910R95008
RECORD OF DECISION
KERR-MCGEE SUPERFUND SITE
CARIBOU COUNTY, IDAHO
September 1995
U.S. Environmental Protection Agency
Region 10
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PREFACE
This Record of Decision documents the remedial action plan for contaminated ground water and
associated sources, and secondary risks associated with on-site solid wastes at the Kerr-McGee
Superfund site. This Record of Decision serves three functions:
• It certifies that the remedy selection process was carried out in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act as amended,
and to the extent practicable, with the national Contingency Plan.
• It summarizes 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, the
selected remedy, and the rationale behind the selection.
In addition, the Record of Decision provides the framework for transition into the next phases
of the remedial process, Remedial Design and Remedial Action.
The Record of Decision consists of three basic components: a Declaration, a Decision
Summary, and a Responsiveness Summary. The Declaration functions as an abstract for the
key information contained in the Record of Decision and is signed by the U.S. Environmental
Protection Agency Regional Administrator. The Decision Summary provides an overview of the
site characteristics, the alternatives evaluated, and an analysis of those options. The Decision
Summary also identifies the selected remedy and explains how the remedy fulfills statutory
requirements. The Responsiveness Summary addresses public comments received on the
Proposed Plan, the Remedial Investigation/Feasibility Study, and other information in the
administrative record.
This Record of Decision is organized into three main sections: the Declaration, the Decision
Summary, and Appendices. Appendix A provides the letter of concurrence from the State of
Idaho, Appendix B consists of the Responsiveness Summary, and Appendix C contains tables
and figures.
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TABLE OF CONTENTS
PREFACE i
DECLARATION . 1
1.0 SITE DESCRIPTION 4
1.1 Introduction 4
1.2 Site Name, Location, and Description 4
2.0 SITE HISTORY AND KEY MILESTONES 7
2.1 Historical Site Activities 7
2.2 Key Milestones : 8
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 10
4.0 SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY 11
5.0 SUMMARY OF SITE CHARACTERISTICS 11
6.0 SUMMARY OF SITE RISKS „ .17
6.1 Human Health Risks .17
6.1.1 Purpose and Approach ....17
6.1.2 Identification of Contaminants of Concern 18
6.1.3 Exposure Assessment .18
6.1.4 Toxicity Assessment 19
6.1.5 Risk Characterization 21
6.2 Environmental Risks 22
6.2.1 Ecological Risk Assessment 22
6.2.2 Finch Pond Evaluation 23
6.3 Uncertainty 24
6.3.1 Human Health Risk Assessment Uncertainties 24
6.3.2 Ecological Risk Assessment Uncertainties , 25
6.4 Need for Action 25
6.5 Remedial Action Objectives 25
7.0 DESCRIPTION OF ALTERNATIVES 27
7.1 Summary of Plant Process Changes 27
7.1.1 Components of Liquid Source Elimination 27
7.1.2 Relationship of LSE to Remedial Action Alternatives 28
7.2 Ground Water Modelling 28
7.3 Summary of Ground Water Alternatives 28
7.3.1 No Action 29
7.3.2 Monitoring and Institutional Controls 29
7.3.3 Liquid Source Elimination 29
7.3.4 Liquid Source Elimination, On-site Disposal of Waste Pond
Solids, and Reuse of Calcine Tailings 29
7.3.5 Ground Water Extraction and Carbon Treatment;
Reuse of Calcine Tailings 30
7.3.6 Ground Water Extraction via Reverse Osmosis
and Carbon Treatment, Disposal of Sludges;
Reuse of Calcine Tailings 30
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7.3.7 Ground Water Extraction and Carbon Treatment;
Reuse and Capping of Calcine Tailings : 31
7.4 Summary of Roaster Reject Remedial Action Alternatives .31
7.4.1 Institutional Controls .32
7.4.2 Resource Recovery/Reuse 32
7.5 Summary of Windblown Calcine Tailings Alternatives 32
7.5.1 No Action for Windblown Calcine Tailings 32
7.5.2 Excavation and Disposal for Windblown Calcine Tailings 32
7.5.3 Capping of Windblown Calcine Tailings 33
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 33
8.1 Threshold Criteria 33
8.1.1 Overall Protection of Human Health and the Environment 33
8.1.2 Compliance with ARARs 35
8.2 Primary Balancing Criteria '. 35
8.2.1 Long-Term Effectiveness and Permanence 35
8.2.2 Reduction of Toxicity, Mobility, or Volume through Treatment 36
8.2.3 Short-Term Effectiveness 36
8.2.4 Implementability 37
8.2.5 Cost : 38
8.3 Modifying Criteria 39
8.3.1 State Acceptance 39
8.3.2 Community Acceptance ;-. 39
9.0 SELECTED REMEDY '. 39
9.1 Remedial Actions for Ground Water 39
9.1.1 Remediation Goals for Ground Water Actions 39
9.1.2 Selected Remedial Actions for Ground water 40
9.1.3 Cost and Volume Estimates for Ground water Actions 40
9.2 Remedial Action for Roaster Reject Solids 41
9.2.1 Remediation Goals/Risk Levels for Roaster Rejects 41
9.2.2 Remedial Action for Roaster Reject Solids 41
9.2.3 Cost and Volume Estimates 41
9.3 Windblown Calcine Tailings 41
9.3.1 Remediation Goals/Risk Levels .41
9.3.2 Remedial Action for Windblown Calcine Tailings 41
9.4 Plant Process Changes Contributing to Remediation Goals 42
9.5 Timely Implementation of Plant Changes 42
9.6 Potential Changes to the Selected Remedy 43
10.0 STATUTORY DETERMINATIONS .43
10.1 Protection of Human Health and the Environment 43
10.2 Compliance With Applicable or Relevant and Appropriate Requirements 43
10.3 Cost-Effectiveness 44
10.4 Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable 44
10.5 Preference for Treatment as a Principle Element 45
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES AS
in
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APPENDICES: APPENDIX A - STATE LETTER OF CONCURRENCE
APPENDIX B - RESPONSIVENESS SUMMARY
APPENDIX C - FIGURES AND TABLES
APPENDIX D - ADMINISTRATIVE RECORD INDEX
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LIST OF FIGURES
Figure
F-1 Location Map 5
F-2 Kerr-McGee Property Boundaries 6
F-3 Vanadium Extraction and Processing Flow Sheet C-1
F-4 Facility Map of Impoundment and Product Storage C-2
F-5 . Historical Waste Impoundments C-5
F-6 Focus of Cleanup Actions 9
F-7 Data Points Available in All Media 13
F-8 Summary of COPCs by Media 14
F-9 Approximate Direction of Ground Water Flow 16
and Extent of Ground Water Contamination"
LIST OF TABLES
Table Page
T-1 Nature and Quantity of Materials Generated at the Soda Springs Plant C-3
T-2 Past and Present Waste Ponds C-6
T-3 Estimated Maximum Concentration of COCs in Ground Water C-9
T-4 Estimated Maximum Concentrations of COCs in Liquid Sources C-10
T-5 Estimated Maximum Concentration of COCs in Solid Sources C-11
T-6 Identification of Chemicals of Potential Concern in On-Site Source Piles C-12
T-7 Identification of Chemicals of Potential Concern in Off-Site Soil C-14
T-8 Identification of Chemicals of Potential Concern in Ground Water C-17
T-9 Work Practices Around Source Materials at KMCC Facility 20
T-10 KMCC Risk Based & Estimated Maximum Concentrations of COC in Ground Water 26
T-11 NCP Nine Criteria 34
T-12 Current Industrial Scenario Exposure Factors C-19
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LIST OF TABLES (continued)
Table Page
T-13 Future On-Site Industrial Scenario Exposure Factors C-21
T-14 Future Off-Site Residential Scenario Exposure Factors C-22
T-15 Summary of Human Health Risks Current Industrial Scenario Concern in Ground Water C-23
T-16 Summary of Human Health Risks Future Industrial Scenario C-24
T-17 Summary of Human Health Risks Future Residential Scenario Northern Border C-25
T-18 Summary of Human Health Risks Future Residential Scenario Southen Border C-26
VI
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DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Kerr-McGee Superfund Site
Caribou County, Idaho
Statement of Basis and Purpose
This decision document presents the selected remedial action for the Kerr-McGee Superfund Site,
in Caribou County, Idaho, which was chosen in accordance with the requirements of the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended, and to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This decision is based on the administrative record for this site. The
State of Idaho concurs with the selected remedy.
Assessment of the She
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this Record of Decision, may present an imminent
and substantial endangerment to public health, welfare, or the environment.
Description of the Selected Remedy
This remedial action addresses all necessary response actions at the Kerr-McGee Superfund Site.
The Kerr-McGee Chemical Corporation's (KMCC) Soda Springs plant is an active operating plant
which primarily manufactures vanadium and vanadium related products from ferrophosphorus ore
and limestone. The processing of the ferrophosphorus and limestone generates three industrial
waste water streams: the solvent extraction (S-X) raffinate waste stream, calcine sluicing waste
stream, and the scrubber ponds waste stream. Solid wastes are also generated: roaster reject
solids, calcine tailings, S-X pond solids, and scrubber pond solids. The primary goals of this
remedial action are to prevent potential human exposure to ground water contaminated with
molybdenum, vanadium, arsenic, tributyl phosphate, total petroleum hydrocarbons, and
manganese, and to restore ground water to its beneficial use as a potential drinking water
resource.
The selected remedy for contaminated ground water includes elimination of uncontrolled liquid
discharges from the site which are the main source of ground water contamination, recycling or
containment of solid sources of contamination, ground water monitoring, and institutional
controls.
The remedy for ground water specifically includes:
o Elimination of uncontrolled liquid discharges from the facility as soon as practicable;
o Excavation and reuse/recycling of buried calcine tailings during the next eight years.
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Excavation and disposal of Solvent Extraction and Scrubber Pond solids in lined cells on-
site;
semi-annual ground water monitoring to determine the effectiveness of source control in
achieving ground water performance standards for the following contaminants of
concern:
Molybdenum
Vanadium
Manganese
Tributyl Phosphate
Total Petroleum Hydrocarbons
Arsenic
o Establishment of Institutional Controls (deed restrictions, limited access, well restrictions
and/or well-head protection) in affected off-site areas to prevent ingestion of ground
water for as long as the ground water exceeds the performance standards.
In addition to the selected remedy for ground water, which addresses the principal risks posed
by this site, this Record of Decision includes remedial actions to address two localized problems:
potential human exposure to roaster reject materials stored above ground and migration of
windblown calcine tailings to surrounding land.
The selected remedial action for the roaster reject materials is resource recovery/reuse {currently
being implemented), and the selected remedial action for windblown calcine tailings is excavation
and disposal (which has been completed).
As part of the overall site strategy, though not part of this selected remedy, KMCC has
developed and submitted to EPA and the State of Idaho, a waste minimization/treatment plan to
eliminate liquid discharges to ground water from the facility within two years. The plan includes:
o construction of new lined ponds to contain the main source of ground water
contamination (S-X raffinate currently discharged to leaking uniined ponds);
o construction and operation of a phosphoric acid plant to consume scrubber water and
calcine tailings to produce phosphoric acid, ammoniated phosphate, and gypsum
fertilizers as marketable products.
KMCC has obtained necessary state permits to construct lined ponds to replace the existing
uniined S-X pond. The new lined ponds are now under construction. The company has also
applied for the necessary permits to operate a phosphoric acid plant which will reuse/recycle
wastes that are currently sources of ground water contamination.
Successful implementation of KMCC's plan, including timely issuance of all permits, along with
excavation and disposal of the S-X and scrubber pond solids, should effectively address the
sources of ground water contamination. This will be subject to confirmation by ground water
monitoring.
Based on information obtained during the Remedial Investigation and on a careful analysis of all
remedial alternatives, EPA and the State believe that the selected remedy will achieve the
remedial action goals. It may become apparent, during the remedy (after implementation of
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source control and continued monitoring) that contaminant levels have ceased to decline and
are remaining constant in ground water at levels higher than the remediation goal. In such a
case, the performance standards and/or remedy will be reevaluated.
Declaration of Statutory Determinations
The selected remedy is protective of human health and the environment, complies with Federal
and State laws and regulations that are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes permanent solutions and alternative
treatment (and resource recovery) technologies, to the maximum extent practicable for this site.
The selected remedy under CERCLA includes treatment, specifically reuse/recycling of calcine
tailings as part of source control to address contaminated ground water and reuse/recycling to
address the roaster reject materials. Re-capture and treatment of contaminated ground water
was not found to be practicable at this site and was not selected because it is much more
expensive than source control, and is neither expected to substantially decelerate the time
frame for cleanup nor significantly reduce the risk associated with contaminants in ground
water beyond what will be achieved with source control actions alone. Since treatment was
incorporated to the extent practicable for this site, the selected remedy satisfies the statutory
preference for treatment as a principal element of the remedy.
Because this remedy will result in hazardous substances remaining in ground water and in the
roaster rejects area above health-based levels, a review will be conducted within five years after
commencement of remedial action to ensure that the remedy continues to provide adequate
protection of human health and the environment.
Chuck Clarke . Date
Regional Administrator
U.S. EPA Region 10
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DECISION SUMMARY
Kerr-McGee Superfund Site
Caribou County, Idaho
1.0 SITE DESCRIPTION
1.1 Introduction
The Kerr-McGee Superfund site ("the site") was listed on the National Priorities List (NPL) on
October 4, 1989. Previous investigations of the site identified hazardous substances from the
site entering ground water from unlined industrial waste water ponds.
1.2 Site Name, Location, and Description
The site includes a vanadium production plant, owned and operated by Kerr.-McGee Chemical
Corporation (KMCC),-and located in Caribou County about 1.5 miles north of Soda Springs, Idaho
(population approximately 3,000) on the east side of State Highway 34 (see Figure 1). KMCC
owns approximately 332 acres of industrial and agricultural land including the plant facilities (see
Figure 2). The plant was constructed in 1963 and covers approximately 80 acres. The remaining
252 acres are used for agriculture. KMCC manages by-products and waste materials resulting
from production operations in three unlined surface impoundments: the solvent extraction (S-X)
pond, scrubber pond, and the calcine tailings pond. Industrial waste waters discharged to
unlined ponds on-site currently infiltrate into the underlying ground water at a rate of 300 to 350
gallons per minute.
The industrial site is surrounded on the north, east, and south sides by agricultural land and on
the west side by State Highway 34. To the west of Highway 34, Monsanto Chemical Company
owns and operates an elemental phosphorous plant, which is also a Superfund site listed on the
National Priorities List (NPL). KMCC owns the agricultural land to the north and east of the
industrial site. A local farmer owns the land to the south of the site.
The site is located within the Bear River Basin which is characterized by broad, flat valleys with
a few scattered topographic features including cinder cones, rhyolitic domes, and uplifted fault
blocks. The site lies in a valley at approximately 6,000 feet elevation. The valley is bordered by
northwest trending mountain ranges reaching approximately 8,OOO feet in elevation. The
northern boundary of the Bear River Valley drainage basin is formed by the Blackfoot Reservoir,
located approximately thirteen miles north of the KMCC site.
Surface drainage in the valley is predominantly to the south. Soda Creek forms the largest
surface water drainage feature, flowing from its headwaters near Fivemile Meadows, southward
toward the Alexander Reservoir located to the west of Soda Springs. Natural springs are
important hydrologic features of the basin, and emerge at several locations to the ground surface
as result of discharge from the underlying ground water aquifer. There are no known floodplain
zones, endangered species, or historical or archeological sites in the immediate vicinity, of the
site. There is a small wetland (Finch Spring/Pond) about one mile south of the site.
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REFERENCE-
U.S.aS. QUADRANGLE ENTTTLEt)
•SODA SPRINGS. DAHO* -
PROVISIONAL EDITION - 198Z
CHEMICAL CORPORATION
SOOASPFaNGS.nAHOfiMX!TY
KERR-McGEE
LOCATION MAP
REVISION:
DATE:
PREWIRED BY:
Dames & Moore
FIGURE 1
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PROPERTY
BOUNDARY
Sooa Springs
REFERENCE-
U.S.GLS. QUADRANGLE ENTITLEO
•SOOA SPWNGS. OAHO--
PROVISIONAL EDmON - 1982.
KERR-MCGEE
lit ( CHEMICAL CORPORATION
SOOA SPWNQS. DAHO RVCUTY
KERR-McGEE
PROPERTY BOUNDARY
MAP
REVISION:
DATE
PREPARED BY:
Dames & Moore
FIGURE 2
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Three primary ground water systems have been identified in the Soda Springs area: the Shallow
Ground Water System, the Mead Thrust Aquifer System (originating from the Aspen Range to
the east of the site); and the Chesterfield Range Aquifer System (originating in the Soda Springs
Hills and Chesterfield Range to the west of the Monsanto Corporation).
2.0 SITE HISTORY AND KEY MILESTONES
2.1 Historical Site Activities
The KMCC Soda Springs plant has operated at its present location since 1963. The vanadium
extraction process is divided into the five steps shown on Figure 3 in Appendix C. These steps
are sizing, conversion, leaching, purification, and packaging. The primary raw materials are
Ferrophosphorous (FeP) ore and limestone. The FeP is purchased from Monsanto in Soda Springs
and FMC Corporation in Pocatello, Idaho. The limestone is mined once a year from a quarry
approximately eight miles east of the plant. The technology used to extract vanadium has not
changed notably since the plant started operations in 1963. Equipment modifications have
increased the processing capacity from an original capacity of 20 tons of ore per day to its
current capacity of 66 tons of ore per day.
Industrial waste waters generated by the vanadium production process are stored in various on-
site ponds. The sized FeP and limestone mix is converted to a water soluble sodium vanadate
via a roasting process. Emissions from the roasters and quench tank are controlled using a
cyclone followed by a venturi scrubber. The air stream flows to the venturi scrubber where
recycled and fresh waters are used to remove solids from the air stream. The air stream then
exits through a stack. A maximum of 210 gallons per minute (gpm) of excess water is
discharged to an uniined scrubber pond which accumulates an estimated 300 tons per year of
scrubber residuals. The location of the scrubber pond is shown on Figure 4 in Appendix C.
Solvent-extraction (S-X) raffinate is contained in a series of three ponds (Figure 4) which consist
of two lined settling ponds that allow limestone to settle, and the S-X pond that contains the
clarified S-X raffinate. The settling ponds are lined with high density polyethylene (HOPE). The
second lined settling pond was constructed immediately downstream of the first lined settling
pond. The lower S-X pond is uniined and excavated into native silts -and silty clays. The S-X
pond has capacity for 5.5 million gallons of industrial waste water and typically operates at 4
million gallons capacity.
Once the vanadium in liquor discharging from the leach tanks has decreased below a specified
concentration, the solids are sluiced to a calcine tailings pond. Approximately 55,000 tons of
leached calcine tailings are produced annually and discharged to an uniined calcine tailings pond.
An average of 80 to 100 gpm of water is used to transport the leached calcine to a tailings pond.
This operation uses recycled scrubber water. Figure 4 shows the location of the calcine tailings
impoundment area. Calcine tailings are deposited at different locations within the impoundment
area depending upon the time of year.
While KMCC's vanadium production process has been substantially the same since it began
operations in 1963, like most operating plants, the KMCC facility is a dynamic entity where
changes are made to improve the efficiency of a process, to meet market demands or to perform
routine maintenance activities. Table 1 in Appendix C lists the nature and quantity of all raw
materials, byproducts, and wastes used at the site. Figure 5 and Table 2 in Appendix C identify
the past and present use of waste ponds at the site. Of the material and waste ponds listed on
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these tables, site investigations described in Section 5.0 have focused cleanup actions on the
following areas (see Figure 6):
-» S-X raffinate pond
-» scrubber pond
-» east calcine tailings area, and
-» roaster rejects pile
Two ponds on the property have experienced containment failures. Both involved ponds in the
S-X raffinate system. In April 1981, the S-X pond lost approximately 2.5 million gallons from
a hole in the bottom of the pond. In September 1989, one of the settling ponds was also
discovered to have a hole in the clay lining in the bottom of the pond. On that occasion an
estimated 650,000 gallons of raffinate was lost.. The hole in the settling pond was repaired, but
another 100,000 gallons of raffinate was discharged to ground water in November 1989. After
the November 1989 pond failure, an HOPE liner was installed.
A Site Investigation in April 1988, leading to NPL listing of the site, identified hazardous
substances in waste ponds including arsenic, cadmium, chromium, lead and vanadium, as well
as three organic compounds.
Samples of boiler blowdown water, roaster scrubber discharge, leached residue solids, and S-X
raffinate were collected as part of the initial Rl activities during January 1991. Analysis of
samples indicate that processing wastes generated at the plant are not regulated as hazardous
wastes under the Resource Conservation and Recovery Act (RCRA) regulations.
2.2 Key Milestones
Previous investigations at the site focused primarily on ground water quality. A summary of
historical milestones include:
May 1985
April 1988
October 1989
March 1990
July 1990
September 1990
October 1990
October 1993
April 1995
June 1995
State of Idaho Hazardous Materials Bureau completed a Preliminary
Assessment of the KMCC facility
U.S. EPA, through its contractor Ecology & Environment, completed a
Site Inspection
EPA listed the Kerr-McGee Superfund Site on the NPL
KMCC was identified as a potentially responsible party for the site
EPA requested that KMCC perform site studies to characterize the nature
and extent of contamination
Agency for Toxic Substances and Disease Registry completed a
Preliminary Health Assessment for the site
EPA signed an Administrative Order on Consent with KMCC to perform
a Remedial Investigation/Feasibility Study
Risk Assessment completed
Remedial Investigation completed
Feasibility Study completed
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3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
This section provides a summary of how the public participation requirements in CERCLA Section
113(k)(2)(b)(i - v) were met in the remedy selection process.
The Remedial Investigation/Feasibility Study (RI/FS) Report and the Proposed Plan for the Kerr-
McGee Superfund site were released to the public for comment on August 1, 1995. These two
documents were made available to the public in both the administrative record and an information
repository maintained at the EPA Superfund Records Center for Region 10 in Seattle,
Washington, and at the Soda Springs Public Library, in Soda Springs, Idaho. The notice of
availability for these two documents was published in the Caribou County Sun on August 3,
1995. A public comment period on the documents was held from August 4,1995, to September
3, 1995.
A public meeting was offered in the Proposed Plan and in the newspaper notice, but no meeting
was requested. A response to the comments received during this period is included in the
Responsiveness Summary, which is part of this Record of Decision (ROD).
In addition to the public comment period EPA conducted the following outreach activities, which
were directed towards interested members of the community to pro vide-current information on
the status of site activities:
September 1989 EPA News Release proposing KMCC site for NPL
August 1990 Community interviews were conducted for Superfund sites in southern
Idaho including Kerr-McGee site
August 1991 Community Relations Plan developed
December 1991 Introductory fact sheet
May 8, 1992 Preliminary Site Characterization Report fact sheet
February 28, 1994 Rl and Risk Assessment information fact sheet
November 22, 1994 Draft Rl report and ground water modelling fact sheet
June 16,1995 Rl and ground water model fact sheet
August 1, 1995 Proposed Plan
August 3, 1995 Notice of opportunity to comment on the Proposed Cleanup Plan
published in the Caribou County Sun newspaper
An administrative record was established at the beginning of the RI/FS and has been maintained
at the EPA offices and the information repository near the site. The selected remedy is based
on the administrative record.
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4.0 SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
Some CERCLA sites are separated into distinct "operable units," such as a "ground water unit"
and a "soils unit", in order to most efficiently remediate the contamination and reduce exposures.
The Kerr-McGee site is not separated into operable units. This ROD addresses the final planned
remedial action at the site. This remedial action, in conjunction with plant modifications
undertaken independently by KMCC, addresses the principal threats to ground water posed by
the conditions at the site.
The selected remedial action for the site recognizes that KMCC's Soda Springs plant is an active
industrial facility and seeks to minimize unnecessary impacts to ongoing operations while
ensuring protection of public health and environment. During the Remedial Investigation KMCC
voluntarily remediated some past disposal areas (e.g., magnesium ammonium phosphate ponds
and boiler blowdown pond-see Figure 5 in Appendix C) and modified their process to
reduce/recycle waste streams. These actions are acknowledged and described in the Rl/FS
document, but have not been managed as part of the CERCLA response action. KMCC has
consulted with EPA and the State on actions that affect the ultimate remedial action and has
applied for the necessary state and/or federal permits related to the individual actions (e.g.,
construction permits for lined ponds, application for air permit for phosphoric acid plant).
The site strategy takes into consideration the actions and process changes that have been
completed or are in process to date. In light of those actions and at KMCC's request, the
Feasibility Study acknowledges the need to eliminate the liquid sources of ground water
contamination and describes the ongoing and completed process changes, but does not
specifically evaluate alternatives to accomplish liquid source elimination. Instead, the selected
remedy specifies the need to eliminate liquid sources and to cease unpermitted discharges from
the facility, and to rely on performance standards and monitoring to ensure the effectiveness of
the cleanup. Actions that are already permitted under state regulatory authority will not be
subject to EPA oversight as part of Superfund cleanup. EPA may require additional actions if the
agency, in consultation with the State, determines that cleanup performance standards are not
or cannot be met in a timely manner.
5.0 SUMMARY OF SITE CHARACTERISTICS
Under EPA's oversight, KMCC collected and analyzed samples of air, soil, waste water, pond
solids and sediment, vadose zone, and ground water at the site between 1991 and 1994. These
efforts were documented in the Remedial Investigation (Rl) report. Sample locations are shown
on Figure 7. Tables 6, 7, and 8 in Appendix C list the contaminants of potential concern sampled
by medium, the range of site concentrations for each, and the maximum background and risk-
based concentrations (screening levels). Figure 8 summarizes the chemicals of potential concern
that were identified for further consideration during the Rl. The final chemicals of concern
addressed in this remedy are discussed in Section 6.0 The major findings of KMCC's
investigations are:
Ground Water. Ground water beneath the site exists in an interconnected aquifer, known as the
Shallow Ground Water Aquifer (or System), which flows through the fractured basalt underlying
the site. Ground water flow in the shallow system is rapid, and is measured in feet per day.
