
site. The no action alternative serves primarily as a point of
comparison for other alternatives.
Following the development of the alternatives in the FS, ten
remedial alternatives (including the no action alternative)
remained for the detailed analysis evaluation. These
alternatives are described below with the original alternative
numbering sequence from the FS report and the Proposed Plan.
Table 8.9 identifies the final disposition of the contaminated
soils for all the alternatives.
8.9.1 No Further Action Alternative (Alternative 1)
The no further action alternative must be evaluated for baseline
comparison as part of the Feasibility Study process. Under this
alternative, remediation goals would not be met because no
remedial action would be undertaken to treat, contain, or remove
contaminated media which exceed the performance standards. The
collection and removal of runoff from the tank farm liner to the
POTW would cease. The liner, retaining wall and underground
tanks would be allowed to deteriorate. . Ground water monitoring
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would also cease and no action would be taken to prevent
migration of contaminants. No institutional controls would be
implemented to restrict access to the Petrochem/Ekotek site or to
restrict exposure to contaminants.
There would be no reduction of toxicity, mobility, or volume
(TMV) associated with site soils (to include buried debris) or
LNAPL. Intrinsic bioremediation is expected to reduce the TMV in
the contaminated ground water.
There would be no treatment or containment components associated
with this alternative. Under the No Further Action Alternative,
all waste would be left in place and there would be no reduction
in risk. The remedial action objectives (RAOs) would not be met
for this alternative because contaminants would migrate, and
protection of human health and the environment would not be
achieved.
Because there are no actions under the No Further Action
Alternative; chemical-, location-, and action-specific ARARs
would not be met.
Five-year reviews would be conducted.
All actions under the No Further Action Alternative has already
been implemented.
The total 30-year present worth cost of this alternative is
$900,000 with a capital cost of $900,000 and no annual O&M costs.
8.9.2 Excavate and Treat Soil Hot Spot Areas and Partially
Excavate and Treat Soils that Exceed Soil PRGs; 75% LNAPL
Removal/Treatment; Contain Buried Debris; Cap Soils; Intrinsic
Remediation of Ground Water; Access Restrictions, and Land Use
Restrictions (Alternative 2)
8.9.2.1 Soils (to include Buried Debris)
Alternative 2 includes excavation and onsite thermal desorption
of 330 CY of hot spot surface soil; 2,300 CY of soils associated
with the former UST #2 exceeding soil PRGs; and 700 CY of offsite
soils exceeding soil PRGs. The former tank farm area may be used
as a staging and temporary stockpile area for the excavation of
the soils located offsite and the excavated soils onsite. The
thermal desorption includes mixing and soil 'handling to ensure
optimal moisture content. There are no anticipated treatment
residuals associated with thermal desorption as the bag house
residuals will be worked back into soils and thermal processes.
Scrubber water, if a scrubber is necessary, will be used as
quench and evaporated. If residuals are generated and cannot be
addressed as described, bag house waste will be characterized and
disposed of offsite in either a solid or hazardous waste
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landfill. Scrubber water will be either treated onsite and
discharged, or transported offsite for disposal.
Treated soils will be used as backfill onsite in the former tank
farm area and placed in the excavations. A regrading of the
former tank farm area and installation of a soil cover will
reduce storm water accumulation and infiltration and migration of
soils off the site. The soil cover will constitute approximately
5,000 SY to include 6 inches of top soil and revegetation.
Figure 8.9.2.1 depicts the components of alternative 2.
A compacted soil/clay cap of a 2.5-ft thickness will be placed
over 2,000 SY of the buried debris area. The cap includes 6
inches of topsoil and revegetation over the compacted clay layer.
A 25-ft deep slurry wall will be installed around a 600-ft
perimeter of the buried debris. The cap and slurry wall prevents
direct exposure to the buried debris, storm water infiltration,
and reduces the potential for LNAPL contamination within the
buried debris to migrate to ground water.
8.9.2.2 LNAPL
Alternative 2 includes installation of a network of 16, 125-ft
long 20-ft deep trenches and 16 extraction sumps for LNAPL
extraction. Skimmers will be used in conjunction with extraction
sumps to remove the LNAPL. The extraction system is estimated to
be operational for a period of 3 years to remove the extractable
LNAPL. The operational time has been estimated for pricing
purposes. The remedy will be complete when the performance
standards have been met. Extractable LNAPL is defined as
measurable LNAPL greater than 0.02 ft in thickness. It is
estimated that this process will remove approximately 75% of the
estimated LNAPL quantity of 10,000 gallons. During installation
of the extraction trenches, approximately 25 percent of the LNAPL
will be directly removed. LNAPL floating on water in the open
trenches during excavation will be removed with absorbent
material. The trench system is estimated to remove approximately
50% of the LNAPL. The remaining LNAPL, approximately 25%, will
be sorbed to subsurface soils and is not anticipated to migrate.
The recovered LNAPL shall be sent to an offsite incinerator for
treatment. Approximately 300 drums have been estimated to carry
the LNAPL to an offsite incinerator. Approximately 700 CY of
soils saturated with LNAPL (generated during trench
installation), and absorbent materials shall be treated via
thermal desorption onsite or disposed in a TSCA, hazardous or
solid waste landfill. LNAPL extraction minimizes contaminant
migration and reduces potential subsurface soil and ground water
contamination.
8.9.2.3 Ground Water
Alternative 2 uses intrinsic remediation and attenuation as the
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process to attain the ground water PRGs, as described in Section
8.4 above. If the favorable conditions that currently exist, in
part, due to the presence of LNAPL, change as a result of the
removal of LNAPL, enhancements will be added to the contaminated
ground water (such as benzoic acid) to allow continuation of
anaerobic degradation.
8.9.2.4 Implementation and Cost
Regrading and placement of the soil cover over the former tank
farm area and the buried debris area will occur after the LNAPL
system is installed within the period of one year.
The recoverable LNAPL is expected to be collected within 3 years
based on the conceptual design developed in the FS.
Intrinsic remediation/attenuation is expected to be effective in
meeting the ground water PRGs within 10 years.
Material, equipment, and specialists are readily available to
implement this remedy.
O&M includes cap and slurry wall maintenance. The 30-year .
present worth cost for Alternative 2 is $5,200,000 and includes
$2,400,000 in capital costs and $2,800,000 in O&M costs. The
following costs are calculated equivalent to, but are not
included in the 30-year PWC: (1) Arsenic treatment is estimated
to cost $3,600,000 and (2) Containment and treatment of organic
contaminants are expected to cost $3,400,000.
8.9.2.5 Other Components
Institutional controls including a fence, warning signs, and
water use restrictions will be installed and implemented to
eliminate exposure pathways. Water use restrictions will include
coordination with the Utah Department of Environmental Quality
and the Utah State Engineer to restrict water usage and prohibit
well drilling on the site and in the vicinity of the plume,
except for remedial purposes. The person who performs the
function of the Utah State Engineer is either the Regional and/or
State Engineer with the Division of Water Rights, within the Utah
Department of Natural Resources.
During excavation activities, dust and odors will be controlled
with foam. Air monitoring will be conducted during the soils
excavation and thermal desorption of the soils onsite to ensure
compliance with air quality requirements. Workers at the site
will be required to wear personal protective equipment to protect
them from potential contaminant exposure.
Soils (to include buried debris), LNAPL and ground water
monitoring will occur at least once each year for 30 years or
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until the site contaminants meet the performance standards or
indefinitely for containment components of the remedy. The
actual number of samples, location of sampling, sampling
techniques, contaminants to be analyzed, analytical methods, and
frequency of samples, etc. will be determined under a Compliance
Monitoring Program that will be developed during remedial design.
An estimated cost for monitoring has been estimated for purposes
of comparing and selecting an alternative for cleanup.
The chemical-, location-, and action-specific ARARs identified in
Table 8.4 would be met.
Five-year reviews would be conducted because waste would remain
onsite.
8.9.3 Consolidate and Contain Soils that Exceed PRGs (Including
Buried Debris); Remove/Treat 75% LNAPL; Intrinsic Remediation of
Ground Water; and Access Restrictions, and Land Use Restrictions
(Alternative 3)
8.9.3.1 Soils (to include Buried Debris)
Alternative 3 includes excavation and offsite disposal in a TSCA
or hazardous waste landfill of 200 CY of hot spot surface soils.
TCSA (40 CFR 761.125) requirements for PCB spill cleanups require
that soil contaminated by spills will be decontaminated to 10 ppm
PCBs by weight provided that soil is excavated to a minimum depth
of 10 inches. The excavated soil will be replaced with clean
soil, i.e., containing less than one ppm PCBs, and the spill site
will be restored (e.g., replacement of turf) (40 CFR 761.125
(c)(4)(v)). Approximately 7,700 CY of soils that exceed the soil
PRGs, to include offsite soils, will be consolidated in the
former tank farm area for containment with a cap and slurry wall.
The TPH soils hot spot areas are included within the soils that
exceed the soil PRGs. The cap includes a 2.5-ft thick compacted
soil/clay cap, 6 inches of topsoil and revegetation more than a
10,000 SY area. The slurry wall is a 25-ft deep bentonite/soil
subsurface barrier, designed to extend 5 ft below the water table
and will be installed around the 1400-ft perimeter of the cap.
Containment with a cap and slurry wall prevents direct exposure
to site soils, reduces soils entrainment and migration offsite in
surface water runoff, and minimizes the potential for contaminant
migration in subsurface soils and ground water. Figure 8.9.3.1
depicts the components of alternative 3 with the exception of 200
CY which has been included in the cost estimate but is not
depicted on the figure.
Alternative 3 has the same components with respect to the buried
debris as alternative 2.
8.9.3.2 LNAPL
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Alternative 3 has the same components with respect to the LNAPL
as alternative 2.
8.9.3.3 Ground Water
Alternative 3 has the same components with respect to ground
water remediation as alternative 2.
8.9.3.4 Implementation and Cost
Soil hot spot removal will be conducted prior to tank and
concrete slab and wall removal, construction of LNAPL trenches,
consolidation of soils that exceed the soil PRGs, and capping.
The trenches will be impacted by neither cap construction, nor
the cap impacted by the trenches, because the trenches will be
completely backfilled and as structurally capable as natural
subgrade material.
All other factor affecting implementation is the same as those
described for alternative 2.
O&M includes cap and slurry wall maintenance. The 30-year
present worth cost for Alternative 3 is $5,700,000 and includes
$3,600,000 in capital costs and $2,100,000 in O&M costs. The
following costs are calculated equivalent to, but are not
included in the 30-year PWC: Arsenic treatment is estimated to
cost $3,600,000, and containment and treatment of organic
contaminants is expected to cost $3,400,000.
8.9.3.5 Other Components
Institutional controls including a fence, warning signs, and
water use restrictions will be installed and implemented during
the implementation of the remedy to eliminate exposure. Water
use restrictions will include coordination with the Utah
Department of Environmental Quality and the Utah State Engineer
to restrict water usage and prohibit well drilling on the site
and in the vicinity of the plume, except for remedial purposes.
The person performing the function of the Utah State Engineer is
either the Regional and/or State Engineer with the Division of
Water Rights, within the Utah Department of Natural Resources.
The construction controls, reviews and monitoring programs are
similar to alternative 2.
The chemical-, location-, and action-specific ARARs identified in
Table 8.4 would be met. The offsite disposal facility may
require that the waste meet land disposal restrictions (LDRs);
this is not anticipated to be a problem because (1) it is
expected that the waste already meets LDRs, (2) a treatability
variance could be obtained for waste that does not meet LDRs, and
(3) the continuing revisions to the RCRA requirements for
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contaminated media may significantly alter the regulatory scheme
at the time of cleanup. Consolidation and capping of the former
UST #2 soils will comply with Utah UST regulatory requirements.
8.9.4 Remove/Dispose of Soils that Exceed PRGs; Partial
Removal/Containment of Buried Debris; Remove/Treat 80% LNAPL; and
Air Sparging/Vapor Extraction of Ground Water (Alternative 4)
8.9.4.1 Soils (to include Buried Debris)
Alternative 4 includes excavation of 200 CY of soil hot spots
areas; 21,000 CY of onsite soils that exceed the soil PRGs; 700
CY of offsite soils that exceed the soil PRGs, and disposal of
the soil hot spot areas into a TSCA or hazardous waste landfill
and the soils that exceed the soil PRGs (to include the TPH hot
spot soils) into a solid waste landfill. Figure 8.9.4.1 depicts
the components of alternative 4. A solid waste landfill was
selected for the soils that exceed the soil PRGs because the
material is not anticipated to be a characteristic hazardous
waste from previous TCLP analyses (refer to section 6.0).
Confirmation sampling will be conducted during RD/RA to confirm
the appropriate disposal option. Removal and disposal of soils
that exceed PRGs eliminate potential exposures to contaminants at
the site and migration of contaminants to other media.
Alternative 4 includes partial excavation in the debris area to
remove approximately 2,000 CY of debris and place a cap over the
remainder of the debris area. The LNAPL is expected to be mixed
with the debris and located above the buried concrete slab. The
2,000 CY of excavated debris is expected to contain 600 CY of
saturated LNAPL debris and 1,400 CY of soil. The volume of
partial excavation was derived by estimating the amount of soil
and debris above the buried concrete slab. The LNAPL saturated
debris will be disposed in a TSCA landfill due to the potential
for the presence of PCBs and it is anticipated that the soils
will be disposed in a solid waste landfill. The soil will be
sampled during excavation, to determine if a solid waste landfill
is appropriate or whether TSCA or hazardous waste landfill
disposal is appropriate. A compacted soil/clay cap of a 2.5-ft
thickness will be placed over 2,000 SY of the buried debris
area. The cap includes 6 inches of topsoil and revegetation over
the compacted clay layer. The removal of the LNAPL-saturated
debris will reduce contaminant migration to ground water and
subsurface soils. The cap prevents direct exposure to the buried
debris area.
8.9.4.2 LNAPL
Alternative 4 includes installation of a network of 7, 125-ft
long and 9, 85-ft long 20-ft deep trenches and 16 extraction
sumps for LNAPL extraction. Skimmers will be used in conjunction
with extraction sumps to remove the LNAPL. In addition to the
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trenches, it is anticipated that the soil excavations will yield
water and LNAPL mixtures. Additional LNAPL will be recovered
using absorbent materials in the open soil excavations. The
extraction system will be operated for 3 years to remove the
extractable LNAPL. Extractable LNAPL is defined as measurable
LNAPL greater than 0.02 ft in thickness. It is estimated that
this process will remove approximately 80% of the estimated LNAPL
quantity of 10,000 gallons. During installation of the
extraction trenches and excavation of the soils, approximately 40
percent of the LNAPL will be directly removed. LNAPL floating
on water in the open trenches during excavation will be removed
with absorbent material. The trench extraction system is
estimated to removed approximately 40% of the LNAPL. The
remaining LNAPL, approximately 20%, will be sorbed to subsurface
soils and is not anticipated to migrate. The recovered LNAPL
shall be sent to an offsite incinerator for treatment.
Approximately 300 drums have been estimated to carry the LNAPL to
an offsite incinerator. Approximately 600 CY of soils saturated
with LNAPL (generated during trench installation) and 400 CY of
direct excavation of LNAPL during soil excavation, and about
twice the amount of absorbent materials as alternatives 2 and 3
shall be treated via thermal desorption onsite or disposed in a
TSCA or hazardous waste landfill. LNAPL extraction minimizes
contaminant migration and reduces potential subsurface soil and
ground water contamination.
8.9.4.3 Ground Water
Alternative 4 includes the installation of a network of
approximately 40 sparging wells, completed below the water table,
to inject air into the dissolved plume area to strip the
chemicals from the water. Four (4) vapor extraction wells will
be installed to recover the injected air and vapors. The system
will be constructed as four separate modules, each with a
compressor to deliver air to 10 wells and a blower to provide a
vacuum to one extraction well. The sparging wells will consist
of 2-inch PVC installed to a depth of 60 ft, and will deliver
approximately 15 cubic ft per minute (cfm) to the saturated zone.
The compressor for each module is rated at 150 cfm (10 wells at
15 cfm each). Each extraction well will be completed of
stainless steel to a depth of 15 ft, and will be designed to
extract the air introduced by the sparging wells using a blower
rated at 300 cfm.
The cuttings generated during the drilling of the sparging and
extraction wells will be disposed of offsite in a solid waste
landfill; confirmation sampling will determine if hazardous waste
disposal is required. If the system performs as anticipated, the
sparging will reduce the toxicity, mobility and volume of the
constituents by removing them from the ground water and
preventing potential exposure. It is anticipated that amounts
below the State of Utah de minimis amount or health-based
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exposure limits of vapor emissions will be released into the
atmosphere, based upon preliminary design of the system during
the FS. These limits will be revisited and verified during the
remedial design of the system.
The location of the four modules that make up the air
sparging/vapor extraction system will be determined during RD/RA,
but will be located to address the plume area shown in Figure
8.9.4.1.
8.9.4.4 Implementation and Cost
The excavation and appropriate offsite disposal of the soil hot
spots (200 CY), soils onsite that exceed soil PRGs (21,000 CY),
and soils offsite that exceed soil PRGs (700 CY) will be
completed in less than six months. The excavation of the buried
debris will occur simultaneously with the excavation of the other
soils.
Soil excavation onsite will be conducted after the removal of the
tanks, liner, concrete slab and wall, and prior to the
construction of LNAPL trenches, and capping of buried debris
area. The trenches will be impacted by neither cap construction,
nor the cap impacted by the trenches, because the trenches will
be completely backfilled and as structurally capable as natural
subgrade material.
Regrading and placement of the soil cover over the buried debris
area will occur after the LNAPL system is installed within the
period of one year.
LNAPL extraction system installation will be conducted after hot
spot removal and excavation of soils that exceed the soil PRGs.
The recoverable LNAPL is expected to be collected within 3 years
based on the conceptual design developed in the FS.
Air sparging/vapor extraction is expected to be effective in
meeting the ground water PRGs within seven years.
Material, equipment, and specialists are readily available to
implement this remedy.
O&M includes 3 years operating and maintenance costs for the
LNAPL extraction system and seven years operation of the ground
water air sparging/vapor extraction system. The 30-year present
worth cost for Alternative 4 is $10,900,000 and includes
$7,200,000 in capital costs and $3,700,000 in O&M costs. The
following costs are calculated equivalent to, but are not
included in the 30-year PWC: arsenic treatment is estimated to
cost $3,600,000. The contingency for organics was not estimated
for this alternative because air sparging is expected to control
the ground water plume.
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8.9.4.5 Other Components
Institutional controls including a fence, and warning signs will
be used during the remedy, however, no institutional controls
will be necessary after the remedy is complete.
During excavation activities, dust and odors will be controlled
with foam. Air monitoring will be conducted during the soils
excavation onsite and offsite to ensure compliance with air
quality requirements. Workers at the site will be required to
wear personal protective equipment to protect them from potential
contaminant exposure.
No long-term monitoring is required for the soils. LNAPL and
ground water long-term monitoring will occur at least once each
year for 30 years or until the site contaminants meet the
performance standards or indefinitely if the remedy has a
containment component. The actual number of samples, location of
sampling, sampling techniques, contaminants to be analyzed,
analytical methods, and frequency of samples, etc. will be
determined under a Compliance Monitoring Program that will be
developed during remedial design. An estimated cost for
monitoring has been estimated for purposes of comparing and
selecting an alternative for cleanup.
The chemical-, location-, and action-specific ARARs identified in
Table 8.4 would be met. The offsite disposal facility may
require that the waste meet land disposal restrictions (LDRs);
this is not anticipated to be a problem because (1) it is
expected that the waste already meets LDRs, (2) a treatability
variance could be obtained for waste that does not meet LDRs, and
(3) the continuing revisions to the RCRA requirements for
contaminated media may significantly alter the regulatory scheme
at the time of cleanup. Excavation and landfilling of the former
UST #2 soils will comply with relevant and appropriate Utah
regulatory UST requirements.
Because the air sparging/vapor extraction system is expected to
remediate the ground water in seven years, the waste is
considered left on the site for that period of time and thus the
site is subject to five-year reviews.
8.9.5 Remove/Thermal Treatment of Soils that Exceed PRGs;
Partial Removal/Containment of Buried Debris; Remove/Treat 80%
LNAPL; Intrinsic Remediation of Ground Water; and Access
Restrictions, and Land Use Restrictions (Alternative 5)
8.9.5.1 Soils (to include Buried Debris)
Alternative 5 includes excavation of 200 CY of soil hot spots
areas; 21,000 CY of onsite soils that exceed the soil PRGs
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(includes 130 CY of TPH hot spot soils); 700 CY of offsite soils
that exceed the soil PRGs, and thermal desorption onsite using a
mobile thermal desorption unit. Figure 8.9.5.1 depicts the
components of alternative 5. The thermal desorption includes
mixing and soil handling to ensure optimal moisture content.
There are no anticipated treatment residuals associated with
thermal desorption as the bag house residuals will be worked back
into soils and thermal processes. Scrubber water, if a scrubber
is necessary, will be used as quench and evaporated. If
residuals are generated and cannot be addressed as described, bag
house waste will be characterized and disposed of offsite in
either a solid or hazardous waste landfill. Scrubber water will
be either treated onsite and discharged or transported offsite
for disposal. Treatment of soil hot spots areas and soils on-
and offsite that exceed the soil PRGs, eliminates potential
exposures to contaminants at the site and migration of
contaminants to other media.
Alternative 5 includes partial excavation in the debris area to
remove approximately 2,000 CY of LNAPL and placement of a cap
over the remainder of the debris area. The LNAPL is expected to
be mixed with the debris and located above the buried concrete
slab. The 2,000 CY of excavated debris is expected to consist of
approximately 600 CY of saturated LNAPL debris and 1,400 CY of
soil. The volume of partial excavation was derived by estimating
the amount of soil and debris above the buried concrete slab, as
shown in Figures 6.1.1.3.A and B. The LNAPL saturated debris
will be disposed in a TSCA landfill due to potential for PCBs and
it is anticipated that the soils will be treated by direct
thermal desorption in the onsite mobile unit. A compacted
soil/clay cap of a 2.5-ft thickness will be placed over 2,000 SY
of the buried debris area. The cap includes 6 inches of topsoil
and revegetation over the compacted clay layer. The removal of
the LNAPL-saturated debris will reduce contaminant migration to
ground water and subsurface soils. The cap prevents direct
exposure to the buried debris area.
8.9.5.2 LNAPL
Alternative 5 is the same as Alternative 4, with one exception.
The overburden of LNAPL saturated soils will be disposed in a
TSCA or hazardous waste landfill and not treated in the onsite
mobile thermal desorption unit.
8.9.5.3 Ground Water
Alternative 5 has the same components with respect to ground
water remediation as alternatives 2 and 3.
8.9.5.4 Implementation and Cost
The excavation and thermal desorption of the soil hot spots (200
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CY), soils onsite that exceed soil PRGs (21,000 CY), and soils
offsite that exceed soil PRGs (700 CY) will be conducted
concurrently with LNAPL extraction and is anticipated to be
complete within one year. The excavation of the buried debris
will occur simultaneously with the excavation of the other soils.
Soil excavation will be conducted after the removal of the liner,
tanks, concrete slab and wall, and before the construction of
LNAPL trenches, and capping of buried debris area. The trenches
will be impacted by neither cap construction, nor the cap
impacted by the trenches, because the trenches will be completely
backfilled and as structurally capable as natural subgrade
material.
Regrading and placement of the soil cover over the buried debris
area will occur after the LNAPL'system is installed within the
period of one year.
LNAPL extraction will be conducted concurrently with soils and
excavation and thermal treatment. The recoverable LNAPL is
expected to be collected within 3 years based on the conceptual
design developed in the FS.
Intrinsic remediation/attenuation is expected to be effective in
meeting the ground water PRGs within 10 years.
Material, equipment, and specialists are readily available to
implement this remedy.
O&M includes maintenance of the buried debris cap and 3 years of
operating the LNAPL extraction system. The 30-year present worth
cost for Alternative 5 is $9,800,000 and includes $3,600,000 in
capital costs and $6,200,000 in O&M costs. The following costs
are calculated equivalent to, but are not included in the 30-year
PWC: arsenic treatment is estimated to cost $3,600,000 and
containment and treatment of organic contaminants is expected to
cost $3,400,000.
8.9.5.5 Other Components
Institutional controls including a fence, warning signs, and
water use restrictions will be installed and implemented during
the remediation to eliminate exposure. Water use restrictions
will include coordination with the Utah Department of
Environmental Quality and the Utah State Engineer to restrict
water usage and prohibit well drilling on the site and in the
vicinity of the plume, except for remedial purposes. The person
performing the function of the Utah State Engineer is either the
Regional and/or State Engineer with the Division of Water Rights,
within the Utah Department of Natural Resources.
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During excavation activities, dust and odors will be controlled
with foam. Air monitoring will be conducted during the soils
excavation onsite and offsite and during thermal desorption
onsite to ensure compliance with air quality requirements.
Workers at the site will be required to wear personal protective
equipment to protect them from potential contaminant exposure.
No long-term monitoring is required for the soils. LNAPL and
ground water long-term monitoring will occur at least once each
year for 30 years or until the site contaminants meet the
performance standards or indefinitely if the remedy has a
containment component. The actual number of samples, location of
sampling, sampling techniques, contaminants to be analyzed,
analytical methods, and frequency of samples, etc. will be
determined under a Compliance Monitoring Program that will be
developed during remedial design. An estimated cost for
monitoring has been estimated for purposes of comparing and
selecting an alternative for cleanup.
The chemical-, location-, and action-specific ARARs identified in
Table 8.4 would be met. Air emission standards and ARARs
regarding thermal desorption will be met. The offsite disposal
facility may require that the waste meet land disposal
restrictions (LDRs); this is not anticipated to be a problem
because (1) it is expected that the waste already meets LDRs, (2)
a treatability variance could be obtained for waste that does not
meet LDRs, and (3) the continuing revisions to the RCRA
requirements for contaminated media may significantly alter the
regulatory scheme at the time of cleanup. Excavation and thermal
desorption of the former UST #2 soils will comply with relevant
and appropriate Utah regulatory UST requirements.
Waste is considered left on the site. Thus, the site is subject
to five-year reviews.
8.9.6 Remove/Thermal Treatment of Soils that Exceed PRGs;
Remove/Treat 100% LNAPL; Remove/Treat/Dispose Buried Debris;
Intrinsic Remediation of Ground Water; and Access and Land Use
Restrictions (Alternative 6)
8.9.6.1 Soils (to include Buried Debris)
With respect to the soils, alternative 6 is the same as
alternative 5. Figure 8.9.6.1 depicts the components of
alternative 6.
Alternative 6 includes excavation of approximately 14,000 CY of
the buried debris, disposal of the debris in a TSCA or hazardous
waste landfill and onsite thermal desorption of the soils.
Approximately one third or 4,000 CY of the excavated material is
anticipated to be debris and the remaining 10,000 CY is
anticipated to be soil. Excavation of the debris area, TSCA or
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hazardous waste disposal and thermal desorption of the debris and
soils will reduce the mobility, toxicity and volume of
contaminants.
8.9.6.2 LNAPL
Alternative 6 includes direct excavation of approximately 3,000
CY of LNAPL saturated soils, removal of LNAPL from water in open
excavations with absorbent material and skimmers, and offsite
incineration of the LNAPL. The basis of design is to remove,
through direct excavation, the soils saturated with LNAPL and
associated overburden of approximately 17,000 CY which is present
in the area where the LNAPL thickness is greater than 0.02 ft.
The overburden soils will be used as backfill. It is anticipated
that no water will be pumped from the excavation, but rather the
design is focussed to remove only LNAPL via skimming and the use
of absorbent materials. The 3,000 CY of saturated soils and
absorbent materials will be thermally desorbed onsite. The
volume of absorbent materials to be used for capturing the LNAPL
is expected to be 5 times the amount in alternatives 2 and 3 and
2 1/2 times the amount in alternatives 4 and 5. It is the goal
of this design to capture and/or recover 100 percent of the
LNAPL, however, it should be noted that when the thickness of the
LNAPL is less than 0.02 ft or the ability to perform direct
excavation cannot be done without demolition to the existing
infrastructure or buildings then recovery will not occur. The
recovered LNAPL shall be sent to an offsite incinerator for
treatment. Approximately 300 drums have been estimated to carry
the LNAPL to an offsite incinerator. LNAPL removal minimizes
contaminant migration and reduces potential subsurface soil and
ground water contamination.
8.9.6.3 Ground Water
Alternative 6 has the same components with respect to ground
water remediation as alternatives 2, 3 and 5.
8.9.6.4 Implementation and Cost
The excavation and thermal desorption of the soil hot spots (200
CY), soils onsite that exceed soil PRGs (21,000 CY), and soils
offsite that exceed soil PRGs (700 CY) will be conducted
concurrently with LNAPL excavation and is anticipated to be
completed within one year and possibly within six months. The
excavation of the buried debris will occur simultaneously with
the excavation of the other soils.
Prior to excavation of soils, the liner, concrete wall and slab,
and two tanks will be removed and disposed at a TSCA or hazardous
waste facility. Approximately 600 CY of soils excavated during
the tank removal will be thermally treated onsite.
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Direct excavation of LNAPL is anticipated to remove as much of
the LNAPL as feasible within one year.
Intrinsic remediation/attenuation is expected to be effective in
meeting the ground water PRGs within 10 years.
Material, equipment, and specialists are readily available to
implement this remedy.
O&M includes the operation of the onsite thermal desorption unit
for a period of one year and monitoring. The 30-year present
worth cost for Alternative 6 is $14,200,000 and includes
$6,900,000 in capital costs and $7,300,000 in O&M costs. The
following costs are calculated equivalent to, but are not
included in the 30-year PWC: arsenic treatment is estimated to
cost $3,600,000, and containment and treatment of organic
contaminants is expected to cost $3,400,000.
8.9.6.5 Other Components
Institutional controls including a fence, warning signs, and
access restrictions will be installed and administered during the
implementation of the soils (to include buried debris) and LNAPL
remedy. Water use restrictions will include coordination with
the Utah Department of Environmental Quality and the Utah State
Engineer to restrict water usage and prohibit well drilling on
the site and in the vicinity of the plume, except for remedial
purposes. The person who performs the function of the Utah State
Engineer is either the Regional and/or State Engineer with the
Division of Water Rights, within the Utah Department of Natural
Resources.
The excavation of the buried debris area will be performed using
a vapor enclosure to control potential dust, organic vapor, or
odor emissions.
During excavation activities, dust and odors will be controlled
with foam. Air monitoring will be conducted during the soils
excavation onsite and offsite and during thermal desorption
onsite to ensure compliance with air quality requirements.
Workers at the site will be required to wear personal protective
equipment to protect them from potential contaminant exposure.
No long-term monitoring is required for the soils or LNAPL.
Ground water long-term monitoring will occur at least once each
year for 30 years or until the site contaminants meet the
performance standards. The actual number of samples, location of
sampling, sampling techniques, contaminants to be analyzed,
analytical methods, and frequency of samples, etc. will be
determined under a Compliance Monitoring Program that will be
developed during remedial design. An estimated cost for
monitoring has been estimated for purposes of comparing and
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selecting an alternative for cleanup.
The chemical-, location-, and action-specific ARARs identified in
Table 8.4 would be met. Air emission standards and ARARs
regarding thermal desorption will be met. The offsite disposal
facility may require that the waste meet land disposal
restrictions (LDRs); this is not anticipated to be a problem
because (l) it is expected that the waste already meets LDRs, (2)
a treatability variance could be obtained for waste that does not
meet LDRs, and (3) the continuing revisions to the RCRA
requirements for contaminated media may significantly alter the
regulatory scheme at the time of cleanup. Excavation and thermal
desorption of the former UST #2 soils will comply with relevant
and appropriate Utah regulatory UST requirements.
Because waste is left on the site, the site is subject to five-
year reviews.
8.9.7 Remove/Thermal Treatment of Soils that Exceed PRGs;
Remove/Treat 100% LNAPL; Remove/Treat/Dispose Buried Debris;
Treat Ground Water in POTW; and Access and Land Use Restrictions
(Alternative 7)
8.9.7.1 Soils (to include Buried Debris)
With respect to the soils, alternative 7 is the same as
alternatives 5 and 6. Figure 8.9.7.1 depicts the components of
alternative 7 and 8.
With respect to buried debris, alternative 7 has the same
components as alternative 6.
8.9.7.2 LNAPL
Alternative 7 has the same components as alternative 6.
8.9.7.3 Ground Water
Alternative 7 includes extraction of ground water at 40 to 100
gallons per minute (gpm) to ensure contaminant plume containment,
and water treatment, if necessary, will be performed with UV
oxidation. Disposal of the water will be via discharge to the
POTW. It is anticipated that POTW treatment standards will be
similar to those already in place at the site; if so, onsite
treatment of the water will not be necessary to meet those
standards. An onsite treatment system (UV oxidation) is included
to allow for onsite treatment. An EPA batch flushing modeling
approach, discussed in EPA guidance on remedial actions for
contaminated sites (EPA, 1988), was used to estimate the number
of pore volumes that must be removed for remediation.
Calculations are available within the FS that show that 40 to 100
gpm will capture the plume, however, the final pumping rate will
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be determined as part of RD. It is also currently anticipated
that one ground water extraction well installed in the former
tank farm area will control the impacted plume area, however, the
actual number of wells(s) and location of the wells will be
determined during RD. The generated water, approximately
3,000,000 to 4,000,000 gallons per month, can be accepted by the
local POTW (Salt Lake City Water Reclamation Plant), according to
the Pretreatment Administrator and the Plant Manager. Discharge
to and treatment by the POTW, if it performs as anticipated, will
reduce the mobility, toxicity and volume of contamination.
8.9.7.4 Implementation and Cost
The excavation and thermal desorption of the soil hot spots (200
CY), soils onsite that exceed soil PRGs (21,000 CY), and soils
offsite that exceed soil PRGs (700 CY) will be conducted
concurrently with LNAPL excavation and is anticipated to be
completed within one year and possibly within six months. The
excavation of the buried debris will occur simultaneously with
the excavation of the other soils.
Prior to excavation of soils, the liner, concrete wall and slab,
and two tanks will be removed and disposed at a TSCA or hazardous
waste facility. Approximately 600 CY of soils excavated during
the tank removal will be thermally treated onsite.
Direct excavation of LNAPL is anticipated to remove as much of
the LNAPL as feasible within one year.
Ground water extraction and POTW discharge is expected to be
effective in meeting the ground water PRGs within six years.
However, the ground water treatment model that was used to derive
the number of years may be overly aggressive due to the
assumptions made within the model so the performance period has
been extended to 20 years.
Material, equipment, and specialists are readily available to
implement this remedy.
O&M includes the operation of the onsite thermal desorption unit
for a period of one year; discharge costs to POTW, compliance
monitoring, and extraction pumping for 20 years; and monitoring.
The O&M costs for the onsite UV oxidation treatment are not
included because they will not be required because the current
concentration of the contaminants is acceptable to the local
POTW. If UV oxidation treatment is needed, it will double the
cost of treatment. The 30-year present worth cost for
Alternative 7 is $16,600,000 and includes $6,800,000 in capital
costs and $9,800,000 in O&M costs. Alternative 7 does include a
contingency measure for arsenic treatment, if concentrations
exceed either the ground water PRGs or the treatment capacity of
the POTW. The 30-year PWC for the arsenic contingency is
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$900,000 because the ground water remedy already includes the
well installation, groundwater extraction, and treatment.
8.9.7.5 Other Components
Institutional controls including a fence, warning signs, and
access restrictions will be installed and administered during the
implementation of the soils (to include buried debris) and LNAPL
remedy. Water use restrictions will include coordination with
the Utah Department of Environmental Quality and the-Utah State
Engineer to restrict water usage and prohibit well drilling on
the site and in the vicinity of the plume, except for remedial
purposes. The person performing the function of the Utah State
Engineer is either the Regional and/or State Engineer with the
Division of Water Rights, within the Utah Department of Natural
Resources.
The excavation of the buried debris area will be performed using
a vapor enclosure to control potential dust, organic vapor, or
odor emissions.
During excavation activities, dust and odors will be controlled
with foam. Air monitoring will be conducted during the soils
excavation onsite and offsite and during thermal desorption
onsite to ensure compliance with air quality requirements.
Workers at the site will be required to wear personal protective
equipment to protect them from potential contaminant exposure.
No long-term monitoring is required for the soils or LNAPL.
Ground water long-term monitoring will occur at least once each
year for 30 years or until the site contaminants meet the
performance standards. The actual number of samples, location of
sampling, sampling techniques, contaminants to be analyzed,
analytical methods, and frequency of samples, etc. will be
determined under a Compliance Monitoring Program that will be
developed during remedial design. An estimated cost for
monitoring has been estimated for purposes of comparing and
selecting an alternative for cleanup.
The chemical-, location-, and action-specific ARARs identified in
Table 8.4 would be met. Air emission standards and ARARs
regarding thermal desorption will be met. The offsite disposal
facility may require that the waste meet land disposal
restrictions (LDRs); this is not anticipated to be a problem
because (1) it is expected that the waste already meets LDRs, (2)
a treatability variance could be obtained for waste that does not
meet LDRs, and (3) the continuing revisions to the RCRA
requirements for contaminated media may significantly alter the
regulatory scheme at the time of cleanup. Excavation and thermal
desorption of the former UST #2 soils will comply with relevant
and appropriate Utah regulatory UST requirements.
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Waste is considered left on the site and thus the site is subject
to five-year reviews.
8.9.8 Remove/Thermal Treatment of Soils that Exceed PRGs;
Remove/Treat 100% LNAPL; Remove/Treat/Dispose Buried Debris;
Treat Ground Water on Site via Ultraviolet Oxidation; and Access
and Land Use Restrictions (Alternative 8)
8.9.8.1 Soils (to include Buried Debris)
With respect to the soils, alternative 8 is the same as
alternatives 5, 6 and 7.- Figure 8.9.7.1 depicts the components
of alternative 8.
With respect to buried debris, alternative 8 has the same
components as alternatives 6 and 7.
8.9.8.2 LNAPL
Alternative 8 has the same components as alternatives 6 and 7.
8.9.8.3 Ground Water
Alternative 8 includes similar components as described in
alternative 7 with an increased extraction of ground water at 500
gpm to ensure contaminant plume containment, and water treatment,
if necessary, with UV oxidation. The treated water will be
reinjected into the aquifer. An onsite treatment system (UV
oxidation) is included to allow for onsite treatment. An EPA
batch flushing modeling approach, discussed in EPA guidance on
remedial actions for contaminated sites (EPA, 1988), was used to
estimate the number of pore volumes that must be removed for
remediation. Calculations are available within the FS that show
that 500 gpm will capture the plume, however, the final pumping
rate will be determined as part of RD. It is also currently
anticipated that two ground water extraction wells will be
installed, at a total extraction rate of 500 gpm, however, the
actual number of wells and location of the wells will be
determined during RD. The generated water, approximately
22,000,000 gallons per month, will be reinjected, after treatment
to meet the ground water PRGs, into the aquifer via four
injection wells. The treatment system includes chemical
treatment for removal of organics. Inorganic treatment
components, with special emphasis on arsenic, will be added if
the inorganic concentrations exceed the ground water PRGs.
Treatment and reinjection, if it performs as anticipated, will
reduce the mobility, toxicity and volume of contamination.
8.9.8.4 Implementation and Cost
The excavation and thermal desorption of the soil hot spots (200
CY), soils onsite that exceed soil PRGs (21,000 CY), and soils
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offsite that exceed soil PRGs (700 CY) will be conducted
concurrently with LNAPL excavation and is anticipated to be
completed within one year and possibly within 6 months. The
excavation of the buried debris will occur simultaneously with
the excavation of the other soils.
Prior to excavation of soils, the liner, concrete wall and slab,
and two tanks will be removed and disposed at a TSCA or hazardous
waste facility. Approximately 600 CY of soils excavated during
the tank removal will be thermally treated onsite.
Direct excavation of LNAPL is anticipated to remove as much of
the LNAPL as feasible within one year.
Ground water extraction, treatment and reinjection are expected
to be effective in meeting the ground water PRGs within 6 years.
However, the ground water treatment model that was used to derive
the number of years may be overly aggressive due to the
assumptions made within the model so the performance period has
been extended to 20 years.
Material, equipment, and specialists are readily available to
implement this remedy.
O&M includes the operation of the onsite thermal desorption unit
for a period of one year; operation of treatment facilities and
reinjection; compliance monitoring, and extraction pumping for 20
years; and monitoring. The 30-year present worth cost for
Alternative 8 is $24,400,000 and includes $7,200,000 in capital
costs and $17,200,000 in O&M costs. Alternative 8 does include a
contingency measure for arsenic treatment, if concentrations
exceed either the ground water PRGs or the treatment capacity of
the POTW. The 30-year PWC for the arsenic contingency is
$900,000 because the ground water remedy already includes the
well installation, groundwater extraction, and treatment.
8.9.8.5 Other Components
Institutional controls including a fence, warning signs, and
access restrictions will be installed and administered during the
implementation of the soils (to include buried debris) and LNAPL
remedy. Water use restrictions will include coordination with
the Utah Department of Environmental Quality and the Utah State
Engineer to restrict water usage and prohibit well drilling on
the site and in the vicinity of the plume, except for remedial
purposes. The person performing the function of the Utah State
Engineer is either the Regional and/or State Engineer with the
Division of Water Rights, within the Utah Department of Natural
Resources.
The excavation of the buried debris area will be performed using
a vapor enclosure to control potential dust, organic vapor, or
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odor emissions.
During excavation activities, dust and odors will be controlled
with foam. Air monitoring will be conducted during the soils
excavation onsite and offsite and during thermal desorption
onsite to ensure compliance with air quality requirements.
Workers at the site will be required to wear personal protective
equipment to protect them from potential contaminant exposure.
No long-term monitoring is required for the soils or LNAPL.
Ground water long-term monitoring will occur at least once each
year for 30 years or until the site contaminants meet the
performance standards. The actual number of samples, location of
sampling, sampling techniques, contaminants to be analyzed,
analytical methods, and frequency of samples, etc. will be
determined under a Compliance Monitoring Program that will be
developed during remedial design. An estimated cost for
monitoring has been estimated for purposes of comparing and
selecting an alternative for cleanup.
The chemical-, location-, and action-specific ARARs identified in
Table 8.4 would be met. Air emission standards and ARARs
regarding thermal desorption will be met. The offsite disposal
facility may require that the waste meet land disposal
restrictions (LDRs); this is not anticipated to be a problem
because (1) it is expected that the waste already meets LDRs, (2)
a treatability variance could be obtained for waste that does not
meet LDRs, and (3) the continuing revisions to the RCRA
requirements for contaminated media may significantly alter the
regulatory scheme at the time of cleanup. Excavation and thermal
desorption of the former UST #2 soils will comply with relevant
and appropriate Utah regulatory UST requirements.
Waste is considered left on the site. Thus, the site is subject
to five-year reviews.
8.9.9 Remove/Dispose Hot Spot Soils; Landfann Soils that Exceed
PRGs; Remove/Dispose Buried Debris; Remove/Dispose 100% LNAPL;
Intrinsic Remediation of Ground Water; and Access and Land Use
Restrictions (Alternative 9)
8.9.9.1 Soils (to include Buried Debris)
Alternative 9 includes excavation of 440 CY of soil hot spot
areas (to include soils that exceeds 50,000 mg/kg TPH); and
excavation and direct biological treatment (land farming) of
approximately 21,000 CY of soils onsite and 700 CY offsite that
exceed soil PRGs. Approximately 200 CY of soil exceeding soil
hot spot criterion is anticipated to contain PCBs and will be
disposed in a TSCA landfill. Approximately 240 CY of soils
exceeding TPH of 50,000 mg/kg will be disposed in a solid waste
landfill. Upon completion of biological treatment of
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approximately 21,700 CY, the soil will be backfilled on the site
and revegetated. Figure 8.7.9,1 shows the components of
alternative 9. The biological treatment (land farming) requires
demolition of all of the site buildings on the eastern portion of
the property.
As part of the remedial design, a study to determine the
degradation potential of the contaminants will be performed.
This study will evaluate appropriate nutrient levels and soil
moisture content, determine the presence of inhibitory
contaminants such as high metal concentrations, and determine
optimum land farming operating guidelines. To enhance the
biodegradation of hydrocarbons, organic material ("bulking
agents") may be added to the soils. A bulking factor of 30
percent has been assumed for costing purposes. An odor study
will also be conducted to evaluate potential odor emissions. If
odors are of concern, land farming will be conducted in
enclosures where odor emissions can be controlled and treated.
Costs associated with enclosing land farming operations within a
structure have not been included as odors are not expected to
warrant enclosure.
Prior to construction of the land farm all of the structures will
be removed from the eastern portion of the site. The land farm
will cover approximately a two-acre area and include a flat
impoundment lined with a synthetic liner. Soil will be excavated
and stored in a stockpile, delivered from the pile area and
dumped by positioning each load in front of the previous load to
form a continuous row of soil. The row will be graded and large
rocks will be removed. The windrows will be established by
advancing earthwork equipment used for aeration through
approximately one third of the cross-section of the soil layer.
Approximately 10,000 CY of material or one lift will be treated
every 2 years. Aeration will be achieved by mechanical methods
using earthwork equipment. The windrows will be periodically
turned and "fluffed" using this equipment. Nutrient levels will
be monitored and adjusted as needed by incorporating controlled-
released fertilizers when the rows are turned. Water will be
added by spraying the rows. The pH may be adjusted by
incorporating lime. Soil samples will be collected at the
beginning of the operation and periodically during land farming
activities to monitor the degradation progress (24 samples have
been used for costing purposes, the actual number of samples will
be determined during RD). Initial operation of the land farm may
require addition of a microbial inoculum. After one lift of soil
is treated, another lift of soil will be removed from the
stockpile and land farmed. The treated soil will be backfilled
on the site and the area revegetated.
Alternative 9 includes excavation of approximately 14,000 CY of
the buried debris, disposal of the debris in a TSCA or hazardous
waste landfill and disposal of the soils that exceed soil PRGs
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into either a TSCA, hazardous or solid waste landfill.
Approximately one third or 4,000 CY of the excavated material is
anticipated to be debris and the remaining 10,000 CY is
anticipated to be soil. Excavation of the debris area, TSCA or
hazardous waste disposal and solid waste landfill disposal of the
soils that exceed soil PRGs (to include soils that exceeds 50,000
mg/kg TPH) will reduce the mobility, toxicity and volume of
contaminants.
8.9.9.2 LNAPL
Alternative 9 has the same components with respect to LNAPL
removal as alternatives 6, 7 and 8 with the exception that
alternative 9 disposes the 3,000 CY of LNAPL-saturated soils at
an offsite permitted TSCA or solid waste landfill.
8.9.9.3 Ground Water
Alternative 9 has the same components with respect to ground
water remediation as alternatives 2, 3, 5 and 6.
8.9.9.4 Implementation and Cost
The excavation and disposal of the soil hot spots (440 CY), and
biological treatment of soils onsite that exceed soil PRGs
(21,000 CY), and soils offsite that exceed soil PRGs (700 CY)
will be conducted concurrently with LNAPL excavation. The
excavation of the soil hot spots (440 CY) will occur within 6
months. The land farming is anticipated to be completed within 6
years assuming 2 years per lift of soil. The excavation of the
buried debris will occur simultaneously with the excavation of
the other soils.
Prior to excavation of soils, the liner, concrete wall and slab,
and two tanks will be removed and disposed at a TSCA or hazardous
waste facility. Approximately 600 CY of soils excavated during
the tank removal will be disposed either in a TSCA, hazardous or
solid waste landfill.
Direct excavation of LNAPL is anticipated to remove as much of
the LNAPL as feasible within one year.
Intrinsic remediation/attenuation is expected to be effective in
meeting the ground water PRGs within 10 years.
Material, equipment, and specialists are readily available to
implement this remedy.
O&M includes the operation of the onsite land farm for a period
of 6 years and dust/odor/air monitoring. The 30-year present
worth cost for Alternative 9 is $18,000,000 and includes
$11,000,000 in capital costs and $7,000,000 in O&M costs. The
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following costs are calculated equivalent to, but are not
included in the 30-year PWC: arsenic treatment is estimated to
cost $3,600,000, and containment and treatment of organic
contaminants is expected to cost $3,400,000.
8.9.9.5 Other Components
Institutional controls including a fence, warning signs, and
access restrictions will be installed and administered during the
implementation of the soils (to include buried debris) and LNAPL
remedies. Water use restrictions will include coordination with
the Utah Department of Environmental Quality and the Utah State
Engineer to restrict water usage and prohibit well drilling on
the site and in the vicinity of the plume, except for remedial
purposes. The person performing the function of the Utah State
Engineer is either the Regional and/or State Engineer with the
Division of Water Rights, within the Utah Department of Natural
Resources.
The excavation of the buried debris area will be performed using
a vapor enclosure to control potential dust, organic vapor, or
odor emissions.
During excavation activities, dust and odors will be controlled
with foam. Air monitoring will be conducted during the soils
excavation onsite and offsite and during biological treatment of
the soils onsite to ensure compliance with air quality
requirements. The biological treatment of the soils may be
conducted in an enclosure. Workers at the site will be required
to wear personal protective equipment to protect them from
potential contaminant exposure.
No long-term monitoring is required for the soils or LNAPL.
Ground water long-term monitoring will occur at least once each
year for 30 years or until the site contaminants meet the
performance standards. The actual number of samples, location of
sampling, sampling techniques, contaminants to be analyzed,
analytical methods, and frequency of samples, etc. will be
determined under a Compliance Monitoring Program that will be
developed during remedial design. An estimated cost for
monitoring has been estimated for purposes of comparing and
selecting an alternative for cleanup.
The chemical-, location-, and action-specific ARARs identified in
Table 8.4 would be met. Air emission standards and ARARs
regarding thermal desorption will be met. The offsite disposal
facility may require that the waste meet land disposal
restrictions (LDRs); this is not anticipated to be a problem
because (1) it is expected that the waste already meets LDRs, (2)
a treatability variance could be obtained for waste that does not
meet LDRs, and (3) the continuing revisions to the RCRA
requirements for contaminated media may significantly alter the
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regulatory scheme at the time of cleanup. Excavation and thermal
desorption of the former UST #2 soils will comply with relevant
and appropriate Utah regulatory UST requirements.
Waste is considered left on the site. Thus, the site is subject
to five-year reviews.
8.9.10 Remove/Dispose Hot Spot Soils; Consolidate/Cap Soils that
Exceed PRGs; Partial Removal/Disposal of Soil and Buried Debris
and Cap Remaining Debris; Remove/Treat 100% LNAPL; Intrinsic
Remediation of Ground Water; and Access and Land Use Restrictions
(Alternative 10)
8.9.10.1 Soils (to include Buried Debris)
Alternative 10 includes excavation of 330 CY of soil hot spot
areas (includes soils exceeding 100,000 mg/kg TPH) for offsite
disposal in the appropriate permitted offsite landfill(s).
Alternative 10 also includes excavation of 7,300 CY of soil
onsite and 700 CY of soils offsite that exceed soil PRGs; and
consolidation of the excavated soil with approximately 13,700 CY
of contaminated soils in the former tank farm area under a soil
or asphalt cap. Approximately 200 CY of soil exceeding soil hot
spot criterion is anticipated to contain PCBs and will be
disposed in an offsite permitted TSCA landfill. Approximately
130 CY of soils exceeding TPH of 100,000 mg/kg (but not
containing PCBs) will be disposed of offsite in a permitted solid
waste landfill. Because a majority of the soils that exceed the
soil PRGs are located in the former tank farm area, this area was
chosen for consolidation. The areas to be excavated (and
consolidated on-site) include approximately 5,000 CY of soils on
the east and south part of the site and backfill with clean soil;
2,300 CY of soils from the former UST #2 area and backfill with
clean soil; and 700 CY of offsite soils and regrade. Prior to
soil consolidation, the two large warehouse buildings will be
demolished and disposed of in a solid waste landfill. The cover
includes either a 42-inch layer of clean soil or a 6-inch asphalt
cap. Soil depth of 42 inches is based on a frost depth of 30
inches, with sufficient extra depth to accommodate a spread
footing for a slab on grade building, and a utility installation
depth of 12 inches below the frost line based on City of Salt
Lake building permit guidelines. The cover will be placed over a
10,000 SY area (8,000 SY over the former tank farm and
warehouse area and 2,000 SY over the debris area). Figure
8.9.10.1 shows the components of alternative 10.
Alternative 10 is similar to alternative 4 which includes partial
excavation in the debris area to remove approximately 2,000 CY of
buried debris and placement of a cap over the remaining debris.
The LNAPL is expected to be mixed with the debris and located
above the buried concrete slab. The 2,000 CY of excavated debris
is expected to contain 600 CY of saturated LNAPL debris and 1,400
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CY of soil. The volume of partial excavation was derived by
estimating the amount of soil and debris above the buried
concrete slab. However, alternative 10 includes demolition and
removal of the slab and further investigation of the debris area
to ensure that all LNAPL-saturated soil and debris is excavated.
The LNAPL saturated debris will be disposed in an offsite
permitted TSCA landfill due to potential for PCBs and it is
anticipated that the soils will be disposed in an offsite
permitted solid waste landfill. The soil will be sampled during
excavation, to determine if a solid waste landfill is appropriate
or whether TSCA or hazardous waste (RCRA Subtitle C) disposal is
appropriate. For costing purposes, it has been assumed that
2,000 CY of buried debris would be disposed in a TSCA landfill.
Disposal cost of additional contamination under the slab, if any,
has not been included or estimated as part of the cost estimate.
After excavation, the 2,000 SY area will be regraded and covered
with either a 42-inch layer of clean soil or a 6-inch asphalt
cap.
8.9.10.2 LNAPL
Alternative 10 has the same components as alternatives 6, 7, 8
and 9, with the exception that alternative 10 identified a volume
of 19,000 CY of overburden and the 3,000 CY of saturated LNAPL
soils will be sent offsite for appropriate disposal (i.e., TSCA,
hazardous or solid waste permitted facility).
8.9.10.3 Ground Water
Alternative 10 has the same components with respect to ground
water remediation as alternatives 2, 3, 5, 6 and 9.
8.9.10.4 Implementation and Cost
The excavation and disposal of the soil hot spots (330 CY), and
excavation and consolidation of soils onsite that exceed soil
PRGs (21,000 CY), and soils offsite that exceed soil PRGs (700
CY) will be conducted concurrently with LNAPL excavation. The
excavation of the soil hot spots (330 CY) will occur within 6
months. The excavation of the buried debris will occur
simultaneously with the excavation of the other soils.
Prior to excavation of soils, the liner, concrete wall and slab,
and two tanks will be removed and disposed at a TSCA, hazardous
or solid waste facility. Approximately 600 CY of soils excavated
during the tank removal will be disposed either in a TSCA,
hazardous or solid waste landfill. The two large warehouse
buildings will be demolished and disposed in a solid waste
landfill.
The overburden above the LNAPL plume will be removed to
facilitate LNAPL excavation and skimming. Once the LNAPL and
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LNAPL-saturated soil have been removed, the overburden will be
backfilled and the remaining soils that exceed the soil PRGs will
be consolidated in the former tank farm area for containment
under clean soil or an asphalt cap. Direct excavation of LNAPL
is anticipated to remove as much of the LNAPL as feasible within
one year. Excavation and consolidation of the soils that exceed
soil PRGs is expected to be completed within one year.
Intrinsic remediation/attenuation is expected to be effective in
meeting the ground water PRGs within 10 years. However, if
ongoing monitoring shows that the intrinsic bioremediation is not
occurring or quantification of biodegradation of vinyl chloride
cannot be adequately performed, then the selection of intrinsic
remediation as a remediation of the contaminated ground water for
the Petrochem/Ekotek site will be reevaluated by EPA and
modifications or initiation of contingency measures may be deemed
necessary by EPA to be protective of human health and the
environment.
Material, equipment, and specialists are readily available to
implement this remedy.
O&M includes monitoring. The 30-year present worth cost for
Alternative 10 is $6,100,000 and includes $4,900,000 in capital
costs and $1,200,000 in O&M costs. The following costs are
calculated equivalent to, but are not included in the 30-year
PWC: arsenic treatment is estimated to cost $3,600,000, and
containment and treatment of organic contaminants is expected to
cost $3,400,000.
8.9.10.5 Other Components
Institutional controls including a fence, warning signs, and
access restrictions will be installed and administered during the
implementation of the soils (to include buried debris) and LNAPL
remedies and after the remedies to ensure containment of the
soils. Water use restrictions will include coordination with the
Utah Department of Environmental Quality and the Utah State
Engineer to restrict water usage and prohibit well drilling on
the site and in the vicinity of the plume, except for remedial
purposes. The person performing the function of the Utah State
Engineer is either the Regional and/or State Engineer with the
Division of Water Rights, within the Utah Department of Natural
Resources.
During excavation activities, dust and odors will be controlled
with foam. Air monitoring will be conducted during the soils
excavation onsite and offsite to ensure compliance with air
quality requirements. Workers at the site will be required to
wear personal protective equipment to protect them from potential
contaminant exposure.
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Long-term monitoring is required for the soils. Ground water
long-term monitoring will occur at least once each year for 30
years or until the site contaminants meet the performance
standards. The actual number of samples, location of sampling,
sampling techniques, contaminants to be analyzed, analytical
methods, and frequency of samples, etc. will be determined under
a Compliance Monitoring Program that will be developed during
remedial design. An estimated cost for monitoring has been
estimated for purposes of comparing and selecting an alternative
for cleanup.
The chemical-, location-, and action-specific ARARs identified in
Table 8.4 would be met. Air emission standards and ARARs
regarding thermal desorption will be met. The offsite disposal
facility may require that the waste meet land disposal
restrictions (LDRs); this is not anticipated to be a problem
because (1) it is expected that the waste already meets LDRs, (2)
a treatability variance could be obtained for waste that does not
meet LDRs, and (3) the continuing revisions to the RCRA
requirements for contaminated media may significantly alter the
regulatory scheme at the time of cleanup. Containment of soils
must meet applicable or relevant and appropriate requirements for
cover and cover maintenance.
Because waste is considered left on the site, the site is subject
to five-year reviews.
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Section 9.0
Summary of the Comparative Analysis of Alternatives
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Section 9.0
Summary of the Comparative Analysis of Alternatives
In this section, alternatives developed for the Site are
evaluated and compared to each other using the nine evaluation
criteria required by the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP; 40 CFR § 300,430) to identify
the alternative that provides the best balance among the .
criteria. The comparative analysis provides the basis for
determining which alternative presents the best balance between
the EPA's nine evaluation criteria listed below. The first two
cleanup evaluation criteria are considered threshold criteria
that must be met by the selected remedial action. The five
primary balancing criteria are balanced to achieve the best
overall solution. The final two modifying- criteria that are
considered in remedy selection are State acceptance and community
acceptance.
• Threshold Criteria
1. Overall Protection of Human Health and the
Environment assesses the protection afforded
by each alternative, considering the
magnitude of the residual risk remaining at
the site after the response objectives have
been met. Protectiveness is determined by
evaluating how site risks from each exposure
route are eliminated, reduced, or controlled
by the specific alternative. The evaluation
also takes into account short-term or cross-
media impacts that result from implementation
of the alternative remedial activity.
2. Compliance with Applicable or Relevant and
Appropriate Requirements addresses whether a
remedy will meet all Federal and State
environmental laws and/or provides grounds for a
waiver. Section 121(d) of the Superfund
Amendments and Reauthorization Act (SARA) mandates
that for all remedial actions conducted under
CERCLA, cleanup activities must be conducted in a
manner that complies with ARARs. The NCP and SARA
have defined both applicable requirements and
relevant and appropriate requirements as follows:
• Applicable requirements are those federal and state
requirements that would be legally applicable, either
directly, or as incorporated by a federally authorized
state program.
• Relevant and appropriate requirements are those federal
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and state requirements that, while not legally
"applicable," are designed to apply to problems
sufficiently similar to those encountered at CERCLA
sites that their application is appropriate.
Requirements may be relevant and appropriate if they
would otherwise be "applicable," except for
jurisdictional restrictions associated with the
requirement.
• Other requirements to be considered are federal and
state nonregulatory requirements, such as guidance
documents or criteria. Advisories or guidance
documents do not have the status of potential ARARs.
However, where there are no specific ARARs for a
chemical or situation, or where such ARARs are not
sufficient to be protective, guidance or advisories
should be identified and used to ensure that a remedy
is protective.
Primary Balancing Criteria
3. Long-Term Effectiveness and Permanence refer
to the ability of a remedy to provide
reliable protection of human health and the
environment over time. The focus of this
evaluation is to determine the effectiveness
of each alternative with respect to the risk
posed by treatment of residuals and/or
untreated wastes after the cleanup criteria
have been achieved. Several components were
addressed in making the determinations,
including:
• Magnitude of residual risk from the alternative.
• Likelihood that the alternative will meet process
efficiencies and performance specifications.
• Adequacy and reliability of long-term management
controls providing continued protection from residuals,
• Associated risks in the event the technology or
permanent facilities must be replaced.
4. Reduction of Toxicity, Mobility, or Volume Through
Treatment refers to the preference for a remedy
that reduces health hazards of contaminants, the
movement of contaminants, or the quantity of
contaminants at the Petrochem/Ekotek Site through
treatment. This criterion evaluates the
ability of the alternatives to significantly
achieve reduction of the toxicity, mobility, or
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volume of the contaminants or wastes at the site,
through treatment. The criterion is a principal
statutory requirement of CERCLA. This analysis
evaluates the quantity of contaminants treated and
destroyed, the degree of expected reduction in
toxicity, mobility, or volume measured as a
percentage of reduction, the degree to which the
treatment will be irreversible, the type and
quantity of residuals produced, and the manner in
which the principal threat will be addressed
through treatment. The risk posed by residuals
will be considered in determining the adequacy of
reduced toxicity and mobility achieved by each
alternative.
5. Short-Term Effectiveness addresses the period of
time needed to complete the remedy, and any
adverse effects to human health and the
environment that may be caused during the
construction and implementation of the remedy.
Measures to mitigate releases and provide
protection is central to this determination.
6. Implementability refers to the technical and
administrative feasibility of an alternative or a
remedy. This criterion analyzes technical
feasibility, administrative feasibility, and the
availability of services and materials. Technical
feasibility assesses the difficulty of
construction or operation of a particular
alternative and unknowns associated with process
technologies. The reliability of the technologies
based on the likelihood of technical problems that
would lead to project delays is critical in this
determination. The ability to monitor the
effectiveness of the alternative is also
considered.
Administrative feasibility assesses the ease
or difficulty of obtaining permits or rights-
of-way for construction. Availability of
services and materials evaluates the need for
off-site treatment, storage, or disposal
services, and the availability of such
services. Necessary equipment, specialists,
and additional resources are also evaluated
in determining the ease by which these needs
could be fulfilled. It also includes
coordination of Federal, State, and local
government efforts.
7. Cost evaluates the estimated capital, operation,
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and maintenance (O&M) costs of each alternative in
comparison to other equally protective
alternatives. Alternatives are evaluated for cost
in terms of both capital costs and long-term O&M
costs necessary to ensure continued effectiveness
of the alternatives. Capital costs include the
sum of the direct capital costs (materials,
equipment, labor, land purchases) and indirect
capital costs (engineering, licenses, or permits).
Long-term O&M costs include labor, materials,
energy, equipment replacement, disposal, and
sampling necessary to implement the alternative.
• Modifying Criteria
8. State Acceptance indicates whether the State
agrees with, opposes, or has no comment on the
preferred alternative.
9. Community Acceptance includes determining which
components of the alternatives interested persons
in the community support, have reservations about,
or oppose.
The strengths and weaknesses of the alternatives were weighed to
identify the alternative providing the best balance among the
nine evaluation criteria.
9.1 Detailed Analysis of Alternatives
9.1.1 Threshold Criteria
9.1.1.1 Overall Protection of Human Health and the Environment
The overall protection of human health and the environment is a
threshold criteria that must be met for EPA to select the
alternative. Protectiveness is achieved by the remedies if the
exposure pathways are either eliminated, reduced to acceptable
exposures or controlled through containment.
All of the alternatives, with the exception of alternative 1,
protect human health and the environment.
Alternatives 2, 3, 4, 5, 6, 7, 8, 9 and 10 are protective of
human health and the environment.
Alternatives 6, 7, 8 and 9 provide protectiveness by removing and
treating the soils (to include buried debris), LNAPL and ground
water.
Alternatives 3, 4 and 10 provide protectiveness by either off-
site disposal or containment on-site of the soils and treatment
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of LNAPL and ground, water.
Alternative 2 achieves protectiveness through a combination of
excavation, offsite disposal, containment and treatment to
achieve EPA's acceptable risk range for the site of 10~4 to 10"6
for the soils (to include buried debris), LNAPL and ground water.
Alternative 2 directly addresses the soils that exceed 10~4 and
contains the low-level contaminated soils (1CT4 to 10"6) onsite.
Alternative 1 does not address the soils exceeding the hot spot
criteria. Alternative 1 may also be protective in the ground
water if over time the ground water PRG for vinyl chloride can be
achieved through natural attenuation. Contamination associated
with the LNAPL is a potential source of ground water
contamination and this alternative does not address these
sources. No remedial actions to contain or remove LNAPL and the
soils that exceed the hot spot criteria are included in
alternative 1; therefore, this alternative does not address the
potential sources and is not protective of the environment.
9.1.1.1.1 Soils (to include buried debris)
Alternatives 6, 7 and 8 achieve protectiveness through a
combination of off-site disposal and on-site thermal treatment of
the soils to achieve a 10~6 risk level within one year.
Alternative 9 uses a combination of disposal and biological
treatment (land farming) of the soils to achieve a 10"s in
approximately six years.
Alternatives 3, 4 and 10 achieve protectiveness through off-site
disposal of the soils exceeding the hot spot criteria and on-site
containment of the same volume of soils treated under
alternatives 6, 7, '8 and 9.
Alternative 2 achieves protectiveness through excavation and
thermal treatment of the soils that exceed 10~4 risk and places a
cover over the low-level contaminated soils (within the 10~4 to
ICf6 risk range) in the former tank farm area to control and
limit exposure to these soils.
9.1.1.1.2 LNAPL
The percentages of LNAPL removal is approximate and reflects the
methods that will be used to extract the LNAPL. Direct
excavation is the most aggressive method and is expected to
extract as much of the LNAPL as feasible thus rendering a
description of approximately 100 percent recoveries. The other
method uses trenches, sumps and pumps to extract LNAPL and is
less successful, thus resulting in reduced percentages of
recovery.
Alternatives 6, 7, 8, 9 and 10 achieve protectiveness by removing
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virtually 100 percent of the LNAPL through a combination of
excavation, disposal and treatment via thermal desorption onsite
and incineration offsite within one year. Little residual, if
any, is expected to remain onsite..
Alternative 4 addresses a smaller percent (e.g., 80 percent) of
the LNAPL through a combination of removal, disposal and
treatment. Some residual is expected to remain onsite, however,
migration of the LNAPL is not expected to occur.
Alternatives 2 and 3 remove, dispose and treat a smaller percent
(e.g., 75 percent) of the LNAPL. Some residual is expected to
remain onsite, however, migration of the LNAPL is not expected to
occur.
9.1.1.1.3 Ground Water
The feasibility study states that alternatives 7 and 8 will
achieve 10~5 ground water PRGs through physical treatment within
six years. Alternative 4 will achieve 10"6 ground water PRGs
through air sparging within seven years. Alternatives 2, 3, 5,
6, 9 and 10 will achieve 10"6 ground water PRGs through intrinsic
remediation/attenuation within ten years.
Although it is helpful to have restoration timeframes estimated,
it is inappropriate to give excessive weight to these timeframes
given their relative similarity and the degree of uncertainty in
the parameters used to derive these timeframes. All of the
alternatives except Alternative 1 include contingency measures.
All of the ground water remedies are protective of human health
and the environment.
9.1.1.2 Compliance with Applicable or Relevant and Appropriate
Requirements
Compliance with applicable or relevant and appropriate
requirements (ARARs) is a threshold criteria that must be met by
the selected remedy. Compliance with ARARs requires that the
remedy comply with the substance of the environmental Federal
and State laws that address the circumstances of the site and the
remediation.
All of the alternatives, with the exception of alternative 1,
comply with Applicable or Relevant and Appropriate Requirements -
(ARARs).
Contingency measures have been developed for containment of the
ground water plume and treatment of arsenic so that all
alternatives can achieve the ARARs, except the No Further Action
Alternative. Alternatives 4, 7 and 8 do not require the
containment contingency measure but do require the arsenic
contingency measure. Alternatives 2, 3, 5, 6, 9 and 10 require
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both the containment and arsenic contingency measures.
9.1.2 Balancing Criteria
The balancing criteria include long-term effectiveness and
permanence; reduction of toxicity, mobility, or volume through
treatment; short-term effectiveness; implementability; and cost.
The remedial alternatives were evaluated and ranked as to how the
balancing criterion are achieved with respect to the response
actions taken within the three media (i.e., soils, LNAPL and
ground water). To adequately address the balancing criteria,
there must be an understanding of the relative risk among the
media. The contaminants within the soils represent a low-level
threat (i.e., 9.75 x 10"5) . The contaminants within the LNAPL
represent a principal threat. The contaminants within the ground
water represent a risk greater than EPA's upper boundary of the
acceptable risk range (i.e., 10~4 ) .
9.1.2.1 Long-term Effectiveness and Permanence
Long-term effectiveness and permanence are evaluated as the
reliability of protection over time. The alternatives will be
ranked as to the time it takes to achieve long-term effectiveness
and permanence, the permanence of the treatment, effectiveness of
the technology and the amount of residuals left onsite.
EPA's acceptable risk range is 10~4 - 10"6. To be considered
protective, the remedies must protect within this range.
Alternatives 6, 7, 8, 9 and 10 achieve the highest overall level
of long-term effectiveness and permanence by permanently removing
the principal threat and potential source of the ground water
contamination through direct excavation of the LNAPL. All of the
alternatives, with the exception of alternative 1, achieve the
same level of ground water long-term effectiveness. Alternatives
6, 7, 8 and 9 treat the low-level contaminated soils.
Alternative 10 achieves protectiveness through containment on-
site by placing the low-level contaminated soils under a 42-inch
soil cap or 6 inch asphalt cap.
9.1.2.1.1 Soils (to include buried debris)
All of the alternatives, with the exception of the No Further
Action alternative, remove soils that exceed 10"4 so that the
remaining soils are considered low-level contaminated soils.
Actions are taken to either treat, dispose, or contain the
remaining low-level contaminated soils (within 10~4 - 10"6) .
Alternatives 5, 6, 7, and 8 achieve the highest degree of long-
term effectiveness through permanent treatment of the soils.
Alternatives 5, 6, 7, and 8 thermally desorb the soils that
exceed soil PRGs and dispose the soils that exceed soil hot spot
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criteria offsite within one year. Thermal desorption of these
soils is permanent and is not expected to result in residual risk
either through the treatment residuals or lack of completeness of
treatment of the soils to 10~6. The disposal of the soils that
exceed soil hot spots criteria permanently removes the risk posed
by these soils from the site.
Alternative 9 also achieves a high degree of long-term
effectiveness through permanent treatment of the soils; however,
the effectiveness of land farming has not been demonstrated for
this site and thus is not considered as effective as the proven
technology of thermal desorption used in alternatives 5, 6, 7 and
8. Alternative 9 biologically treats through land farming the
soils that exceed soil PRGs to 10~6 risk and disposes the soils
that exceed soil hot spot criteria offsite. The land farming
degradation of the soils is permanent and takes six years. The
disposal of the soils that exceed soil hot spots criteria
permanently removes the risk posed by these soils from the site.
Alternative 4 also has a high degree of long-term effectiveness
through disposal offsite. Offsite disposal removes the risk from
the site by transporting that risk to a controlled facility
(e.g., solid waste landfill). It does permanently remove the
risk from the site but offsite disposal is not considered
preferable to treatment. Alternative 4 removes, and disposes
offsite, soil that exceed the soil hot spot criteria and soils
that exceed the soil PRGs. The disposal of these soils offsite
permanently removes the risk posed by these soils from the site
so that no remaining risks from the soils exist.
Alternative 2 provides a medium degree of long-term effectiveness
because it uses a combination of treatment, and containment or
control technologies and institutional controls to prevent
exposure to the low-level contaminated soils within large areas
of the site. Alternative 2 thermally desorbs 330 CY of hot spot
surface soil; 2,300 CY of soils associated with the former UST #2
exceeding soil PRGs; and 700 CY of offsite soils exceeding soil
PRGs to attain the soil PRGs of 10"6 risk within one year.
Thermal desorption of these soils is permanent and is not
expected to result in residual risk either through the treatment
residuals or lack of completeness of treatment of the soils to
10~6. The low-level contaminated soils in the former tank farm
and buried debris areas are contained with soil covers and a
slurry wall. The containment of the soils that exceed the soil
PRGs using caps and slurry wall is not permanent and relies upon
continued maintenance to remain effective. The remaining soils
within EPA's acceptable risk range of 10"4 to 10"6 are not
covered.
Alternatives 3 and 10 provide the lowest degree of long-term
effectiveness because they rely upon a combination of offsite
disposal, containment or control technologies and institutional
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controls to prevent exposure to low-level contaminated soils
within large areas of the site. Alternatives 3 and 10
consolidate and contain the soils that exceed the soil PRGs and
dispose the soils that exceed soil hot spot criteria offsite.
The disposal of the soils that exceed soil hot spots criteria
permanently removes the risk posed by these soils from the site.
