Unitod States
Environmental Protection
Agency
Oftlc* of
Emergency and
Remedial Response
EPA/ROO/R06-88/039
September 1988
Superfund
Record of Decision:
-------
..."., . un
REPORT DOCUMEHTAOOH II. JWIOIIT NO.
PAGE EPA/ROD/R06-B8/039
.. TItle and lubtltte
SUPERFUND RECORD OF DECISION
Atchison/Santa Fe (Clovis), NM
First Remedial Action - Final
Author(I)
l~
S. Radple"', Acc8nIOft No.
I. ~~/88
I.
-
L "'o1onn'n, O,.an'zatlon Rept. No.
t. ...rfomt1nc O,..n'zatlon Na",. and Add-
10. ProjectlTuk/Woril Unit No.
'--
11. Cont18ctCC) or Grant(G) No.
CC)
(G)
12. Sponsortn, Or,anlzatlon Name and Addre..
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
-
Agency
11. Type of Report & "'rlod Covered
800/000
14.
II. Supplementary Not..
II. AbstrKt (Umlt: 200 words)
The Atchison/Santa Fe (Clovis) Superfund site is located just south of the Atchison,
Topeka and Santa Fe (AT SF) Railway switching yard in Clovis, New Mexico. The site is
comprised of an approximately 26-acre playa lake (Santa Fe Lake) which has been owned by
ATSF since the early 1900s.' The surrounding area is mostly industrial, and the lake is
current~y fenced off to public access. The lake was used for the disposal of wastewater
from various operations throughout the years. Wastewater from the washing of hopper
cars used for .hauling potash, cement, fertilizer, grain, and coke ~ere disposed in the
~ake from 1962 to 1982. EPA and.ATSF reached an agreement under an Administrative Order
In Consent for ATSF to conduct an investigation of the lake area. The investigation'
included sampling of the lake water, the sediments at the bottom of the lake, the soils
between the lake bottom and the water table, and the ground water underlying the lake.
The major concern at this site is the potential threat to ground water. The aquifer
that extends under the lake is the source of drinking water for the City of Clovis.
Although contamination of the ground water does not pose a current threat to the city
water supply, it does indicate that migration of contaminants from the lake is possible
if the source. of contamination is not removed. The primary contaminants of concern
affecting the sediments, soil, surface water, and ground water are metals including
ars'enic, chromium and lead, organics including phenols and inorganics.
(See Attached Sheet)
17. Document ANlIysII a. Dncrfpcore
Record of Decision
Atchison/Santa Fe (Clovis), NM
First Remedial Action - Final
Contaminated Media: gw, sediments,
KevdContaminants: metals (arsenic,
- b: 11 entm.II/Open-Ended Tenns
soil, sw
chromium, lead), organics (phenols)
Co COSATI Field/Group
lL Availability Statement
19. Security Clan (This Report)
None
21. No. of ~1"
I
20. Security. Class (This Pa.e)
None
--
22. Price
(S.. ANSI-Z39.J8)
See Inltructionl on Rev.,...
OPTIONAL FORM 272 (4-77)
CFonner')' NTl5-35)
-------
EPA/ROD/R06-88/039
Atchison/Santa Fe (Clovis), NM
First Remedial Action - Final
16.
ABSTRACT (continued)
The selected remedial action for this site includes: construction of a run-on
control dike and ditch system; evaporation of the water in Santa Fe Lake through a pump
and spray sprinkler system; excavation and onsite treatment of the lake sediments
through biodegradation; in situ biodegradation of contaminated soil followed by
excavation and placement in the land treatment area; capping the land treatment area
with a PVC liner and vegetated soil layer; grading and revegetation of the disturbed
area; access restrictions; and ground water and land treatment area monitoring.
Additional action may be taken to remediate ground water contamination if subsequent
monitoring results indicate the need for action. The estimated present worth cost for
-------
ATSF (CLOVIS) SUPERFUND SITE
RECORD OF DECISION
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION SIX
-------
,..' t:' S '4'"
. r
, .... .