Recharge to the system occurs through precipitation, runoff from irrigation, leakage from the
Blackfoot Reservoir, and from the Mead Thrust Aquifer System originating beneath the mountains
to the east. The basalts of Shallow Ground Water Aquifer is considered to be the primary aquifer
at the KMCC site. The Mead Thrust Aquifer is unaffected by the site.
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The regional direction of ground water movement in the shallow ground water system is to the
southwest. Ground water moves from the eastern half of the site in a predominantly western
direction, and moves increasingly south/southwest at the western site boundary. Discharge from
the Shallow Ground Water Aquifer is to Soda Creek, Finch Spring/Pond, Big Springs, the
Alexander Reservoir, and the Bear River. The City of Soda Springs drinking water supply comes
from Formation Springs, which is an expression of the Mead Thrust Aquifer upgradient and to
the east of the site and the Shallow Ground Water Aquifer.
The largest concentrations of site-related contaminants were detected in on-site shallow wells
adjacent to the S-X pond; concentrations in off-site wells were generally one to two orders of
magnitude lower. The highest concentrations at the site boundary have consistently been found
in monitoring well KM-8 (shown on Figure 7), on the western end of the southern site boundary,
down-gradient from the S-X pond. Constituent concentrations in paired shallow and intermediate
depth wells, both on- and off-site, suggest that mixing of pond seepage (and ground water)
occurs vertically throughout the aquifer. On-site intermediate depth wells generally have lower
concentrations than nearby shallow wells, but observed concentrations are generally greater than
background. Concentrations in deeper wells on-site are close to or within range of background
concentrations.
Potential human consumption of ground water from the affected area south of the plant is the
primary pathway of concern at the site. Arsenic, molybdenum, vanadium, tributyl phosphate
(TBP), manganese, and total petroleum hydrocarbons (TPH) in the ground water exceed risk-
based screening concentrations equal to 10"7 risk for carcinogens or a HI of 0.1 for non-
carcinogens, assuming residential ground water use at the site. The maximum concentrations
of these chemicals in ground water at various monitoring locations are summarized below and
in more detail on Table 3 in Appendix C.
Maximum at Maximum Maximum at
Plant Boundary Off-Site Finch Spring
Vanadium 28.6 mg/l 3.54 0.009
Molybdenum 119.0 mg/l 6.00 0.689
Arsenic 0.08 mg/l 0.007 0.002
TBP 4.4 mg/l 0.48 0.008
TPH 2.2 mg/l 0.5 0.5
Manganese 8.63 mg/l 0.54 0.005
The source of these contaminants is the leaching of industrial waste waters from unlined ponds:
the S-X pond, the scrubber pond, and the active calcine tailings pond. In addition, atmospheric
precipitation passing through the vadose zone are believed to leach contaminants from buried
calcine tailings on the east portion of site, and through S-X and scrubber pond solids into ground
water. Table 4 in Appendix C summarizes the estimated mass and concentration of
contaminants of concern in each of the liquid sources. The concentration of contaminants at
various monitoring locations within the plant boundaries and off-site are also shown. In
comparison with the contaminant levels found in ground water (shown above), the highest
concentration of each contaminant, detected in the S-X pond water, is:
Vanadium 117 mg/l
Molybdenum 155 mg/l
Arsenic 0.19 mg/l
TBP 16 mg/l
TPH 41 mg/l
Manganese 0.16 mg/l
12
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O /ur 10
BAK2
OAir7
BAK4
ASO-OS
OAlrl
OAJrB
Not to Scale
ASO08
AS007
Aso-io
KM-16
• KM-18
• KM-1S
A • KM-17
SO-09
ABAKS
LEGEND
Sample locations
• Groundwater
O /*
A Sofl/Souroepite
FIGURE 7
DATA POINTS AVAILABLE IN ALL MEDIA
-------
Uranium 235
Vanadium
Molybdenum
Cobalt
Titanium
Copper
Uranium 238
Radium 226
AIR: Arsenic
Nickel
SOURCE PILES
SOILOFFSITE: Nickel
Vanadium
Cobalt
Titanium
Uranium 238
GRQUNDWATER: Aluminum Molybdenum Uranium 238
Arsenic
Barium
Cadmium
Chloride
Cobalt
Copper
Fluoride
Manganese
Nickel
Nitrates
Selenium
Silver
Sulfate Ion
Vanadium
Radium 226
Radium 228
Tributyl Phosphate
TPH
NOTE
8
SUMMARY &F CHEMICALS OF POTENTIAL CONCERN
-------
These values exceed the maximum levels of COCs in ground water for all contaminants except
manganese. The manganese concentration 0.16 mg/l measured in the S-X pond is lower than
some of the concentrations measured off-site in ground water monitoring well locations. It may
be that the small number of source samples taken from the S-X pond over time provides an
underestimate of manganese concentrations in the S-X pond. In addition, an abnormally high
concentration of manganese was found in well KM-8, which may have been caused by turbidity
in the samples. Despite these uncertainties, site investigations confirm the presence of elevated
levels of manganese downgradient from the site which appear to originate from the KMCC plant.
Figure 9 shows conceptually how contaminants in ground water move from the site southward.
Traces of molybdenum have been detected as far south as Big Spring. As the contaminated
ground water moves away from the plant, it spreads out across a larger area, mixes with
uncontaminated ground water in the aquifer, and the concentrations decrease.
Contaminants in the shallow ground water system are of potential concern because contaminants
exceeding risk-based concentrations (discussed in Section 6.0) make the ground water unsafe
as a drinking water source. No one is currently using the affected portion of the ground water
aquifer as a drinking water source. The municipal water system obtains its supplies from
Formation Spring, which originates in the Mead Thrust Aquifer (not the affected Shallow Ground
Water Aquifer) located to the east of and hydrogeologically upgradient from the site. Neither the
Chesterfield Aquifer nor the Mead Thrust Aquifer are affected by contamination from the site.
Finch Spring. At Finch Spring, ground water discharges into a small pond which is part of a
wetland located approximately one mile to the south of the site. Water quality measurements
at the spring detected elevated levels of contaminatants associated with releases from the site.
Subsequent sediment samples to measure accumulation indicated that molybdenum is present
in sediments above background levels.
Contaminants at levels slightly above background have also been detected at Big Springs, the
southern-most sampling location. Other springs sampled in the area do not show impacts.
Vadose zone. The vadose zone includes the native soils, underlying basalt rock, and solid
sources (calcine tailings, and S-X and scrubber pond solids) buried at the site or beneath the S-X
and scrubber ponds that may leach contaminants into ground water. Metals (vanadium in
particular) are leached from the solid sources but appear to be attenuated within underlying
native soils. Ground water modelling indicates that solid sources are likely contributing between
1 and 20% of the contaminants entering the ground water, so that even if liquids discharged to
and leaking from the ponds were eliminated, remaining solid sources buried or trapped in the
vadose zone would continue to leach metals into ground water. Table 5 in Appendix C shows
the maximum concentrations measured at various locations in the solid sources.
The maximum chemical concentration measured in pond solids and calcine tailings is:
Vanadium 10,700 mg/Kg (scrubber solids)
Molybdenum 1,040 mg/Kg (scrubber solids)
Arsenic 7.7 mg/Kg (pond solids)
TBP 140 mg/Kg (pond solids)
TPH Not measured in solids
Manganese 915 mg/Kg (calcine tailings)
15
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:=X CITY OF
SODA
SPRINGS
FIGURE 9
APPROXIMATE DIRECTION OF GROUNDWATER FLOW AND
EXTENT OF GROUNDWATER CONTAMINATION AT
LEVELS OF CONCERN FROM KERR-McGEE
Prepared for EPA by.
ecology and environment, inc.
-------
Roaster Rejects. The roaster rejects are solid residual materials recovered from the roasters and
stored above ground on-site. They contain a variety of site related constituents, most notably
vanadium at levels as high as 24,000 ppm. This material had been stockpiled on-site but is now
being reused in the process to eliminate the existing stockpile and reduce possible risks to
workers from ingestion or direct contact exposure.
Air. KMCC performed an air pathway analysis and produced a report as part of the Rl. The
study concluded that emissions of metals from the site via the air pathway do not impact human
health or air quality, or result in impacts to off-site soils. This analysis, coupled with analysis of
soil samples from the surrounding area, support the conclusion that there are no significant air
pathways or impacts at the site. Some localized migration of calcine tailings from the surface
of the active calcine area to the surface soils immediately to the north has been observed, but
not at levels that pose risks to humans. Actions to address these "windblown calcine tailings"
were evaluated and are discussed in this document.
Soil. Samples were taken from within the plant boundaries and from surrounding soils off-site.
Statistical comparisons of the off-site soil samples to background soils indicated that the
concentrations of some metals and non-metals exceeded background concentrations at one or
more locations. Constituents which were most frequently detected in off-site samples at
concentrations statistically above background included calcium, chromium, nickel, copper, silver,
uranium and vanadium. Off-site soil contamination is confined to areas in the immediate vicinity
of the windblown calcine tailings and is related to saltation. Due to the presence of radionuclides
on-site, on-site sources and adjacent soils were sampled and analyzed for uranium-238 and in
some cases other radionuclides, and gamma radiation surveys were done in some areas to
analyze gamma activity. The levels of radionuclides in adjacent soils were initially thought to
exceed local background and were analyzed further in the RI/FS (including the risk assessment)
before further sampling determined that local background levels were in fact higher than the
concentrations found either on site or in surrounding soils.
Solid Sources. Samples were taken from the various solid sources/source piles (including pond
sediments) on-site to determine potential contaminants of concern and possible pathways for
contaminant migration to other media. Samples collected from solid sources contained metal
concentrations elevated with respect to background soils. These included chromium, copper,
iron, manganese, molybdenum, silver, vanadium, and zinc, and are discussed above under the
vadose zone and roaster rejects.
6.0 SUMMARY OF SITE RISKS
This section briefly summarizes the results and conclusions of the baseline human health and
ecological risk assessments, which were prepared by EPA and its contractors. This section also
discusses how the results were used, and the need for remedial action at the site.
6.1 Human Health Risks
6.1.1 Purpose and Approach
The human health risk assessment provides an evaluation of potential risks to human health from
exposure to releases or potential releases of hazardous substances at the KMCC facility. Specific
objectives included the following:
• Evaluation of data and identification of chemicals of potential concern;
1.7
-------
• Identification of potential human receptors and exposure pathways;
• Quantification of exposure; and
• Characterization of human health risks to current and future receptors.
The risk assessment provides both a quantitative and qualitative description of current and future
scenarios, identifies the contaminants of greatest toxicologic concern, and evaluates
environmental pathways for the most important exposures.
Equations to assess chemical intake and associated risks, along with appropriate default
parameters were taken from EPA guidance documents. The following assumptions were
incorporated into the risk analysis:
• The industrial facility will remain an industrial facility indefinitely in the future, but
surrounding land outside the facility boundary is assumed to be residential in the future;
• Chemical concentrations in environmental media and resulting exposures remain constant
over time;
• Effected ground water, which is not currently used for drinking and household use, would
be used for those purposes in future off-site residential scenarios;
• Except where site specific information has been provided, EPA default exposure
parameters are representative of the potentially exposed populations; and,
• Soil ingestion is evaluated utilizing the integrated approach described in the 1991 EPA
Human Health Evaluation manual.
6.1.2 Identification of Contaminants of Concern
Samples collected and analyzed from ground water, source piles, and off-site soils were
compared to background levels and with risk-based screening concentrations (equal to 10'7
cancer risk or a Hazard Index of 0.1 using residential assumptions) to identify chemicals of
potential concern (COPCs). COPCs that were identified and carried through subsequent steps
of the risk assessment are shown in Figure 8 in Section 5.0 and identified in more detail in Tables
6, 7 and 8 in Appendix C.
Initial results for radium-226 and radium-228 appeared to show elevated levels of these
constituents in a number of wells, and as a result radionuclides were initially identified as COPCs.
These wells were re-sampled and the resulting activity levels were reported to be low. After
further evaluation of these sampling results and the revised background soil samples,
radionuclides were eliminated from consideration as COPCs for the KMCC site.
6.1.3 Exposure Assessment
An exposure assessment was conducted to identify exposure pathways, develop risk scenarios,
and quantify exposure. The assessment used standard EPA exposure assumptions for most
scenarios and parameters. For the current on-site scenario, some of the exposure parameters
used for current workers are more realistic site-specific reasonable maximum exposure (RME)
estimates based on typical work practices, weather and site-use restrictions at the site. Using
18
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site-specific exposure and work-practice information provided by KMCC, site specific
modifications were made to the intake rates, exposure times, and corresponding averaging time
used to calculate risks in the current scenario. The information that was used to make these
modifications is shown in Table 9.
EPA developed scenarios for the current and potential future industrial use of the industrial site
itself and potential future residential use of adjacent properties (except for the Monsanto plant
to the west). The site is industrial and expected to remain that way, so current on-site
residential exposures were not assessed. The nearest off-site resident at the time of the
assessment is approximately 4,000 feet away and no one was currently using contaminated
ground water for drinking or household purposes, so current off-site residential exposures were
not evaluated further. Future residential use of properties adjacent to the facility was evaluated,
with particular emphasis on residents to the south, who could be exposed to contaminated
ground water in the event of no action.
The following exposure pathways were identified and considered:
• For workers: Ingestion of chemicals in source piles, inhalation of dusts, and external
exposure to gamma radiation.
• For residents: Ingestion of chemicals in off-site ground water and off-site soils, inhalation
of dusts, dermal exposure to organic chemicals in off-site ground water, ingestion of
garden produce, and external exposure to gamma radiation.
Intake values which represent an average exposure and RME for each scenario were used to
develop equations which calculate site specific human health risk.
6.1.4 Toxicity Assessment
A toxicity assessment identifies and quantifies toxicological measures for the chemicals of
potential concern. Quantitative estimates of toxic response developed by EPA were used to
evaluate potential carcinogenicity and non-cancer toxicity for the chemicals of potential concern
at the Kerr-McGee site. Generally, cancer risks were calculated using toxicity factors known as
slope factors, while non-cancer risks rely on reference doses.
Slope Factors (SFs) have been developed by EPA for estimating excess lifetime cancer risks
associated with exposure to potential carcinogens. SFs are expressed in units of ((mg/kg-day)-1)
and 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
SF. This approach minimizes the potential of underestimating cancer risks. SFs are derived from
human epidemiological studies or chronic animal bioassay data, to which mathematical
extrapolation from high to low dose, and from animal to human doses, have been applied.
Reference Doses (RfDs) and reference concentrations (RfCs) have been developed by EPA for
indicating the potential for adverse health effects from exposure to chemicals exhibiting non-
carcinogenic effects. The RfD or RfC is an estimate of lifetime daily exposure for humans
(including sensitive subpopulations) that is likely to be exposed without risk of adverse effect.
RfOs for ingestion exposures are expressed in units of mg/kg day, and RfCs for inhalation
exposures are expressed in units of mg/m3. Estimated intakes of COPCs from environmental
media (e.g., the amount of a COPC ingested from contaminated drinking water) can be compared
to the RfD or RfC. The RfD and RfC for each chemical are derived from human epidemiological
studies or animal studies to which uncertainty factors have been applied.
19
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Tables
Work Practices Around Source Materials at the
KMCC Soda Springs Plant
1 operator
Ferrophos
(FeP)
stockpile
Move - 20
loader buckets
of FeP to the
ore bay
180
Minimal -
, worker is
inside an
enclosed cab
1 operator
Calcine pond
Walk sluice line
to make visual
inspection
250
20 min/trip;
one trip made
every 10 hours
«1 hour/day)
Hands, face
2 operators
Calcine pond
Move sluice
line
12
Hands, face
1 operator
Roaster reject
pile
Stack roaster
rejects onto
stockpile
104
Minimal -
worker is
inside an
enclosed cab
NOTE: Several times a year calcine tails and MAP are transferred from the site for
processing at a local fertilizer plant. This activity takes approximately one day and
operators are located in enclosed cabs.
SOURCE: Dames and Moore on behalf of KMCC
-------
This risk assessment relies on oral and inhalation SFs, RfDs, and RfCs. Because dermal toxicity
factors have not been developed for the chemicals evaluated, oral toxicity factors are used in
estimating risks from dermal exposure. The toxicity factors were obtained from the EPA
Integrated Risk Information System (IRIS), or if no IRIS values were available, from the Health
Effects Summary Tables (HEAST), and several EPA Environmental Criteria and Assessment Office
(ECAO) memoranda, as noted in the risk assessment.
The reference dose for JP-5 fuel was used to represent the dose-response relationship for TPH
in water. It is assumed that TPH levels are the direct result of waste kerosene poured into the
limestone settling pond and later poured into the S-X pond as clarified solution. In an EPA memo
the reference dose for JP-5 is suggested for use in characterizing risks associated with kerosene
in ground water. This is not the most conservative reference dose available for evaluating TPH
in water (the reference dose for marine diesel fuel is more conservative), but it is believed to be
the most representative of kerosene fuels. The same memo also lists reference doses for marine
diesel fuel, JP-4, and gasoline.
6.1.5 Risk Characterization
Risk characterization integrates the results of the exposure and toxicity assessments for the
chemicals of potential concern to identify the actual contaminants of concern. Estimates of
chemical intake were compared with appropriate lexicological endpoints to determine the
likelihood of significant effects for each scenario. Risks were characterized separately for cancer
and non-cancer effects. Exposure pathways resulting in cancer risks greater than 1 in 1,000,000
(also expressed as 1E-06) or a non-cancer hazard quotient greater than .1.0 were identified.
Ground Water. The baseline Human Health Risk Assessment identified ingestion of contaminated
ground water as the primary pathway of concern. This use would require pumping of an existing,
or future private well in the area; which, according to the Risk Assessment is considered "not
likely" at this time because of readily available municipal water.
Potential exposure to concentrations of inorganic and organic chemicals in ground water was
only shown to pose significant potential human health risk (as evaluated by hazard quotients) in
the event contaminated ground water was used for drinking by residents south of the facility
(from the facility south to Finch Spring - ground water to the north and east of the facility is
unaffected). Manganese (HQ = 3), molybdenum (HQ = 32), vanadium (HO-14), TPH (HQ=3),
and tributyl phosphate (HQ = 3), all contribute to non-cancer risk. The HQs for molybdenum and
vanadium were combined in the risk assessment, based on common toxic endpoints, yielding an
HI of 45, a decision which has been reconsidered in the risk management decision (see
uncertainty section). Arsenic in one perimeter well exceeds the Maximum Concentration Limit
(MCL) of 0.05 ug/l, and the estimated carcinogenic risk from arsenic in the ground water (1.4E-
04) is slightly greater than background arsenic risk (1.0E-04).
Radionuclides were originally identified as contaminants of potential concern in ground water but
were later eliminated when sampling showed that activity levels were low and that site soils and
sources were below background.
Manganese was found in ground water at levels that exceed the secondary MCL (0.05 mg/l)
under the Safe Drinking Water Act, which is primarily directed at the aesthetic qualities (e.g.
color, odor), of ground water. The primary MCL established for protection of human health for
manganese was not exceeded at the site. A risk-based concentration of 0.18 mg/l was
calculated in the risk assessment equal to a HI of 1.0. .
21
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Surface Water. Another potential pathway of concern considered in the risk assessment was the
discharge of ground water to surface water. This pathway was not considered significant for
human health but potential impacts to ecological receptors were evaluated through the sampling
of sediments in Finch Pond in the spring of 1995. No impacts to ecological receptors were
identified - see ecological risk discussion below.
Source Piles and Soils - Chemical Risk. For on-site workers under current or future (default)
conditions, the only significant potential pathway of concern identified was excess exposure to
vanadium in the roaster rejects area, which poses a hazard quotient of 1 .7. No off-site soils were
found to pose risks warranting action to protect human health. Potential localized environmental
impacts from soils were considered and are discussed below.
Source Piles and Soils - Radionuciide Risk Estimate and Re-Evaluation. The risk assessment
estimated potential risks to workers and potential residents from exposure to naturally-occurring
radionuclides in source piles and surrounding soils and identified radionuclides as a contaminant
of potential concern. Subsequent information developed in the Monsanto Rl/FS demonstrated
that radionuclide levels in the areas of potential concern at the KMCG site are less than local
background levels. Therefore the conclusion of the risk assessment has been corrected and
radionuclides are no longer considered potential contaminants of concern.
Specifically, when the draft Risk Assessment was released (October 1 993), it relied on 3-6 local
background samples of which the maximum was 1 .3 pCi/g (posing a risk of 2.0 x 10"*). The S-X
pond solids concentrations were found to be 2.3 pCi/g (thought to pose an excess risk of 3.5 x
10~* at the time). The ferrophosphorus and boiler blowdown value also exceeded 1.3 pCi.
Similarly, potential residential exposure in the future to surrounding soils contaminated with
U-238 and it's decay progeny was estimated to pose risks of 5 x 1CT* over background of 4.5
However, subsequent sampling. in support of the Monsanto Rl/FS and risk assessment has
demonstrated that the estimate of future industrial risk from exposure to radionuclides was
overestimated in the KMCC risk assessment because local background is actually 3.0 pCi/g.
Therefore the concentrations in the S-X pond and surrounding soil samples are less than local
background, there is no excess risk, and no RAOs were developed for radionuclides at this site.
Air. No significant airborne exposure pathways to future workers or off-site residents were
identified in the baseline risk assessment.
6.2 Environmental Risks
6.2.1 Ecological Risk Assessment
The scope of the ecological risk assessment was limited to potential impacts upon ecological
receptors directly attributable to the KMCC facility. However, related factors (i.e., agricultural
practices) were considered to determine whether those factors have a compounding effect on
the same receptors.
The ecological risk assessment was generally conducted using a weight of evidence approach.
Evidence considered included qualitative information gathered during site reconnaissance, as well
as quantitative comparisons used in the risk analysis. The assessment considered the following
exposure scenarios:
• Vegetation exposed to potential phytotoxic levels of chemicals in soil;
• Ingestion of potential contaminants in soils by field mice and mule deer; and,
22
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• Ingestion of potential contaminants in impounded water by waterfowl and deer.
In general, the comparison of site exposure concentrations to toxicological reference values
suggested that plant and animal receptors near the site are (using field mice, mule deer and
waterfowl as representative animal species) not at substantial risk from contaminants in off-site
soils. The distribution of potential contaminants is not widespread in off-site soils but rather is
concentrated on the north central portion of the facility boundary. At this location, evidence of
rodent populations, birds, small mammals and ungulate (i.e., hoofed animals) use was not readily
apparent. Based on field observations, the habitat surrounding the KMCC facility and associated
wildlife usage does not appear to have been altered when compared to similar habitat conditions
in other portions of the valley. Ground water contamination leaving the site largely attenuates
before reaching downgradient receptor locations, including Finch Spring, Big Spring and (possibly)
the Bear River, but insufficient data was available to assess potential impacts.
Based on the available information, the findings of the ecological risk assessment support the
following conclusions:
• Sensitive plant species may be at risk to vanadium, chromium, copper, and nickel at
highly localized areas (particularly at sample locations SO-3 and SO-4).
• Field mice may be at risk to vanadium in soil; however, considerable uncertainty exists
in the toxic reference value.
• Chronic exposure from other elevated metals in soil to field mice and deer would result
in low toxicological risk (the predicted chemical intake exposures are less than the toxic
.reference values).
• Acute risks to waterfowl from ingestion of vanadium in scrubber pond water may occur.
However, the scrubber pond is not considered attractive habitat when compared to the
surrounding area and exposure is likely mimimal.
Even though there are no substantial ecosystem risks from chemical releases from the KMCC
facility, actions that would minimize transport of potential contaminants off-site would reduce
chemical exposure to plants and animals.
6.2.2 Finch Pond Evaluation
Subsequent to the baseline ecological risk assessment, discharge of ground water to surface
water was evaluated for potential ecological risks/effects. The two main potential discharge
points considered were Big Spring and Finch Pond. Ground water entering Finch Pond, which
is approximately one mile from the site, contains molybdenum, vanadium, manganese and TBP
above risk-based concentrations. Big Spring, where ground water impacted by the site next
surfaces, shows evidence of low levels of molybdenum above ecological risk-based
concentrations. Based on the higher concentrations found in Finch Spring and the presence of
a small but productive wetland there, a focused investigation was conducted of Finch Pond
sediments to evaluate potential ecological impacts.
Finch pond sediments were sampled in May 1995 to evaluate whether molybdenum or vanadium
have accumulated in the sediments, resulting in potential increased risk to waterfowl and other
water birds via the food chain pathway. Ground water entering Finch Pond has resulted in
accumulation of molybdenum (maximum value 429 mg/kg) at levels statistically higher than
background concentrations. The U.S. Fish and Wildlife Service was consulted and a brief
literature search was conducted for molybdenum toxicity data. Based on the information
available, molybdenum concentrations are nearly an order of magnitude below theoretical risk-
23
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based calculations derived from the literature. EPA determined that the likelihood of significant
ecological effects from molybdenum in the surface water or sediments is low. No impacts to
ecological receptors were identified and further assessment involving toxicity bioassays was
unwarranted.
6.3 Uncertainty
The numerical results of a risk assessment (HQs and cancer risk values) have inherent uncertainty
because of limited knowledge regarding exposure and toxicity, and because of limitations on the
accuracy and representativeness of environmental sampling. Whenever available and
appropriate, site-specific information from the Rl was used for estimation of exposure to reduce
uncertainty. Where information was incomplete, conservative assumptions were made and/or
conservative default values were used to ensure protection of public health and the environment.
The following sections summarize the most significant uncertainties associated with scenarios
in the Kerr-McGee Human Health and Ecological Risk Assessments. The exposure factors used
in each scenario are detailed on Tables 12 - 18 in Appendix C. More details are available in the
Risk Assessment.
6.3.1 Human Health Risk Assessment Uncertainties
Uncertainties associated with this, human health risk assessment included:
• reliance on a small background data set (3-6 samples), which introduces uncertainty
about the true concentrations in environmental media and their significance. Additional
background samples were later collected and evaluated, which contributed to the
elimination of radionuclides from the list of contaminants of concern at this site;
• for some constituents (arsenic, beryllium, and radionuclides in source pHest, background
concentrations exceeded the 10* risk level. Cleanup below background is not considered
practicable.