The containment of the remaining soils within EPA's acceptable
risk range of 10"4 to 10"6 which exceeds the soil PRGs uses soil
covers and slurry walls which are not permanent and rely upon
continued maintenance to remain effective.
Alternative 1 provides no long-term effectiveness as no actions
will be taken to contain, remove, reduce, immobilize or treat the
contaminants that contribute to risk in the soils.
9.1.2.1.2 LNAPL
Of the three media evaluated, the LNAPL and LNAPL saturated soils
contribute the greatest risk to the site. Alternatives 6, 7, 8,
9 and 10 provide the greatest degree of long-term effectiveness
through a combination of on- and offsite treatment of LNAPL and
soils saturated with LNAPL. Alternatives 6, 7, 8, 9 and 10
remove and treat approximately 100 percent of the LNAPL and LNAPL
saturated soils via either onsite thermal desorption of LNAPL
saturated soils or offsite disposal and offsite incineration of
LNAPL. Thermal desorption of the LNAPL saturated soils is
permanent and is not expected to result in residual risk either
through the treatment residuals or lack of completeness of
treatment of the LNAPL saturated soils to 10"6. The removal of
LNAPL saturated soils through offsite disposal is considered
permanent. The removal offsite and incineration of the LNAPL
will permanently reduce the risk posed by the LNAPL from the
site.
Alternatives 4 and 5 provide a medium degree of long-term
effectiveness through partial on- and offsite treatment of the
soils saturated with LNAPL and LNAPL. Alternatives 4 and 5
partially remove and treat approximately 80 percent of the LNAPL
offsite via incineration. The excavated soils saturated with
LNAPL from the construction of the trenches will be thermally
desorbed onsite. The removal and treatment of the LNAPL offsite
permanently reduce the risk to the site, however, residual risk
remains from approximately 20 percent of the unrecovered LNAPL
and from the soils saturated with LNAPL that were not encountered
during construction and therefore not treated via thermal
desorption.
Alternatives 2 and 3 provide the lowest degree of long-term
effectiveness because they treat less contaminants than the other
alternatives. Alternatives 2 and 3 partially remove and treat
approximately 75 percent of the LNAPL offsite via incineration.
The excavated soils saturated with LNAPL from the construction of
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the trenches will be thermally desorbed onsite. The removal and
treatment of the LNAPL offsite permanently reduce the risk to the
site; however, residual risk remains from approximately 25
percent of the unrecovered LNAPL and from the soils saturated
with LNAPL that were not encountered during construction and
therefore not treated via thermal desorption.
Alternative 1 provides no long-term effectiveness as no actions
will be taken to contain, remove, reduce, immobilize or treat the
contaminants associated with and in the LNAPL that contribute to
risk in the ground water.
9.1.2.1.3 Ground Water
All the alternatives achieve long-term effectiveness through the
reduction of the concentrations of the contaminants in the ground
water to 10~6 risk.
Although it is helpful to have restoration timeframes estimated,
it is inappropriate to give excessive weight to these timeframes
for ranking purposes given their relative similarity and the
degree of uncertainty in the parameters used to derive these
timeframes. All of the ground water remedies provide long-term
effectiveness.
There are two contingency measures that will be initiated if any
of the ground water remedies fail to either contain the ground
water plume or treat arsenic that exceeds the ground water PRGs,
so that all alternatives can achieve long-term effectiveness.
Alternatives 4, 7 and 8 do not require the containment
contingency measure but do require the arsenic contingency
measure. Alternatives 2, 3, 5, 6, 9 and 10 require both the
containment and arsenic contingency measures to contain the plume
or treat the contamination to the ground water PRGs. These
contingencies add time to the restoration but will achieve long-
term effectiveness over time.
Alternative 1 provides no long-term effectiveness as no actions
will be taken to contain, remove, reduce, immobilize or treat the
contaminants that contribute to risk in the ground water plume.
9.1.2.2 Reduction of Toxicity, Mobility and Volume Through
Treatment
The alternatives are ranked according to the reduction of
toxicity, mobility, or volume through treatment. Those remedies
that include treatment of the larger quantities of contaminants
are ranked higher than other alternatives.
Alternatives 6, 7, 8 and 9 achieve the highest overall degree of
reduction of toxicity, mobility and volume (TMV) through
treatment by reducing the toxicity and volume of a larger volume
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of contaminants than the other alternatives.
9.1.2.2.1 Soils (to include buried debris)
Thermal desorption of the soil reduces the toxicity by destroying
the contaminants that contribute to risk. Thermal desorption of
these soils is permanent and is not expected to result in
residual risk either through the treatment residuals or lack of
completeness of treatment of the soils to 10~6.
Alternatives 5, 6, 7, and 8 achieve the highest degree of
reduction of TMV through treatment of approximately 22,000 CY of
low-level contaminated soils. Alternatives 5, 6, 7, and 8
thermally desorb the soils that exceed soil PRGs and dispose of
the soils that exceed soil hot spot criteria offsite within one
year. Thermal desorption of the soil reduces the toxicity by
destroying the contaminants that contribute to risk. The
disposal of the soils that exceed soil hot spots criteria reduces
the volume of the contaminants onsite.
Alternative 9 also achieves a high degree of reduction of TMV
through treatment of approximately 22,000 CY of low-level
contaminated soils; however, the effectiveness of land farming
has not been demonstrated for this site and thus is not
considered as effective as the proven technology of thermal
desorption used in alternatives 5, 6, 7 and 8. Alternative 9
biologically treats (land farming) the soils that exceed soil
PRGs to 10" risk and disposes of the soils that exceed soil hot
spot criteria offsite. The land farming degradation of the soils
reduces the toxicity of the contaminants by changing the
contaminants via degradation to less toxic constituents. The
disposal of the soils that exceed soil hot spot criteria reduces
the volume of the contaminants onsite.
Alternative 4 has a medium degree of reduction of TMV through
treatment by reducing the volume of contaminants onsite by
disposing approximately 22,000 CY of low-level contaminated soils
offsite. Offsite disposal reduces the volume of the contaminants
onsite by transporting soils that exceed the soil PRGs to a
controlled facility (e.g., solid waste landfill). Offsite
disposal is not considered preferable to treatment. Alternative
4 removes and disposes offsite soils that exceed the soil hot
spot criteria and soils that exceed the soil PRGs. The disposal
of these soils offsite reduces the volume of contaminants onsite.
Alternative 2 provides a medium degree of reduction of TMV
through treatment. Alternative 2 reduces toxicity through
treatment, and reduces mobility through containment. Alternative
2 uses a combination of treatment, and containment or control
technologies and institutional controls to prevent exposure to
low-level contaminated soils within large areas of the site.
Alternative 2 thermally desorbs 330 CY of hot spot surface soil;
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2,300 CY of soils associated with the former UST #2 exceeding
soil PRGs; and 700 CY of offsite soils exceeding soil PRGs to
attain the soil PRGs of 10~s risk within one year. Alternative 2
thermally desorbs a smaller amount of soils than the amount of
soil treated in alternatives 5, 6, 7, 8 and 9. The soils within
EPA's acceptable risk range of 10~4 to 10~6 in the former tank
farm and buried debris areas are contained with soil covers and a
slurry wall. The containment of the soils that exceed the soil
PRGs through the use of soil covers and slurry walls reduce the
mobility of the contaminants in the soils. The remaining soils
within EPA's acceptable risk range of 10~4 to 10~6 are not
covered.
Alternatives 3 and 10 provide no degree of reduction of TMV
through treatment. Alternatives 3 and 10 rely upon a combination
of offsite disposal, containment or control technologies and
institutional controls to prevent exposure to large areas of the
site. Alternatives 3 and 10 consolidate and contain the soils
that exceed the soil PRGs and dispose the soils that exceed soil
hot spot criteria offsite. Offsite disposal reduces the volume
of the contaminants onsite by transporting soils that exceed the
soil PRGs to a controlled facility (e.g., solid waste landfill).
Offsite disposal is not considered preferable to treatment.
Alternative 3 contains the low-level contaminated soils with a
slurry wall and soil/clay cap. Alternative 10 contains the low-
level contaminated soils under a 42 inch soil cover.
Consolidation and containment reduce the mobility of the soils
that exceed the soil PRGs, however, this reduction of mobility is
not achieved through treatment.
Alternative 1 provides no reduction of TMV through treatment as
no actions will be taken to contain, remove, reduce, immobilize
or treat the contaminants that contribute to risk in the soils.
9.1.2.2.2 LNAPL
Of the three media evaluated, the LNAPL and LNAPL saturated soils
contribute the greatest risk to the site, thus the treatment of
the LNAPL provides the greatest degree of reduction of TMV
through treatment. Alternatives 6, 7, 8, 9 and 10 achieve the
highest degree of reduction of TMV through treatment with a
combination of on- and offsite treatment of LNAPL and soils
saturated with LNAPL. Alternatives 6, 7, 8, 9 and 10 remove and
treat approximately 100 percent of the LNAPL and LNAPL saturated
soils via either onsite thermal desorption or offsite disposal of
LNAPL saturated soils and offsite incineration of LNAPL. Thermal
desorption of the soil reduces the toxicity by destroying the
contaminants that contribute to risk. The removal of the LNAPL
for offsite incineration reduces the volume of contamination on
site but also permanently reduces the toxicity of the
contaminants by thermal destruction.
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Alternatives 4 and 5 achieve a medium degree of reduction of TMV
through treatment by reducing the toxicity and volume of the
contaminants within the LNAPL. Alternatives 4 and 5 removes
approximately 80 percent of the LNAPL at the site. The LNAPL is
sent offsite to an incinerator. The removal of the LNAPL reduces
the volume of contaminants at the site. The excavated soils
saturated with LNAPL from the construction of the trenches will
be thermally desorbed onsite. Thermal desorption of the soil
reduces the toxicity by destroying the contaminants that
contribute to risk. The removal and treatment of the LNAPL
offsite reduce the volume of contaminants on the site; however,
residual risk remains from approximately 20 percent of the
unrecovered LNAPL and from the soils saturated with LNAPL that
were not encountered during construction and therefore not
treated via thermal desorption.
Alternatives 2 and 3 achieve the lowest degree of reduction of
TMV through treatment because they treat less contaminants than
the other alternatives. Alternatives 2 and 3 partially remove
and treat approximately 75 percent of the LNAPL offsite via
incineration. The excavated soils saturated with LNAPL from the
construction of the trenches will be thermally desorbed onsite.
Thermal desorption of the soil reduces the toxicity by destroying
the contaminants that contribute to risk. The removal and
treatment of the LNAPL offsite permanently reduce the risk to the
site, however, residual risk remains from approximately 25
percent of the unrecovered LNAPL and from the soils saturated
with LNAPL that were not encountered during construction and
therefore not treated via thermal desorption.
Alternative 1 provides no reduction of TMV through treatment as
no actions will be taken to contain, remove, reduce, immobilize
or treat the contaminants associated with and in the LNAPL that
contribute to risk in the ground water.
9.1.2.2.3 Ground Water
All the alternatives achieve reduction of TMV through treatment
through the reduction of the concentrations of the contaminants
in the ground water to 10"6 risk; however, the proven
effectiveness of the technologies to achieve the 10"6 risk
differs with each type of treatment.
Alternatives 4, 7 and 8 are ranked as achieving a medium degree
of reduction of TMV through treatment for ground water. These
systems actively treat the contaminants through air sparging,
discharge to POTW, and UV oxidation/reinjection, respectively.
Although these systems are proven technologies at other Superfund
sites, the physical characteristics at the Petrochem site are not
conducive to pump and treat systems which is why this proven
technology has been given a medium ranking. It should be noted
that the contingency containment measure, if implemented, would
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be to the northwest of the site and does not share the same
physical characteristics as the area where these active treatment
systems would be implemented. Alternatives 7 and 8 achieve 10~6
risk in approximately 6 years. Alternative 4 achieves 10"6 risk
in approximately 7 years. There are no treatment residuals
associated with air sparging, discharge to POTW, and UV
oxidation/reinjection.
Alternatives 2, 3, 5, 6, 9 and 10 are ranked as achieving a
medium degree of reduction of TMV through intrinsic remediation
of ground water because intrinsic remediation/attenuation has not
been demonstrated on this site. Studies to quantify the rate of
degradation of vinyl chloride to the less toxic constituents of
ethene and ethane are part of RD. There are no treatment
residuals associated with intrinsic remediation.
One of two, or both contingency measures will be initiated if the
ground water remedies fail to contain the ground water plume
within the compliance boundary or if arsenic exceeds the ground
water PRGs within the contaminated plume. With the
implementation of one or both of the contingencies, all of the
alternatives achieve long-term effectiveness. Alternatives 4, 7
and 8 do not require the containment contingency measure but do
require the arsenic contingency measure. Alternatives 2, 3, 5,
6, 9 and 10 require both the containment and arsenic contingency
measures.
Alternative 1 provides no reduction of TMV through treatment as
no actions will be taken to contain, remove, reduce, immobilize
or treat the contaminants that contribute to risk in the ground
water plume.
9.1.2.3 Short-term Effectiveness
All of the alternatives are designed to be protective of both the
community and workers during implementation of the remedies. The
alternatives will be ranked by how quickly the remedies are
implemented and the amount of mitigating components that are
needed to ensure protectiveness or reduce exposure during
implementation. The alternatives that are achieved quickly shall
be rated as having the highest degree of short-term
effectiveness. The alternatives that require more mitigating
components than others shall be ranked lower than those that
require few mitigating components to ensure protectiveness during
implementation.
All the alternatives include the removal of the liner, concrete
wall and slab, and two tanks in the former tank farm area for
disposal at a TSCA, hazardous or solid waste facility.
Approximately 600 CY of soils excavated during the tank removal
will be disposed either in a TSCA, hazardous or solid waste
landfill.
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Alternatives 2, 3, and 10 provide the greatest overall degree of
short-term effectiveness.
9.1.2.3.1 Soils (to include buried debris)
Alternatives 2, 3, and 10 provide the greatest degree of short-
term effectiveness in that the soils remedy can be implemented
within one year and offer little exposure to the workers and
community. Alternatives 2, 3 and 10 excavate fewer CY of soil
and minimize the disruption of the area for the consolidation of
the soils that exceed the soil PRGs. These alternatives have the
least amount of exposure to the community and workers during
implementation and a lesser amount of mitigating components.
Alternative 10 includes the demolition of two buildings; however,
this activity has not been factored into short-term effectiveness
evaluation because the buildings do not pose a risk to workers.
The mitigating components include using foam to control dust and
odors during excavation and wearing personal protective
equipment.
Alternatives 4, 5, 6, 7, and 8 provide a moderate degree of
short-term effectiveness in that the soils remedy can be
implemented within one year albeit with a greater degree of
exposure to the workers and community and more mitigating
components. Alternatives 4, 5, 6, 7, and 8 disturb through
excavation approximately 22,000 CY which is at least twice as
much excavation as alternatives 2, 3, and 10.
The mitigating components include using foam to control dust and
odors during excavation and wearing personal protective
equipment. More foam will be used because a greater quantity of
soil will be excavated than specified in alternatives 2, 3, and
10. Alternatives 6, 7, and 8 also require a vapor enclosure to
control potential dust, organic vapor, or odor emissions from the
excavation of the buried debris area.
Alternative 9 offers the lowest degree of short-term
effectiveness in that biological treatment (land farming) of the
soils is expected to take six years and more mitigating
components are needed to reduce exposure during implementation.
The mitigating components include using foam to control dust and
odors during excavation and wearing personal protective
equipment. More foam will be used due to the greater quantity of
soil that will be excavated than the quantities identified in
alternatives 2, 3, and 10. Alternative 9 also requires a vapor
enclosure (the necessity of which will be determined during RD)
to control potential dust, organic vapor, or odor emissions from
the excavation of the buried debris area.
Alternative 1 was not ranked for short-term effectiveness as no
actions will be taken to contain, remove, reduce, immobilize or
treat the contaminants that contribute to risk in the soils and
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therefore time and mitigating components are not relevant.
9.1.2.3.2 LNAPL
Alternatives 6, 7, 8, 9, and 10 provide the greatest degree of
short-term effectiveness in that the LNAPL is removed through
direct excavation in less than one year. Although alternatives
6, 7, 8, 9 and 10 expose more LNAPL to the workers (100% recovery
vs. 75% or 80% recovery), the duration of the exposure is two
years less than other alternatives so the net effect is less
total exposure. The mitigating components include using foam to
control dust and odors during excavation and wearing personal
protective equipment. The thermal desorption of the soils
saturated with LNAPL will occur onsite and emissions from the
unit will be monitored throughout the duration of operations.
Alternatives 2, 3, 4, and 5 provide a moderate degree of short-
term effectiveness in that the LNAPL is exposed and treated over
a period of three years. Alternatives 2, 3, 4, and 5 use a
series of excavated trenches and extraction pumps to recover the
LNAPL. To recover approximately 75-80 percent of the LNAPL, this
system is expected to operate for three years. Workers and the
community will be exposed during operation of the system. The
mitigating components include using foam to control dust and
odors during excavation and wearing personal protective
equipment. -The thermal desorption of the soils saturated with
LNAPL will occur onsite and emissions from the unit will be
monitored throughout the duration of operations.
Alternative 1 was not ranked for short-term effectiveness as no
actions will be taken to contain, remove, reduce, immobilize or
treat the contaminants associated with the LNAPL that contribute
to risk to the ground water and therefore time and mitigating
components are not relevant.
9.1.2.3.3 Ground Water
Alternatives 2, 3, 5, 6, 9, and 10 provide the greatest degree of
short-term effectiveness through the use of intrinsic
remediation/attenuation. Intrinsic remediation/attenuation is
expected to achieve the ground water PRGs within 10 years.
Intrinsic remediation is expected to occur naturally and does not
involve mechanical activity (with the exception of enhancements,
if needed). Exposure to the' workers and the community is not
expected to occur.
Alternatives 4, 7 and 8 provide a medium degree of short-term
effectiveness in that the technologies require mechanical
activity and transfer of water to the surface where exposure may
occur. Alternative 4 uses air sparging and vapor extraction;
alternative 7 uses extraction and discharge to POTW; and
alternative 8 uses UV oxidation and reinjection to the aquifer.
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Although all of these technologies are closed systems and are not
expected to expose either the workers or the community during
implementation, the potential is greater than when compared to in
situ intrinsic remediation/attenuation.
Alternative 1 was not ranked for short-term effectiveness as no
actions will be taken to contain, remove, reduce, immobilize or
treat the contaminants in the ground water and therefore time and
mitigating components are not relevant.
9.1.2.4 Implementability
The alternatives are ranked according to difficulty of
construction or operation of the remedy; the available site-
specific data to support the likelihood of success of the remedy;
the reliability of the technologies (to include likelihood of
technical problems in the field); the ability to monitor the
effectiveness of the alternative; the reliance upon institutional
controls to maintain protectiveness; and the availability of
services, equipment and materials.
The alternatives shall be ranked with respect to each other and
not to other technologies that are not being considered at the
Petrochem/Ekotek site.
All of the alternatives have access restrictions to the site
which may include fencing, signs, security checks, etc. during
the implementation of the remedies.
Alternatives 4 and 10 are the most overall implementable
remedies.
9.1.2.4.1 Soils (to include buried debris)
Alternatives 3, 4 and 10 are the most, implementable alternatives
in that caps, slurry walls, and disposal offsite are easily
constructed with few problems in the field; have a high degree of
success; are easy to monitor; and the services, equipment and
materials are readily available. Excavation, landfill disposal,
soil covers/caps and slurry walls are all proven technologies
that have been employed at numerous Superfund sites. Soil
covers/caps and landfill disposal are more implementable than
slurry walls. Monitoring the integrity of a soil cover/cap to
contain soils is straight forward and can be completed through
visual inspections. The integrity of the slurry wall to contain
soils has to be ensured at completion of construction as visual
inspections will not be possible after construction. Monitoring
of the slurry wall to contain ground water contamination requires
strategic placement of wells and periodic sampling. If
contaminants are found outside of the slurry wall the integrity
of the wall has been breached. Alternatives 2, 3, and 10 rely
upon institutional controls to ensure protectiveness. Deed or
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water use restrictions, while a commonly utilized institutional
control to limit or restrict uses of a property, must be
coordinated with the appropriate agencies. Deed restrictions are
effective and permanent, based on their performance at other
Superfund sites, as long as proper coordination and enforcement
is maintained.
Alternatives 2, 5, 6, 7, 8, and 9 are moderately implementable
alternatives as compared to alternatives involving containment
remedies (e.g., caps and slurry walls) in that they all use
technologies that are effective but may have problems in the
field. Alternatives 2, 5, 6, and 7 use onsite thermal
desorption for the treatment of the soils. Although thermal
desorption has been used on numerous Superfund sites, the
likelihood for difficulties in the field is average and should be
anticipated. Field operations should include some time to
rectify problems. Although alternative 2 thermally desorbs at a
smaller scale (3,300 CY vs. 22,000 CY) than alternatives 5, 6, 7,
and 8, the mobilization and types of problems that will occur in
the field are expected to be similar. Alternative 9 uses
biological treatment (land farming) to treat the contaminants in
the soils. Land farming has not been demonstrated to be
effective at the Petrochem/Ekotek site. A study would have to be
conducted during RD to determine the effectiveness of land
farming and to determine the time frame for the degradation of
the contaminants in the soils to reduce the risk to 10"6.
Services, equipment and material are readily available.
Alternative 1 was not ranked for implementability as no actions
will be implemented to contain, remove, reduce, immobilize or
treat the contaminants in the soils.
9.1.2.4.2 LNAPL
Alternatives 6, 7, 8, 9 and 10 are the most implementable because
they involve direct excavation of the LNAPL and soils saturated
with LNAPL for treatment on- and offsite. The soils saturated
with LNAPL will be thermally desorbed onsite while the LNAPL will
be incinerated offsite. Direct excavation and offsite disposal
are proven technologies and experience few problems in the field.
Direct excavation is expected to recover approximately 100
percent of the LNAPL at the site. Services, equipment and
materials are readily available.
Alternatives 2, 3, 4, and 5 are moderately implementable as
compared to alternatives involving direct excavation.
Alternatives 2, 3,'4, and 5 include installation of a network of
trenches and extraction sumps to recover the LNAPL. The
excavation of the trenches is similar to direct excavation of the
LNAPL and will remove approximately 25 percent of the LNAPL. The
extraction system involves extraction sumps which may experience
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problems in the field. The operations and maintenance of the
extraction system are expected to occur over a three-year period.
Skimmers will be used in conjunction with extraction sumps to
remove the LNAPL. The direct excavation of the trenches and the
recovery of the LNAPL via extraction sumps are expected to remove
approximately 75 to 80 percent of the LNAPL at the site. The
soils saturated with LNAPL will be thermally desorbed onsite
while the LNAPL will be incinerated offsite. Services, equipment
and materials are readily available.
Alternative 1 was not ranked for implementability as no actions
will be implemented to contain, remove, reduce, immobilize or
treat the contaminants in the LNAPL that may contribute to the
risk in the ground water.
9.1.2.4.3 Ground Water
Alternative 4 is the most implementable ground water remedy.
Alternative 4 uses the proven technology of air sparging/vapor
extraction to treat the contaminants in the ground water to the
ground water PRGs. Air sparging is an insitu treatment that is
easily maintained and reliable. Services, equipment and
materials are readily available.
Alternatives 2, 3, 5, 6, 7, 9, and 10 are moderately
implementable. All of these alternatives involve technologies
that have been successful at Superfund sites. Alternatives 2, 3,
5, 6, 9, and 10 rely upon intrinsic remediation/attenuation which
has not been demonstrated to be effective at the Petrochem/Ekotek
site. If intrinsic remediation/attenuation is shown to be
effective at the Petrochem/Ekotek site however, it is expected to
be easily implementable because it is in situ and involves
minimal mechanical enhancements. Alternative 7 extracts the
contaminated ground water via pumping and discharges it to a
POTW. The POTW is a successful means of treating the ground
water once it has been extracted. It is the extraction and
capture of the contaminated ground water at the Petrochem/Ekotek
site that reduces the implementability of this technology. The
contaminated aquifer beneath the site has high hydraulic
conductivities, is shallow and lies upon a layer of geothermal
water. The geothermal water contains high TDS (salts). The
ability of the extraction system to efficiently capture the
contaminated water without mixing it with the geothermal waters
beneath may cause difficulties in the design and implementation
of alternative 7. The capture of noncontaminated waters and
geothermal waters increases the amount of water to be treated
unnecessarily and may cause treatment difficulties for the POTW.
Alternative 8 is the least implementable alternative in that UV
oxidation as the treatment component is not reliable and
maintainable in the field. Although UV oxidation has been
performed at a full-scale level at some Superfund sites, EPA has
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found that UV oxidation is one of the technologies that have the
poorest record for reliability and maintainability in the field.
Alternative 8 shares the same extraction and capture problems as
alternative 7.
Alternative 1 was not ranked for implementability as no actions
will be implemented to contain, remove, reduce, immobilize or
treat the contaminants in the ground water that may contribute to
risk.
9.1.2.5 Cost
The alternatives will be ranked in accordance with their 30-year
Present Worth Cost (PWC) which includes Capital, and Operation
and Maintenance (O&M) Costs for the combined remediation of soils
(to include buried debris), LNAPL and ground water. Judgements
will be made as to the certainty of the costs as it relates to
the characterization of the site.
The following are the costs for each of the alternatives:
• Alternative 1
- Capital Costs: $ 900,000
- Annual O&M $ 0
- 30-year PWC $ 900,000
• Alternative 2
- Capital Costs: $ 2,400,000
- Annual O&M $ 2,800,000
- 30-year PWC $ 5,200,000
• Alternative 3
- Capital Costs: $ 3,600,000
- Annual O&M $ 2,100,000
- 30-year PWC $ 5,700,000
• Alternative 4
- Capital Costs: $ 7,200,000
- Annual O&M $ 3,700,000
- 30-year PWC $10,900,000
• Alternative 5
- Capital Costs: $ 3,600,000
- Annual O&M $ 6,200,000
- 30-year PWC $ 9,800,000
• Alternative 6
- Capital Costs: $ 6,900,000
- Annual O&M $ 7,300,000
- 30-year PWC $14,200,000
• Alternative 7
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- Capital Costs: $ 6,800,000
- Annual O&M $ 9,800,000
- 30-year PWC $16,600,000
• Alternative 8
- Capital Costs: $ 7,200,000
- Annual O&M $17,200,000
- 30-year PWC $24,400,000
• Alternative 9
- Capital Costs: $11,000,000
- Annual O&M $ 7,000,000
- 30-year PWC $18,000,000
• Alternative 10
- Capital Costs: $ 4,900,000
- Annual O&M $ 1,200,000
- 30-year PWC $ 6,100,000
Alternatives 2, 3, and 10 are the least costly remedies, ranging
in PWC of $5,200,000 - $6,100,000 (within 25 percent of each
other).
Alternatives 4 and 5 are the next less costly remedies, ranging
in PWC of $9,800,000 - $10,900,000 or approximately 2 times
greater than the least costly remedies. Alternatives 4 and 5
include excavation, offsite disposal and treatment of large areas
and volumes of soil and LNAPL which introduce uncertainty due to
the potential for volume increases (greater extent of
contamination not characterized in the RI). Costs for the
excavation, offsite disposal and treatment of a greater volume
would increase the PWC for these alternatives.
Alternatives 6, 7 and 9 are in the next tier of more costly
remedies, ranging in PWC of $14,200,000 - $18,000,000 or
approximately 3 times greater than the least costly remedies.
Alternatives 6, 7 and 9 have uncertainties associated with the
cost with respect to the buried debris area. The current
estimate includes excavation of 14,000 CY; however, the extent of
contaminated soils may be greater than this estimate. Therefore
the costs associated with the buried debris may actually be
higher than estimated. Alternatives 6, 7 and 9 also include
excavation and treatment of large areas and volumes of soil and
LNAPL which introduce uncertainty due to the potential for volume
increases (greater extent of contamination not characterized in
the RI). Costs for the excavation and treatment of a greater
volume would increase the PWC for these alternatives.
Alternative 8 is the most costly remedy with a PWC of $24,400,000
which is approximately 4.5 times greater than the least costly
protective remedy (i.e., alternative 2). There may be
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uncertainty associated with this cost with respect to the buried
debris area. The current estimate includes excavation of 14,000
CY; however, the extent of contaminated soils may be greater than
this estimate. Therefore, the costs associated with the buried
debris may actually be higher than estimated. Alternative 8 also
includes excavation and treatment of large areas and volumes of
soil and LNAPL which introduces uncertainty due to the potential
for volume increases (greater extent of contamination not
characterized in the RI). Costs for the excavation and treatment
of a greater volume would increase the PWC for this alternative.
9.1.3 Modifying Criteria
State and community acceptance are modifying criteria that shall
be considered in the remedy selection.
9.1.3.1 State Acceptance
EPA received comment from the Director of the State of Utah,
Department of Environmental Quality, Division of Environmental
Response and Remediation. The State supports the selection of
alternative 7, which was identified in the Proposed Plan and at
the July 26, 1995 public meeting as EPA's preferred alternative.
9.1.3.2 Community Acceptance
Community input on the alternatives was solicited by EPA and UDEQ
during the public comment period from July 10, 1995 through
October 23, 1995. Comments received from the public were mixed
in their support for different alternatives.
The Salt Lake City-County Health Department Division of
Environmental Health supports the selection of alternative 7.
The following local governments, citizen groups and persons
support the selection of alternative 6:
• The Capitol Hill Neighborhood Council/TAG
• The Community Action Program
• Salt Lake City Mayor Deedee Corradini
• Sierra Club Utah Chapter
• Ten residents of Swedetown
The following citizen groups and persons support the selection of
alternative 10:
• Salt Lake Area Chamber of Commerce
• Representative from Woodward-Clyde
• Representative from ITEX
• Member of Capital Hill Community
• Representative from Morrison Knudsen Corporation
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The following PRP groups support the selection of alternative 10:
• Ekotek Site Remediation Committee and its
de minimis settlors
• One hundred and eleven Liaison Defendants in civil
action, Ekotek Site PRP Committee v. Self et al..
Civil No. 94-C-277K, US District Court, Utah
• Kennecott Utah Copper Corporation
Additional public comment received by EPA criticizes EPA,
questions the results of the Aquifer Characterization Report and
suggests that settlors be reimbursed for paying more than their
proportion of the total costs.
Responses to the community and PRP comments are found in the
Responsiveness Summary in Section 13.0 of this ROD.
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Section 10.0
Selected Site Remedy
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Section 10.0
Selected Site Remedy
Upon consideration of the requirements of CERCLA, the detailed
analysis of the alternatives, and State and public comments, the
EPA, in consultation with UDEQ and having considered UDEQ's
comments submitted supporting selection of Alternative 7, has
determined that the most appropriate remedy for the Site is
Alternative 10 - Remove/Dispose Hot Spot Soils; Consolidate/Cap
Soils that Exceed PRGs; Partial Removal/Disposal of Soil and
Buried Debris and Cap Remaining Debris; Remove/Treat 100% LNAPL;
Intrinsic Remediation of Ground Water; and Access and Land Use
Restrictions for the Petrochem/Ekotek site located in Salt Lake
City, Utah.
The purpose of this response action is to eliminate the pathway
of direct exposure to soils of an industrial worker through
excavation and offsite disposal of hot spot soils; containment
onsite of low-level contaminated soils under 42-inch soil cap;
eliminate partitioning of LNAPL to the ground water through
removal and treatment of LNAPL; and eliminate the potential
future ingestion of contaminated drinking water through intrinsic
remediation/attenuation of the ground water.
All specified volumes are estimates derived from the data
collected during the RI/FS and are intended to be approximate
volumes for the development of the remedial alternatives. The
actual volumes will be determined during the RA and will include
the extent of contamination as defined by the performance
standards. For example, volume of soils will be defined by the
soil volume that exceeds the soil hot spot criteria or soil
performance standards.
Section 10.1 Components of the Selected Site Remedy
The components of the selected remedy are described and are
detailed below:
Demolition
• The liner, concrete wall and slab, and two 1,000 gallon
capacity tanks will be removed from the former tank farm
area for disposal in a TSCA, or RCRA hazardous or solid
waste permitted landfill.
• The main warehouse and metal warehouse buildings shown on
Figure 2-2 will be demolished and disposed off-site in a
permitted RCRA Subtitle D solid waste landfill.
Soils and Buried Debris
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Soils are classified into three types. Each type has distinct
remediation requirements. Figure 8.9.10.1 illustrates the soils
and debris to be remediated.'
Hot Spots. Hot spots are soils exceeding the Hot Spot
Performance Standards specified in Section 10.1.2. Based upon
the RI/FS data, a total of 330 CY of soil is estimated to exceed
these levels. It is believed that 200 CY of the 330 CY contains
PCBs which requires off-site disposal to a permitted TSCA
landfill. The remaining 130 CY of hot spot soils will be
disposed in an off-site RCRA permitted Subtitle D solid waste
landfill.
Soils in the former tank farm. An estimated 13,700 CY of soils
in the former tank farm exceeds the Soil Performance Standards
listed in Section 10.1.2. Other soils described below also
exceeding soil performance standards will be consolidated with
these soils on the former tank farm. Clean soil at a depth of 42
inches will be placed on top of all these soils after
consolidation. This soil cover will extend over an estimated
10,000 SY (8,000 SY over the former tank farm and 2,000 SY
over the debris area).
Soils outside the former tank farm exceeding soil performance
standards. An estimated additional 7,300 CY of on-site soils
exceeds PRGs, including approximately 5,000 CY in the eastern and
southern parts of the site and 2,300 CY in the former #2 UST
area. And an additional 700 CY of soils immediately adjacent to
the northern boundary of the facility also exceed PRGs. All
soils exceeding soil performance standards will be excavated and
consolidated on the former tank farm and covered with 42 inches
of clean soil as described above. The excavations will be
backfilled with clean soil and regraded.
An estimated 2,000 CY of mixed debris and soil will also be
remediated. Of this, 600 CY of debris is believed to overlie the
buried concrete slab and are saturated with LNAPL. This
saturated debris will be excavated and disposed in a TSCA
landfill due to the potential that it contains PCBs. The
remaining 1,400 CY of soil will be disposed offsite at a TSCA or
RCRA Subtitle D solid waste permitted landfill, depending on
whether it contains PCBs. The slab will be removed and disposed
in a RCRA Subtitle D solid waste permitted landfill. Any LNAPL-
saturated soil or debris underlying the slab will be disposed in
the same manner as that overlying the slab.
LNAPL
An estimated 3,000 CY of LNAPL-saturated soils, predominately in
the former tank farm area and distinct from soils in the former
tank farm area exceeding soil performance standards but not
saturated with LNAPLs (Figure 6.1.2.2 deplicts the areal extent
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of the LNAPL), will be excavated and disposed off-site at a TSCA,
or RCRA permitted Subtitle C or Subtitle D facility, as required
by the level of contamination in those soils. LNAPL from this
and any other excavation where it is encountered in a thickness
at or exceeding 0.02 feet will be recovered and sent off-site for
incineration. It is the goal of this design to capture and/or
recover 100 percent of the LNAPL, however, it should be noted
that when the thickness of the LNAPL is less than 0.02 ft or the
ability to perform direct excavation cannot be done without
demolition to the existing infrastructure or buildings then
recovery will not occur. LNAPL removal is intended to remove the
source of ground water contamination.
These LNAPL-saturated soils underlie approximately 19,000 CY of
soil. The RI/FS data show the 19,000 CY of soil to within the
risk range of 10~4 to 10~6 to the industrial worker. This
overburden shall be excavated and stockpiled during the direct
excavation of the 3,000 CY of LNAPL-saturated soils. The
stockpiles shall be sampled to ensure that soils exceeding the
hot spot performance standards are disposed at. an off-site
permitted landfill. A sampling plan will be developed during
remedial design.
Ground Water
The ground water performance standards as described below in
Section 10.1.2, shall be achieved within the ground water through
intrinsic remediation/attenuation which is a combination of
biodegradation, dispersion, dilution, and adsorption. Intrinsic
remediation/attenuation is expected to effectively reduce
contaminants in the ground water to concentrations protective of
human health (i.e., ground water performance standards) in a
timeframe comparable to that which could be achieved through
active restoration. The active restoration timeframes for ground
water treatment components for this site have been estimated not
to exceed 10 years.
Determining the existence and effectiveness of the biodegradation
component of intrinsic remediation/attenuation is a necessary
part of this remedy. Presently, it is believed by the PRPs that
the plume is being degraded via intrinsic remediation at a higher
rate than the flow of ground water, thereby containing
contaminants on the site. Existing data will be reviewed and
additional data will be collected during the implementation of
this remedy to verify that intrinsic remediation is containing
and degrading contaminants within the ground water plume. The
scope of the additional data collection is described in Section
10.1.1.
Previously Generated Removal/Remedial Waste
All wastes associated with the Emergency Surface Removal Action
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(ESRA) and the remedial investigation shall be removed for off-
site disposal or treatment in the local POTW, respectively. The
ESRA waste shall be disposed, as appropriate, in a permitted RCRA
hazardous waste landfill.
Performance and Compliance Monitoring
A performance and compliance monitoring program shall be
developed for both the soils (to include buried debris) and
ground water (to include LNAPL) media to determine the
effectiveness and completeness of the removal and containment
components of the remedy, and the effectiveness of intrinsic
remediation/attenuation of the ground water.
A soil sampling performance plan shall be developed to confirm
that the excavations outside the former tank farm area encompass
the extent of soils exceeding the soil performance standards; to
monitor and mitigate contaminant releases during excavation of
soils and buried debris; to ensure that the soils contained under
the 42-inch clean soil cover do not exceed the soil hot spot
performance standards; to confirm that the recoverable LNAPL has
been recovered; to confirm that LNAPL-saturated soils has been
excavated for offsite disposal; and to determine the appropriate
off-site disposal destination (i.e., incinerator, TSCA, RCRA
Subtitle C or Subtitle D permitted landfills) of all waste
leaving the site. A soil compliance monitoring plan shall be
developed to ensure the effectiveness and integrity of the 42-
inch clean soil cover.
A ground water monitoring plan shall be developed to fully
characterize the extent and nature of the existing offsite
contaminant migration including further delineation of the
compliance boundary; to ensure that the current extent of the
contaminated ground water plume does not further migrate; and to
determine the impacts of the off-site TCA plume upon the
remediation of the onsite contaminated ground water.
The compliance boundary shall be established during the
remediation of the ground water to ensure that the contaminants
within the ground water do not migrate at concentrations above
the ground water performance standards beyond this boundary. Its
purpose is to ensure protection of the ground water outside the
area of contamination. The compliance boundary is a physical
boundary that is delineated as the present extent of migration of
the site contaminants at concentrations defined by the ground
water performance standards (see Figure 6.1.3.2). The precise
location of the compliance boundary shall be delineated during
remedial des ign.
Notwithstanding the establishment of the compliance boundary
during the remedial design, the selected remedy of intrinsic
bioremediation must meet the ground water performance standards
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throughout the contaminant plume within the time frame set forth
above.
The Region VIII Superfund performance monitoring guidance for
ground water remedies shall be used to develop the ground water
monitoring plan.
The frequency, locations, constituents, sampling methods,
detection limits, analytical methods, etc. and explicit details
of the soil and ground water monitoring plans for performance and
compliance, and for long-term ground water monitoring will be
determined during Remedial Design (RD).
Institutional Controls
Institutional controls are nonengineering methods for preventing
or limiting access to or use of a site. Such controls shall be
implemented as part of the selected remedy to ensure the
effectiveness and protectiveness of the remedy and to prevent or
prohibit all activities that would in any way reduce or impair
the effectiveness and protectiveness of the remedy. All measures
shall be effectively administered, maintained and enforced.
Institutional controls including a fence, warning signs, and
access "use" restrictions shall be installed and administered
during and after the implementation of the soils (to include
buried debris) and LNAPL remedy. Access and land use
restrictions, to ensure no future activity takes place at the
Site that is incompatible or inconsistent with the selected
remedy, shall be established that will run with the land. Water
use restrictions shall include coordination with the Utah
Department of Environmental Quality and the Utah State Engineer
to restrict water usage and prohibit well drilling on the site
and in the vicinity of the plume, with the exception of wells
needed for remedial purposes, during the remediation of the
contaminated ground water. The person who performs the function
of the Utah State Engineer is either the Regional and/or State
Engineer with the Division of Water Rights, within the Utah
Department of Natural Resources.
10.1.1 Additional Data Collection
Additional data collection is required as part of the intrinsic
remediation remedy to demonstrate quantitatively that vinyl
chloride is degrading to the less toxic constituents of ethane
and ethene. ESRC agreed to collect qualitative data to determine
whether ethane and ethene can be detected in the field and
initiated collection of this data in November 1995. Additional
methods shall be developed to detect the low levels of ethane and
ethene. If the results of this data collection render detections
of ethane and ethene, further studies shall be initiated as part
of the selection of intrinsic remediation as a remedy to quantify
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the rate of degradation of vinyl chloride to ethane and ethene.
An approach to quantify the degradation of vinyl chloride to
ethane and ethene through the use of a tracer test has been
developed. The tracer test shall involve the following steps:
(1) Develop a 3-D picture of contaminant distribution
necessary to achieve the design and implementation of a
tracer test. The purpose is to determine if there are
layers of high vinyl chloride concentration and to more
accurately determine the depth at which VC resides,
especially in relation to the geothermal water. This
includes sampling at multiple depths within the
aquifer, using an ultra-low flow sampling pump, to
sample discrete aquifer intervals, coupled with
downhole flow meter measurements. This discrete
sampling approach and flow monitoring at various depths
within the well are designed to define if there are
zones or intervals of varying flow rate and contaminant
distribution. The sampling method will.minimize any
vertical flow in the borehole. The sampling and flow
monitoring will be done for a subset of existing wells.
A number of five wells are believed to be sufficient,
however, the quality of the data as defined by EPA will
determine whether this number is adequate.
(2) Perform a tracer test. The purpose of the test is
to monitor the behavior of vinyl chloride relative to a
conservative tracer such as bromide. The test will be
done using a tight horizontal and vertical grid or
array of temporary Geoprobe points so that the exact
flow direction and degree of dispersion/mixing that are
occurring in the area of the plume can be defined. A
conservative tracer will be injected upgradient using
an existing well. The tracer test results will then be
used to normalize the vinyl chloride data, so that
vinyl chloride breakdown can be accurately tracked.
The above paragraphs describe an approach that was derived during
discussions with the Ekotek Site Remediation Committee (ESRC).
The Responsible Party(s) performing the remedial design may
develop a comparable approach with the objective to quantify the
degradation of vinyl chloride to ethane and ethene. The
comparable approach shall be fully described by the Responsible
Party(s) in a work plan to be approved by EPA during remedial
design.
10.1.2 Performance Standards and Compliance Boundary During
Remediation
The selected remedy for soils (to include buried debris) and
ground water (to include LNAPL) shall fully comply with,
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achieves, and maintain the performance standards described in
this subsection. A listing of the performance standards for the
selected remedy is located in Table 10.1.2. The soil hot spot
performance standards are defined below.
10.1.2.1 Soil Hot Spot Performance Standards
The soil hot spot performance standards are a combination of PRGs
and ARARs and are provided below:
• Benzo(a)anthracene - 780 mg/kg;
• Benzo(a)pyrene - 78 mg/kg;
• Benzo(b)fluoranthene - 780 mg/kg;
• Dibenz(a,h)anthracene - 78 mg/kg;
• Indeno(1,2,3-c,d)pyrene - 780 mg/kg;
• PCBs - 10 mg/kg;
2,3,7,8-TCDD(TEF) - 0.186 ug/kg; and
• Thallium - 160 mg/kg
• Total petroleum hydrocarbon (TPH) - 100,000 mg/kg
Soil hot spot standards establish .the levels of soils that must
be excavated and shipped for offsite disposal to a TSCA-permitted
facility, RCRA hazardous waste disposal facility or RCRA Subtitle
D permitted solid waste landfill. If during the field sampling
the soils are determined to be free of PCBs, it may be determined
that the hot spot soils are more suitable for disposal at an off-
site permitted RCRA Subtitle C hazardous waste landfill or
Subtitle D solid waste landfill.
10.1.2.2 Soil Performance Standards
The soil performance standards were derived from a combination of
the soil PRGs and ARARs. The soil performance standards are as
follows:
• Benzo(a)anthracene - 7.8 mg/kg;
• Benzo(a)pyrene - 0.78 mg/kg;
• Benzo(b)fluoranthene - 3.4 mg/kg;
• Dibenz(a,h)anthracene - 0.78 mg/kg;
• Indeno(1,2,3-c,d)pyrene - 7.8 mg/kg;
• PCBs - 0.15 mg/kg;
2,3,7,8-TCDD(TEF) - 1.86E-06 mg/kg; and
• Thallium - 160 mg/kg
The soil performance standards represent the levels of protection
that must be achieved through containment of the low-level
contaminated soils, i.e., any soils above this, but below the Hot
Spot performance standards shall be consolidated in the tank farm
area under a 42-inch clean soil cap.
10.1.2.3 Ground Water Performance Standards
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The ground water performance standards were derived from a
combination of the ground water PRGs and ARARs. The ground water
performance standards are as follows:
benzene - 0.005 mg/1
chloroform - 0.1 mg/1
cis-l,2-dichloroethene - 0.07 mg/1
vinyl chloride - 0.002 mg/1
benzo(b)fluoranthene - 0.0002 mg/1
antimony - 0.006 mg/1
arsenic - 0.05 mg/1
beryllium - 0.004 mg/1
manganese - 0.05 mg/1
mercury - 0.002 mg/1
nickel - 0.1 mg/1
silver - 0.05 mg/1
thallium - 0.002 mg/1
The selected remedy for ground water shall meet these ground
water performance standards.
10.1.2.4 Compliance Boundary During Remediation
A compliance boundary shall be established during the remediation
of the ground water to ensure that the contaminants within the
ground water do not migrate at concentrations above the ground
water performance standards beyond this boundary. Its purpose is
to ensure protection of the ground water outside of the area of
contamination. The compliance boundary is delineated as the
present extent of migration of the site contaminants at
concentrations defined by the ground water performance standards
(see Figure 6.1.3.2). The precise location of the compliance
boundary shall be delineated during remedial design.
Notwithstanding the establishment of the compliance boundary
during the remedial action, the selected remedy of intrinsic
bioremediation shall meet the ground water performance standards
throughout the contaminant plume within the time frame set forth
above in Section 10.1.
A monitoring system will be developed during RD and installed as
part of RA to detect migration of contaminants above the ground
water performance standards beyond the compliance boundary. In
the event that contaminants above the ground water performance
standards are detected beyond the compliance boundary, EPA, in
consultation with the State, will reevaluate the remedy and may
require that the contingency measure for containment be
activated.
10.1.3 ARARs
The Federal and State ARARs and TBCs for the selected remedy are
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listed in Table 10.1.3. The chemical-, location-, and action-
specific ARARs identified in Table 10.1.3 shall be met. Air
emission standards and ARARs regarding incineration shall be met.
The offsite disposal facility may require that the waste meet
land disposal restrictions (LDRs); this is not anticipated to be
a problem because (1) it is expected that much of the waste
already meets LDRs, (2) a treatability variance could be obtained
for waste that does not meet LDRs, and (3) the continuing
revisions to the RCRA requirements for contaminated media may
significantly alter the regulatory scheme at the time of cleanup.
Excavation and off-site disposal in a permitted TSCA, hazardous
or solid waste landfill of the former UST #2 soils will comply
with relevant and appropriate Utah regulatory UST requirements.
Some of the ARARs are discussed below.
10.1.3.1 Soils (to include buried debris)
• Toxic Substances Control Act (40 CFR Part 761, Subpart G,
PCB Spill Cleanup Policy): Due to the leaks and spills of
oil containing PCBs during the operation of the facility,
the PCB Spill Policy, 40 CFR Part 761, is relevant and
appropriate to the nonrestricted access of the industrial
worker at the Petrochem/Ekotek site. Soil that is
contaminated by PCB spills shall be decontaminated to 10 ppm
PCBs by weight provided that soil is excavated to a minimum
depth of 10 inches. The excavated soil shall be replaced
with clean soil, i.e., containing less than 1 ppm PCBs, and
the spill site shall be restored. The risk-based number of
0.15 mg/kg is more stringent and therefore is the soil
performance standard for the selected remedy (see Table
10.1.2).
• Corrective Action Management Unit - 40 CFR Part 264, Subpart
S:
The Corrective Action Management Unit (CAMU) rule has
been selected as an ARAR for the selected remedy at the
Petrochem Site. As a part of this remedy, the
Petrochem/Ekotek Site has been designated as a CAMU.
The rule, 40 CFR § 264.552(f), requires documentation
of the rationale behind the designation in accordance
with several listed criteria. The following criteria
apply as rationale for the designation in this action:
(1) The CAMU shall facilitate the implementation of
reliable, effective, protective, and cost-effective
remedies;
The CAMU approach shall achieve the above standard by
providing for consolidation of waste materials and
permanent disposal of such wastes on-site. This area
of consolidation is ideally suited for handling these
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activities in a cost-effective manner while providing
protection to human health and the environment. The
on-site repository shall also facilitate this remedial
action because it provides RCRA-quality protection for
the low-level contaminated wastes, whether they are
RCRA Subtitle C or Subtitle D wastes, while also
producing a significant cost savings over off-site
disposal.
Decontamination areas, where materials and equipment
from decommissioning and demolition activities shall be
cleaned, allow for the efficient handling of these
materials. They shall be set up to minimize, if not
completely eliminate, any potential releases into the
groundwater, air, and surface water.
Any temporary staging areas which may be needed during
the excavation and consolidation activities shall be
established within the CAMU. Measures shall be taken
to minimize the possibility of releases into
groundwater during storage.
The consolidation area shall, at a minimum, meet RCRA
solid waste landfill standards and shall utilize proven
technology to safely dispose of the contaminated soils
and sludges. Its location, in an industrial area,
allows for the long-term placement of wastes which will
not impact residential areas or use very limited off-
site RCRA storage space.
The staging and decontamination areas of the CAMU shall
be closed in a manner that will eliminate any long-term
threat. The repository area of the CAMU shall be
constructed to meet the requirements of RCRA Subtitle
D; and long-term monitoring of the groundwater and cap
maintenance shall be conducted in accordance, at
minimum, with RCRA standards.
(2) Remedial waste management: activities associated
with the CAMU shall be protective of human health and
the environment.
The remedial activities within the CAMU will be
protective of human health and the environment. The
CAMU shall be located at the Site so that it will
provide effective separation of the waste management
activities and potential off-site human receptors. A
Health and Safety Plan shall be prepared in accordance
with the Occupational Health Hazardous Waste Operations
to be protective of workers performing remedial
activities. Treatment, management and disposal of
remedial wastes within the CAMU shall eliminate any
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potential hazards that might be associated with off-
site transport, treatment, or disposal.
(3) The CAMU shall include uncontaminated areas of the
facility, only if including such areas for the purpose
of managing remediation waste is more protective than
management of such wastes at contaminated areas of the
facility.
Areas within the CAMU used for temporary staging of
waste materials prior to consolidation as well as
decontamination areas shall be located to maximize
efficient handling of waste materials excavated
pursuant to the selected remedy and to minimize impacts
to uncontaminated areas. The repository area shall be
located in an area that is presently contaminated.
(4) Areas within the CAMU, where wastes remain in place
after closure of the CAMU, shall be managed and
contained so as to minimize future releases, to the
extent practicable.
The consolidation area utilized for permanent disposal
of wastes on the site shall be capped with 42 inches of
clean soil. Soil hot spots in the consolidation area
shall be excavated and removed for off-site disposal
prior to the consolidation of other site wastes. Long-
term maintenance and monitoring of the cap are provided
as part of the selected remedy.
(5) The CAMU shall expedite the timing of remedial
activity implementation, when appropriate and
practicable.
The placement of areas within the CAMU for
decontamination and those for temporary staging and
storage in relationship to the repository shall allow
for the efficient and expedited movement, treatment and
final placement of contaminated materials.
(6) The CAMU shall enable the use, when appropriate, of
treatment technologies (including innovative
technologies) to enhance the long-term effectiveness of
remedial actions by reducing the toxicity, mobility, or
volume of wastes that will remain in place after
closure of the CAMU.
Wastes in various areas on the site, as provided in the
selected remedy, shall be tested prior to
consolidation, with soils meeting hot spot criteria
shipped for off-site disposal. Only soils within EPA's
acceptable risk range as specified in the selected
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remedy, shall be consolidated under the 42-inch soil
cover. Studies conducted under the RI/FS indicate that
there is no potential for leaching of consolidated
soils to the groundwater. Soils saturated with LNAPL
shall also be shipped off-site for disposal in a
permitted landfill. Recoverable LNAPL shall be shipped
off-site for treatment.
(7) The CAMU shall, to the extent practicable, minimize
the land area of the facility upon which wastes will
remain in place after closure of the CAMU.
The final size of the repository, which will contain
the consolidated waste, will be significantly smaller
than the current area affected by the contamination in
place, including areas of off-site soil contamination.
The drying of these materials will further reduce the
amount of repository space needed for long-term
storage. Any LNAPL-saturated soils will be shipped
off-site for disposal in a permitted landfill.
Utah Air Conservation Act (R307-1-1)s The Utah Air
Conservation Act is applicable to the quality of both
fugitive and point source emissions of hazardous air
pollutants (HAPs) and particulates. Air monitoring will be
conducted during the soils excavation to protect workers and
to ensure ambient air standards specified in Table 10.1.2
are not exceeded.
10.1.3.2 Ground Water (to include LNAPL)
• Safe Drinking Water Act, National Primary Drinking Water
Regulations (40 CFR Part 141) and Utah Safe Drinking Water
Act (UCA 19-4-101): These regulations establish health and
treatment-based standards for public drinking water systems.
These regulations are relevant and appropriate because the
shallow ground water aquifer at the site is a potential
future source of water for a public water system or private
supply well.
10.1.3.3 Five-Year Reviews
• Five-Year Review: As specified in Section 121(c) of CERCLA,
as amended by SARA, and Section 300.430(f)(4)(ii) of the
NCP, EPA will review the remedy no less often than each 5
years after the initiation of the remedial action to assure
that human health and the environment are being protected by
the implemented remedy (this review will ensure that the
remedy is protective and that institutional controls
necessary to ensure protections are in place). An
additional purpose for the review is to evaluate whether the
performance standards specified in this ROD remain
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protective of human health and the environment. EPA will
continue the reviews until no hazardous substances,
pollutants, or contaminants remain at the Petrochem/Ekotek
Site above the levels that allow for unrestricted and
unlimited industrial use of the land and unrestricted and
unlimited residential use of the ground water.
10.1.4 Contingency Measures
Two contingency measures have been developed to ensure the
protectiveness of the selected remedy.
10.1.4.1 Contingency Measure for Containment
The contingency measure for containment addresses the potential
for both offsite migration of the organic plume and the
ineffectiveness of the intrinsic remediation alternative. This
contingency provides containment, control, and treatment of the
dissolved ground water plume.
The contingencies consists of ground water extraction, water
treatment of contaminated ground water (not necessary if the POTW
is capable of accepting the untreated contaminated groundwater)
and discharged to the POTW. This contingency includes the
placement/installation of wells at and beyond (as necessary) the
compliance boundary for the purposes of pumping the ground water
at rates that would ensure capture of the migrating plume and
pretreatment of the extracted ground water, if necessary, prior
to discharge to the POTW. The exact locations and number of the
ground water wells shall be approved by EPA during the remedial
design of the selected remedy. The treatment component includes
a UV oxidation system onsite, as described in the FS for
Alternative 8. Treatment standards will be dictated by the
requirements of the POTW prior to discharge to the POTW.
The criterion for triggering implementation of the containment
contingency is either (a) a documented, consistent and verifiable
increase, as determined by EPA, in contaminant concentrations
exceeding the ground water performance standards at or beyond the
compliance boundary, which indicates that the remedy is not
managing the waste within the current extent of the contaminated
ground water plume or (b) the documented ineffectiveness, as
determined by EPA, of the remedy to affect the specified
reduction in contaminant mass within a time frame comparable to
active remediation. The criteria will be further and more
specifically developed and described in the remedial design.
The estimated cost of this contingency measure ranges from
$200,000 to $3,400,000 for a range of operating time from 0 to 30
years. Based on available existing data, the measure would not
be triggered, so the operating time is 0 years. However, to
allow for the worst cast situation of persistent offsite plume
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movement, the costs for a 30-year operating time have also been
estimated.
10.1.4.2 Contingency Measure for Arsenic Remediation.
The arsenic contingency measure consists of ground water
extraction, water treatment, if necessary, and discharge to the
POTW. The contingencies measure for arsenic remediation
addresses the concern regarding the potential for exceedance of
arsenic above its MCL of 0.05 mg/1 within the plume and migration
offsite.
This contingency includes the placement/installation of wells at
and beyond (if necessary) the compliance boundary for purposes of
pumping the ground water at rates that would ensure capture of
the migrating plume and pretreatment, if necessary, prior to
discharge to the POTW. The exact locations and number of the
ground water wells will be approved by EPA during the remedial
design of the selected remedy.
The contingency measure also applies within the plume when, as
determined by EPA, the exceedances of arsenic above the MCL are
demonstrated to be above natural background; the concentrations
and consistency of detections of arsenic above the MCL are
statistically significant; and the effectiveness and the cost of
the pump and treat system justify the reduction of risk. The
statistical method which shall be employed to determine
statistically significant data will be developed as part of the
Compliance Monitoring Program during remedial design of the
remedy and shall be approved by EPA. EPA shall make the
determination of background level, statistical significance of
arsenic detections and whether the effectiveness and cost of
pumping and treating justify the reduction of risk.
Treatment shall be conducted on all contaminated ground water
that exceeds the requirements of the POTW or the ground water
performance standards. Treatment for removing arsenic from
groundwater uses activated alumina adsorption (also known as
gamma aluminum oxide, a porous adsorbent with a moderately high
surface area).
Treatment will occur onsite, although based on the existing site
POTW discharge permit, an arsenic treatment standard is not
specified. Inclusion of the onsite treatment component as part
of this contingency measure allows for treatment prior to
discharge to the POTW, if such a requirement is specified in the
future.
The criterion for triggering implementation of the arsenic
contingency is either (a) a documented, consistent and verifiable
increase in contaminant concentrations exceeding the MCL at or
beyond the compliance boundary, which indicates that the remedy
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is not managing the waste on the site or (b) the documented
ineffectiveness of the remedy to affect the specified reduction
in contaminant mass. The criteria shall be further and more
specifically developed and described in the remedial design.
The estimated cost of this alternative ranges from $300,000 to
$3,600,000 for a range of operating time from 0 to 30 years.
Based on site data available, the alternative would not be
triggered, so the operating time is 0 years. However, to allow
for the worst case situation of a statistically significant
occurrence of arsenic above the MCL, costs for the 30-year
operating time have also been estimated.
10.2 Cost of the Selected Remedy
A detailed cost table (Table 10.2) has been developed for the
selected remedy and is organized by capital costs, O&M costs and
long-term O&M costs. Within each of these cost groups, the
remedy is divided into soils, buried debris, LNAPL and ground
water. The unit costs provided in these tables are based on a
compilation of vendor contacts, EPA documents, contractor
information, and technical references. Each unit cost and
quantity has a corresponding reference designated as unit cost
(UC) or quantity (Q). Each reference refers to a file of backup
information, including calculation sheets, vendor quotes, and
lists of assumptions used to develop the unit costs and
quantities. The files of backup information are located in the
FS.
Also included are costs for the two contingency measures (arsenic
treatment and containment)(Tables 10.2A and 10.2B).
The indirect costs have been calculated by applying factors to
the direct costs identified in each of the tables. A discussion
of how these indirect cost factors were developed and what the
indirect costs includes is provided in this subsection.
10.2.1 Indirect Cost Factors
Indirect costs are applied to the sum of the three main cost
groups which include direct capital costs, direct O&M costs, and
direct long-term O&M activity costs. The indirect costs include:
mobilization/demobilization; indirect, overhead, and profit;
engineering design; and contingencies. The indirect costs vary
due to contamination, technologies selected, size of the project,
and duration. Based on the characteristics of each alternative,
these factors assist in the development of indirect percentages
as explained below. These indirect percentages are then applied
to the direct costs to determine an overall total cost.
In order to provide a uniform basis of an estimate, a cost markup
matrix was developed based on the consideration factors to
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determine indirect cost percentages for direct capital and O&M
costs. The selected remedy has been individually adjusted to be
more representative of its own complexity. The following
subsections explain the indirect markup factors and the
application rationale.
10.2.1.1 Mobilization/Demobilization
Mobilization activities include construction/setup of
contractors' support facilities, mobilization of heavy equipment,
and relocation of management/supervisory personnel.
Demobilization consists of decontamination and removal of
contractors' equipment and facilities from the site. Costs for
these activities are applied as a percentage of direct cost.
These percentages applied can vary from 2 to 7 percent.
10.2.1.2 Indirects, Overhead, and Profit
Indirect costs are calculated as a percentage of the sum of
direct and mobilization/demobilization costs. Indirect costs
cover the cost of onsite management, administrative, technical,
health and safety, and supervisory staff, utilities for site
support facilities (excluding production facilities), engineering
tests, QA/QC program, preparation of work plans, submittals and
as-built drawings, bonding costs, support facilities, and vehicle
maintenance and operation. The range of percentages applied can
vary from 20 to 35 percent. The selected remedy uses 30 percent.
10.2.1.3 Engineering Design
The engineering design costs are estimated as a percentage of the
sum of direct costs; mobilization/demobilization costs; and
indirects, overhead, and profit cost. In general, engineering
percentages were developed based on past experience of
engineering costs on similar projects. These percentages are
dependent upon the degree of complexity associated with the
particular alternative and the complexity of the treatment
technology selected. Standard percentages ranging between 3 and
6.5 percent have been applied to the estimates. The selected
remedy uses 2 percent for the capital costs of the soils and 3
percent for the buried debris remediation; and 2 percent for the
capital costs of the LNAPL and ground water remediation.
10.2.1.4 Contingency
A contingency is applied as a percentage of the sum of direct
cost; mobilization/demobilization; indirects, overhead, and
profits; engineering design; and engineering costs.
Contingencies cover the specific provisions for unforeseeable
elements of costs within the defined project scope. A
contingency is particularly important when previous experience
relating estimated and actual costs have shown those inferable
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events which will increase costs are likely to occur. To
effectively compare the design alternative, contingency has been
applied to each alternative estimated based on the complexity of
the treatment technology, unforeseen and unpredictable
conditions, and/or uncertainties within the scope of this
project. Other considerations which may affect the selection of
the contingency are levels of contamination, environmental media
and climatic conditions, scheduling, changes in federal, state,
or local regulation, and other issues unique to the project such
as management permits and regulatory reviews.
Separate contingencies were developed for capital, O&M, and long-
term activities. A contingency range for this level of detail is
typically 20 to 50 percent. The contingency to be provided for
the current estimates were developed based on four cost
parameters considered for each cost type, including levels of
contamination, the complexity of the treatment technology, the
size of the project, and estimated duration of the activity. The
amount of contingencies applied to the estimates ranged from 25
to 40 percent based on these consideration factors and on past
experience and knowledge with similar remedial projects. The
selected remedy uses 20 percent for the capital costs of the
soils, 30 percent for the capital costs of the buried debris and
LNAPL remediation; 20 percent for the capital costs of the ground
water remediation; 30 percent for the O&M costs of the soils,
buried debris and LNAPL remediation; and 20 percent for the O&M
costs of the ground water remediation.
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Section 11.0
Documentation of Significant Changes
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Section 11.0
Documentation of Significant Changes
To fulfill the requirements of CERCLA section 117(b), this
section discusses the reasons for the selection of a remedy other
than the preferred remedy in the Proposed Plan, changes to the
monitoring program and changes in the removal of the onsite
sludge derived from the Emergency Surface Removal.
11.1 Selection of New Remedy
The Proposed Plan was released on July 6, 1995 to the public
presented alternative 7 as EPA's preferred alternative. The
central differences between alternative 7 and alternative 10, the
selected remedy, are the soil and ground water components of the
remedies. Alternative 10 relies upon containment of the
low-level contaminated soils under a 42-inch soil cap and
intrinsic remediation/attenuation of the ground water to achieve
ground water performance standards. Alternative 7 thermally
desorbs these low-level contaminated soils and relies upon a pump
and treat system to capture the ground water contaminants for
treatment at•the local POTW.
11.1.1 Soil Component
Based upon the public comment received and as part of EPA's
internal deliberation process, EPA revisited the requirements for
treatment of the soils.
The result of the Baseline Risk Assessment for the Site shows
that the accumulative reasonable maximum exposure (RME) risks
from carcinogenic and noncarcinogenic chemicals of concern within
the soils for exposure to the industrial worker is 9.75 X 10"5
and an HI of less than one, respectively. The Role of the
Baseline Risk Assessment in Superfund Remedy Selection Decisions
(OSWER Directive 9355.0-30) states that where the cumulative
carcinogenic site risk to an individual based on the reasonable
maximum exposure for both current and future land use is less
than 10"4, and the noncarcinogenic hazard quotient is less than
one, action generally is not warranted unless there are adverse
environmental impacts. During the investigations at the site,
EPA did not identify an environmental impact. The directive also
states that a risk manager may also decide that a baseline risk
level less than 10~4 is unacceptable due to site specific reasons
and that remedial action is warranted. EPA believes that action
is warranted with respect to the soils, due to the uncertainties
of the risk assessment (see 7.1.5), potential for exposure to
discrete areas where soil exposure exceeds 10~4 and the risk
being so close to the upper bound of the acceptable risk range.
But EPA believes that the action's cost should be proportionate
to the level of protectiveness required.
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Upon review of A Guide to Principal Threat and Low Level Threat
Wastes (Superfund Publication: 9380.3-06FS), EPA has determined
that the contaminants within the soils represent a low-level
threat waste. Low-level threat wastes are those source materials
that generally can be reliably contained and that would present
only a low risk in the event of release. They include source
materials that exhibit low toxicity, low mobility in the
environment, or are near health-based levels. The soils are the
Petrochem site exhibit low toxicity and mobility and are near
health-based levels.
EPA also reviewed the NCP language, Interim Final Guidance on
Preparing Superfund Decision Documents (EPA/624/1-87/90) and A
Guide to Selection Superfund Remedial Actions (OSWER Directive
9355.0-27FS) pertaining to low-level threat wastes. The NCP and
guidance expects EPA to use engineering controls, such as
containment, for waste that poses a relatively low long-term
threat.
CERCLA Section 121 expects EPA to select cost-effective remedies.
Alternative 6 has the same remedy components for the ground water
and LNAPL as does alternative 10 but they have different soil
remedy components. Alternative 6 thermally desorbs the soils at
a total remedy cost of $14.2 million and alternative 10 contains
the low-level contaminated soils under a 42 inch clean soil cover
at a total remedy cost of $6.1 million.
EPA believes that the offsite disposal of wastes that exceed the
10~4 risk and the containment onsite of the remaining low-level
contaminated soils as specified in the selected remedy meets the
cost-effectiveness requirements of CERCLA and the expectations of
the NCP and EPA guidances.
11.1.2 Ground Water Component
Shortly before the release of the Proposed Plan, ESRC submitted
to EPA an Aquifer Characterization Report that discussed new
information regarding the contamination at and near the site and
the hydrogeology of the site. The Aquifer Characterization
Report was referenced in the Proposed Plan. The information of
the report was not incorporated into the Proposed Plan because
EPA decided it was best not to delay the release of the Proposed
Plan and additionally, to provide the document for public review.
EPA and UDEQ hosted a technical meeting with ESRC, County
government representatives, and public citizens during the public
comment period on August 28 and 29, 1995 at the offices of UDEQ
to discuss the ground water components of the alternatives as
they relate to the new information. During this meeting,
numerous concerns were aired regarding the ground water treatment
components of pump and treat systems vs. intrinsic
remediation/attenuation. Many of the concerns regarding the pump
and treat components of alternative 7 were submitted as public
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comments (see Responsiveness Summary). The concerns include:
"pumping will cause up coning of the geothermal water,"
"commingling of geothermal water with contaminated water will
increase total pumping and treatment costs," "pumping may draw
additional offsite contaminants onsite," and "pump and treat may
disrupt current site conditions which may support
bioremediation." The concerns regarding intrinsic
remediation/attenuation were focussed on whether bioremediation
was actually occurring at the Petrochem/Ekotek site and if so,
how to gather data to evaluate the degradation rate. Although
all parties agreed that the conditions appeared generally
favorable for bioremediation, much of the evidence necessary to
demonstrate bioremediation, such as vinyl chloride degrading to
ethene and ethane, was absent.
The information provided in the Aquifer Characterization Report
has lead EPA to support the selection of intrinsic
bioremediation/natural attenuation over a pump and treat system.
However, it should be noted that the containment contingency
(which is a pump and treat system) will be relied upon for
containment should intrinsic bioremediation/natural attenuation
fail to contain the contaminants within the groundwater plume
beneath the site within the boundaries of the compliance
boundary.
In addition to the effectiveness of the ground water remedies,
the Aquifer Characterization Report discusses the information of
1,1,1-trichloroethane (TCA) detections offsite. For further
discussion of this TCA, see section 11.1.4.
11.1.3 Study for Quantification of Bioremediation of Vinyl
Chloride
The selected remedy of intrinsic remediation/attenuation,
includes a study for quantification of bioremediation of vinyl
chloride. That is, a study will be performed as part of RD that
will determine whether vinyl chloride is degrading to ethene and
ethane, and if so, at what rate, and whether that rate is
sufficient to achieve the ground water performance standards
within a comparable timeframe of active treatment systems.
11.1.3.1 Previously Collected Data
ESRC initiated the collection of qualitative data to determine
whether ethane and ethene can be detected in the field in
November 1995. If the results of this data collection render
detections of ethane and ethene, further studies shall be
initiated as part of the intrinsic remediation remedy to quantify
the rate of degradation of vinyl chloride to ethane and ethene.
11.1.3.2 Data to be Collected during Remedial Design and
Remedial Action
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Additional data collection is required as part of the intrinsic
remediation remedy to demonstrate quantitatively that vinyl
chloride is degrading to the less toxic constituents of ethane
and ethene.
Section 10.1.3.2 describes the type of data needed to quantify
the degradation rate of vinyl chloride to ethane and ethene, and
how the studies will be implemented through an EPA approved work
plan during RD.
If biodegradation of the vinyl chloride to ethane and ethene
cannot be quantified, or if the rates are inadequate to meet the
criteria specified in this ROD, as determined by EPA, then the
selection of intrinsic remediation as a remediation of the ground
water for the Petrochem/Ekotek site will be reevaluated by EPA
and modifications to the primary remedy or initiation of
contingency measures may be deemed necessary to be protective of
human health and the environment.
11.1.4 Enhanced Ground Water Monitoring
The Aquifer Characterization Report shows detections as high as
788 ppb of TCA during the spring of 1995, at piezometers located
offsite. The detections of TCA onsite were detected during the
early phases of the investigation and were an order of magnitude
less than the detections of TCA found offsite. Between February
1993 and February 1995, there has been only one onsite detection
of TCA at MW-7 at a single digit ppb concentration. The wells to
the north and east of the site (e.g., W-9, MW-3, W-4a, W-10) have
shown detections of TCA ranging from single digit concentrations
to 227 ppb since November 1994. EPA currently believes that the
TCA plume offsite is from an off-site source not related to the
Petrochem/Ekotek site. However, EPA believes that further
information is needed before definite conclusions can be drawn.
It is not known at this time whether the offsite TCA plume is
migrating onsite. Therefore, EPA has included an enhanced ground
water monitoring program located on the northern and northeastern
part of the site that will determine the impact of the offsite
TCA plume to the onsite ground water remedy.
The frequency, locations, analytes, sampling methods, detection
limits, analytical methods, QA/QC, etc. and explicit details of
the monitoring plans for performance and compliance, and for
long-term ground water monitoring will be determined during
Remedial Design (RD). The Region VIII Superfund performance
monitoring guidance for ground water remedies will be used to
develop the ground water monitoring plan.
11.1.5 Additional Sampling of LNAPL
ESRC submitted data to EPA in October 1995 that was a compilation
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of all the data collected at the site since the release of the
Feasibility Study in January 1995 to August 1995. Most of the
data was collected to gain a better understanding of the site and
was used to develop the Aquifer Characterization Report.
ESRC collected another LNAPL sample in March 1995 and modified
the analytical methods to achieve lower detection limits.
Halogenated volatile constituents were analyzed by purge and trap
concentration (EPA Method 5030) combined with gas chromatography
(GC) as described in EPA Method 8010. The LNAPL was analyzed
specifically for vinyl chloride, 1,1,1-trichloroethane and
tetrachloroethylene by mass spectrometry using selective ion
monitoring (SIM). Vinyl chloride was detected at 480 ppb; 1,1,1-
trichloroethane (TCA) was detected at 130 ppb; and
tetrachloroethylene (PCE) was detected at 410 ppb. All previous
data collected from the LNAPL had detection limits of 10,000 ppb
or greater and therefore vinyl chloride, TCA or PCE was not
detected.
Vinyl chloride, TCA, and PCE detected in the LNAPL were evaluated
as to the likelihood that they would dissolve from the oil.
Table 6.1.2.3 shows the results of the partitioning exercise.