I .. oJ
. t
\~~
.., ~
'", ,'"
./ "0''''''
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VI
1445 ROSS AVENUE, SUITE 1200
DALLAS, TEXAS 75202
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
ATSF (Clovis) site, Clovis, New Mexico
STATEMENT OF PURPOSE
This decision document outlines the selected remedial action for the ATSF
(Clovis) site in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA); and the
National Oil and Hazardous Substance Pollution Contingency Plan, 40 CFR
Part 300, November 20, 1985.
The State of New Mexico (through the New Mexico Environmental Improvement
Division) has been .provided with notice and an opportunity to review and
comment on the remedial investigation and feasibility study, along with
EPA's proposed plan for remedial action. including without limitation.
the te~hnology and degree of treatment therein. The response from the
Ne~ Mexico Environmental Improvement Divisi~n can be found in Attachment
1 of the accompanying Summary of Re~ediar Alternative Selection.
STATEMENT OF BASIS
This decision is based on the administrative record for the ATSF (Clovis)
Superfund site. The index of the administrative record found in
Attachment 2 of the Summary of Remedial Alternative Selection identifies
the items whi~h comprise the administrative record.
DESCRIPTION OF THE REMEDY
Upon review of the information contained in the administrative record, it
is EPA's judgement that evaporation of the water in Santa Fe Lake, the
treatment of the residue of that evaporation and of the lake sediments
through biodegradation in an onsite treatment area outside the lake bed,
the in situ treatment of soils underneath the lake sediments, and the
subsequent removal of the treated soils to the treatment area where it
and the treated sediments would be capped in the treatment area appears
to meet statutory requirements and to best serve the selection criteria
and appropriate guidance in relation to the other solutions evaluated.
-------
and of groundwater under the site during remediation with additional
monitoring and maintenance of the treatment area after closure and annual
groundwater monitoring. A more detailed description of the remedy and an
explanation of hpw it meets statutory requirements is contained in the
"Summary of Remedial Alternative Selection" which follows this Declaration.
The remedial action will be reviewed every five years after its initiation
to assure that human health and the environment are being protected by
the remedial action being implemented.
DECLARATION
The remedy described above is protective of human health and the
environment, attains applicable or relevant and appropriate Federal and
State requirements and is cost-effective compared to the other alternatives
examined. This remedy satisfies the preference for treatment that reduces
toxicity, mobility or volume as a principle element. Finally, it has been
determined that this remedy utilizes permanent solution~ and alternative
technologies to the maximum extent practicable.
The State of New Mexico has been consulted on the selection of remedy for
the ATSF (Clovis) site "and the concurrence of the New Mexico Environmental
Improvement Division has been received.
September 23, 1988
Date
-------
TABLE OF CONTENTS
DECLARATION FOR THE RECORD OF DECISION
LIST OF TABLES
LIST OF FIGURES
LIST OF ATTACHMENTS
SITE LOCATION AND DESCRIPTION
CURRENT SITE STATUS AND SITE RISKS
ENFORCEMENT ACTIVITIES
COMMUNITY PARTICIPATION
'OVERALL SITE STRATEGY
DESCRIPTION OF SIGNIFICANT CHANGES IN THE SELECTED REMEDY
DESCRIPTION OF ALTERNATIVES
COMPARATIVE ANALYSIS OF ALTERNATIVES
SELECTED RE~4EDY
STATUTORY DETERMINATIONS
RESPONSIVENESS SUMMARY
i i i
page
i
iv
iv
iv
1
2
8
8
8
8
.8
12
19
23
-------
TABLE ONE
TABLE TWO
LI ST OF TABLES
ANALYTICAL RESULTS FOR PLAYA LAKES
ANALYTICAL RESULTS FROM LAKE SEDIMENT SAMPLES