• the use of modelled air data, since actual air monitoring data was not collected;
• the assumption that chemical concentrations remain constant over time, particularly the
organic compounds (TPH and TBP) which have been shown to degrade over time rather
than persist in the environment under some conditions;
• the use of the reference dose for JP-5 (a type of fuel with known toxilogical parameters)
to calculate risk-based concentrations for kerosene on site;
the use of conservative assumptions with regard to exposure parammrs in future
scenarios and for current scenarios where site-specific data was not available. Some
assumptions regarding future land uses surrounding the facility, such as residential
ground water use in the vicinity of the southern boundary of the site are highly
speculative (the facility itself was assumed to remain industrial); and,
summation of risks for each media and contaminant for each scenario. The uncertainty
in this method includes a conservative assumption that the routes of absorption and
target organs are similar for each contaminant of concern, as well as the possibility that
potential synergistic interactions between chemicals could result in a cumulative risk
greater than the risks calculated for individual chemicals. The hazard quotients for
molybdenum and vanadium were summed in the risk assessment on the basis of common
toxilogical endpoints, despite having very different levels of uncertainty.
24
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6.3.2 Ecological Risk Assessment Uncertainties
Uncertainties associated with this ecological risk assessment included:
• extrapolations of overall potential ecological risks from an evaluation of a few selected
receptor organisms (mice, deer, waterfowl) intended to be representative of local biota;
• the use of conservative assumptions with regard to exposure parameters for the modelled
receptors; and,
• the selection of toxic reference values for comparison with predicted intakes, which may
over or under-estimate actual conditions.
6.4 Need for Action
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
Where the cumulative site risk to an individual based on RME for both current and future land use
is less than approximately one-in-ten-thousand, and the non-cancer causing HQ is less than one,
cleanup at a site is generally not warranted unless there are adverse environmental impacts. As
described above in the risk characterization section, the non-cancer risks calculated were in
excess of the criteria. Based on the results of the risk assessment, EPA has determined that
cleanup is necessary at the site.
6.5 Remedial Action Objectives
Based on the human health risk assessment for the site, the primary medium of concern is the
ground water and the primary exposure route of concern for ground water is ingestion. Therefore
the Remedial Action Objectives (RAOs) for this site with respect to ground water are:
• Prevent the transport of Contaminants of Concern (COCs) to the ground water from
facility sources that may result in COC concentrations in ground water exceeding risk-
based concentrations (RBCs) in ground water or chemical specific ARARs, specifically
Maximum Contaminant Levels (MCLs). The RBCs shown in Table 10 correspond to a
cancer risk of 10* or a Hazard Index of 1.0.
• Prevent the ingestion by humans of ground water containing COCs having concentrations
exceeding RBCs or MCLs (chemical-specific ARARs)
• Prevent the transport of COCs from ground water to surface water in concentrations that
may result in exceedences of human health RBCs or MCLs in the receiving surface water
body (chemical-specific ARARs)
The ultimate goal of this remedial action is to restore ground water that has been impacted by
site sources to meet all RBCs or MCLs for the COCs.
A secondary remediation goal at the site is risk associated with the roaster reject material. The
RAO for this material is:
• Prevent the ingestion/direct contact with roaster reject area material having vanadium
concentrations in excess of 14,000 mg/kg (concentration shown to correspond to an
Hl = 1).
25
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TABLE 10
Risk-Based and Maximum Concentration of Contaminants of Concern in Ground
Water
All amounts in milligrams per liter (mg/l)
Substance of
Concern
Human Health
Risk Based
Concentration
(RBC) with
HI = 1
AREA EVALUATED (see map)
Within Plant
Boundary
Plant Boundary
to Finch
Springs
Finch Springs
Vanadium
Molybdenum
Arsenic
TBP
TPH
Manganese
0.009
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Finally, to prevent localized areas from being impacted by solid sources which may pose a risk
to sensitive plants and field mice in the area, an RAO has been established for the ecosystem to:
• Prevent the transport of COCs from the active calcine tailings area to the surrounding
soils in amounts that exceed the 95 percent upper threshold limit (UTL) concentration of
the background soils.
7.0 DESCRIPTION OF ALTERNATIVES
This section identifies actions being taken by KMCC which were not explicitly evaluated as
components of the various alternatives. However, actions contemplated by KMCC have a direct
and positive affect on the ability to successfully implement source control, a necessary
component of all remedial action alternatives evaluated. A full discussion of KMCC's plant
changes, the highlights of EPA's remedial action alternatives, and the relationship between the
two are discussed. Section 7.0 also summarizes conclusions of the ground water modelling
effort that was a key component is scoping the range of alternatives considered.
7.1 Summary of Plant Process Changes
The main plant process change that is planned is Liquid Source Elimination. This section
describes the elements of Liquid Source Elimination and how they relate to the remedial action
alternatives considered below. There are currently three liquid sources in unlined impoundments
which contribute the majority of contaminants of concern to ground water. As an active facility,
KMCC has elected to undertake certain process changes or additions in order to discontinue the
use of unlined ponds, while continuing to operate its facility. The process changes, referred to
as Liquid Source Elimination, as described in this section, will be completed under state
regulatory authority outside of the Superfund process.
7.1.1 Components of Liquid Source Elimination
Liquid Source Elimination (LSE) refers to actions that will result in stopping (or eliminating)
contaminants of concern from entering the ground water. KMCC has determined that the
specific components of LSE involve changes in to day-to-day operations and business decisions.
However, the end result of Liquid Source Elimination-to prevent contaminants from entering the
ground water-is a necessary component of all remedial action alternatives considered at the site.
KMCC is taking two separate actions to implement LSE. The first is the creation of two double-
lined evaporation ponds {10 acres of total area) that are being constructed to contain the S-X
raffinate that is discharged from the facility. The evaporation ponds have been sized to handle
all of the raffinate discharge, including winter production and precipitation. A permit to construct.
these ponds has been received from the Idaho Department of Health and Welfare (IDHW).
Construction of the ponds has begun and is expected to be complete by October 1995.
Plans are also in progress to eliminate the other two liquid waste streams, the scrubber water and
calcine sluicing water. KMCC is planning to construct a phosphoric acid plant to produce several
grades of phosphoric acid and granular fertilizer using the impounded calcine as the feed material.
The scrubber water will be used in the digestion step of the acid production process. The solids
generated by the digestion step will be granulated and sold as a soil conditioner and the acid can
be sold in numerous forms. An air permit is required to operate the phosphoric acid plant.
KMCC has submitted an application to the IDHW to obtain the necessary permit. A decision on
the permit is expected by January 1996.
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7.1.2 Relationship of LSE to Remedial Action Alternatives
The process changes or additions being made are referred to in the remedial action alternatives
as LSE. When LSE is completely implemented, all three liquid sources will be eliminated and the
impounded calcine will be excavated and processed. The combined actions of LSE are predicted
to result in a "zero-discharge" to ground water. As part of remedial action alternatives, the
success of source control actions will be subject to confirmation by ground water monitoring.
7.2 Ground Water Modelling
KMCC conducted ground water modelling to assist in scoping the Feasibility Study and to
evaluate and compare remedial action alternatives, specifically to determine what magnitude of
decrease in COC concentrations would be expected in the ground water over time when seepage
of process water from the pond sources is eliminated, and whether the magnitude of the
decrease in COC concentrations would be significantly increased over time if LSE was
supplemented by ground water extraction. The model was not intended to predict precise future
concentrations at specific locations. The model was calibrated to within an order of magnitude
of observed concentrations and is considered reliable within that range of values.
The model addressed the six COCs in ground water: arsenic, manganese, molybdenum,
vanadium, tributyl phosphate, and total petroleum hydrocarbons (because TPH data proved
inadequate for modeling, TPH was assumed to be similar to TBP).
In summary, the findings were:
• Concentrations of arsenic, manganese, molybdenum, and vanadium were predicted to
decrease rapidly after implementation of source control, achieving risk-based performance
goals at the plant boundary within 10 years. Tributyl phosphate and TPH were predicted
to take longer to recover, persisting as long as 30 years if no degradation takes place.
Some evidence suggests that degradation is taking place, lif natural degradation is taken
into account, predicted concentrations may achieve risk-based performance goals in 10-
15 years.
• Predicted reductions in arsenic, manganese, molybdenum and vanadium are 'not
substantially accelerated if LSE is supplemented by three extraction wells pumping a total
of 6,000 gpm.
• Predicted concentrations of TBP (and presumably TPH) would fall below risk-based
performance standards in approximately 15 years (rather than persisting for 30 years) if
LSE is supplemented by three extraction wells pumping a total of 6,000 gpm.
TBP and TPH require a longer time frame for cleanup because they react with subsurface
materials, which slow down, or retard, their movement through the aquifer. The metals are much
less reactive, and move through the aquifer relatively quickly. When the liquid source is
discontinued, clean ground water will flush the metals-contaminanted water through the system
much more quickly than the organics, which will remain in the aquifer for much longer.
7.3 Summary of Ground Water Alternatives
KMCC presented seven alternatives to address sources of contamination to ground water in its
detailed study of cleanup options in the Feasibility Study. The seven alternatives were chosen
after KMCC looked at thirty-five potential ground water treatment technologies. The most
effective technologies were included as part of the seven alternatives. The alternatives consider
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a different range of actions to address contamination at the site, varying in cost, permanence,
and requirements for long-term maintenance. The alternatives are referred to by the numbers
assigned in the Feasibility Study and Proposed Plan.
7.3.1 No Action (Alternative 1)
This alternative leaves the site as-is, without treatment, containment, or elimination of industrial
waste waters entering the ground water. Contaminants would continue to enter the ground
water and remain above risk-based concentrations. Process water discharge and atmospheric
precipitation would continue to leach contaminants from the calcine tailings and pond solids in
the vadose zone.
7.3.2 Monitoring and Institutional Controls (Alternative 2)
This alternative includes semi-annual monitoring at existing monitoring wells. It also includes
institutional controls to limit access to contaminated ground water to prevent it from being
developed as a drinking water source in the future. It does not include treatment of the
contaminated ground water areas.
The present worth cost of this alternative for a 30-year period is estimated to be $1,000,000,
with capital costs of $100,000 and annual operation and maintenance costs of $60,000.
7.3.3 Liquid Source Elimination, Monitoring and Institutional Controls (Alternative 3)
Liquid source elimination removes all discharge of contaminants to unlined ponds, which is the
primary source of contaminants entering ground water. Ground water contamination is predicted
to naturally attenuate once the sources are removed. No action is taken on pond solids or calcine
tailings in the vadose zone for this alternative, and some contaminants would continue to enter
the ground water via atmospheric precipitation passing through the solid sources. This
alternative does not include treatment of contaminated ground water.
Alternative 3 is predicted to reduce vanadium to below RBCs within five years, except for a small
area beneath the buried calcine tailings because no action is taken on the solid sources.
Manganese is predicted to fall below RBCs within the first year after implementation of LSE.
Molybdenum is predicted fall below RBCs within 10 years. TBP and TPH are predicted to fall
below RBCs in 30 years or less.
Monitoring and institutional controls would be included in this alternative and all other
alternatives listed below.
The present worth cost of this alternative is $2,000,000 for a 30-year period. Capital costs are
estimated at $70,000 for construction of lined ponds to replace the unlined S-X pond.
Construction time frame is approximately one to two years to implement all elements, including
KMCC's LSE components (i.e., phosphoric acid plant construction). The lined ponds to replace
the S-X pond are currently being constructed and are expected to be completed by October
1995.
7.3.4 Liquid Source Elimination, On-site disposal of Waste Pond Solids, and Reuse of Calcine
Tailings, Monitoring and Institutional Controls (Alternative 9)
This alternative does not include ground water treatment, but it addresses all sources of
contamination to ground water. As in Alternative 3 above, the unlined ponds are taken out of
service, eliminating them as ongoing sources of contaminants to ground water. In addition, the
pond solids would be excavated and disposed in an on-site landfill created for their disposal. The
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calcine tailings will be reused over a period of eight years. This alternative utilizes a combination
of containment and elimination for the liquid and pond solid sources, and reuse for the calcine
tailings. Approximately 1,800 cubic yards of solids would be excavated from the S-X pond and
4,500 tons of solids from the scrubber pond.
This alternative is expected to reduce concentrations of contaminants in ground water to below
risk based concentrations in a period of 5 to 10 years for most contaminants. TBP and TPH may
require 30 years to achieve risk based concentrations.
Lined ponds to replace the unlined S-X pond are currently under construction and are expected
to be complete in October 1995. The present value cost is $2,200,000, including $1,000,000
for construction of lined cells and excavation and disposal of the S-X and scrubber pond solids,
and 100,000 per year for O&M. Capital and O'&M costs associated with the phosphoric acid
plant for reuse/recovery of the calcine tailings are not included.
7.3.5 Liquid Source Elimination, Ground Water Extraction and Carbon Treatment; On-Site
Disposal of Waste Pond Solids. Reuse of Calcine Tailings, Monitoring and Institutional
Controls (Alternative 26)
The main feature of this alternative is treatment for the organic contaminants in ground water.
Also, the calcine tailings under this alternative are reused over a period of eight years. Metals
in ground water are not treated, but are allowed to naturally attenuate in the subsurface once the
Liquid Source Elimination action described in Alternative 9 is completed. Extracted ground water,
once treated, would be discharged to the Bear River about 5.5 miles south of the site.
This alternative is expected to reduce concentrations of TBP and TPH in ground water to below
risk based concentrations in a period of thirty years or less. Molybdenum, arsenic, vanadium,
and manganese are expected to reach RBCs within five years.
The ground water treatment plant constructability and operability depend on the success of
activated carbon at removing the organic contaminants of concern. The number and size of
carbon units as well as the carbon usage rate are dependent on site ground water quality.
Competitive absorption could substantially affect the feasibility and the capital and operating cost
of the treatment system. Carbon absorption can also be affected by some inorganic constituents,
such as iron. Treatability studies would need to be conducted with activated carbon to determine
whether it would be effective at treating the organic COCs.
The actions for Alternative 26 can be monitored by the collection and analysis of ground water,
by periodic checks of the evaporation pond and landfill leak detection system, and by monitoring
the treatment plant discharge. Monitoring of institutional controls would also be required.
Present value costs for this alternative are $23,000,000. Capital costs associated with the
treatment plant and lined pond construction are $13,000,000, and annual O&M costs are
$1,000,000 during treatment and $70,000 thereafter. Construction time frames for a treatment
system is estimated at five years.
7.3.6 Liquid Source Elimination, On-site Disposal of Pond Solids, Ground Water Extraction,
Treatment via Reverse Osmosis and Carbon Treatment, Disposal of Sludges, Reuse of
Calcine Tailings, Institutional Controls and Ground Water Monitoring (Alternative 34)
Treatment for all contaminants of concern in ground water is accomplished by two treatment
processes, carbon extraction for organics and reverse osmosis (RO) for inorganics. Inorganic
treatment of the extracted ground water would be effected by reverse osmosis, assuming
adequate removal is feasible. Extracted ground water would be collected in a equalization tank.
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This water would be pumped from this tank to a bank of approximately ten RO units to handle
an expected flow rate of 6,000 gpm.
The reject stream from the initial bank of RO units would be sent to another RO until to further
concentrate the contaminants. The concentrated reject stream would be sent to an evaporator.
and to a crystallizer. The evaporator crystallizer removes most of the water. The water vapor
would be further concentrated in a centrifuge with the final slurry stored as waste in a lined
landfill, approximately 20 acres in size. An estimated 11,000 pounds per hour of slurry would
be generated from the treatment process for disposal.
Treatability tests would be required because of concerns for fouling and scaling. The low
concentrations of inorganic COC combined with greater concentrations of general inorganics may
serve to reduce the removal efficiency below what otherwise could be obtained.
As in Alternative 26 above, this alternative is expected to reduce concentrations of TBP and TPH
in ground water to below risk based concentrations in a period of thirty years or less.
Molybdenum, arsenic, vanadium, and manganese are expected to reach RBCs within five years.
The addition of the RO treatment is not expected to accelerate the reduction of COCs in ground
water.
The present worth cost for this alternative is estimated to be $58,000,000. Annual O&M costs
are expected to be $4,500,000 for the first five years, dropping to $1,000,000 for 6th through
15th years, and $70,000 thereafter. Capitals costs are expected to be $33,000,000.
7.3.7 Liquid Source Elimination, On-sfte Disposal of Pond Solids, Ground Water Extraction and
Carbon Treatment, Capping of Calcine Tailings, Institutional Controls and Ground Water
Monitoring (Alternative 35)
This alternative is substantially the same as Alternative 26 above, with the additional action of
requiring that the calcine tailings be capped in the interim period when it is being reused. The
ground water treatment plant constructability and operability depend on the success of activated
carbon at removing the organic contaminants of concern. The number and size of carbon units
as well as the carbon usage rate are dependent on site ground water quality. Competitive
absorption could substantially affect the feasibility and the capital and -operating cost of the
treatment system. Carbon absorption can also be affected by some inorganic constituents, such
as iron. Treatability studies would need to be conducted with activated carbon to determine
whether it would be effective at treating the organic COCs. •
Monitoring and institutional controls and ground water monitoring are included in this alternative
as presented in the alternatives above. As in the other ground water treatment alternatives, this
alternative is expected to reduce concentrations of TBP and TPH in ground water to below risk
based concentrations in a period of thirty years or less. Molybdenum, arsenic, vanadium, and
manganese are expected to reach RBCs within five years.
Present value costs for this alternative are $25,000,000. O&M costs are estimated at
$1,000,000 and construction costs are $15,000,000. The construction time frame for this
alternative is approximately five years.
7.4 Summary of Roaster Reject Remedial Action Alternatives
As a secondary human health concern at the site, an RAO was established for the roaster rejects
area. The RAO for this alternative is to prevent ingestion or direct contact with roaster reject
area material having vanadium concentrations in excess of 14,000 mg/kg. Roaster reject
remedial action alternatives are not concerned with preventing transport of COCs to ground water.
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Roaster reject is material that has been removed from the hearths inside the roaster and
associated ventilated ducts. The removal occurs as part of the weekly, routine maintenance.
Roaster reject material had been stockpiled in past years. However, this material has a
recoverable quantity of vanadium and is now being used as a feedstock into the roasters.
Roaster reject material currently covers an area of approximately 5,000 square feet to a height
of 10 to 12 feet. There is approximately 3,000 tons of material containing vanadium
concentrations ranging from 17,700 mg/kg to 24,300 mg/kg. See Figure 6 in Section 2.0 for
the current location of the roaster reject material.
Two alternatives were considered for the roaster rejects:
7.4.1 Institutional Controls (Alternative RR-1)
This alternative involves instituting additional company policies to specifically address workers
who are exposed to this area, e.g., fencing around the area to limit contact.
7.4.2 Resource Recovery/Reuse (Alternative RR-2)
Roaster reject can be reused at a rate of 8 to 17 tons/week depending on whether one or two
roasters are operating. Roaster reject from ongoing operations is-generated at 2.5 to 5
tons/week, resulting in a net reduction in the source pile of 300 to 600 tons per year through
reuse. It is estimated that the roaster reject will be reused within 5 to 10 years.
This activity is currently being undertaken as part of KMCC's ongoing operations. In the event
that reuse/recovery no longer becomes feasible the institutional controls alternative can be
implemented.
7.5 Summary of Windblown Calcine Tailings Remedial Action Alternatives
The RAO for the windblown calcine tailings is to prevent the transport of COCs from the active
calcine tailings area to the surrounding surface soils in amounts that exceed the 95 percent upper
threshold limit (UTL) of the background soils. The windblown calcine tailings are not considered
a source of COCs to ground water because the quantity dispersed over the surface soils is
negligible with respect to ground water. The buried calcine tailings discussed as a component
of solid sources under ground water remedial action alternatives are separate.
Windblown calcine tailings have been found at only a few inches in depth and tend to accumulate
in and around grass located north of the site. Since they were discovered during the Remedial
Investigation, KMCC has excavated and returned all visible tailings to the active calcine tailings
area. The limited alternatives discussed below discuss additional actions which may be taken
as part of this remedial action to ensure the RAO is met.
7.5.1 No Action for Windblown Calcine Tailings (Alternative WCT-1)
The no action alternative relies solely on institutional controls and access restrictions. Because
the RAO associated with this alternative is for ecosystem, not human health concerns, access
restrictions are unlikely to be effective. There are no costs associated with this alternative.
7.5.2 Excavation and Disposal for Windblown Calcine Tailings (Alternative WCT-2)
The actions associated with this alternative require excavation of windblown tailings and disposal
into the active calcine tailings impoundment area where they are/will be capped with native
material. Costs to implement this alternative is essentially zero, since the action was taken
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during the site investigation. Annual O&M costs associated with documentation of monitoring
and institutional controls are estimated at $ 10,000.
7.5.3 Capping of Windblown Calcine Tailings (Alternative WCT-3)
Capping of the calcine tailings requires placement of fill material over the tailings to prevent
airborne transport. Capping is currently being conducted on an as need basis as part of plant
operations to minimize airborne transport. Annual costs associated with documentation of
monitoring are estimated at $10,000. Construction costs are zero since the action is currently
being conducted as part of plant operations.
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The NCP defines procedures for selecting response actions under CERCLA. As part of those
procedures EPA is required to analyze each remedial action alternative according to nine specific
criteria. The purpose of this evaluation is to promote'consistent identification of the relative
advantages and disadvantages of each alternative thereby guiding selection of remedies offering
the most effective and efficient means of achieving site cleanup goals.
All nine criteria are important, but are weighed differently in the decision-making process
depending on whether they describe a required level of performance (threshold criteria), provide
for consideration of technical merits (balancing criteria,), or involve the evaluation of non-EPA
reviewers that may influence an EPA decision (modifying criteria).
No action and alternative number two for ground water, discussed in Section 7.3, are not
protective of human health and the environment and thus are not further evaluated under the
nine criteria. Neither alternative effectively addresses contaminants moving into the ground
water even though human health may be somewhat protected through administrative or legal
measures identified under institutional controls for alternative two.
This section evaluates all the ground water alternatives developed by KMCC (described in Section
7.3), based on the nine criteria described in Table 11. The purpose of this evaluation is to
highlight the most significant advantages and disadvantages of the alternatives in relations to
each of the nine criteria. This section also evaluates the limited alternatives for remedial action
of the roaster rejects and windblown calcine tailings, which are secondary concerns at the site.
A more detailed evaluation is provided in the Feasibility Study prepared by KMCC.
8.1 Threshold Criteria
8.1.1 Overall Protection of Human Health and the Environment
This criterion addresses whether the remedial actions provide adequate protection, and describes
the mechanism for controlling risks for the different exposure pathways.
Except for alternatives 1 and 2, all of the alternatives provide adequate protection of human
health and the environment. Alternatives 3 and 9 significantly reduces the toxicity, mobility and
volume of contaminants through their liquid source eliminations actions, and provides protection
through reuse, allowing ground water to naturally recover. Alternatives 26, 34, and 35 take the
additional step of treating ground water. This could reduce the time required for the aquifer to
recover to acceptable levels, but in addition to costing ten times as much as Alternatives 3 and
9, the treatment alternatives would have much greater environmental impacts and provide little
additional protection of human health.
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TABLE 11
NCR NINE EVALUATION CRITERIA
EPA ranks the alternatives considered against the following nine evaluation criteria:
THRESHOLD CRITERIA:
1) Overall protection of human health and the environment - How well does the alternative
protect human health and the environment, both during and after construction?
2) Compliance with applicable or relevant and appropriate requirements (ARARs) - Does the
alternative met all applicable or relevant and appropriate state and federal laws and
regulations? .
BALANCING CRITERIA;
3} Long-term effectiveness and permanence - How well does the alternative protect human
health and the environment after completion of cleanup? What, if any, risks will remain at
the site? -
4) Reduction of toxicity, mobility, and volume through treatment - Does the alternative
effectively treat or recycle the contamination to significantly reduce the toxicity, mobility,
and volume of hazardous substances?
5) Short-term effectiveness - Are there potential adverse effects to either human health or the
environment during construction or implementation of the alternative? How fast does the
alternative reach the cleanup goals?
6) Implementability - Is the alternative both technically and administratively feasible? Has the
technology been used successfully at other similar sites?
7) Cost - What are the estimated costs of the alternative? How do costs of the alternative
compare with costs of the other alternatives?
MODIFYING CRITERIA: _____
8) State acceptance - What are the state's comments or concerns about the alternatives
considered and about EPA's preferred alternative? Does the state support or oppose the
preferred alternative?
9) Community acceptance - What are the community's comments or concerns about the
preferred alternative? Does the community generally support or oppose the preferred
alternative?
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Reuse/recovery for the roaster rejects is more protective of human health and the environment
than no action because the quantity of roaster reject material is reduced. There is essentially no
difference in the short-term risk. Reuse/recovery of the roaster reject is clearly superior as
compared to no action. Reuse of the roaster reject lowers the environmental impact and reduces
the volume and toxicity.
For windblown calcine tailings, no action poses minor risks to the ecosystem. Excavation and
disposal and capping are protective of the ecosystem. Excavation and disposal is more
protective than capping because it removes calcine tailings that have already been windblown.
Excavation and disposal would transfer windblown calcine to the existing impoundment. This
latter action has been completed.
8.1.2 Compliance with ARARs
The purpose of this analysis is to evaluate the alternatives for compliance with the major ARARs.
All alternatives except 1, 2, and 3 meet all ARARs.
The Safe Drinking Water Act (SDWA) is a chemical specific ARAR with an MCL for arsenic of
0.05 mg/l. There are no promulgated standards specified under the SDWA which are exceeded
for the other contaminants of concern at the site. Site specific risk-based concentrations will be
met by Alternatives 9 through 35, and also could be met by Alternative 3, though it is less
certain to be successful, and will likely take longer due to the failure to address buried solid
sources.
The Idaho Ground Water Standards (IDAPA Section 16.01.02.299) protect ground water for
beneficial use and the Idaho Antidegradation Policy (IDAPA Sec. 16.01.02.051), requires that
existing water uses and water quality be maintained and protected. These ARARs will be met
by Alternatives 9 through 35 because the absence of any discharges from the site should prevent
degradation and preserve ground water quality standards. Alternative 3 is also likely to meet this
ARAR, but over a longer period of time.