The predicted concentrations show that the maximum concentrations
of vinyl chloride, TCA and PCE have the potential to partition
into the ground water at concentrations of 110 ppb, 0.55 ppb and
1.2 ppb, respectively. When the predicted concentrations in
water are compared to the actual concentrations in water, it is
clear that most compounds present in the LNAPL are not observed
in ground water due to their affinity for the residual organic
phase. However, this partitioning exercise clearly demonstrates
that the LNAPL is a likely source material of the vinyl chloride
in the ground water. A source material is defined as material
that includes or contains hazardous substances, pollutants or
contaminants that act as a reservoir for migration of
contamination to ground water or acts as a source for direct
exposure. Because of the concentrations of the solvents within
the LNAPL, the potential of the LNAPL to partition to the ground
water, and the significant risk to human health or the
environment should exposure occur, the plume and saturated soils
above the plume are considered principal threat wastes.
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Section 12.0
Statutory Determinations
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Section 12.0
Statutory Determinations
EPA's primary responsibility at Superfund sites is to undertake
remedial actions that achieve adequate protection of human health
and the environment. In addition, CERCLA § 121 establishes
several other statutory requirements and preferences. These
specify that when complete, the selected remedial action for a
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 must also 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 treatments that permanently and significantly reduce the
volume, toxicity, or mobility of hazardous substances as their
principal element. The following discussion addresses how the
selected remedy meets these statutory requirements.
12.1 Protection of Human Health and the Environment
EPA's Guidance for Conducting Remedial Investigations and
Feasibility Studies Under CERCLA (1988) indicates that
protectiveness may be achieved by reducing exposure through
actions such as containment, limiting access, or providing an
alternative water supply. The remedial actions described for the
selected remedy will permanently address the principal threat
posed by the LNAPL to human health and the environment through
offsite incineration and reduce the toxicity, mobility, and
volume through bioremediation\natural attenuation of the ground
water.
Short-term and cross-media impacts due to implementation of the
selected remedy are expected to be minimal. Potential risks to
human health and environment through exposure to contaminated
groundwater and soil during well installation and sampling will
be minimized by the use of appropriate preventive and protective
measures. Potential cross media impacts will be minimized by
proper well construction methods.
12.1.1 Soils (to include buried debris)
The soils pose a risk to the future industrial worker at the
site. The reasonable maximum exposure (RME) of the future
industrial worker from surface soil ingestion and dermal contact
with the soils has been estimated to be 9.75 X 10"5. The offsite
disposal of soils exceeding the hot spot criteria, and
consolidation of low level soils onsite under a 42-inch clean
soil cap will effectively eliminate exposure and thus any
12-1
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associated risk to the contaminants.
12.1.2 LNAPL
Risk was not quantified from any of the contaminants within the
LNAPL because the exposure pathway was not complete. Samples of
the LNAPL taken in March 1995 show that the LNAPL has high
concentrations of contaminants. Vinyl chloride was detected at
480 ppb; 1,1,1-trichloroethane was detected at 130 ppb; and
tetrachloroethylene was detected at 410 ppb. The partitioning
exercise described above in this ROD clearly demonstrates that
the LNAPL is a likely source material of the vinyl chloride in
the ground water. The LNAPL is believed to be the likely source
of contamination to the ground water and therefore is considered
a principal threat waste.
The selected remedy removes virtually 100% of the LNAPL from the
site for offsite incineration and disposes the 3,000 CY of LNAPL-
saturated soils offsite in a TSCA-permitted landfill. This
remedy completely and permanently removes the principal threat
waste from the Petrochem/Ekotek site.
12.1.3 Ground Water
Contaminated groundwater at the Site does not currently pose a
significant human health risk because the groundwater is not
presently being used for drinking water or other domestic uses.
Thus, there are no completed exposure pathways.
A potential future risk may occur if a resident does use the
ground water for domestic purposes. The reasonable maximum
exposure (RME) of the future resident drinking the ground water
and showering in the ground water is 7;99 X 10~4. The intrinsic
remediation/attenuation of the ground water reduces this risk to
within acceptable levels. Groundwater monitoring will allow for
evaluating the performance of the selected remedy and the need
for additional action.
12.2 Compliance with ARARs
Under Section 121(d)(1) of CERCLA, remedial actions must attain
standards, requirements, limitations, or criteria that are
"applicable or relevant and appropriate" under the circumstances
of the release at the site. All ARARs would be met upon
completion of the selected remedy at the Petrochem/Ekotek site.
The selected remedy of excavation, offsite disposal,
consolidation and capping onsite of the soils and buried debris;
direct excavation of the LNAPL; intrinsic remediation/attenuation
of the ground water and institutional controls used during
implementation will comply with all Federal and State applicable
or relevant and appropriate chemical-, action-, and location-
12-2
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specific requirements (ARARs). Federal and State statutes and
regulations pertinent to the selected remedy are discussed in
Section 10.0.
12.3 Cost Effectiveness
Section 300.430(f)(1)(ii)(D) of the NCP requires that the
selected remedial action meet the threshold criteria of
protection of human health and the environment and compliance
with the ARARs, and be cost-effective. Cost-effectiveness is
determined by evaluating the following three of the five
balancing criteria to determine overall effectiveness: long-term
effectiveness and permanence; reduction of toxicity, mobility, or
volume through treatment; and short-term effectiveness. Overall
effectiveness is then compared to cost to ensure that the remedy
is cost-effective. A remedy is cost-effective if its costs are
proportional to its overall effectiveness.
12.3.1 Overall Effectiveness
The selected remedy was ranked as having a high degree of long-
term effectiveness and permanence, a moderate degree of reduction
of toxicity, mobility or volume through treatment, and a high
degree of short-term effectiveness.
12.3.2 Overall Effectiveness Compared to Cost
The present worth cost (PWC) of the selected remedy is
$6,100,000. Alternatives 6 and 7 PWC are $14,200,000 and
$16,600,000, respectively. The cost of these alternatives is a
factor of 2.3 - 2.7 times higher than the selected remedy.
Because the selected remedy provides the same level of long-term
effectiveness and a greater degree of short-term effectiveness at
a considerable cost savings than alternatives 6 and 7, EPA
believes that the selected remedy offers the best overall cost
effectiveness.
12.4 Utilization of Permanent Solutions and Alternative
Treatment Technologies (or Resource Recovery Technologies) to the
Maximum Extent Practicable
Section 300.430(f)(1)(ii)(E) of the NCP requires that the
selected remedy shall utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. This requirement shall be fulfilled
by selecting the remedy that satisfies the threshold criteria and
the balancing criteria and provides the best balance of tradeoffs
among alternatives in terms of the five balancing criteria. The
balancing shall emphasize long-term effectiveness and reduction
of toxicity, mobility, or volume through treatment. The
balancing shall also consider the preference for treatment as a
principal element and the bias against off-site land disposal of
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untreated waste. In making the selection, the modifying criteria
of state acceptance and community acceptance shall also be
considered.
12.4.1 Balancing Criteria
EPA has determined that the selected remedy has a high degree of
long-term effectiveness and permanence, and a moderate degree of
reduction of toxicity, mobility or volume through treatment
thereby partially satisfying the two criteria. The selected
remedy fully satisfies the long-term effectiveness criteria and
partially satisfies the preference for treatment by treating the
LNAPL in an offsite incinerator. The selected remedy does not
treat the remaining soils because they are considered low-level
contaminated wastes and do not warrant treatment at a cost of 2.3
times the selected remedy cost.
12.4.2 Modifying Criteria
The State of Utah supports the selection of alternative 7;
however, EPA received numerous comments pertaining to the
difficulty of pumping and treating within the shallow aquifer at
the Petrochem/Ekotek site. The public comments question whether
the shallow aquifer can be effectively and efficiently contained
and captured. The high hydraulic conductivity, low
contamination, and shallow geothermal waters add to the
complexity and difficulty of designing an effective pump and
treat system. EPA has reviewed this information and agrees,
based on present information and subject to the demonstration of
effectiveness of intrinsic remediation/attenuation, and given the
complexity of and potential disadvantages of pump and treat
systems (as described in alternative 7) that intrinsic
remediation/attenuation represents the best alternative.
EPA also received numerous public comments in support of
alternatives 6 and 10. These commenters believe that
alternatives 6 and 10 offers the best balance of the selection
criteria.
12.5 Preference for Treatment as a Principal Element
The selected remedy utilizes permanent solutions and treatment
technologies to the maximum extent practicable at the Site.
The selected remedy includes: treatment of the LNAPL and
intrinsic remediation/attenuation of the ground water.
Removal of the recoverable LNAPL will permanently eliminate a
potential source of groundwater contamination at the Site.
Intrinsic remediation/attenuation of the ground water will reduce
the risk to a future resident to within EPA's acceptable risk
range. Therefore the statutory preference that remedies employ
treatment as a principal element is satisfied, in part, by the
selected remedy.
. 12-4
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The groundwater monitoring program will allow for evaluation of
changes in groundwater quality, the detection of any offsite
migration of contaminated groundwater, and the need for further
action at the Site.
Because the selected remedy will result in hazardous substances
remaining on the site, a review will be conducted at least every
five years after commencement of remedial action to ensure that
the remedy continues to provide adequate protection of human
health and the environment.
12.6 EPA's Selection of the Remedy
Of the alternatives that are protective of human health and the
environment and comply with ARARs, EPA believes that the selected
remedy provides the best balance in terms of long-term
effectiveness and permanence; reduction in toxicity, mobility, or
volume achieved through treatment; short-term effectiveness;
implementability; and cost. The NCP states that EPA expects to
use engineering controls, such as containment, for waste that
poses a relatively low long-term threat, and that the selected
remedy shall be cost-effective. The containment of the soils
onsite satisfies the NCP expectation. The containment of low-
level contaminated waste, cost-effectiveness and receipt of
public comment supporting alternative 10 were important criterion
in selecting alternative 10 as the selected remedy.
12-5
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Section 13.0
Responsiveness Summary
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Section 13.0
Responsiveness Summary
13.1 Public Meeting Transcript
13-1
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PETROCHEM/EKOTEK PUBLIC MEETING
7:00 P.M.
JULY 26, 1995
168 North 1950 West
Salt Lake City, Utah
REPORTING SERVICES, LLC
525 FIRST INTERSTATE PLAZA
17O SOUTH MAIN STREET
SALT LAKE CITY. UTAH 841O1
• S01) 328-1 188 / 1-8OO-DEPOMAX
FAX 328-1 1 89
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INDEX
PAGE
Welcome, Purpose and Introduction
by Nancy Mueller 3
Site History/Background
by J.D. Keetley 5
Superfund Process, Site Risks,
Cleanup Options and Preffered
Alternative by Dan Thornton 12
Ground Rules by Nancy Mueller 32
Public Comments 35
MARY D. QUINN CSR, RPR
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1 July 26, 1995 7:00 p.m.
2
3 PROCEEDINGS
4
5 MS. NANCY MUELLER: Let's go ahead and get
6 started. My name is Nancy Mueller. I'm the
7 community relations coordinator for EPA out of the
8 Denver office. And I'd like to take this opportunity
9 to welcome you to this public meeting tonight for the
10 Petrochem/Ekotek site. It's taken a while to get to
11 this point. We're glad to be here and glad to have
12 you here to give us the comments on the remedy that
13 EPA and UDEQ have identified as what they think is
14 the best approach to dealing with the contamination
15 out of the site. Real briefly this evening, we're
16 going to go through a few things, and then we'll get
17 to the most important part of the meeting, which is
18 obviously to hear what you all have to say regarding
19 what the preferred alternative that's been identified
20 is.
21 First of all, though, I'd like to
22 introduce the players in this little drama. First is
23 Dan Ford, EPA project manager. Up at the other --
24 I'm sorry. Dan Ford. Dan Thornton. Wrong side.
25 Now I'm done. No more. Over in the corner is J.D.
MARY D. QUINN CSR, RPR
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1 Keetley, UDEQ project manager for the site. Front
2 row on the end is Jim Stearns, EPA attorney for the
3 site. Next to Jim is Barry Levene. He's Dan's
4 supervisor out of EPA in Denver. Next to him is
5 Scott Everett, UDEQ toxicologist. Behind Jim is
6 Laura Lockhart for the Utah AG ' s office. And where's
7 Brent? Brent Everett, UDEQ, J.D.'s section chief.
8 At the back is Renette Anderson, UDEQ community
9 relations.
10 This is one of the few meetings that
11 I've been to where you outnumber us. Usually it's
12 the other way around. We have casts of thousands to
13 these meetings and often are disappointed because we
14 don't get a good turnout. We appreciate this
15 tonight.
16 What we're going to be doing tonight is
17 giving you a little bit of presentation on what's
18 gone on at the site regarding the site studies and
19 findings of risk. We're going to go over the cleanup
20 alternatives and explain to you why the alternative
21 that we have identified right now is the preferred
22 one. And Dan will go into that in some detail.
23 He'll briefly discuss the project schedule as we see
24 it now. And then the most important thing, as I
25 said, we'll open it up for public comment, and we'll
MARY D. QUINN CSR, RPR
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1 let you have your say. So with that, I'm going to
2 turn it over to Mr. Thornton. Mr. Keetley, I'm
3 sorry. And we'll get the show on the road, and I'm
4 going to sit down.
5 MR. J.D. KEETLEY: I'm going to run you
6 through a bit of the site history for about the last
7 40, 50 years. I'll try to do it real brief.
8 The Petrochem/Ekotek site is located in
9 northern Salt Lake City at 1628 North Chicago Street.
10 It's a seven acre site surrounded by industrial --
11 UNIDENTIFIED: Can you speak louder?
12 MR. J.D. KEETLEY: It's a seven acre site
13 surrounded by commercial and industrial properties
14 with a small residential area of about 40 or 50 homes
15 directly to the south of the site down in this area.
16 This is the Petrochem site here in northern Salt Lake
17 City. Next slide, please.
18 It began operation in the 1940's as an
19 oil refinery. This is a picture of it in those days.
20 Next slide also.
21 This is a closeup showing some of the
22 tanks and things used during the refinery stage.
23 UNIDENTIFIED: So far, we haven't heard a
24 damn word you've said.
25 MR. J.D. KEETLEY: I'll try to speak
MARY D. QUINN CSR, RPR
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1 louder. Next slide.
2 In 1978, it became the Ekotek property.
3 And at that point, it started dealing with used oil
4 and solvents. And basically what it did, it recycled
5 the used oil to be resold as oil, and the solvents,
6 it disposed of them offsite.
7 In 1981, it became owned by Steven Self
8 and Steven Miller. And at this point, they also
9 started adding hazardous waste to their treatment.
10 They would treat and dispose of hazardous waste in
11 addition to the used oil and solvent recycling.
12 This is a picture of an aerial photo of
13 the Ekotek site in 1979. Just about at the peak of
14 its operation. You can see some of the buildings
15 that are still there now are the main warehouse, this
16 warehouse back here, a warehouse down here, the tank
17 farm area. All the tanks. And the recycling
18 facilities which is in here have been removed since
19 then. Some of the dark areas showing some staining
20 due to contamination and sludge.
21 Next slide. Can you hear me now?
22 UNIDENTIFIED: A little better.
23 MR. J.D. KEETLEY: This is a run through, a
24 brief history, of the site history since 1980. In
25 1980, they applied for a RCRA, which is basically
MARY D. QUINN CSR, RPR
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1 just a permit to handle solid and hazardous waste.
2 They got a part A permit. In July '87, they applied
3 for and received a solid waste handling permit for
4 two of their 60 tanks. If you remember back on that
5 previous slide, or you can look over here, there are
6 over 60 above ground vertical tanks that show up as
7 little circles on here. They applied for and got
8 permits for two of those tanks in July '87.
9 In November '87, Ekotek went out of
10 business, leased the property to Petrochem. Hence
11 the name Petrochem. Usually it's referred to as
12 Ekotek. That was the primary owner during these
13 years.
14 Then in December '87, Petrochem received
15 a violation notice from the State, what is now the
16 Division of Air Quality, within the same Department
17 of Environmental Quality. They received one notice
18 of violation. They were out of compliance. They
19 were emitting air pollutants which they should not
20 have been.
21 January they received a second notice of
22 violation. February of '88 they received another
23 violation from the solid and hazardous waste people
24 for improper and illegal handling practices of their
25 hazardous waste. February '88, Petrochem goes out of
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1 business.
2 During this time, it's important to
3 remember this whole thing happened in a background of
4 public complaints. The public had called the Salt
5 Lake City County Health Department and lodged a few
6 complaints that there had been noxious odors emitting
7 from the sites, smoke coming off the site, and
8 occasionally some liquids had been oozing from the
9 site.
10 This brings us up to late '87, early '88
11 when they received their notices of violations.
12 Ekotek had gone out of business. Petrochem had gone
13 out of business. At that time the site was
14 abandoned, and the State of Utah went out there to
15 investigate what exactly was left over at the site.
16 Next slide, please.
17 What they found, things like this. They
18 found a mess, basically. Lots of tanks, some that
19 were -- had contents in them, some didn't. A lot of
20 left over sludge, stained soil. In other words, it
21 presented an immediate threat to human health.
22 Utah, State of Utah, realized it had a
23 much bigger problem on its lands than our resources
24 could deal with. So we called in at that point the
25 U.S. Environmental Protection Agency, EPA, because
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1 they had much broader resources, and asked them for
2 their help. And between the two of us — basically,
3 the EPA went out and performed an emergency removal
4 action.
5 We went to the site, and what we found,
6 there were altogether over 60 of these above ground
7 storage tanks. Mostly located in the northern end of
8 the tank farm area. Found over 60 above ground tanks
9 plus associated pipings and fittings. Found several
10 underground storage tanks. The volume of liquid that
11 was left over and contents in those tanks was
12 estimated at between 200 to 400,000 gallons.
13 There's -- within the five warehouses that were on
14 the site, they found about 500 55-gallon drums and
15 lots of other smaller containers that contained used
16 oils and other miscellaneous solvents and about 1,100
17 tons of industrial waste in the form of filter cake
18 sludge. The specific contaminants found on the site
19 included chlorinated solvents, organics,
20 hydrocarbons, pesticides, metals, dioxins, and some
21 PCB'S.
22 The emergency response began
23 Thanksgiving weekend of November 1988 with the EPA
24 being the predominant facility agency out there, UDEQ
25 backing them up as needed. The first thing they did
MARY D. QUINN CSR, RPR
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1 was stabilize the site. Next slide.
2 This meant putting up a fence around the
3 perimeter of the site so nobody could get on there,
4 keeping all trespassers off, doing an inventory of
5 the site, going through the drums and the various
6 containers, finding out what chemicals were on the
7 site, taking an inventory of this, shipping off
8 the -- disposing of the waste and shipping off the
9 tanks and containers for offsite disposal.
10 It was also at about this time that some
11 of the parties that had been — we call them
12 potentially responsible parties. Basically parties
13 that had either generated or transported or stored
14 the waste to the site, they were later called
15 potentially responsible parties. They banded
16 together, formed a committee called the Ekotek Site
17 Remediation Committee, and they have been primarily
18 responsible for paying the costs of both the removal
19 activity and the activity that's occurred since then.
20 The removal occurred basically from 1990 to '92, cost
21 estimated between 8 and $10 million. The committee
22 pretty much paid for that whole thing. Next slide,
23 please.
24 The removal continued, like I say, for
25 the two years, '90 to '92. Basically what it did,
MARY D. QUINN CSR, RPR
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1 they sampled the air, the soil, the ground water.
2 They took about 650 empty drums, crushed them, sent
3 them offsite. About 2,300 smaller containers, they
4 identified the contents, shipped them offsite as well
5 as the containers, and the tank farm area, this area
6 to the north, where the majority of contamination was
7 located, it's located in this area here in the north
8 end, the tank farm, they took off the tanks and the
9 pipes and shipped them offsite for recycling, mostly.
10 Took the contents, shipped them off to an
11 incinerator. And there's — there were retention
12 ponds at the time that were collecting water during
13 this whole process. They took that — stored that
14 water, treated it, sampled it, and then disposed of
15 it into the sewage system.
16 This brings us up to 1992. At this
17 time, the removal -- the emergency removal process
18 pretty much came to an end. And at that time, it was
19 listed as a Superfund site. So what this meant was
20 that the emergency removal response dealt with the
21 immediate threats to the public health at that time.
22 With all the various containers and drums and the
23 contents of all that stuff on site.
24 Once that was removed, the Superfund
25 process dealt with the more long-term chronic threats
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1 to the public health, and what this has meant is that
2 there's been an extensive amount of data collection,
3 data gathering and analyzing the data, putting it all
4 together to define the extent of the contamination on
5 the site. And then secondly to come up with a
6 solution as far as how to treat the waste. What to
7 do with the contamination. So Dan Thornton, EPA, is
8 going to go into that whole process called the RI/FS
9 process.
10 That pretty much concludes my
11 presentation at this time. I'll turn it over to Dan
12 Thornton.
13 MR. DAN THORNTON: If anyone can't see
14 these overheads, please let us know. Following on
15 J.D.'s discussion, basically what I'd like to say,
16 there are two sides to the Superfund process. We do
17 emergency removal actions under the emergency
18 response group, and we also do long-term remedial
19 actions in the remedial group. I'm part of the
20 remedial group.
21 What we talked about before, the removal
22 actions where they took away most of the immediate
23 threats at the site, they were dealing with tanks
24 that were sitting at an abandoned site. Animals
25 could come up and let the whole thing flow out of the
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1 ground. It was uncontrolled. What they were dealing
2 with in that instance were imminent and substantial
3 endangerments to human health and the environment.
4 What we're looking at is a little bit
5 longer term, maybe more subtle effects that could be
6 caused by wastes that aren't going to blow up or
7 necessarily get out of our control, but they're there
8 on the site, and we've looked at that in the
9 Superfund process. Now we're trying to address those
10 concerns with a remedial plan.
11 What we see here is basically just a
12 diagram that shows what happens once the site's been
13 placed on the national priorities list as a Superfund
14 priority site. We start by doing a remedial
15 investigation. We gather data. We pull that
16 together to look at the remedial options. The ways
17 we can clean up the site. Then we publish a proposed
18 plan. This happened early this month. And then once
19 that's been done we hold a public meeting, we talk to
20 people about it, we solicit their comments, whether
21 they think our evaluation was accurate, if they think
22 we're doing enough or doing too much, then we move on
23 to later stages in the process. Next slide, please.
24 This slide has the same categories over
25 here. What we're doing is I'm taking a few steps
MARY D. QUINN CSR, RPR
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1 back in the process to help you understand how we
2 arrived at the plan the way we did. In remedial
3 investigation, we do extensive data collection. That
4 follows on with data collection that occurred during
5 those removal actions. For example, we want to know
6 if we're getting all the waste. We looked around,
7 take soil samples, we did extensive characterization
8 of what was in the ground water, we looked at other
9 waste categories and tried to figure out what we were
10 dealing with and how bad it was.
11 After we've done some data collection,
12 even just looking at old manifests for the site,
13 looking at the history of the site, how it operated
14 and what they handled, we begin doing exposure
15 assessments. We look at the potential targets, human
16 health, ecological health, that could be impacted by
17 the site. We look at the potential exposure routes
18 for those contaminants. We also do toxicity
19 assessments where we look at the contaminants, how
20 poisonous they are, what the effects of them would
21 be, and the dose received. All of this information
22 is pulled together into the risk characterization.
23 Next slide, please.
24 So what we do, we start trying to figure
25 out what the risks are based on the contaminants and
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1 their availability. Next slide, please.
2 How can risk occur? It's hard for some
3 of you to see this. We start with the source. There
4 has to be some kind of contamination that's not
5 controlled. Okay? We find a route of transport.
6 That's going to be one of the media at the site.
7 Ground water, soil, surface water, or air. Okay?
8 There's a point of exposure. That just means that
9 someone or something, animal, wetland, sensitive
10 environment, something comes in contact with that
11 chemical that we're concerned about. There's an
12 exposure route. There's some kind of uptake. People
13 drink the ground water, they drink the surface water,
14 they go swimming, they fish, they eat the fish, they
15 breathe air, they breathe dust, they eat with their
16 hands dirty or kids playing in the dirt. You have
17 your receptor. That's whoever is being affected or
18 the sensitive environment. Then again, looking at
19 the toxicity of the substances in question, we pull
20 together an evaluation of what the potential risks at
21 a site would be. Next slide, please.
22 Okay. Basically, at the
23 Petrochem/Ekotek site, we had three major exposure
24 assessments. We were looking at industrial workers
25 who would be on the site, we were looking at lifetime
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1 residents of the area near the site, we were looking
2 at resident adults. Each one of these represents
3 different ways that targets could come in contact
4 with those wastes. There's soil exposures. People
5 can have dermal contact, they could absorb those
6 wastes through the skin possibly. We have lifetime
7 residents, maybe drinking ground water in the future,
8 okay? We have resident adults who if they tapped
9 into that ground water source might be showering,
10 they could have absorption through the skin of
11 volatile substances that come up in the ground water,
12 they could be breathing the vapor. So we counted all
13 of those in the risk assessment. Next slide, please.
14 We made a baseline risk assessment.
15 Now, a baseline risk assessment looks at what's going
16 on at the site. If we didn't do anything, conditions
17 might stay the same, they might get worse. We're
18 saying if we didn't do anything, what's the worst
19 thing that could happen at this site? Currently the
20 ground water doesn't appear to be moving
21 significantly offsite. There's a contaminated plume
22 that -- it seems to be staying fairly stable. The
23 baseline looks at what might happen if that migrated.
24 If it went into another aquifer formation where
25 people had a municipal well, if they had private
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1 wells. We also look at what would happen if access
2 restrictions, like J.D. mentioned, were to fail. Say
3 they didn't maintain the fence. Say the
4 institutional controls that warn people not to drill
5 or well into that aquifer weren't to hold and someone
6 did that. What would happen? Next slide, please.
7 All of these kind of assumptions are
8 used basically to provide the information we need to
9 look at potential health impacts at this site.
10 What's going to happen if we leave the site the way
11 it is? Why do we need to clean it up? It also
12 provides us on a national level a certain amount of
13 consistency, because we know we're addressing sites
14 based on standard levels of risk.
15 What is a baseline risk assessment?
16 Well, when we say it's protective of human health and
17 environment, what we're meaning by that is that we
18 make conservative assumptions. Okay? We look at the
19 possibility that we could make a mistake. We want to
20 make sure that if we make an error, we're not saying
21 that people didn't get exposed when they actually
22 did. Okay? It's also based upon the available
23 toxicological studies and site specific information
24 that both J.D. and I mentioned before. The aquifer
25 characterization studies that we've done, soil
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1 samples, okay? All throughout the process, this
2 information is pulled together.
3 What does the risk assessment do for us?
4 Well, we already mentioned. It determines how likely
5 the site is to pose a health threat to both humans
6 and the environment. It also indicates which
7 chemicals we should pay the most attention to. Where
8 is the real threat? Where's the real risk? It looks
9 at how people could come into contact, the exposure
10 routes we talked about. It identifies the need to
11 take action. Do we need to take action? How soon do
12 we need to take action? It also identifies
13 contamination problems that need to be addressed.
14 Sometimes there might be lesser ones we're not so
15 sure about.
16 Now, some of the things our risk
17 assessment does not do is determine specific health
18 effects that have occurred or will occur, it doesn't
19 identify the specific individuals who are likely to
20 have health problems due to a site, and it doesn't
21 pick out the technologies for us. In part, these
22 things are done by other studies that were done by
23 other agencies at the site. And basically what the
24 risk assessment is doing for EPA and the State is
25 providing framework for us to help evaluate the
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1 alternatives that we're going to pull together at
2 later stages. We already have pulled together,
3 rather.
4 Some basic information about what we
5 found at the site. EPA has a standard set of
6 chemicals they look for when they start at a site.
7 From that list, we develop the list of contaminants
8 of concern. At this particular site we found
9 evidence of 22 different contaminants of concern.
10 Okay? I've classed those into three groups. We have
11 noncarcinogenic substances, those that cause any
12 health effect other than cancer. We have the
13 carcinogenic substances, those that do cause cancer.
14 And then we have a set of five over here out of the
15 22 who have effects in both of these areas. So they
16 can cause cancer, and they can have other effects.
17 What do I mean by other effects? Well,
18 there can be respiratory effects, they can cause
19 trouble breathing, there can be neurological effects.
20 If it's central nervous system it can cause trouble
21 with memory and learning, peripheral nervous system,
22 can cause trouble with coordination, balance,
23 sensation. Next slide, please.
24 The specific chemicals that followed
25 through the analysis and were found in sufficient
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1 levels to cause concern were evaluated again based on
2 whether they were carcinogenic, noncarcinogenic, or
3 both. In the case of noncarcinogenic chemicals, we
4 have arsenic and thallium. Both of these are metals.
5 The arsenic fits into the category of both.
6 Carcinogenics. We had the arsenic and also vinyl
7 chloride. Okay?
8 So based on this evaluation and the risk
9 assessment that was done at the site, we looked at
10 the future uses of the site. It's important to note
11 that we did not find any current risks at the site
12 that were significant enough to warrant a risk
13 evaluation. Or that didn't fall through risk
14 evaluation. Because as J.D. mentioned, the site's
15 been fenced. There is a guard who comes by
16 occasionally and makes sure people aren't getting on
17 the site. We don't believe that these contaminants
18 are presently available by exposure pathways. We
19 base this risk assessment on future use of the site.
20 Are there any questions so far? Yes?
21 UNIDENTIFIED: Wasn't thallium taken out of
22 the risk assessment?
23 MR. DAN THORNTON: I don't believe it was
24 taken out of the risk assessment. But there aren't
25 any remedial alternatives that are going to address
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1 that. Whether we consider something to be naturally
2 occurring or not, it's still a risk. I'd like to get
3 into the next part here. I should probably try to
4 address the questions at the end. I'm sorry. I know
5 a lot of people have questions, and we could get
6 derailed here. I've got about 15 minutes.
7 We've taken these risks. We've looked
8 at what's going on at the site, the likely exposures,
9 whether or not it's something to be concerned about.
10 We've begun looking at the media that are
11 contaminated at the site and how we're going to try
12 to address those. Okay?
13 We've summarized our cleanup options
14 under the next step. I was talking about the
15 remedial investigation. Now we have a feasibility
16 study that takes these different cleanup
17 technologies, looks at what we can do and the
18 benefits we're going to get from those, and then we
19 pull together 10 remedial options. Next slide.
20 There were three major media at the site
21 that we're concerned about. Air exposures are no
22 longer a threat. Basically, the removal actions that
23 J.D. described took care of air emissions. Most of
24 the air emissions were based on activities at the
25 site, not what was left after the businesses went
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1 under. What we have are contaminated soils,
2 contaminated ground water, and there was contaminated
3 surface water. I think the major concern with that
4 right now is just protecting surface water resources
5 to the north of the site. Again, I think the removal
6 action addressed whatever surface releases might have
7 been going on at the site. So now we're really just
8 looking at the ground water and the soil.
9 What we have here is a map of the site
10 that goes into the basic areas where we found
11 contamination during these studies. All right? Some
12 of you probably read the proposed plan. This is the
13 map that was there. Okay? What we see here inside
14 of the larger dotted line area with the vertical
15 lines is the extent of the floating oily substances
16 that we find on top of the ground water. Okay? The
17 substances separate just like Italian dressing would.
18 The oil sits on top, the water is underneath that.
19 They're not really mixing a whole lot. All right?
20 They also seem to be fairly stable. You
21 see this ground water plume has been there for quite
22 some time, as far as we can tell. And yet it hasn't
23 been significantly moving off the site. We're very
24 lucky in that sense. Okay?
25 These are -- it's difficult to really
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1 understand the slide just looking at it. What we're
2 seeing is an image in three dimensions. The ground
3 water is at the base of what we're looking at. It's
4 at least 15 feet below the surface. That plume of
5 oily liquids is sitting on top of it. Perhaps as
6 deep as, you know, to 10 feet below the surface
7 soils. Okay? Then we have contaminated surface
8 soils that have been identified throughout the
9 process. We have a total extractable hydrocarbon
10 spot where the levels exceed 100,000 parts per
11 million. And basically, those are surface soils,
12 maybe down to a depth of a foot or so. So that
13 during the remediation of the site, what we'd see is
14 removing those surface soils, there may be clean
15 soils for the next eight feet. To get at that plume,
16 a lot of that will have to be removed and stockpiled.
17 Okay. What we did as I mentioned before
18 is we looked at the cleanup options by medium.
19 Basically for the soils. There were seven different
20 options that were considered. Okay? We always start
21 by considering no further action. This is a legal
22 requirement that the agency fulfills, because we have
23 to look at the benefits of doing something at the
24 site versus what would happen if we didn't do
25 anything. That's just standard practice. So the
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1 first is always no further action.
2 Any of the ones that you see in red with
3 a star did not pass the evaluation. We looked at
4 whether or not it would be protective, whether it
5 would meet the appropriate laws that it has to meet,
6 and we found that those ones did not. In the other
7 cases, there's a lot of excavation and different
8 types of treatment for landfill disposal. Basically
9 what we're looking at is just increases in the
10 volumes that we're dealing with from one to the next.
11 Okay?
12 The selected remedy, we chose this one
13 down here. Essentially excavation, thermal treatment
14 on site of all of those contaminated soils.
15 For ground water we had six options, and
16 then we added two contingencies to the evaluation.
17 Again, it starts with no action. We considered
18 containment on site with a subsurface barrier. It's
19 basically surrounded with a clay type substance.
20 Almost an underground wall. So that you can't get
21 any lateral migration. The stuff won't move offsite.
22 One of the problems with that is it can still move up
23 and down. We don't know if it's going to contain it.
24 It didn't pass the evaluation.
25 Other options, we considered intrinsic
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1 remediation or attenuation, which is basically
2 waiting for nature to take its course. Some of these
3 substances, particularly the chlorinated organic
4 solvents, may break down naturally. In this case,
5 that's a possibility. It was considered as an
6 alternative.
7 Physical treatment basically means
8 leaving the ground water in place. We're going to
9 pump air up through the ground water. Those volatile
10 substances would come out in the air. We siphon that
11 off and treat the air. That's another way to deal
12 with the ground water contamination.
13 The preferred remedy is extraction from
14 40 to 100 gallons per minute and sending that down to
15 the municipal treatment work site. POTW. I
16 apologize for the acronyms. Basically, that means
17 public treatment, works. We mean the municipal sewage
18 facility. That's what we chose. Extraction and
19 direct treatment means construction of an onsite
20 facility for treating the ground water and
21 reinjecting it.
22 The contingencies basically deal with
23 possibilities. Okay? We're not that concerned right
24 now, because we don't see a lot of movement in the
25 ground water. What we did is we made a contingency.
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1 For example, number two for containment of that vinyl
2 chloride plume. If we start to see it move, if we're
3 concerned that it's going to get away from us and get
4 out of control, that's when we'll institute that. It
5 involves some wells and pumping and sending the water
6 out.
7 The arsenic contingency is basically to
8 sit and sample the water and see if the arsenic
9 levels rise again. The beginning of the process,
10 when we began looking at this, we saw very high
11 levels. They haven't been repeated, so we're holding
12 that in reserve just in case we need to do it. We're
13 not sure it's going to need to be part of the remedy.
14 These are considered contingencies to the remedy.
15 Next slide, please.
16 For buried debris, we again considered
17 no action. Capping it with clean fill, so basically
18 trying to contain it on site. We considered partial
19 excavation, a larger partial excavation, again was
20 one of the technologies that didn't pass the
21 evaluation. What we're talking about there is
22 basically called soil washing. And that was not
23 considered feasible.
24 And then the last one is a partial
25 excavation, taking out some of the saturated soils,
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1 creating corridors, basically, in an area of that
2 plume, and then all of the oily liquids should flow
3 into those corridors, and they can be pumped out,
4 drummed, and sent offsite for treatment. That is the
5 part of Alternative 7 which is currently the
6 preferred remedy.
7 For the oily liquid wastes which are
8 also known as light nonaqueous phase liquids, or
9 LNAPL, we considered five different options. These
10 were no action, a subsurface barrier, extraction.
11 Again, these three just represent different volumes.
12 We were talking about perhaps 75 percent of what we
13 find, 80 percent of what we find, and up to 100
14 percent of what we find. Okay?
15 One of the reasons we left the volumes
16 out of this discussion to this point is because
17 you're going to have to realize that everything I
18 mention about volumes is approximate. We really
19 don't know 100 percent what's down there. The
20 records from back in the early '80s aren't as good as
21 we'd like them to be. We think we have a good feel
22 for what's there, but the cleanup isn't based on
23 saying we're only going to take 10,000 gallons and
24 stop. The cleanup is based on saying we're going to
25 get as much as the technology can get. We're
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1 assuming this oily liquid plume will produce about
2 10,000 gallons of liquid and about 3,000 cubic yards
3 of saturated soils. Okay?
4 Now, those of you who stopped at the
5 table in the door have a copy of this table. It's
6 fairly complicated. But the most important thing to
7 notice about it is that as we go through the remedial
8 alternatives that were considered, each one of these
9 is a combination of all of the different processes I
10 spoke to in the last four slides. What we're really
11 seeing is you move from Alternative 1 to Alternative
12 8 is we move from greater volumes in onsite
13 containment down to greater volumes in offsite
14 disposal or onsite treatment. Okay? Moving from
15 lesser levels to higher levels of treatment, and also
16 moving from left to right from lower volumes to
17 higher volumes. So you'll see an increase in cost
18 differently throughout 1 through 8. You'll also see
19 an increase in the protectiveness and completeness of
20 the remedy.
21 Alternative 9 and 10 are special,
22 because after we completed that initial assessment,
23 EPA went back and asked for two more addenda to the
24 feasibility study which looked at new possibilities.
25 Alternative 9 was to incorporate the possibility of
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1 land farming the soils that were contaminated.
2 That's basically a composting process that would
3 allow those hydrocarbon wastes to break down.
4 Alternative 10 was to look at another way of possibly
5 containing some of the lower level wastes on site.
6 This basically wraps up my presentation.
7 What we look at here is a slide that talks about how
8 EPA makes its decision looking at all of those
9 alternatives. I understand if you've read the
10 proposed plan, these are fairly complicated. If you
11 do have questions about those, I'd like to try to
12 help people understand a little better. I know it's
13 not a very -- it is a complicated site, and the
14 alternatives we're trying to go through are
15 complicated as well.
16 But basically, what we do once we have
17 those alternatives, we look at nine different
18 standards that tell us whether or not this meets
19 minimum goals. Okay? These first two, protection of
20 human health and the environment, and compliance with
21 applicable, relevant and appropriate requirements,
22 affectionately known as ARARs. And all of those are
23 federal and state requirements that may be outside
24 the realm of the Superfund program. We have to make
25 sure what we are doing complies. Those two are
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1 baseline criteria. If you don't meet them, the
2 alternative doesn't make it into the overall
3 evaluation. It doesn't -- it's not part of the final
4 FS. Okay?
5 From that point on, we look at
6 short-term effectiveness. Is the actual
7 implementation of the remedy going to cause
8 additional exposures? Are there any problems with
9 that? Long-term effectiveness and permanence is
10 fairly self-explanatory. I mean, landfilling isn't
11 necessarily as permanent as some direct treatment
12 that destroys the contaminants. Reduction of
13 toxicity, mobility or volume through treatment. We
14 look at whether or not it's feasible to implement
15 these options as we've discussed them. We look at
16 the cost of this part of the remedy.
17 And it's important enough that what
18 we're talking about today is not the whole picture,
19 because as J.D. mentioned, just for the removal
20 actions, almost $10 million was spent. We're not
21 sure how much that was. But this is part of the
22 whole. Okay?
23 And then we look at State acceptance and
24 community acceptance. A large part of that is what
25 we're doing here now. We published a proposed plan
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1 with a preferred remedy. This is what we believe to
2 be the best approach to the contaminations we found
3 at this site. But your input is going to be very
4 important in making the final decision, and then when
5 we have that, we'll be prepared to write a record of
6 decision and come out with a final plan. Okay?
7 So just to recap, I went through those
8 alternatives and sort of showed you which parts of
9 that were part of Alternative 7. Now what I want to
10 do is show you in essence. Alternative 7 involves
11 the excavation and treatment of the surface soils.
12 Essentially about 22,000 cubic yards. Okay? That's
13 part of a larger soils treatment. You have to
14 understand. Okay? The buried debris area and the
15 oily liquid wastes plume are also going to involve an
16 extraction of soils. In order to get treatment of
17 those, we're going to have to blend all of these
18 soils together so that the treatment technology will
19 work. So basically, that's all going to be done
20 together at once. Okay?
21 We also have excavation of the oily
22 liquid wastes. 3,000 cubic yards of soil will be
23 taken out, but then the rest of that is going to be
24 skimmed out using a pump and skimming machine. It
25 will be drummed and sent offsite for treatment.
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1 The ground water extraction. Again,
2 we're looking at a direct treatment technology here.
3 We're extracting the ground water at a fairly — I
4 don't think it's an extreme rate. We have a very
5 porous aquifer with a very high production of water.
6 So we can get that. And basically, we would just be
7 sending that down to a municipal treatment plant.
8 And then finally, we're going to excavate the debris
9 area and dispose of that debris.
10 All of these options are going to depend
11 in part on what we find when we get to the site.
12 We've got other stages to this process where we're
13 going to be looking at what's there and what are our
14 alternatives. But essentially, that's how
15 Alternative 7 plays out. Thank you.
16 MS. NANCY MUELLER: Thanks, Dan. Now we're
17 coming to your part of the meeting. Before we get
18 started, though, I'd like to just maybe lay down a
19 few ground rules and introduce a person that I forgot
20 that's pretty key to this process. This,is Mary
21 Quinn. She's a certified court reporter. She will
22 be preparing a transcript of this meeting tonight
23 which will be put into the administrative record up
24 at the Marriott Special Collections Library at the
25 University of Utah as well as being available at the
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1 record center in Denver at the EPA offices.
2 A couple of the ground rules that we'd
3 like to -- I'd like to give you. First of all, all
4 comments are welcome. We're here to listen to you.
5 We want to hear what you have to say. Because
6 there's some residents that are here this evening,
7 we'd like to give them first chance to give their
8 comments, either residents or representatives of --
9 we have a community group that's represented here
10 that has been very active in working with us on a lot
11 of the issues at the site. So we'd like to let the
12 private citizens, if you will, have a say first. If
13 you didn't sign up, that's no problem. We'll still
14 let you make comment. If you signed up and changed
15 your mind, that's no problem either. You don't have
16 to say anything.
17 Because there's quite a few of you here
18 tonight, we'd like to give everybody a chance to have
19 their say. We'd like you to keep your comments as
20 brief and to the point as possible. And if you can,
21 three to five minutes would be great.
22 Mary has asked that when you do stand to
23 give your comments, please state your name very
24 clearly to her, and if it's an unusual spelling,
25 spell it for her too. It's important that we get
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1 that right in the transcript. And if you come back
2 for a second comment, please state your name the
3 second time as well.
4 Jim just reminded me, if after you've
5 been here tonight and even if you've made a comment
6 tonight, you can still submit written comments to us.
7 Right now, the close of the comment period is the 8th
8 of August, I believe. Those comments need to come in
9 to Dan by that time. The address is in the proposed
10 plan. There's extra copies out at the sign-in table
11 by the front door. If you didn't get one or if you
12 don't have it anymore, please feel free.
13 Dan just informed me that we've received
14 a request to extend the public comment period, so you
15 have 30 days beyond what the proposed plan says.
16 That will be published in the newspaper in Salt Lake
17 here announcing that extension. So we'll go into the
18 first week of September now. I can't count my days
19 quite that fast. I don't want to make another
2 0 mistake.
21 So with that, I've got the sign-in
22 sheet. Renette, were there any more? Okay. You
23 signed in as you came in. And we have some — we
24 have two community representatives that we'd like to
25 give their chance to. The first one is Paul
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1 Anderson. And he is the technical consultant for the
2 group for the Petrochem site. September 7th is when
3 the public comment period is closed.
4 MR. PAUL ANDERSON: I'll read this into the
5 record. My name is Paul Anderson. I'm a consulting
6 geologist and the Capitol Hill Neighborhood Council's
7 technical advisor on the Petrochem/Ekotek site.
8 The trustees of the council met last
9 week and reviewed EPA's proposed plan for the site.
10 The trustees are an executive body of the Council
11 with representatives from various neighborhoods or
12 areas within the Council boundaries. The trustees
13 decided to make a statement at this meeting, but the
14 Capitol Hill Neighborhood Council has not reviewed
15 the preferences of the trustees and reserves the
16 right to revise its position on the proposed plan
17 after the full Council meets in mid August. The
18 Council asked for a 30-day extension to the public
19 comment period in order for the full Council to
20 discuss the proposed plan and make written comments.
21 The Council trustees support the
22 recommendations of the Capitol Hill Neighborhood
23 Council's Ekotek Committee which in February of 1995
24 expressed to EPA and the State a preference for
25 Alternative 6. After review of the proposed plan and
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1 new Alternatives 9 and 10, the trustees see no
2 compelling reason to change their recommendation to
3 the EPA and the State of Utah. Alternative 6 remains
4 their preferred alternative.
5 Alternative 6 differs from EPA's
6 selected Alternative 7 in addressing the cleanup of
7 contaminated ground water at the site. EPA has
8 selected a pump and treat technology for ground water
9 cleanup. The trustees prefer the use of intrinsic
10 remediation for the following reasons:
11 One. Ground water contamination is
12 limited to the uppermost or shallow aquifer. This
13 aquifer is not used for drinking water in the local
14 area.
15 Two. The levels of contamination are
16 very low and limited, based on the last few
17 sampling — episodes of sampling, to vinyl chloride.
18 Three. Recent sampling and the expanded
19 network of monitoring wells indicate that an offsite
20 source of the parent product of vinyl chloride
21 exists. Until this source is located and removed, it
22 is unreasonable to attempt to aggressively -- to
23 attempt to aggressively pump and treat onsite ground
24 water.
25 Four. Hydrogeologic data indicates that
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1 under present conditions, the likelihood of migration
2 of the plume into the deeper principal aquifer, the
3 one used for drinking -- which is used for drinking
4 water, is remote. It also appears to the trustees
5 unlikely that the shallow aquifer would be considered
6 as a source of drinking water in the next decade,
7 which is the estimated time required for intrinsic
8 remediation to prove effective.
9 Five. Geochemical conditions at the
10 site indicate a reasonable probability that intrinsic
11 remediation will work. The trustees recognize the
12 need for continued monitoring with the possible
13 expansion of both the constituents monitored and the
14 number of monitoring locations.
15 Six. Intrinsic remediation represents
16 some risk in that it is not a proven technology at
17, this site, but the cost is much lower than the pump
18 and treat alternative, and it is not clear that the
19 risk is any greater.
20 The trustees encourage EPA to consider
21 proceeding with the soils cleanup if the debate on
22 how to clean up the ground water appears to be an
23 extended one. Thank you f.or the opportunity to
24 comment.
25 MS. NANCY MUELLER: Thank you. The other
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1 community representative is Karen Silver from the
2 Salt Lake community action program. Karen?
3 MS. KAREN SILVER: I have no comments at
4 this time.
5 MS. NANCY MUELLER: Thank you. Okay. I'm
6 going to start going down the list now. I may mangle
7 your names. So bear with me, please. First name on
8 here, Denise Kennedy. Are there any other residents
9 that didn't sign up that would like to say something
10 before Denise gets started? Okay. If you change
11 your mind, you can still come back.
12 MS. DENISE KENNEDY: I'm Denise Kennedy
13 with the law firm of Holland & Hart. And we're
14 common counsel for the Ekotek Site Remediation
15 Committee which is a group of about 43 companies that
16 were all customers of the Ekotek site and have been
17 working with EPA and the State of Utah in cleaning up
18 the emergency removal action that J.D. Keetley
19 referred to, conducting the remedial investigation
20 and feasibility study.
21 If anybody wants to move up, feel free.
22 We don't have overhead. We've just got these
23 graphics. But you can all see those, hopefully.
24 We've got individual representatives of
25 some of the Committee members here. Some of them
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1 will make statements after the Committee presentation
2 is concluded, and others will -- we just want you to
3 know they're here, they're committed to working with
4 the State and EPA and the community on the cleanup.
5 Those companies that are represented
6 here tonight are Union Pacific, Kennecott, Quaker
7 State Minute Lube, U.S. Steel, DHP Minerals, Parker
8 Hambly, and Texaco.
9 By way of background, I want to explain
10 a little bit of the Committee's involvement with the
11 site. The Committee members are all essentially
12 innocent customers of the Ekotek site. They used the
13 Ekotek site. They had used oil or hazardous waste
14 that had to be disposed of. The Ekotek site was a
15 fully permitted, regulated facility legally entitled
16 to accept those wastes. And the Committee members
17 relied on the regulatory — the regulatory
18 authorities in sending wastes to the site.
19 Unfortunately, the law that is at issue
20 here tonight, Superfund, doesn't care about whether
21 you did something wrong or not. It imposes liability
22 in a situation here where the owners have all gone
23 bankrupt. There was actually a criminal proceeding
24 against the owners of the site for not complying with
25 the law. But again, we're dealing with -- no one is
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1 at fault in terms of the parties that are going to be
2 responsible for paying the cleanup costs of the site.
3 The Committee has already spent about
4 $17 million in the removal action at the site and
5 conducting a remedial investigation feasibility
6 study. The prior work that's been done at the site
7 addressed the immediate problems. If you go out and
8 look at the site today, it looks very different from
9 the pictures we saw today. There are a few buildings
10 remaining on site, but otherwise all of the tanks,
11 all of the visible contamination problems are gone.
12 Now with the remedial investigation and the
13 feasibility study completed, it's time to talk about
14 what additional cleanup actions need to be taken at
15 this site.
16 Because there is no fault on the part of
17 the Committee members, no environmental laws were
18 violated in connection with their use of the site,
19 the cleanup should not be a punitive cleanup. We
20 should not be punishing the companies that are
21 basically under the law having to come forward and
22 pay for the cleanup of the site. The law requires
23 that the most effective cleanup that protects human
24 health and the environment and meets the cleanup
25 standards be selected. We don't believe that's been
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1 done here. Just because we've got viable companies
2 doesn't justify selecting a cleanup method that is
3 ten and a half million dollars more expensive than a
4 cleanup remedy that meets all of the standards.
5 These are strong words. The comments
6 that are going to follow by some of the other
7 representatives of the Committee will strongly
8 support a different, less expensive remedy, but
9 again, one that we believe meets all of the cleanup
10 requirements. I don't want you to lose sight,
11 though, of the fact that the Committee is committed
12 to a safe cleanup. And we want to get that site
13 cleaned up, we want it to be protective of human
14 health and the environment, and we want that site to
15 get put back into use. We want someone to come back
16 in and get that site — redevelop the site so that we
17 don't have a blight on the neighborhood.
18 I want to just kind of refer to this
19 chart. More detail will be gone into by some of the
20 other representatives. EPA's already gone into some
21 of the specific detail about Alternative 7 which is
22 EPA's preferred alternative, and Alternative 10 which
23 is the Committee's preferred alternative.
24 As this chart indicates, and this is
25 right out of the proposed plan, Figure 3 from the EPA
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1 proposed plan, there are three categories here. The
2 minus sign if a particular remedy doesn't meet the
3 requirement, and these are the requirements that EPA
4 has to consider in determining the appropriate remedy
5 at the site. The check mark says it meets the
6 requirements. And the plus sign says it fully
7 complies with the requirements.
8 Alternative 7, the black marks are what
9 appear on the EPA proposed plan. Has pluses across.
10 The Alternative 10 has some checks and some pluses,
11 but it meets all of the requirements.
12 As you heard from Paul Anderson, the
13 representative for the community group, in fact there
14 is additional ground water information developed by
15 the Committee over the last three or four months at
16 considerable expense that EPA had before it came out
17 with the proposed plan, but because of timing chose
18 not to consider that information. We understand they
19 are going to consider this information in this next
20 comment procedure. But many of the factors alluded
21 to by Paul Anderson indicate that the pump and treat
22 option on the ground water simply will not work.
23 When you review the text of the proposed
24 plan, it indicates that the reason they've determined
25 that Alternative 7 gets a plus and not a check for
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1 protectiveness is because they deemed that pump and
2 treat is more protective than the intrinsic
3 remediation. When you review the ARARs, ARARs are
4 the applicable, relevant and appropriate standards,
5 essentially the ground water cleanup standard, again
6 in reviewing the text of the proposed plan, is the
7 basis for EPA considering this to be a plus. They
8 believe pump and treat is more effective than
9 intrinsic remediation. Again, that's not considering
10 this recent ground water information. Similarly,
11 here, implementability. They both get pluses.
12 This additional ground water information
13 suggests that pump and treat is something not
14 implementable. It's not a feasible technology at
15 this site.
16 Cost. EPA should be comparing the
17 costs. Here we've got ten and a half million dollars
18 less. In our minds, that renders this fully in
19 compliance with the cost effectiveness, and in light
20 of some of the less expensive remedies, that would
21 give this one a negative sign.
22 In considering the additional ground
23 water information that's been developed and the cost,
24 Alternative 10 actually ranks higher than the EPA
25 alternative.
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1 I just want to introduce briefly the --
2 there will be four people following me who are all
3 representatives of the Committee. And I'd like to
4 briefly refer to them and indicate what they're going
5 to be talking about. We'll have Sarah Black with
6 Rust Environmental and Infrastructure. She was the
7 project coordinator on the remedial investigation
8 feasibility study. The Committee actually did that
9 work. EPA made sure we did it right and complied
10 with the requirements. But we actually did the work
11 in the remedial investigation and feasibility study.
12 It was Sarah that headed up that project.
13 Sarah is going to compare the cleanup
14 elements of Alternative 7 and Alternative 10. In
15 addition, we'll discuss this new ground water
16 monitoring information indicating that there is an
17 offsite source of a precursor to the vinyl chloride.
18 It's a solvent that has been measured offsite
19 upgradient of the site that we know to be — as it
20 breaks down, it will break down to vinyl chloride,
21 and we believe that is a significant source of the
22 vinyl chloride we're measuring onsite.
23 Arsenic is a naturally occurring ground
24 water constituent in the Salt Lake Valley rather than
25 something that's attributable to the site operations.
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1 Dr. Jennifer Heath will follow Sarah. Woodward-Clyde
2 Consultants. She was involved in working with EPA.
3 She'll discuss the risk assessment and why the
4 Committee's preferred alternative fully protects
5 human health and the environment, meeting all the
6 cleanup standards.
7 Dr. Bob Berry is a senior hydrogeologist
8 with Shepherd Miller out of Fort Collins in Colorado.
9 He's going to talk about the recent ground water work
10 that we've all been referring to that's been done,
11 what it tells us about why pump and treat won't work,
12 and why, hydrogeologically and given the offsite
13 source of TCA and the naturally occurring arsenic
14 contamination, pump and treat simply will not work at
15 this site.
16 Dr. Ed Bouwer is a professor at Johns
17 Hopkins University. He's a nationally renowned
18 expert on intrinsic bioremediation of these solvents.
19 He's the author of two books. One is funded by the
20 National Research Council, the other was funded by
21 EPA. Actually, sorry, he was cooperating or working
22 on those books. There were many authors involved.
23 One was a National Research Council book, and one was
24 sponsored by EPA. The books together demonstrate
25 that pump and treat has been attempted at numerous
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1 contaminated sites throughout the country and simply
2 has not worked.
3 Intrinsic bioremediation appears to be
4 the most promising remedy for ground water for these
5 organic solvents that we're dealing with. He'll give
6 his opinion that intrinsic bioremediation would be
7 effective at the site and his conclusion that the
8 offsite plume of the organic solvent that's moving
9 onto the site is a contributing factor to the vinyl
10 chloride measured on site.
11 With that, I'll sit down and let Sarah
12 Black comment.
13 MS. SARAH BLACK: I'll bring up a couple of
14 these posters as well. My name is Sarah Black with
15 Rust Environmental and Infrastructure as Denise
16 indicated. I've been involved with the project since
17 1991. And I'd like to just take a few moments to
18 compare the two alternatives that are being talked
19 about here tonight. Alternative 7, which is
20 preferred by EPA, and Alternative 10, which the
21 Committee prefers.
22 We'd like to point out that both
23 alternatives meet EPA's standards and requirements,
24 as Denise just showed with her graphic. We don't
25 believe that Alternative 7 is necessary. Both
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1 alternatives accomplish the same goals for soils with
2 risks greater than one in 10,000 for the floating oil
3 and for the debris area. And that is that the --
4 what we call the hot spot soils are those soils with
5 risks greater than one in 10,000 will be either
6 treated on site or taken off site for disposal. The
7 oil will be excavated and either treated on site,
8 again, or taken offsite for disposal. And the debris
9 area, same situation. It will either be -- with both
10 alternatives would be excavated and either treated
11 with onsite treatment or taken off for disposal. The
12 differences come in how the excavated soil and ground
13 water are dealt with, as Denise indicated.
14 Alternative 7 would thermally treat all
15 of the excavated soil that would have to be removed
16 to get at the oil. And that would be accomplished
17 with a thermal disorption unit that would be moved
18 onto the property and operated for several months.
19 Alternative 10 by contrast puts three
20 feet of clean soil which would be imported, clean
21 soil purchased as back-fill into the excavation at
22 the ground water table. Replaces the excavated soil
23 in on top of that clean soil and then places three
24 and a half feet of clean soil at the surface to
25 prevent exposure.
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1 If you think back to Dan's discussion of
2 risk, he talked about how that exposure has to be
3 present to cause risk. We feel that — we've
4 actually got a little graphic here that shows a cross
5 section through the site that demonstrates — if you
6 can't see this, we'll have it in the back here -- but
7 this shows the clean soil that would be placed at the
8 water table, the replaced stockpiled soil, and three
9 and a half feet of clean soil at the surface to
10 prevent any exposure.
11 The three and a half feet of soil in our
12 opinion prevents any future exposure as well by
13 exceeding any standard construction techniques or —
14 standard construction techniques and utility depth of
15 excavation.
16 In terms of the ground water, we don't
17 believe that pump and treat is a viable approach.
18 And our recent data that Denise alluded to shows that
19 the unique hydrogeology of this site works — really
20 works against effective capture of the plume of
21 contaminants.
22 Our monitoring data has revealed that
23 there actually is another source of solvents
24 upgradient of the site. TCA is the name of the
25 solvent that actually can be a precursor to vinyl
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1 chloride. We feel that's contributing. And in fact,
2 in our opinion, pump and treat would never be
3 effective to accomplish its goal with that other
4 source present.
5 And finally, ground water treatment. To
6 address arsenic as a contaminant we don't feel will
7 be effective since in our view, the arsenic is a
8 naturally occurring background constituent. It has
9 occurred in our monitoring at concentrations higher
10 than EPA's maximum contaminant limit in a well nearby
11 at 160 parts per billion. And we also have
12 information for the region that shows that it can
13 occur higher -- right now in the drinking water
14 aquifer at higher than EPA's standard.
15 So these issues will be gone into in
16 more detail by Dr. Berry and Dr. Bouwer. So with
17 that, I'll turn it over to Jennifer Heath which is
18 actually going to discuss some more about the risk
19 issues at the site. Thank you.
20 MS. JENNIFER HEATH: I am Dr. Jennifer
21 Heath with Woodward-Clyde. I've been working on
22 behalf of the Ekotek Site Remediation Committee
23 representing risk assessment at the site and was
24 involved with the EPA risk assessors when they did
25 the human health and ecological risk assessments.
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1 Can everyone hear me? What I'd like to talk --
2 UNIDENTIFIED: We didn't get your name.
3 MS. JENNIFER HEATH: I'm Dr. Jennifer
4 Heath. I've been working on behalf of the Ekotek
5 Site Remediation Committee for a couple of years at
6 this site and was involved with the EPA risk
7 assessors when they performed the risk assessment
8 that Dan discussed earlier.
9 What I'd like to do this evening is
10 briefly discuss risks associated with the site prior
11 to remediation under the current conditions as well
12 as risks associated with Alternatives 7 and 10.
13 That's EPA's preferred alternative and the
14 Committee's preferred alternative.
15 I'd like to step back for a second and
16 reiterate something that Dan said in his presentation
17 about risk assessment. You remember he had an
18 overhead where off to one side there were four little
19 boxes about the risk assessment, and one was .
20 exposure, and one was toxicity. And we need to keep
21 in mind that risk is a function of exposure and
22 toxicity. You have to have both of them. Exposure
23 has to do with whether humans or ecological receptors
24 can come into contact with contaminants from the
25 site. Toxicity has to with inherent properties of
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1 chemicals and adverse effects. You need to have both
2 a toxic chemical and exposure in order to have the
3 risk. If there isn't any exposure, there is not any
4 risk. Indeed, that's what most remediation is doing
5 is changing how ecological receptors can be exposed
6 to site related contaminants. It's reducing where
7 remediation is meant to reduce exposure potential to
8 contaminants.
9 EPA did as Dan explained what he called
10 a conservative risk assessment. That means it was a
11 protective risk assess. And Dan said that pretty
12 clearly. I just wanted to summarize for you quickly
13 what the results of that risk assessment was. What
14 I'm referring to here is back in EPA's proposed plan.
15 On the top half of Page 5, they briefly summarize the
16 results of the risk assessment. And that's what I'm
17 harking back to when I provide you this number which
18 is one in 100,000.
19 Using the current site conditions where
20 all the contaminants are now and assuming that there
21 are workers, industrial sort of indoor office
22 workers, onsite in a regular work setting. And they
23 work there 219 days a year for five years. But there
24 wasn't any cleanup at the site. The risk associated
25 with the site is one in 100,000. Let's put that into
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1 a bit of context.
2 On the other side, we have EPA's risk
3 range that they stated in policy documents. And the
4 risk range that EPA has provided is a range of one in
5 10,000 to one in a million. And if the risk is
6 within or below that range where the accumulative
7 risk — this is a statement out of an EPA policy
8 document — where the accumulative risk is less than
9 one in 10,000, and our risk is one in 100,000, that's
10 less than one in 10,000, cleanup action generally is
11 not warranted. So according to EPA policy documents,
12 it's not necessary to do any remediation at this site
13 in order to protect human health or also the
14 environment.
15 However, the Committee wants to do
16 remediation on this site. We want to make it cleaner
17 than it already is. And so what I'd like to talk
18 about for just a moment is a quick look at comparison
19 of residual risks associating with Alternative 7,
20 EPA's preferred alternative, and Alternative 10, our
21 alternative, just associated with soil.
22 The other speakers are going to talk
23 about ground water. Just looking at the soil
24 remediation aspect, those of them will reduce soil
25 related risk to a level of one in a million.
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1 Right now, this is kind of a diagram
2 that's showing us where we are now. We're starting
3 out at ten to the minus five, according to EPA's risk
4 assessment. We're starting out at a soil related
5 risk of ten to the minus five. Both of these
6 alternatives are going to clean it up to ten to the
7 minus six. Which is at the most protective end of
8 that range that EPA provides. Both EPA's preferred
9 alternative as well as ours are going to achieve the
10 same level of additional protection of human health
11 associated with the soils.
12 To remind, according to EPA's policy
13 document, the site would not necessarily require
14 cleanup as is. Even if it were used in the faculty
15 for industrial purposes. We do want to return the
16 site to productive use. However, we would like to go
17 ahead, nevertheless, and clean up the soils to an
18 even cleaner level, and the alternative that Sarah
19 described where we sort of sandwiched excavated soils
20 between three feet of clean soil underneath and three
21 and a half feet of clean soil above precludes any
22 potential exposure. If there's no exposure, there's
23 no risk. And therefore, it provides protection to a
24 very significant level and the same level as EPA's
25 alternative.
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1 We feel that our alternative is as
2 protective as EPA's. We would like EPA to be
3 considering that alternative. Thank you. I'd like
4 to introduce Dr. Bob Berry.
5 MR. ROBERT BERRY: I'm Bob Berry. I'm a
6 hydrologist with Shepherd Miller, a consulting firm
7 in Fort Collins, Colorado. We are consultants to the
8 Committee for hydrology to help them understand the
9 complex hydrology of the site. Apologize for the
10 small size. You can look at this later after the
11 talk.
12 Let me lay some groundwork for you. If
13 I need to draw, I will. You've heard about pump and
14 treat. You've heard Paul Anderson say that the
15 Citizens Committee does not favor pump and treat for
16 two reasons. One, the plume is not moving on the
17 site. And the second, there is a potential offsite
18 source coming into the site. In this case from the
19 mountains, from uphill. Which would just make things
20 worse if you txied to pump it.
21 There's a third reason you don't want to
22 use pump and treat out here. That is the unique
23 nature of this aquifer which will mean if you try to
24 pump the fresh water, what you will get instead is
25 what is called geothermal water. Hot water. And you
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1 won't be getting vinyl chloride. You'll be getting
2 hot water. You'll be sending that hot water to your
3 public waste water facility. On this graph, you can
4 see that here's the site right here. Small little
5 area right here. This is the Wasatch Mountains. And
6 this is the Salt Lake Valley down through here. In
7 the Salt Lake Valley, there are three bodies of
8 water, underground bodies of water called aquifers.
9 There's a shallow one called the shallow aquifer.
10 You do not use it in the Salt Lake Valley. It's
11 where the swampy water you see in the valley comes
12 from. It's not used for drinking water. It would
13 not be good for drinking water.
14 Beneath that is the principal aquifer,
15 as it's called here. It's called principal because
16 that's where most of the water for Salt Lake comes
17 from. That's your major source of water. It sits in
18 a body of sand and gravel down here. And this is
19 where most of the water in Salt Lake for public use
20 comes from.
21 There's a third aquifer which I'll talk
22 about in some detail. It's geothermal water. Hot
23 water. Where does it come from? You have hot
24 springs all along the Wasatch Front. Most of you who
25 have lived here all your lives know about that.
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1 Clark Springs, Warren Springs, so forth along the
2 fault. What these things are, hot water coming up
3 from deep within the earth. This water is salient.
4 You don't want to drink it. It's usually too hot to
5 even bathe in. Very hot.
6 The Ekotek site sits on top of this
7 geothermal or hot water. In fact, there is only
8 about 40 to 60 feet of fresh water sitting on top of
9 this hot water. The fresh water is where the
10 contamination is. The vinyl chloride is in the fresh
11 water. It's not in the hot water. The fresh water
12 that flows into the site comes from two principal
13 sources. The Wasatch Mountains. It flows
14 downgradient, so to speak, down from the mountains
15 underneath the site.
16 There's another source of fresh water
17 beneath Ekotek. And that is from the principal
18 aquifer. The one where most of your water comes from
19 in Salt Lake City. The water down here is under
20 pressure. And it's under greater pressure than the
21 fresh water beneath Ekotek. What happens? Water
22 flows from high pressure to low pressure. You've
23 heard from high to low. Usually from uphill to
24 downhill. Really, it's from high pressure to low
25 pressure. This water is under greater pressure than
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1 it is underneath the site. So water from the
2 principal aquifer flows into the site. So you have
3 converging flow. Flow from the mountains, flow from
4 the valley. They converge right here.
5 That's why the vinyl chloride plume
6 isn't moving. It can't go anywhere. It can work its
7 way down from the mountains, and that is the offsite
8 source you've heard about. Dr. Bouwer will talk
9 about that in more detail. So it can come down from
10 the mountains and come underneath the site, but it
11 can't go anywhere. Why? Because water from the
12 principal aquifer is flowing up to meet it. These
13 two sources of water meet right underneath the site.
14 The vinyl chloride can't go any where. It's stuck.
15 It's going to stay there.
16 That's why as Paul Anderson and everyone
17 preceding me said, the plume isn't moving. It isn't
18 a threat to anybody right now. It's staying where it
19 is. That is one of the beneficial aspects of this
20 site in terms of ground water. We don't have to
21 rush. We can watch and see what happens with time.
22 As you'll hear next it is already beginning to
23 degrade. Vinyl chloride is naturally decreasing in
24 concentration.
25 You've also seen in Alternative 7 that
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1 the EPA would like us to pump the vinyl chloride out.
2 Put in a well and pump the vinyl chloride out. What
3 will happen if you do that? If you put the pump in
4 with this geothermal or hot water right beneath it,
5 what you're getting is hot water. Not fresh water.
6 Why? Because what's holding this pressure surface
7 down right here is this converging flow of two fresh
8 water bodies.
9 If you start pumping it, you pull that
10 pressure down. And this geothermal or hot water
11 comes right up. This happens, for instance, in
12 coastal regions such as Florida, Hawaii, the East
13 Coast of the United States, places like Maine, for
14 instance, and Massachusetts. These areas have fresh
15 water on top of salt water. They have to get their
16 drinking water from the fresh water. Nobody wants to
17 drink ocean water. So they do put wells into that
18 fresh water in order to have drinking water for
19 people that live along the shore line.
20 But they have to be careful how they
21 pump it. If they pump it too hard, it's sea water,
22 not fresh water. Many of the larger cities on the
23 East Coast, and especially in Hawaii, have already
24 pumped too much fresh water. They can't pump any
25 more. They have to get surface water for their
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1 drinking water. They can't use ground water any
2 more.
3 What will happen here is if you put in a
4 pump, even at 40 to 100 gallons a minute, you will
5 bring geothermal or hot water right up into the pump
6 and down to your public waste facility. That isn't
7 what you want to do. That's not going to clean up
8 the vinyl chloride. It's also going to make cleaning
9 up the vinyl chloride difficult, if not impossible.
10 These aren't two floating bodies of water. This
11 isn't like oil and vinegar. An aquifer is sand.
12 Sand saturated with water. Sand has pores in it.
13 Large pores and small pores. When the geothermal or
14 hot water comes up into that sand part of that
15 pressure water aquifer, it's going to fill a large
16 pore. It's going to block off the small pore.
17 You're not going to get anything out of the small
18 pores. That means you won't get the vinyl chloride
19 out. Not only will you be pumping hot water instead
20 of fresh water, you will not be able to get all the
21 vinyl chloride out. Your cleanup efficiency will
22 drop well below 50 percent, maybe below 30, depending
23 on how much you try to pump.
24 You've heard pump and treat won't work
25 because the plume is not going anywhere. There's an
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1 offsite source. There's a third reason. I'd like
2 all of you to understand who live in this area.
3 Ekotek sits on top of a geothermal reservoir. It
4 sits on top of hot water from deep in the earth. If
5 you try to pump the vinyl chloride, you'll wind up
6 sending hot water to your public treatment facility.
7 Down your sewer system to your waste facility. And
8 that's the last thing you want to do.
9 I'd like to turn it to Dr. Ed Bouwer.
10 He'll explain the chemistry of what's going on and
11 why the vinyl chloride is naturally decreasing in
12 concentration.
13 MR. ED BOUWER: I'm Professor Bouwer,
14 B-0-U-W-E-R, professor of environmental engineering
15 at Johns Hopkins University in Baltimore, Maryland.
16 And as Denise mentioned, I've been working in this
17 area for 16 years. On subsurface and ground water
18 contamination. And recently I was part of the
19 committee on the National Research Council that
20 examined alternatives to ground water cleanup.
21 Looked at pump and treat, evaluated its merits and
22 pitfalls as well as made recommendations.
23 Two conclusions from that are pump and
24 treat is not a very viable remedial strategy,
25 particularly for chlorinated solvent type
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1 contamination. And secondly, that we strongly
2 endorse technology like intrinsic remediation to help
3 clean up sites.
4 I was contacted last fall by the
5 Committee to examine the site, and I essentially
6 started in October last year like you all started,
7 looked at it, made recommendations on how to go about
8 assessing whether or not intrinsic processes were
9 occurring, and helped interpret the data to make our
10 final conclusion which we recently submitted an
11 aquifer characterization report and made
12 presentations to EPA and others. I want to highlight
13 what those findings are.
14 First of all, what do we mean by
15 intrinsic remediation? The aquifer is cleaning
16 itself up. We found out by examining sites now for
17 10 or 15 years that several sites, Mother Nature is
18 doing a pretty good job. Chemicals have been there a
19 long time, microorganisms there are there are
20 adapting to the contaminants and contaminants are
21 being degraded and converted to innocuous and
22 nontoxic compounds on their own, left to natural
23 devices. What I want to do is provide you evidence
24 that we have at the site and how I base my
25 enthusiastic and positive opinion about intrinsic
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1 remediation.
2 First of all, what we've been doing at
3 the site, we've been characterizing concentration
4 levels of contaminants in the ground water. This has
5 been done for several years now. We have data
6 starting in January of 1993. What we're plotting is
7 a concentration of the vertical axis in time and the
8 horizontal axis. We've looked at vinyl chloride in
9 this particular monitoring well on this site. We
10 observed a general cleaning trend in the
11 concentrations of vinyl chloride. This is one well.
12 Another well. Similar kind of data, concentration
13 versus time, showing this trend.
14 If we look at the removal, what's
15 happening is vinyl chloride is being transformed, in
16 this case to a nontoxic product. This transformation
17 as a removal process converts vinyl chloride from a
18 toxic compound itself to a nontoxic final product.
19 If you look at the rate, how fast it declines, we can
20 extrapolate that it will take roughly three to five
21 years to reach the cleanup goals, which are two part
22 per billion. This particular well seems to be in
23 that range. Some of the other ranges are getting
24 close to that. This would suggest natural process,
25 intrinsic remediation, would take three to five years
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1 to achieve the removal of the vinyl chloride.
2 Other measurements. We not only look at
3 the disappearance of the compounds, but we also look
4 for the right chemistry. We know that these solvents
5 in order to degrade like the vinyl chloride appears
6 to be doing, it needs a certain chemistry. That
7 chemistry turns out to be an aerobic chemistry.
8 There are aerobic organisms, but there are others
9 that are anaerobic. They were on this earth before
10 plants carried out photosynthesis. We have a measure
11 for that.
12 This blue sort of cloud-like circle
13 there, what that does is it describes an envelope at
14 the site in which we have very strong anaerobic
15 conditions. Very favorable for this transformation
16 of vinyl chloride. Indeed, the vinyl chloride that
17 we're speaking of is disappearing in into region
18 shown by the circle. This other line is a similar
19 region not quite as anaerobic but fairly anaerobic.