TABLE THREE ANALYTICAL RESULTS FROM ANALYSIS OF SOIL SAMPLES
TABLE FOUR
TABLE FIVE
TABLE SI X
FIGURE ONE
FIGURE TWO
ANALYTICAL RESULTS FOR GROUNDWATER
CRITERIA FOR SELECTION OF REMEDY
ESTIMATED COSTS
LIST OF FIGURES
SITE MAP AND WELL LOCATIONS
LOCATION OF SOIL BORINGS
FIGURE THREE CROSS-SECTION OF RUN-ON CONTROL
FIGURE FOUR
ATTACHMENT ONE
ATTACHMENT TWO
DIAGRAM OF LAND TREATMENT AREA CLOSURE
LIST OF ATTACHMENTS
STATE OF NEW MEXICO CONCURRENCE
ADMINISTRATIVE RECORD INDEX
ATTACHMENT THREE RESPONSIVENESS SUMMARY
;v
3
5
6
7
14
17
1
2
21
-------
SUMMARY Of REMEDIAL ALTERNATIVE SELECTION
ATSF (Clovis), Clovis, New Mexico
Site Location and Description
The ATSF (Clovis) Supe~fund site is located just south of the Atchison,
Topeka and Santa Fe Railway switching yard in Clovis, New Mexico. As
Figure 1 below shows, Santa Fe Lake, the focus of the site, is located
between Brady and Kimberly roads. Santa Fe Lake is a playa lake that was
used for the disposal of wastewater from various operations at the
switching yard. Playa lakes are natural depressions common on the
Southern High Plains. These depressions are usually shallow, and serve
as drainage collection points in the flat topography of the area. They
are characterized by a layer of low permiability clay on the lake bottom,
and water of poor quality Que to evaporation of the trapped lake water.
Santa Fe Lake was used for this purpose from the time of the construction
of the switching yard in the early 1900s, though the types of material
discharged into the lake have changed through the years. In 1962 a railway
hopper car washing facility was built at the switching yard. The hopper
cars were used for the hauling of bulk materials such as potash, cement,
fertilizer, grain, and coke. The cars were cleaned at the switching yard
and the wastewater from this operation was discharged into the lake. The
hopper car washing operation continued until 1982 when it was closed.
Concern about the lake is concentrated in four areas: the lake water, the
sealments that have settled to the bottom of the lake, the so.i1s between
.the lake bottom and the water table, and the groundwater that lies under
the lake.
,., ST"En
@
MA'''y
...
...
i
CleMs Swi1c"y""
Alb......,.....
.
CLOVIS
.
NM@
29
NM@
.23
NM@
25
IUM'E"L Y
'''AOY
o
~
..
::i
FIGURE 1
AT 8& SF SITE MAP AND WELL lOCATIONS
-------
2
Current Site Status and Site Risks
This site was proposed for the National Priorities List (NPL) in November
1981. Following the NPL listing and an extensive period of negotiations,
EPA and the At~hison, Topeka and Santa Fe Railway (ATSF) reached an agree-
ment under an Administrative Order for ATSF to conduct an investigation
of the lake area and to develop alternatives for correcting any problems
discovered. The investigation included sampling of the lake water, sampling
of the lake sediments, borings beneath the lake bed to get soil samples,
and the installation and sampling of monitoring wells to sample the area
groundwater. Figure 2 shows the locations in the sampling effort. In
addition to the samples taken above, samples were taken to determine what
the natural conditions in the area were. These "background samples"
included the sampling of water wells owned by the City of Clovis, sampling
of other area playa lakes, and borings outside the lake area to get clean
soil sampl es.
The results of the lake sampling are shown in Table 1. As the table
shows, when the water in Santa Fe Lake is compared to that in other playa
lakes in the area, the .Santa Fe Lake water contains elevated amounts of .
the following: arsenic, boron, chloride, fluoride, total-phenolics,
sulfate. total dissolved solids (TDS). and total orQanic carbon (TOC).
r-------,ii
() 11\.--
. : I SAIIT. PI N'lL" ~ 'I r--
= ~ I . /I
: ,/' I III
:I,f" 0 0 0 II
~~.... i' '~~"~~~~" I 0 III
"~~"(' ~~~~~~~~~~~~, II
..~~ "~~" ~,,"'~~"', L oJl .