The Environmental Protection and Health Act, Idaho Code 39-101 to 129, protects the
environment and human health and safety by reviewing design requirements and approving solid
waste disposal sites. The substantive requirements of this action-specific ARAR will be met by
Alternatives 9 through 35. Alternative 3 does not meet this ARAR because it would allow solid
wastes to remain in existing unlined ponds.
The Rules for Control of Fugitive Dust, IDAPA Section 16.01.01.650, are applicable to the
roaster rejects alternatives and windblown calcine tailings alternatives. No action/institutional
controls and reuse/recovery would meet this ARAR. Construction components of ground water
alternatives would also meet this ARAR.
8.2 Primary Balancing Criteria
8.2.1 Long-Term Effectiveness and Permanence
This criterion evaluates the ability of a remedial alternative to maintain reliable protection of
human health and the environment over time, once cleanup goals have been achieved.
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Alternatives 9, 26, and 35 have similar long-term effectiveness due to the reuse of contaminants
reducing any potential long-term exposures. Alternative 34 has slightly lower long-term
effectiveness than alternatives 9, 26 and 35 due to the need to dispose of inorganic solids
generated by the reverse osmosis treatment process. Alternative 3 has less long-term
permanence than the others because calcine, tailings would be left in place.
For Roaster Rejects alternatives, reuse/recovery is assigned a higher score for long-term
effectiveness because the quantity of source material is reduced, which results in minimal
remaining risk. Controls are adequate for the small quantity of roaster reject material that may
be staged prior to use after the existing stockpile has been consumed. The magnitude of
remaining risk for no action does not decrease from that which currently exists.
Excavation/disposal and capping of windblown calcine tailings both have high long-term
effectiveness because the windblown calcine tailings have been covered and are no longer
exposed to possible airborne transport. No action provide less long-term permanence because
it is ineffective at reducing the risk to the ecosystem.
8.2.2 Reduction of Toxicity, Mobility, or Volume Through Treatment
This criterion evaluates the anticipated performance of the various treatment technologies and
addresses the statutory preference for selecting remedial actions which permanently and
significantly reduce toxicity, mobility, or volume of hazardous substances. This preference is
satisfied when treatment is used to reduce the principal threats at a site through destruction of
toxic contaminants, irreversible reductions in contaminant mobility, or reductions in the total
volume of contaminated media.
Alternative 34 offers the greatest reduction in toxicity, mobility and volume due to treatment of
all contaminants of concern in ground water. Alternatives 26 and 35 are similar to 34, but do
not include treatment of inorganic contaminants.
Alternatives 9 and 3 do not employ treatment to address COCs in ground water. Alternative 9
relies upon natural attenuation to achieve the ground water cleanup levels. Treatment is used
in addressing two of the three industrial waste streams that are sources of ground water
contamination, through Liquid Source Elimination activities, explained in Section 7.1. Alternative
3 utilizes slightly less treatment of sources than Alternative 9 because the calcine tailing are left
in place.
For Roaster Rejects Alternatives, no action does not reduce the toxicity, mobility, or volume of
the roaster reject material. Reuse reduces the volume of the source pile, reduces the mobility
(by making saleable products), and reduces the toxicity. The volume of source pile would be
reduced from 3000 tons to almost zero within 5 to 10 years by the reuse alternative.
No action on windblown calcine tailings does not reduce the toxicity, mobility, or volume of the
windblown calcine tailings. Excavation/disposal and capping reduce the windblown volume and
the mobility (though not through treatment), but not the toxicity of the calcine tailings.
8.2.3 Short-Term Effectiveness
The short-term effectiveness criterion focuses on the period of time needed to achieve protection
of human health and the environment, and adverse impacts which may occur during remedial
construction and remedial action, until cleanup goals are achieved.
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Short-term risks to workers are not a large factor at this site since the significant risk is from
ground water currently unused as a drinking water source. Risks posed during the
implementation of the remedies are mostly associated with construction risks associated with
fugitive dust, the presence of heavy machinery, open trenches, etc. Standard construction
practices and methods will be used to adequately protect the public health. The potential exists
in Alternatives 3 through 35 for exposure to COCs by fugitive dust inhalation and accidental
contact or ingestion of solid sources. Dust suppression measures and general hygiene practices
will be followed. The potential for exposure to COCs in ground water may occur for Alternatives
26, 34, and 35, during extraction, well construction or sampling, but the risk is low because the
main risk to human health is by long-term ingestion of water containing COCs.
Alternative 3 does not prevent further contamination of ground water from solid sources (calcine
tailings).
Alternatives 26, 34 and 35 could cause environmental impacts in the. Bear River that may be
unavoidable due to discharge of such a large volume (6,000 gpm) of treated water. All
alternatives, except 1 and 2, meet the cleanup objectives for reductions of contaminants in
ground water. Alternatives 26, 34 and 35 are expected to restore the ground water to its
beneficial use as a potential drinking water source in a period of five to ten years for most
contaminants of concern. TBP and TPH may require a longer time period, approximately fifteen
years. The time frames for TBP and TPH to fall be low risk-based concentrations are expected
to double to ten and thirty years, respectively, under Alternatives 3 and 9, which do not include
active ground water treatment.
For the roaster rejects, no action and reuse/recovery pose very minor or no risk to the community
with essentially no difference between the risks imposed by either option. Reuse/recovery poses
slightly greater risk to workers because handling of the material may cause slight amounts
fugitive dust containing vanadium. Environmental impacts are considered to be minimal. Reuse
will be more protective of the environment because the quantity of material will be reduced.
Remedial objectives can be immediately met by no action and reuse/recovery combined with
company policies, such as access restrictions.
All of the windblown calcine tailings alternatives pose minor risks to the community with
essentially no difference between the risks imposed by them. No action has slightly lower risk
to workers than the other alternatives because calcine tailings are not handled. No action would
not address the environmental impacts to the ecosystem. Excavation and disposal would
immediately remove the risk to the ecosystem. Capping alone would not be as protective of the
ecosystem as excavation and disposal because calcine tailings that have been windblown would
not be recovered. Remedial objectives can be immediately met by excavation/disposal. No
action would not meet the RAOs.
8.2.4 Implementability
This evaluation addresses the technical and administrative feasibility of implementing the
alternative, including the availability of materials and services required to construct the remedy.
Alternatives 3 and 9 have the most easily implemented technical aspects because they depend
on proven containment technologies and reuse of waste streams (constructing lined ponds and
reusing calcine tailings in phosphoric acid production). Alternatives 26, 34, and 35 have less
easily implemented technical aspects because of uncertainties concerning the extraction,
treatment and discharge of ground water. Treatment of ground water would result in a.discharge
of 6,000 gpm to the Bear River. Alternatives 3 and 9 are administratively implementable because
37
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a similar phosphoric acid production plant was permitted to operate in the area in the past. The
administrative feasibility of discharging treated ground water is considered low due to opposition
from the State of Idaho. The ability of these alternatives to treat low contaminant levels is
'Uncertain. Discharge permit requirements would need to be established for this site.
Roaster rejects alternatives, no action and reuse, are both technically feasible. Reuse is currently
being implemented causing the stockpile to be reduced by 300 to 600 tons/year. No action and
reuse are also both administratively feasible. New permits would not be required for either
action.
No action of windblown calcine tailings is technically feasible, but not administratively feasible
because it is ineffective at reducing risks to the ecosystem caused by windblown calcine tailings.
Excavation/disposal is technically and administratively feasible. Excavation and disposal of
windblown calcine tailings has already been done. Capping would also be implementable.
8.2.5 Cost
Present worth costs are used to evaluate and compare the estimated monetary value of each
remedial alternative. The costs are determined by summing the estimated capital costs and
estimates of the discounted operation and maintenance (O&M) costs over the projected lifetime
of the remedial alternative. Estimated present worth costs are based on a 30-year life of the
remedial alternative using a discount rate of five percent. Costs for source control and ground
water components of each alternative are summarized below:
Alternative 2
Alternative 3
Alternative 9
Alternative 26
Alternative 34
Alternative 35
Capital cost
Annual O&M
Present Worth
Capital cost
Annual O&M
Present Worth
Capital cost
Annual O&M
Present Worth
Capital cost
Annual O&M
Present Worth
Capital cost
Annual O&M
Present Worth
Capital cost
Annual O&M
Present Worth
$100,000
$60,000
$1,000,000
$1,000,000
$70,000
$2,000,000
$1,000,000
$100,000
$2,200,000
$13,000,000
$1,000,000
$23,000,000
$33,000,000
$4,500,000
$58,000,000
$15,000,000
$1,000,000
$25,000,000
Costs associated with roaster rejects and windblown calcine tailings are not included here
because the do not significantly (less than $ 10,000) affect the cost of the overall alternatives and
the actions are already in progress. Note that for Alternative 34, annual O&M drops to
$1,000,000 after the first five years, once active treatment is completed.
38
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8.3 Modifying Criteria
8.3.1 State Acceptance
The Idaho Department of Health and Welfare concurs with the selected remedy and final remedial
action described in this ROD for the Kerr-McGee Superfund site. The combination of measures
identified as Liquid Source Elimination which will result in the addition of a phosphoric acid plant
to consume the calcine tailings, and the scrubber water, in addition to lined ponds to replace the
existing unlined S-X pond, will adequately prevent contaminants of concern from entering the
ground water once the remedial action has been completed. The ground water is expected to
naturally recover once LSE actions have been complete. This approach and the selected remedy
are deemed to be in compliance with the environmental laws and regulations of the State of
Idaho.
8.3.2 Community Acceptance
EPA has attempted to keep the public informed of activities leading up to the selection of the
remedial action identified in this ROD. The public has not expressed a significant interest in
activities at the site. One public comment was received during the public comment period which
was supportive of the selected remedy.
9.0 SELECTED REMEDY
The selected -remedy for this site is Alternative 9, which includes distinct remedial actions for
contaminated ground water, stockpiled roaster reject solids, and windblown calcine tailings.
Together they constitute the selected remedy for the Kerr-McGee site. For purposes of providing
complete information about the actions and the basis for each one, they are discussed separately
below.
9.1 Remedial Actions for Ground Water
9.1.1 Remediation Goals for Ground Water Actions
The remediation goals for ground water are to prevent human exposure to ground water
contaminated with chemicals of concern, specifically vanadium, molybdenum, arsenic, tributyl
phosphate, total petroleum hydrocarbons, and/or manganese exceeding risk-based concentrations
in the absence of MCLs (chemical specific ARARs), and to restore ground water to its beneficial
use as a drinking water resource.
Chemicals of concern are those substances exceeding risk-based concentrations calculated in the
baseline risk assessment to correspond to a Hazard Index of 1.0 for each chemical identified in
Table 10). The COCs at this site (except arsenic) do not have established chemical-specific
ARARs (MCLs) under the Safe Drinking Water Act, so human health risk-based concentrations
developed in the baseline risk assessment have been established to correspond to a cancer risk
of 10* or a Hazard Index of 1 in accordance with EPA guidance.
The point of compliance for evaluation of the performance of the selected remedial actions for
ground water will be the boundary of the currently active industrial facility, using existing
monitoring wells, (shown in Figures 1 & 7).
39
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9.1.2 Selected Remedial Actions for Ground Water
The following actions constitute the selected remedy for contaminated ground water:
o Elimination of uncontrolled liquid discharges from the facility to soils, surface or ground
water as soon as determined practicable;
o Excavation and reuse/recycling of buried calcine tailings (in the areas shown on Figure
6, Section 2.0} over the next eight years.
o Excavation and on-site disposal of Solvent Extraction and Scrubber Pond solids
(sediments and the top few inches of underlying soils containing elevated levels of
ground water COCs) in lined, covered, cells on-site;
o Semi-annual monitoring of ground water to determine the effectiveness of the source
control measures described above in achieving the following risk-based ground water
performance standards, as measured at the point of compliance:
Vanadium: 0.26 mg/l
Molybdenum: 0.18 mg/l
Tributyl Phosphate: 0.18 mg/l
Total Petroleum Hydrocarbons: 0.73 mg/l
Manganese: 0.18 mg/l; and.
Arsenic: 0.05 mg/l
A comprehensive evaluation of monitoring data will be conducted annually to verify that
reductions of COCs in ground water are occurring consistent with the ground water
modelling.
o Establishment of Institutional Controls (deed restrictions, limited access, well restrictions
and/or well-head protection) in the affected areas on- and off-site (areas with
concentrations > RBCs) to curb certain types of uses of ground water for as long as the
ground water exceeds the performance standards.
o Until such time as monitoring demonstrates that the performance standards have been
achieved for all COCs, reviews will be conducted no' less often than every five years
(using monitoring) to confirm the elimination of liquid discharges and effectiveness of
source control and ensure that the remedy continues to provide adequate protection of
human health and the environment.
9.1.3 Cost and Volume Estimates for Ground Water Actions
The estimated capital cost for the selected ground water remedy is $2,000,000. Additional costs
will be incurred by KMCC to construct the phosphoric acid plant that are not reflected in these
capital costs.
The following is a summary of the volumes of material that will be addressed by the selected
remedy:
• Source Elimination: Currently about 350 gpm of industrial waste water is discharged from
the unlined S-X and scrubber ponds that leach into ground water. The selected remedy
addresses this material by requiring elimination of uncontrolled discharges.
40
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• Pond Solids (Sediments and Soils): Approximately 1,800 cubic yards from the S-X pond
solids and 4,500 cubic yards from the scrubber pond will be excavated and disposed of
in lined ponds on site. Excavation must ensure that all visible pond solids are removed.
• Calcine Tailings: The current calcine tailing production rate is about 90 tons/day (full
capacity is about 150 tons/day) and the estimated volume of buried material is
approximatley 700,000 tons. The anticipated throughput of the planned phosphoric acid
plant is 350 tons/day. At this rate, the buried calcine tailings will be consumed in
approximately 8 years.
9.2 Remedial Action for Roaster Reject Solids
9.2.1 Remediation Goals/Risk Levels for Roaster Rejects
The remediation goal for roaster rejects is to prevent contact and or human exposure to the
roaster reject solids, particularly ingestion of solids containing levels of vanadium greater than
14,000 mg/kg, which corresponds to hazard index greater than one as calculated in the risk
assessment. The roaster rejects are not considered a source of ground water contamination.
9.2.2 Remedial Action for Roaster Reject Solids
The selected remedy for the roaster reject area of the facility is resource recovery/reuse. Roaster
rejects stockpiled during past operating practices will be reused as feedstock material for the
production of vanadium over the next 5-10 years. During the time material remains stockpiled,
it must be maintained in an area that is designed to minimize potential migration of materials to
the surrounding environment or direct human exposure to it. So long as roaster rejects remain
stockpiled in their current fashion, a review will be conducted every five years to ensure the
remedy remains protective.
9.2.3 Cost and Volume Estimates
There is currently about 3,000 tons of material containing vanadium concentrations exceeding
20,000 mg/kg. Approximately 300-600 tons of material will be consumed each year, depending
on the number of roasters operating. At that rate, the stockpile should be eliminated in 5-10
years. The approximate cost is estimated to be $10,000, with annual operating costs less than
the value of the vanadium in the material.
9.3 Windblown Calcine Tailings
9.3.1 Remediation Goals/Risk Levels
The goal of this remedial action is to prevent the transport of COCs from the active calcine
tailings area to the surrounding soils in amounts that exceed the 95% UTL of background soils.
The windblown calcines are not considered a source of ground water contamination.
9.3.2 Remedial Action for Windblown Calcine Tailings
The selected remedy for windblown calcine tailings observed in the Remedial Investigation is
excavation and on-srte disposal. The company voluntarily excavated all visible windblown calcine
tailings in the spring of 1995. Sampling will be done during remedial design to confirm that
remediation goal has been met, and to ensure that no further action is needed.
41
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9.4 Plant Process Changes Contributing to Remediation Goals
In recognition of RI/FS results and anticipation of the need to eliminate the source of ground
water contamination, KMCC has already developed and submitted (to EPA and the State of
Idaho) elements of a waste minimization plan to eliminate liquid discharges from the facility and
to reuse/recycle buried calcine tailings such that on-site containment will not be necessary. The
KMCC plan includes:
• construction of new lined evaporation ponds to contain the main source of ground water
contamination (S-X raffinate currently discharged to leaking unlined ponds);
• construction and operation of a phosphoric acid plant to consume other liquid and solid
wastes and produce a marketable product.
The company has obtained all the necessary state permits to build and operate the lined S-X
ponds, which are now under construction. The company has also applied for the necessary
permits to operate a phosphoric acid plant.
Successful implementation of KMCC's plan in a timely manner, along with excavation and
disposal of the S-X pond solids, should effectively address the sources of ground water
contamination. The success of source control actions will be subject to confirmation by ground
water monitoring.
9.5 Timely Implementation of Plant Changes
Elements of Liquid Source Elimination being implemented by KMCC outside of the Superfund
process must be implemented in a timely manner to ensure adequate protection of human health
and the environment. KMCC has a permit and is already constructing lined ponds to replace the
unlined S-X pond, and it has applied for the necessary air pollution control permit to operate a
phosphoric acid plant, a necessary part of their plan to address the scrubber and calcine waste
streams. EPA has solicited input from KMCC and from IDHW to determine how soon KMCC can
reasonably be expected to implement the these elements of their waste minimization/Liquid
Source Elimination plan.
IDHW has provided a general timeline for air permit processing of thirty days for permit
application review to ensure the application is complete, followed by a sixty-day technical
evaluation period, a thirty-day public comment period, and fifteen days to respond to public
comment prior to issuing the permit. KMCC's application was complete as of July 20, 1995.
Currently, IDHW is in the process of performing its technical evaluation. If there are no delays
in the general permit process, KMCC can be expected to obtain the permit by December 5, 1995.
This assumes that KMCC's permit application for a phosphoric acid plant will be granted.
KMCC has indicated that the construction time frame for the phosphoric acid plant is expected
to take four to five months. Following construction, an additional one to two months to reach
maximum processing capacity of 350 tons/day of calcine tailings is expected, after which time
the scrubber pond water may be diverted to the phosphoric acid plant. The water used to sluice
the calcine will then be recycled. One to two months after the acid plant is operating at full
capacity, KMCC will be able to have the scrubber pond out of service completely.
KMCC also anticipates that harsh winter weather typical of the area may prevent construction
of the phosphoric acid plant until May 1996. Based on these considerations, timely
implementation will require that the plant construction be completed by October 1996, with the
phosphoric acid plant in operation by February 1997 (and the unlined ponds out of service). S-X
and scrubber pond solids would be expected to be excavated the following summer.
42
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9.€> Potential Changes to the Selected Remedy
Based on information obtained during the Rl and on a careful analysis of all remedial alternatives,
EPA and the State believe that the selected remedy is a final remedy and will achieve the
remedial action goals. It may become apparent, during the remedy (after implementation of
source control and continued monitoring), that contaminant levels have ceased to decline and are
remaining constant at levels higher than the remediation goal over some portion of the
contaminated plume. In such a case, the performance standards and/or remedy will be
reevaluated.
The schedule for implementation may be modified if significant changes occur to the expectations
outlined above. However, if EPA determines that LSE is not being implemented in a timely
manner, additional CERCLA enforcement action may be taken.
10.0 STATUTORY DETERMINATIONS
10.1 Protection of Human Health and the Environment
The selected remedy will provide adequate protection of human health through a combination of
source control and institutional controls. In order to accomplish source control, the company has
made and continues to make process changes to treat, reuse and recycle the waste streams
which have been the source of ground water contamination," and lined ponds are being
constructed to manage S-X liquids under a state permit in anticipation of and consistent with this
selected remedy. Exposure to roaster rejects, which potentially pose unacceptable risks to
humans, will be reduced and eventually eliminated by reuse/recycle of all stockpiled material over
the next several years.
Ground water modelling predicts that within ten years of implementation of the selected remedy
(source control) levels of vanadium, molybdenum, arsenic, and manganese will achieve the
health-based performance standards; levels of TPH and TBP are predicted to achieve the
performance standards in thirty (30) years or less (possibly much less if degradation occurs). The
performance standards have been established at levels that correspond to a hazard quotient of
1 for non-carcinogens and the 10"6 level for carcinogenic risks.
Implementation of the selected remedy will not pose unacceptable short-term risks or cross-media
impacts. During the period of time before and after source control, during which the ground
water is recovering naturally through dilution, institutional controls will be established to prevent
exposure to contaminated ground water.
10.2 Compliance With Applicable or Relevant and Appropriate Requirements
The selected remedy will comply with all chemical, action and location-specific federal and state
ARARs. No ARAR waivers will be used. Specifically:
40 C.F.R. Part 141. Safe Drinking Water Act. Establishes MCLs and non-zero MCLGs. The MCL
for arsenic is relevant and appropriate to the ground water beneath and beyond the boundaries
of the currently operating facility, and will be met by source control and natural attenuation;
Idaho Ground Water Standards (IDAPA Sec. 16.01.02.2991. Protects ground water for beneficial
uses, along with the Idaho Antidearadation Policy (IDAPA Sec. 16.01.02.051). which requires
that existing water uses and water quality be maintained and protected. These ARARs will be
met by source control and natural attenuation;
43
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Environmental Protection and Health Act. Idaho Code 39-101 to 129. Authorizes rules to protect
the environment and human health and safety through state oversight of solid waste disposal and
state approval of disposal locations and design. This requirement is relevant and appropriate for
the on-site disposal of S-X and scrubber pond liquids and solids (once excavated). Since KMCC
has been issued and is currently in compliance with the requisite permit for the new lined S-X
ponds, the substantive and administrative requirements of this ARAB are already being met. The
substantive portion of this ARAR will also be met for on-site disposal of the pond solids;
Rules for Control of Fugitive Dust. 1DAPA S 16.01.01.650. This ARAR is relevant and
appropriate for the management of the roaster rejects material as well as during excavation and
reuse/recycling of buried calcines. This ARAR is met for roaster rejects by the requirement that
those materials be maintained in an area that is designed to minimize potential migration to the
surrounding environment for as long as the material remains stockpiled. Fugitive dust control
measures will also be required during excavation of buried calcines for reuse/recycling.
10.3 Cost-Effectiveness
The selected remedy affords overall effectiveness proportionate to its costs. The selected source
control remedy is cost effective because it will achieve most cleanup goals within ten years and
all goals within thirty years or less, at a cost of about $2,200,000, without adverse affects on
the plant operations. The no action alternative and other more limited alternatives would not
achieve the cleanup goals. The addition of a pump-and-treat system would increase costs by
$ 10-20 million without achieving the goals much more quickly than natural recovery after source
control.
10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies to the Maximum
Extent Practicable
The selected remedy utilizes permanent solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable for this site. It meets the statutory
requirements, is protective of the environment, addresses all sources of contamination, utilizes
treatment in waste minimization efforts (reuse/recycle of two waste streams) and achieves the
ground water cleanup goals in about the same time frame as more expensive ground water
treatment options.
Source control is expected to eliminate the source of the problem such that the aquifer will
recover naturally to its beneficial use within ten years for most contaminants (levels of TPH and
TBP are predicted to return to normal and achieve performance standards in 30 years or less)
without treatment. The selected remedy for the roaster rejects is resource reuse/recovery. The
material currently stockpiled will be used as feedstock, and in the future the material will be used
at such a rate as to eliminate the need for permanent stockpiling.
The selected remedy provides the best balance of tradeoffs among the alternatives with respect
to the evaluation criteria, particularly the five balancing criteria. It provides similar long term
effectiveness and permanence as the more expensive treatment options. The source control
component will achieve some reduction of toxicity and volume of contaminants, and will restrict
mobility via lined ponds for the S-X raffinate, to eliminating the source of future contamination.
The pump and treat alternatives would treat a greater volume of contaminants and remove them
from the environment, but at substantially higher cost and with only marginal reductions in the
time to achieve the cleanup goals. In addition to costing ten times as much as the selected
remedy, the pump and treat alternatives would have substantially greater short term impacts than
the selected remedy during the construction of the system and afterwards due to the need to
capture and dispose of very large volumes of treated water. The implementability of the pump-
44
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and-treat alternatives is also questionable due to the lack of feasible disposal alternatives for the
large volume of treated water. Other alternatives considered, including no action, institutional
controls alone, and control of only selected solid sources, all failed to adequately address some
or all of the evaluation criteria.
Once the threshold criteria of protection of public health and the environment and compliance
with ARARs was addressed, the most significant factors in determining the selected remedy were
the combination of long term effectiveness, permanence and cost effectiveness. State and
community acceptance were considered informally during the RI/FS by keeping the public and
state representatives informed and offering opportunities for their input during the process, as
well as formally at the conclusion of the FS. The state was consulted and concurred on the
proposed plan for cleanup. The public was given the opportunity to comment on the proposed
plan. A single public comment supporting EPA's selected remedial action was received during
the public comment period.
10.5 Preference for Treatment as a Principle Element
The selected remedy includes treatment, specifically reuse/recycling of calcine tailings as part of
source control to address contaminated ground water. Re-capture and treatment of contaminated
ground water was not found to be practicable at this site and was not selected because it is
much more expensive than source control, and not expected to substantially accelerate the time
frame for cleanup. This remedy also includes reuse/recycling to address the roaster reject
materials. Since treatment was incorporated to the extent practicable for this site, the selected
remedy satisfies the statutory preference for treatment as a principal element of the remedy.
Also, as pan of the overall site strategy, though not the selected remedy, KMCC has developed
a waste minimization/treatment plan and .is changing its industrial processes to eliminate liquid
discharges to ground water from the facility within the next one to two years. In order to do so,
KMCC has applied for a permit to operate a phosphoric acid plant, which will recycle/reuse
wastes which are currently the source of ground water contamination to.manufacture a new,
marketable product.
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES
CERCLA Section 117(b) requires that the Record of Decision document and discuss the reasons
for any significant changes made to the selected remedy from the time the Proposed Plan and
RI/FS reports were released for public comment to the final selection of the remedy.
The preferred alternative identified in the Feasibility Study and in the Proposed Plan is Alternative
9, Liquid Source Elimination, on-site disposal of pond solids, and reuse of calcine tailings, ground
water monitoring, and institutional controls.
The Proposed Plan did not explicitly describe the actions taken to address secondary risks on the
roaster rejects pile, which were documented in the FS. However, the selected remedial action
for reuse of the roaster rejects is already being implemented by KMCC. Similarly, the excavation
and disposal of windblown calcine tailings was not specifically described in the Proposed Plan,
but voluntary actions by KMCC to address windblown calcine tailings were taken during the site
investigation. These actions do not significantly impact either the cost or the scope of the
remedial action identified in the Proposed Plan.