20 Reactions can occur for degradation. There's an
21 envelope around the site that has very favorable
22 chemistry due to natural conditions already there.
23 If we go in and do pump and treat, one
24 of the main problems, another additional problem in
25 addition to what Bob Berry and others have already
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1 said, when you start pumping, you're going to disrupt
2 this favorable chemistry. And you will no longer
3 have the reducing conditions anymore. You'll be
4 pulling in geothermal water, also pulling in other
5 water surrounding, and you'll collapse that natural
6 condition. What's you'll do is disrupt this
7 favorable natural chemistry, and you will no longer
8 get effective intrinsic remediation. Pump and treat
9 itself will disrupt what nature already seems to be
10 doing quite well at the site.
11 Over the past six months, we have done
12 more extensive monitoring at the facility. We've
13 expanded a network of wells that are present. And I
14 should get Vanna White to walk around the room with
15 this. The Ekotek site is here. Again, we're looking
16 toward the site boundary. The vinyl chloride has
17 been detected in this region. That's where I showed
18 the favorable anaerobic chemistry. What we've
19 discovered over the last six months by expanding the
20 monitoring well network, we have an offsite source of
21 a TCA which is a parent compound for vinyl chloride.
22 It's been puzzling over the past year of
23 looking at this site, we've never seen an obvious
24 source for this vinyl chloride. The levels are low,
25 part in billion range. Very low risk at the site.
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1 I've worked at a number of sites, and we find tens of
2 thousands of higher concentrations. Already the
3 vinyl chloride is very low. Very manageable risk
4 , exists from that.
5 What source could have caused that vinyl
6 chloride? We've identified our major source. There
7 is this trichloroethane, TCA compound that's moving
8 into the site. What's happening is TCA is being
9 transformed by these natural processes. What
10 happens? It gets degraded to vinyl chloride. As
11 this TCA comes in, it gets transformed to vinyl
12 chloride. Then we have this vinyl chloride plume.
13 Fortunately, the site chemistry is
14 favorable and it's handling that vinyl chloride and
15 we're keeping this plume very tight to the site. Dan
16 Thornton mentioned the plume is not moving. It
17 appears to be stable. Therefore, again, intrinsic
18 remediation seems to be doing the job in terms of
19 remediating ground water there.
20 I guess the remark is pump and treat —
21 given this offsite source now, this pumping will
22 simply pull more of this in and is not going to clean
23 up that TCA source. It's going to hamper the pump
24 and treat activity and will disrupt the natural
25 processes. And, in fact, the vinyl -- vinyl chloride
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1 is being contained. I hope EPA gives intrinsic
2 remediation a chance before they select pump and
3 treat for the alternative on this site. Thank you
4 very much.
5 MS. DENISE KENNEDY: Just in summary, there
6 are two ways to clean up the site. Both of them meet
7 all of the EPA requirements for the foregoing reasons
8 that we've all suggested. The fact that one is more
9 cost effective than the other. We believe that
10 Alternative 10 should be selected as the site cleanup
11 remedy. We're here to talk with people. We're happy
12 to talk with anybody after the meeting. We're open
13 and looking forward to talking with the State and EPA
14 on the remedy. We're committed to a remedy that's
15 soundly based in technology and science at the site.
16 Thank you.
17 MS. NANCY MUELLER: Thanks, Denise. Okay.
18 Mr. Ray? Phil Ray?
19 MR. PHIL RAY: I have no comment at this
20 time.
21 MS. NANCY MUELLER: Thank you. Mr. Chiaro?
22 MR. PRESTON CHIARO: Preston Chiaro,
23 C-H-I-A-R-O. I'm the vice president of technical
24 services for Kennecott Utah Copper Corporation.
25 We're a member of the Ekotek Site Remediation
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1 Committee and have been working with the other people
2 and companies along with the EPA and State trying to
3 find a solution to the problem at the site.
4 Like many other small and large
5 businesses here in Salt Lake, we sent used oil to the
6 Ekotek site with the belief that it would be recycled
7 responsibly. Unfortunately, that wasn't the case.
8 And we now have the problem at the site. The former
9 owners of the site are not available to take care of
10 the problem, so we're stuck with it.
11 We are — Kennecott's very familiar with
12 cleanups of abandoned hazardous waste sites. We're
13 spending money on the west side of the valley to
14 clean up mine waste sites. We do want the cleanup
15 alternative as chosen here to be as affirmative as
16 possible. We want to protect people and the
17 environment. We also want it to be cost effective.
18 As Denise said, the parties who sent
19 materials to the site were following the law at the
20 time. We didn't do anything irresponsible. We don't
21 think a punitive remedy is really appropriate in this
22 situation. I've got several pages of comments which
23 basically will reiterate and support what the Ekotek
24 Site Remediation's findings have been. We'll submit
25 the written comments to the record.
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1 I would like to summarize that we do
2 support Alternative 10 as being the best remedy for
3 this site. It does meet EPA's requirements. It's a
4 cost effective remedy as an added bonus. It actually
5 creates less disruption at the site than EPA's remedy
6 does. As you heard from the experts that have spoken
7 tonight, some aspects of EPA's preferred remedy,
8 preferred approach, actually carry more risks with
9 them than the Committee's recommended solution. So
10 that's primarily why we support Alternative 10.
11 We also stand ready to meet with any of
12 the local citizenry, the Capitol Hill Neighborhood
13 Council or the TAG group to discuss any of these
14 issues. We live and work in this area and have our
15 own workers in this area as well as the people making
16 the decisions on the site. We have a vested interest
17 in this area. We want to do the right thing. We
18 think Alternative 10 is the responsible choice. And
19 that's what we support.
20 MS. NANCY MUELLER: Thank you. Brad Bowen?
21 MR. BRAD BOWEN: My name is Brad Bowen. I
22 represent Consolidated Freightways. Consolidated is
23 also interested in helping clean up this site, but it
24 wants to emphasize that it did nothing wrong. They
25 did nothing wrong either. This was a site licensed
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1 by the State of Utah, and in fact in some instances,
2 the State of Utah directed potentially responsible
3 parties to the site even after the inspectors knew or
4 should have known the site was being improperly
5 operated and was operating beyond the scope of its
6 license. Consolidated feels that it really has been
7 treated as a wrongdoer despite the substantial
8 efforts it has undertaken to help remedy the problems
9 at Ekotek.
10 Consolidated Freightways promptly joined
11 the Remediation Committee and has expended
12 substantial funds in helping to clean up the
13 property. As Denise indicated earlier, $17 million
14 has already been spent by this Committee in helping
15 remedy the problems of this site.
16 I'd like to point out that I believe a
17 number of the EPA assumptions are really ridiculous.
18 We're talking about drilling for drinking water and
19 an aquifer that clearly has not been used for
20 drinking water. They've ignored the zoning
21 prohibitions. There already exists a public water
22 supply. This poses no threat of any kind to any
23 public drinking water. This isn't an agricultural
24 area. EPA proposal ignores the geothermal aquifers
25 and the rain water from the Great Salt Lake. It
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1 ignores naturally occurring chemicals in the ground
2 water on the site. The EPA proposal in fact goes
3 well beyond EPA's own requirements for site
4 remediation.
5 EPA acknowledged that Alternative Number
6 10 meets all of its standards and requirements.
7 Adoption of an alternative that costs ten and a half
8 million dollars more than an equally acceptable
9 solution puts the faculty of these companies and
10 future jobs at risk.
11 Through the course of the remediation
12 efforts, including all the studies, research and
13 information gathered and performed by the Committee,
14 viewing it as objectively as possible, Consolidated
15 feels that EPA is acting punitively to members of the
16 Committee. Even to the extent of taking actions
17 which substantially undermine the efforts of the
18 Committee to obtain contributions for the remediation
19 costs. In many instances, it would have been better
20 for members of the Committee to have ignored the
21 EPA's administrative orders and wait in the wings as
22 many of the companies did. Those potentially
23 responsible parties are now being encouraged to
24 settle with EPA under terms much more favorable than
25 should be allowed and to ride on the coattails of the
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1 actions of this Committee.
2 Consolidated feels EPA's selection of
3 Alternative 7 is a slap in the face to the
4 responsible actions of this Committee and is a direct
5 contradiction to direct policy of the EPA. Not only
6 has the EPA enacted impossibly high standards, they
7 have also selected an alternative which goes far
8 beyond even their own standards at a cost to the
9 potentially responsible parties of approximately ten
10 and a half million dollars.
11 As a member of the Committee,
12 Consolidated is frankly tired of being treated as a
13 wrongdoer instead of as a responsible corporate
14 citizen. It's tired of high handedness and expensive
15 solutions that go beyond reason. Consolidated
16 objects to the plan proposed by EPA and demands EPA
17 allow some measure of reasonableness to govern this
18 site and requests the proposal set forth by the Site
19 Remediation Committee, mainly Alternative 10, be
20 accepted.
21 MS. NANCY MUELLER: Thank you. Carolyn
22 McHugh?
23 MS. CAROLINE MCHUGH: Caroline McHugh, M-C
24 cap H-U-G-H. I represent EHP Minerals. EHP also
25 sent used oil to the site to be recycled with the
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1 understanding it would be recycled and resold. We
2 support strongly the Site Remediation Committee's
3 proposal. We believe that the EPA's proposal ought
4 to be reconsidered, particularly in light of the
5 evidence that it may actually exacerbate the problem
6 on ground water. Thank you.
7 MS. NANCY MUELLER: Thank you. I can't
8 read this name. H&M Oil?
9 MR. ED MCCASLAND: Yes. That's me. I'm Ed
10 McCasland. I think the whole damn bunch of you
11 stinks. By golly, I never seen such a setup of
12 screwing the little man over. You've just taken
13 advantage of us, and you've put most of us out of
14 business. I'm 75 years old. I know damn well
15 something is going to get me one of these days. But
16 it hasn't got me yet. I've lived this long and
17 worked with this oil for lots of years. 20 odd
18 years. And I cannot feel that it's ever hurt me one
19 ounce. I mean, you know, just hasn't done it. And I
20 listen to all these artists -- I don't know what you
21 call them -- whatever they're called. We've got a
22 special name in engineering language. But you talk
23 to -- talked all this time trying to tell somebody
24 something. And we, the little men, the laymen, we
25 don't understand what you're saying. So I personally
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1 think that you just wasted our monies, our time, our
2 efforts, and you broke the hell out of us. Now,
3 that's the way it is.
4 MS. NANCY MUELLER: Thank you, sir. We
5 have another McCasland here?
6 UNIDENTIFIED: No comment at this time.
7 MS. NANCY MUELLER: Thank you. Shane
8 Smoot?
9 MR. SHANE SMOOT: The name is Shane Smoot,
10 S-M-0-O-T. I'm vice president with Q Lube that was
11 previously operated as Quaker State Minute Lube. And
12 the points that I really want to make tonight really
13 deal with what H&M Oil has just hit on.
14 Our liability at this site evolved from
15 eight quick lubes that were operated over a six-year
16 period of time before Ekotek started bouncing checks
17 and we pulled out of the site. Our ultimate
18 liability relative to this site is in the
19 neighborhood of -- in excess of $2 million. For
20 changing oil at eight quick lube facilities. The
21 unfortunate thing about it is when Superfund was
22 enacted, it was enacted to protect the service
23 station dealers, and had EPA acted appropriately in
24 promulgating management standards, our entire
25 liability would be exempt. It didn't happen. And
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1 now we're talking about a remedy that could cost us
2 just on the intrinsic bioremediation versus pump and
3 treat, that could cost our entity $400,000.
4 And there were several critical points
5 that were made tonight that I think must be heard by
6 EPA and the State of Utah. And those are, first of
7 all, there doesn't appear to be migration of the
8 plume. Secondly, there's questionable effectiveness
9 of pumping and treating. Next, the -- there appears
10 to be an offsite source. And the evidence that
11 intrinsic bioremediation is going to be more
12 effective. I do not see any reason why EPA should
13 not give intrinsic bioremediation an opportunity to
14 work and test it before we go to the drastically more
15 expensive and extensively less effective alternative
16 of pump and treat.
17 I'm concerned. We've had to bite our
18 tongue on a number of occasions and actually over
19 the -- over the period of time that I've been
20 involved with the Committee, and I was in that first
21 small group that formulated the Committee, and I've
22 watched this evolve over a number of years, I've
23 heard all the war stories about Ekotek, and when it
24 comes right down to it, what we're cleaning up is an
25 old used oil recycling facility. It's not all of the
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1 double X death contaminants that were alluded to
2 through a lot of the discussions.
3 So my point is merely that I see no down
4 side to EPA giving intrinsic bioremediation a chance.
5 The Committee is not proposing that intrinsic
6 bioremediation be relied upon exclusively and the
7 Committee walk away. But give it a chance. If it
8 doesn't work, let's look at other alternatives. But
9 don't jump to a ten and a half million dollar remedy
10 that appears to not be the answer to the problem.
11 I do want to commend, however — I
12 believe EPA and the State of Utah have made attempts
13 over the period of time to try and work with the
14 Committee, and I do not want to be overly critical of
15 the State of Utah or of EPA. I have not always
16 agreed with them on their positions. But I think the
17 Committee has been asked to do a lot of things that
18 should not have been asked, but nonetheless, we bit
19 our tongues, we've done what has been required of us,
20 and given all the evidence on the table, I just can't
21 see any down side, again, to EPA giving intrinsic
22 bioremediation a chance. If it doesn't work, that's
23 fine. We still have the viable parties.
24 But from a small party's perspective,
25 and you have to remember there are large parties on
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1 the Committee, but there are also a lot of small
2 parties that are being hurt, and hurt significantly.
3 And as a result, if EPA would consider that, it would
4 be greatly appreciated, and I think history will bear
5 out that it will be the right decision. Thank you.
6 MS. NANCY MUELLER: Thank you. Harry
7 Patterson?
8 MR. HARRY PATTERSON: I'm Harry Patterson.
9 I'm manager of environmental site remediation for
10 Union Pacific Railroad. I'm also the technical
11 committee chairman for the Ekotek Site Remediation
12 Cleanup.
13 Union Pacific like a number of companies
14 became involved in this site early on because of our
15 past use at this site. Union Pacific like other PRPs
16 sent used oil, in our case locomotive used oil, to
17 this site for refining. In our case, we took back
18 this rerefined oil and continued to use it in our
19 locomotive facility for crank case oil.
20 Union Pacific was not an owner of Ekotek
21 in any way. We had no influence over their
22 management of the oil refining, refining process, or
23 the wastes that did generate.
24 Because Union Pacific sent a large
25 volume of oil to this site, we have actively
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1 participated in this cleanup. Since the late '80s,
2 through the Committee, we've helped identify, analyze
3 and remove all the liquids that were left on this
4 site by the last owners. We've removed some soil,
5 we've removed the tank farm facility, and we've
6 completed the RI/FS that's resulted in this draft
7 record of decision for the site's cleanup.
8 This is -- the Committee has spent over
9 $17 million in performing the removals and
10 investigations with the full direction and input from
11 the EPA. I believe everyone that has been involved
12 in this site is aware of the changes that have
13 occurred at this site over the years. Union Pacific
14 and the Ekotek Site Remediation Committee have
15 treated this property in a responsible manner in all
16 respects .
17 We at Union Pacific and the Committee's
18 objective is to remediate the site so it's fully
19 protective of the environment and health of those
20 living in the area and in a most efficient and cost
21 effective manner. By EPA's own analysis as you've
22 heard tonight, Alternatives 7 and 10 meet minimum
23 requirements to protect human health and the
24 environment. As you've heard, our experts have —
25 who have studied this site have concluded that
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1 pumping and treating the ground water will be
2 ineffective because of the complicated ground water
3 conditions and the adjacent contaminant plume which
4 we've found to exist near the site.
5 Union Pacific believes Alternative 10
6 will be the least disruptive and best alternative for
7 remediating this site. Hazardous hot spots in the
8 soils will be removed and disposed of offsite.
9 Remaining oils, contaminated soils which EPA risk
10 assessment clearly show are not a hazard to anyone
11 will be sandwiched and contained on the site in a way
12 that will pose no health risks to anyone working on
13 the site or anyone living near it.
14 As our experts have reported, risks to
15 the environment at the Ekotek site are fully
16 eliminated with Alternative 10 which is estimated to
17 be at least $10 million less costly than Alternative
18 7. The EPA to require more cleanup would be
19 arbitrary, capricious, and punitive to the companies
20 that have willingly participated in this site
21 assessment removal and hopefully an ultimate final
22 cleanup of the site.
23 We urge everyone, the EPA, the
24 neighborhood, and the local community to come
25 together. Let's come together, let's find the cost
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1 effective, reasonable alternative, and let's finish
2 this cleanup. Thank you.
3 MS. NANCY MUELLER: Thank you. That's
4 everyone that's signed up. Is there anyone else that
5 would like to make a comment? Sir?
6 MR. JERRY HAYES: Would it be possible to
7 ask — Jerry Hayes, president of the Utah Automobile
8 Dealers' Association, representing 145 dealers, new
9 car dealers, and truck dealers, in 37 communities in
10 the State of Utah. And we produce the largest
11 segment of taxable gross sales in the State of Utah.
12 $3 billion. Among the 145 dealers in smaller
13 communities particularly, they are small businessmen.
14 We have 83 dealers that have been
15 impacted by this action that we feel is
16 unconstitutional to charge back somebody on a law
17 retroactively that has cost our dealers from 50,000
18 to 85,000 dollars apiece. Now, from what I've heard
19 here, I'm quite impressed with the presentation that
20 would save $10 million for those of us who are
21 providing funds for this cleanup. Now, may I ask
22 four questions?
23 MS. NANCY MUELLER: Surely.
24 MR. JERRY HAYES: All right. What is the
25 difference between waste oil contributors, what they
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1 had to pay, and toxic waste contributors? Because
2 waste oil is not a hazardous waste. Why we are even
3 named in it is my question. Who can answer it?
4 MS. NANCY MUELLER: Jim, would you like to
5 try that?
6 MR. JIM STEARNS: Yes, I guess I can.
7 You're speaking about the de minimis --
8 MR. JERRY HAYES: Yes. Waste oil is not a
9 hazardous waste.
10 MR. JIM STEARNS: Okay. The substances at
11 the site that Dan spoke of, the chemicals of
12 concern -- I'm an attorney. You'll have to
13 understand the reason I'm responding is because it
14 relates to the de minimis settlement. Jim Stearns,
15 I'm sorry. With EPA Region 8.
16 Those chemicals are related to the waste
17 oil. And EPA performed a toxicity assessment for
18 purposes of that settlement that determined that
19 there was no significant difference between the
20 toxicities from what you're calling solvents and
21 those same chemicals that occur in waste oil. There
22 are PAH compounds and so on. And essentially, it's a
23 soup, you know. That's really what we concluded that
24 we would not — it was not justified to charge in the
25 settlement. For settlement purposes, we didn't feel
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1 that it was justified to charge solvent contributors
2 more than waste oil contributors. Based on the
3 toxicity ratings for each of the constituents of
4 waste oil and the types of solvents sent to the site.
5 MR. JERRY HAYES: Do you really believe
6 that to be so?
7 MR. JIM STEARNS: I do.
8 MR. JERRY HAYES: When they have declared
9 waste oil to be nonhazardous?
10 MR. JIM STEARNS: Okay. EPA -- that's
11 another aspect. Well, there is a court case that the
12 Committee has been involved with as you know that
13 waste oil -- that issue came up. That issue was
14 litigated in court. EPA did make a determination
15 that waste oil would not be regulated under RCRA,
16 which is another statute, Resource Conservation
17 Recovery Act. That's the cradle to grave statute
18 that regulates ongoing management treatment, storage
19 disposal of substances like waste oil. But that
20 determination is not a determination that there is no
21 risk from waste oil. And the Superfund process goes
22 through a whole risk assessment based on the
23 chemicals that were found at the site. That's what
24 we're moving ahead on.
25 MR. JERRY HAYES: So everybody paid the
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1 same, whether it was oil or highly toxic chemicals?
2 MR. JIM STEARNS: Right. We did not want
3 to make the determination -- because --
4 MR. JERRY HAYES: And you feel that is
5 reasonable?
6 MR. JIM STEARNS: I do.
7 MR. JERRY HAYES: Or what should be done is
8 it isn't the degree of toxicity or hazard to the
9 community. Everyone's treated equally on this?
10 MR. JIM STEARNS: Yes.
11 MR. JERRY HAYES: Okay. What's the
12 advantage or disadvantage of settling with the PRP or
13 the EPA? You have a choice of doing either one.
14 What's the up side and down side of both of these?
15 MR. JIM STEARNS: All right. Again --
16 MR. JERRY HAYES: Can anybody answer? I'm
17 waiting for an answer.
18 MR. JIM STEARNS: I can answer that. I
19 spoke to — EPA put out a de minimis settlement. The
20 Committee also put out their settlement. It's a
21 complicated story. Because CERCLA is a broad base
22 statute. And it has a — okay. What was the
23 question again?
24 MR. JERRY HAYES: Some of my --
25 MR. JIM STEARNS: The advantages of
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1 settling?
2 MR. JERRY HAYES: Half of the 83 dealers
3 settled with the PRP and half settled -- I shouldn't
4 say half. Some of them haven't settled. Some of
5 them are so upset and mad about it, they're just
6 saying, "Jump in the lake. Do what you have to do
7 it. I'm not going to pay for anything that I wasn't
8 responsible for years and years and years ago."
9 MR. JIM STEARNS: I understand that.
10 MR. JERRY HAYES: Okay. So that's --
11 that's a diversion. Why should they settle with PRP
12 or why should they settle with EPA? What's the up
13 side or down side of settling?
14 MR. JIM STEARNS: EPA -- the government
15 offers you — it's a direct covenant not to sue. We
16 cannot go after you directly for your liability at a
17 Superfund site. If you settle with the Committee,
18 potentially you still have some exposure from the
19 government. But we have gone on record at this site
20 saying that we would not — if you settle with the
21 Committee, we would not be coming after you.
22 MR. JERRY HAYES: That doesn't make sense.
23 MR. JIM STEARNS: Yes, I know.
24 MR. JERRY HAYES: You said if you settle
25 with EPA, then you would be settled with government.
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1 Then you said if you settle with PRP, then they could
2 still go back and make you settle with the
3 government.
4 MR. JIM STEARNS: If you settle with the
5 Committee, you do not have a release from the
6 government. You only have a release from the
7 Committee. If you settle with the government, you
8 also get contribution protection under the statute.
9 If you resolved your liability to the United States
10 government at this site, you would -- the law
11 provides for a contribution protection that is
12 intended to protect you from a private contribution
13 suit. Such as the Committee. So their settlement
14 would not offer similar protection from the
15 government. You're only resolving your liability to
16 vis-a-vis the cost recovery suit —
17 MS.-DEMISE KENNEDY: To further complicate,
18 we have EPA permission to add all of the parties that
19 settle with us to each of the administrative orders
20 and preparation the consent decree. So it's a back
21 doorway of getting the same protection.
22 MR. JERRY HAYES: Because I've had my
23 dealers say, "Which way shall I go? What's the up
24 side and down side?" And it's such a confused mess
25 .that I —
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1 MS. DENISE KENNEDY: I think the easy
2 answer is your settlement is closed.
3 MR. JIM STEARNS: We have closed our
4 settlements now. We did a de minimis effort that
5 lasted about two years. We had several waves of
6 settlements. We've pretty much ended it.
7 MR. JERRY HAYES: I had a call last week
8 from one that sold out in 1986. If you don't think
9 he was upset. If the cleanup costs are less than
10 budgeted, will there be a refund?
11 MR. ED MCCASLAND: Hell, no.
12 MR. JERRY HAYES: Thank you. Is that the
13 answer?
14 MR. ED MCCASLAND: That's the answer. It
15 would be mine. I don't know who got another one.
16 You ain't getting nothing back from the damn
17 government or nobody else. The Committee, all of
18 them got you.
19 MS. DENISE KENNEDY: The settlements don't
20 provide for a refund.
21 MR. JERRY HAYES: Can anybody answer that?
22 How about the smart ones here?
23 UNIDENTIFIED: We're not involved. We're
24 not lawyers. This is lawyer stuff.
25 MR. JERRY HAYES: These are very simple
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1 questions. That don't seem to really have an answer.
2 MR. JIM STEARNS: Well, if I can try to
3 respond? EPA has a national initiative to try to do
4 de minimis settlements at the Superfund sites. What
5 that means is a lot of sites have -- involve a lot of
6 small contributors like yourselves. This was a very
7 typical example of that.
8 The de minimis settlement from EPA's
9 standpoint is designed to try to get people out early
10 so that they aren't dragged through the whole
11 process. They have an option -- in that sense, it's
12 voluntary -- to get out early based on early
13 estimates of the site cost. In order to save
14 parties, small contributors, small businesses, the
15 transaction costs of continuing to be dragged through
16 the process for years and years and years.
17 We have — Congress provided a section
18 of the law that encourages EPA to do early de minimis
19 settlements. And the way we do that is to estimate.
20 We base our settlement amount on an estimate of site
21 cost. But we can only do it with the information
22 that's present at that time. We based our settlement
23 in this site, we based it on information and
24 projections that we had based on information that we
25 had available to us about a year and a half ago.
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1 November, that's when we first started this. And at
2 that point, I think it was early in the data
3 gathering stage. We had the information some of the
4 samples -- all the information indicated to us that
5 the remedy that was necessary would cost in the
6 neighborhood of some $57 million. We used that
7 coupled with about 10 or $12 million of past costs
8 for removal. That led us to the determination of
9 $69 million as the basis for the de minimis
10 settlement. You recall that figure.
11 Okay. This is a highly unusual site in
12 that now it seems after six seasons of continuous
13 data gathering, it seems that something that we could
14 have not predicted back then, that the data now
15 appears to be less, you know.
16 MR. JERRY HAYES: Great. So who gets the
17 overage?
18 MR. JIM STEARNS: For whatever reason.
19 This is a highly unusual site in that regard.
20 Nationwide, most times the costs shoot up.
21 MR. JERRY HAYES: Do the attorneys get the
22 overage? Quickly, two other questions.
23 MR. JIM STEARNS: I'm on government salary
24 myself.
25 MR. JERRY HAYES: Who owns the site? Who?
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1 MS. DENISE KENNEDY: It's a good question.
2 There have been three bankruptcies related to the
3 site. Everybody keeps abandoning the property.
4 MR. JERRY HAYES: When it's all over, who
5 will own this site?
6 MS. DENISE KENNEDY: Probably the bank.
7 MR. JERRY HAYES: Which bank?
8 MS. DENISE KENNEDY: I don't know the name.
9 MR. JERRY HAYES: Anybody know who's going
10 to own it?
11 UNIDENTIFIED: Nobody wants it.
12 MR. JERRY HAYES: Shane, do you know who
13 will?
14 MR. SHANE SMOOT: One of the liens was
15 Commercial Leasing, wasn't it? Yes. I'd have to go
16 back through the records. There were a couple of
17 liens on the property. But obviously, they don't
18 want to foreclose on the property, take possession,
19 and then participate in the liability. So they're
20 kind of sitting out there. If in fact we end up with
21 a clean site, then maybe they'll foreclose. I don't
22 know. Most of them appear just to -- I don't know.
23 It may escape the -- go to the State ultimately.
24 MR. JERRY HAYES: The last one is, the man
25 that caused all the problems, I understand is living
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1 in California in a big huge home with a four or five
2 car garage and four or five cars and swimming pools.
3 What has happened to him to pay the price everybody
4 else is paying that he should have paid?
5 MR. J.D. KEETLEY: I'll take that answer.
6 What happened was the State did prosecute. Steven
7 Self is the fellow you're referring to. He was
8 president of Ekotek. Then Steven Miller who was the
9 vice president. They were basically the two owners
10 of Ekotek for that 10 or 20 year period.
11 What happened was in 1990, during the
12 emergency removal activity, the U.S. Justice
13 Department came and they started prosecution
14 proceedings against those two fellows. And they came
15 up with altogether a 12 count indictment against
16 Steven Self. That started happening in 1990. That
17 was the first environmental crime prosecuted in Utah
18 and one of the first ones in the United States. The
19 outcome was they started with 12 indictments, they
20 found him guilty on six.
21 MR. ED MCCASLAND: Eight.
22 MR. J.D. KEETLEY: He got --
23 MR. ED MCCASLAND: Eight of them, by God.
24 I sat through 16 days of it.
25 MR. J.D. KEETLEY: He eventually -- through
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1 his lawyers or whatever, he got that struck down to I
2 think being found guilty on -- four of them were
3 later overturned. Ultimately, there were two counts
4 of indictment for like mishandling of wastes and
5 trying to cover up what he had done. He was
6 ultimately found guilty on two. I don't think he
7 ever served any jail time. I think what happened was
8 he did some community hours in lieu of jail time. He
9 may have paid a fine, but what he said was he had —
10 he himself and his business declared bankruptcy. So
11 he was not at that point, right, legally liable — he
12 wouldn't be liable anymore for any more costs.
13 You're right. He lives in California
14 around San Diego somewhere. I think the way the
15 state law is, state by state law, the way they work
16 out is that you can -- depending on the state you're
17 in, and California is one of those states, you can
18 maintain a house and a certain amount of liquidity --
19 of assets in your name and still declare bankruptcy,
20 and those are off limits from any kind of lawsuits
21 like what we're facing. He didn't go to jail. He
22 paid a little bit of money, but he still has a home
23 and still had a fair amount of money. And yes, he
24 got off. That's one of those things where if you do
25 the right thing, if you know the right people -- he
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1 more or less got off.
2 MS. DENISE KENNEDY: There is a pending
3 unilateral EPA order against him to participate in
4 cleanup of the site which EPA has never enforced.
5 That was issued by EPA back in '89, and nothing has
6 happened since.
7 MR. JIM STEARNS: We are maintaining -- we
8 are looking at that as possibly continuing his
9 liability of the site. In spite of the bankruptcy.
10 Bankruptcy is hard to get around.
11 MR. JERRY HAYES: That's all. Thank you
12 for your --.
13 MR. ED MCCASLAND: I have one comment I
14 would like to add. Steve Self lives at Holbrook,
15 California. Lived down from as far from me to you
16 from the Mexican border. If it gets too hot, he
17 runs. He's done in more than once. The house is
18 worth over half a million dollars. 4,000 square
19 feet. He drives three automobiles. One of them is
20 a — a Jaguar, yes. Jaguar. And these are all
I
21 within the-home. Three or four car garage there.
22 All of this. And the State of California says you
23 can go to 50,000 bucks. Not no half a million
24 dollars. For a home. So is that where the money
25 went? I don't know. Nobody ever said a darn thing
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1 about it. Just sits there and keeps living there.
2 Living on my and your funds.
3 MS. NANCY MUELLER: Any further comment,
4 questions? Karen?
5 MS. KAREN SILVER: My name is Karen Silver
6 from Salt Lake Community Action Program. And I did
7 have some questions. It was helpful to hear the
8 information first. Most of these are for Dr. Bouwer.
9 How will the LNAPL removal affect the anaerobic
10 balance that you're counting on for this remediation?
11 MR. ED BOUWER: That's a good question. We
12 don't know exactly. There's several scenarios that
13 could happen. The source for the anaerobic water
14 geothermal activity, creating anaerobic conditions.
15 It could be removal of the LNAPL may also disrupt
16 that as well. What will happen is not the short-term
17 but a lot of reducing conditions there, it will take
18 a while to adjust. If this offsite TCA is not
19 addressed and we continually have this source, that
i
20 could disrupt that natural remediation. So it
21 really — we need to look more at the offsite site
22 now for the vinyl chloride before you make any
23 decisions about long-term potential.
24 MS. KAREN SILVER: Okay. And I was reading
25 up at the University library in the public document
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1 stuff, and there was a March 14th, 1995 letter from
2 Dr. Hutchins at the Kerr Lab to Sarah Black. And it
3 said that the method that you suggested in your
4 research for this bioremediation, that it hadn't been
5 published and that it may have been designed for
6 aerobic rather than anaerobic degradation. Can you
7 address that?
8 MR. DAN THORNTON: That's more appropriate
9 for the EPA to address. We've discussed this. Sarah
10 came to me and asked, "What is this document? I've
11 never seen it." We've identified — there is not —
12 the letter from Dr. Hutchins on that date to Sarah
13 which you're referring to is a document that Sarah
14 sent to me. In that letter, she quoted a statement
15 from Dr. Hutchins at Kerr Labs -- they're one of our
16 labs that produce data for the EPA -- in which he was
17 talking about the possibility of doing a tracer study
18 on this aquifer, which is something that we have
19 maintained is needed to support the possibility of
20 intrinsic remediation. And he was talking about the
21 technical feasibility of the specific test. And I
22 believe Sarah and I are going to spend a good bit of
23 time later on now working through exactly what he was
24 saying. I'm not sure from the nature of what she
25 said in the letter what exactly he was talking about.
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1 But we are going to pursue that further.
2 MR. ED BOUWER: I know what he's talking
3 about. Okay. The tracer study involved taking water
4 from the site, pumping it out, and adding a tracer,
5 pumping it back down. The — Professor Bouwer,
6 B-0-U-W-E-R. Another line of evidence that you can
7 try to do to document intrinsic remediation is if you
8 can compare loss of like vinyl chloride which is
9 degrading to a chemical that doesn't degrade, which
10 is bromide or some other tracer, that you add. Then
11 you have more comparable studies where reactions are
12 occurring. There's no natural bromide or natural
13 tracer at the site.
14 One proposal was to pump up the water at
15 the site, add bromide, and pump it back down and
16 follow the movement of the vinyl chloride and the
17 bromide together. And we asked the people at Kerr
18 Lab what they thought about this technique. And
19 nothing had been published on this. And the concern
20 that Dr. Hutchins had is when we bring it up, it's
21 difficult to keep things anaerobic above ground, and
22 when you have oxygen introduced, you get a false
23 reading. You've disrupted the system. It's
24 essentially impossible to conduct a good tracer study
25 at the site and not disrupt the anaerobic conditions
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1 that exist.
2 MS. KAREN SILVER: Okay. Thanks. I
3 understood from an earlier presentation that there
4 are spikes or bullets of TCA coming into the site
5 which are also from that offsite source. But I don't
6 see with what -- with my very limited knowledge of
7 water and stuff, I don't see how those bullets fit
8 with how fast that vinyl chloride is dissipating or
9 whatever, or bioremediating, whatever is happening to
10 it. It seems to me that if the purported industry is
11 maintaining levels of production at constant rates —
12 which it looks like it is because it's doing a rate
13 job killing off the mountain. But anyway, that the
14 TCA bullets would keep remaining more constant. And
15 you wouldn't have that much vinyl chloride going
16 wherever it's going.
17 MR. ED BOUWER: What we do see, actually,
18 at some wells, spikes now increase it. There have
19 been increases that contribute to this new source.
20 Up until December, we did not see any TCA of this
21 other source. What we think is happening, and Bob
22 Berry can comment, the past few years you've had a
23 drought, more or less. Ground water levels have
24 declined. What we think is happening, the wet spring
25 has pushed ground water from the mountains, and
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1 that's where the TCA is coming in. What we
2 hypothesize or think is happening is that there's a
3 sloshing action. You get periodic pulses of solvent
4 in. And so the time scale of that may be years from
5 that pulsing. You get a slug in of TCA degrading to
6 vinyl chloride, vinyl chloride is disappearing at its
7 rate, and then another slug comes in, then you get a
8 spike of vinyl chloride going down.
9 That's what I mentioned earlier. We
10 need to characterize TCA better. We know it's a
11 major source of — can be a major source of vinyl
12 chloride in the area. Fortunately the ground water
13 is stagnant, it's contained, and the natural
14 processes are at least containing the vinyl chloride
15 aspect.
16 MS. KAREN SILVER: Thanks. I have two more
17 questions. Let see. The first one is it affects --
18 it would affect both the scenarios, Alternative 7 and
19 Alternative 10, I believe. How will the wet and the
20 dry times impact either of those ground water
21 remediation plans? Has that been looked at?
22 MS. NANCY MUELLER: Can you answer that for
23 Alternative 7?
24 MR. DAN THORNTON: Based on our current
25 understanding, there may be some changes in the
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1 aquifer characteristics. I mean, whether we have
2 these -- as Dr. Berry was showing before, there's
3 ground water that comes up from the lower formation,
4 we believe. There may be some variability in where
5 these plumes are located. We're not entirely sure of
6 that at this point. But we're looking into the
7 possibility that the data shows some minor
8 variations. I don't think that in either scenario
9 that it would be such a major disruption that we
10 would have to change the way we were going about
11 affecting the cleanup. But if we did see something
12 like that, you know, certainly we would be monitoring
13 the water as it was being extracted or even in the
14 case of intrinsic remediation, they talked about
15 doing ongoing monitoring to see what's happening. If
16 we saw changes, then certainly we would consider the
17 alternatives.
18 MS. KAREN SILVER: Okay. Thanks. The last
19 question is for the Committee. It seems to me if —
20 maybe I'm just not clear on Alternative 10, but what
21 you're saying about putting the clean soil at the
22 water level and then making the sandwich with the
23 crummier soil and then putting clean soil on top of
24 it, it seems to me you're going to have to excavate
25 all that soil out, dump it somewhere, bring in clean
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1 soil, certify that it's clean soil, and then dump the
2 crummier soil on, and then bring in another load of
3 the certified clean soil? Is that the idea?
4 MS. DENISE KENNEDY: Yes.
5 MS. KAREN SILVER: Thank you.
6 MS. DENISE KENNEDY: There are areas on the
7 site --
8 MR. ED MCCASLAND: What are you going to do
9 with the waste material you take out of the hole,
10 dammit? Oh-oh. The dirt that you take out of the
11 hole, what are you going to do with it?
12 MR. DAN THORNTON: I can address that.
13 Actually, the hole is where the tank farm was. And
14 we're talking — I showed everyone before a map of
15 the site when these things overlap. There is
16 apparently a fairly thick layer of clean soil where
17 there isn't any contamination. And the location for
18 Alternative 10 that we considered where we were going
19 to consolidate all these contaminated soils is not
20 the same as where we're talking about finding a plume
21 of oily liquid waste, for example. We're not talking
22 about extracting those and just -- we don't know what
23 we're going to do.
24 We're looking at a different area on the
25 site. It would probably help if I had a map
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1 available so I could kind of show you. This at least
2 looks the clearest, although it isn't necessarily the
3 biggest map we have. On the eastern portion of the
4 site, generally speaking, we're looking at ground
5 water contamination and the soily liquid waste that
6 got down there on top of the ground water. It's
7 generally in this area. More to the north, I guess.
8 Okay? The area that we're talking about
9 consolidating this stuff is the former tank farming
10 area. So if there were excavations that took some of
11 those wastes out, those would be treated as the
12 alternative set. Either by landfilling or some kind
13 of offsite treatment technology. Just going to be
14 taken out. And then with what's left, we're going to
15 be consolidating the other soils, especially from
16 this — the western portion and whatever else is here
17 into that area. So part of it overlaps. The debris
18 area that's showing up — there's going to be
19 demolition of buildings, because the buildings may
20 overlap that debris area. To get at it, we're
21 probably going to have to take out a few more things.
22 These are all -- that feasibility study
23 looks very clearly at some of these other things that
24 we.'re not mentioning here. Like underground storage
25 tanks that are onsite that are going to be removed.
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1 There are details like these building demolitions.
2 That's all costed in. But we're trying to avoid the
3 fine print here and just give you a broader picture
4 of what we're trying to accomplish.
5 MR. ED MCCASLAND: That fine print is where
6 you'11 get us.
7 MR. JERRY HAYES: Who makes the decision
8 whether or not we go with Plan 7 and $10 million or
9 go with Plan 10 and spend the full shot? Is it the
10 EPA's decision? Are they going to listen to these
11 people? What's going to happen? What good is the
12 hearing? What's the results of this?
13 MS. NANCY MUELLER: You're helping make the
14 decision. The comments that were made tonight as
15 well as the written comments that we'll be getting,
16 each one will be considered by EPA and addressed in
17 what's called a responsiveness summary which becomes
18 part of the record of decision for the site. Which
19 is EPA's document that says this is what we've
20 decided is the best. Based on comments, pro, con,
21 whatever. We've decided that this is the best.
22 That's the main purpose to have a meeting like this
23 and to have a public comment period, to bring this
24 information together to give the people that are most
25 affected by what our decision is going to be, to give
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1 you a chance to give us your input.
2 There are certain scientific things that
3 we have to consider that -- it's EPA's job to
4 consider the scientific side. But there's a lot of
5 other community concerns. And so you are helping
6 make the decision. Yes, it is ultimately EPA's. But
7 we are very committed to listening to public comment
8 and incorporating that comment into our decisions.
9 MR. J.D. KEETLEY: I'd like to say one
10 thing in closing. We're wrapping this up. To just
11 address the main issue that probably brought 95
12 percent of you here as far as who pays for the site
13 cleanup, I like to look at this whole process using
14 an analogy of getting a driver's license. Sure, the
15 State has been brought up before the State was
16 overseeing what happened out there at Ekotek. And
17 things got out of control out there back in the '70s
18 and '80s. They got permission from the State, truly,
19 to operate some of their operations. Permitted by
20 State.
21 But I make the analogy, I look at this
22 as going out and getting a driver's license. You're
23 getting permission from the State to drive a car, but
24 the State's not obligated for whatever you do. It's
25 your responsibility. Hopefully, you have insurance
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1 to cover whatever you do. The State just gives you
2 the permission to operate a motor vehicle. That's
3 where their liability ends.
4 That's what happened the at the Ekotek
5 site. The State gave limited permission for them to
6 carry on some of they are operations. Things got out
7 of control. There's always going to be law breakers.
8 We don't want a police state with police checking up
9 on what everybody does so it inhibits our freedom.
10 It got out of control. That was definitely a
11 regrettable situation.
12 Given that that occurred, as far as who
13 cleans up for the site, I also think it's -- there's
14 a lot of -- I heard your comment as far as it is
15 hurting the little guy quite a bit. And I think
16 that's also a regrettable situation. It's part of
17 the Superfund law. And I don't -- I also heard
18 somebody mention the term wrongdoer. I don't think
19 any of the agencies here are looking at anybody as a
20 wrongdoer. It's just the way that the law, the
21 liability law, is set up that if you were a generator
22 or transporter of wastes and you brought it to a site
23 like Ekotek and something happens like what happened
24 at Ekotek, you become responsible for it, the
25 payment. It's regrettable especially when it falls
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1 on the shoulders of people that don't have that much
2 money.
3 But going back to the analogy of
4 driving, operating a motor vehicle, it's like
5 insurance. Once again, that's the law. That's the
6 way the laws in this country are set up. It always
7 falls on the people that obey the law. All the laws
8 of this country fall on the shoulders of the people
9 that obey the law. It's unfortunate. I can't do
10 anything about it. Nobody here can do anything about
11 it. Some modifications to the overall program can be
12 made. I agree with you sympathetically. It's a
13 pretty regrettable situation. But I don't know what
14 alternatives there are going to be.
15 I will say that this meeting tonight in
16 regards to the proposed plan, it's not written in
17 stone. So what might happen in the future, it's not
18 written in stone. Things can change. I can't
19 predict what will be the outcome by the time the ROD
20 is signed several months down the road. I will say
21 comments like yours kind of help give us direction as
22 far as what to do, which way to go.
23 And also as far as your comment about
24 things seem to go over your head, believe me, a lot
25 of this stuff goes over a lot of our heads. Goes
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1 over my head. I'll tell you why these discussions
2 are so technical is because there's $10 million.
3 This probably is going to either cost $6 million or
4 $16 million. There's a lot of -- people are willing
5 to get very technical and very legalistic to save 10
6 million bucks. That's pretty -- I would be, too. So
7 don't — that's just the way it goes. Even if it
8 goes over your head, it's going over a lot of
9 people's heads. There's going to be a decision out
10 of this, and it's going to be $10 million one way or
11 the other. That's the bottom line as far as why
12 things have gotten to the point they've gotten. Why
13 they've gotten so technical.
14 MS. NANCY MUELLER: Thanks. Anything else?
15 MS. DENISE KENNEDY: I want to respond to
16 the driver's license analogy briefly. What we're
17 talking about is that $10 million. We don't want to
18 be punished by paying $10 million more to clean up
19 this site than we need to.
20 MS. CAROLINE MCHUGH: I want to respond to
21 your driver's license analogy. You license a taxi
22 driver. I hire the taxi driver to take me across
23 town. The taxi driver runs into this gentleman, and
24 the State orders me and the federal government orders
25 me, the passenger, to pay for his injuries. That's
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1 CERCLA under your analogy.
2 MR. ED MCCASLAND: I think you ought to get
3 your hand out of your pocket and let's go home
4 MS. NANCY MUELLER: Thank you all for
5 coming.
6 (Whereupon the proceedings were
7 concluded at 9:35 p.m.)
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STATE OF UTAH
)
) SS.
COUNTY OF SALT LAKE )
I, MARY D. QUINN, Certified Shorthand Reporter,
Registered Professional Reporter and Notary Public
in and for the State of Utah certify:
That the foregoing hearing was taken before
me at the time and place therein set forth;
That the statements and comments made at the
time of said hearing were recorded stenographically
by me and were thereafter transcribed;
That the foregoing transcript is a record of
the hearing and statements made at the time of said
hearing.
I FURTHER CERTIFY that I am neither counsel for
nor related to any party to said action nor in
anywise interested in the outcome thereof.
IN WITNESS WHEREOF I have subscribed my name and
•—• Ł~^
affixed my seal this _2____ daY of -JC^L '
19
NOTARY PUBLIC
MARY O. QUINN
476 East South Temple #357
Salt Lake City, Utah 84111
My Commission Expires
January 9th, 1958 \
STATE OF UTAH
MARY D./QUINN C"SR, RPR
My Commission Expires 1/9/98
MARY D. QUINN CSRf RPR
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13.2 Response to
Comments on the
Proposed Plan for Petrochem/Ekotek
Superfund Site
July 1995
13.2.1 EPA's Response to Comments from the Capitol Hill
Neighborhood Council, Katharine Hunt, Vice-Chair
1) Comment
1. Capitol Hill Neighborhood Council (CHNC) strongly recommends
that EPA select cleanup Alternative 6 at the Petrochem/Ekotek
site. CHNC has spent considerable time in discussions at the
full council level as well as numerous committee meetings to
thoroughly examine the alternatives described in the FS as well
as consider possible modifications to those alternatives. We
have requested two extensions of the public comment period in
order to fully explore all of the options and be sure that our
position on the cleanup was sound and considerate of as many
views as possible from within the council. We do appreciate
EPA's sensitivity to the community's need for additional time and
thank the agency for granting the requested extensions.
Response
EPA values the participation of the Capitol Hill Neighborhood
Council and has extended the public comment deadline twice
to allow adequate time for review of the Proposed Plan and
preparation of comments.
2) Comment
2. Swede Town residents are always foremost in the council's
consideration when examining the effects of the site, both past
and future. These are the people who have endured the brunt of
illegal burns and associated airborne toxins, the illegal spills,
which often made their way into the public access of North
Chicago Street. Accounts of shoes being "dissolved" by stepping
in these spills have been recounted by members of the CHNC Ekotek
Committee. Living with the unknown of how the site and its
illegal pollution has effected these residents and their children
has caused great mental anguish.
Frustration after frustration in early encounters by Swede Town
residents with local regulatory authorities are documented. If
the early warnings provided by the local residents had been
heeded, it is likely that the site would never have progressed to
the point of requiring listing as a superfund site. These
residents have suffered the ill effects and are looking for some
sense of restitution for past blatant disregard for their astute
and early recognition of the ongoing environmental degradation
13-2
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while the regulatory authorities looked the other way.
The "costs" of the human suffering, both physical and
psychological from past operations will remain unknown and
unquantifiable. The remedy selected by the EPA will have an
effect on the community now and in the future. A more aggressive
cleanup at the site will relieve some of the psychological
anxiety of how the remaining toxins might effect the residents
and their children. Technical arguments about low toxicity
levels at the site by the current governmental agencies and the
TAG advisor carry varying amounts of credibility in the minds of
the community residents. The residents relied upon the judgement
of "knowledgeable" regulators in the early eighties when they
voiced their concerns about the operations at the site. How
ironic that the early warnings from the technically
unknowledgeable community, if heeded, could have saved society
millions of dollars. Society owes Swede Town residents a
thorough cleanup. Selection of an alternative with cost savings
as a motivating criteria, flies in the face of the residents who
attempted to nip the problem in the bud. It is impossible to
associate a cost of the "human" effect, but there is one. CHNC
encourages EPA to consider these "costs" in evaluation of the
alternatives.
Response
Section 121 of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) states that the selected
remedy shall be consistent with the National Contingency Plan
{NCP) and be cost-effective. In evaluating the cost
effectiveness of proposed alternative remedial action, the short-
and long-term costs of such action, including the costs of
operation and maintenance for the entire period during which the
activities will be required is taken into account. The NCP
states that EPA expects to use engineering controls, such as
containment, for waste that poses a relatively low long-term
threat. The selection of alternative 10 as the selected remedy
meets the requirements of CERCLA and is consistent with the
expectations cited in the NCP. The light non-aqueous phase
liquids (LNAPL) or "oily liquids", which EPA believes is the
source of contamination to the ground water, will be excavated
and treated off-site via incineration. The ground water will be
addressed through bioremediation/attenuation. All soils
exceeding the soil hot spot criteria will be excavated and
disposed off-site. The remaining soils are within EPA's
acceptable risk range for the reasonable maximum exposure of an
industrial worker. These soils will be buried underneath a 42
inch clean soil cap so that no exposure to any one entering the
site can occur. This alternative is as protective to the local
residents as any of the other alternatives considered; however,
this alternative is considerably less expensive. Alternative 10
costs $6.1 million while alternatives 6 and 7 cost $14.2 and
13-3
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$16.6 million, respectively. Thus for the same level of
protectiveness, alternative 10 is much more cost-effective than
alternatives 6 and 7.
3) Comment
3. Alternative 6 ground water remedy calls for intrinsic
remediation. Intrinsic remediation, as proposed in the FS, is
not adequate to address all of our concerns (see Technical
Comments below). CHNC feels this alternative will provide
adequate immediate protection of the resource and pump and treat,
as proposed may not be effective. We would like to continue to
work with EPA and the PRPs to strengthen this ground water remedy
to insure immediate control of the contaminated ground water
plume and strong verification that natural attenuation of
contaminants concentrations associated with the site are a
reality.
Response
The selected remedy, alternative 10, requires that the
potentially responsible parties (PRPs) performing the Remedial
Design/Response Action (RD/RA) conduct studies to quantify the
rate of degradation of vinyl chloride to ethane and .ethene to
demonstrate the existence of and rates of bioremediation. This
and other features of the remedy will ensure immediate control
and strong verification that bioremediation/natural attenuation
is a reality.
4) Comment
4. We feel Alternative 6 ranks highest compared to the other
alternatives with respect to EPA's nine criteria for evaluation
of FS alternatives.
1) Overall protection of human health and environment
Alternative 6 cleans up all of the soils contaminated
to 10~6 and higher. This can only be viewed as ranking
higher at meeting this criteria than alternatives that
leave contaminated soils between 10"4 and 10'6 on site.
The policy that no present pathway for toxins to reach
a receptor equates to no risk is flawed. Toxins left
in the soils in the shallow subsurface continue to have
risk associated with them. Certainly we acknowledge
that a tanker truck filled with gasoline and driving
down, the street has potential risk associated with it.
The gasoline is sealed off from potential receptors,
but the potential for a collision or future leak in the
tank exists through the dimension of time (until the
tanker is empty). We view the same argument as
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applicable to the site subsurface soils. There will be
potential for these subsurface soils to be excavated in
the future because of the land use for the site or from
surface fault rupture associated with the Warm
Springs/Hobo Springs faults. Granted these may be
relatively low risks, but to assign no risk to
contaminated soils left on-site is a flaw in the risk
analysis. If there was no risk then there should also
be a release of liability for the remaining subsurface
soils. This is not the case, and therefore, we believe
EPA must consider the diminished overall protection to
human health and the environment by allowing
contaminated soil to remain on-site, even if it is
buried.
2) Compliance with ARARs
Alternative 6 complies with the identified ARARs for
the site as per the FS.
3) Long-term effectiveness and permanence
Alternative 6 soils treatment provides long-term
effectiveness. The soils will be clean after thermal
desorption. Leaving soils on-site and under a cap is
less permanent and only equally as effective if you
assume (as we do not) that the surface of the soil
today will always be there to provide protection. Part
of the long term effectiveness of alternative 10
depends on use of deed restrictions, which have had
mixed results at other superfund sites.
Future productive use the site is important to the
community. Alternative 6 provides a soils cleanup that
leaves the site free of encumbrances for future use.
Alternative 10 would require deed restrictions (which
have been used with mixed results at other superfund
sites) and would not allow for certain types of
excavations on the site and is thereby inferior to
alternative 6. With a more complete reduction of soil
contaminants, both the EPA and the PRPs are less likely
to be required to take any future action at the site.
4) Reduction of toxicity, mobility, or volume
Alternative 6 soils treatment aggressively performs a
real reduction of toxicity, mobility, and volume using
the thermal desorption process. Alternative 6 stands
heads and shoulders above alternative 10 in addressing
this criteria. Alternative 10 would leave contaminated
soils on-site which allows the toxicity and volume of
contaminated soil to remain unchanged after the remedy
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is complete. The mobility of the contaminants in the
buried soils is also unchanged.
5) Short-term effectiveness
Alternative 6 soils cleanup should meet ARARs within
one year of implementation. It meets the criteria for
short term effectiveness.
6) Ability to be implemented
Alternative 6 soils treatment is a proven technology
and easily implemented at this site.
7) Cost
Alternative 6 is more expensive than Alternative 10,
but the differential between the two should be examined
more closely. In alternative 6 for the buried debris,
the FS states 4000 CY of buried debris is anticipated
to be generated and disposed of in a TSCA landfill. In
alternative 10, the volume of buried debris/soils
included in the costs for TSCA landfilling is 2,000 CY.
Since the disposal costs for soils or debris is the
same in alternative 10, either alternative 10 must
double the cost of the buried debris or alternative 6
costs should be reduced by the same amount (see Table
1). This analysis liberally allows for the cost of
treating the remaining 10,000 CY of soil to apply
solely to Alternative 6. If, however, all 10,000 CY
of soil anticipated for treatment in alternative 6 is
not below the 10"4 level, additional costs should be
added to Alternative 10 to reflect the cost of TSCA
landfilling these soils. In short the cost
differential reflected in the FS documents is not
correct and needs a close examination during the
writing of the Record of Decision.
As stated in comment 2 above, CHNC feels that there is
a real cost to the Swede Town community for a limited
cleanup. These costs will be reflected in property
values and in "human costs" which are real and have
value, and must be evaluated by EPA in the decision-
making process.
8) State acceptance
The State has supported EPA in accepting Alternative 7
as their choice. On 10/18/95 the State confirmed that
it continues to support this alternative. The only
difference between alternative 7 and our choice of 6 is
the ground water remedy. CHNC and the State of Utah
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support the same soils remedy for the site.
9) Community acceptance
CHNC, Salt Lake City Office of the Mayor, and the Salt
Lake City/County Health Department (representing the
county's position) all support the soils remedies in
alternative 6. At the final vote of the entire
community council (75 in attendance) only one vote was
cast in the negative. This indicates the overwhelming
unity in support of the council's preference for
Alternative 6.
Response
Section 9.0 of the Record of Decision details the summary of the
comparative analysis of the alternatives which compares
alternative 6 with all the other alternatives, including
alternative 10, the selected remedy. Sections 10.0 and 12.0
describe the selected remedy, and the statutory determinations
regarding the selected remedy, respectively. Section 11.0
describes the information that is new or that was revisited in
the effort to select a remedy. EPA believes that the selection
of alternative 10 is in accordance with CERCLA and is consistent
with the NCP and EPA's guidance in selecting response actions.
CERCLA requires the selected remedy to be in accordance with the
National Contingency Plan and provide a cost-effective response.
Cost-effectiveness is defined by evaluating long- and short- term
effectiveness, and reduction of toxicity and mobility and volume
through treatment against the cost. The risk presented by the
site soils is 9.75 X 10~5 to an industrial worker. This risk
level is within EPA's acceptable risk range of 10"4 - 10"6,
however, EPA believes that further actions should be taken. Thus
EPA is supportive of excavating and disposing in an off-site
Subtitle C or D permitted landfill, as appropriate, all isolated
hot spot soils areas that exceed 10"5, which will have the
overall effect of further reducing the 9.75 X 10"5 risk. The
remaining soils will be buried on-site under a 42 inch clean soil
cap.
The nature of the contaminants with these soils is primarily PAHs
which although long chain hydrocarbons, will degrade over time
thus further reducing their potential to yield risk. Thus the
long-term risk at the site is minimal, both because of the nature
of the contaminants within the soils and because the exposure
pathway will be cut-off by 42 inches of clean soil.
Although the treatment of these soils would provide further
reduction of risk, the existing concentrations of contaminants
within the soils are within EPA's acceptable risk range for an
industrial worker. Treating soils within EPA's acceptable risk
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range is not an expectation expressed in the NCP and existing EPA
policy. For example, the NCP states that EPA is expected to use
engineering controls, such as containment, for waste that poses a
relatively low long-term threat. EPA's preference for treatment
is generally applied to principal threat waste or to reduce the
risk to within EPA's acceptable risk range. Since the soils do
not present a principal threat and the soils are within EPA's
acceptable risk range, treatment cannot be justified.
The difference between alternative 6 and alternative 10 is
primarily the actions regarding the soils and buried debris. The
total cost difference is $8.1 million. Both alternatives are
equally protective of human health and the environment.
A National Remedy Review Board (NRRB) was established by EPA as
one of the October 1995 Superfund Administrative Reforms to help
control remedy costs and promote both consistent and cost-
effective decisions at Superfund sites. All proposed cleanup
actions are to be reviewed by the Board where: (1) the estimated
preferred alternative exceeds $30 million; or (2) the preferred
alternative costs over $10 million and this cost is 50% greater
than that of the least-costly, protective, Applicable, Relevant
and Appropriate Regulation (ARAR) - compliant alternative. The
preferred alternative for Petrochem, as presented in the Proposed
Plan, triggered the second criteria for review by the NRRB. The
Proposed Plan for the Site, issued in July of 1995, identified
Alternative 7 as EPA's preferred alternative. The total cost of
Alternative 7 is estimated to be $16.6 million. The least
costly, protective, ARAR-compliant alternative (Alternative 10 in
the Proposed Plan is estimated to cost $6.1 million).
In its review, the NRRB considers the nature and complexity of
the site; health and environmental risks; the range of
alternative actions considered to address site risks; and quality
and reasonableness of the costs estimates for alternatives;
regional, State/tribal and other stakeholder opinions on the
proposed actions to the extent they are known at the time of
review; and any other relevant factors or program guidance.
The establishment of the NRRB was intended to bring to bear the
Agency's extensive experience on decisions at a select number of
high stakes sites. Generally, the NRRB makes "advisory
recommendations" to the appropriate Regional decision maker. In
this instance, that recommendation states that, "...the NRRB
believes that the Region may benefit from considering other less
costly alternatives that address only the principal threats
through treatment while yielding fully beneficial property use
with minimum restrictions." The Board's recommendation are part
of EPA's decision making process, and were carefully considered
in Region VIII's selection of Alternative 10 as the final remedy
for the Site.
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5) Comment
Comparison of costs associated with the cleanup of the buried
debris.
Alternative 10 cost (per the Second Addendum to the Final Revised
Feasibility Study - Petrochem/Ekotek Site, April 7, 1995) and
Alternative 6 cost (per the FS) are tabulated below. In this
tabulation several changes have been made to the cost analysis
from the original FS documents. The intent here is not to make
the cost estimates "more accurate" but to make sure the cost
comparisons are apples and apples. We do not believe the
original FS documents made an accurate comparison in this
respect.
No changes have been made to the unit costs of any of the items
in Table 1.
Rationale for Table 1 is as follows:
Dust/Air Controls; In Alternative 6 vapor enclosures
were used while in Alternative 10 foam was used.
Assuming that either technology is effective, it seems
unreasonable to charge a vapor enclosure to Alternative
6 when a much less expensive technique of foam will be
equally effective. Therefore, foam was used in the
costs for both alternatives. The operation and
maintenance cost for the vapor enclosure was,
therefore, omitted from the costs of Alternative 6.
Volume of soil in Alternative 10: The same volume was
applied (4,000 CY) under the "Quantity" in Alternative
10 as in 6 to be sure the cost comparison reflected
performing the same task on the same volume, where
appropriate. It is possible that the volume estimated
will be different. If the buried debris volume is
overestimated, the cost benefit will apply equally to
both alternatives. The quantity of buried debris, for
cost comparison, is moot. Overestimation of
contaminated soils of 10~4 and below will reduce the
cost of Alternative 6, this overestimation will have no
cost reducing effects on alternative 10.
Underestimation of the amount of "hot spot" soils will
increase the cost of the alternative 10 while having no
cost effects on alternative 6. Alternative 6 is only
going to cost more if the total amount of contaminated
soils increases, while alternative 10 will become more
costly if the "hot spot" soils associated with the
buried debris increases.
Demolition of Slab:- This cost was omitted from
Alternative 6 in the FS, but added to that alternative
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in this analysis.
Investigation under slab; This cost was omitted from
alternative 6, but added to that alternative in this
analysis. It is unrealistic to assume that once the
slab has been demolished and removed that these data
will not be gather under either alternative.
Other costs applied as a percentage of capital costs:
These costs were applied equally to both alternatives
and the contingency cost was reduced from that which
was originally in Alternative 10.
Response
EPA has reviewed the cost estimates submitted in the feasibility
study and finds that these cost estimates are within the level of
accuracy required by EPA's guidance which is +50% / -30%. EPA
agrees that there are differences in the estimates and
appreciates the effort that has been expended on the commentor's
part to compare the estimates. The commentor's comparison of
"apples to apples" shows that there is a difference of $2,114,907
which represents a difference between alternatives 6 and 10 of
$5,985,093. Taking into account the commentor's comparison,
alternative 10 is a little less than half the cost of alternative
6 and achieves the threshold criteria of protection of human
health and the environment. Alternative 10 disposes off-site
soils that exceed the soil hot spots and LNAPL-saturated soils.
The ROD describes how the debris area will be excavated and how
the LNAPL-saturated soil within the buried debris will be
disposed off-site. The commentor's comparison verifies that
although the cost differences between alternatives 6 and 10 may
be narrowed by $2 million, the remaining cost gap between the two
alternatives is still quite significant.
6) Comment
Aquifer Characterization Report.
General Comment: The report is an important addition
to understanding the hydrogeology of the site. The
figures and illustrations are very helpful in
understanding the points presented. The CHNC attended
and participated in developing the conclusions at the
meeting held on August 28 and 29, 1995 regarding this
document. We continue to support those conclusions.
Additional data needs were discussed during this
meeting and we very much encourage development of these
data needs as part of the Record of Decision. Our
support of intrinsic remediation is contingent upon
further investigations into its effectiveness at the
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site and additional monitoring locations west of the
presented wells.
Response
See response to comment 3.
7) Comment
Aquifer Characterization Report
1. Page vii, paragraph 2, last sentence. Data in the report
does not support the conclusion that ground water beneath the
site is stagnant. In a high conductivity aquifer the volume of
water moving through the aquifer can be the same as that moving
through adjacent lower K materials and at the same time have
proportionately reduced gradient.
Response
EPA believes that the data collected to date does show migration
of contaminated ground water to the northwest and west of the
Site which clearly refutes the idea of stagnation. However, EPA
believes that the flow is relatively slow. EPA believes
additional data is needed to fully and accurately define the flow
rate for the site and believes that this information is vital to
proving the hypothesis that the contaminated ground water
directly beneath the Site is undergoing bioremediation at a rate
that prevents further migration of contaminated ground water
beyond the present extent of contamination.
8) Comment
Aquifer Characterization Report
2. Page 3-5, paragraph 2, 1st sentence. The geothermal gradient
for the Salt Lake Valley is much higher than the rest of the
Great Basin according to Klauk and Riji, 19 , Utah Geological
Survey publication. They estimate the gradient to be 58° C/km.
Response
For purposes of responding to comments on the Aquifer
Characterization Report, EPA has concentrated its efforts to
respond to issues directly relating to selection of the remedy.
EPA did not generate this report and cannot provide the
interpreted information or answer questions as to how the
document was developed as requested by the commenter.
9) Comment
Aquifer Characterization Report
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3. Page 3-5, paragraph 3. Figure 3-6 needs to have the contour
interval specified.
Response
See response to comment 8.
10) Comment
Aquifer Characterization Report
4. Page 4-2, paragraph 2. Figure 4-2 shows the potentiometric
surface of Units 1, 2 and 3 converging just west of the site.
This is certainly plausible, but the available data leaves the
possibility for other interpretations. The presence of the
shallow bedrock below the site may mean Unit 3 is not directly
connected to Unit 1.
Response
See response to comment 8.
11) Comment
Aquifer Characterization Report
5. Page 4-2, paragraph 3. Recharge to Unit 3 may also come
directly through the bedrock/valley-fill interface below the
site.
Response
See response to comment 8.
12) Comment
Aquifer Characterization Report
6. Page 4-3, top sentence. The amount of flow from Unit 1 to
Unit 2 may be understated. Evapotranspiration from unit 2 and
less permeable sediments just west of the site to block the
upward flow from Unit 3 would enhance this flow potential.
Response
See response to comment 8.
13) Comment
Aquifer Characterization Report
7. Page 4-7, reference to figure 4-7. It is understood that the
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potentiometric contour lines in this figure are interpretive.
If, however, the cross section were contoured strictly on the
basis of head without regard to the three units, the flow net in
the area of the site would look quite different. The lowest head
value in this area is in the deep zone from well P-5. Since
ground water flows to lower head, it seems very reasonable to
assume that shallow ground water below the site is moving both
down and to the west. This relationship is completely missed in
the cross section.
Based on these data, it is important that new wells be considered
for the area to the west of P-5/P-6 and at depths similar to the
deeper zone and perhaps beyond that depth. This is the most
likely area for contaminants from the site ground water to move
to based on the current report. The fact that contaminants have
appeared in the deeper zone of P-5 should sound the alarm that
contaminants may be leaving the site to the west, at depth. With
this new information on the contaminant flow direction to the
west (May 1995 samples from deep zones of P-5 and P-6) it is ever
more likely that contaminated ground water may find its way
either into surface discharge to the west wetlands and ponds or,
perhaps into Unit 3. Both of these paths are very undesirable
and must be closely monitored.
Response
EPA agrees with the concerns expressed in this comment. The
location of the compliance boundary is graphically delineated in
the ROD and shall be further refined during the remedial design.
The areal extent of this contamination as well as the depth of
this contamination must be clearly delineated to ensure no
further migration of the contaminants. The containment
contingency has been.fully described in the ROD and shall be
implemented to prevent further migration of contamination beyond
its current extent.
14) Comment
Aquifer Characterization Report
8. Page 4-7, paragraph 3. The reference to a trend of
"geothermal activity" increasing in the spring to early summer
cannot be confirmed by examination of discharge data from Wasatch
Hot Springs from 1920 to 1939 (Ground Water in the Jordan Valley
Utah, Taylor and Leggette, 1949, U.S. Geological Survey Water
Supply Paper 1029, p. 40-41). Perhaps this trend is one found
generally in thermal springs in Utah, but historic data from this
nearby spring does not confirm the statement in the report. If
site specific data exists to support this conclusion it should be
included in the report.
Response
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See response to comment 8.
15) Comment
Aquifer Characterization Report
9. Figure 5-6. The contour line for vinyl chloride is
incorrectly plotted on the map. Well W-4a has a concentration of
3.87 and lies outside the 1.0 contour line. Well MW-7 has a
concentration of 0.62 and lies inside the contour line. Has the
rest of the contouring on other maps been done with the same
care?
Response
See response to comment 8.
13.2.2 EPA's Response to Comments from Mayor Deedee Corradini of
Salt Lake City, Utah
16) Comment
The Capitol Hill Community Council and the TAG group have
selected Alternative 6 as their preferred alternative. In the
interest of long-term effectiveness and permanence, as well as
the reduction of toxicity, mobility and volume, the City joins
the community in their support of this alternative.
Response
See response to comment 4.
13.2.3 EPA's Response to Comments from Salt Lake Area Chamber
of Commerce, Fred S. Ball, CCE, President CEO and Arlen Crouch,
Chair, Board of Governors.
17) Comment
The Salt Lake Area Chamber of Commerce Environmental Committee
met recently to discuss the various alternatives for addressing
soil and ground water contamination at the Petrochem/Ekotek
Superfund Site in Salt Lake City. The committee unanimously
concluded that "Alternative 10" was the most cost effective
remediation method (it is our understanding that "Alternative 10"
is $10 million less than EPA's "Alternative 7) which would meet
EPA cleanup goals and protect public health and the environment.
After full consideration of the facts, the Board of Governors of
the Chamber supports the committee's decision, and feels that
"Alternative 10" is the most cost effective and reasonable plan
to complete the cleanup operation.
We exhort the Environmental Protection Agency to make
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"Alternative 10" the cleanup process which will finally bring
this issue to a close.
Response
See response to comment 4 and 18.
13.2.4 EPA's Response to Comments from the Community Action
Program, Karen Silver
18) Comment
I am writing to comment on the Proposed Plan for the
Petrochem/Ekotek site. The Capitol Hill Neighborhood Council TAG
Committee, which I have been providing advocacy support to,
supports Alternative 6 as being of most benefit to the
neighborhood. At the Council meeting on October 28th the entire
group voted. Alternative 6 was chosen by a very wide margin.
The issue of cost benefit ratios has been raised pertaining to
this site. I would like to address this. In none of the
alternatives do I find information about cost benefits to the
residents. This needs to be factored into any alternative.
These are people who have diligently over the years reported
concerns about the activities of Ekotek and its predecessors to
entities which could have taken action. Property values have not
risen. Basic amenities such as sewer connections have not been
put in the area. The prospects these residents face if they even
think of trying to sell and move are bleak. These residents are
practically being forced to stay in the area. Options that
residents in other communities have, such as making major
improvements to property or moving, are being severely limited
for the residents in this neighborhood. These residents deserve
the best cleanup possible. At present, Alternative 6 seems to
fit the bill.
Response
See response to comment 4. With respect to cost benefits, CERCLA
and the NCP defines how EPA is to evaluate cost-effectiveness of
a remedy. Section 121 of CERCLA states "in evaluating the cost
effectiveness of proposed alternative remedial actions, the
President shall take into account the total short- and long-term
costs of such actions, including the costs of operation and
maintenance for the entire period during which such activities
will be required." The NCP states "Cost-effectiveness is
determined by evaluating the following three of the five
balancing criteria noted in Section 300.430 (f) (1) (i) (B) to
determine overall effectiveness: long-term effectiveness and
permanence, reduction of toxicity, mobility, or volume through
treatment, and short-term effectiveness. Overall effectiveness
is then compared to cost to ensure that the remedy is cost-
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effective. A remedy shall be cost-effective if its costs are
proportional to its overall effectiveness." CERCLA and the NCP
do not allow EPA to consider local property values or other
factors cited in your comment as part of the evaluation of cost-
effectiveness. However, CERCLA requires that the selection of
the remedy take into account the degree of support of a remedial
action by parties interested in the site. The NCP details a
process for the participation of the public and identifies
Community Acceptance as one of the modifying criteria of the nine
criteria used for evaluating and selecting a response action.
EPA has reviewed all the comments submitted to EPA by all
interested parties and has incorporated these comments into the
selection of the remedy. This responsiveness summary provides
EPA's responses to each of the comments submitted to EPA by all
interested parties. EPA believes that the selection of
alternative 10 is in accordance with CERCLA and is consistent
with the NCP and EPA's guidance in selecting response actions.
13.2.5 EPA's Response to Comments from Ten Swedetown Residents
19) Comment
We the residents of the Swedetown area in Salt Lake City, Utah
live feel very strongly that the clean up project for the Ekotek
Site should be cleaned up and we support Alternative #6 process.
We feel that the residents have been the real losers in the
situation, due to the possible health risk that Ekotek has
presented.
We feel that it is important that this site gets cleaned up and
in a proper manner.
Response
Alternative 10, the selected remedy, is protective of human
health and the environment. The LNAPL, which EPA believes to be
the source of contamination to the ground water, will be
excavated and incinerated off-site. The ground water will be
remediated through bioremediation/attenuation. The soils that
exceed the hot spot criteria will be disposed off-site. The
remaining soils, which are within EPA's acceptable risk range for
the industrial worker, will be contained under a 42 inch clean
soil cap. The industrial worker scenario was chosen because of
the area is zoned industrial, leading EPA to believe that the
likelihood for residential development is low. The selected
remedy eliminates exposure to both the industrial worker and to
anyone who accesses the Site. The selected remedy eliminates all
exposure pathways and thus prevents any possible health risk to
the local residents and the industrial worker.
13.2.6 EPA's Response to Comments from North Associates
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Incorporated, Allan Woodbury
20) Comment
As a resident of the Capital Hill Community, I would like to go
on record as opposing the recommendation that is being made by
our neighborhood council that Cleanup Method Alternate 6 be
imposed on the PPA's.
My feeling is that the PPA's should choose the method of cleanup
that satisfies EPA & legal criteria, which would likely be
Alternate 10.
Words such as "contamination", "toxic", etc. throw fear into the
minds of the general public. Most people have no real perception
of relative risk factors, as they apply to public health. The
greatest harm from Ekotek has been to the surrounding property
values, which are primarily reduced by the fact that the Ekotek
site has been labelled a "superfund site". The label itself is
more harmful to the health of the residents than are the
contaminants at the site.
My own opinion is that the superfund law is a bad piece of
legislation which unfairly penalizes innocent people & destroys
property values. The bulk of the money is being spent on lawyers
and studies, neither of which really do much to cleanup the
sites. Common sense is being ignored & the economy suffers.
Response
See response to comment 4. EPA's use of the words
"contamination" and "toxic" is not meant to throw fear into the
minds of the general public, but to explain the findings of the
investigations that have been completed at the Petrochem/Ekotek
Site. EPA has engaged the public in a conversation about the
risks posed by this site and the use of the terms "contamination"
and "toxic" are a necessary part of our vocabulary to explain the
results of the remedial investigation and the baseline risk
assessment.
13.2.7 EPA's Response to Comments from Claude H. Nix
Construction, Incorporated, Claude H. Nix, President.
21) Comment
Small companies such as ours are rarely able to afford legal
assistance that requires a considerable amount of time.
Therefore, we elected to pay the "used oil Settlement (No
Reopener)" fee proposed to us. It later came to our attention
that larger companies, through the lengthy legal process have
successfully reduced their settlement amount to somewhat less
than half of the specified amount per gallon. This amount was
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already less than that charged to small contributors. In
addition, since the amount collected is well over the amount
needed for the cleanup, they may not have to pay at all.
Although they have probably spent considerable amounts for legal
fees, no environmental improvement has occurred. Suggestion:
Once a settlement amount is decided, it should not be negotiable.
Response
Comment is noted.
22) Comment
During the course of events, we have received a minimum of two
copies of all pertinent documents. This includes copies sent to
our lawyer. Not only is this wasteful and confusing for small
companies, it is contrary to EPA's mission of pollution
prevention and conservation. In addition, the publication
announcing the proposed plan was printed in what appears to be an
expensive manner, i.e., special order paper in booklet form.
Suggestion, only keep defendants on the mailing list. Include
lawyers only upon a defendant's request. All documents should be
copied on inexpensive recycled paper, double sided.
Response
EPA's standard procedure is to produce all documents as double
sided to reduce waste. The brochure on the proposed plan was in
fact printed on recycled paper as indicated on the back page of
the document. One method EPA uses to keep the public informed is
the distribution of fact sheets. EPA maintains a mailing list of
all PRPs, interested businesses, attorneys, State and local
government representatives and citizens and uses this list to
mail fact sheets. Anyone who does not want to receive EPA's fact
sheets can, upon their request, be taken off the mailing list.
23) Comment
The Superfund law is a detriment to environmental protection.
Small companies intending to do their part to protect the
environment, but are unfortunate enough to become involved in a
Superfund case, are left Cynical and discouraged. It is unlikely
that any of these small companies will voluntarily or willingly
cooperate with state or EPA on other more positive issues and
programs. Suggestion: It is our opinion that much could be
gained in the relationship between the defendants and the
government agencies if the surplus amount collected by the
"Committee" is refunded to contributors. The amounts should be
in proportion to those amounts paid. If this is not possible,
the defendants should be able to be a part of the decision making
process on how the extra money is to be spent.
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Response
The Superfund law has provided the legal framework for the
cleanup of over 3,000 sites nationwide. CERCLA liability is
retroactive to the parties who either generated, transported to,
or were owners and/or operators of a site where hazardous waste
has contaminated the environment. It is EPA's policy to "cash
out" parties who contributed a minor portion of the waste (de
minimis portion) to the site. Often these parties are small
businesses. The purpose of de minimis settlements is to allow
parties to cash out early during the Superfund process so that
they can save the transactional cost of participation. .A meeting
was held at the Salt Lake Hilton in February, 1992, to discuss
the EPA 104(e) information request letters and to offer
de minimis settlements through ESRC.
EPA's de minimis settlements were based upon a range of potential
future remedial alternatives that are fully described in the
Preliminary Identification of Remedial Alternatives (PIRA)
published in 1993. The first two quarters of data collected at
the Petrochem/Ekotek Site formed the basis of the conclusions and
the development of the alternatives, described with associated
estimated costs, in the PIRA. The first two quarters of sampling
had higher concentrations of contaminants than the subsequent
quarters, as explained in the ROD. The Proposed Plan is based
upon significantly more data than the PIRA. Thus the total
response cost estimated for cleanup of the Petrochem/Ekotek site
which was used by EPA for purposes of settling with de minimis
parties was higher than the alternatives described in the
Proposed Plan published in July 1995. De minimis settlements
with EPA are voluntary and are offered as a form of insurance
against other parties that might sue them for contribution. So
although the de minimis settlements were conducted in a manner
consistent with EPA's policy, EPA recognizes that the cle. minimis
settlers have paid more than their proportionate share. However,
to provide reimbursements, EPA's policies regarding settlements
would have to be completely restructured. The current policy
does not envision the concept of reimbursements to de minimis
settlers.
13.2.8 EPA's Response to Comments from Robert's TEA Service,
Incorporated, Steve Roberts, Trustee for Robert's TEA
24) Comment
Ed Roberts is deceased. His spouse Wanda feels terrible you have
extracted so much money from her. I only am trying to help her.
Your agency is a terrible blight on citizens that have been
honest and hardworking for years. You have gotten all the money
you could from my parents. Quit bothering my widowed mother. A
lowly gas station owner is dead, the business is gone. The
government has accomplished its purpose.
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Response
EPA would like to express sincere sympathy on the passing
of your father. Your father's business was identified as either
a generator or transporter of the waste oil that was disposed at
the Petrochem/Ekotek site and is a portion of the contamination
at the site that requires remediation. CERLCA, the law governing
the remediation of hazardous waste sites and the associated
liability, requires that the generator or transporters or owner
and/or operators pay for the cleanup. EPA recognizes the impact
this action has had on a number of people in similar situations,
and so proposed the deminimis settlements to minimize the impact
on individuals and to adhere to the intent of the law.
13.2.9 EPA's Response to Comments from Woodward-Clyde, John N.
Philbrook, Vice President, Manager, Denver Operations
25) Comment
I am pleased to see that EPA is now addressing the final cleanup
alternatives for the Ekotek site. However, I find the EPA
preferred alternative, Alternative 7, to be very costly in light
of similar cleanup goals achieved by other alternatives that cost
much less.
When compared to the other alternatives given in the Proposed
Plan, Alternative 4, 5, 6, 8, and 10 all meet the EPA cleanup
goals that are protective of the public health and the
environment. Of these alternatives, Alternative 10 is the most
cost effective cleanup alternative for the Site that meets the
EPA cleanup goals. Alternative 10 is as protective as EPA's
preferred Alternative 7 in terms of reducing soil and groundwater
exposures and, therefore, risks; however, Alternative 10 costs
over $10 million dollars less.
I would request that the EPA further consider the costs in
implementing cleanups in its remedial decisions, as well as the
reduction of risks, therefore, I urge the EPA to choose
Alternative 10 as the preferred cleanup alternative for the
Petrochem/Ekotek Superfund Site.
Response
See response to comment 4.
13.2.10 EPA's Response to Comments from ITEX, Peter P. Fote,
Western Region
26) Comment
I find the EPA preferred alternative, Alternative 7, to be
unreasonably stringent and costly in light of similar cleanup
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goals achieved by other alternatives that cost much less.
When compared to the other alternatives given in the proposed
Plan, Alternatives 4, 5, 6, 8 and 10 all meet the EPA cleanup
goals that are protective of the public health and the
environment. Of these Alternatives, Alternative 10 is the most
cost effective cleanup alternative for the Site that meet the EPA
clean up goals.
It is my opinion, derived from knowledge of the subsurface
hydrogeologic conditions at the Site, that state-of-the-art
ground water pump and treat technology will not be productive in
the cleanup of the dissolved phase portion of contaminated
groundwater. The reason is the vertical hydraulic conductivity
of the shallow thermal aquifer below the Site is as equal to or
greater than the horizontal hydraulic conductivity. A
groundwater pump and treat system will yield greater amounts of
geothermal water over time and less meteoric fresh water from
where the dissolved contaminates reside. The radius of influence
in the meteoric fresh ground water in the horizontal plane will
be minimal in relation to capturing the dissolved phase plume.
Potentially, the pump and treat system will yield vast amounts of
clean geothermal water to be discharged to the POTW for
treatment. Also, the geothermal groundwater beneath the Site has
a conductivity in the range of 15,000 /zQ /cm versus the
conductivity of the meteoric fresh ground water which is 1,000 /jQ
/cm. The POTW will have problems treating the high conductivity
geothermal groundwater. The groundwater pump and treat system
will achieve nothing but the treatment of vast amounts of clean
ground water over the life of the system at extensive cost to the
PRP Committee. The natural attenuation of the dissolved phase
plume is the only economically and technically feasible
treatment available due to the hydrogeologic subsurface
conditions existing at the Site.
Alternative 10 is as protective as EPA's preferred Alternative 7
in terms or reducing soil and groundwater exposures and,
therefore, risks; however, Alternative 10 costs over $10 million
dollars less.
I believe it is time that the EPA be reasonable and consider the
costs of implementing cleanups in its remedial decisions, as well
as the reduction of risks; therefore, I urge the EPA to choose
Alternative 10 as the preferred cleanup alternative for the
Petrochem/Ekotek Superfund Site.
Response
See response to comment 4 and 18. Alternative 10, the selected
remedy relies upon bioremediation/attenuation to address the
contaminants within the ground water plume. However, EPA will
rely upon a pump and treat system for the containment contingency
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off-site if containment is deemed necessary to prevent further
migration of the contaminants. By selecting alternative 10, EPA
is not concluding pump and treat could not be effective at the
site. Alternative 10 provides overall a better balance of trade
offs among the nine criteria for remedy selection. EPA
recognizes some of the potential difficulties associated with
pump and treat. However, if bioremediation/attenuation does not
work or is ineffective in meeting remediation levels, then pump
and treat may be the next best approach.
13.2.11 EPA's Response to Comments from Morrison Knudsen
Corporation, Donald J. Carpenter.
27) Comment
A technical review of the EPA's Proposed Plan for the Ekotek
Superfund Site allows one to conclude that Alternative 10 more
cost effectively achieves the protective goals set forth in
CERCLA than the selected Alternative 7. Figure 3 presented in
the July, 1995 EPA announcement for the proposed plan of the
Petrochem/Ekotek Superfund Site documents that Alternative 10
meets the two threshold cleanup criteria and the five balancing
criteria. The EPA has noted that Alternative 10 "meets minimum
requirements" for certain cleanup criteria. Moreover, the EPA
has suggested that other alternatives, such as Alternative 7,
"Fully complies with the requirement". Clearly the EPA is
attempting to incorrectly subdivide compliance criteria.
Fundamentally, an alternative either complies or does not comply
with a criterion. It is recognized that more expensive
treatment, beyond that required to comply with the criteria, may
be employed. The cost benefit of this additional treatment is,
however, questionable. Alternative 10, which employs industry
proven containment practices, can be readily implemented without
the short-term concern of exposing the community to Products of
Incomplete Combustion (PICs) generated during on-site thermal
treatment; compounds that may pose a significant additional
threat to residents and the community. The acknowledgement by
the EPA that Alternative 10 meets the CERCLA evaluation criteria,
argues that this readily implementable alternative, that does not
create an additional short-term exposure hazard to the community,
should be selected in lieu of Alternative 7.
Response
The threshold criteria of Overall Protection of Human Health and
the environment, and Compliance with ARARs are criterion that
each alternative must meet in order to be eligible for selection.
Long-term effectiveness and permanence; reduction of toxicity,
mobility, or volume through treatment; short-term effectiveness;
implementability; and cost are considered primary balancing
criteria. The alternatives by nature of the actions being
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considered achieve varying degrees of each of the balancing
criteria. Overall protection of human health and the environment
draws on the assessments of other evaluation criteria, especially
long-term effectiveness and permanence, short-term effectiveness,
and compliance with ARARs. EPA acknowledges that alternative 10
meets the threshold criteria.
See also response to comment 4.
13.2.12 EPA's Response to Comments from Liaison Defendants in
the Civil Action, Ekotek Site PRP Committee V Self et al.. Civil
No 94-C-277K, submitted by the law office of Parry Murray Ward &
Moxley, Douglas J. Parry, Esquire and Bret F. Randall, Esquire.
28) Comment
EPA should Select the most Cost Effective Remedy. The Liaison
Defendants are potentially liable for remediation costs at the
Petrochem/Ekotek site for nothing more or less than selling,
transporting, or otherwise conveying new and used petroleum
products for the sole purpose of recycling and re-use. The
United States Congress long ago found and declared as follows:
The Congress finds and declares that -
(1) used oil is a valuable source
of increasingly scarce energy and
materials;
(2) technology exists to re-refine,
reprocess, reclaim, and otherwise
recycle used oil;
(3) used oil constitutes a threat
to public health and the
environment when reused or disposed
of improperly; and
that, therefore, it is in the national
interest to recycle used oil...
42 U.S.C. 6901a.
Ekotek was federally and state licensed and had an EPA hauler
identification number and held itself out to be a viable, legal
recycler of used oil and other petroleum materials. The Liaison
Defendants were instructed and in many cases required by the Utah
State Department of Health to convey their used oil to licensed
used oil recyclers, including Ekotek. The Liaison Defendants
never believed that their re-use and recycling of petroleum would
give rise to such significant environmental liability for the
Petrochem/Ekotek site. To the contrary, the Liaison Defendants
reasonably believed that their attempt to re-use and recycle
their petroleum was a positive attempt to help the environment.
In fact, many of the Liaison Defendants accepted quantities of.
used petroleum from "do-it-yourself" customers who likely would
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have improperly disposed of their oil had the Liaison Defendants
not accepted it for recycling. Now these Liaison Defendants are
potentially liable for these same volumes of oil that likely
would have been dumped in fields or into the sewer.
In light of Congress' findings and the strong federal policy
favoring the recycling of used petroleum, the conduct of the
Liaison Defendants in selling, transporting or otherwise
conveying new and used petroleum products for the sole purpose of
recycling and re-use is fundamentally different from a more
typical federal superfund site, where companies literally dump
worthless chemicals on a site with the intent to ultimately
dispose of their wastes. None of the Liaison Defendants dumped a
worthless, contaminated byproduct at the Petrochem/Ekotek Site
with the intent to ultimately dispose of the waste.
Moreover, numerous of the Liaison Defendants are "service station
dealers" within the meaning of CERCLA 114(c), U.S.C. 9614(c) and
complied with the Used Oil Management Standards. The only reason
these Liaison Defendants are potentially liable for costs of
remediation at the Petrochem/Ekotek Site, according to the judge
in the civil action, is- that EPA delayed promulgation of the used
oil management standards for years after Congress required that
the standards be passed. EPA's delay should not penalize the
Liaison Defendants who can establish their entitlement to
statutory protection as a "service station dealer."
Imposing CERCLA liability on the Liaison Defendants for recycling
petroleum has severely impaired Congress1 stated policy that the
recycling of used oil is in the "national interest" and that
service station dealers are entitled to a statutory exemption
from liability under CERCLA. EPA should not further exacerbate
these problems by selecting a remedy which is far more expensive
than necessary to adequately protect human health and the
environment at the Petrochem/Ekotek site.
Response
EPA disagrees with the commenter's assertion that imposing CERCLA
liability on parties who sent waste oil and related materials to
the Petrochem Site contradicts Congress1 policy that recycling
oil is in the national interest. EPA also disagrees with the
commenter's implication that the alternative to CERCLA liability
would be disposal of waste oil in fields or down sewers. Such
actions would constitute illegal disposal.
While EPA regrets that the Petrochem Site has become contaminated
and subject to a Superfund cleanup action, this is in fact what
has happened and EPA is charged by Congress, pursuant to
Superfund, to take appropriate action to ensure that the public
is not exposed to undue risk from the contamination. EPA selects
the appropriate remedial actions for a Superfund Site independent
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of the determination of which parties may or may not be liable at
a Site. Remedial actions are selected on the basis of risk
presented by the contamination released at a Site, while
liability for cleanup costs is determined pursuant to
Section 107 of the Superfund law (CERCLA).
Under Section 107 of CERCLA, parties who generate hazardous
substances that are transported to a Superfund site and parties
who transport such substances to a Superfund site for treatment
or disposal may be liable for costs of cleanup. Although
Congress provided an exclusion for petroleum related products,
the exclusion does not extend to waste oil or other used
petroleum materials that have become contaminated through use
beyond the contaminate levels normally present in virgin or
unused refined oil. Moreover, because recycling involves aspects
of treatment and disposal, CERCLA Section 107 provides no
exemption from liability for the type of recycling of waste oil
that occurred at the Petrochem Site. Finally, although Congress
provided an exemption from Superfund liability for certain
"service station dealers" who recycle waste oil, Congress
expressly provided that the exemption would not be effective
until EPA's oil recycling rules were promulgated (the rules had
to first be in place because, for such dealers to qualify for the
exemption, the law provides that they must demonstrate compliance
with EPA's waste oil recycling rules). Because EPA's waste oil
recycling regulations were not promulgated until after the
Petrochem facility had stopped operating, the exemption was not
available for contributors of waste oil to Petrochem.
EPA's legal position regarding these issues is presented in
"Defendant United States of America's Response to Liaison
Defendants' Motion for Summary Adjudication of Issues, filed on
December 29, 1994, in The Ekotek Site PRP Committee v. Steven M.
Self, et al.. C.A. 94 C 277K (U.S. District Court, District of
Utah). The U.S. District Court has ruled on these issues in that
case, in its Memorandum Order, March 24, 1995, and follow up
Memorandum Order, June 12, 1995. In general, the ruling upholds
and is supportive of EPA's position regarding liability
associated with waste oil.
29) Comment
The Liaison Defendants Favor Alternative 10. EPA determined that
Alternative 10 satisfies all applicable requirements and
standards. Alternative 10 is more than $10 million less
expensive than the remedy proposed by EPA. The Liaison
Defendants prefer Alternative 10 for the following reasons:
1. The slight, perceived benefits of EPA's proposed
remedy are greatly outweighed by the significant
differences in cost: over $10 million.
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2. At the July 26, 1995 public meeting, even the
landowners' association opposed EPA's proposed remedy
on the grounds that it was too costly and that the
proposal to pump and treat groundwater in the shallow
aquifer will not work and is not necessary.
3. The Liaison Defendants should not be penalized for
conduct they reasonably believed would actually serve
to protect the environment, that is, the sale,
transport and conveyance of new and used petroleum for
the purpose of re-use and recycling, consistent with
Congress' stated policy favoring the recycling of
petroleum.
4. The contamination plume is stable.
5. Risk of off-site public exposure is virtually non-
existent.
6. The evidence suggests that intrinsic bioremediation
of the shallow aquifer is feasible, effective, and the
least costly alternative.
7. The evidence suggests that the pump and treat
technology will not work.
8. Because the contamination plume is stable, EPA
should at least give bioremediation of the shallow
aquifer a chance to work. If the remedy is not
effective over time, other remedies could be
considered.
9. Alternative 10 satisfies all applicable standards
and requirements.
10. Alternative 10 is by far the most cost effective
remedy.
For the foregoing reasons, the Liaison Defendants hereby request
that EPA change its proposed plan and select Alternative 10.
Response
See response to comment 4. The stability of the plume has not
been verified by the data collected to date. Although, an
observation of the existing data leads EPA to believe that
migration of contaminants from the Site is slow, the actual
containment of the plume cannot be verified with the existing
data. The selected remedy requires the collection of further
data to support that bioremediation is occuring at such a rate as
to contain any further migration of the contaminants. Until that
information is available, EPA believes that assertions as to the
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stability of the plume cannot be substantiated.
13.2.13 EFA's Response to Comments from Kennecott Utah Copper
Corporation, Frederick D. Fox, Director Environmental Affairs.
30) Comment
Kennecott is aware of comments being submitted by the ESRC on
EPA's Proposed Plan for the Site and fully endorses these
comments and requests that the record recognize Kennecott's
belief that Alternative 10 is a more effective cleanup remedy
than the EPA preferred Alternative 7 for the reasons outlined
below and in the ESRC's comments.
Kennecott also believes that the EPA preferred Alternative 7 is
arbitrary and capricious and does not consider all relevant facts
and findings presented in the Remedial Investigation and
Feasibility Study for the Site.
Kennecott was named as a PRP because we, like hundreds of other
companies, sent used oil to Petrochem/Ekotek Recycling Inc. in
the belief that it would be responsibly recycled. Improper and
illegal practices by Ekotek resulted in closing the facility and
bankruptcy proceedings, leaving Kennecott and others responsible
for cleaning up the Site under CERCLA. To date, Kennecott has
spent several millions of dollars as part of the ESRC to
eliminate any immediate and substantial risks presented by the
Site to public health and the environment and to continue with
the remedial investigation and feasibility study. In total, the
ESRC has spent over $17,000,000 on cleanup activities and studies
for this seven (7) acre site to ensure the public and the
environment are protected.
EPA's preferred Alternative 7 includes on-site thermal treatment
of soils, off-site treatment and disposal.of oil and debris, and
a pump and treat alternative for the ground water, all at an
estimated cost of $16,600,000.
Kennecott's preferred Alternative 10 includes off-site disposal
of soils, oil, and debris and consolidation and encapsulation of
soils that already meet EPA's acceptable risk criteria by placing
an appropriate depth of clean soil at the ground surface and at
the ground water table. Kennecott's preferred alternative
addresses continued monitoring to ensure EPA's cleanup criteria
are met. The estimated cost the Kennecott's preferred
alternative is $6,100,000, substantially less than the EPA's
selected alternative and all other alternatives that meet the
cleanup criteria.
If the EPA includes pertinent information in the ESRC's Aquifer
Characterization Report when comparing the site-wide remedial
alternatives, then it clearly should discount pump and treat as a
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technically viable groundwater remedy. In addition., if EPA
considers cost effectiveness in the cleanup evaluation criteria
(which it should), it should also discount thermal desorption as
an economically viable soils remedy. Both soils alternatives,
thermal desorption and clean soil encapsulation, achieve a risk-
based cleanup goal of 1 X 10"6 and will allow for similar future
uses of the Site.
In summary, for the reasons stated above and those articulated in
the comments submitted by the ESRC, Kennecott requests that EPA
change its selected alternative and choose Alternative 10 as
being the most cost effective cleanup remedy for the Site that is
equally protective of public health and the environment.
Response
See response to comment 4.
31) Comment
In addition, Kennecott attended the EPA sponsored July 26, 1995
public meeting and the August 28-29, 1995 workshop on ground
water, as well as other non EPA sponsored meetings on Ekotek, and
can state with certainty that the general public has not been
provided with enough opportunities to fully understand the
complexities associated with Site conditions to adequately
comment on EPA's Proposed Plan.
Therefore, Kennecott believes it is in the best interest of the
public for EPA to extend the public comment period on the
Proposed Plan and additional 30 days and to conduct one more
public hearing to address the conclusions reached by EPA and ESRC
at the August 28-29, 1995 workshops.
Response
EPA extended the comment period through October 23, 1995.
13.2.14 EPA's Response to Comments from Sierra Club Utah
Chapter, Ivan Weber, Utah Chapter Sierra Club
32) Comment
The contamination of the site under the fraudulent,
environmentally contemptuous management of the site's owners was
a sustained, heinous crime that has, to date, gone essentially
unpunished. We applaud the determination of EPA and the State
Department of Environmental Quality to remediate the site
responsibly. It is unfortunate, however, that the initiation of
substantial action has taken so long. While some of the reasons
for this inaction are obvious (court proceedings, CERCLA
proceedings, PRP identification and settlement negotiations,
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technical analyses, review process mechanics, etc.), there really
should have been an aggressive triage, followed by implementation
of those source-control steps, motivated by the relative infancy
of the problem. It would seem that groundwater problems,
especially, might have been nipped more nearly in the bud, so to
speak.
Response
The Petrochem/Ekotek Site was addressed by EPA's emergency
response team when identified by the State of Utah as an imminent
and substantial threat in 1989. The bulk of the waste,
containers, tanks, pipes, sludges, process equipment, and most of
the on-site facilities were removed from the Petrochem/Ekotek
Site through the activities and under the auspices of the
emergency response team from 1989-1992.
EPA is committed to cleaning up Superfund sites faster. The
Superfund Accelerated Cleanup Model (SACM) was a program
initiated by EPA in 1992 to address the seemingly slow pace at
which EPA has historically cleaned up sites. To date, EPA has
accomplished the cleanup of over 3,000 sites nationwide. EPA
also has an emergency response team that addresses imminent and
substantial threats of release when identified.
33) Comment
Without knowing a great deal more about the dynamics of the plume
of groundwater contamination, and especially about the
interaction of the non-aqueous phase liquids with groundwater, we
find it difficult to get an idea of the rate of spread of
contaminants. It is a pretty good bet, though, that they are
spreading, considering that they weren't there before Ekotek, but
now they are where they are. This mess didn't happen in an
instant. They have varying dynamics and vectors, and they need
to be stopped as quickly as possible.
Please consider the voice of the Sierra Club to be added to the
chorus that calls for action — but not action that causes more
problems.
Response
The selected remedy, alternative 10, relies upon
bioremediation/attenuation to address the contaminants with the
ground water plume. It is expected that the
bioremediation/attenuation is occurring at a rate that would
prevent further migration of these contaminants. If during the
remedial action, EPA finds that bioremediation/attenuation is not
occurring as anticipated, and further migration of the
contaminants is demonstrated, the containment remedy may be
implemented. The conceptual design of the containment remedy is
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to capture the contaminants at the compliance boundary and thus
prevent further migration of the contaminants.
34) Comment
Debris: Assuming that separation from oily soils is feasible,
debris obviously should be removed to the nearest disposal site,
whether that consists of encapsulation on-site or a qualified
landfill off-site.
Response
The selected remedy, alternative 10, requires that the LNAPL-
saturated soils and debris within the debris area be disposed
off-site at an appropriate disposal facility.
35) Comment
Soils: The summary of remedial alternatives indicates the nine
options (Alternative one is not an option), and in most of them
there is some considerable quantity of contaminated soils that
are removed and either treated on-site (we will return to this)
or shipped to a qualified disposal site. Having advocated
responsive, expedited action, we realize that this choice is not
an easy one. Costs are, of course, a major consideration, along
with effectiveness of the action. We have a great deal of
concern about thermal destruction of this kind of potpourri of
oily compounds, including dioxins, polycyclic aromatic
hydrocarbons (PAH's), polychlorinated biphenyls (PCB's), and
dense non-aqueous phase liquids (NAPL's), especially in proximity
with dense residential communities and important wetland-related
and montane ecosystems.
We are not at all convinced that this process won't produce other
chlorinated hydrocarbons that stand a considerable chance of
being as dangerous as the initial constituents of the oily soils.
Off-site encapsulation or thermal destruction is possibly more
appealing, if the site is carefully chosen, but even that is not
very satisfying. Off-site bioremediation seems to offer some
potential for avoidance of the kinds of problems presented by
thermal processes, even if it does require a lot more time, and
possibly greater cost. Energy consumption in transportation, and
the pollution it produces, must also be integrated into this
analysis.
With this qualification, we agree that Alternative 7 seems to be
best for dealing with soils expeditiously.
Response
EPA believes that alternative 10, the selected remedy, which
includes off-site disposal of all soils that exceed the soil hot
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spot criteria and encapsulation of the remaining soils under a 42
inch clean soil cap offers the best balance of nine criteria.
36) Comment
Oily Liquids; The alternatives vary in the proportion of oily
liquids that are proposed to be removed, but Alternative 7 is one
that would seek to remove 100%. We believe that this approach is
imperative. Thermal destruction, however, is less comforting,
wherever it occurs. We are aware that much, much more
significant quantities are being "burned" both in incinerators
and in manufacturing operations (as fuel) on our doorstep. This
does not lead us to suspend our educated guesses that some of the
nation's largest sources of dioxins and furans are immediately
upwind of Salt Lake City. That also does not excuse adding to
the quantity by incineration of the Ekotek oily liquids.
Bioremediation off-site should be fully considered as an
alternative, before diving into thermal destruction for
ecological risk reasons, if not for human toxicological ones —
even if that means that the 10,000 gallons of recoverable oily
liquids have to be put into a monitored tank someplace while we
think about it. The demise of songbirds, amphibians, and
countless other creatures, as well as the incidence of breast and
other carcinogens, should impose a de facto moratorium on
incineration of these kinds of compounds, as well as on their use
as energy or as carbon sources (as in magnesium extraction),
until we know what we can do and how to do it safely. As it is,
we continue to do things, predicated on what we do not know about
their effects.
A modified Alternative 7, therefore, to seriously explore
alternatives to thermal destruction, would be preferable to the
Sierra Club.
Response
The selected remedy, alternative 10, addresses the LNAPL in the
same manner as alternative 7. To address the concerns of the
public, EPA is continuing to work toward lowering the emission
standards for Hazardous Waste Combustion Facilities. The latest
effort, summarized in the Environmental Fact Sheet titled Revised
Technical Standards Proposed for Hazardous Waste Combustion
Facilities dated March 1996, proposes to reduce the emission
standards for hazardous waste burning incinerators, cement kilns,
and lightweight aggregate kilns. The proposed standards would
achieve significant reductions in some of the top priority
pollutants for EPA - dioxins and furans by 98 percent, mercury by
80 percent, cadmium and lead by 95 percent, and four other toxic
metals by 87 percent. In developing this rule, EPA met with
affected stakeholders to elicit their feedback on a wide range of
regulatory approaches. These groups include owners and operators
of affected facilities, environmental groups, citizens' groups,
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nonprofit health organizations, and states. EPA believes that
improving a viable and proven technology is in the best interest
of the protecting human health and the environment.
37) Comment
Groundwater: Setting aside the possibility of the presence of
arsenic, extraction seems to be the best choice. Treatment of
the extracted groundwater at a publicly-owned treatment works
(POTW) depends utterly on the specific contaminants, a profile of
which is not in-hand as of these comments. Aggressive pumping
(and we question that the 60 to 90 gpm proposed in Alternative 7
is aggressive enough, and whether one extraction well is enough,
either) seem desirable, considering the general north-westward
flow that we understand groundwater to exhibit in this area. The
possible effects on wetlands to the west of the Salt Lake
International Airport are of primary concern, especially for the
relatively shallow zones, which tend to emerge and blend with
waters of these ecologically critical, transitional zones around
the Great Salt Lake.
We also question the ability of POTW1s to deal, dependably, with
some of the organic contaminants that Alternative 7 may send to
them, especially near-trace amounts of dioxins, PAH's, vinyl
chloride, and other toxic constituents of the water on the site.
Air sparging and limited thermal destruction may make some sense,
but there is extreme caution appropriate, for the same reasons
that were discussed earlier with respect to these contaminants in
soils. The accumulation of organic chlorides due to inadequate
destruction through incineration in many forms, and synthesis of
these deadly compounds in many technologies, may be the end not
only of many of us, but also of a tragic proportion of wildlife.
If and only if the catalog of contaminants, and their variation
across the site, allow classification of site waters in such a
way that the quantities of actual organics-polluted water can be
reduced significantly, then it would seem that some of the
"enhanced pump-and-treat technologies" outlined in the recent
National Research Council document, Alternatives for Ground Water
Cleanup, and in other recent scientific sources, could be
considered for application to this site. This might necessitate
more than one well, or a "nested" well, screened at several
depths.
If, again, this approach resulted in classification of some of
the water to assure that a POTW can deal with a significant
portion of it, then so be it. Maybe the proximity of a golf
course to the near west could allow use of some as irrigation
"graywater", at significantly lower costs.
Avoidance of thermal destruction to the greatest extent possible,
and avoidance of burdening a POTW with organic contaminants that
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it cannot handle, or even analyze adequately, are the crux of our
concerns about remedial technologies.
Response
The selected remedy, alternative 10, relies upon
bioremediation/attenuation to address the contaminants within the
ground water plume. The public comment received regarding the
technical difficulties of capturing the contaminants directly
beneath the Site, the high hydraulic conductivity beneath the
Site, the potential for upconing of the geothermal waters beneath
the Site, and the relatively low levels of contamination beneath
the Site contributed to EPA's decision to rely upon
bioremediation/attenuation to address the ground water
contamination. However, EPA will consider a containment
contingency that includes a pump and treat system at the
compliance boundary if further migration of the contamination
within the ground water occurs. With respect to the
effectiveness of the POTW, the POTW will only accept waste water
that it is capable of achieving treatment levels as specified by
its permit. Coordination with representatives of the POTW by the
PRPs performing the feasibility study has shown that the POTW is
capable of accepting Petrochem's waste water with two caveats.
Pretreatment of the arsenic may be required and the volume must
be less than 100 gpm.
13.2.15 EPA's Response to Comments from Monroe, Incorporated,
submitted by the office of Parry Murray Ward & Moxley, Kevin R.
Murray
38) Comment
1. Monroe has no Position on the Proposed Plan Remedy Selection.
Monroe has no position or comments on the.Proposed Plan and the
remedy selected by the Agency. Rather its comments are limited
to the Aquifer Characterization Report dated June 19, 1995 by
Rust Environment and Infrastructure, Inc. (hereinafter referred
to as the "Aquifer Characterization Report").
Response
Comment is noted.
3 9) Comment
2. The Aquifer Characterization Report is Based on Insufficient
and Unreliable Data. The Aquifer Characterization Report
indicates that an upgradient source of TCA contamination exists,
contends that other solvent contaminants are degradation products
of TCA, and concludes that those solvents in the ground water at
the Ekotek site originated from this off-site source. The report
does not name the reported source but strongly suggests that the
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Monroe facility on Beck Street is located where the source is
suspected. Our review indicates that these conclusions were
reached based upon two samples collected in March and May 1995
from a well immediately west of the Monroe facility. The samples
contained TCA in a concentration higher than typically found
elsewhere in the study area. However, similar concentrations
were also found north and west of Ekotek site. It is Monroe's
opinion and the opinion of Monroe's consultant that insufficient
documentation is presented in the Aquifer Characterization Report
to conclude that the Monroe property is the source of the
contaminants. This opinion is based on the following
observations from the data and methodology of the Aquifer
Characterization Report:
1. The Aquifer Characterization Report (the "report")
states definitively that an upgradient source of TCA
exists (see pages vi, 7-1). This statement and
conclusion are not supported by either the historical
Ekotek site information or chemical ground water sample
results. The conclusion appears to have been reached
late in the analysis and was based upon the results of
two ground water samples collected from Monitoring Well
P-12 during March and May 1995.
2. The occurrence of TCA is not objectively depicted
in the report. TCA has been detected on the east, west
and north of the Ekotek site with concentrations of the
same order of magnitude found on each of these sides.
The Aquifer Characterization Report emphasizes the
occurrences of TCA east of the Ekotek site. Figures 5-
1 through 5-7 cannot be considered reliable since the
contamination contours depicted extend beyond the known
data. In some instances the contours are drawn based
upon a single sampling point. These drawings appear to
have been drafted to fit some preconceived pattern of
contamination rather than to present a statistically
valid presentation of the data. The graphical
presentation also fails to show one of the higher
detected concentrations of TCA (124 ppb) found in
ground water from Monitoring Well P-13 located 1950
feet west of the Ekotek site. No statistical
evaluation of the data has been conducted. It is
unreasonable to base remedial action decisions on high
or low anomalous values.
3. The Aquifer Characterization Report indicates that
a gravel aquifer exists north of the Ekotek site and
because of a higher permeability than the surrounding
soil, it transports contaminants from east to west
(pages 4-4, 7-1). The aquifer hydraulic conductivity
testing (Table 2.2) and the variable nature of the
sediments as presented in the boring logs (Appendix A)
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suggest that the gravel zone depicted in Figure 4.4 is
an oversimplification. Of the four aquifer tests
conducted in the area, two showed permeabilities
greater than 200 ft/day and two showed permeabilities
less than 25 ft/day. The lower numbers are more
consistent with the majority of slug tests conducted on
wells completed in the shallow aquifer. Both of the
higher permeability values were obtained from deeper
wells. Similarly high values would likely be obtained
from testing deeper strata at most of the monitoring
well locations. No permeability test was reported for
Monitoring Well P-12. The significance of this is that
no permeability test has been conducted in the area of
the suspected upgradient source. The suggestion of a
higher permeability gravel conduit also conflicts with
another conclusion of the Aquifer Characterization
Report that states "the fine-grained sediments in Unit
2 acts as a dam to westward flow away from Unit 1"
(page 4-9).
4. Well logs indicate that the majority of PID hits
were encountered in the shallow sediments indicating
that the contaminants were initially in the shallow
soil and were not migrating at depth onto the Ekotek
site. This contradicts the conclusion that
contaminants migrated to the site from an upgradient
source.
5. Ground water elevations used to determine the
ground water gradient were corrected for temperature
based upon the expansion coefficient of water in a
Cylinder. This methodology may be flawed since a
ground water monitoring well is not a closed Cylinder
but a slotted screen that allows water to equilibrate
to the surrounding materials. Therefore, the Rust
ground water gradient maps may be unreliable and the
conclusions based on them invalid.
6. The comparison of the .interaction between the
thermal water and the ground water with that of sea
water and fresh water (page 4-3) may be unrealistic
since the difference in density between sea water and
fresh water is much larger than the difference in
density between the ground water and thermal water at
the Ekotek site. Again, this may call into question
the validity of the basic assumptions of the Aquifer
Characterization Report.
7. The Aquifer Characterization Report states that no
consistent ground water gradient (page 4-11) is present
at the Ekotek site and that a "back and forth movement
of the site ground water" (page 5-5) may occur. If
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this is the case, TCA and other contaminants may be
spreading both up and down gradient from the Ekotek
site and the assertion of an upgradient source may be
invalid.
8. The Aquifer Characterization Report failed to
consider the relative mobility of TCA, DCA, DCE, and
vinyl chloride. Because vinyl chloride is the least
mobile of the contaminants, it would be the least
affected by the back and forth movement of ground water
and would remain closest to the source. Vinyl chloride
has been found in wells CH-3, CH-4, MW-6, MW-7, CH-9,
CH-10, W-10, P5, and P6, all on west of the Ekotek site
and not in P-12, the well near the suspected upgradient
source. This pattern seems to indicate that the source
of the contaminants is the Ekotek site with a westward
movement of the plume downgradient from the Ekotek
site. TCA is more mobile than vinyl chloride and DCA
and DCE are the most mobile of these compounds.
Therefore, it is understandable that more monitoring
wells were found to contain DCA and DCE than the other
solvents and that vinyl chloride was found in the
fewest wells.
9. TCA, DCE, and DCA are heavier-than-water compounds.
Therefore, their movement would not necessarily
correspond to the direction of ground water flow.
Their movement, in significant concentrations, would
more likely be controlled by subsurface sediment
geometry and permeability and the occurrence of these
compounds upgradient of the Ekotek site is not
.definitive proof for an upgradient source. Vinyl
chloride is lighter-than-water and would be the most
likely contaminant to move in the direction of ground
water flow. The location of wells found to contain
vinyl chloride indeed suggests the Ekotek site as the
source with a plume migrating toward the west.
10. To suggest that TCA did not come from the Ekotek
site (page 5-1) because historic records did not
indicate storage or use of the compound is meaningless.
The fact that the Ekotek site did not properly
document, store, or handle its wastes is the basis for
the present action.
11. Further data in the area of P-13 may be required
to evaluate the theory that Aquifer Units 1, 2, and 3
converge immediately west of the Ekotek site (Section
4). The potentiometric surface value used in the
report is taken from a well near the Jordan River,
approximately 3/4 mile from the Ekotek site. This is
significant in evaluating the potential for contaminant
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flow to the west.
12. Errors in Rust's presentation of data call into
question the data analysis, quality control of the
work, and therefore the validity of the conclusions.
The laboratory data from the "P" wells is not tabulated
correctly in Appendix D. For example, the laboratory
data sheets for samples collected from Monitoring Well
P-12 indicate a sample was collected on March 17, 1995.
In Appendix D, the tabulated data, the date of this
event is listed as February 1995. Only a small portion
of the data sheets were available for review. Also, in
Appendix D "NA" is shown in many boxes, presumably
meaning "not analyzed". Other boxes are blank,
particularly for arsenic. Were these not analyzed or
not reported? Table 2.5C does not show a ground water
elevation for monitoring well MW-1. However, an
elevation is presented in Figure 4.8.
Response
See response to comment 8. EPA currently believes, based upon
the sampling episodes to date, that the source of the TCA shown
in P-12 is off-site. In addition, EPA believes that the data
presented in the Aquifer Characterization Report is insufficient
to draw conclusions regarding the source of the off-site TCA, the
migration pathway of TCA, the extent of the TCA, and its
potential affect upon the remediation of the Petrochem/Ekotek
Site. A monitoring program will be designed as part of the
selected remedy, alternative 10, to identify the impacts of this
plume upon the remediation of the on-site contaminated ground
water at the Petrochem/Ekotek site.
13.2.16 EPA's Response to Comments from the Environmental Health
Division, submitted by Terry D. Sadler, Director of the Division
of Environmental Health
40) Comment
The Salt Lake City-County Health Department Division of
Environmental Health (The Department) supports the USEPA's
preferred alternative 7 in part. We concur with the removal of
22,000 cubic yards of contaminated surface soils and blending
them with soils saturated with oily liquids (10,000 cubic yards
from the debris area and 3,000 cubic yards from the oil area),
provided the contaminants in these soils do not require disposal
in a TSLA landfill. This action includes the removal and
stockpiling of 17,000 cubic yards of clean soils from above the
plume of oily liquids to remove 100% of the oily liquids for off-
site thermal destruction.
We also concur with thermally treating the blended soils on-site
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wherein contaminants are driven off and then destroyed. The
clean soils from the stockpile area and the cleaned soils from
thermal treatment will be used as backfill on the site.
Additionally, 4,000 cubic yards of buried debris will be removed
for off-site disposal in a TSLA permitted landfill.
Any alternative that does not remediate the entire volume of
contaminated soils, all buried debris and all light, non aqueous
phase liquids (LNAPL or "oily liquids") is not acceptable to The
Department.
Additional information supplied by the Site Remediation Committee
on the complexities of the ground water regime beneath the site
puts into question the advisability to include the pump and treat
portion of the preferred alternative into the Record of Decision
(ROD) at this time. However, evidence must be obtained that
demonstrates that intrinsic remediation of the groundwater is
indeed occurring and that degradation of the vinyl-chloride to a
less toxic end product will occur.
Response
The selection of a remedy by EPA must meet the threshold criteria
for protection of human health and the environment, and
attainment of ARARs. Containment, treatment, and remedies using
a combination of containment and treatment that meet the
threshold criteria are suitable for selection. Thus complete
remediation of the entire volume (by treatment) of waste is not
necessary to achieve the threshold criteria. With respect to the
selection of alternative 10 as the selected remedy, see response
to comment 4. Alternative 10 addresses the commenter's concerns
regarding ground water.
41) Comment
Not addressed in the current preferred alternative or in any
alternative thus proposed is the contaminated clay wastes
deposited by Bonus Oil on the property at 2300 North listed as
the Radio Station Site and Brinkerhoff property. Somehow in the
re-assignment of project managers these contaminants were
overlooked as being a part of the Petrochem/Ekotek contribution
to the degradation of the environment. The Department contends
that the contribution of Bonus Oil to both sites cannot be
ignored and that clean-up must occur at this time and be included
as a significant part of the final ROD.
Response
EPA conducted a Preliminary Assessment and Site Investigation
(PA/SI) and sampled in January 1994 the properties known as
"Radio Station Properties" and owned by Sun Broadcasting, Mssrs.
Flandro and Reaveley, and Mrs. Brinkerhoff. From the
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investigations, EPA concluded that these properties were not
candidates for further action by EPA. The reasons are clearly
specified in a letter dated April 21, 1994 from EPA to Allan W.
Flandro and Clyde W.. Reaveley, Karen Silver, Mrs. Keith
Brinkerhoff, and Stuart E. Hunt. This letter is available in
EPA's records center as part of the Site records.
13.2.17 EPA's Response to Comments from the Ekotek Site
Remediation Committee (ESRC), submitted by the office of Holland
& Hart, Denise W. Kennedy, Common Counsel for the ESRC
13.2.17.1 Letter dated July 12, 1995
42) Comment
Needless to say, the Committee is dismayed at the Preferred
Alternative presented in the Proposed Plan. While we understood
that EPA was not in a position to determine whether
an off-site source was responsible for the ground water
contamination at the Ekotek Site, we were shocked at EPA's
apparent disregard of the very strong evidence in the Aquifer
Characterization Report that a pump and treat ground water remedy
would not only be more expensive than the more effective
intrinsic bioremediation, but would be infeasible. The
hydrogeology study resulting in the Aquifer Characterization
Report was no small undertaking by the Committee (this effort
cost in excess of $100,000) and resulted in significant new
information concerning the ground water in the area - - including
further evidence that pump and treat would not be feasible. This
work was undertaken by the Committee at EPA's request in its
comments on the Feasibility Study and we had expected
that EPA would consider it and the prior ground water information
submitted by the Committee in the Proposed Plan.
Response
A technical review of the Aquifer Characterization Report and its
subsequent incorporation into the Proposed Plan would have
delayed the release of the Proposed Plan by six to ten
weeks. The Proposed Plan was nearly completed when the Aquifer
Characterization Report was submitted on June 19, 1995. EPA made
the decision to release the Proposed Plan and invite public
comment on the findings of the Aquifer Characterization Report in
conjunction with public comments regarding the response actions
for the site. This action does not constitute a disregard for
the information in the Aquifer Characterization Report, but
rather a commitment on behalf of the Agency to further the
progress of this site to the implementation of a response action.
43) Comment
The continued reference to arsenic ground water contamination in
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the Proposed Plan came as a surprise to us given comments made by
EPA that it did not consider arsenic a problem. In fact, the
Committee has submitted significant information and data
evidencing that the arsenic levels measured at the Ekotek Site
are well within background arsenic concentrations. This
is further supported by information in the Aquifer
Characterization Report evidencing the significant geothermal
water presence. The combination of high naturally occurring
arsenic in the rock and soils and geothermal water which is known
to leach the arsenic from the rock/soils, results in elevated
levels of naturally-occurring arsenic in the ground water. In
submitting recent arsenic data to EPA demonstrating that off-site
upgradient area wells exhibited arsenic concentrations many times
higher than the Ekotek Site wells, we were told that EPA did not
think arsenic was a concern. This, of course, flies in the face
of the Proposed Plan which would lead the public or others who
are not privy to all of the Site data to believe that arsenic is
a significant concern at the Site.
Response
The reference to arsenic in the ground water should not be a
surprise to the Committee as all formal communications (i.e.,
written correspondence) between EPA and ESRC have detailed
the debate as to whether the arsenic is natural or anthropogenic.
EPA required ESRC to describe and price a contingency in the FS
that would contain and treat arsenic above the MCL. The final FS
submitted by ESRC on January 20, 1995 contains the arsenic
contingency. As described above, the Aquifer Characterization
Report was not reviewed prior to the release of the Proposed
Plan. Data submitted as part of the Aquifer Characterization
Report show that samples taken from the off-site piezometers
upgradient of the site (e.g., P-ll and P-12) contain an order of
magnitude below the MCL for arsenic. A sample from an on-site
well (e.g., MW6) showed concentrations of arsenic above the MCL.
And wells potentially influenced by the site (e.g., W-7, P-6a,
W-10) have concentrations of arsenic above the MCL. The data
from the Aquifer Characterization Report does not allow
conclusions to be drawn as to whether the arsenic concentrations
are natural or anthropogenic. There is evidence within the
104(e) data base that suggests that PRPs sent waste containing
arsenic to the site. However, since there is insufficient data
to conclude whether the anthropogenic contribution of arsenic is
statistically significant, a contingency has been included in the
selected remedy that will address the migration of arsenic from
the site and/or the treatment of arsenic that exceeds the MCL if
the concentrations of arsenic are shown to be statistically
significant and site-related, i.e., not attributable to
background.
It should be noted, that the public has access to all the data in
EPA's possession via our Superfund Records Center.
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44) Comment
The Committee's preferred alternative is Alternative 10. Figure
3 in the Proposed Plan supports the Committee's view that
Alternative 10 is the most cost-effective remedy to achieve all
NCP requirements. We are surprised in this day and age of
emphasis on cost-effective remedies under CERCLA (or at least
that has been the gist of statements made by Administrator
Browner to Congress) that EPA would select one of the most
expensive options available -- one that costs 170% more than an
equally effective remedy.
Response
See response to comment 4.
45) Comment
While we recognize the difficulties of summarizing the risk
assessment results in layman terms, we are concerned with the
erroneous and potentially inflammatory language contained
in the Summary sections of the Proposed Plan.
Response
With respect to the language in the Summary of Site Risks of the
Proposed Plan, this language is neither erroneous nor potentially
inflammatory as it explains the actual results of the Baseline
Risk Assessment for the Site.
13.2.17.2 Letter dated September 5, 1995 from the Ekotek Site
Remediation Committee (ESRC), submitted by the office of Holland
& Hart, Denise W. Kennedy, Common Counsel for the ESRC
46) Comment
As requested at the Technical Meeting for the Petrochem/Ekotek
Site in Salt Lake on Monday and Tuesday of this week (August
28/29), I [Robert C. Berry] am providing a summary of the
equations and calculations used to estimate the maximum pumping
rate sustainable before the geothermal water enters the well
screen for cleanup of vinyl chloride from the fresh water aquifer
at the Site. I have used both a distance of 40 feet between the
well screen and the top of the geothermal water (geothermal water
at 60 feet and the well screen 20 feet below the water table in
the fresh water aquifer) and a distance of 20 feet between the
well screen and the top of the geothermal water (geothermal water
at 40 feet and the well screen at 20 feet below the water table
in the fresh water aquifer). At the meeting, I presented the
case for a 40-foot separation between the well screen and the top
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of the geothermal water because this allows for the maximum
pumping rate. The attached table presents the calculations for
both the 40-foot and the 20-foot separation cases.
As the attached table shows for the case of a 40-foot separation
between the bottom of the well screen and the top of the
geothermal water, the most probable range of pumping rates that
will prevent upconing is 20-40 gpm. This was presented at the
meeting. The maximum rate would be 46.9 gpm. Therefore, the
conclusion was presented at the meeting that with a well screen
20 feet below the fresh water surface and 40 feet above the
geothermal water contact (case with geothermal water at 60 feet
and well screen 20 feet below water table for fresh water with
vinyl chloride), the maximum pumping rate to avoid geothermal
water in the pumping well would be in the range of 20-40 gpm.
You would still have upconing of the geothermal water, but the
dome of upconed geothermal water would not reach the well screen
of the pumping well. The top of the dome would be just below the
well screen.
Response
EPA believes that calculations provided assumes simple geology
(single layer model) with an average conductivity of 100 to 300
feet/day and allows consideration of only a single well.
However, the geology at Petrochem is quite complex and the use of
a single layer model may be used for screening purposes, but
should not be depended upon to represent the site adequately or
to assist in the design and location of a proposed remediation
well(s). It may be more appropriate to look at the design of
several wells with shorter screens which can not be accomplished
using the Schmorak and Mercado approach. For example, Figure 4-6
of the Aquifer Characterization Report illustrates the geologic
complexities at Petrochem and shows that there are several
layers. If a well is installed in Unit 3 (predominantly sand),
a single layer model is not adequate since gravel underlies the
sand, and because there is a upward component of flow in Unit 3
not due to upwelling of geothermal waters. On the other hand, if
a remediation well is installed in Unit 2, it would intersect
silts and clays with underlying sands with upward vertical flow.
Such a system cannot be modeled using a single layer approach.
The calculations appear to have incorrectly used effective
porosity instead of the dimensionless ratio of the critical
interface rise (Zcr) to the saline interface/well screen distance
(d) or (Zcr/d). The referenced literature discusses appropriate
values for this empirical ratio ranging from approximately 0.25
to 0.75. Use of these values will increase the upper limit of
the range of calculated maximum pumping rates.
Hydraulic conductivity affects the potential pumping rate from an
extraction well and well spacing required for plume capture. The
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most appropriate system design depends on many factors including
extent of contamination, hydraulic conductivity of aquifer
materials, hydraulic gradient, and concerns regarding saline
water intrusion. In general, more wells would be required for
ground-water capture in low conductivity materials than in higher
conductivity materials due to the limited influence of each well.
If conditions permit, installation of a system in the higher
conductivity areas may result in superior system performance.
Thus, although the Schomrak and Mercado is an appropriate
approach for a single layer geology or to use for screening
purposes, the conclusions from this approach do not eliminate a
pump and treat system as a viable alternative for the
Petrochem/Ekotek Site. The selected remedy, alternative 10,
relies upon bioremediation/attenuation to address the
contamination in the ground water beneath the Site. However, if
it is demonstrated that bioremediation/attenuation is not
containing the contaminants within the current extent of
contamination, then EPA shall consider the use of the containment
contingency which relies upon a pump and treat system.
13.2.17.3 Letter dated September 8, 1995 from the Ekotek Site
Remediation Committee (ESRC), submitted by the office of Holland
& Hart, Denise W. Kennedy, Common Counsel for the ESRC
47) Comment
Summary of Comments. As detailed more fully below, the Ekotek
Site Remediation Committee (ESRC) believes that
the cleanup alternative selected by the EPA, Alternative 7, is an
ineffective, excessively costly and, in fact, impossible
alternative to fully implement. The ESRC believes that
Alternative 10, which has been characterized by the EPA as
meeting all of the EPA's National Contingency Plan cleanup goals
for protecting public health and safety, is the best
choice for the Site.
The ESRC has demonstrated in several different ways that pumping
and treating ground water at the Petrochem/Ekotek Site ("Site")
will do nothing to improve ground water quality and further
reduce public exposure risks. However, it could damage the
aquifer in such a manner that any other ground water remediation
alternative, including intrinsic bioremediation, would no longer
be effective. Additionally, it was concluded by all parties at
the August 28-29, 1995 workshop that off-site contamination would
continue to encroach upon the Site, under a pump and treat
scenario, thereby masking any cleanup efforts until such
contamination is remediated by the responsible party.
Response
EPA maintains that a properly designed pump and treat system is a
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viable alternative for the remediation of the ground water. See
response to comment 46.
EPA would like to expound upon the stated conclusion of the
August 28-29, 1995 workshop. The parties conditioned that a pump
and treat remediation of the groundwater would not succeed on-
site, if the TCA off-site was shown to be a source of some of the
on-site vinyl chloride. However, no conclusions can be drawn
from the existing data that the TCA off-site is a source of the
on-site vinyl chloride. Also, see the response to comment 39.
48) Comment
The ESRC's Aquifer Characterization Report (RUST E&I, 1995)
clearly evidences that pump and treat (EPA's selected ground
water remedy) will not achieve cleanup goals and will,
conversely, interfere with natural bioremediation of the low
level vinyl chloride contamination. Based on the site-specific
data gathered to date, it is this latter alternative
(bioremediation) that the ESRC believes has the most promise for
effecting cleanup of the ground water. In fact, at a recent
workshop meeting with many of the stakeholders at the
Ekotek Site, conclusions relevant to ground water remediation
were agreed to by all participants. [Text is provided that
outlines the conclusions].
Response
With respect to the viability of a pump and treat system, see the
response to comment 46. With respect to the selection of the
remedy, see response to comment 4.
49) Comment
The EPA's selected Alternative 7 includes thermal desorption for
treatment of soils. The process of thermal desorption carries
with it a much higher short-term risk to the public with
no significant difference in the risk-based cleanup goal, when
compared to the soil containment plan in Alternative 10. Both
soil remediation alternatives achieve the risk-based
cleanup goal of 1 X 10-6 (1 in one million), and will allow
redevelopment of the property; the ESRC's alternative is not only
more cost-effective, it will permit redevelopment sooner
with less environmental impact and disruptions to the
neighborhood than EPA's alternative.
Response
With respect to the comparison of the balancing criteria among
the alternatives, see the response to comment 4.
EPA supports the redevelopment of the Petrochem/Ekotek Site that
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is compatiable with and does not interfere or reduce the
protectiveness of the selected remedy. EPA believes that
redevelopment can occur with the selection of alternative 10 as
the selected remedy and has received recent interest in the
property from three different parties. EPA encourages all
interested parties to promote and facilitate, within their means,
the redevelopment of the property.
50) Comment
Risk Assessment. The summary of Site Risks in the Proposed Plan
omits critical information necessary to an understanding of the
potential Site risks. EPA's Proposed Plan at 5. The
conservatism built into Superfund risk assessments is legendary.
These risk assessments result in numbers that grossly overstate
any true risk, or risk reasonably likely to occur. For example,
EPA uses a number of policy-based toxicity and exposure
assumptions in its risk assessments that are then combined in the
Site risk assessment. Toxicity assessment assumptions include
the following:
• A substance that has been judged to cause cancer in
animals is assumed to cause cancer in humans.
• In laboratory animal experiments, benign
(noncancerous) tumors are assumed to be malignant (cancerous)
tumors.
• In laboratory animal experiments, cancer risk observed
from exposures thousands of times greater than potential human
exposures are assumed to be predictive of human cancer.
• Where laboratory animal experiments have used
different species (e.g., rats vs. mice), humans are assumed to be
as susceptible to cancer as the species most susceptible to
cancer.
• It is assumed that there is no safe exposure to any
carcinogen.
Exposure assessment assumptions for ground water include the
following:
• Site ground water is assumed to be potable.
• Substance concentrations in ground water are assumed
to be calculated upper-bound values or the highest measured site
values.
• Substance concentrations in ground water are assumed
to remain constant throughout the duration of exposure.
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The result of combining the many very conservative (even
unrealistic) assumptions is that Site risks may be overestimated
by a factor of 100 or 1,000 or more. See "Science and
Judgement in Risk Assessment" National Research Council/National
Academy of Science, 1994; Milloy, "Science-based Risk Assessment:
A Piece of the Superfund Puzzle" (National Environmental Policy
Institute, 1995) (hereafter cited as "NEPI, 1995"); "Exaggerating
Risk: How EPA's Risk Assessments Distort the Facts at Superfund
Sites Throughout the United States" Hazardous Waste Cleanup
Project, 1993; "A Historical Perspective on Risk Assessment in
the Federal Government" Harvard School of Public Health Center
for Risk Analysis, 1994.
Response
EPA believes that the Summary of Site Risks within the Proposed
Plan is in accordance with EPA guidance (i.e., Guidance on
Preparing Superfund Decision Documents, EPA/540/G-89/007, July
1989) and adequately describes the conclusions of the Baseline
Risk Assessment. With respect to the commenter's assertion
regarding the conservatism of risk assessments, EPA dedicates a
portion of the Baseline Risk Assessment and a chapter of the ROD
to the
discussion of how risk is assessed and the associated
uncertainties. EPA clearly states when assumptions are
conservative and maintains that conservative assumptions are
necessary to ensure protection of human health and the
environment.
The Baseline Risk Assessment (BRA) for the Petrochem/Ekotek Site
follows accepted EPA guidance. In particular, the methodology
used was based on Risk Assessment Guidance for Superfund (RAGS)
(EPA 1989a in the BRA). Regarding the use of animal data, RAGS
states the following on page 7-5:
"The toxicity data base for most chemicals lacks
sufficient information on toxic effects on humans. In
such cases, EPA may infer the potential for the
substance to cause an adverse effect in humans from
toxicity information drawn from experiments conducted
on non-human mammals, such as the rat, mouse, rabbit,
guinea pig, hamster, dog, or monkey. The inference
that humans and animals (mammals) are similar, on
average, in intrinsic susceptibility to toxic chemicals
and that data from animals can in many cases be used as
a surrogate for data from humans is the basic premise
of modern toxicology. This concept is particularly
important in the regulation of toxic chemicals. There
are occasions, however, in which observations in
animals may be of uncertain relevance to humans. EPA
considers the likelihood that the agent will have
adverse effects in humans to increase as similar
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results are observed across sexes, strains, species,
and routes of exposure in animal studies."
Chemicals that induce benign tumors also frequently induce
malignant tumors, and certain benign tumors may progress to
malignant tumors. Benign and malignant tumor incidence are
combined for analysis of carcinogenic hazard when scientifically
defensible. The Agency follows the National Toxicology Program
framework for combining benign and malignant tumor incidence of a
particular site. The commenter is referred to the policies set
forth in the 1986 Guidelines for Carcinogen Risk Assessment and
the 1992 draft working paper Working Paper for Considering Draft
Revisions to the U.S. EPA Guidelines for Cancer Risk. The
scientific studies used to develop the cancer slope factors for
each or any of the carcinogenic COCs is available to the public.
It is difficult to respond to the claim that the benign tumor
data was inappropriately applied without definitive examples.
The assertion that there is no safe exposure to any carcinogen is
not necessarily assumed in the BRA. Exposure to carcinogens
resulting in a risk below the range of 10~4 to 10"6 is considered
"safe."
Groundwater ingestion was considered in the BRA in accordance
with the guidance. RAGS states that a pathway (in this case,
groundwater ingestion) is complete if there is (1) a source or
chemical release from a source, (2) an exposure point where
contact can occur, and (3) an exposure route by which contact can
occur. For this site (1) the groundwater is contaminated, (2)
there are wells in the area and new wells may be drilled, and (3)
although groundwater within a one mile radius is not currently
used for domestic purposes, it is used for stock watering, has
been used for domestic purposes in the past, and could
potentially be used for human consumption in the future.
Furthermore, the groundwater beneath the site is recognized as a
potential drinking water resource by the State because it is
hydraulically connected to the primary drinking water source for
Salt Lake City.
Groundwater concentrations are assumed to be the 95 percent upper
confidence limit of the mean or the highest measured site value,
whichever is lower. Use of the 95 percent upper confidence limit
of the mean is also in accordance with the guidance (RAGS,
Section 6.5).
As stated in RAGS (page 6-27), "If groundwater modeling is not
used, current conditions can be used to represent future
concentrations in groundwater assuming steady-state conditions."
In conclusion, although there is a range of different opinions
regarding risk assessments, it is EPA's current accepted guidance
and policies that govern how a risk assessment is to be conducted
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and the BRA for the Petrochem/Ekotek Site was performed in
accordance with these guidances and policies.
51) Comment
Ground Water Risk is Overstated. The ground water risk is
particularly overstated. While EPA agreed to use the more
realistic future industrial use scenario for soils risks, it
continued to use an unrealistic future residential use scenario
for ground water. See Baseline Human Health Risk Assessment,
Ekotek Site (EPA, 1994) ("BRA"). Future ground water use,
whether industrial or residential, is extremely unlikely. A
municipal water supply exists in the area, and will continue to
be available into the future. Further, the ESRC has been advised
that state and local authorities will not issue well drilling
permits for the area surrounding the Site. Salt Lake Valley
Interim Groundwater Management Plan, Utah Department of Natural
Resources, Division of Water Rights (April 5, 1991).
Additionally, the ground water under the Site is impacted by
geothermal activity which detracts from potability. The
monitoring of the ground water quality conducted by the ESRC over
the course of the RI/FS and development of the supplemental
hydrologic investigation shows elevated temperature and
electrical conductivity (generally greater than 1,000 umhos/cm)
and characteristic sulfur odor which reflects the upwelling of
heated and mineralized geothermal water in the Site vicinity.
This has been explained in greater detail in the Aquifer
Characterization Report. Future consumption of ground water
containing site-related contaminants, is an unrealistic
assumption and should, at a minimum, have been more clearly
stated in the Proposed Plan. It is critical that the Record of
Decision ("ROD") carefully describe the conservative and, in many
cases, unrealistic assumptions that underlie the BRA.
The Proposed Plan states that 8 in 10,000 residents and 2 in
10,000 workers could develop cancer from exposure to the ground
water. This statement is unnecessarily inflammatory and
misleading. EPA risk assessments estimate Site risk using two
different levels of exposure assumptions, the Reasonable Maximum
Estimate ("RME") and the Central Tendency Estimate ("CTE").
While both the RME and the CTE result in very conservative
estimates of potential risk, the RME is significantly more
conservative than the CTE. The RME uses upper-bound values
(typically 90% - 95%) for all of the exposure assumptions that
are then multiplied together to estimate total ground water risk.
The CTE, by contrast, uses average values (50%) for all of the
exposure assumptions (which are then multiplied together). The
statement of ground water risk in the Proposed Plan is based on
the RME, with no mention that risk was also estimated using the
CTE. The CTE ground water risk from the BRA was 8 X 10~5
residents (8 in 100,000) and 3 X 10"5 workers (3 in 100,000), an
order of magnitude less than the RME risk. EPA's own policy
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documents emphasize the importance of describing the full range
of risk (including the CTE) for risk management decision making.
See "EPA Risk Characterization Program" (1995, memo from Carol
Browner), "Policy for Risk Characterization" (March 1995) ,
"Guidance for Risk Characterization" (February 1995); Elements to
Consider When Drafting EPA Risk Characterizations (1995) . Yet,
EPA's Proposed Plan (and ground water cleanup alternative) did .
not factor in the significantly lower CTE ground water risk. The
CTE is not only more realistic (albeit very conservative), than
the RME, it was, apparently, the basis for the soils risk
presented in the Proposed Plan, adding to the confusion created
by the Proposed Plan discussion of Site risks.
Further, based on the probabilistic nature of risk assessment and
the compounding of the very conservation toxicity and exposure
assumptions, it is also just as likely that no one, even if
exposed to the ground water, will develop cancer from the ground
water.
In order to statistically detect a cancer risk of 5 in 10,000
(close to the residential ground water cancer risk specified in
the Proposed Plan [8 in 10,000]), a population of 20 million
people (over one tenth of the United States population) would
have to be drinking and showering in the ground water from the
Site for 350 days a year for 30 years (statistics per NEPI,
1995) . This is particularly striking where, as here, not even
10,000 workers or residents would come into contact with the Site
ground water, much less the requisite statistical sample. It is
extremely important to clarify for the public the meaning and
significance of the final risk numbers from the BRA. The
Proposed Plan failed to do this and, therefore, misrepresents
that ground water from the Ekotek Site will cause cancer in
residents and workers. This is simply not the case.
Response
With respect to the ground water ingestion pathway, see response
to comment 50.
EPA disagrees with the commenter that the use of RME in the
Proposed Plan is inflammatory or misleading. The use of RME in
the Proposed Plan is appropriate and it accurately reflects the
results of the Baseline Risk Assessment. The Baseline Risk
Assessment for the Site was developed in accordance with the Risk
Assessment Guidance for Superfund (July, 1989)("RAGS"). This
guidance states "Actions at Superfund sites should be based on an
estimate of the reasonable maximum exposure (RME) expected to
occur under both current and future land-use conditions. The
reasonable maximum exposure is defined here 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
(i.e., well above the average case) that is still within the
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range of possible exposures. In general, it has been EPA's
practice to rely upon the estimate of the RME to determine
whether action is warranted (OSWER Directive 9355.0-30, "Role of
the Baseline Risk Assessment in Superfund Remedy Selection
Decision", April, 1991). The ROD, a more detailed document than
the Proposed Plan, provides the reader with both the RME and the
CTE levels.
Although it is possible that "no one, even if exposed to the
groundwater, will develop cancer from the groundwater," by the
same token, it is also possible that several people would develop
cancer as a result of exposure to the groundwater. The use of
conservative factors could potentially be offset by the fact that
many of the COCs do not have numeric toxicity criteria. The
quantitative risks could actually be underestimated if these
chemicals have adverse effects associated with them. In
addition, humans may be more sensitive to some of the
contaminants than animals used in the development of toxicity
criteria. EPA believes that there are uncertainties associated
with any quantification of risk. Sections 3.4, 4.3, 5.3, and 6.5
of the BRA discuss uncertainties associated with the risk
assessment. Page 6-8 states that uncertainties are "limitations
to the risk assessment process which cannot be resolved
quantitatively given the current understanding of human health
and using current risk assessment methodology. These
uncertainties are addressed in part by consistent application of
conservative assumptions regarding the toxic effects of
chemicals." It is also stated that such procedures are intended
to protect human health. In some cases this may result in
overestimation of risks; however, it is also likely that risks
are not overestimated in all cases. The objective of a BRA is to
estimate potential risks, while providing a margin of safety in
an attempt to prevent underestimation of the risks. In any case,
as stated previously, the BRA closely follows the most current,
accepted, EPA guidance.
The Proposed Plan states that "assuming no cleanup were to occur,
approximately 8 in 10,000 residents and 2 in 10,000 workers could
develop cancer from exposure to the groundwater." It does not
state that site groundwater "will cause cancer." The statement
presented in the Proposed Plan is consistent with the findings of
the BRA. The number of people required for a statistical sample
has nothing to do with the fact that, in this case, the
acceptable risk level is exceeded. The acceptable risk number is
exceeded regardless of how many people are exposed. The ROD will
state that an excess lifetime cancer risk of 10"6 indicates that,
as a reasonable maximum estimate, an individual has a 1-in-l-
million additional chance of developing cancer as a result of
site-related exposure to a carcinogen over a 70-year lifetime
under specific .exposure assumptions at the site.
52) Comment
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Site Does Not Pose Imminent and Substantial Danger. The Proposed
Plan erroneously states that the Site, if not remediated, "may
present an imminent and substantial danger to public health,
welfare, or the environment." EPA Proposed Plan at 5. This is
not true, and is not supported by the BRA. Rather, the BRA
demonstrates that, considering site-related contaminants,
appropriate exposure scenarios, and no remediation, the Site does
not present an unacceptable risk to humans or the environment,
much less an "imminent and substantial danger."
Indeed, the cancer risk estimate cited in the Summary of Site
Risks for future Site workers exposed to soil is 10" , well
within EPA's acceptable risk range of ICf4 to 10"6. 40 C.F.R.
Part 300. At this level, EPA's own guidance indicates that no
soils remediation would be required. See EPA, "Role of the
Baseline Risk Assessment in Superfund Remedy Selection Decisions"
(April 22, 1991).
Consumption of ground water does not reasonably reflect current
or even foreseeable future Site conditions. One of the ground
water contaminants, arsenic, is naturally occurring, as discussed
further below. Site monitored levels of arsenic are, in fact,
below the average naturally occurring arsenic levels measured in
ground water throughout the Salt Lake Valley. Removal of arsenic
from the cancer risk estimate in the BRA would reduce the cancer
risk estimate by almost half (3 in 10,000). Another chemical
considered in the BRA, and contributing to the unrealistically
high EPA risk estimates was thallium. EPA has agreed not to
pursue thallium cleanup because it determined that thallium is
not representative of Site ground water conditions.
Nevertheless, thallium remains in the BRA, giving it an
additional measure of conservatism.
Response
The accumulative site risk exceeds EPA's acceptable risk range of
10"4 to 10"6, so clearly the actions specified in the ROD are
warranted and if not addressed, present an unacceptable risk to
human health and the environment and may present an imminent and
substantial danger to public health. The reasonable maximum
exposure (RME) under an industrial scenario from site soils is
9.75 X 10~5 and the RME under the residential scenario from site
groundwater is 7.99 X 10"4. CERCLA 104 states that whenever a
hazardous substance is released or there is a substantial threat
of such a release into the environment, or there is a release or
substantial threat of release into the environment of any
pollutant or contaminant which may present an imminent and
substantial danger to the public health or welfare, action is
authorized, consistent with the national contingency plan, to
remove or arrange for the removal of, and provide for remedial
action relating to such hazardous substance, pollutant, or
contaminant at any time, or take any other response measure
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consistent with the national contingency plan which is deemed
necessary to protect the public health or welfare or the
environment.
The selection of the remedy involves risk management decisions.
The goal of the remediation is to achieve the acceptable risk
range of 10~4 to 10"6. This may include the remediation of all or
a portion of the contaminants identified as contributing risk.
The risk management decision to remediate a portion of the
contaminants does not remove the contribution of risk from the
unremediated contaminant(s) (e.g., thallium), but rather
incorporates extenuating conditions that assist EPA in deciding
which contaminants can be addressed that would achieve EPA's
acceptable risk range.
53) Comment
No Basis to Assess Risk Reduction Achieved by Alternatives. The
Proposed Plan states that Alternatives 6 through 9 provide "the
greatest risk reduction." EPA has no basis from which to make
this statement. This is particularly true because EPA has not
factored in risk to the remediation workers and other short-term
risks associated with the selected cleanup alternative. See
NEPI, 1995 (health risks to cleanup workers during remediation
far outweigh risks to future Site workers or nearby residents
from NPL sites). Further, residual risks have not been compared
among the alternatives. Unless a comparison of residual risk is
undertaken, EPA cannot simply assume that removal of contaminated
material equals risk reduction. See Risk Assessment Guidance for
Superfund (Volume I), Human Health Evaluation Manual, Part C
(1989). As discussed further below, containment of the soils
(Alternative 10) eliminates exposure to the soils and thus
eliminates the risk from the soils. This achieves at least an
equivalent level of risk reduction, if not more so, than EPA's
selected alternative of thermal desorption.
Response
With respect to risk reduction, EPA agrees that prevention or
elimination of the exposure to the contaminants has the same end
effect of risk reduction or elimination.
54) Comment
Containment of Soils is Protective. Risk is a function of
exposure and toxicity. Toxicity is the inherent ability of a
chemical to cause adverse effects in receptor organisms, in this
case humans. All chemicals have the ability to cause non-cancer
adverse effects; some chemicals have the ability to cause cancer.
Exposure describes how a person can come into contact with Site-
related contaminants. In the absence of exposure there is no
risk. Both alternatives eliminated exposure to the soils;
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Alternative 7 by thermal desorption with its attendant risks and
uncertainties, and Alternative 10 by containment. Contrary to
the conclusions of the Proposed Plan, Alternative 10 (which
isolates affected soil via sandwiching between clean soil layers)
is as protective as Alternative 7 in terms of soil-related risk.
Response
EPA agrees that in the absence of exposure there is no risk.