45
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In addition, costs in the Proposed Plan vary from the FS because in the FS capital costs were
rounded to the nearest million dollars. EPA believed that it was more appropriate to represent
costs without rounding in the Proposed Plan, to more precisely display the costs of each
alternative for public comment. However, the rounded FS costs are used in the ROD to be
consistent with documentation provided in the FS and to avoid potential confusion.
These matters are being noted in this section as a matter of clarification, but do not change any
essential element described in the Proposed Plan to address principal threats to ground water at
the Kerr-McGee site. No significant changes were made to the preferred alternative as presented
in the Proposed Plan.
46
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APPENDIX A
STATE LETTER OF CONCURRENCE
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IDAHO DEPARTMENT
OF HEALTH AND WELFARE
DIVISION OF Apr i 0 1QQ5
ENVIRONMENTAL QUALITY v*
-: SUPEBFwiw
1410 North Hilton. Boise. ID 63706-1255. (206) 334-0502 Philip E.Batt. Governor
October 10, 1995
Peter Contreras
US EPA Region 10 HW-113
1200 Sixth Ave.
Seattle, WA 98101
RE: State of Idaho Concurrence on the Kerr McGee Record of Decision
Dear'Mr. Contreras:
Thank you for providing representatives of the State of Idaho an
opportunity to review and comment on the Kerr McGee, Soda Springs,
Idaho Superfund Record of Decision. Staff from our Southeastern Idaho
Regional Office, Central Office, and Attorney General's Office, have
had opportunity to review and provide editorial comments on the
document and it's draft.
The Division of Environmental Quality (DEQ) may not have the authority
to enforce any institutional controls related to the drilling of
domestic wells outside the boundaries of the Kerr McGee facility.
Therefore, should well drilling occur, the DEQ would regard such an
activity as a Record of Decision (ROD) remedy failure and expect the
EPA to reevaluate and revisit the institutional controls element of the
Kerr McGee remedial action.
We appreciate your consideration of our input in the remedy selection
process. Having been instrumental in the remedy selection, we concur
with the ROD.
Sincerely,
Wallace N. Cory,
Idaho Division of[ Environmental Quality
Administrator
WNC:GB:rop
cc: George Spinner, SEIRO Regional Administrator
Dean Nygard, Acting Remediation Bureau Chief
Mike Thomas, Superfund Program Manager
Boyd Roberts, SEIRO Remediation Supervisor
Gordon Brown, SEIRO Remediation Project Officer
O: \DATA\WPS1 \M1W\( -OSTRF.RA. LTR
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RESPONSIVENESS SUMMARY
1.0 Purpose
This section contains a summary of comments and concerns raised during the public comment
period held from August 4 to September 3, 1995. A brief description of community involvement
is also included.
2.0 Community Involvement
EPA conducted community interviews in August 1990 and found community interest in the Kerr-
McGee Superfund Site to be low. Citizens and local officials have expressed more concern over
other environmental issues in the- area, such as the Monsanto Superfund Site in Soda Springs,
the FMC Superfund Site in Pocatello, and the Southeast Idaho Slag Studies.
EPA offered to hold a public meeting to discuss the Proposed Plan during the the public comment
period and notice of opportunity to comment was published in the local newspaper, the Caribou
County Sun. No one requested a public meeting. As a result of the Proposed Plan, two
newspaper articles were published announcing that EPA was seeking comments and describing
the preferred alternative.
3.0 Summary of Comments Received
EPA held a public comment period from August 4, 1995 to September 3, 1995. The public sent
one (1) letter .providing public comment. No phone calls were received providing public
comment:
Comment: The commentor agreed with EPA's Preferred Alternative 9 and supported it as having
a favorable cost/benefit ratio in reaching the goal of clean ground water at the least cost. The
commentor believed the more costly alternatives would have a deleterious effect on society
because of the high costs and modest benefits.
Response: Comment noted.
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APPENDIX C
FIGURES AND TABLES
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- \W- j
Ij 1JU/V^— J
'\!j?@ i
-• ipa, . \ PEnnoPHOSPHonous
(/I > -- OPE STORAGE
u! >^" i ^
LJ . _xci
' S* SCRUOOER
«>«Ar( \DCUOH or
f FACtlTY BOUNDARY
~J
..',•- - --.- •r-'^i
\
» ^— • .-x
"^ /
\ ' 1
x~7 !
i
i
LCINE TAILINGS AREA 1
1
|
1
1
2oN i -
\ X ,
'OND ^^-x 1
Z^>\^ '
®KERR-MCGEE
CHEMICAL CORPORATION
SOOA SPHIX5S. OAHO FA'tUTY
FACILITY MAP OF
IMPOUNDMENT AND
PRODUCT STORAGE AREAS
ncvisiON- OATC pntPM«oOY:<
Games i Moore
FIGURE 4
-------
.Sod« Spring Rl/fS
HI R.(.ort
ab«r !«9J
TABLE 1
NATURE AND QUANTITY OF MATERIALS
GENERATED AT THE SODA SPRINGS FACILITY
n
i
.Material TVPO
Ammonium Mecavanadate (AMV) Product
Potassium Hecavanadnce (K- Produce
VAN)
Sodiun Ammonium
Decavanadaco (SAVAN)
Vanadium Pencoxide
VANOX-13 (V40,,)
Solvent Extraction
Raffinane
Product
Product
Product
Waste
Magnesium Ammonium By-produce
Phosphate (MAP) Residuals
Wa t e r
Quantity •
Produced as needed
Produced as needed
50 gpm (1989)
70-85 gpm (1990) ;
1200-1600 Tons/year
5 gpm (no longer used)
Nature/Handling
Light cream colored powder stored
on-site in 17.5-gal. fiber dra-ns
until shipment.
White powder stored on-'site In 30-
gal. steel drums or 17.5-gal.
fiber drums until shipment.
Stored in various size steel and
fiber drums on-site until
shipment.
Three grades, low alkali granular,
fine granular and flaked are
stored on-site in various size
drums until shipment.
Black powder packaged in 2 kg
cans, Cans packaged in boxes for
shipment,
Liquid residuals originating from
the solvent extraction circuit.
They are 'discharged to the
settling .ponds and then to the S-X
pond.
By.-product generated by the
removal of phosphorus and calcine
during the first precipitation
stage of vanadium cake. It Is
stored in the MAP pond. These
ponds have been closed.
-------
KHCC Sod* Sprint* RI.TS
DRAH Rt (Uport
Hov.mb.r 1»«
TABLE 1 (continued.1)
NATURE AND QUANTITY OF MATERIALS
GENERATED AT THE SODA SPRINGS FACILITY
Hntei-tnl
Quantity
Noturo/Htmclltne
Leached Calcine Tailings
Scrubber Residuals
o
Boiler Blowdown
Waste
Water
Waste
Water
Water
100 Tons/day (1989)
140 Tons/day (1990)
153 Tons/day (1991, 1992)
100 Tons/day (1993)
80-100 gpm
200 Tons/year (1989)
300 Tons/year (1990)
300 Tons/year (1991)
210 gpm
1.5 gpm
Solid residuals from leaching of
the calcined ore. They are
discharged In a slurry to the
calcine tail-Ings pond on the east
side of the property. In 1988,
34% of this output was sold to a
local fertilizer plant. 13% was
sold in 1989.
Residuals from the baghouse on the
limestone crushing circuit and
scrubber tails from the three
roasters. The tails are slurrled
to pond on the southeast corner of
the property. (Prior to February
1990, the limestone crushing
circuit used a wet scrubber system
for partlculate control).
Discharged from the water softener
regeneration unit feeding water to
.the boiler. Discharge goes to the
boiler blowdown pond. This pond
was closed In 1992. Water is now
recycled.
Roaster Reject
Secondary
Feedstock
250 Tons/year
Residual from calcining step revised
in the roaster feed.
-------
7'77'rr77'r^7^77-^ S7
'/CtKtoeffiM'.
lallinasl'oiiatft TAILINGS pom
ySZ/rWT1///?/////?}^,
"•ovv'' Calcine Tailings /fvyy'i'VS
vvvj (covered) x/XXx//
x>W tteif.a *t**tt x///x./V
/
= = = = ~ --> Limestone '£$$&£%
© Settling Ponds MW-'Cift-*;i;j;>;5
EXPLANATION
• • Fence
— — — —r 0«t road
tt G Hlocnt flow
M v\M © Monitoring wcl and *
dosgrulon nuiifccr
Ctosod rnpoorrtiiKH of
disposal area (oovcrod)
* WELLS MSTALLED PfUOR TO THE re
(NVEST1GATXJM. WEUS UW-I AND
MW.J AH£ AOMOXJNEO. FKURE DOCS
NOT MCUIOG It.*!' CEIUGS WCIXS.
ADAPTED FROM PflKT NdJUOGO
N DRAFT (VF3 STUDY PREPAflED BT
JAMB M. MOMT
-------
TABLE 2
PAST & PRESENT WASTE PONDS
KERR-McGEE SODA SPRINGS FACILITY
KHCC Sod* Sprlnn RI/FS
DRAFT RI Report
November 199)
Ponds
Calcine Tailings Pond
(West) (1)
MAP Ponds (3)
o
Solvent Extraction
(S-X) pond (1)
Dates Used
1963-1973
1973-1993
1993
1968-Present
Current
Status
Closed
Active
Closed
Active
Quant1tv/Na ture
244,000 tons of leach
residue
1200-1600 tons/ year of
by-product.
5 gpm water.
Pond Capacity 5.5 million
gallons. Liquid storage
of effluent from S-X
process. Pond maximum
depth measured at 6.75;
pond average depth is 3
to 5.5 feet
Other Comments
This area was covered and seeded
In 1973
3 ponds are used in parallel Co
hold magnesium ammonium phosphate
prior to sale of fertilizer.
While pond Is filled, the by-
product from the other is sold.
MAP ponds will be closed by the
end of 1993. MAP will be
discharged to a truck following
filtering for fertilizer sales.
This pond was rebuilt and expanded
in 1981. From October 1987 to May
1989 the pond was not used.
Effluent during this period was
used to fill the new limestone
settling pond. Reuse commenced in
May 1989.
1(626-019-031
-------
TABLE 2 (continued)
PAST & PRESENT WASTE PONDS
KERR-McGEE SODA SPRINGS FACILITY
KMCC Sod* Sprlngj RI/FS
DRAFT Rl Rtport
November 199}
Ponds
Limestone Settling Ponds
(5)
o
Scrubber Pond
Boiler Slowdown Pond (1)
Dates Used
1974-1983
1963-1988
1984-1988
1988-Present
1993
1972-Ptesent
1963-1992
Current
Status
Closed
Closed
Closed
Active
Active
Active
Closed
Quantify/Nature
500,000 gallons
750,000 gallons
1,000,000 gallons
750,000 gallons
Used for pH control of
S-X tails.
2,500 tons scrubber
tails. Pond averages 2 to
3 feet in depth, with
maximum depth measured at
6.9 feet.
1.5 gpm. No solids are
discharged to this pond.
Other comments
Covered and seeded in 1983.
Covered and seeded in 1988.
Covered and seeded in 1988.
The last pond used to neutralize
S-X tails.
Additional lined pond added
similar in size to Limestone
Settling Pond #4.
900 tons of the scrubber bottom
tails from this pond were sold to
fertilizer plant as feed stock in
1988.
Discharged from the water softener
regeneration unit feeding water to
the boiler. This pond was
formerly used as a scrubber pond.
-------
TABLE 2 (continued)
PAST & PRESENT WASTE PONDS
KEflR-McGEE SODA SPRINGS FACILITY
KHCC Sod* Sprlnii RI/FS
DRAFT RI Rtport
November 1993
Ponds
Calcine Tailings Pond
(East) (3)
Dates Used ,
1972-Present
Current
Status
Active
Quantity/Nature
625.000 tons calcine
tails
Landfill (Solid Waste
Disposal Pits) (3)
1963-1973
Closed
Wood, paper, office
trash, cleaned process
equipment.
o
00
Other Comments
In 1976 the exposed surface area
of the tails was reduced to
control fugitive dust. Current
procedure Is to open a trench
large enough to hold one year's
discharge. Once it is filled, a
new trench is dug and the old one
is covered. Recently, an old
trench has been left open to allow
access to tails for sale.
Trash Is now taken to the local
landfill.
-------
KMCC Soda Springs KPFS
DRAFT Comparative AuNvi Report
February 1995
TABLE 3
ESTIMATED MAXIMUM CONCENTRATION BASIS
COCs IN GROUND WATER
(mg/l)
PLANT BOUND ARIES
coc
Vanadium
Molybdenum
Ancnc
TBP
TVH
Maiuinc^c
KM-2
15.1
l.«4
0.03
NA
NA
0.26
KM-3
13.2
4.91
0.02
NA
NA
0.«2
East
KM-4
10.9
Ztl
0.02
NA
NA
0.95
KM-I1
0.49
5.6
0.002
NA
NA
0.14
Avg.Conc.
(mgl)
9.92
3.79
0.01 S
NA
NA
049
PLANT BOUNDARIES (CONTINUED)
I
COC
Vanadium
Molybdenum
Ancnk
TBP
TPH
Manganese
WeB
KM-3 KM-6 KM-7 KM-S KM-9 KM- 13
1S.S 4.S 2.46 2t.6 3.59 6.42
1.46 2.14 0.59 119 1.74 6.79
0.012 0.006 0.004 O.OS 0.005 0.004
NA 0.11 NA 4.4 NA NA
NA NA NA 2.2 NA NA
0.4 0.23 0.11 S.63 0.1S 0.13
Ayg.
10.28
* 21.95
0.019
i26
2.20
1.61
Arithmetical
Final AVJL Cone.
10.10
12.S7
0.018
2.26
2.20
1.05
PLAXT BOUNDARIES TO FINCH SPRING
COC
VaMdmn
Molybdenum
Ansnic
TBP
TPH
Manoanoe
KM-15
3.13
6
0.004
0.4E
0.5
O.S4
KM-16
3.S4
i.n
0.007
0.005
0.5
0.36
KM-17
0.07
OJt
0.001
O.OS6
0.5
0.08
KM-ll
2.99
5.92
0.004
0.41
1
0.33
Fmefa
Sprinz
0.009
O.CS9
0.002
0.008
0.5
0.005
Arithmetical
Final AVR. Cooc.
1.95
2.96
0.004
0.19S
0.60
0.26
FINai SPRING TO BIG SPRING
COC
Vuudtum .
Mchtdaiutn
Ancnic
TBPW
•mi
M^n^«ncu
Finch
Spring
0.009
0.6(9
0.002
0.008
0.50
0.005
Rig Sprint;
0.007
0.375
0.001
0.001
0.50
0.006
AriiiuiKiical
Foul Avs. Cone.
0.008
0.532
0.002
0.005
0.50
0.006
N'oizs:
1) All dau it the maximum eoncenmooa gran for each chankal meaiured in the respective umple location
from Appendix B of ihc Draft RIRcpon. Data for Big Spring is from analytical rcsulu ftom aampling
rounds in December 1993 or M»y 1994.
2) Any \aluc in Appendix B preceded with a •<•» given a v»lue of one half the detection limit in the
table above.
3) Any Vahie in Appendix B«^ a NA or >% denotation mdtoici thai TO
-------
TABLE 4
ESTIMATED MASS AND CONCENTRATIONS OF COCs
IN LIQUID SOURCES
KMCC Sod* Springs RI/FS
DRAFT Comparative Analysis Report
February 1995
S-XPOND
WWT Flow Rate (gnm)*
Chemical Cone. (mrA.)1
Chemical mass (Ib) I Year
Contaminants of concern
Arsenic
65
0.19
54
Manganese
65
0.16
•*$
MolvMenum
65
155
•J4.000
Vanadium
65
IP
33,000
TBP
65
16
4.557
TPH
65
4!
12.000
Total mass (Ib)1
NA
NA
94.000
Total Volume (ealf
NA
NA
34.164.000
SCRUBBER POND
WWT Flow Rate (gpm)5
Chemical Cone (mg/L)'
Chemical mass (Ib) 1 Year
Conuminanls of concern
Arsenic
210
0.008
7
Manganese
210
O.OS
74
Molybdenum
210
1.03
94S
Vanadium
210
22
20.000
TBP
210
0
0
TPH
210
0
0
»
Total mass (Ib)
NA
NA
21.000
Tola! Volume (ea!)
NA
NA
110376.000
CALCfN'E POND
WWT Flow Rase (gpm)1
Chemical Cone. (mg/L)'
Chemical mass (Ib) I Year
Contaminants of concern
Arsenic
100
0
0
Manganese
100
0.12
53
Molvbdenutn
100
2 i
1.052
Vanadium
100
9C
39.000
TBP
100
0
0
TPH
100
0
0
Total mass (Ib)
NA
NA
41.000 .
Toul Volume (Sal)
NA
NA i
i
j
52,560,000
TOTAL
Chemical mass (Ib) I Year
Conununants of concern
Arsenic
61
Manganese
172
Molybdenum
46,000
Vanadium
93,000
TBP
4,557
TPH
12.000
Toul mass (Ib)
1.56E + 05
Toul Volume (gal)
1.97E + 08
1) Total mass rounded to nearest 1000 Ibs.
2) Total Volume of Liquid Source.
3) Flow rale and concentration data from Table A-2. Appendix A. of th* attached Revised Draft Ground Water Modeling Report,
Chemical concentrations are based on one sampling round.
'-) Refer to Table of Acronyms for explanalion of abbreviations.
C-10
-------
TABLE 5
ESTIMATE i> MASS AND VOLUME OF COCs
IN SOLID SOURCES
KMCC Soda Springs RI/FS
DRAFT Comparative Analysis Report
Fcbnury 1995
POND SOLIDS
Soil Volume (tons)
Chemical Cone. (rag/Kg)
Chemical Mass (Ibs)
Arsenic
550
7.7
8.5
Manganese
550
IS2
200
coc
Molybdenum
550
444
4SS
Vanadium
550
7770
S.55E+O3
TBP
550
140
154
TPH
550
NA
NA
Total
NA
KA
9.40E-KJ3
SCRUBBER SOLIDS
COC
Soil Volume (tons)
Chemical Cone. (mg/Kg)
Chemical Mass (Ibs)
Arsenic Manganese Molybdenum Vanadium TBP
4230 4230 4230 4230 4230
3.6 557 1040 10700 NA
30 4.71E+03 8.80E-K>3 . 9.05E-KM NA
' TPH
4230
NA
NA
Total
NA
NA
1.04E-K)5
CALCINE SOLIDS
COC
Soil Volume (tons)
Chemical Cone. (mg/Kg)
Chemical Mass (Ibs)
Arsenic
681750
0
0.00
Manganese
681750
915
1.25E+06
Molybdenum
681750
13.3
1.81E-KM
Vanadium
681750
2000
2.73E-KJ6
TBP
681750
NA
NA
TPH
681750
NA
NA
Total
NA
NA
3.99E-KJ6
TOTAL
Soil Volume (tons)
Chemical Mass (Ibs)
Arsenic
686530
39
Manganese
686530
1.2SE+06
COC
Molybdenum
686530
2.74E+04
Vanadium TBP TPH
686530 686530 686530
2.83E+06 154 NA
Total
NA
4.11E-H)6.
Notes: 1) NA - Not Analyzed or Not Applicable
2) Concentration data extracted from Table B-3-8, Appendix B, Draft Remedial Investigation
Report Dames & Moore, November, 1993. Chemical concentrations shown in this table
arc the maximum concentrations encountered in Table B-3-8.
3) Sec text for basis of source volume quantities.
4) Refer to Table of Acronyms for explanation of abbreviations.
C-ll
-------
Table 6
Identification of Chemicals of Potential Concern in Onsite Source Piles
' .-H * "• *
Anftlyte
Aluminum
Antimony
Arsenic
*
Barium
Beryllium
Cadmium
Calcium
. Chromium
(Total)
Chromium VI
;$$>att.v? , *";
$&*' . '< X-
Fluoride
Iron
Lead
Magnesium
Manganese
S&totrf;,'>
Nickel
Nitrate, as N
Selenium •
fcatigeof Site
> ConcentraUom
tmjt/kg)
313-12.300
U-19.1
U-7.0
11.5-153
U-1.8
U-18.2
7,370-246,000
16.1-4,860
<0.05-17
1.8-48.6
26-13,700
U-22.2
591-75,500 '
0.7-94.7
821-157,000
20.9-915
U- 1,040
14.1-2,070
No Data
U-13.1
Msxlititini
Bock- ..{' \
ground Soil
17,400
- •>•."!':,"%
>....*.'..-s*.^)i"f...
172
';'A-"44.
^x...^...^^./ftv..'J^.!&...
/ "'£ $
"i'-**»V
66.1
^ •• 2^^vWv' s
* ^ / •.*•
. r.-.\*u.
- -.^e
'««fe
Not Analyzed
;.:\Vft
13
"ii$&
NoJicnnc^r ftttCs No.
HQ*n.l of Kxc.
. 200,000
82
61-
140,000
1.000
100
2.000,000
1,000
\J; ,.,.i(5bO I/IB
12,000
' ;
29,000
1,000 (7/18)
4,100
330,000
1.000
Carcinogenic RBCs
IIC-7
33.0
13
-------
U)
Table 6 (Continued)
Identification of Chemicals of Potential Concern in Onsite Source Piles
/;?**%<
Silver
Tlwntum
VM
Zint
•^ TKuujtmt
• !Cba«pt*iioiM
tJ^^m^^
U-174
23.3-1.350
51.7-24,300
8.8-330
.•5 ^ %_.
Mnxttnum|«cy
trOuUd.Stt|||.
" ^ %^f
as?
' |a
, Ai^<
* /'-^ v'£^
1000 1/18
. \ ' 1,400
61000
Carcinogenic R&Cs
JE-7 . • ...::: I:,--:
Radionuclides in Onsite Source Piles
f v • f \
i^*!vti':; *
. •^t-.'.JSSs-- •:...'. ••$ .
K-40
Le»d-210+D
Polonlum-210
RMl^226+6
Radium-228+D
Thop turn- 228
Thorium- 230
Thorium- 232 I
Uranium- 234
-*«as
' «\ '', " * '
^KilWwfettitM*
^.^'^.^i^j^c^ 11*7 %
4.0E-02
A.9E-01
2.1E+00
:..<.../ -..^s^fte
7.5E-03
3.9E-03
2.3E+01
2.6E401
2.0E«01
£f "• •. «• . "• ^
•. t jt t .. L j» j i ^ i ..
^j^^^^^/.iJ.aiOE^.uzsr. tri ,..,..,
^"'^M3t%K",.
U ,= Not Detected
** • Uranium-238, U234; and U235 values have been converted from mg/kg to Pci/g using the equation given in Section
• 6 of this document.
RBC = Risk-Based Concentrations +D indicates that radionuclide progeny are included in risk calculations
Shading indicates exceedences of column values; shading in the analyte column indicates identification of a COPC.
Sources: 1 IRIS Database (1993)
2 HEAST, (USEPA 1993)
3 USEPA (1992f,g,h)
-------
o
Table 7
Identification of Chemicals of Potential Concern in Offsite Soil
(All values reported in mg/kg)
•$SoHDijiil %$
;.-..^.$MMnfatiffi^3;
Aluminum (0-1")
(0-6")
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
(Total)
fe' - k -;V-
> ?• ,••,'$.
4^*>'J^r ,mH&^
Copper
Fluoride
^f'Vt
^tehledr- Site
IMtotoii'atloitt .. .
7,340-17,900
6,860-23,500
u
u
2.0-6.1
u-7.2
89.2-185
84-222
u-0.88
u-l.l
u-14.2
u-7.8
6.980-83,000
5,840-64,500
18.2-229
16.8-186
6.0-20.9
7.4-17.9
23.5-537
15.6-445
1.3-11.2
1.4-16.8
l<&&tk)J*'/' ,
.r-Jyi , A '
"'\n?M&y-^'-, '•
<.-J?jfM.,-.:fe?. "•-
6
6
s.s£ -": v,-<
V ,?'•*, V ••' ." "'
«' '^- ^,»^^ -/>'
•V .s?^n *^^. ls-'...
-14'- *"Vj
..irf.. ':).'-. '.v»
i
2
9.7, , ,
.7_^».. ._,
*3jtf*>if3
> - s*'^ Vl «1.v%/ ^ % \V , ^ % %
'2Zi«\K^ v* "S *«
46.6
66.1
Moncaticer RBCNo.of
ttOtsfl.l ' Exc.
27,000
11
8.2
1,900
140
27.0
2'7,000
1,000
1,600
Carcinogenic RBCs
IE-7
0.037
-------
?
Table 7 (Continued)
Identification of Chemicals of Potential Concern in Offsite Soil
(All values reported in mg/kg)
'i^fa*tfj&mj&*''*$
.:;-:fe^:I^Ot^(ltttfijaft:::::,-s':'.
Iron (0-1") '
(0-6")
Lead
Magnesium
Manganese
Molybdenum
Nickel
v.5 v"'
Selenium
Silver
Jit&tiwn
,s:>S$
Range of Site ,-?
'.. Cortcontralioiis*:?:
9930-18900
11100-17300
8.7-25.6
9.8-17.5
2950-10000
3380-7130
475-722
463-727
u-5.2
u-3.1
22.3-667
20.2-555
u
u
u-4.2
u-2.4
272-710
266-868
52.6-766
30.4-569
39.8-248
40.3-163
•^f$ *VV $$'&, ^ s-
^'maSSAwA
A fiiij^iihd ., .
19200
23000
39
81
.&i\ '.
t«»if. -,.-:..
->*^v v - v- '
&^ o^f *
-'' ' ' ' ••%',
tt ?5\^ ' -
-------
n
Table 7 (Continued)
Identification of Chemicals of Potential Concern in Offsite Soil
Thorium-232 (0-1")
(0-6")
one.
0.45-0.85
0.50-1.2
0.39-5.6
0.26-4.9
1.7
1.6
6.4E+00
-------
I
I—
^1
Table 8
Identification of Chemicals of Potential Concern
in Ground Water
f f fj.