Alternative 7 offers permanence through the treatment of the
contaminants via thermal desorption while alternative 10 is
equally protective, but allows waste to remain on site. Because
contamination remains on site, there is a potential for risk
should exposure occur.
55) Comment
Arsenic is Naturally Occurring in Ground Water. Arsenic is a
naturally-occurring substance in the earth's crust. The average
concentration of arsenic in the rocks and soils in the earth's
crust is approximately 1.8 parts per million ("ppm"). Vance,
National Environmental Journal (Aug. 1995). Further, the
Remedial Investigation for the Site showed that there is no
significant statistical difference between the concentration of
arsenic in soils on-site and soils off-site. The off-site soils
represent local background conditions. Soil arsenic, both on-
site and off-site, averages around 10-15 ppm; there is no
statistical distinction between on-site and off-site soil,
suggesting that soil in the general vicinity of Ekotek is
elevated in arsenic relative to the average crustal abundance
value of 1.8 ppm. The similarity in arsenic concentrations in
both on-site and off-site soils indicates that Site activities
have not impacted Site soils and therefore could not have
contributed to arsenic in ground water. For this reason, arsenic
was not identified as a soil contaminant of concern ("COC") in
the BRA.
EPA has accepted that arsenic is a naturally-occurring
constituent of ground water in the Salt Lake Valley, based on
correspondence from EPA to the ESRC. EPA letter, dated October
27, 1994. At issue is the concentration at which arsenic occurs
naturally in the ground water.
Arsenic occurrences above the EPA MCL of 0.05 ppm are erratic
spatially and not repeatable from one sampling event to another
in any given well. Four occurrences above the MCL for arsenic
have been recorded from the wells installed on-site. The early
elevated levels in two of these wells (W-l and W-3) can be
attributed to improper sample collection and solids in the sample
due to inadequate well development. The other two exceedances
(W-l and MW-6) were each 0.051 ppm, 0.001 above the MCL and have
not been repeated since January 1994 and February 1995,
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respectively. The average arsenic concentration in the fresh
water aquifer under the Site based on the wells installed by the
ESRC is 0.0156 ppm. The average arsenic concentration in the
deeper geothermal water around the Site vicinity is 0.0232 ppm,
and has been observed to range up to 0.163 ppm. See ESRC letter
to EPA, dated March 9, 1995.
In addition to Site monitoring data, published water quality data
for the Salt Lake Valley collected by the United States
Geological Survey ("USGS") evidences arsenic concentrations
ranging up to 0.360 ppm in the shallow unconfined aquifer (Unit
2), and up to 0.280 ppm in the confined Principal Aquifer (Unit
3). The average arsenic concentration in the shallow aquifer
(Unit 2), based on the 51 wells sampled by the USGS, is 0.034
ppm; the average arsenic concentration in the Principal Aquifer
(Unit 3) based on 33 wells sampled by the USGS is 0.029 ppm.
Other arsenic monitoring data further evidences that arsenic
occurs in the Principal Aquifer at levels higher than those
measured at the Ekotek Site. See Runnells, Regional Geochemistry
for the Great Salt Lake Area (1992)(average arsenic levels of
0.07 ppm, with values up to 0.437 ppm). These values are higher
than the average for the Site wells (0.0156 ppm). All of these
data taken together suggest that arsenic in ground water under
the Site is within the naturally-occurring ranges in the Salt
Lake Valley, and that the few elevated measurements of arsenic at
the Site are within the ranges recorded by other agencies and
other studies.
Rain infiltration through soil is the most likely source of
arsenic in the vicinity of the Site and probably on-site. A
second possible natural source is the Principal Aquifer,
especially for arsenic concentrations west of the high-
conductivity ridge under the Site. During the winter months, the
geothermal activity is low and the Principal Aquifer can flow
eastward into the Site. This accounts for higher arsenic along
the west side of the Site and for generally higher arsenic values
in the winter. A third and possible source is geothermal
activity along the Warm Springs fault. Arsenic is considerably
higher in geothermal water upgradient of the Site associated with
the Warm Springs fault. The soil and Principal Aquifer sources
are the more likely sources. Both are natural sources that
cannot be remediated.
If the used oil present in the LNAPL were a contributing source
of the arsenic, it is logical to assume that wells completed
within or adjacent to the plume of oil would show the highest
arsenic concentrations. However, this is not the case; the wells
where elevated levels of arsenic have occurred (W-l, W-3, W-7,
MW-6, P-3 and P-6A) were not spatially related to the LNAPL plume
(MW-6 is completed below the water table). Further, the ESRC has
performed additional testing on the LNAPL to supplement existing
data. A Toxicity Characteristic Leaching Procedure ("TCLP") test
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was run on the LNAPL for RCRA metals. The results show that
arsenic is not leached from the substance because it was not
detected in the TCLP leachate test, which had a detection limit
of 0.10 ppm. These data strongly suggest that the oil is not a
source of arsenic.
Response
EPA believes that there is insufficient data with respect to Site
ground water background data to definitively state that the
concentrations of arsenic on-site are natural. EPA believes that
the basis for, and implementation of, the arsenic contingency are
fully described in the ROD and offer the best approach to an
inconclusive feasibility study.
56) Comment
Vinyl Chloride is Not a Site Source. There are presently no
verified sources of chlorinated solvents on the Ekotek Site.
There is no evidence of dense non-aqueous phase liquids ("DNAPL")
at the Site, and no significant amounts of Site COCs in the
LNAPL. Although chlorinated solvents may have been shipped to
the Site, separate, discrete sources of this solvent material
have not been located in the Site soils or ground water. See
Feasibility Study at 2-12. Because the parent solvents have not
been detected consistently in the ground water above trace
concentrations (typically 0.001 to 0.02 ppm) and solvent
breakdown products have been detected, there is no evidence of a
DNAPL at the Site. Recent analyses of the LNAPL show parent
solvent compounds at less than 0.05 ppm.
If chlorinated solvents were present as non-aqueous phase liquids
("NAPL") or in the LNAPL, concentrations dissolved in the ground
water would be much higher than presently detected. Field work
has shown that contaminant concentrations of greater than one
percent of the aqueous solubility limit are typically associated
with NAPL presence. Cohen, R.M. and J.W. Mercer, DNAPL Site
Evaluation (C.K. Smoley, Boca Raton, FL, 1993). The aqueous
solubilities for vinyl chloride, TCE, and TCA are 1,100 ppm,
1,100 ppm, and 480 ppm, respectively. Therefore, if a NAPL
source for these chlorinated solvents existed on-site, the ground
water concentrations would likely be in the range of 1 to 10 ppm,
not the 0.001 to 0.02 ppm detected in the ground water or the
0.05 ppm in the LNAPL.
The recent discovery of 1,1,1-Trichloroethane ("TCA") in
monitoring wells upgradient from the Ekotek Site indicates a
likely source of the vinyl chloride, in the on-site ground water.
TCA which yield 1,1-DCE, 1,1-DCA, and vinyl chloride as
intermediates or products. McCarty, P.L., "Ground Water
Treatment for Chlorinated Solvents," Handbook of Bioremediation,
Chapter 5, pp. 87-116 (Norris et al. Lewis Publishers, Boca
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Raton, FL., 1994). The types of abiotic and biotic reactions are
explained in detail in the Aquifer Characterization Report.
The concentration patterns of TCA, 1,1-DCA, 1,1-DCE, and vinyl
chloride observed during the recent months of sampling are
consistent with TCA being one source of the vinyl chloride.
Ground water upgradient from the Site contains high
concentrations of TCA, and this contaminated ground water is
moving toward and beyond the Site. The abiotic conversion of TCA
to 1,1-DCE forms a plume of 1,1-DCE within the plume of TCA. The
upgradient ground water containing TCA and 1,1-DCE is less
reducing than ground water at the Site because the LNAPL and
other organics on-site provide substrate for anaerobic microbial
activity. When the TCA and 1,1-DCE encounter the strongly
reducing conditions at the Site, the 1,1-DCE is transformed to
vinyl chloride and the TCA is transformed to 1,1-DCA. These
conversions are known to be quite rapid under strongly reducing
conditions. The low concentrations of vinyl chloride measured in
Site ground water are consistent with the low levels of 1,1-DCE.
The TCA appears to enter the ground water in pulses or slugs,
probably in response to heavy precipitation episodes or increases
in the ground water elevation (water table). The TCA from these
periodic inputs is rapidly transformed, but the intermediates,
including vinyl chloride, degrade at a slower rate and can be
measured over a period of years.
While the presence of cis-l,2-DCE in Site ground water is another
possible source of vinyl chloride, the source of the cis-l,2-DCE
on-site remains unresolved and the low levels of cis-l,2-DCE
(0.012 ppm to non-detect) are inconsistent with an on-site
tetrachloroethene ("PCE"). The presence of TCE and PCE as NAPL
would cause much higher ground water concentrations of cis-1,2-
DCE and, in turn, vinyl chloride (in the range of 1% of the
aqueous solubility). See above discussion of NAPLs.
Response
EPA believes the source of the vinyl chloride on site to be the
LNAPL plume. In March 1995, the Light Non-Aqueous Phased Liquid
(LNAPL) was re-analyzed by ESRC for halogenated volatile
constituents (solvents) by purge and trap concentration (EPA
Method 5030) combined with gas chromatography (GC) as described
in EPA Method 8010. The LNAPL was also analyzed specifically for
vinyl chloride, 1,1,1-trichloroethane and tetrachloroethylene by
mass spectrometry using selective ion monitoring (SIM) . Vinyl
chloride was detected at 480 ppb; 1,1,1-trichloroethane was
detected at 130 ppb; and tetrachloroethylene was detected at 410
ppb. Previous LNAPL analytical methods used detection limits of
10,000 ppb and found no detections because the limits were high.
The compounds that were detected in the LNAPL were evaluated as
to the likelihood that they would dissolve from the oil into the
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ground water. Table 6.1.2.3 of the ROD shows the results of the
partitioning exercise. The predicted concentrations show that
the maximum concentrations of vinyl chloride, 1,1,1-
trichloroethane and tetrachloroethylene have the potential to
partition into the ground water at concentrations of 110 ppb,
0.55 ppb and 1.2 ppb, respectively. Upon further review, EPA
derived a theoretical equilibrium partitioning of vinyl chloride
from LNAPL at the site to ground water using the effective
solubility of vinyl chloride (VC) in water. Data from the March
1995 sampling event was used and the effective solubility of VC
in water was calculated using the simplifying assumptions of
Raoult's Law which relates the effective solubility to the mole
fraction of the compound in the mixture. The resulting
partitioning from LNAPL to ground water, although subject to
significant uncertainty, was close to the MCL of 2 ug/1. The
March 1995 sampling of the LNAPL is the only sampling event where
the detection limits were sufficiently low to detect the
concentrations of the chemicals of concern (COCs). More studies
would have to be completed to accurately describe the range of
the concentrations of the COCs within the LNAPL using the lower
detection limits, and to accurately estimate the mole fraction.
A thorough investigation of the LNAPL has not been completed and
thus there may be portions of the LNAPL that have higher
concentrations of vinyl chloride, 1,1,1-trichloroethane and
tetrachloroethylene. In addition, it is likely that the LNAPL
may have partitioned in greater concentrations to the ground
water in the past and is currently approaching equilibrium.
57) Comment
Pump and Treat is Not a Proven Technology. Pump and treat is an
ineffective technology for ground water remediation at the Ekotek
Site. Numerous studies have shown that pumping ground water
cannot reliably extract most organic contaminants in the
subsurface. National Research Council, Alternatives for Ground
Water Cleanup (National Academy Press, Washington, D.C., 1994).
The extracted water can be treated effectively, but the problem
is that the extraction is inefficient due to geologic complexity
and chemical characteristics of organic contaminants (for
example, hydrophobicity, sorption, and low aqueous solubility).
Consequently, aquifers do not get remediated with pump and treat.
In many cases pump and treat results in a rapid and dramatic .
decline in contaminant concentration. But when pumping stops,
any contaminant present as residual phases within soil pores
continues to dissolve slowly into the ground water. Hasbach, A.
"Moving Beyond Pump-and-Treat, "Pollution Engineering (March 15,
1993) . This has been observed in hundreds of ground water
systems installed around the country, and few, if any, have
achieved successful remediation.
Response
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With respect to the viability of a pump and treat system for the
Petrochem/Ekotek Site, see response to comments 46 and 47.
58) Comment
EPA Technical Impracticability Guidance. EPA's own guidance
recommends a phased approach to Site remediation and early
actions to remove contaminant sources when there is a high degree
of uncertainty regarding the potential outcome of ground water
restoration efforts. EPA, "Guidance for Restoration," OSWER
Directive 9234.2-25. The Aquifer Characterization Report clearly
evidences that there is, at best, a high degree of uncertainty as
to whether pump and treat will work. See Pump and Treat
Conclusions from EPA workshop, supra at 2. This is consistent
with the ESRC's preferred Alternative 10, which incorporates
early actions to remove contaminant sources, with ongoing
monitoring of the efficacy of intrinsic remediation. In its
Technical Impracticability Guidance, EPA, based on its experience
over the past decade (1983 to 1993), suggests that achieving the
required final cleanup standards may not be practicable at some
sites due to the limitations of remedial technology.
Response
EPA has selected alternative 10 as the selected remedy with the
ground water remediation component being conditioned upon the
quantification of the bioremediation or degradation component of
attenuation. The selected remedy must ensure that
bioremediation/attenuation is comparable to an active restoration
of the ground water.
59) Comment
Site Hydrogeology. Two hydrogeologic conditions at the Site make
pump and treat remediation of vinyl chloride unnecessary and
infeasible: (1) the Site is situated above a ground water
stagnation zone that greatly reduces the rate at which vinyl
chloride can migrate off-site; and (2) the close proximity of
geothermal water (40-60 feet) to the surface will cause upconing
of the geothermal water when shallow ground water is pumped. The
Aquifer Characterization Report explains the hydrogeology of the
Site in considerable detail and contains plates and figures to
illustrate the concepts summarized below. Where appropriate,
relevant plates or figures from the Report are referenced.
a. Ground Water .Stagnation Zone. As Figure 4.2 from the
Report illustrates, the unconfined, coarse-grained aquifer (Unit
1) which underlies the Site abuts the shallow, unconfined fine-
grained aquifer (Unit 2) and the deep, confined aquifer (Unit 3
or Principal Aquifer) which extends out into the Salt Lake
Valley. Converging flow between the Principal Aquifer and
recharge to the fresh water aquifer at the Site (Unit 1) from the
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Wasatch Mountains is the principal cause of the stagnation zone,
along with geothermal flow between the Hobo Springs and Warm
Springs fault zones. There is also an increase in hydraulic
conductivity from the fine-grained sediments to the coarse-
grained gravels across the northern part of the Site, which
contributes to the decrease in hydraulic gradient from east to
west across the Site. Thus, the stagnation zone beneath the Site
is the result of two factors, converging flows from the west and
east and a substantial increase in hydraulic conductivity due to
the presence of gravels beneath the Site. The volume of recharge
to the unconfined aquifer from the Principal Aquifer is unknown,
but is thought to be considerably less than recharge from the
Wasatch Mountains.
There is evidence based on the movement of the 1,1-DCA plume that
the net movement of the plume is severely limited. Sampling of
1,1-DCA has shown that this plume is severely limited. Sampling
of 1,1-DCA has shown that this plume moves back and forth on a
seasonal basis and has not migrated from beneath the Site.
During the late spring months, water flowing into the stagnation
zone from the east (Wasatch Mountains) due to spring runoff
causes the 1,1-DCA plume to move to the west. But during the
winter months, the lull in geothermal activity allows flow from
the confined part of the Principal Aquifer to the west to flow
into the Site, thus pushing the 1,1-DCA plume back to the east.
Graphics illustrating this "sloshing" and the hydrodynamics of
the stagnation zone in the fresh water aquifer beneath the Site
are found in the Aquifer Characterization Report (Figures 4-2, 4-
7, 4-10). This would not be the case if ground water from the
Principal Aquifer were a continued large volume source for the
Site fresh water aquifer.
The upwelling geothermal water along the Hobo Springs fault zone
appears to be the controlling influence on the amount of water
that can flow from the Principal Aquifer into the Site fresh
water aquifer. Increased geothermal activity along the fault
zone can temporarily close the connection between the Site fresh
water aquifer and the Principal Aquifer. Water that does flow
into the Site fresh water aquifer either from the Principal
Aquifer or by recharge from the Wasatch Mountains can cause a
depression in the fresh water; the geothermal water contact can
absorb the increase in mass of water beneath the Site.
Alternatively, some of this inflowing water may eventually flow
out of the Site to the north or northwest, following the regional
gradient in this part of the Salt Lake Valley. Fine-grained
sediments north of the Site probably slow the northward outflow
from the Site, thus contributing to the stagnation zone found
beneath the Site.
The presence of the stagnation zone means that contaminants can
enter the Site fresh water aquifer from either the west or the
east. These contaminants will collect in the stagnation zone.
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To the west is the confined part of the Principal Aquifer. An
unconfined part of the Principal Aquifer exists beneath the Site.
To the east are found additional industrial sites and then the
Warm Springs fault and the Wasatch Mountains. Water entering the
stagnation zone is accommodated both by additional depression in
the contact surface between the fresh water and the geothermal
water and possibly by some northward flow or leakage from the
stagnation zone, especially during periods of high influx to the
stagnation zone.
As discussed above, and based on the data developed in the
Aquifer Characterization Report, the current contaminant plume
appears to be limited to the stagnation zone. Thus, pump and
treat is not required to control the plume of vinyl chloride
beneath the Site.
b. Upconing of Geothermal Water. To effectively remove
vinyl chloride from the Site, capture wells will have to be
screened completely through the fresh water aquifer down to the
contact with the geothermal water, a distance of approximately
40-60 feet. To produce effective capture, three wells will
probably be needed with a minimum drawdown of 0.5 feet in the
fresh water aquifer water table. Based on the pumping test
performed at the Site, a pumping rate of 125 gpm would be
necessary to create 0.5 feet of drawdown. This pumping rate
multiplied by three pumping wells is 375 gpm, or 16,200,000
gallons per month. This value is four times the original
estimate of 4,000,000 gallons per month discussed with the POTW
(and on which EPA's Alternative 7 is based). This will cause
upconing of the geothermal water into pumping wells following the
Ghyben-Herzberg principle (see Fetter, C.W., Jr, Applied
Hydrogeology (Merrill Publishing Company, Ohio, 1980).
The amount of upconing will depend on the pumping rates and
proximity of the well screens to the geothermal water contact.
Assuming a maximum density for the geothermal water of 1.025,
upconing of 20 feet is possible and this would mean that half of
the water pumped in a well with a screen length of 40 feet that
is set just above the geothermal water contact would be
geothermal water. If the density of the geothermal water is
less, then more upconing is possible. Even at shallow screen
depths (20 feet) upconing will occur. The equations of Schmorak
and Mercado (1969) as presented and utilized by Walton, Practical
Aspects of Ground Water Modeling (National Water Well Assn. 1988)
show that the maximum pumping rate for a well with a screen 40
feet above geothermal water (screen depth of 20 feet with
geothermal water at 60 feet) would be about 20 gpm - 40 gpm. Any
pumping rate greater than about 40 gpm would result in the
upconing geothermal water entering the well screen. The minimum
total pumping rate to achieve a 0.5 foot depression in the fresh
water aquifer table would be around 375 gpm, as shown above.
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This means each of the three wells would need to pump at a
minimum of 125 gpm, not the 40 gpm necessary to avoid upconing.
Upconing of geothermal water will seriously reduce the
effectiveness of pump and treat for vinyl chloride and will cause
increased mixing of geothermal water and fresh water. Also,
geothermal water entering the fresh water aquifer would occupy
mostly the large pore spaces of the sand and gravel, making it
difficult to remove the dissolved vinyl chloride from the smaller
pore spaces. Increased pumping would only cause more upconing
and less removal of vinyl chloride.
Thus, since potential capture wells must either be pumped at a
rate too low to achieve plume containment (much less capture), or
pumped at a rate that will cause upconing of geothermal water,
pump and treat is simply not a viable remedial alternative for
the Ekotek Site.
Response
EPA has selected alternative 10 as the remedy for the
Petrochem/Ekotek Site which relies upon
bioremediation/attenuation to address and contain the
contaminants within the ground water plume within the current
extent of contamination. With respect to the stagnation zone,
see response to comment 7. With respect to the viability of a
pump and treat system, see response to comments 46 and 47.
60) Comment
Off-Site Vinyl Chloride Source. As discussed above, the vinyl
chloride concentrations in the ground water appear, in large
part, attributable to an off-site, upgradient source. Regardless
of whether off-site, upgradient source(s) are the only source(s)
of the Site vinyl chloride (as the ESRC believes), or a
contributing source, the off-site source(s) must be addressed
before remediation of the Site ground water can be undertaken.
This is particularly true with pump and treat, since pumping
would only exacerbate migration of the off-site plume into the
ground water under the Site by increasing the ground water
gradient in the fresh water aquifer and thereby increasing the
flux rate of contaminant into the. Site.
Response
With respect to the off-site TCA being the source o.f the on-site
vinyl chloride, see response to comment 39. With respect to the
source of the vinyl chloride on-site, see response to comment 56.
61) Comment
Naturally Occurring Arsenic. Pump and treat will not work for
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arsenic remediation because: (1) there is no consistent arsenic
contamination at the Site, and (2) the most likely sources for
arsenic, the soil and possibly the Principal Aquifer, are natural
sources. Pump and treat will not stop rain water infiltration
through soil from adding arsenic to ground water. Pump and treat
may, especially during the winter months, degrade the water
quality by pulling in more water from the Principal Aquifer that
is elevated in arsenic (average of 0.07 ppm with values up to
0.437 ppm). Runnells, 1992.
Removal of arsenic by pump and treat cannot attain a clean-up
goal because the fresh water aquifer at present averages below
the MCL. Elevated arsenic levels are sporadic spatially and not
repeated in time. In short, there is no arsenic plume. Further,
the ongoing natural arsenic contribution to the ground water
system under the Site would result in a pump and treat system
operated into infinity, with no hope of removing the naturally
occurring arsenic from the aquifer. Under these circumstances,
it is simply not technically feasible to attempt pump and treat
to address arsenic in the ground water.
Response
With respect to arsenic, see response to comment 43.
62) Comment
POTW Limits. The Salt Lake City publicly-owned treatment works
("POTW") cannot accommodate the volume and quality of extracted
water anticipated by EPA. The POTW is in the process of
developing a treated water reuse program, and cannot accept large
volumes of water with low concentrations of contaminants yet
potentially high specific conductance and salinity (due to the
geothermal influence at the Site). The higher pumping rates
which would be necessary to affect the plume based on the
expanded knowledge of the Site hydrogeology, as well as the
geothermal upconing, as explained above, represent a higher
volume of more saline water than the ESRC believes the POTW is
prepared and able to accept.
Response
With respect to the POTW accepting the volume and quality of
extracted water, the Feasibility Study states that ESRC has
completed the necessary coordination with the POTW to determine
that the quantities and quality of the ground water extracted at
pumping rates of 40-100 gpm was a viable alternative (i.e., 7)
worthy of consideration for selection. With respect to the
upconing of geothermic waters and viability of pump and treat
systems for this Site, see response to comments 46 and 47.
63) Comment
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Bioremediation of Vinyl Chloride. Studies for the past 15 years
have determined that many organic contaminants are biodegraded in
the subsurface. This research has characterized the possible
reactions and conditions that are needed for reactions to occur.
This has led to interest in engineering bioremediation where
chemicals such as oxygen and nutrients are added to the
subsurface to stimulate bioremediation (active Site remediation).
In the past few years, it has been recognized that there are many
natural bioremediation reactions occurring at waste sites. The
long exposure of microorganisms in the soil to contaminants at
waste sites has led to adaptation and bioremediation reactions in
the soil. For aquifer restoration, the naturally occurring
hydrogeochemical conditions at the Site must allow the rate of
bioremediation to exceed the rate of contaminant migration.
Intrinsic remediation is not a "do-nothing" approach. There must
be continual monitoring to confirm the progress of contaminant
bioremediation and the effectiveness of intrinsic reactions. The
advantages of this approach are (1) no alternative of ground
water gradients, (2) minimal disruption of the ground surface at
the Site, and (3) lower cost.
The information presented in the Aquifer Characterization Report
demonstrates that natural processes are controlling the
contamination in the ground water at the Ekotek Site. The
hydrogeology and contaminant distribution in the ground water has
been delineated. Chemical analyses have been conducted that
indicate electron acceptors and other reactants and products
indicative of anaerobic bioremediation processes are present. A
region of low redox exists in the subsurface around the Ekotek
Site, as shown in figures presented in the Aquifer
Characterization Report. The data and chemistry of the Site
ground water are highly encouraging for intrinsic reactions of
chlorinated solvents at the Ekotek Site.
As discussed in the Aquifer Characterization Report, the
hydrogeology of the Site and the surrounding region create a
stagnation zone or area of convergence beneath the Site, when
westward-flowing ground water from the Wasatch Mountains meets
eastward-flowing ground water from the Principal Aquifer. The
zone of stagnation has helped to contain the plume of chemicals.
There is no significant migration of the plume off-site, and the
plume, in fact, tends to expand and contract with seasonal
variations in the area of convergent flow.
The initiation of pump and treat will have an adverse impact on
the conditions currently favorable to intrinsic bioremediation.
The pumping will create a hydraulic gradient toward the Site,
causing the influx of more oxygenated and less reducing ground
water, which will decrease the effectiveness of the current Site
conditions in naturally reducing the contaminant concentrations.
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Because the vinyl chloride plume lies within the stagnation zone,
the potential for migration has been greatly reduced. The vinyl
chloride plume is slowly but noticeably decreasing in
concentration due to bioremediation. The very low concentrations
of vinyl chloride increased in some wells near the northern
extent of the Site in 1995, but this was expected given the
recent migration of TCA into the area. Bioremediation will not
change the Site hydrology or chemistry, and thus will allow the
current reducing conditions at the Site to continue the
degradation and reduction in level of vinyl chloride. In
contrast, pump and treat of the vinyl chloride will not only fail
to recover the vinyl chloride, it will alter the reducing
conditions at the Site and possibly prevent the natural
bioremediation from continuing. The ESRC strongly believes that
natural bioremediation must be given a chance to work. Long-term
vinyl chloride monitoring (10 years) to confirm or refute natural
bioremediation is the only viable option given all of the
evidence indicating pump and treat will not succeed.
Response
Alternative 10, the selected remedy, relies upon
bioremediation/attenuation to address the contaminants within the
ground water beneath the Site. With respect to
bioremediation/attenuation of the contaminants within the ground
water underneath the Site, see response to comment 33. With
respect to the stagnation zone, see response to comment 7. With
respect to the viability of a pump and treat system on the Site,
see response to comments 46 and 47.
64) Comment
No Current Exposure to Ground Water. A well survey was performed
during the RI/FS to locate any existing wells in the vicinity of
the Site. Records from the Utah Division of Water Rights were
obtained and reviewed, and a field survey was performed, to
determine the exact location of each well within one mile of the
Site. There are no wells being used for domestic drinking water.
Remedial Investigation at 3-6, Table 3.4, Figure 3-8. As the
above-referenced Attachment 3 indicates, there is a moratorium on
the drilling of any wells into the Principal Aquifer when a
municipal water supply is available. The municipal water system
is available in the entire vicinity of the Ekotek Site. Thus, at
this time, there is no current exposure to the ground water, nor
is any allowed until the moratorium is lifted.
Response
The ground water beneath the Petrochem/Ekotek Site is considered
a potential drinking water source by the State of Utah. As such,
the remedy described in the ROD shall return this ground water to
its beneficial use as a drinking water source within a reasonable
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timeframe given the particular circumstances of the site as
specified in the selected remedy.
65) Comment
Intrinsic Bioremediation is Only Viable Alternative. In light of
the foregoing analysis and discussion, intrinsic remediation is
the only technically feasible alternative available to address
the low levels of vinyl chloride in the Ekotek ground water. Of
course, the efficacy of intrinsic bioremediation cannot be
established conclusively until the off-site, upgradient TCA
source is eliminated.
At the EPA workshop meeting on August 28-29, 1995 in Salt Lake
City, EPA seemed to indicate that without absolute proof that
bioremediation was occurring at the Site, it would, by default,
select pump and treat for ground water cleanup. As the ESRC
explained, and as EPA's experts agreed, the very low levels of
vinyl chloride, relative to the analytical detection limits and
other contaminated sites, makes it difficult to establish with
any higher degree of certainty that bioremediation is indeed
occurring at the Site. Further, as set forth above and as EPA's
experts agreed, there are significant concerns with the
effectiveness of pump and treat in the unique hydrogeologic
regime of the Ekotek Site. Under these circumstances, then, when
(1) no one is currently exposed to ground water, (2) the vinyl
chloride levels are very low, (3) the plume is migrating very
slowly, if at all, (4) pump and treat might disrupt
bioremediation, and (5) the Site conditions are conducive to
bioremediation, it would be arbitrary and capricious for EPA to
select pump and treat simply because bioremediation cannot be
proven to a level of scientific certainty.
Response
The commenter misrepresents the degree to which EPA's experts
agreed with ESRC regarding pump and treat systems and the
necessity of acquiring more information to quantify
bioremediation at the Site.
It is more accurate to state that at the Workshop meeting August
28-29, 1995, EPA acknowledged that there is some difficulty in
quantifying the degradation rate of the on-site vinyl chloride to
ethane and ethene, but to state, imply or conclude that EPA's
experts believe that the degree of certainty that bioremediation
is occurring at the site cannot be further established is
completely wrong. EPA's experts stated that although ESRC can
show that conditions are favorable at the Site for
bioremediation, ESRC cannot conclude that bioremediation is
occurring until the rate of degradation of the vinyl chloride to
ethane and ethene is quantified. Much discussion then took place
as to the difficulties of obtaining sampling methods with low
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detection limits and the strengths and weaknesses of approaches
used to quantify bioremediation. After the meeting, ESRC
representatives met with EPA to develop an approach for the
quantification of bioremediation. ESRC has already initiated the
first two activities and the ROD describes the follow-up
activities under the description of pilot studies.
With respect to conclusions regarding pump and treat systems,
EPA's experts listened to the presentation and engaged in
questions and acknowledged that all pump and treat designs must
consider site conditions. Beyond these conclusions, ESRC is
greatly misrepresenting the outcome of the meeting to conclude
that EPA believes the selection of a pump and treat system would
be an arbitrary and capricious decision. During the meeting, EPA
asked that ESRC provide the basis of the calculations and
conclusions being presented regarding the upconing of the
geothermal waters. ESRC provided these calculations in a letter
dated September 5, 1995. EPA's review and response to this
letter is found in the response to comments 46 and 47.
In conclusion, the selection of bioremediation/attenuation relies
upon the ability of the Respondents performing the response
action to quantify the rate of bioremediation to demonstrate that
bioremediation/attenuation is comparable to an active restoration
program. If bioremediation/attenuation does not contain and
remediate the contaminants within the ground water plume, EPA
will consider other remediation technologies. The containment
remedy, which is a pump and treat system, has been developed to
ensure containment of the contaminants if
bioremediation/attenuation fails.
66) Comment
Containment of Soils is Fully Protective. The National Oil and
Hazardous Substances Pollution Contingency Plan ("NCP") states
that "EPA expects to use 'treatment to address the principal
threats posed by a site, wherever practicable' and 'engineering
controls, such as containment, for waste that poses a relatively
low long-term threat.1" 40 CFR Section 300.430(a)(1)(iii).
EPA's guidance document, "A Guide to Principal Threat and Low
Level Threat Wastes" (OSWER 9380.3-06FS, November, 1991), defines
principal threat wastes as those source materials considered to
be highly toxic or highly mobile which pose a potential risk of
10~3 or greater. According to the guidance, low-risk wastes with
risks less than 10"3 can be reliably contained and would present
only a low risk in the event of release.
Thus according to EPA's own guidance, containment of soils at the
Site would be protective, since the Site soils fall within EPA's
definition of low-risk wastes. The Proposed Plan is inaccurate
when it states that "Alternatives 6 through 9 are more protective
than the other alternatives" since Alternative 2 through 5 and 10
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have elements of containment and treatment which isolate or
remove low-risk soils and prevent exposure.
Containment has been selected by EPA at many other sites as
meeting the requirements of the NCP and being fully protective
(at least 50 sites involve containment in the available ROD data
base). Specific examples where EPA has selected containment
include the Peak Oil/Bay Drums site in Brandon, Florida, where
ex-situ stabilization and solidification were selected to address
lead in soil, followed by on-site containment. It is noteworthy
that in the Peak Oil ROD, EPA made the following statement:
"Based on the industrial character of the facilities surrounding
the Bay Drums site and the expectation that the area will remain
industrial in the future, EPA determined that a cancer risk of
10~4 for a current worker scenario is appropriate for the site."
Peak Oil ROD, Operable Unit 3, at 44 (1993).
Selected other RODs for which EPA has chosen containment as part
of the remedy include .the Laskin Poplar Oil Site (Ohio), the Old
Inger Refinery (Louisiana, refinery waste reclamation), the Swope
Oil and Chemical Site (New Jersey, oil and chemical reclamation),
the Waste Disposal Inc. Site (California), the Purity Oil Site
(California), and the Sharon Steel Site (Utah). In the Laskin
Poplar Site ROD, EPA states that "[i]n the judgement of the U.S.
EPA, the principal threat at the site is being addressed by the
treatment portion of the Source Removal Operable Unit with a
remedial action that primarily contains the remaining
contaminants." Id. at 38. EPA's selected remedy for the Old
Inger Refinery Site, a former refinery waste reclamation
facility, also incorporated on-site treatment of heavily impacted
soils and water (land treatment and carbon adsorption) while
using containment for "slightly contaminated soils" which would
"provide adequate protection to public health and environment."
Id. at 20.
At the Swope Oil and Chemical Site, a RCRA cap was deemed
protective after excavation and off-site disposal of shallow soil
contaminated with solvents and PCBs. At the Waste Disposal Inc.
Site in California, contaminated soil will be consolidated under
a RCRA-equivalent cap and institutional controls will be used to
prevent exposure. At the Purity Oil Site in California,
containment was selected as part of the remedy to prevent
exposure to soils. At the Sharon Steel Site in Midvale, Utah,
after selective excavation and consolidation of soils, a five-
foot cap will be placed over the site. EPA has deemed the Sharon
Steel selected remedy (and contingency remedy of removal and off-
site disposal) "protective of human health and the environment."
Id., at 4.
These are just a few of the many NPL sites at which EPA has
determined that containment of low-risk soils is protective of
human health and the environment.
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The ESRC's preferred alternative, Alternative 10, includes
isolation of low-risk Site soils under a clean soil cap of 42
inches. This cap thickness was selected based on a typical frost
depth in the Salt Lake City area (approximately 30 inches) and
the typical practice under Salt Lake City building codes of
excavating approximately 12 inches below frost depth for utility
placement. A cap thickness of 42 inches thus would prevent
exposure under future typical building scenarios, to the maximum
anticipated depth of excavation; it is therefore protective, and
will not hinder future redevelopment of the Site.
Response
With respect to the selection of the remedy, see response to
comment 4.
67) Comment
EPA's Selected Soil Remedy (Thermal Desorption) is Not Warranted.
The cost and logistics of thermal desorption are not justified at
the Petrochem/Ekotek Site, because, as discussed above, the
calculated soil risks are already within EPA's defined acceptable
risk range and the soil is classified as low-risk material.
Because the soils do not currently present an unacceptable risk,
thermal desorption represents an excessive remedy that is more
than needed and is, therefore, not cost effective.
Further, thermal desorption will present short-term impacts to
the neighborhood such as visual disruption, increased traffic,
noise, and potential odors which are unnecessary. The Site is
located in an air quality non-attainment area, and even over the
relatively short time period of thermal desorption, there is the
potential for impacts to air quality.
Response
With respect to the selection of the remedy, see response to
comment 4.
68) Comment
LNAPL. The Proposed Plan is inaccurate in stating that 100%
removal of the LNAPL will be accomplished. The FS actually
states that "[d]irect excavation is anticipated to remove as much
of the LNAPL as feasible..." EPA must recognize the
uncertainties and changing conditions that may be encountered
under actual construction conditions in the field, and that "100%
removal" of the LNAPL is not possible due to the practicalities
of remediation. The direct excavation of LNAPL is only
envisioned as an effective means for capturing the majority of
the recoverable LNAPL in the areas of the Site where the greatest
mass of oil is located. The excavation of soils close to the
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water table will involve excavation of water along with the oil
and soil, and a dewatering pad will be required to allow drainage
of the water back into the excavation. The withdrawal of water
will create a hydraulic gradient toward the excavation, which
will tend to allow the LNAPL to move toward the excavation for
collection through skimming. This will also tend to make the
walls of the excavation unstable, constraining the design of the
excavation and making it essential to concentrate on that portion
of the LNAPL plume with the most recoverable oil per volume of
soil removed. The sides of the excavation will have to be sloped
and benched to provide the stability for an excavator to remove
the soil, and this will physically limit the area available for
excavation. Even with these design constraints, direct
excavation is still the most effective method for capturing the
greatest amount of recoverable LNAPL.
Response
EPA recognizes that 100% removal of the LNAPL is not technically
feasible, however, EPA believes that the use of percentages is a
good communication tool to present the goals of the LNAPL
removal. The use of these percentages in the Proposed Plan does
originate from the use of these percentages in the feasibility
study. The ROD discusses the techniques that will be used to
remove the LNAPL (e.g., trenches, skimming, direct excavation)
and also provides a definition of extractable LNAPL (e.g.,
extractable LNAPL is defined as measurable LNAPL greater than
0.02 ft in thickness).
The selected remedy, alternative 10, contains 100% of the removal
of the LNAPL. The goal of removing as much LNAPL as technically
feasible, or 100% of the LNAPL, will be fully described in the
development of the remedial design of the remedy.
69) Comment
Buried Debris. The ESRC's preferred alternative (Alternative 10)
addresses buried debris to an equivalent level as EPA's preferred
Alternative 7, and does so in a manner that provides flexibility
and cost-effectiveness. Both alternatives remove the buried
debris and soil over the concrete slab, and provide for either
on-site treatment or off-site disposal of the material. While
Alternative 7 provides costs for additional excavation to the
water table, with all excavation and removal activities conducted
under a vapor dome, Alternative 10 allows the remedial contractor
to explore beneath the concrete slab to determine exactly how
much additional material removal is necessary. The costs
presented for Alternative 10 reflect a contingency to allow for
all necessary excavation. The potential for odors will be
controlled under Alternative 10 with foam application, which is a
more cost-effective approach in the control of potential odors
and as protective as a vapor dome. Thus, with respect to the
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buried debris, the Proposed Plan is inaccurate in stating that
Alternative 10 does not achieve the same long-term effectiveness
and permanence as Alternatives 6 through 9.
Response
The cost estimates for Alternatives 7 and 10 differ in the buried
debris area with respect to the volume of LNAPL-saturated soil
that will be disposed in a TSCA-permitted landfill. Alternative
7 identifies 4,000 CY while -Alternative 10 identifies 2,000 CY of
LNAPL-saturated soil. This leaves the impression that
alternative 7 is addressing more of the waste than alternative
10. However, alternative 10 does include a contingency to
provide for further excavation. EPA agrees with the commenter
that alternative 10 includes the excavation of all soils within
the buried debris area that exceed the soil hot spot criteria
and/or are saturated with LNAPL. The remaining soils within the
risk range of 10"4 to 10"6 will be contained on-site beneath a 42
inch clean soil cover. The integrity of the cap relies upon
continued inspections and maintenance. Alternatives 6 through 9
treat all the contaminants within the buried debris and do not
rely upon further inspections or maintenance thus their
permanence and associated long-term effectiveness is greater than
alternative 10.
70) Comment
EPA Must Properly Consider Cost in Selecting Its Preferred
Alternative. In its Proposed Plan, EPA compares the remedial
alternatives set forth in the Feasibility Study with the 9
evaluative criteria set forth in the NCP. 40 CFR Part 300
(1994). EPA's regulations divide the NCP criteria into (1)
threshold criteria (protection of human health and the
environment, and compliance with applicable or relevant and
appropriate requirements ("ARARs")), (2) primary balancing
criteria (long-term effectiveness and permanence; reduction of
toxicity, mobility or volume through treatment; short-term
effectiveness; implementability; and cost), and (3) modifying
criteria (State and Community acceptance). 40 CFR 300.430. As a
threshold matter, any remedial alternative selected must provide
overall protection of human health and the environment and comply
with ARARs. The alternatives are then compared to the five
primary balancing criteria; in contrast to the threshold
criteria, a remedial alternative need not meet all of the
balancing criteria to be selected. As a final check on a
selected alternative, State and Community acceptance must be
considered.
As Figure 3 in the Proposed Plan indicates, EPA has determined
that both the Committee's preferred alternative, Alternative 10,
and the EPA selected alternative, Alternative 7, meet the NCP
threshold criteria. EPA also concludes that both Alternative 7
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and 10 meet the primary balancing criteria. EPA, however, has
gone beyond a determination of whether an alternative meets the
NCP requirements, it has used a check mark to denote compliance
and a plus sign for "full" compliance. There is no provision in
either CERCLA or the NCP for the distinction between a check mark
and a plus sign.
Once it is determined that an alternative meets one of the NCP
criterion, further comparison as to whether it meets the
criterion more or less than another alternative is an exercise in
subjectivity that does not further NCP cleanup objectives. This
is particularly true where, as here, the comparison does not
evaluate cost. EPA's Proposed Plan simply lists the estimated
cost for each of the alternatives, rather than attempting any
kind of comparison. However, a quick review of Figure 3 in the
Proposed Plan indicates that Alternative 10 is by far the most
cost effective of the ten alternatives. For $10.5 million less
than the EPA proposed remedy, all NCP criteria can be met. Thus,
at a minimum, the NCP cost criteria for Alternative 10 must be
weighed against Alternative 7. There is simply no evidence in
the Proposed Plan that this comparison was undertaken.
In selecting a cleanup alternative that is $10.5 million more
than an alternative that meets all NCP criteria, EPA has not only
failed to apply the cost primary balancing criterion, it has
ignored the dictate of CERCLA 121(b)(1) that requires remedies to
be cost-effective. The NCP specifies that once a remedial action
meets the threshold criteria (protects human health and the
environment, and meets ARARs), its cost effectiveness must be
determined. 40 CFR 300.430(f)(1)(ii)(D). Cost effectiveness is
determined by comparing long-term effectiveness, treatment, and
short-term effectiveness with cost. Id. EPA acknowledges that
both Alternative 7 and 10 provide long-term effectiveness,
treatment and short-term effectiveness. Alternative 10 is,
however, 63% less expensive than Alternative 7 -- it is clearly
more cost effective than Alternative 7. Yet EPA inexplicably
selected the more costly alternative with no attempt to address
the remedy's cost effectiveness. In fact, EPA's Proposed Plan
document is noticeably silent on the issue of cost effectiveness
or cost.
When all statutory criteria for remedy selection are considered,
including EPA's omitted cost effectiveness, Alternative 10 stands
out as the one remedy that in EPA's own analysis meets all NCP
criteria and is significantly less expensive than the other
alternatives, particularly the EPA preferred Alternative 7. As
the Court in Ohio v. EPA. 997 F.2d 1520 (B.C. Cir. 1993), stated,
"there is nothing in [CERCLA] Section 121 to suggest that
selecting permanent remedies is more important than selecting
cost-effective remedies." Id. at 1532. EPA must reconsider its
selection of Alternative 7 in light of the statutory and
regulatory emphasis on cost effectiveness, and its failure to
13-71
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consider or address those issues in the Proposed Plan.
Response
With respect to the selection of alternative 10 as the selected
remedy, see response to comment 4.
71) Comment
Alternative 10 Is Preferable to Alternative 7 When Pump and Treat
Concerns are Considered. Based on the text of EPA's draft
Proposed Plan it appears that EPA's rationale for ranking
Alternative 7 higher than Alternative 10 for the protectiveness
and ARARs threshold criteria, even though both meet the criteria,
is based on its determination that pump and treat is a more
effective ground water cleanup technology than intrinsic
bioremediation. However, as the foregoing comments well
evidence, the opposite is in fact true, and particularly so at
the Ekotek Site. Intrinsic bioremediation is the only
potentially effective ground water technology for cleanup of the
ground water whereas all of the evidence indicates that pump and
treat will not be effective. Thus, based on the EPA information,
it appears that Alternative 7 should receive a minus in the
protectiveness and ARARs column or, at a minimum, a check mark.
This revision, coupled with a true weighing of cost, would result
in Alternative 10 actually ranking higher than Alternative 7.
Response
With respect to the viability of a pump and treat system at the
Site, see response to comments 46 and 47. With respect to
bioremediation/attenuation, see response to comment 33.
72) Comment
Containment of Soils is Consistent with NCP Requirements.
Alternative 10 not only meets the NCP selection criteria, but it
complies with the NCP expectations criteria. The NCP identifies
the following relevant expectations that EPA "shall consider... in
developing appropriate remedial alternatives":
(A) EPA expects to use treatment to address the
principal threats posed by a site, wherever
practicable. Principal threats for which
treatment is most likely to be appropriate
include liquids, areas contaminated with high
concentrations of toxic compounds, and highly
mobile materials.
(B) EPA expects to use engineering controls, such
as containment, for waste that poses a
relatively low long-term threat or where
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treatment is impracticable.
40 CFR 300.430(a)(1)(iii).
Subsequent to promulgation of this regulation, EPA issued
guidance clarifying principal threats and low level threats.
EPA, "A Guide to Principal Threat and Low Level Threat Wastes"
(OSWER, Nov. 1991). This guidance clarifies that the low level
and principal threat distinction applies to source material such
as contaminated soil or floating product on ground water. While
the guidance states that no threshold risk level has been
established to equate to principal threat, it states that "a
potential risk of 10~3 or greater" would suggest treatment. In
general, principal threat wastes are liquids or highly mobile or
toxic wastes. Low level threat wastes, in contrast, are those
that generally can be reliably contained and
that would present only a low risk in the
event of release. They include source
materials that exhibit low toxicity, low
mobility in the environment, or are near
health-based levels.
Guidance at 2. An example provided in the Guidance of low level
threat waste is soil with contaminant concentrations that present
an excess cancer risk near the acceptable risk range. Id. at 2.
The excavated Site soils at Ekotek clearly fall within this
description. The overall excess cancer risk from Site soils,
before hot spot removal, is 1 X 10~5, which is not just near the
acceptable risk range, it is well within it. The more mobile
LNAPL at the Site will be removed and treated off-site, thus also
falling squarely within EPA's NCP expectations.
EPA's apparent disregard for its own regulations and interpretive
guidance in selecting a preferred alternative at the Ekotek Site
is nothing short of arbitrary and capricious. Alternative 10
presents an effective, safe, and efficient remedy that fully
complies with all statutory and regulatory criteria -- and is
$10.5 million cheaper than EPA's selected alternative.
Response
With respect to the selection of alternative 10 as the selected
remedy, see response to comment 4. As clarification, the
reasonable maximum exposure (RME) under an industrial scenario
from site soils is 9.75 X 10~5 and the RME under the residential
scenario from site groundwater is 7.99 X 10"4.
73) Comment
The Ekotek Cleanup Is An Opportunity for EPA to Demonstrate Its
Commitment to Superfund Reform. As the recent debates over
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Superfund reform (both administrative and legislative) evidence,.
one of EPA's main failings in implementing Superfund has been its
continued failure to consider cost in its remedy selection
process. While EPA gives lip service to cost and lists it as one
of the NCP evaluative criteria, it simply does not truly give
equal weight to cost in making its remedy decisions.
As discussed above, Figure 3 in the Proposed Plan illustrates
this. While the alternatives are ranked for six of the seven NCP
criteria, EPA did not rank the alternatives for cost. Yet to
provide a meaningful comparison, costs must also be weighed.
Those alternatives, including Alternative 10, with lower cost
estimates should be ranked higher under cost than those
alternatives with higher cost estimates, including Alternative 7.
It is not, as EPA indicates, a matter of comparing two
alternatives that both meet the NCP requirements with the
selected alternative simply doing a better job of meeting those
requirements; it is a matter of two alternatives that both meet
the requirements and one is significantly more cost effective
than the other by a factor of nearly three times.
Selection of Alternative 10 as a cleanup remedy for the Ekotek
Site would not only comply with all statutory requirements, it
would send a message that EPA is serious about its desire to
reform its implementation of Superfund, that it does not need
Congress to beat it over the head with the requirement that
remedies be cost effective, and that it intends to comply with
the NCP and CERCLA Section 121 in selecting cost-effective
remedies.
Response
With respect to the selection of alternative 10 as the selected
remedy, see response to comment 4.
13.2.17.4 Letter dated September 14, 1995 from the Ekotek Site
Remediation Committee (ESRC), submitted by the office of Holland
& Hart, Denise W. Kennedy, Common Counsel for the ESRC
74) Comment
On behalf of the Ekotek Site Remediation Committee, this letter
is a formal request that the United States Environmental
Protection Agency undertake an immediate investigation pursuant
to EPA's relevant statutory and regulatory authorities, including
but not limited to Sections 104 and 106 of the Comprehensive
Environmental Response, Compensation and Liability Act, as
amended, to identify and remediate the source of the
Trichloroethane ("TCA") that is migrating into the ground water
under the Ekotek Site from an upgradient source. As the August
28-29, 1995 workshop meeting indicated, any efforts to achieve
ground water cleanup at the Ekotek Site through inherent
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bioremediation or other means will be impeded and constrained by
this off-site source is addressed, it will continue to increase
the vinyl chloride levels being measured at the Ekotek Site. We
urge your immediate attention to this problem and request that
prompt emergency action be taken.
Response
EPA has exercised its authorities under CERCLA Section 104(e) to
make inquiries as to possible sources of the TCA; packages
describing the information available is currently being reviewed
by RCRA within EPA and the State of Utah; and the selected
remedy, alternative 10, includes enhanced-monitoring at the north
and northwestern portion of the Site to gain a better
understanding of the TCA's impact upon the Site remediation.
13.2.17.5 Letter dated October 23, 1995 from the Ekotek Site
Remediation Committee (ESRC), submitted by the office of Holland
& Hart, Denise W. Kennedy, Common Counsel for the ESRC
75) Comment
The following comments are submitted on behalf of the Ekotek Site
Remediation Committee (ESRC), and supplement those comments
submitted on September 8, 1995. The additional comments provided
herein relate to the reasonableness and practicality of the EPA's
selected cleanup plan (Alternative 7) for remediating the Ekotek
Site in Salt Lake City, Utah (Site). The ESRC continues to
believe that Alternative 7 is not only impractical to implement,
but would result in a lower level of protection at a
significantly higher cost when compared to Alternative 10, if it
were to be implemented. The ESRC respectfully requests,
therefore, that the EPA consider the advantages of Alternative 10
including the proposed enhancements and find in favor of using
the modified Alternative 10 for completing Site remediation.
Response
With respect to the selection of alternative as the selected
remedy, see response to comment 4.
7 6) Comment
Enhanced Alternative 10 Soil Remedy. Since the time of its prior
comments, the ESRC has met on several occasions with
representatives of the Capital Hill Community group to discuss
the cleanup remedies for the Site. In the course of these
discussions with the Community group, the Committee considered
ways of enhancing the soils portion of Alternative 10 to address
concerns with the remedy. For example, the thickness of the
clean soil layer on top could be increased (total layer of 6-7
feet), buffer zones could be created to ensure that the
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containment area is not breached by excavation on adjacent
properties. These augmentations to Alternative 10 would be
reasonable, practical, and cost effective ways to ensure
continued protectiveness of the soil remedy. Such an approach
would best accomplish the statutory and regulatory mandates of
CERCLA that cost effective protective remedies be chosen rather
than defaulting to the vastly more expensive remedy of thermal
desorption. This is particularly true here, where the
"contaminated" soils are within EPA's acceptable risk range, and
not in need of remediation.
Response
EPA appreciates the suggestions presented in this comment. The
suggestions, for the most part, concentrate on the aspects of the
cleanup that would enhance the attractiveness of the property for
redevelopment. EPA encourages ESRC to facilitate the
redevelopment of the property. As a committee that is made up of
numerous businesses, and by virtue of financing and performing
the RI/FS the committee understands the nature and extent of the
contamination, which places the committee in a unique situation
to influence redevelopment.
77) Comment
Cost Effectiveness of Soils Cleanup. As discussed at length in
our September 8, 1995 comments, the ESRC is greatly concerned
with the EPA's failure to consider cost in its selection of
Alternative 7. The extra cost of the EPA's Preferred Alternative
will not produce a corresponding health risk benefit. EPA's
selection of Alternative 7 is completely at odds with its newly
announced Superfund Administrative Reforms. These reforms
highlight the importance of selecting cost effective remedies,
with a new emphasis on cost reduction. Alternative 10 fits
squarely within the new EPA guidance on Administrative Reforms.
During discussions with the ESRC, the Capital Hill Community
group indicated that its concern with the soil cleanup was more a
concern for future site redevelopment and the "Superfund stigma"
forever associated with a site and not so much a concern about
adverse health risk. While we are sympathetic with the Community
group's concerns, we jointly recognized that since the community
will not be paying for any portion of the remedy, cost or cost
effectiveness is not the community's concern. There is no
incentive for any community group to even consider cost in
selecting its preferred cleanup remedy.
However, it is EPA's statutory (Section 121(a) of CERCLA) and
regulatory (40 CFR 300.430(e)(9)) mandate to consider cost and
cost effectiveness in remedy selection. For all of the reasons
set forth in these and the ESRC's prior comments. Alternative 10
13-76
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is the remedy that fits the selection criteria best and is one of
several that is categorized by the EPA as adequately protective
of human health and the environment. Community acceptance of
that remedy is then factored in after adequacy of the remedy and
costs have been considered. As the court in Ohio v. EPA, 997
F.2d 1520, 1533 (B.C. Cir. 1993) noted:
CERCLA requires the selection of remedial actions "that
are protective of human health," not as protective as
conceivably possible. A "risk range of 10"4 to 10"6
represents EPA's opinion on what are generally
acceptable levels." 55 Fed. Reg. 8716 (1990).
Although cost cannot be used to justify the selection
of a remedy that is not protective of human health and
the environment, it can be considered in selecting from
options that are adequately protective.
Where, as here, the potential health risk from the soils is very
minimal (and within EPA's acceptable risk range), the preference
of a Community group that is not concerned with cost cannot
override selection of a protective, cost effective remedy. There
is no incentive for a community group to ever accept anything but
the most expensive cleanup remedy.
In the ESRC's view, EPA's Brownfields initiative is an
appropriate way of dealing with the Community group's concerns
regarding a Superfund stigma at the Ekotek Site. To that end, we
have encouraged the City, County, and State to pursue Brownfields
redevelopment of the Site. The ESRC remains ready and willing to
assist in that effort.
Response
With respect to the selection of alternative 10 as the selected
remedy, see response to comment 4. With respect to the
Brownfields initiative, EPA would like to encourage ESRC
to facilitate redevelopment of the property for the reasons
specified in the response to comment 76. Redevelopment must be
compatiable with and not interfere or reduce the protectiveness
of the selected remedy.
78) Comment
Additional Groundwater Investigation. During discussions on
September 28, 1995, between the ESRC's technical experts on
intrinsic bioremediation and EPA's experts, the ESRC agreed to
undertake two additional projects to further support the
selection of intrinsic bioremediation as the most effective
groundwater remedy. These two actions are as follows:
A. The generally accepted biogeochemical indicators of
bioremediation (e.g., redox, dissolved oxygen, dissolved organic
13-77
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carbon, methane, sulfate/sulfide, etc.) would be plotted in
comparison with contaminant concentrations, on the same map,
using various colors, to help define active areas of
bioreduction. Because this task can be done with the existing
data, the ESRC has begun this effort and will submit the results
to EPA when completed.
B. The ESRC will make a more exhaustive effort to detect ethene
and ethane. . This time a larger sample volume (160 ml or larger)
will be used to lower the detection limit to a point where these
substances may be detectable. Any detection of ethene or ethane
(the breakdown products of vinyl chlorine) in the reducing zone
will positively demonstrate that bioremediation is occurring at
the Site. Such a demonstration will (l) provide proof of vinyl
chlorine transformation, and, (2) conclusively support the
selection of bioremediation as the ground water remediation
procedure of choice at the Site. However, the inability to
detect ethene or ethane, because the vinyl chloride from which
those substances are derived is at such a low concentration in
ground water to begin with, will not alter the ESRC's position
regarding the use of bioremediation at the Site.
Following the completion of the above work, the ESRC has agreed
to meet with the EPA and its experts to discuss the findings.
Response
EPA engaged in discussions with ESRC for the purpose of
developing an approach to quantify the rate of bioremediation of
vinyl chloride within the contaminated ground water plume beneath
the Site. The comment describes the first two steps of the
approach. The steps described in the comment are expected to
determine whether the degradation products (e.g., ethane and
ethene) of the vinyl chloride exist at the site. The next steps,
not discussed in your comment, quantify the degradation rate.
The quantification of bioremediation is necessary to determine
whether bioremediation/attenuation is comparable to an active
restoration system. The selected remedy, alternative 10,
includes a pilot study that quantifies the degradation rate of
vinyl chloride to ethane and ethene.
79) Comment
Flexible ROD. While the alternatives set forth in the
Feasibility Study represent the ESRC's best efforts to quantify
and estimate cleanup methods and costs, based on the data
gathered to date, there remains uncertainty about certain Site
conditions. These uncertainties could significantly affect
remediation actions during actual cleanup operations. It is,
therefore, important that EPA's Record of Decision (ROD)
recognize the uncertainties inherent in Site conditions and the
ultimate impact they may have as field work progresses. The
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remedy description in the ROD should not be written in such a
manner that specified details unnecessarily constrain field
activities and the need to make immediate on-site decisions
during remediation.
One example of the need for flexibility has to do with reasonable
recovery of the floating product on the groundwater (LNAPL). The
exact subsurface extent and volume of the LNAPL is not precisely
known. It is likely that portions of the LNAPL plume are nothing
more than a mere sheen on the groundwater. Because of the
extensive soil excavation required to reach the LNAPL, it is
vitally important that the portion of the ROD dealing with LNAPL
removal recognize a reasonable level of recovery rather than
dictate a mandatory cleanup procedure or level.
A second area of uncertainty is the buried debris. The
Alternative 6 and 7 buried debris remedies are costed for full
excavation down to the groundwater. However, Alternative 10
recognizes that future investigation below the concrete slab may
indicate that only partial or no excavation is necessary. The
ROD needs to recognize the need for flexibility to make common
sense determinations as excavation is occurring beneath the
concrete slab in the buried debris area. This can be
accomplished by either selection of the buried debris portion of
Alternative 10, or building that same flexibility into the buried
debris alternative that is selected.
While these are but two examples, it is clear that the ROD for
any excavation and cleanup of the magnitude planned at the Ekotek
site that the ROD must be written (regardless of which cleanup
alternative is selected) to allow maximum flexibility in all
field decisions.
Response
While EPA appreciates the suggestions for flexibility in the ROD,
EPA policy requires an enforceable ROD that removes ambiguity
regarding EPA's expectations of the cleanup.
80) Comment
EPA De Minimis Settlement Funds. One attendee at the July 26,
1995 public meeting asked whether EPA intended to refund any of
the de minimis settlement monies it had received. For strong
public policy reasons, the ESRC believes EPA should not begin
down the slippery slope of refunding money collected on de
minimis settlements.
First, the issue is premature. The cost estimates used in the
Feasibility Study and subsequent Proposed Plan are nothing more
than rough estimates. Actual cleanup costs will not be known for
some time. As discussed above, there are many uncertainties
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associated with cleanup and any one of these could dramatically
increase estimated cleanup costs.
Second, each of the parties that chose to settle with EPA had the
option of joining the ESRC and taking' the risk that ultimate
cleanup costs would be less than estimated by EPA. The De
Minimis Settlement Administrative Order on Consent clearly does
not provide for refunds, nor would any party inquiring about
refunds have been led to believe that refunds would be issued.
De minimis settlement opportunities at Superfund Sites,
particularly those issued pre-ROD as is the case with Ekotek
Site, are designed to allow parties to settle out early on with
the risk that on a per gallon basis they may end up paying more
than parties who participate in actual cleanup activities. It
would be highly unusual and unfair to refund money to de minimis
settlers and, in effect, credit to those parties, the benefits of
any cost savings achieved by the parties that participated in
final cleanup activities. Additionally, those parties remaining
involved in cleanup activities incur transaction costs not
reflected in any of the cleanup cost estimates. It is to reduce
the incurrence of transaction costs by de minimis parties that de
minimis settlements are designed to address - - not to ensure to
an absolute degree that each and every party involved at the Site
pays the same per gallon amount towards cleanup costs. For these
reasons, the ESRC encourages EPA to stand firm on its position
that refunds are not appropriate in the context of a de minimis
settlement.
Response
This issue is under consideration by EPA. Current law and EPA
policy do not provide for reopening of settlements for
reimbursement.'
13.2.18 EPA's Response to Comments from State of Utah,
Department of Environmental Quality, Division of Environmental
Response and Remediation, Kent P. Gray, Director dated
October 23, 1995.
81) Comment
UDEQ supports the EPA in the selection of alternative 7 as the
preferred alternative for the following reasons:
- UDEQ is not only concerned with industrial risks but
also with residential risks associated with the site,
notably risks associated with PAHs and PCBs in the
soils. These risks are associated with both current
and future use. There are currently approximately 30
homes in the adjacent Swedetown area. As with other
properties, UDEQ is concerned that future land use of
this site could change to a residential usage, similar
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to what occurred at other industrial areas in the Salt
Lake valley (i.e., Valley Smelters, Sandy Smelters,
Bingham Creek, etc.). As was explained in UDEQ
comments on the draft Remedial Investigation Report
(comments dated March 3, 1994), Salt Lake City is
experiencing phenomenal population growth in the
urbanized areas due to both native population growth
and to a great in-migration population movement. With
such population pressures, sections of the city which
are now industrial/commercial cannot necessarily be
assumed to be off-limits to further population
encroachments.
- Utah has a Total Petroleum Hydrocarbon (TPH)
guideline for soil remediation. This value is 10,000
ppm TPH for soils. The TPH guideline is currently a
"To Be Considered" (TBC) under CERCLA. UDEQ feels
strongly that on-site soils exceeding this value be
remediated.
- For soils, a permanent solution such as the one
outlined in EPA's alternative 7 must be preferred, both
by EPA guidelines, and by common sense. Any kind of
cap or landfill at the site would require operation and
maintenance in perpetuity, and would require
institutional controls. Because the protectiveness of
the remedy would depend on the effectiveness of
operation and maintenance and institutional controls,
it is inherently less protective than a permanent
remedy. See 40 CFR Part 300.430(e) (9) (iii) (A) , (C) ,
and (D).
- In addition, a cap or landfill at the site would
discourage beneficial property use after cleanup is
completed. UDEQ desires a site which will have a
beneficial property use after the cleanup is completed.
UDEQ does not want the Petrochem/Ekotek site to be a
repository of contaminated materials for an indefinite
future, thereby potentially placing limits on its
future use and economic viability.
- Nor would such an impediment to development be
consistent with EPA's new Brownfields initiative.
- The local governments (Salt Lake City and County)
support a more comprehensive cleanup, and support
alternative 7. Local citizens prefer removal of
contamination from the site, and do not want a
repository or landfill left on-site. See 40 CFR Part
300.430(e) (9) (iii) (I) .
- We support this alternative because it reduces the
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toxicity, mobility, and volume of contamination better
than any of the other alternatives, as is required by
the National Contingency Plan (NCP).
UDEQ does recognize that a permanent solution is a more expensive
one. Cost is not the only factor to be weighed, however. EPA
must also weigh other factors, including long-term effectiveness,
permanency, and community support. Given all of these factors,
EPA clearly has the discretion to select the more permanent
remedy in alternative 7.
UDEQ feels that alternative 7 offers the best cleanup for the
site, as this alternative proposes cleanup of the LNAPL-
contaminated soils, the Buried Debris-PCB area, contaminated
groundwater, and the on-site soils in a way that protects the
public health and the environment, and at a reasonable cost.
Response
With respect to the selection of alternative 10 as the selected
remedy, see response to comment 4. With respect to industrial
vs. residential exposure, alternative 10 through the prevention
of exposure to contaminated soils (i.e., underneath 42 inches of
clean soil) is protective for both the industrial worker and the
resident. While it is true that the integrity of the cap must be
maintained to ensure protectiveness, the depth of 42 inches of
clean soil provides a rigid protective layer against exposure.
Normal behavior by residents includes gardening and landscaping
to depths generally less than 24 inches. Institutional controls
would have to be imposed as to the drilling of wells or
construction practices that would bring the buried contaminated
soils to the surface, but these institutional controls should not
prohibit redevelopment of the Site. Such controls are included
in the selected remedy.
EPA has received notice of interest in the Site from three
individuals. One of the individuals provided a letter of
interest to EPA and the State.and stated that alternative 10
provided a greater incentive for redevelopment to him than
alternatives involving thermal desorption of the soils. Thus the
assumption that the alternative which treats the soils provides a
greater incentive for redevelopment than the alternative that
contains the soil underneath 42 inch cap may not apply to the
Petrochem/Ekotek Site.
13.2.19 Letters asking for Extensions to the Public Comment
Period
EPA received letters from (1) Salt Lake City Corporation, Sam V.
Souvall, District 3, Councilmember; (2) Paul B. Anderson
Consulting Geologist, Paul B. Anderson, CHNC TAG Advisor; and (3)
Capitol Hill Neighborhood Council, Eric Jergensen, Chairman,
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asking for an extension to the September 8, 1995 closure of the
comment period. EPA responded by extending the comment period to
October 23, 1995.
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Tables
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TABLE 2.3.1A
OBSERVED SPECIES/EVALUATED SPECIES
PETROCHEM/EKOTEK SITE
Evaluated in Ecological
Observed Species Risk Assessment
(Yes/No)1
Pigeon Yes
House Sparrows No
House Finches No
House Mice No
European Starlings No
Redtail Hawks No
Killdeer No
American Robin No
1 Species not evaluated in Ecological Risk Assessment were not observed feeding or drinking on site.
Also, lack of small mammals and habitat to support small mammal population eliminated evaluation of
observed raptors or other predators.
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TABLE 2.3.1B
VEGETATION SPECIES OBSERVED
PETROCHEM/EKOTEK SITE
Common Name
Scientific
Tree and Shrub Species
boxelder
Chinese sumac
elm
juniper
pear
plum
sycamore
Herbaceous Species
bull thistle
cheatgrass
common sunflower
curlycup gumweed
dalmation toadflax
dock
field bindweed
foxtail barley
kochia
orchard-grass
prickly lettuce
rabbitbrush
ragweed
rose
Russian thistle
sweetclover
vetch
Acernegundo
Ailanthus altissima
Ulmus sp.
Uniperus sp.
Pyrus communis
Prunus sp.
Platanus sp.
Cirsium vulgarme
Bromus tectorum
Helianthus annuus
Grindelia squarrosa
Linaria dalmatica
Rumex sp.
Convolvulus arvensis
Hordeum jubatum
Kochia scoparia
Dactylis glomerata
Lactuca serriola
Chrysothamnus nauseosus
Ambrosia sp.
Rosa sp.
Salsola pestifer
Melilotus sp.
Vicia sp.
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TABLE 4.3
FACT SHEETS FOR
PETROCHEM/EKOTEK SITE
Published Date
January 1990
April 1990
March 1991
September 1992
July 1993
October 1993
July 1995
Fact Sheet Title
Removal Action
Information Bulletin
Information Bulletin
Superfund Program
Community Health
Deminimis Settlement
Proposed Plan
Description
Brief description of debris
removal onsite.
Update of events on site
from December of 1989
Overall update, included
notice of 104Es
Brief description of
superfund program and its
applicability to
Petrochem/Ekotek Site
Update on effects of
community health from
onsite pollution.
Facts on deminimis
settlement with PRPs
Overview of the alternatives
evaluated for the proposed
cleanup remedy.
-------
TABLE 6.1.1.1 A
SUMMARY STATISTICS TABLE FOR ONSITE SURFACE SOILS
PETROCIIEM/EKOTEKSITE <
ANALYTE
EXT HYDROCARBONS (ppin)
TOTAL METALS (ppiii)
Antimony
Arsenic
iery Ilium
Cadmium
Chromium
Copper
^cad
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Vnnmlium
vlnngancsc
PCIfs (ppin)
Aroclor - 1254
Aroclor - 1260
PESTICIDES (ppin)
Altlrin
licta - BHC
ilclla - BHC
4,4' - ODD
Did, hin
inilosulliin 1
Imlusullan 11
Endosuiran Eiillnlc
Endrin kctonc
VOLATILE ORGANIC COMPOUNDS (p
Acetone
Benzene
2-Butnnonc
Chloromelhane
1 ,1-DichloicUinnc
Cis- 1 ,2-Dichloroethene
Elhyl Benzene
Mclhylene Chloride
Tctrachloroethcnc
Toluene
1,1,1-Trichlorclhanc
Trichlorocllicne
Tolal Xylcncs
FREQUENCY
op
DETECTION 2
52 / 60
19 / 60
46 /60
55 / 60
45 / 60
59 /60
60 / 60
60 / 60
28 / 60
55 /60
1 / 60
8 / 60
19 / 60
59 / 60
30 / 30
30 / 30
4 /60
18 / 60
1 / 11
1 / 11
1/11
1/11
2/11
1 / 11
1 / 11
1/11
1/11
ran)
25 / 30
/30
/ 30
/30
/ 30
/30
5 /30
14 / 30
3 / 30
16 / 30
2 / 30
2 / 30
12 / 30
RANGBOp
DETECTED
CONCENTRATION
6.9 - 160000
2.03 - 19
4.8 - 237
0.09 - 1.31
0.515 - 19
2.2 - 76
9.5 - 1080
7.1 - 2330
0.1 - 0.6
4 - 105
8.3 - 8.3
1 - 15
8 - 88
20 - 2170
10.4 - 42.8
130 - 495
3.75 - 16.9
0.735 - 92.2
0.1 - 0.1
0.11 - 0.11
0.008 - 0.008
0.014 - 0.014
0.0028 • 0.08
0.042 • 0.042
0.076 - 0.076
0.13 - 0.13
0.14 - 0.14
0.01 - 0.41
0.01 - 0.01
0.063 - 0.063
0.002 - 0.002
0.019 - 0.019
0.02 - 0.02
0.004 - 0.015
0.002 - 0.15
0.009 - 0.13
0.001 - 0.033
0.007 - 0.03
0.031 - 0.11
0.001 - 0.075
MEAN
13586
4.66
21
0.43
4.29
19
104
270
0.15
18
2.8
1.2
8
281
23
264
1.0
3.1
0.027
0.033
0.024
0.036
0.043
0.022
0.043
0.048
0.048
0.094
0.009
0.174
0.018
0.009
0.009
0.008
0.022
0.013
0.007
0.009
0.013
0.011
5TANPARP
tJEVIATlOtl
30769
3.96
34
0.33
4.39
16
155
348
0.14
17
1.1
2.0
13
342
8
111
2.6
12
0.026
0.031
0.018
0.022
0.025
0.012
0.023
0.034
0.036
0.091
0.005
0.110
0.011
0.006
0.006
0.005
0.034
0.023
0.007
0.006
0.019
0.014
UPPER
93 #
QNE-SIPED
CONF. UM.
20226
5.52
28.3
0.51
5.2
22.8
137
346
0.18
21.6
3.0
1.7
11.2
354
25.0
298
1.5
5.7
0.041
0.049
0.034
0.048 .
0.057
0.028
0055
0.067
0.068
0.122
0.010
0.208
0.021
0.011
0.010
0.009
0.033
0.020
0.009
0.011
0.019
0.016
EXPoaORfi
POINT
CONG.
20226
5.52
28
0.51
5.23
23
137
346
0.18
22
3.0
1.7
11.2
354
25.0
298
1.5
5.7
0.041
0.049
0.008
0.014
0.057
0.028
0.055
0.067
0.068
0.122
0.010
0.063
0.002
0.011
0.010
0.009
0.033
0.020
0.009
0.011
0.019
0.016
Page 1 of 2
-------
TABLE 6.1.1.1 A
SUMMARY STATISTICS TAHUC R)ll ONSITK SlIUKACK SOILS
riiTKOCIIKM/KKOTKKSITK '
lii'ptiii
FftfiQUBNcY RAGGED* MS* tiXpOStmii
Of * DBTBCTfcP STANPAUD oNU-SlPfiP POINT
ANAIrYTB . . jpptBCTlON « CONCENTRATIONS MEAN fc>#V|ATlQt4 CONfl. MM- CONc,
SKM1VOI,ATILIJ OROAN1C COMPOUNDS (p|mi)
Accnnplitlicne
Anllirnccnc
3cn/.o (n) Pyrenc
icnzo (b) Fluoranthcnc
I)cn7.n (g,h,i) pcrylcne
Icur.o (k) Fliininnthcne
lcn7.o(n)Anlhrnccne
lutylhcir/.ytplitlifllnle
)i-n-Bulylpl)thiilnle
^hiyscnc
)ilicn/. (n,h) Anlhrnccnc
)ibcii7.ofiiri\n
2,6-Dinitrololucnc
Iiis(2-Elhylhexyl) Phlhalntc
•luoranthcne
7luorene
Indcno (1,2,3-cd) Pyrcnc
2-Mclhylnnplilhnlcnc
^nplillinlcne
!3i-n-Oi;lyl Phllinlntc
i'liciiniitlircnc
Phenol
I'yrcne
1 ,2,4-Trichlorol)cn7.cnc
3 /47
4/47
6 / 47
\10 1 47
9 / 47
5 / 47
8 / 47
6 / 47
2 / 47
16 / 47
8 /47
1 /47
I /47
4 / 47
7 / 47
4 / 47
9 / 47
2 747
2 / 47
11/47
8 /i 47
1 / 47
9 / 47
1 /47
0.23 - 8.05
0.42 - 36.2
0.16 - 54.7
0.23 - 59.4
0.55 - 27.2
0.74 - 34.9
0.26 - 100
0.27 - 15
0.43 - 41.8
0.38 - 88
0.83 - 16
3.72 - 3.72
34 - 34
0.22 - 2
0.38 - 171
0.13 - 7.41
0.13 - 26
0.14 - 0.51
0.37 - 0.83
0.11 - 2.1
0.47 - 118
18.6 - 18.6
0.56 - 170
11.4 - 11.4
9.1
9.7
10.3
10.1
10.0
9.8
10.8
8.4
10.6
9.2
9.2
9.0
9.5
10.0
12.8
9.1
9.4
8.9
9.0
9.0
11.3
9.4
12.9
9.2
16.1
16.6
17.4
17.7
16.4
16.5
20.9
13.5
16.4
18.5
16.1
16.1
16.6
15.9
28.5
16.1
16.3
16.2
16.2
16.0
22.6
16.2 .