Antimony
Beryllium
Cadffllum
Calcium
Chloride
Chromium (Total)
Cobalt
Copper
PluQfW*' t -,
Iron
Lead
Magnesium
iMiin|ahe«
Mercury
3<£i\ '>£
il&i&'ilV - ' $*$£<£' -»
Potassium
£* '*;,TK.
Sodium
Suj'foteton* - <,,*
Vanadliiin
Zinc
U-19.6
U-0.03
U-0.08
U-0.39
U-8,006
U-0.006
89-625
5-12.100
U-0.062
110.079
U-0.375
U-0.48
U-22.1
U-0.013
39.3-291
U-6.8
U-0.0008
U-II9
U-0.384
0.50-157
1.5-972
U-0.143
U-0.035
3.3-8800
28-23.100
U-28.6
U-0.44
, ,>''4f;C o.r
- ' " ,V aoow
' •"/' 0.00*5
'> ' " J62
t\- 7
/ - O.OOJ
0025
,80123
\1 -)Sxlf:;t &*
*\ f-is ^y^' »'*
? v /- ^oois
' x- 4S'{
v '^abots
*-""V' J^opoi
not analyzed
"' tt"> t ^ e *
'^!?f"H^- 0<^
> ^-* ' ""* '^ ^ I.' ' *»5
i?^^;
. - *^^; ;( '; £.i
><£^i^i%^'^>f
.f'',-^^^" 0.0!
5vL^^k..Mr
v"-
s^j "!... '/ " f
"• > ' ' {0*'OIJ
005
2
0,004
000$
250SMCL
O.I
0.2
2.0SMCL, 4
0.3
0.015
•
0.002
10.1]
10
0.05
' O.I SMCL
JSOSMCL
(5)SMCL
MCtO
tO.05)
f0003]
10051
2
10)
0005
O.I
4
0
0.002
(01)
to
0.05
Human HeijtfftBC
(residential tttrftrlo)
IJE-03
' i'd^-OJ
K8E-02
'I.9E-03
3.1E+03
3.6E-OI
9.IE-02
1.4E-01
3.2J5-01
•
-
•
I.8E-02
MH4)3
7.3E-OI
5.8E-t-00
I.8E-02
1.8E-02
2.6E-02
7.3E-OI
-------
I
!—•
oe
Table 8 (Continued)
Identification of Chemicals of Potential Concern
in Ground Water
RMoiiucfides
Di-n-octyl Phthalate
Bis(2-Ethylhexyl) Phthalate
Butyl Benzyl Phihalate
Rallgeof ' sn
Concentrations (pCi/1)
U-4.13
U-39
U-3.22
2.1-2.6
U-0.003J
U-0.006J
U-0.009J
0.003-14
MCL
20
20
30
0.1
MCLG
Radionocllde RBC
(Residential)
1B-07 .
0.04
0.049
0.3
Human-Health RBC
(residential scenario)
7.3E-02'
7.3E-02
7.3E-02
7.3E-OI
1 = The RBC for TPH was derived from the RfD for JP-5 fuel.
J = Estimated Value
U = Not Detected
Parentheses in the MCL and MCLG columns indicate a proposed value.
Wells used in this screening include KM-1 through KM-13, the Lewis and pinch Wells, Boy Scout, Kelly Park and Spring
Organic data are from wells KM-6 and KM-8.
Shading indicates maximum detected concentration exceeds column values, shading in the analyte column indicates a
COPC. :
-------
Table 12
Current Industrial Scenario Exposure Factors*
Fcrropbosphorous P3e
Route
KME Exposure Factors
ptoncaurcmogcns
,-Carcino(eBs
Source Material IngestioD * * . f * " . ' '' -
Intake Rate
Exposure Frequency
Exposure Duration
Body Weigh!
Averaging Time
6.25 mg/day
1 80 days/year
25 years
70kg
9, 125 days
6.25 mg/day
180 days/year
25 years
70kg
25.550 days
Dust Inhalation
Inuke Rate
Exposure Frequency
Exposure Duraium
Body Weight
Averaging Time
External Gamma Exposure
Gamma Shielding Factor (S.)
unities:
Gamma Exposure Factor (T.)
.SoureeMalerial
Calcine Tamncs I
Route
5
-------
Table 12 (Continued)
Current Industrial Scenario Exposure Factors
Roaster Reject Pile
(Continued}
Route
Extenmt Gatnma Exposure
Gamma Shielding Factor (S.)
unities*
Gamma Exposure Factor (T,)
unitless
Calcine TaiUngs Pond 2
Route
Somce Material Ingestion
Intake Rate
Exposure Frequency
Exposure Duration
Body Weight
Averaging Time
DustJabaiation
Intake Rate
Exposure Frequency
Exposure Duration
Body Weight
Avenging Time
E*texnal€iitiaa Exposure. - - -:
Gamma Shielding factor (S.)
unidess
Gamma Exposure Factor (T.)
unidess
Roaster Reject Pile
Route
Source Material logestion
make Rate
Exposure Frequency
Exposure Duration
Body Weight
Averaging Time
{Kttt :$nftatati 'i - 4 -, "tygf
0.0
.005
RME Exposure Factor ^, ^.,, ''-"-'-,
••
6.25 me/day
104 days/year
25 years
70kg
9.125 days
' ', ' 7 -•'*" '?'- "' -^
2.5 m3/day
104 days/year
25 years
70kg
9. 125 days
? *
.
'
Caranargens % ••','•
•• ^ f ' ''•
6.25 mg/day
104 days/year
25 years
70kg
25 .550 days
- ^ ' V!l '*•
2.5 m3/day
250 days/year
25 years
70kg
25.550 days
." , , „ . '
0.0
0.012
* Average exposure factors were not developed for the current industrial receptors because site-specific data were used.
Specific intake rates for die current industrial scenarios are derived by dividing EPA default industrial intake rates by (hours spent
at source material each day/8 hours).
C-20
-------
Table 13
Future On-site Industrial Scenario Exposure Factors
Haute
RME Exposure Factors
Carcinogens
Source Material ingestion
Intake Rate
Exposure Frequency-
Exposure Duration
Body Weight
Averaging Time
50 mg/day
250 days/year
25 years
70kg
V. 1 25 days
50 me/day
250 days/year
25 year>
70 ky
25.550 days
Dust inhalation
Intake Rate
Exposure Frequency
Exposure Duration
Body Weight
Avenging Time
20 m3/day
250 days/year
25 years
70kg
9. 125 days
20 m3/d*v
250 days/year
25 years
70kg
25.550 days
BrtenaJCaBsma&tponire
Gamma Shielding Factor (S.) unities*
Gamma Exposure Factor (T.) unitless
-
-
-0.0
0.23
C-21
-------
Table 14
Future Offsite Residential Scenario Exposure Factors
Route
HME Exposure fSadorS " " ,
Noncarcinogens -^ ' ' '. Caronogens t%
AVG Exposure Factors
•Moncararegens
Carcinogens
Soil lng«siion
Ingestion Factor
(age and body weight
adjusted)
Exposure Frequency
Averaging Time
114 mg/vear
kg/day
350 days/year
10.950 days
1 14 me/vear
kg/day
350 days/year
25.550 days
100 ing/day
275 days/year
3.285 days
Dust inhalation ' : :L;:;-
Intake Rale
Exposure Frequency
Exposure Duration
Body Weight
Averaging Time
20 TO '/day
350 days/year
30 years
70 kg (adult)
10.950 days
20 mVday
350 days/year
30 years
70 kg (adult)
25.550 days
20 m'/dxy
275 days/year
9 years
70kg
3.285 days
Water Ingtsfkro - »
Intake Rate
Exposure Frequency
Exposure Duration
Body Weight
Avenging Time
2 I/day
350 days/year
30 years
70kg
10,950 days
2 I/day
350 days/year
30 years
70kg
25.550 days
ipiiilil^^h water - 4/i -^^rcy^v^"^
Contact Rate
Exposure Frequency
Skin Surface Area Exposed
Exposure Duration
Body Weight
Avenging Time
Absorption
wi^n^^^>°
Intake Rate* (Roots)
Intake Rate' (Fruits)
Intake Rate" (Leafs)
B. (dry wt)
Exposure Frequency
Exposure Duration
Body Weight
Averaging Time
0.17 hr/day (bathing)
2.6 hr/day (swimming)
350 days/year (badiing)
7 days/year (swimming)
20.000cm3
30 years
70kg
10.950 days
0.12 hr/day (bathing)
2.6 hr/day (swimming)
350 days/year (bathing)
7 days/year (swimming)
20,000 cm2
30 years
70kg
25 .550 days
Chemical Specific
dry weight
37 g/day
12 g/day
3 g/day
Chemical-Specific
1 20 days/year
30 years
70kg
10.950 days
"X ' ' ** •? *"
37 g/day
12 g/day
3 g/day
120 days/year
30 years
70kg
25.550 days
j&ernai Gamma 'Exposure "'• -'•• ' "
Gamma Shielding Factor
S«) unitless
Gamma Exposure Factor
(T«) unitless
0.0
0.022
a ** Based on intake rates of 200 mg/iday child and lOOmg/day adult and body weight
child of 15 kg and body weight adult of 70 kg.
b = Belcher and Travis (1989)
1.4 I/day
275 days/year
9 years
70kg
3.285 days
'*' <*£•'":'" '<«--
0. 12 hr (bathing)
2.6 hr (swimming)
275 days/year
(bathing)
7 days/year
(swimming)
20.000cm2
9 years
70kg
3.285 days
100 me 'day
275 days/year
25.550 days
- ••::• :
20 m'.'day
275 days/year
9 vears
70 kg (adult)
25.550 days
1.4 I/day
275 days/year
9 years
70kg
25,550 days
~:,
0.6 mg/cnr
275 days/year (barning)
7 days/year (swimming)
20.000 cm'
9 years
70kg
25 ,550 days
Chemical Specific
' -\-,
Not Evaluated
C-22
-------
?
u>
Table 15
Summary of Human Health Risks
Current Industrial Scenarios
INGESTION PATHWAY - NONCARCINOGENIC RISKS
COPC
Molybdenu
m
Vanadium
; _ >^eAf« ' .':'..'.
FeP
<.o.
0.03
CAti
<.OI
0.01
CAL 2
<.o.
0.01
ROR
<.o,
0.09
INGESTION AND EXTERNAL PATHWAYS - CARCINOGENIC RISKS
z&dote
m t.-* V <
**?»»,
U-235 + D
U-238 + D
'I'^'^j^'^^A* -,.,,.. v lJl^^/J*ita*»^Jk!i ^
;) , ^V^f^V', ' ' '
^ !-^:^^;^'
09 'fa
ME- 3. IE- 3.IE-07
09 07
. I.3E- 3.0E- 3.IE-07
08 07
, , '-55
v^
I.IE-IO
7.lt-09
All Radionuclides Combined 1.9E-05
iMl;
^ifi^*
3.IE-08
I.7E-07
gt
y^f1
3.IE-08
I.7E-07
CAL 2
oral
I.6E-
09
I.OE-
07
?X>
I.8E-
08
9.7E-
08
Tolnl
I.9E-09
2.0E-07
ROR
oral Ext fnhalailo Total
4.4E-09 4.9E- S.4E-08
08
2.lli-t)7 2.0E- 4.0E-07
07
INHALATION PATHWAY • CARCINOGENIC RISKS
lift
Arsenic
Nickel
'*S*\LJ'^'!%&%&*^> '•+>
r^*'"»' V^SS^*^^^ ^
8.5E-09
5.0E-09
:- -
;^;
'-WEC
3.9E-09
2.3E-09
hd&Jui£r"F-
CAL2.
2.3E-09
3.IE-09
«OR
4.9E-09
1 .8E-08
• = See Table C-2 '
" = See Table E-l, 2
FEP = Ferrophosphorus Pile
CAL 1,2- Calcine Tailings
ROR .= Roaster Rejects
-------
r>
ro
Table 16
Summary of Human Health Risks
Future Industrial Scenarios
COPC
Copper
Molybdenum
^Sinldtul ', s '„ '""
*M&* „
i&M :- _f.
. V4*K*t, -*&,
TOTAL
Source Piles
Boiler Slowdown
Cancer*
/Jtffoi
3.1E-07
1.3E-06
, >4M,
HQ
...
0.01
0.27
Calcine Tailings
Cancer* "
...
6.0E-07
3.5E-06
4.IE-06
HQ
...
0.00
0.14
Ferrophos
Cancer*
2IE-04
2.8E-06
2.8E-06
^2jB,04
HQ
.
o.ot
0.37
• Map Ponds
Cancer*
...
2.7E-07
1 .6E-06
I.9E-06
HQ
-...
0.01
0.73
Roaster Rejects
Cancer'
7.7E-07
3.3E-06
4.1E-06
HQ
0.04
1.70
Scrubber Pond
Cancer*
5.4E-06
6.3E-07
6.0E-06
HQ
0.18
0.10
0.75
S-X Pond
Cancer"
3.5E-04
I.4E-06
3.2E-07
3,5E^4
HQ
...
0.02
0.15
a = total cancer risk (oral, external, and inhalation)
Background industrial risk for Ra-226. U-235, and U-238 = 2.0E-04
Uranium-238 values are estimated from a mass value reported for total uranium; ppiu (total uranium) x 0.332 = pCi/mg U-238
— Chemical is not a COPC for these source piles.
-------
Table 17
Summary of Human Health Risks
Future Residential Scenario, Northern Border
Soil COPC
Non-Cancer Risk (HQ)
Cancer Risk
Nickel
Vanadium
.03
Air COPC
Arsenic
Nickel
Non-Cancer Risk
Cancer Risk
1.7E-09
1.2E-08
C-25
-------
Table 18
Summary of Human Health Risks
Future Residential Scenario, Southern Border
Ground Water COPC
Aluminum
Arsenic j':--: - •<.•?'•«. .'-::/:;;;', :;f::;
Barium
Cadmium
Copper
Fluoride
Manganese
Molybdenum
Nickel
Nitrate
Selenium
Silver
Vi, '*v - * ^» - ** -j
c*^Mfa0v - , " - ^>*J"&»^ 3*5$
tm/ "< . : " *:v -j
Tribwyl Riosphaie
Soil COPC
Nickel
Vanadium
U-3t38*D ; '"",',
Non-Oncer Risk (HQ)
(RME) HQ
0.35
0.63
* -I^E^e*
AVG
* = This risk is equivalent to background risks (at concentrations of 0.005 mg/l)
* = The average concentration was less than background: therefore, no average risk calculated.
C-26
-------
Table 18 (Continued)
Summary of Human Health Risks
Future Residential Scenario, Southern Border
Air COPC
Arsenic
Nickel
Demul Exposure
10 Ground Water COPC
TPH
Tributyl Phosphate
Garden Scenario
COPC
Nickel
Vanadium
Uramum-238 + D
Non-Cancer Risk (HQ)
(RME) HQ
(AVG) HQ
Non-Cancer Risk (HQi
(RME) HQ
<.01
<.OJ
(AVG) HQ
t
Non-Cancer Risk (HQ)
(RME) HQ
0.18
0.01
(AVG) HQ
Cancer Risk
1E-07
1 .6E-07
Cancer Risk
Cancer Risk
1.3E-08
C-27
-------
APPENDIX D
ADMINISTRATIVE RECORD INDEX
-------
KERR-McGEE CHEMICAL CORPORATION
ADMINISTRATIVE RECORD
TABLE OF CONTENTS
September 26, 1995
0.0 INDEX/TABLE OF CONTENTS
1.0 SITE IDENTIFICATION
1.1 Correspondence [Reserved]
1.2 Site Inspection Report
1.3 Sampling and Analysis Data
1.4 Hazardous Ranking Score (HRS) Package
2,0 REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS)
2.1 Correspondence
2.2 Work Plan
2.2.1 Comments
2.3 Sampling and Analysis Plan (SAP)
2.4 Health and Safety Plan
2.5 RI/FS Data
2.6 Interim Reports and Technical Memoranda
2.7 Preliminary Site Characterization Report
2.8 Risk Assessment
2.9 Remedial Investigation (RI) Report
2.9.1 Draft RI Report
2.9.2 Correspondence/Comments
2.9.3 Final RI Report
2.9.4 Finch Spring Sediment Characterization Program
2.10 Feasibility Study (FS) and Interim Reports
2.10.1 Correspondence/Comments
2.10.2 Remedial Action Objectives
2.10.3 Development and Screening
2.10.4 Comparative Analysis Report
2.10.5 Feasibility Study
2.10.6 Groundwater Modeling (see 2.10.4 Comparative
Analysis Report Volume 3)
2.10.7 NPDES Application
-------
2.11 Proposed Plan
2.11.1 Comments
3.0 RECORD OF DECISION (ROD)
3.1 Correspondence
3.2 ROD
4.0 STATE COORDINATION
4.1 Correspondence
5.0 ENFORCEMENT
5.1 Correspondence
5.2 Notice Letters and Responses
5.3 Administrative Order on Consent
6.0 HEALTH ASSESSMENTS
6.1 Correspondence [Reserved]
6.2 Preliminary Health Assessment
7.0 NATURAL RESOURCE TRUSTEES
7.1 Correspondence
8.0 PUBLIC PARTICIPATION
8.1 Mailing List
8.2 Community Relations Plan
8.3 Fact Sheet/Press Releases
8.4 Newspaper Articles
8.5 Notices of Availability of Information
9.0 TECHNICAL SOURCES/GUIDANCE DOCUMENTS
9.1 Technical Sources
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 10
1200 Sixth Avenue
Seattle, Washington 98101
ADMINISTRATIVE RECORD INDEX
for
KERR-MCGEE CHEMICAL CORPORATION
SUPERFUND SITE
Soda Springs, Idaho
September 27, 1995
-------
t (KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
HEADING: 1.0. . SITE IDENTIFICATION
|SUB-HEAD: 1. 2. . Site Inspection Report
1. 2. - 0000001
: DATE: 04/01/88 PAGES: 154
! AUTHOR: Unknown /Ecology & Environment, Inc.
ADDRESSEE: John E. Osborn/EPA
DESCRIPTION: Final Site Inspection Report for Kerr McGee Chemical Corporation
i (KMCC) Soda Springs, Idaho
| SUB-HEAD: 1. 3. . Sampling and Analysis Data
1. 3. . - 0000001
DATE: 03/14/87 PAGES: 17
J AUTHOR: Unknown/EPA
ADDRESSEE: Unknown/Unknown .
DESCRIPTION: Analyses required on metals and physical & general inorganics and
ion chromatograph. Also includes seven organics traffic reports
(raw data located at EPA Region 10, Seattle, WA)
1. 3. . - 0000002
DATE: 07/31/87 PAGES: 18
AUTHOR: Mark A. Ader/Ecology & Environment, Inc.
} ADDRESSEE: J. Osborn/EPA
DESCRIPTION: Field Sample Data and Chain of Custody Sheets for samples taken at
Kerr McGee (raw data located at EPA Region 10, Seattle, WA)
1. 3. . - 0000003
DATE: 09/09/87 PAGES: 36
AUTHOR: Patrick McGrath/Ecology & Environment, Inc.
ADDRESSEE: John E. Osborn/EPA
DESCRIPTION: QA of Case 7718 (Organics) Kerr McGee Chemical Company (raw data
located at EPA Region 10, Seattle, WA)
1. 3. - 0000004
DATE: 09/09/87 PAGES: 20
AUTHOR: Patrick McGrath/Ecology & Environment, Inc.
ADDRESSEE: John E. Osborn/EPA
DESCRIPTION: QA of Case 7718 (Organics) Kerr McGee Chemical Company (raw data
located at EPA Region 10, Seattle, WA)
1. 3. - 0000005
DATE: 01/07/88 PAGES: 28
AUTHOR: Unknown/EPA
ADDRESSEE: "Unknown/Unknown
DESCRIPTION: EPA Region X Management system Sample/Project Analysis Results
Kerr-McGee Industries (raw data located at EPA Region 10, Seattle,
WA)
10/19/95 U. S. Environmental Protection Agency, Region 10 Page ]
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
SUB-HEAD: 1. 4. . Hazardous Ranking Score (HRS) Package
1. 4. . - 0000001
DATE: 10/26/88 PAGES: 22
AUTHOR: L. S. Russell/The Mitre Corporation
ADDRESSEE: David Bennett/EPA •
DESCRIPTION: Transmittal letter with attached Hazardous Ranking Score Package
10/19/95 U. S. Environmental Protection Agency, Region 10 Page 2;
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
HEADING: 2. 0. . REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS)
SUB-HEAD: 2.1. . Correspondence
2. 1. - 0000001
DATE: 05/13/91 PAGES: 6
AUTHOR: George W. Condrat/Dames & Moore
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Letter summarizing the proposed methodologies and locations for
seismic geophysical surveys - KMCC, Idaho Facility
2. 1. . - 1035894
DATE: 09/25/91 PAGES: 15
AUTHOR: Christine Psyk/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Letter regarding review of the Source Characterization Memorandum
dated September, 1991
2. 1. . - 1035895
DATE: 10/09/91 PAGES: 3
AUTHOR: Russell H. Jones/Kerr-McGee
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Summary of key points discussed in a teleconference held 10/05/91
2. 1. . - 1035896
DATE: 10/21/91 PAGES: 6
AUTHOR: Christine Psyk/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: EPA comments on the Gamma Survey Plan
2. 1. . - 1035897
DATE: 10/22/91 PAGES: 3
AUTHOR: Christine Psyk/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Letter regarding Enseco and TMA/Eberline Laboratory Quality
Assurance Plans and EPA comments on the Air Modeling Plan
2. 1. . - 1035898
DATE: 10/24/91 PAGES: 4
AUTHOR: Russell H. Jones/Kerr-McGee
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Letter and enclosures related to the Soda Springs RI/FS project
10/19/95 U. S. Environmental Protection Agency, Region 10 Page
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2. 1. . - 1035421
DATE: 12/13/91
AUTHOR
ADDRESSEE
DESCRIPTION
PAGES: 5
Russell H. Jones/Kerr-McGee
Christine Psyk/EPA
Letter stating that Enseco may have exceeded holding times on some
of the parameters being analyzed for the Soda Springs remedial
investigation project (with attachments)
2. 1. . - 1035422
DATE: 01/10/92 PAGES: 2
AUTHOR: Christine Psyk/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Follow up letter to a telephone conference on 01/10/92 regarding
detection limit for Polonium 210
2. 1.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1035423
01/24/92 PAGES: 3
Russell H. Jones/Kerr-McGee
Christine Psyk/EPA
Letter and attached technical memorandum which discusses the
rationale behind the approach used for analysis Po-210 in the
ferrophos
2. 1.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1035424
01/30/92 PAGES: 1
Christine Psyk/EPA
File/EPA
Record of Communication documenting a telephone call with Rick
Poeton of Air Programs on 01/30/92
2. 1. - 1035425
DATE: 03/13/92 PAGES: 2
AUTHOR: Christine Psyk/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Letter regarding review of the preliminary data package submitted
to EPA at a meeting on 02/11/92
2. 1. - 1035426
DATE: 04/07/92 PAGES: 1
AUTHOR: Christine Psyk/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Letter requesting that specified wells be resampled
10/19/95
U. S. Environmental Protection Agency, Region 10
Page
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2. 1. . - 1035427
DATE: 04/30/92 PAGES: 2
AUTHOR: Russell H. Jones/Kerr-McGee
ADDRESSEE: Charles Polityka/DOI
DESCRIPTION: Letter of transmittal for the Preliminary Site Characterization
Report for Phase l, Volumes 1 and 2 (not included).
2. 1. . - 1035428
DATE: 05/07/92 PAGES: 2
AUTHOR: William D. Lough 1 in /Dames & Moore
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Letter regarding revisions to the Phase I Preliminary Site
Characterization Report of 04/24/92
2. 1.
DATE:
AUTHOR:
ADDRESSEE:
IESCRIPTION:
- 1035429
05/07/92 PAGES: 2
Christine Psyk/EPA
Russell H. Jones/Kerr-McGee
EPA comments on the Dames & Moore sample plans for the sampling
round that begins 05/11/92
2. 1.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1035430
05/28/92 PAGES: 13
Christine Psyk/EPA
Russell H. Jones/Kerr-McGee
Letter and attached EPA comments on the Preliminary Site
Characterization Report
2. 1. . - 1035899
DATE: 06/18/92 PAGES: 3
AUTHOR: Christine Psyk/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
)ESCRIPTION: Letter regarding SAIC site visit to Soda Springs on June 23rd and
24th
2. 1. . - 1035431
DATE: 07/07/92 PAGES: 14
AUTHOR: Christine Psyk/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Follow up letter to a telephone conference of 07/02/92 regarding
EPA comments on Kerr-McGee's Phase II Sampling and Analysis Plan
(with attachments)
LO/19/95
U. S. Environmental Protection Agency, Region 10
Page
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2. 1. - 1035432
DATE: 08/11/92 PAGES: 7
AUTHOR: Christine Psyk/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Letter with attachments regarding EPA and IDHW comments on the
Phase II Sampling and Analysis Plan
2. 1. - 1035433
DATE: 09/09/92 PAGES: 2
AUTHOR: Beth Feeley/EPA
Russell H. Jones /Kerr-McGee
Letter providing approval for the August 1992 RI/FS Phase II
Sampling and Analysis Plan
ADDRESSEE
DESCRIPTION
2. 1.
DATE:
AUTHOR:
- 1035900
11/13/92 PAGES: 8
Russell H. Jones/Kerr-McGee
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Response to EPA's request for information regarding outdoor work
practices at the Soda Springs facility and commercial agricultural
production in the vicinity of the site
2. 1.
DATE:
AUTHOR:
- 1035901
01/29/93 PAGES: 3
Russell H. Jones/Kerr-McGee
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Summary of Kerr-McGee Chemical Corporation's comments on the
Preliminary Ecological Evaluation Report
2. 1. . - 1035902
DATE: 06/08/93 PAGES: 10
AUTHOR: Russell H. Jones/Kerr-McGee
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Letter and attached comments on SAIC's Preliminary Draft Human
Health Risk Assessment
2. 1. - 1035904
DATE: 09/15/93 PAGES: 1
AUTHOR: Timothy H. Brincefield/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Letter of transmittal for the Draft Human Health and Ecological
Risk Assessments (filed as document number 2.8-1035461)
10/19/95
U. S. Environmental Protection Agency, Region 10
Page
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2. 1. . - 1035903
DATE: 10/11/93 PAGES: 2
AUTHOR: Carol Sweeney/EPA
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Memo regarding comments on revised Risk Assessment for Kerr-McGee
Chemical Corp. Site
2. 1.
DATE
AUTHOR
ADDRESSEE
DESCRIPTION:
- 1035905 . '
: 10/22/93 PAGES: 2
: Timothy H. Brincefield/EPA
: Russell H. Jones/Kerr-McGee
: letter regarding Kerr-McGee Soda Springs Facility Risk Assessments
and RI/FS Schedule
2. 1. . - 1035906
DATE: 09/29/94 PAGES: 3
AUTHOR: Timothy H. Brincefield/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Fax memo and attachments regarding the table of potential effluent
limitations consistent with NPDES requirements
2. 1. . - 1035908
DATE: 03/27/95 PAGES: 2
AUTHOR: Russell H. Jones/Kerr-McGee
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Response letter regarding changes to be made to the Remedial
Investigation Report dated 12/17/93
2. 1. - 1035909
DATE: 04/20/95 PAGES: 1
AUTHOR: Peter Contreras/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Approval of the Draft Sampling Plan for Finch Spring
2. 1.
DATE
AUTHOR
ADDRESSEE
DESCRIPTION
- 1040466
; 07/11/95 PAGES: 4
; Peter Contreras/EPA
: Scott Sprague/Kerr-^McGee
: Letter to document telephone conversation of 06/29/95 regarding the
upcoming Record of Decision anticipated for the summer and the
current status of Kerr-McGee's.process changes
2. 1. . - 1040467
DATE: 07/17/95 PAGES: 2
AUTHOR:"Scott B. Sprague/Kerr-McGee
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Letter regarding schedule for implementing process changes
10/19/95
U. S. Environmental Protection Agency, Region 10
Page
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2. 1. - 1040468
DATE: 08/23/95 PAGES: 2
AUTHOR: Scott B. Sprague/Kerr-McGee
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Letter regarding schedule for implementing process changes
SUB-HEAD: 2. 2.
Work Plan
2. 2. . - 0000001
DATE: 08/01/91 PAGES: 171
AUTHOR: Unknown/James M. Montgomery Consulting Engineers, Inc.
ADDRESSEE: Unknown/KMCC
DESCRIPTION: Remedial Investigation/Feasibility Study Work Plan Kerr-McGee
Chemical Corporation Soda Springs, Idaho (RI/FS Project Plans
Volume 1 of 2. See AR 2.3 0001 for Volume 2).
2. 2. - 1035439
DATE: 09/13/91 PAGES: 1
AUTHOR: Russell H. Jones/Kerr-McGee
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Letter to clarify a point in the Radibnuclide section of the Source
Chracterization Memorandum submitted on 09/04/91
SUB-HEAD:
2. 1.
Comments
2. 2. 1. - 0000001
DATE: 01/16/91 PAGES: 16
AUTHOR: John Meyer/EPA
Russell H. Jones/Kerr-McGee
Comments on draft RI/FS Work Plan and draft Sampling and Analysis
Plan for Kerr-McGee Soda Springs facility
ADDRESSEE
DESCRIPTION
2. 2. 1.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 0000002
04/19/91 PAGES: 26
John Meyer/EPA
Russell H. Jones/Kerr-McGee
Transmittal of EPA Comments on the Kerr-McGee RI/FS Work Plan for
the Soda Springs Facility, March 1991
2. 2. i.
DATE
AUTHOR
ADDRESSEE
DESCRIPTION
- 0000003
; 05/14/91 PAGES: 8
: Russell H. Jones/KMCC
; Christine Psyk/EPA
; Record of Understanding Kerr-McGee Chemical Corporation Soda
Springs RI/FS Project Plans
10/19/95
U. S. Environmental Protection Agency, Region 10
Page
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2. 2. 1. - 0000004
DATE: 05/15/91 PAGES: 3
AUTHOR: Christine Psyk/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Summary of differences in EPA's understanding of how RI/FS Work
Plan issues were resolved
2. 2. 1. - 0000005
DATE: 05/15/91 PAGES: 4
AUTHOR: Russell H. Jones/KMCC
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Letter submitted to record telephone conversation between EPA and
KMCC on 5/9/91 regarding clarification of EPA comments on the Soda
Springs RI/FS Work Plan dated 4/19/91
2. 2. 1.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 0000006
05/16/91 PAGES: 3
Christine Psyk/EPA
Russell H. Jones/Kerr-McGee
Notice that although EPA and KMCC are in .agreement on the majority
of comments on the KMCC RI/FS Work Plan, further clarification of
differences in understanding is provided
2. 2. 1.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 0000007
05/21/91 PAGES: 15
Russell H. Jones/KMCC
Christine Psyk/EPA
Cover letter and attached summary prepared by Dames & Moore which
responds point by point to the comments contained in EPA's 4/19/91
letter
2. 2. 1.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 0000008
07/03/91 PAGES: 13 '
Christine Psyk/EPA
Russell H. Jones/Kerr-McGee •
EPA Comments on and Direction for Revising the RI/FS Work Plan for
the Kerr-McGee Superfund Site in Soda Springs
2. 2. 1. - 0000009
DATE: 08/02/91 PAGES: 6
AUTHOR: George W. Condrat/Dames & Moore
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: August, 1991 Work Plan Revision
Soda Springs RI/FS
Response to EPA Comments- KMCC
10/19/95
U. S. Environmental Protection Agency, Region 10
Page
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2. 2. 1. - 0000010
DATE: 08/08/91 PAGES: 2
AUTHOR: Christine Psyk/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Letter regarding a few minor adjustments to the KMCC August 1991
page revisions to the RI/FS Work Plan
SUB-HEAD: 2. 3. . Sampling and Analysis Plan (SAP)
2. 3. - 0000001
DATE: 08/01/91 PAGES: 545
AUTHOR: Unknown/James M. Montgomery Consulting Engineers, Inc.
ADDRESSEE: Unknown/KMCC
DESCRIPTION: RI/FS Sampling and Analysis Plan (RI/FS Project Plans Volume 2 of
2. See AR 2.2 0001 for Volume 1)
2. 3. . - 1035445
DATE: 09/18/91 PAGES: 15
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Air Modeling Plan for Kerr-McGee Chemical Corporation RI/FS
2. 3. . - 1035892
DATE: 10/21/91 PAGES: 1
AUTHOR: Donald Matheny/EPA
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Memo regarding review of Laboratory Quality Assurance Project Plan
for Kerr-McGee Chemical Corporation RI/FS Soda Springs, Id,
10/03/91, Enseco, Inc.
2. 3. - 1035893
DATE: 10/22/91 PAGES: 5
AUTHOR: Unknown/Unknown
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Enseco Product Summary; Extractable Petroleum Hydrocarbons by
GC/FID
2. 3. - 1035446
DATE: 04/28/92 PAGES: 12
AUTHOR: William D. Loughlin/Dames & Moore
ADDRESSEE: Russell H. Jones/Kerr-McGee .
DESCRIPTION: Letter and attached proposed sample collection and analysis plan
for the May 1992 sample round
10/19/95 U. S. Environmental Protection Agency, Region 10 Page
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2. 3. - 1035447
DATE: 05/05/92 PAGES: 12
AUTHOR: Russell H. Jones/Kerr-McGee
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Letter and attached revised sampling plan for the May llth sampling
event at the Soda Springs facility
2. 3. . - 1035448
DATE: 08/26/92 PAGES: 72
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: August 1992 RI/FS Phase II Sampling and Analysis Plan
SUB-HEAD: 2. 4. . Health and Safety Plan
2. 4. - 0000001
DATE: 10/01/90 PAGES: 71
AUTHOR: John G. Danby/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Health and Safety Plan Remedial Investigation Kerr-McGee Chemical
Corporation Soda Springs, Idaho
SUB-HEAD: 2. 5. . RI/FS Data
2. 5. - 1035449
DATE: 01/08/92 PAGES: 14
AUTHOR: Donald Matheny/EPA
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Memo and attached data validation report of fluoride analysis
2. 5. . - 1035450
DATE: 01/24/92 PAGES: 26
AUTHOR: Donald Matheny/EPA
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Memo and attached inorganic data validation report
2. 5. . - 1035451
DATE: 06/17/92 PAGES: 9
AUTHOR: J. Blazevich/EPA
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Report of data validation of BNA's for the Kerr-McGee Chemical
Company project
LO/19/95 U. S. Environmental Protection Agency, Region 10 Page 11
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2. 5. - 1035452
DATE: 06/26/92 PAGES: 16
AUTHOR: Donald Matheny/EPA
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Memo and attached data validation report of volatile organic
analysis of samples
2. 5. . - 1035453
DATE: 06/30/92 PAGES: 9
AUTHOR: J. Blazevich/EPA
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Report of data validation of BNA's for the Kerr-McGee Chemical
Company project
2. 5. - 1035454
DATE: 07/06/92 PAGES: 27
AUTHOR: Donald Matheny/EPA
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Memo and attached data validation report of inorganic analyses of
samples
2. 5. . - 1035455
DATE: 07/06/92 PAGES: 13
AUTHOR: Katherine York/CSC
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Memo and attached corrected data report for Kerr McGee
SUB-HEAD: 2.6. . Interim Reports and Technical Memoranda
2. 6. . - 1035456
DATE: 09/01/91 PAGES: 132
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Kerr-McGee
DESCRIPTION: Source Characterization Memorandum for Kerr-McGee Soda Springs
RI/FS
2. 6. . - 1035457
DATE: 09/18/91 PAGES: 21
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Off-Site Ground Water and Surface Water Sampling Memorandum for
Kerr-McGee Chemical Corporation RI/FS
10/19/95 U. S. Environmental Protection Agency, Region 10 Page
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2. 6. - 1035458
DATE: 11/20/92 PAGES: 250
AUTHOR: Unknown/Danes & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Final Air Pathway Analysis Report for Kerr-McGee Chemical
Corporation
SUB-HEAD: 2. 7. . Preliminary Site Characterization Rep'ort
2. 7. . - 1035459
DATE: 04/24/92 PAGES: 250
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Preliminary Site Characterization Report for Phase I at Soda
Springs, Idaho Facility; RI/FS Phase I Report Volume 1 of 2 Report
Text
2. 7. - 1035460
DATE: 04/24/92 PAGES: 500
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Preliminary Site Characterization Report for Phase I at Soda
Springs, Idaho Facility; RI/FS Phase I Report Volume 2 of 2
Appendices
SUB-HEAD: 2. 8. . Risk Assessment
2. 8. - 1035462
DATE: 03/05/92 PAGES: 5
AUTHOR: Gary Pascoe/Environmental Toxicology International
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Memorandum regarding proposed exposure scenarios
2. 8. - 1035461
DATE: 10/01/93 PAGES: 193
AUTHOR: Unknown/Science Applications International Corporation
ADDRESSEE: Unknown/EPA
DESCRIPTION: Draft Human Health and Ecological Risk Assessments for Kerr-McGee
Chemical corporation
SUB-HEAD: 2. 9. 1. Draft RI Report
2. 9. 1. - 1040255
DATE: 11/01/93 PAGES: 250
AUTHOR: Unknown/Dames & Moore
ADDRESSEE:" Unknown/Unknown
DESCRIPTION: Draft Remedial Investigation Report Volume 1 of 4 Main Text
10/19/95 U. S. Environmental Protection Agency, Region 10 Page 13
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2. 9. 1. - 1040256
DATE: 11/01/93 PAGES: 500
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Draft Remedial Investigation Report Volume 2 of 4 Appendices
2. 9. 1. - 1040257
DATE: 11/01/93 PAGES: 200
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
•DESCRIPTION: Draft Remedial Investigation Report Volume 3 of 4 Appendices
2. 9. 1. - 1040258
DATE: 11/01/93 PAGES: 20
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Draft Remedial Investigation Report Volume 4 of 4 Attachments
SUB-HEAD: 2. 9. 2. Correspondence/Comments
2. 9. 2. - 1035934
DATE: 11/09/93 PAGES: 1
AUTHOR: James C. Eldridge/Science Applications International Corporation
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Comments on Round 6 Proposed Ground Water Sampling
2. 9. 2. - 1035935
DATE: 01/28/94 PAGES: 1
AUTHOR: Donald Matheny/EPA
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Comments on the Draft Remedial Investigation Report
2. 9. 2. - 1035936
DATE: 01/28/94 PAGES: 4
AUTHOR: Lorraine Edmond/EPA
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Comments on the Draft Remedial Investigation Report
2. 9. 2. - 1035937
DATE: 02/02/94 PAGES: 1
AUTHOR: Joe Goulet/EPA
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Comments on the Draft Remedial Investigation Report
10/19/95 U. S. Environmental Protection Agency, Region 10 Page 14
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2. 9. 2. - 1035938
DATE: 02/02/94 PAGES: 15
I AUTHOR: Andrew Hafferty/Ecology & Environment, Inc.
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Comments on the Draft Remedial Investigation Report
2. 9. 2. - 1035939
DATE: 02/07/94 PAGES: 2
AUTHOR: James C. Eldridge/Science Applications International Corporation
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Response to US Fish and Wildlife Service Comments on the Draft
Remedial Investigation Report
2. 9. 2. - 1035940
"' DATE: 06/13/94 PAGES: 14
AUTHOR: Timothy H. Brincefield/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: EPA comments on the Draft Remedial Investigation Report
2. 9. 2. - 1035941
DATE: 07/12/94 PAGES: 36
AUTHOR: Russell H. Jones/Kerr-McGee
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Response to EPA's comments on the Draft Remedial Investigation
Report
2. 9. 2. - 1035942
DATE: 01/26/95 PAGES: 3
AUTHOR: Timothy H. Brincefield/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Letter addressing outstanding issues and comments with respect to
the Draft Remedial Investigation Report
2. 9. 2. - 1035987
DATE: 05/18/95 PAGES: 3
AUTHOR: Raymond Wayne/Ecology & Environment, Inc.
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Modem transmission of comments on the Final Remedial Investigation
Report
SUB-HEAD: 2. 9. 3. Final RI Report
2. 9. 3. - 1040251
DATE: 04/25/95 PAGES: 500
AUTHOR:"Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Final Remedial Investigation Report Volume 1 of 4 Main Text
10/19/95 U. S. Environmental Protection Agency, Region 10 Page 15
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2. 9. 3. - 1040252
DATE: 04/25/95 PAGES: 800
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Final Remedial Investigation Report Volume 2 of 4 Appendices A-B
2. 9. 3. - 1040253
DATE: 04/25/95 PAGES: 250
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Final Remedial Investigation Report Volume 3 of 4 Appendices C-D
2. 9. 3. - 1040254
DATE: 04/25/95 PAGES: 500
AUTHOR: Unknown /Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Final Remedial Investigation Report Volume 4 of 4 Attachments 1-2
SUB-HEAD: 2. 9. 4.
Finch Spring Sediment Characterization Program
2. 9. 4. - 1035944
DATE: 08/12/94 PAGES: 15
AUTHOR: Russell H. Jones/Kerr-McGee
Timothy H. Brincefield/EPA
Letter and attached report titled Evaluation of the US Fish and
Wildlife Service Recommendation for Further Environmental .Sampling
at Finch and Big Springs
ADDRESSEE
DESCRIPTION
2. 9. 4.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1035945
09/26/94 PAGES: 22
Russell H. Jones/Kerr-McGee
Timothy H. Brincefield/EPA
Letter and revised report titled Evaluation of the US Fish and
Wildlife Service Recommendation for Further Environmental Sampling
at Finch and Big Springs
2. 9. 4.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1035946
11/11/94 PAGES: 2
Bill/Dames & Moore
Peter Contreras/EPA
Fax message and attached calculation sheet for Theoretical Hazards
of Ingesting Sediment from Finch Pond to Mallard Ducks
10/19/95
U. S. Environmental Protection Agency, Region 10
Page
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
* 2. 9. 4. - 1035947
DATE: 11/22/94 PAGES: 3
t AUTHOR: Rone A. Brewer/Ecology & Environment, Inc.
] ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Modem .transmission of the notes from the conference call regarding
the need for further sampling at Finch Spring
.2. 9. 4. - 1035948
j DATE: 11/30/94 PAGES: 2
\ AUTHOR: Russell H. Jones/Kerr-McGee
ADDRESSEE: Peter Contreras/EPA '
t DESCRIPTION: Letter regarding the need for sediment sammpling in Finch Pond
i
2. 9. 4. - 1035949
{ DATE: 12/06/94 PAGES: 2
AUTHOR: Rone A. Brewer/Ecology & Environment, Inc.
ADDRESSEE: Peter Contreras/EPA
. DESCRIPTION: Modem transmission to comment on the waterfowl sediment ingestion
• risk assessment notes provided to EPA by Dames & Moore for
Kerr-McGee Chemical Corporation
2. 9. 4. - 1035907
DATE: 12/28/94 PAGES: 2
j AUTHOR: Peter Contreras/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Letter regarding Finch Spring sediment sampling
2. 9. 4. - 1035951
DATE: 01/20/95 PAGES: 2
j AUTHOR: Russell H. Jones/Kerr-McGee
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Letter and attached outline of the Approach to Sediment
Characterization at Finch Pond
2. 9. 4. - 1035952
; DATE: 02/01/95 PAGES: 1
AUTHOR: Joe Goulet/EPA
ADDRESSEE: Peter Contreras/EPA
: DESCRIPTION: Comments on the Approach to Sediment Characterization at Finch Pond
. 2. 9. 4. - 1035953
: DATE: 02/06/95 PAGES: 3
AUTHOR: Rone A. Brewer/Ecology & Environment, Inc.
ADDRESSEE: Peter Contreras/EPA
; DESCRIPTION:'Modem transmission to comment on the proposed Approach to Sediment
Characterization at Finch Pond
10/19/95 U. ,S. Environmental Protection Agency, Region 10 Page 17
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2. 9. 4. - 1035954
DATE: 02/17/95 PAGES: 2
AUTHOR: Andrew Hafferty/Ecology & Environment, Inc.
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Modem transmission to document the teleconference on the PRP's
proposed Approach to Sediment Characterization at Finch Pond
2. 9. 4. - 1035955
DATE: 03/30/95 PAGES: 32
. AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Draft Sample Collection and Analysis Plan for Finch Pond Sediment
Characterization Program for Kerr-McGee Soda Springs, Idaho RI/FS
2. 9. 4. - 1035956
DATE: 04/06/95 PAGES: 3
AUTHOR: Rone A. Brewer/Ecology & Environment, Inc.
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Modem transmission to provide review and comment on the Draft
Sample Collection and Analysis Plan for Finch Pond Sediment
Characterization Program
2. 9. 4. - 1035957
DATE: 04/12/95 PAGES: 1
AUTHOR: Donald Matheny/EPA
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Memo with comments on the draft Field Operations Work Plan for
Oversight at Finch Pond Soda Spring ID
2. 9. 4. - 1035958
DATE: 04/19/95 PAGES: 12
AUTHOR: Andrew Hafferty/Ecology & Environment, Inc.
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Letter and attached Final Work Plan for Field Oversight at the
Kerr-McGee/Finch Spring Site
2. 9. 4. - 1035959
DATE: 04/20/95
AUTHOR:
ADDRESSEE:
PAGES: 1
Peter Contreras/EPA
Russell H. Jones/Kerr-McGee
DESCRIPTION: Approval of the Draft Sample Collection and Analysis Plan, Finch
Pond Sediment Characterization Program for Kerr-McGee Soda Springs
Idaho RI/FS
10/19/95
U. S. Environmental Protection Agency, Region 10
Page
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2. 9. 4. - 1040469
DATE: 06/01/95 PAGES: 21
AUTHOR: Unknown/Ecology & Environment, Inc.
ADDRESSEE: Unknown/EPA
DESCRIPTION: Trip Report for Field Oversight at the Kerr-McGee/Finch Spring Site
in Soda Springs, Idaho
2. 9. 4.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1040470
06/09/95 PAGES: 30
Maricia M. Alforgue/EPA
Peter Contreras/EPA
Quality assurance review of the analysis for aluminum, molybdenum,
and vanadium of twenty soil samples from the Kerr-McGee/Finch
Spring site
I-
2. 9.
I
4. - 1040471
DATE: 06/16/95 PAGES: 1
AUTHOR: Andrew Hafferty/Ecology & Environment, Inc.
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Letter of transmittal for Trip Report for Field Oversight of PRP
Sampling of Finch Spring sediments and nearby soils (report is
filed as document number 2.9.4-1040469)
| 2. 9. 4.
1 DATE:
AUTHOR:
. ADDRESSEE:
! DESCRIPTION:
- 1040472
07/24/95 PAGES: 66
Russell H. Jones/Kerr-McGee
Peter Contreras/EPA
Letter and attached statistical analysis of the Finch pond sampling
results
2. 9. 4.
- 1040473
DATE: 07/27/95 PAGES: 1
AUTHOR: Andrew Hafferty/Ecology & Environment, Inc.
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Modem transmission regarding preliminary evaluation of findings
presented in the 07/24/95 Kerr-McGee Statistical Analysis of Finch
Pond Sampling Results
2. 9. 4. - 1040474
DATE: 08/16/95 PAGES: 1
AUTHOR: Andrew Hafferty/Ecology & Environment, Inc.
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Modem transmission regarding data validation summary check
10/19/95
U. S. Environmental Protection Agency, Region 10
Page 19
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(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2. 9. 4. - 1040475
DATE: 08/16/95 PAGES: 1
AUTHOR: Andrew Hafferty/ Ecology & Environment, Inc.
ADDRESSEE: Peter Contreras/EPA
Modem transmission regarding preliminary evaluation of findings
presented in the 07/24/95 Kerr-McGee Statistical Analysis of Finch
Pond Sampling Results
DESCRIPTION:
2. 9. 4. - 1040476
DATE: 08/18/95 PAGES: 6
AUTHOR: Rone A. Brewer /Ecology & Environment, Inc.
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Modem transmission to compare the data obtained for the EPA during
oversight procedures with data obtained by the PRPs during sediment
sampling at Finch Spring/Pond in Soda Springs, Idaho
2. 9. 4.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1040477
08/18/95 PAGES: 2
Rone A. Brewer/Ecology & Environment, Inc.
Peter Contreras/EPA
Modem transmission to review the ecological assessment for Finch
Spring using the recent sediment sampling data (KMCC 1995) for
aluminum, molybdenum, and vanadium
2. 9. 4.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1040478
08/24/95 PAGES: 1
Peter Contreras/EPA
Susan Burch/U. S. Fish & Wildlife Service
Letter regarding results of Kerr-McGee's sediment sampling
activities at Finch pond conducted the week of 05/15/95 (enslosure
not attached)
2. 9. 4. - 1040479 . '
DATE: 09/20/95 PAGES: 2
AUTHOR: Peter Contreras/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Letter stating that based on EPA's review of information provided
by Kerr-McGee, EPA is not planning further actions to characterize
ecological effects at Finch Pond stemming from releases at the
Kerr-McGee Superfund site
SUB-HEAD: 2.10. 1.
Correspondence/Comments
2.10. 1. - 1035960
DATE: 11/23/93 PAGES: 5
AUTHOR:^Russell H. Jones/Kerr-McGee
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Letter and attached Remedial Action Objectives Memorandum
10/19/95
U. S. Environmental Protection Agency, Region 10
Page
20;.
>
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2.10. 1. - 1035961
DATE: 12/14/93 PAGES: 2
AUTHOR: Carol Sweeney/EPA
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Comments on Remedial Action Objectives Memorandum
2.10. 1. - 1035962
DATE: 12/20/93 PAGES: 1
AUTHOR: Andrew Hafferty/Ecology & Environment, Inc.
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Comment on the Remedial Action Objectives Memorandum
2.10. 1.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1035963
01/06/94 PAGES: 8
Andrew Hafferty/Ecology & Environment, Inc.
Timothy H. Brincefield/EPA
Letter and attached comments on the Development and Screening
Alternatives Memorandum
2.10. 1. - 1035964
DATE: 01/06/94 PAGES: 9
AUTHOR: James C. Eldridge/Science Applications International Corporation
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Comments on the Remedial Action Objectives Memorandum and the
Development and Screening Alternatives Memorandum
2.10. 1. - 1035965
DATE: 01/07/94 PAGES: 2
AUTHOR: Lorraine Edmond/EPA
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Memo regarding comments on the Screening Alternatives Memorandum
2.10. 1.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1035927
01/17/94 PAGES: 2
Ray Wayne/Ecology & Environment, Inc.
Timothy H. Brincefield/EPA
Comments on EPA memoranda on the PRP's proposed approach to
groundwater modeling at Kerr-McGee
2.10. 1. - 1035967
DATE: 02/10/94 PAGES: 4
AUTHOR: James C. Eldridge/Science Applications International Corporation
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Revised comments on Development and Screening Alternatives
""Memorandum
10/19/95
U. S. Environmental Protection Agency, Region 10
Page
21
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2.10. 1. - 1035968
DATE: 03/24/94 PAGES: 4
AUTHOR: Lorraine Edmond/EPA
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Comments on Ground Water Modeling Plan
2.10. 1. - 1035969
DATE: 04/06/94 PAGES: 11
AUTHOR: Russell H. Jones/Kerr-McGee
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Response to comments on the draft Ground Water Modeling Plan
2.10. 1. - 1035970
DATE: 06/17/94 PAGES: 6
AUTHOR: Timothy H. Brincefield/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Comments on Remedial Action Objectives and Development of "Screening
Alternatives Memoranda
2.10. 1. - 1035971
DATE: 07/06/94 PAGES: 4
AUTHOR: Russell H. Jones/Kerr-McGee
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Response to EPA comments providing additional information on
adsorption coefficient values to be used in the modeling effort
2.10. 1.
- 1035972
DATE: 07/OS/94 PAGES: 1
AUTHOR: Timothy H. Brincefield/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee ;
DESCRIPTION: Letter granting extension for submission of the revised Remedial
Action Objectives Memorandum and the Development and Screening
Alternatives Memorandum
2.10. 1. ' - 1035974 ' ;
DATE: 10/26/94 PAGES: 12 1
AUTHOR: Timothy H. Brincefield/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Letter and comments on revised Development and Screening Memorandum •
2.10. 1. - 1035975
DATE: 11/02/94 PAGES: 3 '
AUTHOR: Lorraine Edmond/EPA
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION:'"Comments on the draft interim Ground Water Modeling Report
10/19/95
U. S. Environmental Protection Agency, Region 10
Page 22 .