28.4
16.1
13.1
13.8
14.5
14.5
14.0
13.8
15.9
11.8
14.6
13.7
13.2
13.0
13.5
13.9
19.8
13.0
13.4
12.9
12.9
12.9
16.8
13.3
19.8
13.1
8.05
13.8
14.5
14.5
14.0
13.8
15.9
11.8
14.6
13.7
13.2
3.72
13.5
2.0
19.8
7.41
13.4
0.51
0.83
2.1
16.8
13.3
19.8
11.4
DIOXINS/KUHANS (ppin)
TC«» (Till1) Cancer
TCIJD (TI'.F) Noncnnccr
HxCDD (Tolnl) Cnncer
7/7
7 / 7
7 n
1.08G-05 - I.OHH-04
1.4311-05 - 1.40IJ-04
3.3IE-05 - 3.23E-04
5.3111-05
6.4711 05
I.I7B-04
3.56H-05
4.42E-05
I.OIU04
7. 9215-05
9.72P.-05
I.9IU-04
7.9212-05
9.72U-05
1.9 112-04
^ TnMc tlcrvivcil from data in August 1994 Dnscline Human Hcnllh Risk Assessment.
2 Table includes onsitc surface samples OSI-OS4. Offsitc samples OS5-OS14 arc not included.
Page 2 of 2
-------
TABLE 6.1.1.IB
SUMMARY STATISTICS TABLE FOR REFERENCE SURFACE SOILS
PETROCHEM/EKOTEK SITE'
•UPPER.
FREQUENCY RANGE -0? 93% EXPOSURE
OF DETECTED . STANDARD . ONE-SIDED POINT
DETECTION2 CONCENTRATIO.N'S MEAN DEVIATION CGNRLJM, CONC.
EXT. HYDROCARBONS (ppm) 1 10 i 22.5 -22.5
4.5
6.32 8.17
8.17
TOTAL METALS (ppm)
Antimonv
Arsenic
Bcrvllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Zinc
Vanadium
Manganese
2 .' 10 ! 6.75 - 12.1
10 ; 10
10 / 10
10 / 10
10 / 10
10 / 10
10 /' 10
7 / 10
10 / 10
10 / 10
10 / 10
10 / 10
11.4 - 36.1
0.022 - 0.1
4.59 - 12.5
16.4 - 49.9
39.6 - 231
43.4 - 1150
0.105 - 0.291
6.43 - 16 1
149 • 2430
16.8 - 33.1
215 - 1050
3.485
18.03
0.0358
7.077
25.57
103.72
303.04
0.1415
11.479
611.9
21.77
387.5
3.38
8.10
0.023
2.71
11.0
69.1
321
0.084
2.71
694
5.23
238
5.44
22.7
0.049
8.65
32.0
144
489
0.19
13.0
1014
24.8
526
5.44
_22.7
0.049
8.65
32.0
144
489
0.19
13.0
1014
24.8
526
DIOXLXS/FURANS (ppm)
TCDDfTEF)
2 / 3
5.71E-07 - 1.33E-06
1.02E-06
4.00E-07
1.69E-06
1.33E-06
SEMIVOLATILE ORGANIC COMPOUNDS (ppm)
Benzo (a) Pvrene
Benzo (b) Fluoranthene
Benzo (gJu) pervlene
Benzo (k) Fluoranthene
Benzo(a)Anthracene
Chrvsene
Fluoranthene
Indeno (1.2,3-cd) Pvrene
Phenanthrene
Pvrene
1 / 10
i ; 10
1 / 10
1 / 10
1 / 10
1 / 10
1 / 10
1 ; 10
1 / 10
1 ' 10
1.2 - 1.2
1.4 - 1.4
0.9 - 0.9
0.9 - 0.9
1.4 - 1.4
1.5 - 1.5
2.8 - 2.8
0.9 - 0.9
2.4 - 2.4
2.7 - 2.7
0.345
0.365
0.315
0.315
0.59
0.375
0.505
0.315
0.465
0.495
0.300
0.364
0.206
0.206
0.285
0.395
0.806
0.206
0.680
0.775
0.519
0.576
0.434
0.434
0.755
0.604
0.972
0.434
0.859
0.944
0.519
0.576
0.434
0.434
0.755
0.604
0.972
0.434
0.859
0.944
' Table dervived from data in August 1994 Baseline Human Health Risk Assessment
: Found in offsitc reference surface soil samples OS5-OS14
-------
TABLE 6.1.1.1C
SUMMARY STATISTICS TABLE FOR ONSITE SUBSURFACE SOILS
PETROCHEM/EKOTEK SITE '
UPPER
FREQUENCY RANGE OF 95% EXPOSURE
OF pETECTED- STAXJDARD ONE-SIDED POINT
DETECTION' CONCENTRATIONS MEAN' DEVIATION CONF.UM. CONC,
EXT. HYDROCARBONS (ppm) • i -0 114
TOTAL ORGANIC CARBON (%) i 3S 45
70 - 203000 7688 25219
0.06 - 12.78 1.32 2.57
11608
1.96
11608 !
1.96 i
TOTAL METALS (ppm)
Antimony
.Arsenic
Bervllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Vanadium
23 113 j 1.17 - 41.9
?5 113
;:5 113
59 . 113
113 113
1.51 - 372
0.06 - 1.11
0.515 - 50.5
1.75 - 60.3
112 / 113 | 3.3 - 344
" - 113
r •' 113
104 , 113
3 / 113
11 / 113
:5 / 113
!3S / 113
65 , 66
Manganese 1 26/66
2.85 - 3880
0.103 - 2.8
1 - 980
4.52 - 15
1.1 - 11.2
1.24 - 36
9.97 - 2030
4.03 - 35.9
13 - 8823
4.02 4.60
14.2 35.6
0.39
3.46
13.7
25.9
116
0.13
20.7
2.68
1.00
6.46
116
20.0
349
0.24
5.40
9.29
50.0
427
0.28
91.4
1.55
1.07
8.64
298
8.77
1062
4.73
19.7
0.43
4.30
15.2
33.7
183
0.18
35.0
2.92
1.16
7.81
163
21.8
568
4.73 |
f9T7
0.43
4.30 I
15.2
33.7
183
0.18
35.0
2.92
1.16
7.81
163
21.8 1
568
PCBs (ppm)
Aroclor- 1232 1 / 113
Aroclor- 1260
11 .• 113
6.36 - 6.36
0.11 - 3.41
0.24
0.34
0.59
0.53
0.33
0.42
0.33
0.42
PESTICIDES (ppm)
Aldrin : ; 16
delta - BHC
1 / 16
Dieldrin i 5 / 16
Endosulfan I 2/16
gamma -BHC : / 16
Heptachlor epoxide . / 16
0.00095 - 0.00098
0.0011 - 0.0011
0.0034 - 0.02
0.00095 - 0.0012
0.0012 - 0.0012
0.0014 - 0.0014
0.0097
0.0104
0.0159
0.0106
0.0102
0.0168
0.0097 0.0106
0.0097
0.0099
0.0106
0.0104
0.0143
0.0149
0.0232
0.0143
0.0143
0.0145
0.00098
0.0011
0.02
0.0012
0.0012
0.0014 I
DIOXIN/FURAiN (ppm)
TCDD (TEF)
: / 4
2.30E-06 - 5.57E-05 | 1.64E-05
2.62E-05
4.72E-05
4.72E-05 1
VOLATILE ORGANIC COMPOUNDS (ppm)
Acetone Z5 . 79
Benzene .3 79
2-Butanone (MEK) 1 -! ' 79
Carbon Disulfide 5 . 79
Carbon Tetrachloride : 79
Chlorobenzene 1 9/79
Chloroethane
Chloroform
Chloromethane
1.1-Dichlorethane
1.2-Dichlorethane
1,1-Dichlorethene
: / 79
1 / 79
'. / 79
~ / 79
1 / 79
: ' 79
Cis-1.2-Dichloroethene 1 4/79
1 ,2-Dichloropropane
Ethvl Benzene
Methvlene Chloride
Stvrene
: ' 79
:i / 79
:4 / 79
; / 79
Tetrachloroethene | 11/79
Toluene 35 / 79
1.1,1-Trichlorelhantf ! : 79
Trichloroethene I ~ : 79
Total Xvlenes ! " ; 79
0.011 - 10
0.001 - 0.83
0.014 - 0.57
0.001 - 0.038
0.034 - 0.034
0.006 - 1.59
0.12 -0.12
0.019 - 0.019
0.033 - 0.033
0.004 - 0.72
0.36 - 0.36
0.1 - 0.1
0.019 - 0.061
0.04 - 0.04
0.001 - 5.46
0.002 - 0.93
0.035 - 0.035
0.007 - 2.S5
0.001 - 36.6
0.001 - 0.031
0.003 - 0.699
0.001 - 64
0.682
0.0485
0.354
0.217
0.0159
0.0677
0.0365
0.0283
0.0984
0.0600
0.0326
0.0503
0.0168
0.0286
0.271
0.0471
0.033
0.075
0.67
0.0283
0.0252
1.77
1.71
0.137
0.901
0.582
0.042
0.226
0.091
0.067
0.239
0.141
0.076
0.120
0.042
0.067
0.895
0.121
0.069
0.327
4.15
0.067
0.088
7.91
1.00
0.074
0.52
0.33
0.024
0.11
0.054
0.041
0.14
0.087
0.047
0.073
0.025
0.041
0.44
0.070
0.046
0.14
1.44
0.041
0.042
3.25
1.00 j
0.074
0.52
0.038 }
0.024
0.11
0.054
0.019
0.033
0.087
0.047
0.073
0.025 j
0.04 1
0.44
0.070 1
0.035
0.14
1.44
0.031
0.042
3.25 1
Page 1 of 2
-------
TABLE 6.1.1.1C
SUMMARY STATISTICS TABLE FOR ONSITE SUBSURFACE SOILS
PETROCHEM/EKOTEK SITE '
• •••.•. UPPEK
FREQUENCY RANGE OF 95% EXPOSURE
OF Q-ETECTED- STANDARD ONE-SIDED POINT
DETECTJON2 CONCENTRATIONS MEAN DENTATION CONT.LTM CONC,
SEMIVOLATILE ORGANIC COMPOUNDS fppmi
Acenaphthvlene : 85 | 1.9-39.5
Acenapthene 1 85 1 7S.5 - 78.5
.Anthracene : 85
Benzo (a) Pvrene 3 . 85
Benzo (b) Fluoranthene " ' 85
Benzo (gji,i) pervlene | S / 85
Benzo (k) Fluoranthene
Benzo(a)Anthracene
Butvlbenzviphthalate
Di-n-Butvlphthalate
2 / 85
5 / 85
2 I 85
3 / 85
bis(2-Chloroethvl) Ether 1 3/85
Chrvsene
11 .'85
Dibenz (aji) Anthracene . S / 85
Dibenzofuran 1 1/85
2,4-Dimethvlphenol
bis(2-Ethvlhexvl) Phthalate
Fluoranthene
Fluorene
Indeno (1,2.3-cd) Pvrene
2 -Methvlnaphthalene
2-Methvlphenol
4-Methvlphenol
: . 85
14 / 85
5 85
5 / 85
6 1 85
16 / 85
2 / 85
5 / 85
Naphthalene | 14-85
Di-n-octvl Phthalate 8/85
Phenanthrene
Phenol
Pvrene
15 / 85
: / 85
13 / 85
1.2,4-Trichlorobenzene 1 1 85
1.28 - 54.1
0.023 - 0.13
0.019 - 0.081
0.02 - 0.27
0.027 - 0.027
0.022 - 6.1
1.2 - 1.5
6.02 - 9.39
0.77 - 16.1
0.022 - 9.7
0.028 - 0.27
0.53 - 0.53
5.6 - 6.7
0.021 - 1.9
0.021 - 25.4
0.28 - 102
0.03 - 0.23
0.52 - 226
0.55 - 5.5
1.14 - 16.2
0.21 - 84.5
0.018 - 8.8
0.065 - 239
3.55 - 14
0.023 - 24
31.5 - 31.5
2.43
2.99
2.71
2.08
2.07
2.07
2.08
2.23
3.73
3.98
2.43
2.02
2.06
2.10
2.18
3.71
2.39
3.31
2.07
7.25
2.13
2.39
3.80
3.18
5.37
2.27
2.49
2.44
9.98
12.4
10.8
9.16
9.16
9.16
9.16
9.15
9.92
9.93
9.37
9.15
9.16
9.16
9.18
9.94
9.51
14.2
9.16
27.7
9.17
9.30
12.6
7.80
27.3
9.25
9.72
9.70
4.23
5.22
4.66
3.74
3.73
3.72
3.74
3.88
5.52
5.77
4.12 .
3.67
3.72
3.75
3.84
5.50
4.11
5.87
3.72
12.3
3.79
4.07
6.07
4.59
10.3
3.94
4.25
4.19
4.23
5.22
4.66
6713
0.08
0.27
0.03
3.88
1.50
5.77
4.12
3.67
0.27
0.53
3.84
1.90
4.11
5.87
0.23
12.3
3.79
4.07
6.07
4.59
10.3
3.94
4.25
4.19
1 Table dervived from data in August 1994 Baseline Human Health Risk Assessment.
" Found in all onsite subsurface soil samples
Page 2 of 2
-------
TABLE 6.1.1.3
SOIL/BURIED DEBRIS
EXCEED ANCE AREAS AND VOLUMES1
Location
:•" -:x;: ".•• '•• ' • • . •• • • : ; . . p;.-
PRO Exceedance Areas2
(Offsite and Onsite)
Debris Area
Former UST #2 Area
Hot Spot Criteria
Exceedance Areas3
Total Hydrocarbon Hot Spot
Area4
0-1 Foot
Area
(SY)
18,700
2,000
400
700
400
Volume
(CY) :•;
7,000"
600
100
200
130
1-5 Feet
Area
(SY).
5,000
2,000
100
Volume
(CY)
6,000"
3,000
200
--
5-20 Feet
Area
(SY)
1,000
2,000
500
Volume
(CY) :
7,000
10,000
2,000
--
Total
Impacted
Area (SY)
19,000"
2,000
700
700
400
Total
Volume
(CY) ;
20,000"
14,000"
2,300
200
130
" Approximate estimate.
1 Source: FS, January 1995.
2 Derived from Risk-Based concentrations exceeding a carcinogenic risk of 10E-6.
3 Derived from Risk-Based concentrations exceeding a carcinogenic risk of 10E-4.
4 Total Hydrocarbon Hot Spot includes soil/debris with TPH concentrations exceeding 100,000 ppm.
-------
TABLE 6.1.2.3
CALCULATED PARTITIONING OF CHEMICALS FROM FREE PHASE HYDROCARBON TO WATER1
Maximum Maximum Calculated Organic Caibon OctanoI/Water Fraction Fraction Calculated Maxiibuni Measured Maximum
Concentration Concentration Partition Partition Organic ReMdual Cbiitcentratibn Concentration
in Hydrocarbon in Soil (1) Coefficient (2) Coefficient (2) Carbon (3) Saturation (4) in Water (5) in Groundwater
Compound (Coll; rrtg/kR) (Csoil; fflj?/kft) (Koc; unitless) (Kow; unitless) (foe; unitlessj ^{fi^iiitfd^^v*^ (rag/1)
Aroclor-1242
Aroclor-1260
3enzene
Toluene
1 ,2-Dichlorobenzene
1 ,4-Dichlorubenzene
Ethylbcnzene
n-Propylbenzene
p-Isopropyltoluene
n-Butylbenzene
sec-Butylbenzene
Xylenes
1 ,2,4-Trimethylbenzene
1 ,2,5-Trimethylbenzene
Vinyl Chloride
1,1,1 -Trichloroethane
Tetrachloroelhylene
Naphthalene
Acenaphthene
Fluorcnc
I'henanthrene
Anthracene
Pyrene
Chrysene
48
116
2
14
198
29
21
37
118
90
73
166
366
55
0.48
0.13
0.41
181
50
85
175
30
87
24
10
23
0
3
40
6
4
7
24
18
15
33
73
11
0.096
0.026
0.082
36
10
17
35
6
17
5
5.1E+03
2.6E+06
l.OE+02
1.8E+02
1.7E+03
1.6E+02
2.6E+02
7.4E+02
2.5E+03
8.9E+02
1.6E+03
3.7E+03
1.6E+03
2.5E+00
1.3E+02
3.0E+02
3.3E+03
1.8E+01
5.0I-+03
3.9E+04
8.5E+04
1.7E+05
2.5E+05
1.3E+04
8.1E+06
1.6E+02
6.3E+02
2.7E+03
4.2E+03
1.4E+03
5.2E+03
4.4E+04
1.7E+04
1.6E+03
6.0E+03
2.6E+03
4.0E+00
2.2E+02
3.1E+02
5.0E+04
2.1E+04
2.4E+04
3.7E+04
3.5E+04
3.3E+05
8.1E+05
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.0308
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.20
0.20
3.5E-03
1.4E-05
1.2E-02
2.1E-02
6.7E-02
6.9E-03
1.5E-02
6.9E-03
2.0E-03
4.2E-03
9.1E-02
5.5E-02
1.9E-02
1.1E-01
5.5E-04
1.2E-03
3.6E-03
2.3E-03
3.4E-03
4.1E-03
6.3E-04
2.4E-04
2.8E-05
<2.0E-03
<2.0E-03
5.2E-03
6.5E-03
<5.0E-03
<5.0E-03
4.7E-03
<1.0E-02
<1.0E-02
<1.0E-02
<1.0E-02
1.8E-02
<1.0E-02
<1.0E-02
1.6E-01
1.6E-03
<5.0E-04
<5:OE-03
<5.0E-03
<5. OIi-03
<5.()E-03
<5.0E-03
<5.0E-03
<5.0E-03
(l)Csoil=foil*Coil
(2) Montgomery (1991)
(3) Median of measured concentrations
(4) Estimated based on Dragun (1988)
(5)Cw=foil*Coil/(foc*Koc+foil*Kow)
1 Source: March 1995 Sampling Data Packages from RUST
PARTCALC.XLS 12/1/95
-------
TABLE6.1.3.2A
SUMMARY STATISTICS TABLE FOR ONSITE GROUNDWATER FOR
1ST, 2ND. AND 3RD QUARTERS SAMPLING
ittttat
FREfgJENCY RANGE OF 95% EXPOSURE
OF DEJECTED- - STANDARD ONESIDED POJNT
ANALYJE DETECTION* CDNCKOTRA1K»® MEAN DEVIATION CONF.iiM CONC,
EXT. HYDROCARBONS (ppm) 5/40 05-16 0719
TOTAL METALS (ppm)
Antimony
Arsenic
Beryllium
Tgdniium
I^hronuurfl
Copper
vfanganese
vlercurv
Nickel
Selenium
Silver
rhallium
Zinc
2 / 40
31 / 40
1 / 40
1 / 40
4 / 40
1 / 40
14 / 18
6 / 40
4 / 40
1 / 40
3 / 40
3 / 40
5 / 40
00042 - 0.026
0.00313 - 0.15
00056 - 00056
0005 - 0005
001 - 0.35
0029 - 0029
0.03 - 0.41
000035 - 0.0204
001 - 0.05
017 - 0.17
0.078 - 0.27
0.1 - 0.2
0013 - 0.61
0.0025
00157
0.0004
0.0037
0.0172
00116
0.0978
0.0007
0.0179
0.0319
00187
0.0395
0.0342
2.53
0.0039
0.0258
0.0008
0.0013
0.0549
0.0221
01143
0.0032
00180
O.OZ37
0.0452
0.0361
0.1130
1.394
00035
0.0226
0.00061
0.0040
0.0318
00175
0.1447
0.0016
0.0227
0.0382
0.0307
0.0491
0.0642
1 394
0.0035
00226
0.0006
0.0040
0.0318
0.0175
0.1447
00016
0.0227
0.0382
0.0307
0.0491
00642
VOLATILE ORGANIC COMPOUNDS (ppm)
Acetone
taizene
Carbon Disulfide
Chloroform
,1-Dichlorethane
Cis 1,2-Dichloroethene
ithyl Benzene
Styrene
Toluene
1.1,1-Trichlorethane
Vinyl Chloride
Total Xylenes
1 / 40
9 / 40
12 / 40
1 / 40
15 / 40
5 / 32
1 / 40
1 / 40
2 / 40
2 1 40
8 / 40
3 / 40
0021 - 0.021
0.00052 - 00052
00021 - 0.017
0.0069 - 0.0069
00017 - Oil
0005 - 0.103
00047 - 0.0047
00019 - 00019
0.00065 - 00065
00016 - 0.00252
00016 - 0.16
0.001 - 0018
0.01440
0.00065
000751
0.00100
000866
0.00583
0.00081
0.00087
000143
000077
0.00647
0.00131
001003
0.00085
0.00555
0.00103
0.01929
0.01794
0.00080
000041
0.00138
0.00058
0.02514
0.00294
0.0171
0.00088
0.0090
0.00127
0.01380
0.01121
0.00103
000098
0.00180
0.00092
0.0132
0.0021
0.0171
0.0009
0.0090
0.0013
00138
0.0112
00010
00010
00018
00009
00132
00021
SEMTVOLATILE ORGANIC COMPOUNDS (ppm)
Acenaphthene
Benzo (b) Fluoranthenc
Sutylbenzylphthalate
bis(2-Chloroelhyl) Ether
Chrysene
1 ,2-Dichlorobenzene
,3-Dichlorobenzene
,4-Dichlorobenzene
bis(2-Ethylhexyl) Phthalale
rluoraie
2-Methylnaphthalene
Naphthalene
Di-n-octyl Phthalate
"henanthrene
1 / 40
2 / 40
2 / 40
1 / 40
1 / 40
5 / 40
1 / 40
2 / 40
1 / 40
1 / 40
1 / 40
2 / 40
1 / 40
1 / 40
00013 - 0.0013
00008 - 0.00089
00005 - 000061
0.0049 - 0.0049
0.00067 - 0.00067
0.00068 - 00051
0.00061 - 000061
000093 - 0.00094
00014 - 0.0014
0.0016 - 0.0016
00034 - 0.0034
00067 - 0.01
0.00068 - 0.00068
0.00063 - 000063
0.00129
000129
001140
0.00151
0.00127
0.00155
0.00127
0.00130
0.01167
0.00130
0.00134
0.00161
0.00128
0.00127
0.00112
0.00111
001246
000114
0.00113
0.00136
0.00113
0.00111
0.01221
0.00112
000117
0.00195
0.00112
0.00113
0.00159
0.00159
00147
0.0018
0.00157
0.00191
0.00157
0.00159
0.01493
0.00160
0.00165
0.00213
000158
0.00157
0.0013
0.0009
00006
0.0018
0.0007
0.0019
00006
0.0009
0.0014
0.0016
0.0017
0.0021
0.0007
00006
1 Table derrived from data in August 1994 Baseline Human Health Risk Assessment
2 Found in all onsite sampling wells excluding W-7. W-9, W-10, MW1. KW2 and MW3
-------
TABLE 6.1.3.2B
SUMMARY STATISTICS TABLE FOR GROUNDWATER COCS
DURING 4TH. 5TH. AND 6TH QUARTER SAMPLING
PETROCHEM/EKOTEK SITE
FREQUENCY RANGE OF
OF DETECTED STANDARD
DETECTION CONCENTRATIONS MEAN DEVIATION
TOTAL METALS (ppm)
Antimony
Arsenic
Beryllium
Manganese
Mercury
Nickel
Silver
Thallium
0 / 29
24 / 29
1 / 29
21/29
2 1 29
6 / 29
0 / 29
7 / 29
ND
0.0027 - 0.051
0.00066 - 0.00066
0.012 - 1.02
0.00027 - 0.0525
0.011 - 0.05
ND
0.007 - 0.008
~
0.013
0.00066
0.22
0.0264
0.038
~
0.0073
~
0.011
•—
0.297
0.037
0.016
—
0.00049
VOLATILE ORGANIC COMPOUNDS (ppm)
Benzene
Chloroform
Cis 1,2-Dichloroethene
Vinyl Chloride
0 / 31
2 / 31
2 / 31
1 / 31
ND
0.005 - 0.0133
0.0095 - 0.0103
0.0028 - 0.0028
—
0.0092
0.0099
0.0028
—
0.0059
0.00057
—
SEMTVOLATILE ORGANIC COMPOUNDS (ppm)
Benzo (b) Fluoranthene
0 / 16
ND
--
-
GWQ456.XLS 3/29/96
-------
TABLE6.1.3.2C
SUMMARY STATISTICS TABLE FOR GROUNDWATER COCS
FROM OCTOBER 1994 THROUGH AUGUST 1995'
PETROCHEM/EKOTEK SITE
FREQUENCY RANGEOF
OF \ DETECTED STANDARD
DETECTION CONCENTRATIONS MEAN DEVIATION
TOTAL METALS (ppm)
Arsenic
106/165
0.0011-0.098
0.02
0.02
VOLATILE ORGANIC COMPOUNDS (ppm)2
Benzene
Chloroform
Cis 1,2-Dichlororethene
Vinyl Chloride
18/165
18/165
34/165
45/165
0.00059-0.00213
0.00005-0.00931
0.00445 - 0.0120
0.00055-0.00103
0.00123
0.00212
0.00704
0.00341
0.00216
0.00341
0.00454
1 Data collected in Oct 94, Nov 94, Dec 94. Jan 95, Feb 95, March 95, May95, and August95.
2 Constituents are those that account for significant portion of risk or are biodegradation constituents.
KT.XLS
-------
TABLE7.1.4A
NONCARCINOGENIC RISKS FOR EACH COC AND SCENARIO
PETROCHEM/EKOTEK SITE
CHEMICAL
OF CONCERN
aldrin
antimony
arsenic
beryllium
chloroform
dichloroethene, cis-1,2
diedrin
manganese
mercury
nickel
silver
thallium (as chloride)
TOTALS
SOIL
INDUSTRIAL
RME
6.86E-02
6.86E-02
CTE
6.01E-02
6.01E-02
RESIDENTIAL
RME
5.01E-03
5.04E-02
3.69E-04
4.15E-03
5.13E-01
5.73E-01
CTE
1.79E-03
1.80E-02
1.32E-04
1.48E-03
1.83E-01
2.04E-01
GROUNDWATER
INDUSTRIAL
RME
8.60E-02
7.37E-01
1.19E-03
1.25E-03
1.10E-02
2.83E-01
5.15E-02
1.11E-02
6.01E-02
6.01E+00
7.25E+00
ClE
5.27E-02
4.52E-01
7.31E-04
7.64E-04
6.72E-03
1.74E-01
3.16E-02
6.81E-03
3.69E-02
3.68E+00
4.44E+00
RESIDENTIAL
RME
3.05E-01
2.61E+00
4.23E-03
4.42E-03
3.89E-02
l.OOE+00
1.83E-01
3.94E-02
2.13E-01
2.13E+01
2.57E+01
CTE
1.29E-01
1.11E+00
1.79E-03
1.87E-03
1.65E-02
4.26E-01
7.74E-02
1.67E-02
9.05E-02
9.04E+00
1.09E+01
CIIRSKNON.XLS
-------
TABLE7.1.4B
CARCINOGENIC RISKS FOR EACH COC AND SCENARIO
PETROCHEM/EKOTEK SITE
CHEMICAL
OP CONCERN
aldrin
arsenic
jenz (a)anthracene
Benzene
3enzo(a)pyrene
t)enzo(b)fluoranthene
benzo(k)fluoranthenc
beryllium
chloroform
dibenz(a,h)an(hracene
dieldrin
indeno( 1 ,2,3-c.d)pyrene
PCBs
vinyl chloride
2,3,7,8-TCDD (TEF)
HxCTM)
TOTAL
SOIL
INDUSTRIAL
RME
2.03E-06
1.85E-05
1.84E-06
1.68E-05
1.71E-06
5.03E-05
6.36E-06
9.75E-05
CTE
3.56E-07
3.25E-06
3.23E-07
2.94E-06
2.99E-07
3.14E-06
5.14E-07
1.08E-05
RESIDENTIAL
RME
8.07E-07
6.92E-06
6.13E-05
6.28E-06
6.01E-07
1.29E-06
5.72E-05
1.05E-06
5.82E-06
9.10E-05
1.32E-05
i.3in-or>
2.47E-04
CTE
5.87E-08
7.30E-07
6.66E-06
6.63E-07
6.34E-08
1.36E-07
6.03E-06
7.65E-08
6.13E-07
4.28E-06
8.25E-07
8.23E-08
2.02E-05
GROUNDWATER
INDUSTRIAL
RME
1.38E-04
8.91E-08
2.27E-06
9.15E-06
2.71E-08
8.75E-05
2.37E-04
CTE
1.69E-05
1.09E-08
2.78E-07
1.12E-06
3.33E-09
1.07E-05
2.90E-05
RESIDENTIAL
RME
3.40E-04
2.20E-07
5.59E-06
2.26E-05
6.68E-08
4.31E-04
7.99E-04
CTE
4.48E-05
2.89E-08
7.36E-07
2.97E-06
8.80E-09
5.67E-05
1.05E-04
rHRSKCAR.Xl.S
-------
TABLE 7.1.5
EXPOSURE ASSUMPTIONS AND POTENTIAL EFFECT ON EXPOSURE ASSESSMENT1
Exposure Assumption Enposwre
Potential Magnitude far
Exposure Exposure
Environmental Sampling and Analysis
Sufficient samples may not have been taken to characterize the media being evaluated
Low
Data collected were skewed towards the most contaminated areas Low
F.fTecLs on the quantitative risk of high detection limits for PAHs Moderate
Exposure Parameter Estimation
'ITie use of RME scenarios for receptor populations
'Hie use of CTE scenarios for receptor populations
Low
Low
Exposure Pathways
Selection of exposure pathways would not adequately characterize future land use Ix>w
Pathway Analysis
Assuming the risk to a potential receptor from contact with groundwater during showering is
equal to the risk for digestion of VOCs in groundwater, instead of using a model
Low
Low • I order of magnitude risk
Moderate I • 3 orders of magnitude risk
High ' orders ol magnitude
1 From Baseline Risk Assessment, August 1994.
UNCREA.XLS
12/1/95
-------
TABLE 7.2.2
SUMMARY OF ECOLOGICAL RISK ASSESSMENT
PETROCHEM/EKOTEK SITE
Chemical
,1,1 -Trichloroethane
Acetone
Tetrachloroethene
Trichloroethene
Vlethylene Chloride
3thylbenzene
Toluene
Xylenes
Trichlorobenzene
Mixed PAHs
Benzo(a)pyrene
Phalate Esters
4,4'-DDD
Aldrin
Dieldrin
Beta-Hexachlorocyclohexane
Delta-Hexachlorocyclohexane
Endosulfans
Endrin Ketone
Polychlorinated Biphenyls
Beryllium
Selenium
Silver
Thallium
Dioxins/Furans
On-Site Migratory Birds
COC
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
Risk Evaluation
Risk
Screening
—
—
—
—
—
—
—
—
—
—
X
—
—
—
—
—
—
—
—
X
X
—
—
X
X
Potential
Chronic Risk1
—
-_
—
—
—
—
—
—
—
—
X
—
—
—
— •
—
—
—
—
-_
—
—
—
X
X
Potential
Acute Risk1
—
-_
_-
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
--
Peregrine Falcons
COC
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
X
X
Risk Evaluation
Risk
Screening
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
-
Potential
Chronic Risk1
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
__
—
—
—
—
—
—
—
—
-
Potential
Acute Risk1
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
— .
—
—
—
—
-
1 - Potential substantial risk based on conservative assumptions.
X - Chemical retained as COC, retained for risk assessment, or potentially presents a risk.
— - Chemical not retained, etc.
ECORATBL.X1.S 6/5/96
-------
Table 8.4
Federal and State ARARs and TBCs for all the Alternatives
Page 1 of 21
Citation
Description
Evaluation
Chemical-Specific ARARs
Safe Drinking Water Act (42 use Sections 300f-300j-26)
40 CFR Part 141,
including Subparts B and G
40 CFR Part 141, Subpart F
40 CFR Part 143
Establishes health-based standards for public
drinking water systems (MCLs).
Establishes drinking water quality goals set at
levels of no known or anticipated adverse
health effects, with an adequate margin of
safety (MCLGs).
National Secondary Drinking Waster
Standards establish welfare-based standards
for public water supply systems.
These regulations are relevant and appropriate
because the shallow ground water beneath the
Petrochem/Ekotek Site is being used or may
be used in the future as a source of water for a
public water system or private supply wells.
Treated ground water from the treatment plant
would be injected into the shallow ground-
water system under alternative 8 . The
standards are relevant and appropriate
throughout the ground water for alternatives
1, 2, 3, 4, 5, 6, 7, 8, 9, and 10, and to the
treatment plant effluent at the point of
injection for alternative 8.
Non-zero MCLGs are relevant and
appropriate for alternatives 1, 2, 3, 4, 5, 6, 7,
8, 9, and 10, since ground water is in the
vicinity of the Petrochem/Ekotek site is being
used or may be used as a source of water for a
public water system or private supply wells.
The National Secondary Drinking Water
regulations are relevant and appropriate
because the shallow ground water at the
Petrochem/Ekotek site is being used or may
be used in the future as a source of water for a
public water system or private supply wells.
Federal Water Pollution Control Act (amended by the Clean Water Act, 42 USC
Section 7401, et seqj
40 CFR Part 403, Pre-Treatment
Standards
Establishes standards for discharge of toxic
pollutants to Publicly Owned Treatment
Works (POTWs).
This regulation is relevant and appropriate for
discharge being sent offsite to the local POTW
under alternative 7 and as part of the
contingencies. Pre-treatment is necessary if
standards are not met.
Solid Waste Disposal Act - RCRA Subtitle C (42 USC Section 6901, fit SŁq4
40 CFR Part 264, Subpart F
Sets ground water protection standards for
land disposal units and releases from solid
waste management units.
Alternatives 1, 2, 3, 4, 5, 6, 7, 8, 9, and 10
are relevant and appropriate because the site
operates like a hazardous waste management
(land disposal) unit. The State of Utah
operates an approved delegated program for
this portion of RCRA. See requirements
under Utah Solid and Hazardous Waste Act
and accompanying regulations.
-------
Table 8.4
Federal and State ARARs and TBCs for all the Alternatives
Page 2 of 21
Citation
Description
Evaluation
Toxic Substances Control Act (15 USC Section 2605)
40 CFR Part 761
Subpart G, PCS Spill Cleanup
Policy
Sets forth PCB Spill policy and disposal
requirements.
Spills and other uncontrolled discharges
of PCBs at concentrations of 50 ppm or
greater constitute the disposal of PCBs.
PCBs resulting from the clean-up and
removal of spills, leaks, or other
uncontrolled discharges, must be stored
and disposed in accordance with this
regulation. Alternatives 2, 3, 4, 5, 6, 7,
8, 9, and 10 address PCBs that spilled,
leaked, or were discharged during the
operation of the Petrochem/Ekotek
facility. All of the above alternatives will
be disposing PCBs in a permitted TSCA
landfill as part of the cleanup alternatives
therefore the requirement to clean up to
10 ppm in the soils is relevant and
appropriate for alternatives 2, 3, 4, 5, 6,
7, 8, 9, and 10.
Utah Water Quality Act (UCA Section 19-5-101, Łt seqj
UCA 19-5-101 and
UCA Section 19-5-107
Establishes the rulemaking and enforcement
authority for the regulation of water quality
with the Utah Water Quality Board.
This act makes it unlawful for any person
to discharge a pollutant into waters of the
State or to cause pollution that constitutes
a menace to the public health and welfare,
or is harmful to wildlife, fish or aquatic
life, or impairs domestic, agricultural,
industrial, recreational, or other beneficial
uses of water, or to place or cause to be
placed any wastes in a location where
there is probable cause to believe it will
cause pollution. This Act is applicable to
alternatives 1, 2, 3, 4, 5, 6, 7, 8, 9, and
10 at the Petrochem/Ekotek site in that
pollutants were discharged into the soils
and the ground water during operations of
the facility.
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Page 3 of 21
Citation
Description
Evaluation
Utah Water Quality Act (UCA 19-5-101, Łt seq.)
UAC R317-6, The Groundwater
Protection Rule
Establishes groundwater quality standards,
groundwater classes, and groundwater
class protection levels for the protection of
groundwater quality of the State.
Groundwater quality standards establish
numerical clean-up levels for
contaminated groundwater. These
standards are relevant and appropriate to
alternatives 1, 2, 3, 4, 5, 6, 7, 8, 9, and
10 at the Site to the extent there is
ongoing groundwater contamination.
UAC R309, Utah Drinking
Water Rules
These rules establish maximum
contaminant levels in public drinking water
systems within the State of Utah.
These levels are relevant and appropriate
because the shallow ground water beneath
the Petrochem/Ekotek Site is being used
or may be used in the future as a source
of water for a public water system or
private supply wells. Treated ground
water from the treatment plant would be
injected into the shallow ground-water
system under alternative 8. The standards
are relevant and appropriate throughout
the ground water for alternatives 1,2,3,
4, 5, 6, 7, 8, 9, and 10, and to the
treatment plant effluent at the point of
injection for alternative 8.
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Page 4 of 21
Citation
Description
Evaluation
Utah Air Conservation Act (UCA 19-2-101, et seq.)
UAC R307-1-1, and R307-1-3,
Utah Air Conservation Rules
Fugitive Dust Standard, R307-1-
3.1.8.AandR307-l-4.5.2,
U.A.C.
All Emissions subject to BACT,
R307-1-3.1.8.A, U.A.C.
Analysis for Degenerate Air
Quality, R307-1-3.1.8.B,
U.A.C.
These regulations constitute the legal bases
for control of air pollution sources in the
State of Utah. The National Ambient Air
Quality Standards (NAAQS) to protect the
public health and welfare. Standards have
been set for six pollutants: (1) paniculate
matter equal to or less than 10 microns
particle size; (2) sulfur dioxide; (3) carbon
monoxide; (4) ozone; (5) nitrogen dioxide;
and (6) lead. National Standards of
Performance for New Stationary Sources
(NSPS), National Prevention of Significant
Deterioration of Air Quality (PSD)
standards, and the National Emission
Standards for Hazardous Air Pollutants
(NESHAPS) also apply and are legally
enforceable in Utah.
The State of Utah air pollution regulations
are relevant and appropriate to the control
of fugitive dust and particulate emissions
at the site. The NAAQS standards are not
enforceable in and of themselves, rather it
is the emissions standards, which are
promulgated to attain the NAAQS, that
are directly enforceable and are ARARs.
Those standards and requirements
include, the fugitive dust standard; a
requirement that all emissions are subject
to BACT; and an analysis is required to
assure that any emissions will not cause
air quality to degenerate beyond any
pertinent level. All proposed remedial
technologies should be evaluated to
determine whether any New Source
Performance Standards may be considered
ARARs.
Utah Underground Storage Tank Act (UCA 19-6-401)
UAC R315-101, Utah Solid and
Hazardous Waste Rules (TPH
clean-up levels)
This regulation sets standards for cleaning
up total petroleum hydrocarbons (TPH).
This regulation, in combination with the
Division of Environmental Response and
Remediation's "Guidance for Estimating
Numeric Cleanup Levels for Petroleum-
Contaminated Soil at Underground Storage
Tank Release Sites" which is a TBC that
sets standards for cleaning up TPH.
Alternatives 2, 3, 4, 5, 6, 7, 8, 9, and 10
remove two 1 ,000 gallon underground
storage tanks in the former tank farm
area. In addition, all the alternatives
address the soils at the location of the
previously removed UST #2. Because the
waste at the site is sufficiently similar to
RCRA hazardous waste, the regulation is
relevant and appropriate to all alternatives
2, 3, 4, 5, 6, 7, 8, 9, and 10.
Chemical-Specific TBCs
ASTM ES 38-94, "Emergency
Standard Guide for Risk-Based
Corrective Action Applied at
Petroleum Release Sites"
Risk-based corrective action (RBCA) is a
generic term for corrective action
strategies that categorize sites according to
risk and move all sites toward completion
using appropriate levels of action and
oversight. ASTM's RBCA provides an
effective strategy for incorporating site-
specific data into a scientifically based
decision-making process to manage
Leaking Underground Storage Tanks
(LUST) sites.
This guidance integrates risk and
exposure assessment practices that mirror
EPA's risk assessment that was completed
at the Petrochem/Ekotek site. This
guidance is directly applicable such that
the TPH constituents cleanup goals for
soils shall be as specified in the soils
preliminary remediation goals
performance standards for alternatives 2,
3, 4, 5, 6, 7, 8, 9, and 10.
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Table 8.4
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Page 5 of 21
Citation
Description
Evaluation
Clean Air Act Section 109,
301 (a)
40 CFR Part 50
National Primary and Secondary Air Quality
Standards. Pursuant to the Clean Air Act
Section 109, EPA has promulgated National
Ambient Air Quality Standards (NAAQS)
for ambient air, to protect the public health
and welfare. Standards have been set for
six pollutants: (1) particulate matter equal
to or less than 10 microns particle size; (2)
sulfur dioxide; (3) carbon monoxide; (4)
ozone; (5) nitrogen dioxide; and (6) lead.
The NAAQS may be used as other criteria
or guidelines to be considered fTBC)
during operations of the excavation of the
soils and LNAPL, thermal desorption of
the soils and air sparging of the ground
water. The NAAQS are TBCs for
alternatives 2, 3, 4, 5, 6, 7, 8, 9, and 10.
Guidance for Estimating
Numeric Cleanup Levels for
Petroleum-Contaminated Soil at
Underground Storage Tank
Release Sites
This guidance establishes cleanup goals for
TPH.
For the Petrochem/Ekotek site, the
specified cleanup level is 100 mg/kg
TPH. The State of Utah is currently in
transition from the use of this guidance to
the adoption of RBCA therefore this
guidance may no longer be considered.
The hot spot criteria requires removal of
soil that exceeds 100,000 mg/kg TPH
levels.
Action-Specific ARARs
Solid Waste Disposal Act (42 USC Section 6901, et
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101,
Utah Solid Waste Management Act (UCA Section 19-6-501, et seq.)
40 CFR 241, Guidelines for the
land disposal of solid wastes
UAC R315-301: Solid Waste
Authority, Definitions, and
General Requirements
UACR315-302: Solid Waste
Facility Location Standards
UAC R315-303: Landfilling
Standards
UAC R315-304: Industrial
Solid Waste Facility
Requirements
UAC R315-305: Class IV
Landfill Requirements
UAC R315-307: Landtreatment
Disposal Standards
Establishes guidelines for the land disposal
of all solid waste materials and delineates
minimum levels of performance required of
any solid waste land disposal site operation.
Offsite disposal of wastes will occur at the
Petrochem/Ekotek site. The offsite
disposal of waste classified as solid waste
must comply with both the substantive
and administrative requirements of these
regulations pursuant to EPA's offsite
policy. This regulation is directly
applicable to alternatives 2,3, 4, 5, 6, 7,
8, 9, and 10. In addition, Part 241
requirements and cited State rules are
relevant and appropriate with respect to
the performance of the operations and
maintenance of soil covers under
alternatives 2, 3, 4, 5, and 10 which
leaves solid waste in place (e.g., the
debris area, contaminated soils
consolidated on-site).
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Page 6 of 21
Citation
Description
Evaluation
Solid Waste Disposal Act (42 USC Section 6901,
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101, fit seq.)
Utah Solid Waste Management Act (UCA Section 19-6-501,
40 CFR Part 257, Criteria for
Classification of Solid Waste
Disposal Facilities and Practices
UAC R315-301: Solid Waste
Authority, Definitions, and
General Requirements
UAC R315-302: Solid Waste
Facility Location Standards
Establishes criteria for use in determining
which solid waste disposal facilities and
practices pose a reasonable probability of
adverse effects on health or the environment
and thereby constitute prohibited open
dumps.
The Petrochem/Ekotek site has an area of
waste identified as buried debris. The
buried debris area and tank farm area
where waste will be consolidated and
covered (left in place) are subject to the
classification of solid waste and the
associated limits of release or exposure of
the solid waste with respect to flood
plains, endangered species, surface water,
ground water, production of crops,
disease, air and safety. This regulation is
relevant and appropriate to alternatives 1,
2, 3, 4, 5, 6, 7, 8, 9, and 10.
40 CFR Part 258, Criteria for
Municipal Solid Waste Landfills
UAC R315-303: Landfilling
Standards
Subpart E, Ground-Water
Monitoring and Corrective
Action
UAC R315-308: Groundwater
Monitoring Requirements
Subpart F, Closure and Post-
Closure Care
UAC R315-302: Solid Waste
Facility Location Standards
UAC R315-303: Landfilling
Standards
UACR315-304: Industrial
Solid Waste Facility
Requirements
Establishes design and operations criteria for
all new municipal solid waste landfills or
expansions of existing facilities; and sets
forth closure/post-closure requirements.
Alternatives 2, 3, 4, 5, and 10 partially
remove the solid waste located in the
debris area and caps the remaining debris
and consolidates and covers other waste
in the former tank farm area. This
regulation is relevant and appropriate for
alternatives 2, 3, 4, 5, and 10 for closure
and post-closure requirements.
40 CFR 260, Hazardous Waste
Management System: General
UACR315-1: Utah Hazardous
Waste Definitions and
References
UAC R315-2: General
Requirements - Identification
and Listing of Hazardous Waste
Establishes the definitions of terms, general
standards, and overview information
applicable to parts 260 through 265 and
268.
This regulation is applicable in as much as
the definitions and overview provided in
this regulation apply to the applicable or
relevant and appropriate sections of parts
260 through 265 and 268. See specific
information regarding parts 260 through
265 and 268 below.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
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Table 8.4
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Page 7 of 21
Citation
Description
Evaluation
Solid Waste Disposal Act (42 USC Section 6901, et
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101, et
40 CFR Part 261, Identification
and Listing of Hazardous Waste
UACR315-2-3: Definition of
Hazardous Waste
UACR315-2-4: Exclusion
UACR315-2-7: Residues of
Hazardous Waste in Empty
Containers
UACR315-2-9: Characteristics
of Hazardous Waste
UACR315-2-10: Lists of
Hazardous Waste
UACR315-2-11: Discarded
Commercial Chemical Products
UACR315-50: Appendices
Identifies those solid wastes which are
subject to regulation as hazardous wastes
under parts 124, 262, 263, 264, 265, 270,
and 271, and which are subject to the
notification requirements of section 3010
ofRCRA.
The classification of the waste will be
determined in the field for purposes of
proper offsite disposal and treatment. At
present, the soils at the site have not been
determined to be hazardous as defined by
subpart C, characteristics of hazardous
waste. However, the waste is a pollutant,
contaminant or hazardous substance that
presents a risk to human health and the
environment therefore the waste is
sufficiently similar such that RCRA
regulations are relevant and appropriate.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
40 CFR Part 262, Standards
Applicable to Generators of
Hazardous Waste
UACR315-5: Hazardous Waste
Generator Requirements
Establishes standards for RCRA generators
to include shipment of hazardous waste
from a treatment, storage, or disposal
facility; treatment, storage or disposal of
hazardous waste onsite; and compliance
requirements and penalties for persons
who generates a hazardous waste but do
not comply with this part.
The remediation activities at the
Petrochem/Ekotek site will generate waste
that will be sufficiently similar to RCRA
hazardous waste such that use of this
requirement is well suited to the situation.
The requirement is relevant and
appropriate to the ground water treatment
residuals (alternatives 4 and 8); soils and
debris excavated from the site (all
alternatives); waste generated during
construction activities for the treatment
facility as described in alternative 8; and
residuals, if any, from the thermal
treatment of soils and LNAPL in
alternatives 2, 3, 4, 5, 6, 7, 8, 9, and 10.
Alternatives 2, 3, 4, 5, 6, 7, 8, 9, and 10
include the shipment of sufficiently
similar hazardous waste to an offsite
facility and temporary storage of waste
during implementation of the remedies
thus this part is relevant and appropriate
to these alternatives.
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Table 8.4
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Page 8 of 21
Citation
Description
Evaluation
Solid Waste Disposal Act (42 USC Section 6901, el
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101, fit seqj
40 CFR Part 264, Standards for
Owners and Operators of
Hazardous Waste Treatment,
Storage, and Disposal Facilities
Subpart B, General Facility
Standards
UAC R315-8-2 (TSDFs):
General Facility Standards
Subpart C, Preparedness and
Prevention
UACR315-8-3: Preparedness
and Prevention
Subpart D, Contingency Plan
and Emergency Procedures
UACR315-8-4: Contingency
Plan and Emergency Procedures
Establishes minimum standards that define
the acceptable management of hazardous
waste for owners and operators of facilities
which treat, store, or dispose of hazardous
waste.
Alternatives 2, 3, 4, 5, 6, 7, 8, 9, and 10
perform treatment of the soils or soils
saturated with LNAPL; dispose of
hazardous waste offsite; and stores waste
during the implementation of the remedy,
remediates the ground water and
consolidates contaminated soils in the
former tank farm area for final disposal.
Because these remediation activities
constitute treatment, storage, and/or
disposal activities, the requirements of
this part are relevant and appropriate to
the various components of the alternatives
cited. Thus, site activities must meet
these standards, which include waste
analysis, site security,emergency control
and response equipment, personnel
training, contingency planning, and
implementation.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
40 CFR Part 264, Subpart F,
Releases from Solid Waste
Management Units
UACR315-8-6: Groundwater
Protection
Establishes requirements to detect,
characterize, and respond to releases to the
uppermost aquifer from a facility that
treats, stores, or disposes of hazardous
waste.
Alternatives 2, 3, 4, 5, and 10 contain the
debris area with a cover and alternatives
2, 3, and 10 consolidates waste in the
former tank farm area under a cover
thereby creating a waste management
unit(s). The design of the ground water
compliance monitoring program for the
detection of releases from the solid waste
management unit cited in the above
alternatives is relevant and appropriate, as
well as any corrective action that may be
necessary should the hazardous
constituents exceed the established
concentration limits specified in the
compliance monitoring program.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
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Page 9 of 21
Citation
Description
Evaluation
Solid Waste Disposal Act (42 USC Section 6901,
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101,
40 CFR Part 264, Subpart G,
Closure and Post-Closure
UACR315-8-7: Closure and
Post-Closure
Establishes requirements for the closure and
post-closure of facilities that treat, store or
dispose of hazardous waste.
Because excavation, consolidation and
containment via cover of contaminated
materials constitute disposal of a waste
that is sufficiently similar to RCRA
hazardous waste such that use of the
requirement is well suited to the situation,
the requirement is relevant and
appropriate to the activities described in
alternatives 2, 3, 4, 5, and 10. Because
the alternatives 2, 3, 5, 6, 7, 8, and 9
provide onsite treatment and temporary
storage of the wastes, this requirement is
relevant and appropriate. Closure and
post-closure care for the disposal areas
must meet these standards which include
removal of waste, waste residues,
contaminated system components, and
contaminated subsoils; or closure with
wastes and/or contamination in place with
containment systems and post-closure care
to include ground water monitoring and
inspection and maintenance on
containment and monitoring systems.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
40 CFR Part 264, Subpart I,
Use and Management of
Containers
UACR315-8-9: Use and
Management of Containers
Establishes operating and performance
standards for container storage of hazardous
waste and applies to owners and operators
of all hazardous waste facilities that store
containers of hazardous waste.
The ground water monitoring program,
and LNAPL recovery at the
Petrochem/Ekotek site is expected to store
hazardous waste at the site during the
implementation of alternatives 2, 3, 4, 5,
6, 7, 8, 9, and 10. The intrinsic
remediation/attenuation pilot study is
expected to produce large quantities of
contaminated waste that will most likely
be stored in a container under alternatives
2, 3, 5, 6, 9, and 10. Because the waste
is sufficiently similar to RCRA hazardous
waste, this regulation is relevant and
appropriate to activities involving storage
or temporary storage of contaminated
materials in containers which includes the
alternatives cited in this paragraph.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
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Citation
Description
Evaluation
Solid Waste Disposal Act (42 USC Section 6901, et
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101, fit seq4
40 CFR Part 264, Subpart J,
Tank Systems
UACR315-8-10: Tanks
Establishes operating and performance
standards for tank systems to include
closure and post-closure requirements.
This regulation applies to owners and
operators of facilities that use tank systems
for storage or treating hazardous waste.
Alternatives 2, 3, 4, 5, 6, 7, 8, 9, and 10
excavate two 1,000 gallon tanks from the
former tank farm area and may store
ground water in tanks if contingencies are
implemented. Because the waste is
sufficiently similar to RCRA hazardous
waste, this regulation is relevant and
appropriate to the activities involving
closure of the tanks.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
40 CFR Part 264, Subpart L,
Waste Piles
UACR315-8-12: Waste Piles
Establishes operating and performance
standards for waste piles to include closure
and post-closure requirements. This
regulation applies to owners and operators
of facilities that store or treat hazardous
waste in piles.
Alternatives 2, 3, 4, 5, 6, 7, 8, 9, and 10
all excavate soils and store soils onsite in
preparation for treatment or consolidation.
The manner in which the soils are stored
constitutes a waste pile. Alternative 9
utilizes land farming that may be
sufficiently similar to treatment using
waste piles that this regulation is relevant
and appropriate. Because the waste is
sufficiently similar to RCRA hazardous
waste, this regulation is relevant and
appropriate to the activities described
above, as well as to the closure and post-
closure of waste piles.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
40 CFR Part 264, Subpart M,
Land Treatment
UACR315-8-13: Land
Treatment
Establishes operating and performance
standards for land treatment units to
include closure and post-closure
requirements. The regulation applies to
owners and operators of facilities that treat
or dispose of hazardous waste in land
treatment units.
Alternative 9 utilizes land farming that
may be sufficiently similar to treatment
using land treatment units that this
regulation is relevant and appropriate.
Because the waste is sufficiently similar to
RCRA hazardous waste, this regulation is
relevant and appropriate to the activities
described above, as well as to the closure
and post-closure of land treatment units.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
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Citation
Description
Evaluation
Solid Waste Disposal Act (42 USC Section 6901,
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101,
40 CFR Part 264, Subpart N,
Landfills
UACR315-8-14: Landfills
Establishes operating and performance
standards for landfills to include closure
and post-closure requirements. The
regulation applies to owners and operators
of facilities that dispose of hazardous waste
in landfills.
Alternatives 2, 3, 4, 5, and 10 have
containment of remaining debris and
consolidate and contain waste onsite that
is sufficiently similar to landfilling.
Because the waste is sufficiently similar to
RCRA hazardous waste, this regulation is
relevant and appropriate to the activities
described above, as well as to the closure
and post-closure of landfills.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
40 CFR Part 264, Subpart O,
Incinerators
UACR315-8-15: Incinerators
Establishes operating and performance
standards for incinerators (includes thermal
treatment by definition) to include closure
requirements. The regulation applies to
owners and operators of facilities that
incinerate hazardous waste.
Alternatives 2, 3, 4, 5, 6, 7, 8, 9, and 10
have varying levels of thermal desorption
(a form of incineration, by definition in
40 CFR part 260) onsite. Because the
waste to be treated is sufficiently similar
to RCRA hazardous waste, the use of the
regulation is well suited to the situation,
therefore the requirements are relevant
and appropriate to the thermal treatment
components of the alternatives cited in
this paragraph.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
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Citation
Description
Evaluation
Solid Waste Disposal Act (42 USC Section 6901, et seqj
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101, ci siqj
40 CFR Part 264, Subpart AA,
Air Emission Standards for
Process Vents
UACR315-8-17: Air Emission
Standards for Process Vents
Establishes operating and performance
standards for air emissions from process
vents. The regulation applies to owners
and operators of facilities that treat, store,
or dispose of hazardous wastes and applies
to process vents associated with
distillation, fractionation, thin-film
evaporation, solvent extraction, or air or
steam stripping operations that manage
hazardous wastes with organic
concentrations of at least 10 ppm.
Alternatives 2, 3, 4, 5, 6, 7, 8, and 9
have varying levels of thermal desorption
which may have process vents and
because the gases that may be released are
sufficiently similar to RCRA hazardous
waste such that the use of the regulation is
well suited to the situation, the
requirement is relevant and appropriate to
the onsite thermal treatment system.
Alternatives 4 and 8 may include process
vents as components of air sparging/vapor
extraction and the treatment facility using
UV oxidation, respectively, in the
treatment of the ground water. These
ground water treatment systems must
meet these standards, which include
standards for process vents and test
methods and procedures, and are
therefore considered relevant and
appropriate requirements.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
40 CFR Part 265, Subpart P,
Thermal Treatment
UACR315-7-23: Thermal
Treatment
Establishing operating and performance
standards for thermal treatment. The
regulation applies to owners or operators
of facilities that thermally treat hazardous
waste in devices other than enclosed
devices using controlled flame combustion.
Thermal treatment in enclosed devices
using controlled flame combustion is
subject to the requirements of subpart O.
Alternatives 2, 3, 4, 5, 6, 7, 8, and 9
have varying levels of thermal desorption
(a form of incineration, by definition in
40 CFR part 260) onsite.
Whether the thermal desorption unit will
be an enclosed device using controlled
flame combustion or another type of
device will be determined during the
Remedial Design. Therefore, this
regulation will be considered relevant and
appropriate if the thermal desorption unit
incorporates any device other than an
enclosed device using controlled flame
combustion which shall be governed by
the requirements of subpart 0. Because
the waste to be treated is sufficiently
similar to RCRA hazardous waste, the use
of the regulation is well suited to the
situation, therefore the requirements are
relevant and appropriate to the thermal
treatment components of the alternatives
cited in this paragraph given the
conditions described.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
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Citation
Description
Evaluation
Solid Waste Disposal Act (42 USC Section 6901, ei segj
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101, et seqj
40 CFR Part 265, Subpart Q,
Chemical, Physical, and
Biological Treatment
UACR315-7-24: Chemical,
Physical, and Biological
Treatment
Establishes operating and performance
standards for chemical, physical, and
biological treatment. The regulation
applies to owners and operators of
facilities which treat hazardous wastes by
chemical, physical, or biological methods
in other than tanks, surface
impoundments, and land treatment
facilities.
Alternative 8 uses chemical/physical
treatment of ground water via UV
oxidation in a treatment facility that is not
considered a tank, surface impoundment
or land treatment facility. Alternative 4
uses physical treatment of ground water
via air sparging/vapor extraction which
will not use a tank, surface impoundment
or land treatment facility. Alternatives 2,
3, 5, 6, 9 and 10 may use enhancements
to the biological treatment of the ground
water via intrinsic remediation/attenuation
which will not occur in a tank, surface
impoundment or land treatment facility.
Because the chemical, physical and
biological treatment is sufficiently similar
to RCRA hazardous waste such that the
use of the requirement is well suited to the
situation, the requirement is relevant and
appropriate to the alternatives cited in this
paragraph.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
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Table 8.4
Federal and State ARARs and TBCs for all the Alternatives
Page 14 of 21
Citation
Description
Evaluation
Solid Waste Disposal Act (42 USC Section 6901, et
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101, et seqj
40 CFR Part 267, Interim
Standards for Owners and
Operators of New Hazardous
Waste Land Disposal Facilities
Establishes standards for new hazardous
waste land disposal facilities. The
regulation applies to owners and operators
of new hazardous waste landfills, surface
impoundments, land treatment facilities
and individually permitted Class I
underground injection wells.
Alternatives 2,3,4, 5, and 10 have
containment of remaining debris and
consolidates and contains waste onsite that
is sufficiently similar to landfilling and
associated ground water monitoring.
Because the waste is sufficiently similar to
RCRA hazardous waste, this regulation is
relevant and appropriate to the activities
described, as well as to the closure and
post-closure of landfills.
Alternative 9 utilizes land farming that
may be sufficiently similar to treatment
using land treatment units so that this
regulation may be relevant and
appropriate. Because the waste is
sufficiently similar to RCRA hazardous
waste, this regulation is relevant and
appropriate to the activity described
above, as well as to the closure and post-
closure of land treatment units.
Alternative 8 injects the treated ground
water into the aquifer which is sufficiently
similar to Class I underground injection
wells. Because the waste is sufficiently
similar to RCRA hazardous waste, this
regulation is relevant and appropriate to
the activity described.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
58 Federal Register 8658
40 CFR Part 264, Subpart S,
Corrective Action Management
Units (CAMUs)
Permits the agency to establish a
Corrective Action Management Unit
(CAMU) or units at CERCLA remedial
sites.
EPA has designated the
Petrochem/Ekotek Site as a CAMU.
Because the waste is sufficiently similar to
RCRA hazardous waste, the requirement
is relevant and appropriate to the
activities.
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Table 8.4
Federal and State ARARs and TBCs for all the Alternatives
Page 15 of 21
Citation
Description
Evaluation
Solid Waste Disposal Act (42 USC Section 6901, et seq.)
40 CFR Part 280, Technical
Standards and Corrective Action
Requirements for Owners and
Operators of Underground
Storage Tanks (UST)
UAC R311-202: UST Technical
Standards
UAC R311-207: Assessing the
PST Fund for LUSTs
UAC R311-211: Corrective
Action Clean-up Standards for
CERCLA and UST Sites
Establishes technical standards and
corrective action requirements for
underground storage tanks. The regulation
applies to all owners and operators of an
underground storage tank system.
Alternatives 2, 3, 4, 5, 6, 7, 8,
9, and 10 remove two 1,000
gallon underground storage tanks
in the former tank farm area. In
addition, all the alternatives
address the soils at the location of
the previously removed UST #2.
Because the waste at the site is
sufficiently similar to RCRA
hazardous waste, the regulation is
relevant and appropriate to
alternatives 2, 3, 4, 5, 6, 7, 8, 9,
and 10.
The State of Utah has an
approved, delegated program
under RCRA for these
requirements.
Federal Water Pollution Control Act (amended by the Clean Water Act)
Utah Water Quality Act (UCA Section 19-5-101,
40 CFR Part 122, EPA
Administered Permit Programs:
The National Pollutant Discharge
Elimination System (NPDES)
Establishes requirements for stormwater
discharges related to industrial activity.
Stormwater runoff, snow melt runoff, and
surface runoff and drainage associated with
remedial actions which discharge to
surface waters shall be conducted in
compliance with RCRA, FWQC, CWA
technology-based standards and best
management practices.
Although none of the alternatives
have a discharge component as
part of the remedies, stormwater
discharges may occur during the
implementation of the remedies
(e.g., runoff discharge from the
open trenches or open excavation
of the LNAPL during
precipitation event). Therefore,
the stormwater discharges limits
must be meet which include
sampling, analysis, and treatment
requirements. Because the waste
at the site is sufficiently similar to
wastes regulated by NPDES
permits, this regulation is
relevant and appropriate to the
activities described in this
paragraph.
The State of Utah has an
approved, delegated program for
these requirements.
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Table 8.4
Federal and State ARARs and TBCs for all the Alternatives
Page 16 of 21
Citation
Description
Evaluation
Utah Hazardous Substances Mitigation Act (UCA 19-6-301,
UACR315-101: Clean-up
Action and Risk-Based Closure
Standards for RCRA Sites
Establishing clean-up standards for
remedial decisions using risk analysis, and
management for RCRA corrective action
sites.
Because site is not being clean-closed, as
defined by the rule, requires appropriate
site management.
Toxic Substances Control Act (15 USC 2625 and 2665)
40 CFR Part 761
Subpart G, PCB Spill Cleanup
Policy
Sets forth PCB Spill policy and disposal
requirements.
PCBs resulting from the clean-up and
removal of spills, leaks, or other
uncontrolled discharges, must be stored
and disposed in accordance with this
regulation. Alternatives 2, 3, 4, 5, 6, 7,
8, 9, and 10 address PCBs that spilled,
leaked, or were discharged during the
operation of the Petrochem/Ekotek
facility. All of the above alternatives will
be disposing PCBs as part of the cleanup
alternatives thus the requirement to clean
up to 10 ppm in the soils is relevant and
appropriate for alternatives 2, 3, 4, 5, 6,
7, 8, 9, and 10.
Safe Drinking Water Act
40 CFR Part 144, Underground
Injection Control Program
Part 145, State UIC Program
Requirements
Part 146, Underground Injection
Control Program: Criteria and
Standards
Part 147, State Underground
Injection Control Programs
Establishes standards for construction and
operation of injection wells. Provides for
protection of underground sources of
drinking water.
Alternative 8 reinjects treated water into
the aquifer beneath the Petrochem/Ekotek
site. The requirements of this regulation
is applicable to alternative 8. The
requirements include constructing,
operating, and maintaining a well in a
manner that does not result in
contamination of an underground source
of drinking water at levels that violate
MCLs or otherwise affect the health of
persons. These requirements will be met
by ensuring the effluent from the ground
water treatment facility under alternative 8
meets standards that are protective of
human health (based on MCLs and risk-
based concentrations).
The State of Utah has an approved,
delegated program for these requirements.
-------
Table 8.4
Federal and State ARARs and TBCs for all the Alternatives
Page 17 of 21
Citation
Description
Evaluation
Clean Air Act
40 CFR Part 60, Standards of
Performance for New Stationary
Sources
40 CFR Part 61, National
Emission Standards for
Hazardous Air Pollutants
Establishes performance standards for
new stationary sources of air pollutants.
Establishes emission standards for
hazardous air pollutants from specific
sources.
Alternatives 2, 3, 4, 5, 6, 7, 8, and 9
have varying levels of thermal desorption
of soils onsite. Alternative 8 treats
ground water via UV oxidation in an
onsite treatment facility. Because these
treatment components may create air
pollutants, these alternatives are relevant
and appropriate for the activities
described in this paragraph.
Alternatives 2, 3, 4, 5, 6, 7, 8, and 9
have varying levels of thermal desorption
of soils onsite. Alternative 8 treats
ground water via UV oxidation in an
onsite treatment facility. Because these
treatment components may create
emissions from the treatment of benzene,
beryllium, chloroform, inorganic arsenic,
mercury, manganese, nickel,
trichloroethylene, and vinyl chloride,
these alternatives are relevant and
appropriate for the activities described in
this paragraph.
Utah Air Conservation Act (UCA 19-2-101, fit seq4
UAC R307-1-1, and R307-1-3,
Utah Air Conservation Rules
UAC, R307-1-3.1.8.B,
Analysis for Degenerate Air
Quality
UACR307-l-3.1.8.Aand
R307-1-4.5.2: Fugitive Dust
Standards
These regulations constitute the legal
bases for control of air pollution sources
in the State of Utah. The National
Ambient Air Quality Standards (NAAQS)
to protect the public health and welfare.
Standards have been set for six
pollutants: (1) particulate matter equal to
or less than 10 microns particle size; (2)
sulfur dioxide; (3) carbon monoxide; (4)
ozone; (5) nitrogen dioxide; and (6) lead.
National Standards of Performance for
New Stationary Sources (NSPS),
National Prevention of Significant
Deterioration of Air Quality (PSD)
standards, and the National Emission
Standards for Hazardous Air Pollutants
(NESHAPS) also apply and are legally
enforceable in Utah.
Regulates fugitive dust in general (e.g.,
from windblown soils), and associated
with construction.
The State of Utah air pollution regulations
are relevant and appropriate to the control
of fugitive dust and particulate emissions
at the site. The Federal NAAQS
standards are not enforceable in and of
themselves, rather it is the emissions
standards, which are promulgated to attain
the NAAQS, that are directly enforceable
and are ARARs. Those standards and
requirements include, the fugitive dust
standard; a requirement that all emissions
are subject to BACT; and an analysis is
required to assure that any emissions will
not cause air quality to degenerate beyond
any pertinent level. All proposed
remedial technologies should be evaluated
to determine whether any New Source
Performance Standards may be considered
ARARs.
Alternatives 2, 3, 4, 5, 6, 7, 8, 9 and 10
involve construction activities that disturb
the soils and create fugitive dust. This
applicable requirements mandates BACT
to control fugitive dust.
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Table 8.4
Federal and State ARARs and TBCs for all Alternatives
Page 18 of 21
Citation
Description
Evaluation
Utah Air Conservation Act (UCA 19-2-101, et seq4
UACR307-1-3.1.8.A
Requires BACT for all emissions.
Alternatives 2, 3, 4, 5, 6, 7, 8, 9 and 10
generate emissions either through
construction fugitive dust or release of
VOCs from excavation. This applicable
requirement mandates BACT for all
emissions, unless specifically exempted.
UAC R307-1-4: Standards for
VOC emissions and dust
Regulates VOC emissions.
Alternatives 2, 3, 4, 5, 6, 7, 8, 9 and 10
generate emissions either through
construction fugitive dust or release of
VOCs from excavation. This applicable
requirement limits VOC emissions from
the Site, e.g., direct excavation of
LNAPL.
Utah Water Quality Act (UCA 19-5-101)
UCA 19-5-101
Establishes the rulemaking and
enforcement authority for the regulation of
water quality with the Utah Water Quality
Board.
This act makes it unlawful for any person
to discharge a pollutant into waters of the
State or to cause pollution that constitutes
a menace to the public health and welfare,
or is harmful to wildlife, fish or aquatic
life, or impairs domestic, agricultural,
industrial, recreational, or other beneficial
uses of water, or to place or cause to be
placed any wastes in a location where
there is probable cause to believe it will
cause pollution. This Act is applicable to
alternatives 1, 2, 3, 4, 5, 6, 7, 8, 9, and
10 at the Petrochem/Ekotek site in that
pollutants were discharged into the soils
and the ground water during operations of
the facility.
UAC R317-7, Underground
Injection Control Program
Establishes standards for construction and
operation of injection wells. Provides for
protection of underground sources of
drinking water.
Alternative 8 reinjects treated water into
the aquifer beneath the Petrochem/Ekotek
site. The requirements of this regulation
is applicable to alternative 8. The
requirements include constructing,
operating, and maintaining a well in a
manner that does not result in
contamination of an underground source
of drinking water at levels that violate
MCLs or otherwise affect the health of
persons. These requirements will be met
by ensuring the effluent from the ground
water treatment facility under alternative 8
meets standards that are protective of
human health (based on MCLs and risk-
based concentrations).
-------
Table 8.4
Federal and State ARARs and TBCs for all the Alternatives
Page 19 of 21
Citation
Description
Evaluation
Utah Water Quality Act (UCA 19-5-101)
UAC R317-8, Utah Pollutant Discharge
Elimination System (UPDES) Rule and
Permit Regulations
Establishes requirements for stormwater
discharges related to industrial activity.
Stormwater runoff, snow melt runoff, and
surface runoff and drainage associated with
remedial actions which discharge to
surface waters shall be conducted in
compliance with RCRA, FWQC, CWA
technology-based standards and best
management practices.
Although none of the alternatives have a
discharge component as part of the
remedies, stormwater discharges may
occur during the implementation of the
remedies (e.g., runoff discharge from the
open trenches or open excavation of the
LNAPL during precipitation event).
Therefore, the stormwater discharges
limits must be meet which include
sampling, analysis, and treatment
requirements. Because the waste at the
site is sufficiently similar to wastes
regulated by NPDES permits, this
regulation is relevant and appropriate to
the activities described in this paragraph.
Utah Hazardous Substances Mitigation Act (UCA 19-6-301, fit seqj
Utah Underground Storage Tank Act (UCA 19-6-401,
UAC R311-211: Corrective Action
Clean-up Standards Policy - UST and
CERCLA Sites
Establishes general standards for clean-up
of contaminated sites.
Requires source elimination or control,
and establishes various numerical
standards. At this site, these standards
will be met by meeting other ARARs.
UAC R311, Underground Storage Tank
Rules
Establishes requirements for the removal
of underground storage tanks (USTs),
required cleanup of any leakage attributed
to the USTs while in service, and closure
requirements for a facility after removal of
the UST.
Alternatives 2, 3, 4, 5, 6, 1, 8, 9 and 10
remove two 1,000 gallon underground
storage tanks in the former tank farm
area. These alternatives also address the
soils at the location of the previously
removed UST #2. Because the waste at
the site is sufficiently similar to
constituents governed by this regulation,
the regulation is relevant and appropriate
to these alternatives.
40 CFR Part 279
Utah Used Oil Management Act, UCA
19-6-701, etseq., UAC R315-15:
Standards for the Management of Used
Oil
Governs management, use and disposal of
used oil.
This is applicable to material qualifying as
used oil generated by the clean-up of this
Site. It provides management standards,
e.g., prohibiting use for dust suppression.
UAC R315-1, Utah Hazardous Waste
Management Regulations
Establishes standards for the treatment,
storage and disposal of hazardous waste.