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
4
2.10. 1. - 1035977
DATE: 11/07/94 PAGES: 2
5 AUTHOR: David Anderson/Ecology & Environment, Inc.
: ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Modem transmission regarding comments on the draft Interim Ground
, Water Modeling Report
2.10. 1. - 1035976
DATE: 11/14/94 PAGES: 4
AUTHOR: Peter Contreras/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Letter and attached comments on the draft Interim Groundwater
Modeling Report
2.10. 1. - 1040183
DATE: 12/21/94 PAGES: 5
AUTHOR: Timothy H. Brincefield/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Letter and approval of the Draft Final Development and Screening
Alternatives Memorandum dated 11/15/94
2.10. 1. - 1035979
DATE: 01/23/95 PAGES: 10
AUTHOR: Unknown/State of Idaho
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Handwritten transmittal page from Gordon Brown with attached KMCC
Raffinate Evaporation Pond information
2.10. 1.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1035980
02/01/95 PAGES: 2
Russell H. Jones/Kerr-McGee
Peter Contreras/EPA
Fax cover sheet and attached letter requesting an extension to the
submittal deadline for the Comparative Analysis Report
2.10. l.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1035981
02/02/95 PAGES: 3
Russell H. Jones/Kerr-McGee
Peter Contreras/EPA
Fax cover sheet with attached letter and proposed agenda for the
meeting on 02/07/95 between Kerr-McGee Chemical Corporation and EPA
2.10. 1. - 1035982
DATE: 02/03/95 PAGES: 1
AUTHOR^Peter Contreras/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Letter granting an extension of the submittal due date for the
Comparative Analysis Report
10/19/95
U. S. Environmental Protection Agency, Region 10
Page
23
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2.10. 1. - 1035983
DATE: 02/17/95 PAGES: 3
AUTHOR: Scott B. Sprague/Kerr-McGee
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Letter describing the plant process changes that Kerr-McGee
Chemical Corporation is planning to implement in order to become a
zero discharge facility
2.10. 1.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1040262
02/24/95 PAGES: 2
David Anderson/Ecology & Environment, Inc.
Peter Contreras/EPA
Modem transmission to comment on the Revised Draft Groundwater
Modeling Report and Volume 3 of the Comparative Analysis for
Kerr-McGee Superfund site
2.10. 1. - 1035984
DATE: 02/27/95 PAGES: 2
AUTHOR: Lorraine Edmond/EPA
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Memo regarding comments on the draft Comparative Analysis Report
2.10. 1. - 1040261
DATE: 03/15/95 PAGES: 4
AUTHOR: Andrew Hafferty/Ecology & Environment, Inc.
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Modem transmission to document the EPA/PRP meeting that took place
on 03/01/95
2.10. 1. - 1040260
DATE: 03/31/95 PAGES: 17
AUTHOR: John Chen/Ecology & Environment, Inc.
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Modem transmission to provide Revised Final Review and Comment on
the Draft Comparative Analysis Report
2.10. 1. - 1035985
DATE: 04/04/95 PAGES: 22
AUTHOR: Peter Contreras/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Letter and attached comments on the draft Comparative Analysis
Report
10/19/95
U. S. Environmental Protection Agency, Region 10
Page.
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2.10. 1. - 1035986
DATE: 04/20/95 PAGES: 2
AUTHOR: Peter Contreras/EPA
ADDRESSEE: Russell H. Jones/Kerr-McGee
DESCRIPTION: Approval of the request for extension to Feasibility Study
submittal
2.10. 1. - 1040259
DATE: 06/30/95 PAGES: 15
AUTHOR: Peter Contreras/EPA
ADDRESSEE: Scott Sprague/Kerr-McGee
DESCRIPTION: Transmittal letter with attachments and comments on the Draft
Comparative Analysis Report
SUB-HEAD: 2.10. 2. Remedial Action Objectives
2.10. 2. - 1035988
DATE: 08/05/94 PAGES: 16
AUTHOR: Scott B. Sprague/Kerr-McGee
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Letter and attached revised Remedial Action Objectives Memorandum
and response to comments provided by EPA
SUB-HEAD: 2.10. 3. Development and Screening
2.10. 3. - 1035989
DATE: 12/01/93 PAGES: 72
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Development and Screening Alternatives Memorandum
2.10. 3. - 1035990
DATE: 11/01/94 PAGES: 113
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Draft Final Development and Screening Alternatives Memorandum
2.10. 3. - 1035991
DATE: 12/06/94 PAGES: 13
AUTHOR: Scott B. Sprague/Kerr-McGee
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Letter and attachments regarding refinement of alternatives for
detailed analysis ' .
SUB-HEAD: 2^10. 4. Comparative Analysis Report
10/19/95 U. S. Environmental Protection Agency, Region 10 Page 25
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2.10. 4. - 1035992
DATE: 02/15/95 PAGES: 250
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Draft Comparative Analysis Report Volume 1 of 3 Main Text
2.10. 4. - 1035993
DATE: 02/15/95 PAGES: 250
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Draft Comparative Analysis Report Volume 2 of 3 Appendices
2.10. 4. - 1035994
DATE: 02/15/95 PAGES: 450
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Draft Comparative Analysis Report Volume 3 of 3 Revised Draft
Ground Water Modeling Report
SUB-HEAD: 2.10. 5. Feasibility Study
2.10. 5.. - 1040263
DATE: 06/01/95 PAGES: 350
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Draft Feasibility Study Report Volume 1 of 2 Main Text
2.10. 5. - 1040264
DATE: 06/01/95 PAGES: 250
AUTHOR: Unknown/Dames & Moore
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Draft Feasibility Study Report Volume .2 of 2 Appendices
SUB-HEAD: 2.10. 7. NPDES Application
2.10. 7. - 1036000
DATE: 07/13/93 PAGES: 75
AUTHOR: Scott B. Sprague/Kerr-McGee
ADDRESSEE: Cindi Hamiel/EPA
DESCRIPTION: Letter and attached NPDES Permit Application for the Kerr-McGee
Chemical Corporation Soda Springs Vanadium Facility
2.10. 7. - 1035999
DATE: 06/16/94 PAGES: 1
AUTHOR:"Scott B. Sprague/Kerr-McGee
ADDRESSEE: Cindi Godsey/EPA
DESCRIPTION: Letter regarding harmonic mean flow for the Bear River
10/19/95 U. S. Environmental Protection Agency, Region 10 Page 26 ,
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
2.10. 7. - 1035997
DATE: 01/10/95 PAGES: 3
AUTHOR: Russell H. Jones/Kerr-McGee
ADDRESSEE: Gordon Brown/State of Idaho
DESCRIPTION: Letter regarding intention to meet with the State to discuss issues
relating to the proposed waste water discharges from the Soda
Springs facility
SUB-HEAD: 2.11.
Proposed Plan
2.11. . - 1040369
DATE: 08/01/95 PAGES: 11
AUTHOR: Unknown/EPA
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Proposed Plan for Kerr-McGee Superfund Site
SUB-HEAD: 2.11. 1.
Comments
2.11. 1. - 1040480
DATE: 08/07/95 PAGES: 1
AUTHOR: Ralph R. Reeves/Unknown
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Letter commenting on the Proposed Plan and stating that Alternative
9 appears to provide a way of reaching the goal of clean ground
water at the least cost
10/19/95
U. S. Environmental Protection Agency, Region 10
Page 27
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
HEADING: 3. 0. . RECORD OF DECISION (ROD)
SUB-HEAD: 3. 2. . ROD
3. 2. - 1040465
DATE: 09/28/95 PAGES: 129
AUTHOR: Chuck Clarke/EPA
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Record of Decision for Kerr-McGee Superfund Site, Caribou County,
Idaho
10/19/95 U. S. Environmental Protection Agency, Region 10 Page
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
HEADING: 4. 0. . STATE COORDINATION
SUB-HEAD: 4. 1. . Correspondence
4. 1. . - 1035434
DATE: 12/24/91 PAGES: 1
AUTHOR: Gordon Brown/Idaho Department of Health and Welfare
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Letter to confirm telephone conversation of 12/23/91 and to respond
to request for information regarding Idaho Solid Haste Regulations
4. 1. - 1035435
DATE: 06/17/92 PAGES: 2
AUTHOR: Christine Psyk/EPA
Gordon Brown/IDHW .
Formal request to the state to identify applicable or relevant and
appropriate requirements (ARARs) or other requirements to be
considered (TBCs) in evaluating potential cleanup measures
ADDRESSEE
DESCRIPTION
4. 1. - 1035436
DATE: 07/07/92 PAGES: 1
AUTHOR: Christine Psyk/EPA
ADDRESSEE: Gordon Brown/IDHW
DESCRIPTION: Letter regarding the issue of secular equilibrium, Po-210 detection
limits for the ferrophosphorus
4. 1. . - 1035437
DATE: 08/03/92 PAGES: 5
AUTHOR: Rob Hanson/I
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
4. 1. .. - 1035913
DATE: 12/17/93 PAGES: 1
AUTHOR: Gordon Brown/State of Idaho
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Comments on the Remedial Action Objectives Memorandum
4. 1. .
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1035914
01/13/94 PAGES: 1
Cecil D. Andrus/State of Idaho
Timothy H. Brincefield/EPA
Letter stating no objection to the major conclusions and
recommendations of the draft Remedial Investigation Report
4. 1. - 1035915
DATE: 02/23/94 PAGES: 1
AUTHOR: Gordon Brown/State of Idaho
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Comment on the Kerr McGee Ground Water Modeling Plan
4. 1. - 1035916
DATE: 06/27/94 PAGES: 5
AUTHOR: Gordon Brown/State of Idaho
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Letter and enclosures regarding current status of the Kerr McGee
permit to construct and modify the air operating parameters at the
site
4. 1. . - 1035917
DATE: 10/31/94 PAGES: 2
AUTHOR: Gordon Brown/State of Idaho
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Letter regarding the Kerr McGee Chemical Corp. NPDES Application
4. 1. - 1035918
DATE: 12/15/94 PAGES: 1
AUTHOR: Gordon Brown/State of Idaho
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Comments on the Refinement of Alternatives for Detailed Analysis
Document
4. 1. . - 1035919
DATE: 03/10/95 PAGES: 1
AUTHOR: Gordon Brown/State of Idaho
ADDRESSEE: Peter Contreras/EPA
DESCRIPTIONf"Letter regarding comments on the Comparative Analysis Report that {
were given directly to Bill McLoughlin during a meeting on 03/01/96
10/19/95
U. S. Environmental Protection Agency, Region 10
Page 3 .
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
4. 1. . - 1035920
DATE: 04/12/95 PAGES: 1
AUTHOR: Gordon Brown/State of Idaho
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Comments on the draft Sample Collection and Analysis Plan Finch
Pond Sediment Characterization Program
4. 1. - 1035921 -
. DATE: 04/21/95 PAGES: 3 '
AUTHOR: Peter Contreras/EPA
Gordon Brown/State of Idaho
Formal request for identification of applicable or relevant and
appropriate requirements or other requirements to be considered in
evaluating potential cleanup measures for the Kerr-McGee Superfund
site
ADDRESSEE
DESCRIPTION
4. 1. - 1040481
DATE: 06/02/95 PAGES: 37
AUTHOR: Gordon Brown/Idaho Department of Health and Welfare
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Letter and attached submittal of ARARs (applicable or relevant and
appropriate requirements) and TOCs (to be considered) for the
Kerr-McGee site in Soda Springs
4. l.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1040482
07/06/95 PAGES: 2
Peter Contreras/EPA
Gordon Brown/IDHW
Letter regarding inquiry of phosphoric acid plant permit
application
4. 1.
DATE:
. AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1040483
07/14/95 PAGES: 2
Gordon Brown/Idaho Department of Health and Welfare
Peter Contreras/EPA
State of Idaho response to the status of Kerr McGee permits to
construct and operate a phosphoric acid plant
4. 1.
DATE:
AUTHOR:
ADDRESSEE:
DESCRIPTION:
- 1040484
09/09/95 PAGES: 2
Peter Contreras/EPA
Gordon Brown/IDHW
Formal request for State concurrence and review of the draft Record
of Decision for the Kerr-McGee Superfund site
10/19/95
U. S. Environmental Protection Agency, Region 10
Page
31
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
HEADING: 5. 0. . ENFORCEMENT
SUB-HEAD: 5. 1. . Correspondence
5. 1. . - 1035910
DATE: 06/23/94 PAGES: 1
AUTHOR: Rodman H. Frates/C. L.-Frates and Company
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Certificate of Insurance
SUB-HEAD: 5. 2. . Notice Letters and Responses
5. 2. . - 0000001
DATE: 03/01/90 PAGES: 8
AUTHOR: Charles E. Findley/EPA
ADDRESSEE: G. B. Rice/KMCC
DESCRIPTION: Notice of Potential Liability
5. 2. . - 0000002
DATE: 04/03/90 PAGES: 16
AUTHOR: Barbara Hoffman/KMCC
ADDRESSEE: Wally Scarburgh/EPA
DESCRIPTION: KMCC response to 3/5/90 104(e) request for information
5. 2. - 0000003
DATE: 04/03/90 PAGES: 46
AUTHOR: Unknown/KMCC
ADDRESSEE: Unknown/EPA
DESCRIPTION: 104(e) Response: Attachment 1: Copies of Farming Leases
5. 2. - 0000004
DATE: 04/03/90 PAGES: 2
AUTHOR: Unknown/KMCC
ADDRESSEE: Unknown/EPA
DESCRIPTION: 104(e) Response: Attachment 2: List of Insurance Policies
5. 2. - 0000005
DATE: 04/03/90 PAGES: 75
AUTHOR: Unknown/KMCC
ADDRESSEE: Unknown/EPA
DESCRIPTION: 104(e) Response: Attachment 3: 1980 Hydrologic Assessment and
Graphs
10/19/95 U. S. Environmental Protection Agency, Region 10 Page
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
5. 2. - 0000006
DATE: 04/03/90 PAGES: 18
\ AUTHOR: Unknown/KMCC
ADDRESSEE: Unknown/EPA
DESCRIPTION: 104(e) Response: Appendix A (Climatological Data)
5. 2. - 0000007
DATE: 04/03/90 PAGES: 3
; AUTHOR: Unknown/KMCC
ADDRESSEE: Unknown/EPA
DESCRIPTION: 104(e) Response: Appendix B (Well Inventory Data) (Confidential
.- document located at EPA Region 10, Seattle, WA)
5. 2. - 0000008
DATE: 04/03/90 PAGES: 19
AUTHOR: Unknown/KMCC
ADDRESSEE: Unknown/EPA
DESCRIPTION: 104(e) Response: Appendix C (Chemical Data)
5. 2. ". - 0000009
DATE: 04/03/90 PAGES: 16
AUTHOR: Unknown/KMCC
ADDRESSEE: Unknown/EPA
DESCRIPTION: 104(e) Response: Appendix A Product, By-Product, Waste Chemical
Analysis List
5. 2. . - 0000010
DATE: 04/03/90 PAGES: 2
AUTHOR: Unknown/KMCC
ADDRESSEE: Unknown/EPA
DESCRIPTION: 104(e) Response: Appendix B Water Assays for April 1981
5. 2. - 0000011
DATE: 04/03/90 PAGES: 2
AUTHOR: Unknown/KMCC
ADDRESSEE: Unknown/EPA
DESCRIPTION: 104(e) Response: Appendix C NRC Notification
5. 2. - 0000012
DATE: 04/03/90 PAGES: 4
AUTHOR: Unknown/KMCC
ADDRESSEE: Unknown/EPA
DESCRIPTION: 104(e) Response: Appendix D Leach Residue Pond Permit Sample
^Analysis
10/19/95 U. S. Environmental Protection Agency, Region 10 Page 33
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
5. 2. - 0000013
DATE: 04/03/90 PAGES: 40
AUTHOR: Unknown/KMCC
ADDRESSEE: Unknown/EPA
DESCRIPTION: 104(e) Response: Appendix E 1980-1990 Sample Summaries
5. 2. - 0000014
DATE: 04/03/90 PAGES: 13
AUTHOR: Unknown/KMCC
ADDRESSEE: Unknown/EPA
DESCRIPTION: 104(e) Response: Appendix F RCRA Part A Withdrawal
5. 2. . - 0000015
DATE: 04/03/90 PAGES: 9
AUTHOR: Unknown/KMCC
ADDRESSEE: Unknown/EPA
DESCRIPTION: 104(e) Response: Appendix G Well Completion Data
5. 2. - 0000016
DATE: 07/03/90 PAGES: 59
AUTHOR: Charles E. Findley/EPA
ADDRESSEE: Robert Griffin/KMCC
DESCRIPTION: Notice of potential liability with respect to the Kerr-McGee
Superfund Site in Soda Springs, Idaho
SUB-HEAD: 5. 3. . Administrative Order on Consent
5. 3. - 0000001
DATE: 09/14/90 PAGES: 83
AUTHOR: Unknown/Unknown
ADDRESSEE: Unknown/Unknown
DESCRIPTION: U.S. EPA Docket No. 1090-02-22-105 Administrative Order on Consent
for Remedial Investigation/Feasibility Study in the Matter of:
Kerr-McGee Site
10/19/95 U. S. Environmental Protection Agency, Region 10 Page
-------
I
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
« HEADING: 6.0. . HEALTH ASSESSMENTS
j SUB-HEAD: 6. 2. . Preliminary Health Assessment
6. 2. - 0000001
DATE: 09/12/90 PAGES: 12
] AUTHOR: Unknown/Agency for Toxic Substances and Disease Registry
' ADDRESSEE: Unknown/Unknown
DESCRIPTION: Preliminary Health Assessment for Kerr-McGee Corporation Soda
Springs, Idaho CERCLIS No. IDD041310707
10/19/95 U. S. Environmental Protection Agency, Region 10 Page 35
-------
(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
HEADING: 7.0. . NATURAL RESOURCES TRUSTEES
SUB-HEAD: 7. 1. . Correspondence
7. 1. - 0000001
DATE: 06/12/91 PAGES: 6
AUTHOR: Jonathan P. Deason/U. S. Department of Interior
ADDRESSEE: Charles E. Findley/EPA
DESCRIPTION: Preliminary natural resources survey on the Kerr-~McGee Chemical
Corporation site in Soda Springs, Idaho
7.1.. - 1035438
DATE: 08/27/91 PAGES: 2
AUTHOR: Christine Psyk/EPA
ADDRESSEE: Charles Polityka/DOI
DESCRIPTION: Letter regarding the stage in the Superfund process of the
Kerr-McGee site so that the Trustees can provide the necessary
input if they so choose
7.1.. - 1035440
DATE: 04/29/92 PAGES: 2
AUTHOR: Christine Psyk/EPA
ADDRESSEE: Charles Polityka/DOI
DESCRIPTION: Letter inviting comment on the draft Preliminary Site
Characterization Report for Kerr-McGee
7. 1. . - 1035441
DATE: 05/27/92 PAGES: 1
AUTHOR: Charles H. Lobdell/Dept. of the Interior
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Comments on the Preliminary Site Characterization Report
7. 1. . - 1035922
DATE: 09/03/93 PAGES: 2
AUTHOR: Timothy H. Brincefield/EPA
ADDRESSEE: William Mullins/U. S. Fish & Wildlife Services
DESCRIPTION: Request for review of the Draft Human Health and Ecological Risk
Assessments for the Kerr-McGee Superfund Site
7. 1. . - 1035923
DATE: 09/03/93 PAGES: 2
AUTHOR: Timothy H. Brincefield/EPA
ADDRESSEE: Dan Thayer/BIA
DESCRIPTION: Request for review of the Draft Human Health and Ecological Risk
Assessments for the Kerr-McGee Superfund Site
10/19/95
U. S. Environmental Protection Agency, Region 10
Page
-------
I
, (KMCAR)
* 7. 1.
I
I
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7. 1.
KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
- 1035924
09/03/93 PAGES: 2
Timothy H. Brincefield/EPA
Cecil D. Andrus/State of Idaho
Request for 'review of the Draft Human Health and Ecological Risk
Assessments for the Kerr-McGee Superfund Site
- 1035925
09/20/93 PAGES: 2
Charles H. Lobdell/U. S. Fish and Wildlife Service
Timothy H. Brincefield/EPA
Comments on the Draft Human Health and Ecological Risk Assessments
- 1035442
DATE: 12/29/93 PAGES: 2
AUTHOR: Timothy H. Brincefield/EPA
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Memo to the Natural Resource Trustees requesting comments on the
draft Remedial Investigation Report
7. 1. . - 1035926
DATE: 12/29/93 PAGES: 2
AUTHOR: Timothy H. Brincefield/EPA
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Memo to the Kerr-McGee Site Team and Natural Resource Trustees
requesting assistance to review the draft Remedial Investigation
Report
7. 1. - 1035928
DATE: 01/25/94 PAGES: 2
AUTHOR: Greg Tourtlotte/Idaho Fish & Game
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Comments on the draft Remedial Investigation Report
7. 1. . - 1035443
DATE: 01/26/94 PAGES: 2
AUTHOR: Charles H. Lobdell/Dept. of the Interior
ADDRESSEE: Timothy H. Brincefield/EPA
DESCRIPTION: Comments on the Draft Remedial Investigation Report
7. 1. . - 1035930
DATE: 02/02/94 PAGES: 1
AUTHOR: Timothy H. Brincefield/EPA
ADDRESSEE: Peter Contreras/EPA
DESCRIPTIONfMemo regarding request from Dan Kotansky of BLM for the Kerr-McGee
Remedial Investigation Executive Summary, list of COPCs, and
Conclusions
10/19/95
U. S. Environmental Protection Agency, Region 10
Page
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(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
7. 1. - 1035931
DATE: 04/05/95 PAGES: 1
AUTHOR: Peter Contreras/EPA
ADDRESSEE: Susan Burch/U. S. Fish & Wildlife Services
DESCRIPTION: Request for review and comment on the Draft Sample Collection and
Analysis Plan, Finch Pond Sediment, Characterization Progam
7. 1. - 1035933
DATE: 04/14/95 PAGES: 2
AUTHOR: Charles H. Lobdell/U. S. Fish and Wildlife Service
ADDRESSEE: Peter Contreras/EPA
DESCRIPTION: Comments on the Finch Spring Sediment Sampling
10/19/95 U. S. Environmental Protection Agency, Region 10 Page 3f
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(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
HEADING: 8. 0. . PUBLIC PARTICIPATION
.SUB-HEAD: 8. 1. . Mailing List
8. 1. . - 1040464
DATE: 05/23/95 PAGES: 4
AUTHOR: Unknown/EPA
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Kerr-McGee Mail List
SUB-HEAD: 8. 2. . Community Relations Plan
8. 2. - 0000001
DATE: OB/12/91 PAGES: 11
AUTHOR: Unknown/EPA
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Community Relations Plan .Kerr-McGee, Inc. Soda Springs, .Idaho
SUB-HEAD: 8. 3. . Fact Sheets/Press Releases
8. 3. . - 0000001
DATE: 09/01/89 PAGES: 1
AUTHOR: Wally Scarburgh/EPA
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Press release regarding the addition of the Kerr-McGee Chemical
Corporation plant in Soda Springs, Idaho to the National Priorities
List
8. 3. . - 1040485
DATE: 12/01/91 PAGES: 2
AUTHOR: Unknown/EPA
ADDRESSEE: Unknown/Unknown
DESCRIPTION: EPA Fact Sheep to introduce the Superfund process and the related
activities at the Kerr-McGee Chemical Corporation north of Soda
Springs, Idaho
8. 3. . - 1040486
DATE: 05/08/92 PAGES: 2
AUTHOR: Unknown/EPA
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Superfund Fact Sheet- announcing that Kerr-McGee is to conduct
additional testing this Spring and Summer
8. 3. . - 1040487
DATE: 02/28/94 PAGES: 3
AUTHOR:" Unknown/EPA
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Superfund Fact Sheet stating that site investigation is on schedule
for cleanup decision by October 1994
10/19/95 U. S. Environmental Protection Agency, Region 10 Page 39
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(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
8. 3. . - 1040488
DATE: 11/22/94 PAGES: 2
AUTHOR: Unknown/EPA
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Superfund Fact Sheet regarding evaluation of options for
groundwater cleanup
8. 3. . - 1040489
DATE: 06/16/95 PAGES: 3
AUTHOR: Unknown/EPA
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Superfund Fact Sheet stating that site investigation and risk
assessment is complete
SUB-HEAD: 8. 4. . Newspaper Articles
8. 4. . - 1040490
DATE: 08/16/95 PAGES: 1
AUTHOR: Tim Jackson/The Journal
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Kerr-McGee's new ponds halt chemical leaching
8. 4. . - 1040491
DATE: 08/17/95 PAGES: 1
AUTHOR: Unknown/Unknown
ADDRESSEE: Unknown/Unknown
DESCRIPTION: EPA Wants Comments on K-M Clean Up
SUB-HEAD: 8. 5. . Notices of Availability of Information
8. 5. - 1040492
DATE: 08/03/95 PAGES: 1
AUTHOR: Unknown/Caribou County Sun
ADDRESSEE: Unknown/Unknown
DESCRIPTION: Notice of Opportunity to Comment on the U.S. Environmental
Protection Agency's Proposed Cleanup Plan for the Kerr-McGee
Chemical Corporation Site
10/19/95 U. S. Environmental Protection Agency, Region 10 Page
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(KMCAR) KERR MCGEE CHEMICAL CORPORATION - ADMINISTRATIVE RECORD INDEX
HEADING: 9. 0. . TECHNICAL SOURCES/GUIDANCE DOCUMENTS
SUB-HEAD: 9. 1. . Technical Sources
9. 1. . - 1035444
DATE: 01/28/92 PAGES: 8
AUTHOR: Russell H. Jones/Kerr-McGee
ADDRESSEE: Christine Psyk/EPA
DESCRIPTION: Letter and attached technical memorandum outlining Kerr-McGee's
approach for determining the appropriate valance state of chromium
in ores and tailings located at the Soda Springs facility
10/19/95 U. S. Environmental Protection Agency, Region 10 Page 41
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