Alternatives 2, 3, 4, 5, 6, 7, 8, 9, and 10
include components of disposal, storage
during implementation, and treatment of
hazardous waste. Because the waste at
the site is sufficiently similar to RCRA
hazardous waste, the regulation is relevant
and appropriate for the alternatives
described in this paragraph.
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Table 8.4
Federal and State ARARs and TBCs for all the Alternatives
Page 20 of 21
Citation
Description
Evaluation
Utah Hazardous Substances Mitigation Act (UCA 19-6-301, el seq*)
Utah Underground Storage Tank Act {UCA19-6-401, fit seq.)
UCA 19-6-301, Utah Hazardous
Substances Mitigation Act
Establishes requirements for remedial
investigations and remedial action plans
at CERCLA ficHUies.
Alternatives 2, 3, 4, 5, 6, 7, 8,9, and 10
are all remedial action plans for the
remediation of thePetrochem/Ekotek site.
The regulation is applicable to the
activities of the alternatives listed in this
paragraph.
Action-Specific TBCs
Clean Air Act Section 109,
301 (a)
40 CFR Part 50
National Primary and Secondary Air
Quality Standards. Pursuant to the Clean
Air Act Section 109, EPA has
promulgated National Ambient Air
Quality Standards (NAAQS) for ambient
air, to protect the public health and
welfare. Standards have been set for six
pollutants: (1) paniculate matter equal to
or less than 10 microns particle size; (2)
sulfur dioxide; (3) carbon monoxide; (4)
ozone; (5) nitrogen dioxide; and (6) lead.
The NAAQS may be used as other criteria
or guidelines to be considered (TBC)
during operations of the excavation of the
soils and LNAPL, thermal desorption of
the soils and air sparging and UV
oxidation of the ground water. The
NAAQS are TBCs for alternatives 2,3,4,
5, 6, 7, 8, 9, and 10.
ASTM ES 38-94, "Emergency
Standard Guide for Risk-Based
Corrective Action Applied at
Petroleum Release Sites"
Risk-based corrective action (RBCA) is a
generic term for corrective action
strategies that categorize sites according
to risk and move all sites toward
completion using appropriate levels of
action and oversight. ASTM's RBCA
provides an effective strategy for
incorporating site-specific data into a
scientifically based decision-making
process to manage Leaking Underground
Storage Tanks (LUST) sites.
This guidance integrates risk and
exposure assessment practices that mirror
EPA's risk assessment that was completed
at the Petrochem/Ekotek site. This
guidance is directly applicable such that
the TPH constituents cleanup goals for
soils shall be as specified in the soils
preliminary remediation goals
performance standards for alternatives 2,
3, 4, 5, 6, 7, 8, 9, and 10.
Guidance for Estimating Numeric
Cleanup Levels for Petroleum-
Contaminated Soil at
Underground Storage Tank
Release Sites
This guidance establishes cleanup goals
for TPH.
For the Petrochem/Ekotek site, the
specified cleanup level is 100 mg/kg
TPH. The State of Utah is currently in
transition from the use of this guidance to
the adoption of RBCA therefore this
guidance may no longer be considered.
The hot spot criteria for TPH removal is
100,000 mg/kg.
-------
Table 8.4
Federal and State ARARs and TBCs for all of the Alternatives
Page 21 of 21
Citation
Description
Evaluation
Location-Specific ARARs
Endangered Species Act (16
USC Sections 1531 - 1543)
40 CFR Part 6, Procedures for
Implementing the Requirements
of the Council on
Environmental Quality on the
National Environmental Policy
Act
50 CFR Part 402
Requires action to conserve endangered
species within critical habitat upon which
species depend. Includes consultation with
Department of Interior.
The Petrochem/Ekotek site was not found
to be a critical habitat for any endangered
species.
Migratory Bird Treaty Act (16
USC Section 703-712)
56 CFR Parts 10, 20, and 21
Protects migratory birds, nests, eggs, or
products thereof.
Petrochem/Ekotek site is, at times, a
habitat for migratory birds thus these
regulations apply to alternatives 1,2,3,
4, 5, 6, 7, 8, 9, and 10.
-------
TABLE 8.9
Petrochem/Ekotek Superfund Site
Soil Components of the Alternatives
Page 1 of 2
Location of
Soils
Northern Offsite
Soils
Former Tank
Farm Area
Western Area
(Excluding
Tank Farm)
Eastern Area
Eastern UST# 2
Buried Debris
Overburden Soils
Level of Contamination
Industrial risk level
(Volume of Soils in CY)
> 10"
200 CY
130 CY1
2000 -4000 CY2
>ir
700 CY
1 3,700 CY
170 CY
4,200 CY
2,300 CY
10,000 CY
17,000- 19,000
CY3
Disposition of the Soils after implementation of Alternative
ALT1
NC
NC
NC
NC
NC
NC
NA
ALT 2
EX/TH
CP
THof
Hot
Spots
TH'
TH
CP
NA
ALT 3
EX/CS
CP
DSof
Hot
Spots
EX/CS
EX/CS
CP
NA
ALT 4
EX/DS
EX/DS
EX/DS
EX/DS
EX/DS
PE/DS/
CP
NA
ALTS
EX/TH
EX/TH
EX/TH
EX/TH
EX/TH
PE/DS/
CP
NA
ALT 6
EX/TH
EX/TH
EX/TH
EX/TH
EX/TH
EX/TH
EX/BF
ALT?
EX/TH
EX/TH
EX/TH
EX/TH
EX/TH
EX/TH
EX/BF
ALTS
EX/TH
EX/TH
EX/TH
EX/TH
EX/TH
EX/TH
EX/BF
ALT 9
EX/LF
EX/LF
EX/DS-
Hot
Spots;
LF
EX/DS-
Hot
Spots;
LF
EX/LF
EX/DS
EX/BF
ALT
10
EX/
CC
CP
DSof
Hot
Spots;
EX/
CC
DSof
Hot
Spots:
EX/
CC
EX/
CC
PE/DS
/CP
EX/BF
-------
TABLE 8.9
Petrochem/Ekotek Superfund Site
Soil Components of the Alternatives
Page 2 of 2
Location of
Soils
" '\> C "5l:
^*" '->;&&*
LNAPL-Saturated
Soils from
Trenching
LNAPL-Saturated
Soils with Direct
Excavation
Level of Contamination
Industrial risk level
(Volume of Soils in CY)
> KV4
600 - 700 CY4
3,000 CY5
>10^
Disposition of the Soils after implementation of Alternative
ALT1
NC
NA
ALT 2
TH
NA
ALT 3
TH
NA
ALT 4
DS
NA
ALTS
DS
NA
ALT 6
NA
EX/TH
ALT?
NA
EX/TH
ALTS
NA
EX/TH
ALT 9
NA
EX/DS
ALT
10
NA
EX/
DS
Notes:
1 - These soils represent the volume of Total Petroleum Hydrocarbons soils that exceeds 100,000 ppm.
2 - These soils have been identified as soils saturated with LNAPL. This identification does not mean that a determination has been made that these soils exceed the 10"4 risk level. The
estimated volumes of LNAPL-saturated soils for alternatives 1-9 is 2,000 CY. The estimated volume of LNAPL-saturated soils for alternative 10 is 4,000 CY.
3 - The estimated volumes of overburden soils for alternatives 1-9 is 17,000 CY. The estimated volume of overburden soils for alternative 10 is 19,000 CY. Most of the overburden
soils are not contaminated (i.e., does not exceed 10"s risk level). Some of the overburden soils may be soils identified as contaminated in the former tank farm area which will be
addressed as identified under the former tank farm soils.
4 - These soils have been identified as soils saturated with LNAPL. This identification does not mean that a determination has been made that these soils exceed the 10"4 risk level.
These are the soils that are saturated with LNAPL during the removal of the LNAPL using the two different trenching operations.
5 - These soils have been identified as soils saturated with LNAPL. This identification does not mean that a determination has been made that these soils exceed the 10"4 risk level.
These are the soils that are saturated with LNAPL during the removal of the LNAPL using direct excavation.
Codes:
NA - No Applicable NC - No Action
BF - Backfilled CC - Clean Soil Cover after Consolidation
CP - Clean soil cover (in place) CS - Consolidation on Site and Covered
DS- Offsite Disposal EX - Excavation
LF - Landfarmed PE - Partial Excavation
TH - Thermal Treatment .onsite
-------
lahlfiJULJLl
Srfpffpd Remedy Pprfnrmanre Standards
Soil
(Soils to be
consolidated
and contained
on-site;
numbers
identify lower
boundary)
Groundwater
Constituents
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Dibenz(a,h)anthracene
Indeno(l ,2,3-c,d)pyrene
PCB
Thallium (as chloride)
2,3,7,8-TCDD(TEF)
Antimony
Arsenic
Benzene
Benzo(b)fluoranthene
Beryllium
Chloroform
Cis-1 ,2-dichloroethene
Manganese
Mercury
Nickel
Silver
Thallium (as chloride)
Vinyl Chloride
Carcinogen
or
Noncarcinogen
C
C
C
C
C
C
N
C
N
C
C
C
C,N
C,N
N
N
N
N
N
N
C
Risk
Assessment
PRGs
7.8 mg/kg
0.78 mg/kg
7.8 mg/kg
0.78 mg/kg
7.8 mg/kg
0.15 mg/kg
160 mg/kg
1.86E-06 mg/kg
0.006 mg/1
0.05 mg/1
0.005 mg/1
0.0002 mg/1
0.004 mg/1
0.1 mg/1
0.07 mg/1
0.05 mg/1
0.002 mg/1
0.1 mg/1
0.05 mg/1
0.002 mg/1
0.002 mg/1
SDWA
MCL
(mg/1)
0.006
0.05
0.005
0.0002
0.1
0.07
0.05
0.002
0.1
0.1
0.002
0.002
Utah
Groundwater
Stds (mg/1)
0.05
0.05
0.002
0.05
TSCA
ppm
10
RCRA
40CFR
Part 264 F
0.05 mg/1
0.002 mg/1
0.05 mg/1
Performance
Standards
7.8 mg/kg
0.78 mg/kg
7.8 mg/kg
0.78 mg/kg
7.8 mg/kg
0.15 mg/kg
160 mg/kg
1.86E-06 mg/kg
6ug/l
50 ug/1
5ug/l
0.2 ug/1
4 ug/1
100 ug/1
70 ug/1
50 ug/1
2 ug/1
100 ug/1
50 ug/1
2 ug/1
2 ug/1
Note: National Ambient Air Quality Standards (NAAQS) would be applicable at this site. UDEQ's Division of Air Quality only applicable ambient air standard would be for PM-10
particulate matter which has a 24-hour averaged limit of 150 ug/m*. Local ordinances place a limit of 20% opacity for any dust plume arising from on-site activity.
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Table 10.1.3
Federal and State ARARs and TBCs for Alternative 10 the Selected Remedy
Page 1 of 16
Citation
Description
Evaluation
Chemical-Specific ARARs
Safe Drinking Water Act (42 U.S.C. Sections 3QOf-300j-26)
40CFRPart 141,
including Subparts B and G
Establishes health-based standards for public
drinking water systems (MCLs).
These regulations are relevant and appropriate
because the shallow ground water beneath the
Petrochem/Ekotek Site is being used or may
be used in the future as a source of water for a
public water system or private supply wells.
The standards are relevant and appropriate
throughout the ground water for the selected
remedy.
40 CFR Part 141, Subpart F
Establishes drinking water quality goals set at
levels of no known or anticipated adverse
health effects, with an adequate margin of
safety (MCLGs).
Non-zero MCLGs are relevant and
appropriate for the selected remedy since
ground water is in the vicinity of the
Petrochem/Ekotek site is being used or may
be used as a source of water for a public water
system or private supply wells.
40 CFR Part 143
National Secondary Drinking Waster
Standards establish welfare-based standards
for public water supply systems.
The National Secondary Drinking Water
regulations are relevant and appropriate
because the shallow ground water at the
Petrochem/Ekotek site is being used or may
be used in the future as a source of water for a
public water system or private supply wells.
Federal Water Pollution Control Act
(amended by the Clean Water Act, 42 USC Section 7401, et seq)
40 CFR Part 403, Pre-Treatment
Standards
Establishes standards for discharge of toxic
pollutants to Publicly Owned Treatment
Works (POTWs).
This regulation is relevant and appropriate for
discharge being sent offsite to the local POTW
under the contingencies that may occur as part
of the selected remedy. Pre-treatment is
necessary if standards are not met.
Solid Waste Disposal Act - RCRA Subtitle C (42 U.S.C. Section 6901, et seq.)
40 CFR Part 264, Subpart F
Sets ground water protection standards for
land disposal units and releases from solid
waste management units.
Ground water protection standards are
relevant and appropriate because the site (in
particular, the consolidated waste in the
former tank farm area) operates like a
hazardous waste management (land disposal)
unit. The State of Utah operates an approved
delegated program for this portion of RCRA.
See requirements under Utah Solid and
Hazardous Waste Act and accompanying
regulations.
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Table 10.1.3
Federal and State ARARs and TBCs for the Selected Remedy
Page 2 of 16
Citation
Description
Evaluation
Toxic Substances Control Act (15 USC Section 2605)
40 CFR Part 761
Subpart G, PCB Spill Cleanup
Policy
Sets forth PCB Spill policy and disposal
requirements.
PCBs resulting from the clean-up and
removal of spills, leaks, or other
uncontrolled discharges, must be stored
and disposed in accordance with this
regulation. The selected remedy
addresses PCBs that spilled, leaked, or
were discharged during the operation of
the Petrochem/Ekotek facility. The
requirement to clean up to 10 ppm in the
soils and remove such soils to a permitted
TSCA landfill is relevant and appropriate
for the selected remedy.
Utah Water Quality Act (UCA Section 19-5-101, et seqj
UCA 19-5-101 and
UCA Section 19-5-107
Establishes the rulemaking and enforcement
authority for the regulation of water quality
with the Utah Water Quality Board.
This act makes it unlawful for any person
to discharge a pollutant into waters of the
State or to cause pollution that constitutes
a menace to the public health and welfare,
or is harmful to wildlife, fish or aquatic
life, or impairs domestic, agricultural,
industrial, recreational, or other beneficial
uses of water, or to place or cause to be
placed any wastes in a location where
there is probable cause to believe it will
cause pollution. This Act is applicable to
the selected remedy at the
Petrochem/Ekotek site in that pollutants
were discharged into the soils and the
ground water during operations of the
facility.
UAC R317-6, The Groundwater
Quality Protection Rule
Establishes groundwater quality standards,
groundwater classes, and groundwater class
protection levels for the protection of
groundwater quality of the State.
Groundwater quality standards establish
numerical clean-up levels for
contaminated groundwater. These
standards are relevant and appropriate to
the selected remedy at the Site to the
extent there is ongoing groundwater
contamination.
UAC R309, Utah Drinking
Water Rules
These rules establish maximum contaminant
levels in public drinking water systems
within the State of Utah.
These levels are relevant and appropriate
because the shallow ground water beneath
the Petrochem/Ekotek Site is being used
or may be used in the future as a source
of water for a public water system or
private supply wells. The standards are
relevant and appropriate throughout the
ground water for the selected remedy.
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Table 10.1.3
Federal and State ARARs and TBCs for the Selected Remedy
Page 3 of 16
Citation
Description
Evaluation
Utah Underground Storage Tank Act (UCA 19-6-401)
UAC R315-101, Utah Solid and
Hazardous Waste Rules (TPH
clean-up levels)
This regulation sets standards for cleaning
up total petroleum hydrocarbons (TPH).
This regulation, in combination with the
Division of Environmental Response and
Remediation's "Guidance for Estimating
Numeric Cleanup Levels for Petroleum-
Contaminated Soil at Underground Storage
Tank Release Sites" which is a TEC, sets
standards for cleaning up TPH.
The selected remedy removes two 1,000
gallon underground storage tanks in the
former tank farm area. In addition, the
selected alternative addresses the soils at
the location of the previously removed
UST#2. Because the waste at the site is
sufficiently similar to RCRA hazardous
waste, the regulation is relevant and
appropriate to the selected remedy.
Chemical-Specific TBCs
Clean Air Act Section 109,
301 (a)
40 CFR Part 50
National Primary and Secondary Air
Quality Standards. Pursuant to the Clean
Air Act Section 109, EPA has promulgated
National Ambient Air Quality Standards
(NAAQS) for ambient air, to protect the
public health and welfare. Standards have
been set for six pollutants: (1) paniculate
matter equal to or less than 10 microns
particle size; (2) sulfur dioxide; (3) carbon
monoxide; (4) ozone; (5) nitrogen dioxide;
and (6) lead.
The NAAQS may be used as other criteria
or guidelines to be considered (TBC)
during operations of the excavation of the
soils and LNAPL. The NAAQS are
TBCs for the selected remedy.
ASTM ES 38-94, "Emergency
Standard Guide for Risk-Based
Corrective Action Applied at
Petroleum Release Sites"
Risk-based corrective action (RBCA) is a
generic term for corrective action
strategies that categorize sites according to
risk and move all sites toward completion
using appropriate levels of action and
oversight. ASTM's RBCA provides an
effective strategy for incorporating site-
specific data into a scientifically based
decision-making process to manage
Leaking Underground Storage Tanks
(LUST) sites.
This guidance integrates risk and
exposure assessment practices that mirror
EPA's risk assessment that was completed
at the Petrochem/Ekotek site. This
guidance is directly applicable such that
the TPH constituents cleanup goals for
soils shall be as specified in the soils
preliminary remediation goals
performance standards for the selected
remedy.
Guidance for Estimating
Numeric Cleanup Levels for
Petroleum-Contaminated Soil at
Underground Storage Tank
Release Sites
This guidance establishes cleanup goals for
TPH.
For the Petrochem/Ekotek site, the
specified cleanup level is 100 mg/kg
TPH. The State of Utah is currently in
transition from the use of this guidance to
the adoption of RBCA. The hot spot
criteria requires removal of soil that
exceeds 100,000 mg/kg TPH levels.
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Table 10.1.3
Federal and State ARARs and TBCs for the Selected Remedy
Page 4 of 16
Citation
Description
Evaluation
Action-Specific ARARs
Solid Waste Disposal Act (42 USC Section 6901, et
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101, fit seq.)
Utah Solid Waste Management Act (UCA Section 19-6-501, fit seq4
40 CFR 241, Guidelines for the
land disposal of solid wastes
UAC R315-301: Solid Waste
Authority, Definitions, and
General Requirements
UACR315-302: Solid Waste
Facility Location Standards
UAC R315-303: Landfiliing
Standards
UAC R315-304: Industrial
Solid Waste Facility
Requirements
UAC R315-305: Class IV
Landfill Requirements
UAC R315-307: Landtreatment
Disposal Standards
Establishes guidelines for the land disposal
of all solid waste materials and delineates
minimum levels of performance required of
any solid waste land disposal site operation.
Offsite disposal of wastes will occur at the
Petrochem/Ekotek site as part of the
selected remedy. The offsite disposal of
waste classified as solid waste must
comply with both the substantive and
administrative requirements of these
regulations pursuant to EPA's offsite
policy. In addition, Part 241
requirements and cited State rules are
relevant and appropriate with respect to
the performance of the operations and
maintenance of the soil cover where solid
waste is consolidated and left in place.
40 CFR Part 257, Criteria for
Classification of Solid Waste
Disposal Facilities and Practices
UAC R315-301: Solid Waste
Authority, Definitions, and
General Requirements
UAC R315-302: Solid Waste
Facility Location Standards
Establishes criteria for use in determining
which solid waste disposal facilities and
practices pose a reasonable probability of
adverse effects on health or the environment
and thereby constitute prohibited open
dumps.
The buried debris area and tank farm area
where waste will be consolidated and
covered (left in place) are subject to the
classification of solid waste and the
associated limits of release or exposure of
the solid waste with respect to flood
plains, endangered species, surface water,
ground water, production of crops,
disease, air and safety. This regulation is
relevant and appropriate to the selected
remedy.
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Table 10.1.3
Federal and State ARARs and TBCs for the Selected Remedy
Page 5 of 16
Citation
Description
Evaluation
Solid Waste Disposal Act (42 USC Section 6901, et seq.)
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101, el seq.)
Utah Solid Waste Management Act (UCA Section 19-6-501, et seq.)
40 CFR Part 258, Criteria for
Municipal Solid Waste Landfills
UACR315-303: Landfilling
Standards
Subpart E, Ground-Water
Monitoring and Corrective
Action
UACR315-308: Ground-water
Monitoring Requirements
Subpart F, Closure and Post-
Closure Care
UACR315-302: Solid Waste
Facility Location Standards
UACR315-303: Landfilling
Standards
UACR315-304: Industrial
Solid Waste Facility
Requirements
Establishes design and operations criteria for
all new municipal solid waste landfills or
expansions of existing facilities; and sets
forth closure/post-closure requirements.
The selected remedy partially removes the
solid waste located in the debris area and
caps the remaining debris and
consolidates and covers other waste in the
former tank farm area. This regulation is
relevant and appropriate for the selected
remedy for closure and post-closure
requirements.
40 CFR 260, Hazardous Waste
Management System: General
UACR315-1: Utah Hazardous
Waste Definitions and
References
UACR315-2: General
Requirements - Identification
and Listing of Hazardous Waste
Establishes the definitions of terms, general
standards, and overview information
applicable to parts 260 through 265 and
268.
This regulation is applicable in as much as
the definitions and overview provided in
this regulation apply to the applicable or
relevant and appropriate sections of parts
260 through 265 and 268. See specific
information regarding parts 260 through
265 and 268 below.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
40 CFR Part 261, Identification
and Listing of Hazardous Waste
UACR315-2-3: Definition of
Hazardous Waste
UACR315-2-4: Exclusion
UACR315-2-7: Residues of
Hazardous Waste in Empty
Containers
UAC R315-2-9: Characteristics
of Hazardous Waste
UACR315-2-10: Lists of
Hazardous Waste
UACR315-2-11: Discarded
Commercial Chemical Products
UAC R315-50: Appendices
Identifies those solid wastes which are
subject to regulation as hazardous wastes
under parts 124, 262, 263, 264, 265, 270,
and 271, and which are subject to the
notification requirements of section 3010 of
RCRA.
The classification of the waste will be
determined in the field for purposes of
proper offsite disposal and treatment. At
present, the soils at the site have not been
determined to be hazardous as defined by
subpart C, characteristics of hazardous
waste. However, the waste is a pollutant,
contaminant or hazardous substance that
presents a risk to human health and the
environment therefore the waste is
sufficiently similar such that RCRA
regulations are relevant and appropriate.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
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Table 10.1.3
Federal and State ARARs and TBCs for the Selected Remedy
Page 6 of 16
Citation
Description
Evaluation
Solid Waste Disposal Act (42 USC Section 6901, et seq.)
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101, el sep.)
40 CFR Part 262, Standards
Applicable to Generators of
Hazardous Waste
UACR315-5: Hazardous Waste
Generator Requirements
Establishes standards for RCRA generators
to include shipment of hazardous waste
from a treatment, storage, or disposal
facility; treatment, storage or disposal of
hazardous waste onsite; and compliance
requirements and penalties for persons
who generates a hazardous waste but do
not comply with this part.
The remediation activities at the
Petrochem/Ekotek site will generate waste
that will be sufficiently similar to RCRA
hazardous waste such that use of this
requirement is well suited to the situation.
The requirement is relevant and
appropriate to the soils and debris
excavated from the site. The selected
remedy include the shipment of
sufficiently similar hazardous waste to an
offsite facility and temporary storage of
waste during implementation of the
remedies thus this part is relevant and
appropriate to the selected remedy.
40 CFR Part 264, Standards for
Owners and Operators of
Hazardous Waste Treatment,
Storage, and Disposal Facilities
Subpart B, General Facility
Standards
UAC R315-8-2 (TSDFs):
General Facility Standards
Subpart C, Preparedness and
Prevention
UAC R315-8-3: Preparedness
and Prevention
Subpart D, Contingency Plan
and Emergency Procedures
UAC R315-8-4: Contingency
Plan and Emergency Procedures
Establishes minimum standards that define
the acceptable management of hazardous
waste for owners and operators of facilities
which treat, store, or dispose of hazardous
waste.
The selected remedy stores waste during
the implementation of the remedy,
remediates the ground water and
consolidates contaminated soils in the
former tank farm area for final disposal.
Because these remediation activities
constitute treatment, storage, and/or
disposal activities, the requirements-of
this part are relevant and appropriate to
the various components of the selected
remedy. Thus, site activities must meet
these standards, which include waste
analysis, site security .emergency control
and response equipment, personnel
training, contingency planning, and
implementation.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
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Table 10.1.3
Federal and State ARARs and TBCs for the Selected Remedy
Page 7 of 16
Citation
Description
Evaluation
Solid Waste Disposal Act (42 USC Section 6901, et seq.)
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101, et seqj
40 CFR Part 264, Subpart F,
Releases from Solid Waste
Management Units
UAC R315-8-6: Groundwater
Protection
Establishes requirements to detect,
characterize, and respond to releases to the
uppermost aquifer from a facility that
treats, stores, or disposes of hazardous
waste.
The selected remedy contains the debris
area with a cover and consolidates waste
in the former tank farm area under a
cover thereby creating waste management
unit(s). The design of the ground water
compliance monitoring program for the
detection of releases from the solid waste
management unit cited in the selected
remedy is relevant and appropriate, as
well as any corrective action that may be
necessary should the hazardous
constituents exceed the established
concentration limits specified in the
compliance monitoring program.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
40 CFR Part 264, Subpart G,
Closure and Post-Closure
UACR315-8-7: Closure and
Post-Closure
Establishes requirements for the closure
and post-closure of facilities that treat,
store or dispose of hazardous waste.
Because excavation, consolidation and
containment via cover of contaminated
materials constitute disposal of a waste
that is sufficiently similar to RCRA
hazardous waste such that use of the
requirement is well suited to the situation,
the requirement is relevant and
appropriate to the activities described in
the selected remedy. Closure and post-
closure care for the disposal areas must
meet these standards which include
removal of waste, waste residues,
contaminated system components, and
contaminated subsoils; or closure with
wastes and/or contamination in place with
containment systems and post-closure care
to include ground water monitoring and
inspection and maintenance on
containment and monitoring systems.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
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Table 10.1.3
Federal and State ARARs and TBCs for the Selected Remedy
Page 8 of 16
Citation
Description
Evaluation
Solid Waste Disposal Act (42 USC Section 6901, et seq.)
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101, fit seq4
40 CFR Part 264, Subpart I,
Use and Management of
Containers
UACR315-8-9: Use and
Management of Containers
Establishes operating and performance
standards for container storage of hazardous
waste and applies to owners and operators
of all hazardous waste facilities that store
containers of hazardous waste.
The ground water monitoring program,
and LNAPL recovery at the
Petrochem/Ekotek site is expected to store
hazardous waste at the site during the
implementation of the selected remedy.
The intrinsic remediation/attenuation pilot
study is expected to produce large
quantities of contaminated waste that will
most likely be stored in a container.
Because the waste is sufficiently similar to
RCRA hazardous waste, this regulation is
relevant and appropriate to activities
involving storage or temporary storage of
contaminated materials in containers
which includes the selected remedy cited
in this paragraph.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
40 CFR Part 264, Subpart J,
Tank Systems
UACR315-8-10: Tanks
Establishes operating and performance
standards for tank systems to include closure
and post-closure requirements. This
regulation applies to owners and operators
of facilities that use tank systems for storage
or treating hazardous waste.
The selected remedy excavates two 1,000
gallon tanks from the former tank farm
area and may store ground water in tanks
if contingencies are implemented.
Because the waste is sufficiently similar to
RCRA hazardous waste, this regulation is
relevant and appropriate to the activities
involving closure of the tanks.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
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Table 10.1.3
Federal and State ARARs and TBCs for the Selected Remedy
Page 9 of 16
Citation
Description
Evaluation
Solid Waste Disposal Act (42 USC Section 6901, et seq.)
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101, fit
40 CFR Part 264, Subpart L,
Waste Piles
UACR315-8-12: Waste Piles
Establishes operating and performance
standards for waste piles to include closure
and post-closure requirements. This
regulation applies to owners and operators
of facilities that store or treat hazardous
waste in piles.
The selected remedy excavates soil and
stores soil onsite in preparation for
consolidation. The manner in which the
soils are stored constitutes a waste pile.
Because the waste is sufficiently similar to
RCRA hazardous waste, this regulation is
relevant and appropriate to the selected
remedy as well as to the closure and post-
closure of waste piles.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
40 CFR Part 264, Subpart N,
Landfills
UACR315-8-14: Landfills
Establishes operating and performance
standards for landfills to include closure
and post-closure requirements. The
regulation applies to owners and operators
of facilities that dispose of hazardous waste
in landfills.
The selected remedy has containment of
remaining debris and consolidates and
contains waste onsite that is sufficiently
similar to landfilling. Because the waste
is sufficiently similar to RCRA hazardous
waste, this regulation is relevant and
appropriate to the selected remedy as well
as to the closure and post-closure of
landfills.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
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Table 10.1.3
Federal and State ARARs and TBCs for the Selected Remedy
Page 10 of 16
Citation
Description
Evaluation
Solid Waste Disposal Act (42 USC Section 6901, et seq.)
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101, et seq4
40 CFR Part 265, Subpart Q,
Chemical, Physical, and
Biological Treatment
UACR315-7-24: Chemical,
Physical, and Biological
Treatment
Establishes operating and performance
standards for chemical, physical, and
biological treatment. The regulation
applies to owners and operators of
facilities which treat hazardous wastes by
chemical, physical, or biological methods
in other than tanks, surface impoundments,
and land treatment facilities.
The selected remedy may use
enhancements to the biological treatment
of the ground water via intrinsic
remediation/attenuation which will not
occur in a tank, surface impoundment or
land treatment facility. Because the
chemical, physical and biological
treatment is sufficiently similar to RCRA
hazardous waste such that the use of the
requirement is well suited to the situation,
the requirement is relevant and
appropriate to the selected remedy.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
40 CFR Part 267, Interim
Standards for Owners and
Operators of New Hazardous
Waste Land Disposal Facilities
Establishes standards for new hazardous
waste land disposal facilities. The
regulation applies to owners and operators
of new hazardous waste landfills, surface
impoundments, land treatment facilities
and individually permitted Class I
underground injection wells.
The selected remedy has containment of
remaining debris and consolidates and
contains waste onsite that is sufficiently
similar to landfilling and associated
ground water monitoring. Because the
waste is sufficiently similar to RCRA
hazardous waste, this regulation is
relevant and appropriate to the activities
described in the selected remedy as well
as to the closure and post-closure of
landfills.
The State of Utah has an approved,
delegated program under RCRA for these
requirements.
58 Federal Register 8658
40 CFR Part 264, Subpart S,
Corrective Action Management
Units (CAMUs)
Permits the agency to establish a
Corrective Action Management Unit
(CAMU) or units at CERCLA remedial
sites.
EPA has designated the
Petrochem/Ekotek Site as a CAMU.
Because the waste is sufficiently similar to
RCRA hazardous waste, the requirement
is relevant and appropriate to the activities
described in the selected remedy.
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Table 10.1.3
Federal and State ARARs and TBCs for the Selected Remedy
Page 11 of 16
Citation
Description
Evaluation
Solid Waste Disposal Act (42 TJSC Section 6901, et seq.)
Utah Solid and Hazardous Waste Act (UCA Section 19-6-101, et
40 CFR Part 280, Technical
Standards and Corrective Action
Requirements for Owners and
Operators of Underground
Storage Tanks (UST)
UAC R311 -202: UST Technical
Standards
UACR311-207: Assessing the
PST Fund for LUSTs
UACR311-211: Corrective
Action Clean-up Standards for
CERCLA and UST Sites
Establishes technical standards and
corrective action requirements for
underground storage tanks. The regulation
applies to all owners and operators of an
underground storage tank system.
The selected remedy removes
two 1,000 gallon underground
storage tanks in the former tank
farm area. In addition, the
selected remedy addresses the
soils at the location of the
previously removed UST #2.
Because the waste at the site is
sufficiently similar to RCRA
hazardous waste, the regulation is
relevant and appropriate to the
selected remedy.
The State of Utah has an
approved, delegated program
under RCRA for these
requirements.
Federal Water Pollution Control Act (amended by the Clean Water Act)
Utah Water Quality Act (UCA Section 19-5-101, et seq.)
40 CFR Part 122, EPA
Administered Permit Programs:
The National Pollutant Discharge
Elimination System (NPDES)
Establishes requirements for stormwater
discharges related to industrial activity.
Stormwater runoff, snow melt runoff, and
surface runoff and drainage associated with
remedial actions which discharge to
surface waters shall be conducted in
compliance with RCRA, FWQC, CWA
technology-based standards and best
management practices.
Although none of the alternatives
have a discharge component as
part of the remedies, stormwater
discharges may occur during the
implementation of the remedies
(e.g., runoff discharge from the
open trenches or open excavation
of the LNAPL during
precipitation event). Therefore,
the stormwater discharges limits
must be meet which include
sampling, analysis, and treatment
requirements. Because the waste
at the site is sufficiently similar to
wastes regulated by NPDES
permits, this regulation is
relevant and appropriate to the
activities described in this
paragraph.
The State of Utah has an
approved, delegated program for
these requirements.
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Table 10.1.3
Federal and State ARARs and TBCs for the Selected Remedy
Page 12 of 16
Citation
Description
Evaluation
Utah Hazardous Substances Mitigation Act (UCA 19-6-301, et seij.)
UACR3 15-101: Clean-up
Action and Risk-Based Closure
Standards for RCRA Sites
Establishing clean-up standards for
remedial decisions using risk analysis, and
management for RCRA corrective action
sites.
Because site is not being clean-closed, as
defined by the rule, requires appropriate
site management.
Toxic Substances Control Act (15 USC 2625 and 2665)
40 CFR Part 761
Subpart G, PCB Spill Cleanup
Policy
Sets forth PCB Spill policy and disposal
requirements.
Spills and other uncontrolled discharges
of PCBs at concentrations of 50 ppm or
greater constitute the disposal of PCBs.
PCBs resulting from the clean-up and
removal of spills, leaks, or other
uncontrolled discharges, must be stored
and disposed in accordance with this
regulation. The selected remedy
addresses PCBs that spilled, leaked, or
were discharged during the operation of
the Petrochem/Ekotek facility. The
selected remedy will be disposing PCBs
as part of the cleanup thus the
requirement to clean up to 10 ppm in the
soils is relevant and appropriate.
Utah Air Conservation Act (UCA 19-2-101, et &eqj
UACR307-l-3.1.8.Aand
R307-1-4.5.2: Fugitive Dust
Standards
UACR307-1-3.1.8.A
UAC R307-1-4: Standards for
VOC emissions and dust
Regulates fugitive dust in general (e.g.,
from windblown soils), and associated with
construction.
Requires BACT for all emissions.
Regulates VOC emissions.
This applicable requirement mandates
BACT to control fugitive dust.
This applicable requirement mandates
BACT for all emissions, unless
specifically exempted.
This applicable requirement limits VOC
emissions from the Site, e.g., direct
excavation of LNAPL.
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Table 10.1.3
Federal and State ARARs and TBCs for the Selected Remedy
Page 13 of 16
Citation
Description
Evaluation
Utah Air Conservation Act (UCA19-2-101,
UAC R307-1-1, and R307-1-3,
Utah Air Conservation Rules
Analysis for Degenerate Air
Quality, R307-1-3.1.8.B, U.A.C.
These regulations constitute the legal
bases for control of air pollution sources
in the State of Utah. The National
Ambient Air Quality Standards (NAAQS)
to protect the public health and welfare.
Standards have been set for six
pollutants: (1) particulate matter equal to
or less than 10 microns particle size; (2)
sulfur dioxide; (3) carbon monoxide; (4)
ozone; (5) nitrogen dioxide; and (6) lead.
National Standards of Performance for
New Stationary Sources (NSPS),
National Prevention of Significant
Deterioration of Air Quality (PSD)
standards, and the National Emission
Standards for Hazardous Air Pollutants
(NESHAPS) also apply and are legally
enforceable in Utah.
The State of Utah air pollution regulations
are relevant and appropriate to the control
of fugitive dust and particulate emissions
at the site. The Federal NAAQS
standards are not enforceable in and of
themselves, rather it is the emissions
standards, which are promulgated to attain
the NAAQS, that are directly enforceable
and are ARARs. Those standards and
requirements include, the fugitive dust
standard; a requirement that all emissions
are subject to BACT; and an analysis is
required to assure that any emissions will
not cause air quality to degenerate beyond
any pertinent level. All proposed
remedial technologies should be evaluated
to determine whether any New Source
Performance Standards may be considered
ARARs.
Utah Water Quality Act (UCA 19-5-101, et
UCA 19-5-101
Establishes the rulemaking and
enforcement authority for the regulation
of water quality with the Utah Water
Quality Board.
This act makes it unlawful for any person
to discharge a pollutant into waters of the
State or to cause pollution that constitutes
a menace to the public health and welfare,
or is harmful to wildlife, fish or aquatic
life, or impairs domestic, agricultural,
industrial, recreational, or other beneficial
uses of water, or to place or cause to be
placed any wastes in a location where
there is probable cause to believe it will
cause pollution. This Act is applicable to
the selected remedy at the
Petrochem/Ekotek site in that pollutants
were discharged into the soils and the
ground water during operations of the
facility.
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Table 10.1.3
Federal and State ARARs and TBCs for the Selected Remedy
Page 14 of 16
Citation
Description
Evaluation
Utah Water Quality Act (UCA 19-5-101)
UAC R317-8, Utah Pollutant
Discharge Elimination System
Rule and Permit Rules (UPDES)
Establishes requirements for stormwater
discharges related to industrial activity.
Stormwater runoff, snow melt runoff, and
surface runoff and drainage associated with
remedial actions which discharge to
surface waters shall be conducted in
compliance with RCRA, FWQC, CWA
technology-based standards and best
management practices.
Although none of the alternatives have a
discharge component as part of the
remedies, stormwater discharges may
occur during the implementation of the
remedies (e.g., runoff discharge from the
open trenches or open excavation of the
LNAPL during precipitation event).
Therefore, the stormwater discharges
limits must be meet which include
sampling, analysis, and treatment
requirements. Because the waste at the
site is sufficiently similar to wastes
regulated by NPDES permits, this
regulation is relevant and appropriate to
the activities described in this paragraph.
Utah Hazardous Substances Mitigation Act (UCA 19-6-301,
Utah Underground Storage Tank Act (UCA 19-6-401, et seqj
UAC R311, Underground
Storage Tank Rules
Establishes requirements for the removal
of underground storage tanks (USTs),
required cleanup of any leakage attributed
to the USTs while in service, and closure
requirements for a facility after removal of
the UST.
The selected remedy removes two 1,000
gallon underground storage tanks in the
former tank farm area. The selected
remedy addresses the soils at the location
of the previously removed UST #2.
Because the waste at the site is sufficiently
similar to constituents governed by this
regulation, the regulation is relevant and
appropriate to the selected remedy.
UAC R311-211: Corrective
Action Clean-up Standards
Policy - UST and CERCLA
Sites
Establishes general standards for clean-up
of contaminated sites.
Requires source elimination or control,
and establishes various numerical
standards. At this site, these standards
will be met by meeting other ARARs.
UCA 19-6-301, Utah Hazardous
Substances Mitigation Act
Establishes requirements for remedial
investigations and remedial action plans at
CERCLA facilities.
The selected remedy is a remedial action
plan for the remediation of the
Petrochem/Ekotek site. The regulation is
applicable to the activities of the selected
remedy.
-------
Table 10.1.3
Federal and State ARARs and TBCs for the Selected Remedy
Page 15 of 16
Citation
Description
Evaluation
40 CFR Part 279
Utah Used Oil Management Act, UCA
19-6-701, etseq., UAC R315-15:
Standards for the Management of Used
Oil
Governs management, use and disposal of
used oil.
This is applicable to material qualifying as
used oil generated by the clean-up of this
Site. It provides management standards,
e.g., prohibiting use for dust suppression.
Action-Specific TBCs
ASTM ES 38-94, "Emergency Standard
Guide for Risk-Based Corrective Action
Applied at Petroleum Release Sites"
Risk-based corrective action (RBCA) is a
generic term for corrective action
strategies that categorize sites according to
risk and move all sites toward completion
using appropriate levels of action and
oversight. ASTM's RBCA provides an
effective strategy for incorporating site-
specific data into a scientifically based
decision-making process to manage
Leaking Underground Storage Tanks
(LUST) sites.
This guidance integrates risk and
exposure assessment practices that mirror
EPA's risk assessment that was completed
at the Petrochem/Ekotek site. This
guidance is directly applicable such that
the TPH constituents cleanup goals for
soils shall be as specified in the soils
preliminary remediation goals
performance standards for the selected
remedy.
Clean Air Act Section 109, 301 (a)
40 CFR Part 50
National Primary and Secondary Air
Quality Standards. Pursuant to the Clean
Air Act Section 109, EPA has promulgated
National Ambient Air Quality Standards
(NAAQS) for ambient air, to protect the
public health and welfare. Standards have
been set for six pollutants: (1) paniculate
matter equal to or less than 10 microns
particle size; (2) sulfur dioxide; (3) carbon
monoxide; (4) ozone; (5) nitrogen dioxide;
and (6) lead.
The NAAQS may be used as other criteria
or guidelines to be considered (TBC)
during operations of the excavation of the
soils and LNAPL. The NAAQS are
TBCs for the selected remedy.
Guidance for Estimating Numeric Cleanup
Levels for Petroleum-Contaminated Soil at
Underground Storage Tank Release Sites
This guidance establishes cleanup goals for
TPH.
For the Petrochem/Ekotek site, the
specified cleanup level is 100 mg/kg
TPH. The State of Utah is currently in
transition from the use of this guidance to
the adoption of RBCA. The hot spot
criteria for TPH removal is 100,000
mg/kg.
-------
Table 10.1.3
Federal and State ARARs and TBCs for the Selected Remedy
Page 16 of 16
Citation
Description
Evaluation
Location-Specific ARARs
Endangered Species Act (16
USC Sections 1531 - 1543)
40 CFR Part 6, Procedures for
Implementing the Requirements
of the Council on
Environmental Quality on the
National Environmental Policy
Act
50 CFR Part 402
Migratory Bird Treaty Act (16
USC Section 703-712)
56 CFR Parts 10, 20, and 21
Requires action to conserve endangered
species within critical habitat upon which
species depend. Includes consultation with
Department of Interior.
Protects migratory birds, nests, eggs, or
products thereof.
The Petrochem/Ekotek site was not found
to be a critical habitat for any endangered
species.
Petrochem/Ekotek site is, at times, a
habitat for migratory birds thus these
regulations apply to the selected remedy.
-------
TABLE 10.2 COSTS OF SELECTED REMEDY
Coil linn 1
'• •'<:• • •• 'I. ' '• •. ' •'•:• ^ i''i '..!'v. •|,1.H'1:i''i^;ir-i'.,i'!';Wlv:S'::.:>i-!?-r''-l.''
.Viii/r
Sludge I'ilc
ICxcivalimi/l.niidmg of Sludge
Trnns|x>ilalioii of Sludge to Landfill
Disposal of Sludge al RCRA ll»7.. Waste Lund fill
Suil/ITI-VMi.sc. Diums
l.iiiulini; ofDrinn.i
Trans|H>iUli«n of Diums to Landfdl
Disposnl ofDinnis to RCRA llaz. Waste Landfill
Oil/Wnlcr Dunns
Loading of Drums
( )|lsitc Incinci Minn
Removal ofTnnki
Kxcavnliixi of Tank Noili
Tank Disposal
T[niis|xxl«liun li> Crilificd l:>cilily
Trans|xnlalion to landfill
Olfsilc TSCA Undlill
l.inci Rctnovil
Loading of Liner 1
TrmnpoitalUni of Liner to l-anls
D\isl/Air Coiiliols - l-'onm
SliH Ytir Kiid Yrir Hull Cost
!>.-;'.r;."..i . .,,,;..•. M,.: IV •:.,.•• C»pl(»ICojU • '
1 1 $1.85
1 1 $30.00
1 1 $266.2-1
1 1 J2.36
1 1 $8.17
1 1 $72.51
i
1 1 $2.36
1 1 $700.00
1 1 $773.00
1 1 $1.85
1 1 $450.00
1 1 $800.00
1 1 $30.00
1 1 $266.24
1
1 . 1 $8.65
1 1 $30.00
1 1 $266.2-1
1 1 $0.18
1 1 $55.60000
1 1 $1.85
, 1 1 $1.86
1 1 $1.80
1 1 $0.55
1 1 $0.52
1 1 $1.85
1 1 $16.61
1 1 S-1.86
1 1 $30.00
1 1 $266.24
1 1 $1.85
' 1 1 $16.61
Unit)
/cy
/cy
/cy
Alnnn
Alnini
Alnnn
AllHIII
Alium
/lank
/cy
/tnnk
/lank
/cy
/cy
/cy
/cy
/cy
/sy
/job
/cy
/cy
/cy
/sy
/.iy
/cy
/cy
/cy
/cy
/cy
/cy
/cy
Quantity
'- ,' • ".'•• •-' r
90
90
90
200
200
200
20
20
2
600
2
2
600
600
300
300
300
7.000
1
700
700
700
2.000
2.000
200
200
200
200
200
130
130
llffmnrc
••'' :•:,':
UCIO.Q-IO
UC-ll.Q-IO
UC-I2.Q-IO
IC-36.Q-9
UC-II.Q-9
UC-I2.Q-9
UC-36.Q-9
UC-I7.Q-9
UC-31
UC-IO
UC-31
UC-3 1
UC-25
I KM 2
UC-36.Q 8
UC-I1.Q8
UC-I2.Q 8
UC-32.Q-8
1IC-17
UC-IO
UC-35
UC-25
UC-3 2
UC-8
UC-IO
UC-9
UC-35
UC-25
UC-12
UC-IO
UC-9
Tolal
Coil
$167
$2.700
$23.% 2
$•172
$1.631
$14.502
$•17
$14.000
$1.546
$1,110
$900
$1.600
$18.000
$159,744
$2.595
$9.000
$79,872
$1.260
$55.600
$1,295
$3.402
$1.260
$1,100
$1,040
$170
$1.322
$972
$6.000
$5.3.248
$241
$2.159
I'lTWIll Will III
Coil
$167
$2.700
$21. %2
$•172
$1.634
$14. VU
$47
$14,000
$1.516
$1.110
$'X10
$1.600
$18.000
$159.744
$2.595
$9.000
$79.872
$1.7^0
$55,(.0(1
$1.295
$1.107
$1.260
$1.100
$1.0-10
M/0
$1.32?
$97?
$6.000
$53.248
$?•!)
5?.l V>
-------
TABLE 10.2 COSTS OF SELECTED REMEDY
Cu.l linn 1
(.'ontiimnliny Soil Sampling
Tnui5|K)it«lion ID I.nmlfill
l)is|Hisnl nl ImhlMiinl l.nnilUM
I'xi nvnlion of I'tnnir.r US 1 111 Soils - Cnmnlidilc
ID T«nk l:«rni Area
Conlinnntui y Soil Snniplinp,
rinnr.|H)tt Soils lo t'np Arm
ItncHill CiniMilidnlcil Soil
Itniklill Onn Snil in lvxc«vMc I'HCis In Tiink Furin Arc* frotn l:,«sl Side
Mxcuvitr/l.oiiil Soils
lipiir.jHMl Soils
IliuUill Cnmoliilnlrd Soil
('(•tilimiiiliify Soil Sninplinp,
llncklill Clc«n Soil in Kxcnvnlrxl Arcns
Krj;.iii(lc r.xcuvnir.l Arms
Hr.vrP.rl,li,,,
llncklill OHM Soil Tin C«p Arr.n
Kcvrp.rlnliiHi
l:.xr«v«liini of Soil/Dolxis
Ihisl/Aii (,'inilrnls - l-'omn
('ixilninnloiy Soil Sninpling
MnlrrinU 1 Iftinllin|;/Sc['.rcp,nlion
1 r»ns|Knl»liosnl it ISCA l.nniHill
SUrt Vcir Knil Yrir Hull Cosl
1 1 $1.86
I I $30.00
I I $100.00
1 1 $1.85
1 1 $1.86
I I $1.80
1 1 $2.25
1 1 $2.25
1 1 $0.55
1 1 $0.52
1
1 1 $10,155.00
1 1 $29.185.00
I $1.85
1 $1.80
1 $2.25
1 $1.86
i I $2.25
I $0.55
I $0.52
I $2.25
I $0.52
1
1 1 $2.11
I I $I6.6I
I I $1.86
I I $I.3I
I I $30.00
I I $266.21
Hulls
/cy
/cy
/cy
/cy
/cy
/cy
/cy
/cy
/sy
/.sy
12 weeks
/mo •
/cy
/cy
/cy
/cy
/cy
/sy
/sy
/cy
/sy
Mnliili/ji
Indirccls
/cy
/cy
/cy
/cy
/cy
/cy
Qmnlllr
130
130
130
2.300
2,300
2,300
2.300
2,300
700
700
1
1
5.000
5,000
5,000
5.000
S.OOO
1 0.000
10.000
6,000
8.000
lioii/Dcmoliili/nlion:
. Overhead &. Profit:
|ji|;incxring Design
Contingency
Soils
2,000
2,000
2.000
2.000
2.000
2.000
Rcfcmire
UC-35
UC-2S
UC-I2
UC-IO
UC-35
UC-II
UC-H
UC-H
UC-32
UC-8
UC-10
UC-10
I
UC-IO
UC-25
UC-H
UC-35
UC-H
UC-32
UC-8
UC-50
UC-8
SuMoUl:
MI.MI.
•1%
30V.
2V,
20%
Cipllil SulHolil:
UC-18
UC-9
UC-35
UC-19
UC-II
UC-12
Told
Cosl
$632
$3.900
$13.000
$1,255
SII.I78
$1.110
$5.175
$5.175
$385
$.161
$10.155
$117.910
$9.250
$9.000
$ 1 1. 250
$21.300
$ll.250
$5.500
$5,200
$13.500
$1,160
$762.828
$30.51.1
$2.18.002
$20.627
$210.391
$1.262.361
$1,280
$33,220
$9,720
$2.620
$60.000
$532.180
j'mrnl VVortii
Cojl
$632
$3.900
$13.000
$1.255
sn.m
$1.110
$5. 1 75
$5.175
$185
$161
$10.155
$117.910
$9.250
$9.000
$11.250
$21.300
$ll.250
$5,500
$5.200
$13.500
$•1,160
$762.828
•* $30.513
$218.002
$20.627
$210,391
$1,262.361
$1.280
$33.220
$9.720
$2.620
$60.000
$532.180
-------
TABLE 10.2 COSTS OF SELECTED REMEDY
ToUl I'lTSfiii Woilh
Coil linn \
Demolition oCSlab
lrans|>oitalioncirsiab to TSCA Landfill
Disposal ofSlab in TSCA Landfill
Investigation under Slab
llacklill Clean Soils
licvcgclnlion
Slirl Yrir Knil Ytir Hull Coil
$.1.08
$30.00
$266.21
$1.215.00
$2.25
$0.52
unit! Q<'«!!i!ir
/sy 8.100
/cy 200
/cy 200
/sample 10
/cy 2.000
hy 2.000
MoJiiliulioiv'Dctiioliilir.jluxi:
IndircvlJ, Ovcilic«d A l*rofil:
l:.ii|;incciing Design:
Coiilingcncy:
Hffrmirt
UC-.10.Q-M
UC-I2.Q-I1
UC-I I
UC-I
UC-25
UC-I
Subtotal:
IIIIML
6%
30%
3V.
30%
Hurled IHIirU Ctpllil Siiblolil:
l-NAl'I.
Absorbent Material
i:/.Y/.Skiimncrs
Kxcavalioti of Overburden
llncklill ol Overburden
I'xcavalion
Dust/Air Controls - loam
1
Confirmatory Soil Sampling
Tmm|K>il«li(Hi to TSCA Landlill
Dis|x,sal at TSCA Landlill
(iraiinil H'atrr
Deed Restriction1;
Microcosm Sliulyf*)
$750.00
$110.00
$1.62
$2.25
$1.K5
/ $1661
$1.86
$.10.00
$266.21
I
I I $10.000.00
1 1 $100.000.00
/pallet 10
/skimmer 10
/cy 1 9.000
/cy 1 9.000
/cy 3.000
/cy 3.000
/cy 3,000
/cy 3.000
/cy 3,000
Mobili^jiliod/Deinoliili/Jilioti
Indirccls. Ovctlicud A 1'iolil
r'nginccring Design
Conlingcncy
LNAIM,
lump sum 1
/study 1
Moliili/.«li(ni/l)ciiu>liili«liixi
UC-I 7
UC-I 7
UC-26
UC-M
UC-IO
DC- 29
UC-35
UC-25
UC-I 2
Subtotal:
IIMMI.
5V,
.10%
2%
.10%
Cipllil Subtotal:
UC-15
UC-.11
Subtotal
LI .ML
3%
IndirccU. Ovcilictd A I'rofil: .10%
ClMl
$25.872
$6,000
$5.1.218
$12.150
$1.500
$1,010
$715.110
$11.708
$216.951
$10,801
$3I7,27J
$1,171,871
$7.500
$16.100
$87.780
$12.750
JS..VM)
$19,810
$11.580
$90.000
$798,720
SI. 111. Ill)
$55,656
$150,610
$30.188
$161.915
$2.011.718
$10,000
$100,000
$110.000
$1.200
$1.1.260
Coil
$25.872
$6.000
$5.1.218
$12.150
$1,500
$1,010
$715.1 1(1
$11.708
$216.951
$10.801
$117,278
$1.171,871
$7.500
$16.100
$87.7KI)
VI 2. 7 Ml
$S 5M)
$19.8(0
$11.580
$90,000
$798.770
$1.111.110
$55.656
$150.610
$10.188
$161.915
$2.011.718
$10.000
$100.000
$110.000
$4.200
$1.1.76(1
-------
TABLE 10.2 COSTS OF SELECTED REMEDY
Coil linn j
'
,. • , . . • ,....,.,,.. ..VI, .,•,..' -.->. :,. : ., i. ,, si ».-, ;/.••.
Soih
Notic
.«•
lluritd Drhrii
1,
IJVAI'I.
OfTsilc InciiKTitiim nCI.NAI'l,
l.iilxif
Coiifiiinnlmy l.NAI'L Sampling
(irminit Water
InliinMC Kcmcilinlioii Mnniliuing
i^ -. ±_^~ — — ^^=
Slirt Yeir Knil Ynr Hull Cojl Unlls Oiiinllty Ittfrrtiirt
Knginccring Design: 2V.
CoiilingctKy: 20V.
Croimdwilrr CiplUI Stililolit:
Total Cipllil Coils:
' , '•<• MI i'""K-' > •'Upcnllotu A Milnlctuntt Coili ••• • >"'.•.:<<:' :
NA NA NA NA NA NA
Stililotnl:
1
Moliili7jilictnol)ili7jilioi): 0V.
liidiiccls, Ovcfhcail A I'rnfil: 0%
Uitginccring Design: 0V.
Contingency: 0V.
SiilliOdM SuliloUl:
/
NA NA NA NA NA NA
SuliloUl:
Mii: 0%
Imlitccls. (7vcihc4id A IVofil: 0V.
r.neinccring IX:jigM: 0V.
O>iilinp,ciicy: 0V.
llutlrd Drbili OAM Snlilolil:
| | $700.00 Alnnn 300 DC- 1/
| | $5000 /lir 210 UC-17
i
I I $1.120.00 A|lr 4 UC-3B
Sulilcilil:
IIMMM
Moliili/Jlioii/Dctnobili/^lion: 5V.
Indirccls. (>vctlic*d A IVofil: 30V,
l-'nginccring Design: 0V.
ConlingciKy: 30%
I.NAI'l, OAM Sutilnltl
i
| 2 $730.00 /s»mplc-yr 80 UU--1.I
S'ulilotiil
Tol.l 1
Coil
$3.749
$1».2'12
$22';.'t5l
s-t.sm.-io-t
'
$0
$0
$0
w
$0
$0
$0
$0
$0
$0
JO
$0
$0
III
$210.000
$10.500
$•1.480
$22'l.980
$11. 249
$70,869
$0
$92.129
$.199.227
$! Id, 800
: $116.800
'rrifiil Wnillt
Ctnl
$.1.7-1')
J18.2U
$229..|5I
$-l.88l.'l()4
$0
$0
JO
JO
$0
$0
$n
$0
$0
JO
JO
JO
JO
VO
$210.000
$10.51)0
J'l.'IKI)
$224.980
$11.249
$70.869
JO
$92.129
$.199.227
$108.589
-------
TABLE 10.2 COSTS OF SELECTED REMEDY
Oul llrm ) Slirl Yfir Kml Ynr llnll Coil Unlli Qtiinllty Rcfmnce
I.I. Ml.
MuliiliMilinn/DcmnliiliMlinn: .1%
Indirect*. Ovcrlicid A Profit: 10%
I'nfiinccriiig Design: 0V.
Contingency: 20%
Croitndtvilrr OAM SuModl:
Told 0AM Coin:
1
: , ,• ... : >:-'ii > ' Long-Ttnn Oprnlloiu A M«lnlci»«nct Coili :•
.V.'i'/t
None NA NA NA NA NA NA
.Subtotal:
}
liHlircclJ, OvctlicaJ A l*rofil: 0V,
1 Contingency: 0%
1 .Soil* Long-Trnn OA M ,SnWo(.l:
lluiinl Drtirii
Mi»^ ; NA NA NA MA NA NA
Siibl.ilnl:
liulirccls, Ovcil>c«d A Pro fit: 0%
Contingency: 0%
Iliulrd Drliitt I.mig-Trmi OAM SuMndl:
I.NAI'1.
M,1lr NA NA NA NA NA NA
Siiltlolnl:
Imlirccls. Ovcrlrcad A Profit: 0%
Contingency: 0%
I.NAI'I. Long-Term OAM StiMoUl:
{inmntl ll'tifrr
(iioiiiul Wntrr Monilniiiip, 1 30 $1,255.00 /sninplc-yr 20 UU-.I
Site Krvicws 1 30 $11.720.00 /5 yrs 1 UC-2
Sul.ic.l.l:
TnUI 1
CoM
$.1.5(11
$Ki.O'H
$0
$31.279
$117.674
$5Hf..WI
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$75.1.000
$70.120
$823.320
i'rrar n( Worth
Co»l
$3.258
$13.551
$0
$2'>.0»0
$171.181
$57.1.708
JO
$0
$0
$0
$0
_ ^ $_o
M
$0
$0
...„
J>
$0
JO
$0
$0
$0
$385.850
$12,605
$-118.155
-------
TABLE 10.2 COSTS OF SELECTED REMEDY
linn
.
Slirt Vtir
Knd Vcir
Unll Cosl
Units
Qiiinllly
^ii, - t_l-1-
lurrrtnfe
tolil
Cojl
Worth'
Cmt
I.I.MI.
ItHlirocij. Ovcilic.il A IW.I: 10V. $21f..W! JI2S.VU.
Coniingcncy: 20% __ "I'M"!* ___ ?L??'??L
Groiinilwiltrl.ong-TtnnOAMSuMol.l: " $1.2*1.179 $f-S2.789
Silc-Wiilc Allr.niKlivc L'niu|xiticnls:
Allcinnlivc N III Hot S|xil l.xcuvilioii. 1,11x11111 Dis|K>s*l, CniMilidiilinii. •ml Ctp (Clcin .Soil or Asplull)
Mlr.rnnlivc 1.5: I.NAI'I, Hxlntcliini (KxcAVitini/Skimniing). Direct Tlicnml Treatment (Otfsile Incincmlimi). «nd OfTsilc Dispouil of.Soih
Allcinnlivc (iW.l: IniriiiMc Kemnliitlinn/Altciiiitlion incl)fij, l.imlfill Disposul. Cup (Clcnn Soil of Asplull)
Tnlil Long-Term OAM OM|J:
Tot.I Alltmitlvc Cojl:
l.cvrl of Cniindrncc:
$I.2H-I..179
$r,S2.7R9
$d.752.fiR'« $(1.107.901
$7.000,000 ' $6.000.000
(*) Mir.iiKxiMii study only |icr Tiif inol M iicccjsiiry to coiifinn intrinsic rcinaliilion (Section 2.2.1.3 ofroisiliilily Study).
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Table 10.2A
Costs of Contingency Ground Water Arsenic Treatment for Selected Remedy
Cost Item Start Year End Year Unit Cost Units
Quantity
Reference Total Cost Present
Worth Cost
Capital Costs
Extraction Wells
Well 1 1 $4,500.00 /well
Pump 1 1 $4,361.00 /pump
Utility Trench 1 1 $20.00 /If
Arsenic Treatment
Treatment Vessel 1 1 $122,300.00 /system
Activated Aluminum 1 1 $0.59 /lb
1
1
200
1
36,400
Mobilization/Demobilization:
Indirect, Overhead & Profit:
Engineering Design:
Contingency:
UC-37
UC-39
UC-22
UC-44
UC-44
Subtotal:
MMMH
5%
30%
2%
30%
Total Capital Costs:
$4,500
$4,361
$4,000
$122,300
$21,476
$156,637
$7,832
$49,341
$4,276
$65,426
$283,511
$4,500
$4,361
$4,000
$122,300
$21,476
$156,637
$7,832
$49,341
$4,276
$65,426
$283,511
Operation & Maintenance Costs
Extraction Pump 1 30 $5,357.00 /pump-yr
Discharge to I'OTW 1 30 $0.80 /!()() ci-yi
Compliance Monitoring (Discharge) 1 30 $975.00 /sample-yr
1
70,272
60
Mobilization/Demobilization:
Indirect, Overhead & Profit:
Engineering Design:
Contingency:
Total
Contingency Arsenic Treatment
UC-39
UC-46
UC-42
Subtotal:
MMMH
5%
30%
0%
30%
O&M Costs:
Total Cost:
Cost Range:
$160,710
$1,686,528
$1,755,000
$3,602,238
$180,112
$1,134,705
$0
$1,475,116
$6,392,171
$6,675,683
$300,000
$82,350
$864.205
$899,291
$1,843,847
$92,292
$581,442
$0
$755,874
$3,275,455
$3,558,967
to $400,000
I'S ITRO
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Table 10.2B
Costs of Contingency Ground Water Containment for Selected Remedy
Cost Item Start Year
End Year Unit Cost Units Quantity Reference
Total Cost
Present
Worth Cost
Capital Costs
Extraction Wells
Well 1
Pump 1
Utility Trench 1
UV Oxidation
System 1
Transportation 1
Setup 1
Facility 1
1 $4,500.00 /well 1 UC-37
1 $4,361.00 /pump 1 UC-39
1 $20.00 /If 200 UC-22
1 $67,000.00 /system 1 UC-22
1 $1,500.00 /system 1 UC-22
1 $3,000.00 /system 1 UC-22
1 $1,812.48 /system 1 UC-33
Subtotal:
MMMH
Mobilization/Demobilization: 5%
Indirect, Overhead & Profit: 30%
Engineering Design: 2%
Contingency: 30%
Total Capital Costs:
$4,500
$4,361
$4,000
$67,000
$1,500
$3,000
$1,812
$86,173
$4,309
$27,145
$2,353
$35,994
$155,973
$4,500
$4,361
$4,000
$67,000
$1,500
$3, 000
$1,812
$86,173
$4,309
$27,145
$2,353
$35,994
$155.973
Operation & Maintenance Costs
lixlraclioii Pump 1
Discharge to POTW 1
Compliance Monitoring (Discharge) 1
30 $5,357.00 /pump-yr 1 UC-39
30 $0.80 /I00cf-yr 70,272 UC-46
30 $975.00 /sample-yr 60 UC-42
Subtotal:
MMMH
Mobilization/Demobilization: 5%
Indirect, Overhead & Profit: 30%
Engineering Design: 0%
Contingency: 30%
Total O&M Costs:
Total Cost:
Contingency Arsenic Treatment Cost Range:
$160,710
$1,686,528
$1,755,000
$3,602,238
$180,112
$1,134,705
$0
$1,475,116
$6,392,171
$6,548,144
$200,000
$82,350
$864.205
$899,291
$1,843,847
$92,292
$581,442
$0
$755,874
$3,275,455
$3,431,455
to $3,000,000
I'S PTRO
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Figures
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Legend
JJ Main Warehouse and
Building Area
EsflmitHj EXMflt 4 - /Eu
ol BurtM Conerw Z . f^
Tank Farm Area
East of Main Warehouse
| | Balance of Areas
Concrete Loading Ramp
Former LIST 2 Area
Northeast of Metal Warehouse
80
100 ISO 200 fMt
Site Areas
Figure 2-2
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EXPLANATION
..•{- >, -,;^;f
•"
4*
IT*
SITt BOUNDARY
| Bl«l MHO
RAI_ROAD
- rtNcE
SHALLOW OHOUNO WATtR MONITORING wfLL
DEEP GROUND WATER MONITORING WtLL
SOIL SAUPLEISI
DEEP SOIL BomHUi 1)0 FtEII
J*. SUBSURFACE TRENCHCS Ann
I SAMPLE LOCATIONS
ME TEOROLOdCAI. STATION
*'" VOLATILES 5AMPLIHO STATION
SURFACE WATER SAMPLE
PIEZOMETER LOCATIONS
inosono oo ---
C I8B4BOO 00 —
E IB9470O.OO —
CDM
FEDERAL PROGRAMS CORPORATION
tdUr? of Cfem|) Dr««»cr It Ucl«* (no.
WEST SAMPLE LOCATION
MAP
PETROCIIEM/EKOTEK SITE
Fiquic G IA
-------
1883100.00 —
E isasooo oo —
FENCE
SHALLOW OROUNO WATER MWITOOtNG WEL
OCEP OR(X»A WATER MONITORING WELL
SOIL SAMPLEISI
^EP SOIL ecwwcs i>5 TITI
<° SUBSURFACE TRENCHES AND
"" SAMPLE LOCATIONS
GCOPROBE LOCATION
METEOROLOBCAL STATION
AIR VOLATILE? 5AMPLMO STATION
SURFACE WATER SAMPLE
'IE70METCP LOCATIONS
FTDEHAi PROGRAMS CORPORATT^S
EAST SAMPLE LOCATION
MAP
PETROCHEM/EKOTEK SITE
-------
Legend
Finn, Hot Spot ind Norttiim
Portion o( WinliouM/BuUingi
ina Does Not Include Dtbrii Ant)
Hot Spot (10-4 Risk- \
Based) Exceedance Area
PRG (10-6 Risk Based)
Exceedance Area
Debris Area
Former UST 2 Area
Total Hydrocarbon
Hot Spot Area
BO 100 150 200 feet
Exceedance Areas 0-1 Feet Depth
6 1 1 3A
-------
III PRG (10-6 Risk-
Based) Exceedance Area
Oebns Area
Former UST 2 Area
Exceedance Areas
1-5 Feet Depth
C;n,,rn f 1 .1
-------
Legend
PRG (10-6 Risk-
Based) Exceedance Area \
Debris Area
Former UST 2 Area
0 BO 100 1BO 200 fMt
Exceedance Areas +5 Feet Depth
P 1 1 '
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. ES73LATED EXTENT. OF
LNAPL
FORMER TANK FARM/
PROCESSING AREA
\
NORTHEAST OF THE
METAL WAREHOUSE
EAST OF THE
MAIN WAREHOUSE
i MAIN WAREHOUSE !
•- AND BUILDINGS ,
\AREA
CONCRETE ^v-x/xx \
LOADING
BALANCE
AREAS
(EASTERN
FORMER UST :
NO. 2 AREA -?H
ESTIMATEDV EXTENT
OF DIESEL, IMPACTS
SOURCE: RUST ENVIRONMENT 8 INFRASTRUCTURE 11/94
LEGEND
— LNAPL FLUME
— PHYSICAL SITE BOUNDARIES
SCALE IN FEET
50 0 100 200
LNAPL PLUME
PETROCHEM/EKOTEK SITE
SALT LAKE CITY, UTAH
-------
ROUNDWATER
FORMER TANK FARM/
PROCESSING AREA
I MAIN WAREHOUSE
i MAIN WAREHOUSE:
\ AJTD BUILDINGS ;
\AREA
* r
AREAS
(EASTERN HALF)
FORMER UST r^
NO. 2 AREA. ^
ESTIMATED\ EXTEIsT!
OF DIESEL IMPACTS—
SOURCE: PUST ENVIRONMENT 3 INFRASTRUCTURE 11/94
ESTIMATED EXTENT OF CONTAMINATION
AT THE CONCENTRATIONS SPECIFIED
IN THE GROUND HATER PERFORMANCE
STANDARDS.
SCALE IN FEE"
50 0 100 200
GROUND1VATER .PLUME
PETP.OCHEM/EKOTEK SITE
TTV
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X -'-— X ------- X — ;— X- ---- X ---------- X ------ X ---- X
X ---- X ---- X - X --- X--- ..... X- X
D
n
b i
o
00
.if
o
o o o o o
o o o o o o
COM FEDERAL PROGRAMS CORPORATION
• njfc.ldl.rr of Camp Drtxtr It Vflei lea. .
UST LOCATIONS
PETROCHEM/EKOTEK SITE
SALT LAKE CITY, UTAH
0 -1 2
-------
Legend
[\'XJ Excavation Offslte Soils;
' Onsite Thermal Desorption
Selective Excavation;
Onsite Thermal Desorption
[ | LNAPL Removal System
hrHH Clay/Soil Cap with
LLLUI Slurry Wall
$8i Soli Cover
0 BO 100 160 200 faot
Alternative 2 Petrochem Ekotek Site Salt Lake City, Utah
P 9.2 1
-------
Legend
'| : j Consolidate Soils
under cap
K'-'l Selective Excavation
— Offsite TSCA Landfill
| 1 LNAPL Removal System
Clay/Soil Cap and
Slurry Wall
(0 100 160 200 feat
Alternative 3 Petrochem Ekotek Site Salt Lake City, Utah
-------
Legend
Offsite Solid Waste
Landfill Disposal
Selective Excavation
Offsite TSCA Landfill
.•CN Direct Excavation and
Disposal of LNAPL Soil
LNAPL Removal System
Capping of Remainder
(Clay/Soil)
15000 CY
10000 SY
(indudM Oflite, Formir
rvnir Hot Spoti tnd Northern
Portion of Wirttioutt/Buldlnjj
mi Don Not Indudi D«brt» AIM)
MrSpvgmpy '
Vipor ExncMn
Selective Removal (LNAPL)
Offsite Disposal of
Debris and Soil
] Air Sparging/Vapor Extraction
(to be divided into 4 areas)
tO 100 160 200 feet
Alternative 4 Petrochem Ekotek Site Salt Lake City, Utah
-------
Legend
| : j Onslte Thermal
Desorption
Direct Excavation and
Treatment LNAPL Soil
LNAPL Removal System
Capping of
Remainder (CLAY/SOIL)
Selective Removal
(LNAPL); Offsite
Disposal of Debris;
Treatment of Soil
Selective Excavation
offsite TSGA Landfill
16000 CY
10000 SY
(IndudM OW&, Formr4M
Finn, Hot Spot, and Norttitm
Portion ot Win
go
100 160 200 fMt
Alternative 5 Petrochem Ekotek Site Salt Lake City, Utah
-------
Legend
Finn, Hot Spot, inti Northern
Portion of
am Do*t Not Indudi D*M§ AIM)
Onslte Thermal
Desorption
Direct Removal of LNAPL \\\
through Excavation & Skimming
Complete Removal;
Offsite TSCA Disposal of
Debris; Treatment of Soils
Selective Excavation
Onslte Thermal Desorption
0 • 60 100 160 200 feet
Alternative 6 Petrochem Ekotek Site Salt Lake City, Utah
-------
Legend
I I I] Onslte Thermal
1——J Desorptlon
|x^[ Direct Removal of LNAPL
through Excavation
& Skimming
Complete Removal;
Offslte TSCA Disposal of
Debris; Treatment of Soils
Selective Excavation
Onsite Thermal Desorptlon
Alternative 7 Includes groundwater
extraction (40 to 100 gpm)
and discharge to POTW.
Alternative 8 includes groundwater
extraction (500 gpm), traatmant, and
reinfection.
urn, Hot Spot and Norttiwn
Portion of WmhoiMAuMingt
MM Don Not Indudt Dibrk Ant)
BO 100 180 200 feat
Alternative 7 & 8 Petrochem Ekotek Site Salt Lake City, Utah
Fipure 6.9.7.1
-------
Legend
nm, Hot Spol tnd Northern
Portion of WMhouMAuMlngs
ant DOM Net Indud* Otbrli AIM)
Excavation and Treatment
by Onslta Land Farming
Onslta Land Farm
Direct Removal of LNAPL
through Excavation & Sklmmlm
Complete Removal; Offslte
Disposal of Debris and
Soil In Landfill
Risk-Based Hot Spot (10-4 Risk-
Based) Removal and
Disposal In TSCA Landfill
Total Hydrocarbons Hot Spot Removal
and Disposal In Solid Waste Landfill
ao 100 IBO 200 ta«
Alternative 9 Petrochem Ekotek Site Salt Lake City, Utah
-------
Legend
I I 1 Excavate and Consolidate
1 3 Soils Under Clean Soil
form*
Uric
10000 8Y(WM«t OP) / Firm'
1400 Jt ,' , ATU,
Selective Excavation
Offslta Disposal
Direct Removal of LNAPL
through Excavation & Skimming
Consolidation Area Clean Soil
Removal LNAPL
Saturated Debris
Offslta disposal
0 BO 100 1BO 200 fMt
Alternative 10 Petrochem Ekotek Site Salt Lake City, Utah
p O
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