, ".A ,~~~~~~~~~~~~~~~~~~~~, ----- I
\ s ,~~~~~~~~.~~~~~~~~~~~~~~~" ".D II
: ~~~~~~~~~%~~~~~~~~~~~~~~~~~~,~ S II
. ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~, II
dtHNfNfHHfff~fHtHlHNHlt .::
I1W' ~~~~~~~te.iA~~~~~~~~~~~~~~ II
E> :W~mtHHmttttHttttHHm "£ . 1:5
I".~ ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~. G> III
~mHmtm!~tttmHmmtH~ l.2£ :\1
:~tftl11111UlfffffflJIJlfflllF . ~----:i!
S ~~~~~~~~~~~~~~~~~~~~~~~~~~~ II
,~~~~~~~~~~~~~~~~~~~~ Le. ... II
""",'~~"",' " It. II
""',"~~"',' ~
""""~'"
'~~~~~,~' II FI GURE TWO
:: SAMPLING LOCATIONS
---JL-
L
aCCUI 100\8 I.. 'a '( f¥(L-C co
N
LEGEND
& I:XIIT... "OMTCMI ." .
E> SOIL IORING
Note:
-------
TABLE ONE
ANALYTICAL RESULTS FOR PLAYA LAKES
--------------------------------------------------------------------
LAKE SAMPLED
( mg /1 )
. PL-1
PL-2
PL-3
HIGH
t1EAN
SANTA FE LAKE
--------------------------------------------------------------------
Arsenic 0.003 0.002 <0.002 0.003 0.002 <0.4
Barium 0.13 0.12 <0.038 0.13 0.096 0.41
*Boron <0.6 <0.6 <0.6 0.6 0.6 530
Cadmium <0.003 <0.003 <0.003 0.003 0.003 0.018
*Chloride 16 7 130 130 51 2,200
Chromium 0.015. 0.021 0.018 0.021 0.018 0.059
Cyanide NO NO NO NO NO NO
*Fluoride 4.6 0.5 1.8 4.6 2.3 44.0
Hydrocarbons <0.2 <0.2 <0.2 0.2 0.2 0.2
Lead <0~05 <0~05 <0.05 0.05 0.05 0.14
Mercury NO NO NO NO NO NO
Nitrate 0.038 1.15 4.7 4.7 2.2 <0.1
pH 8.4 7.8 8.1 8.4 8.1 9.0
* Total <0.005 <0..005 <0.005 0.005 0.005 0.088
Phenolics
Selenium <0.003 <0.003 <0.012 0.012 0.006 <0.48
Silver <0.009 0.020 0.021 0.021 0.017 0.027
*Sulfate 130 10 74 130 71 5,630
*TOS 350 270 710 710 443 57,000
*TOC 4 7 20 20 10 510
* Chemical was selected as a contaminant of concern for surface water.
-------
4
The sample results for the lake sediments are presented in Table 2. The
levels of boron," lead, chromium, hydrocarbons, total phenolics, and total
organic carbon were high enough to warrant closer examination. An EP
Toxicity test was run on the sediment samples. The results showed that
the resulting levels of metals were below the toxicity standards. The
results of the soil sampling effort are presented in Table 3. As the
comparison between the background soil samples and the soils from under
the lake bed shows, hydrocarbon and total phenolics are elevated. Four
other chemicals are also of some concern. These are sulfate, chloride,
boron and barium. Finally, Table 4 presents the groundwater sampling
results. Looking at the levels of chemicals detected in the wells near
the lake as compared to those found in the uncontaminated City water
wells, only chloride is significantly above background levels, in
monitoring wells Band C. The chloride levels exceed the 250 mg/liter
standard for chloride, measuring 265 and 430 mg/liter. While these
chloride levels pose no health threat, they may be an- indicator of
potential contaminant movement from the lake into the underlying ground-
. water.
The major concern with this site is the potential threat to the groundwater.
The groundwater aquifer that extends .nder the lake is the source for the
dr"nking water for the "City of Clovis. An examination of.the results
shown in Table 4 indicates that contamination in the groundwater under
the lake does not pose a current threat to the City water supply, but
may pose a future threat if the source of contamination is not eliminated.
This is shown by comparing the sample results from upgradient monitoring
well MWA to those of downgradient well MWC. Levels of fluoride, boron
and chromium, contaminants found at elevated levels in the lake water,
do not increase in MWC. One contaminant that did increase as the ground-
water passed under the lake was chloride. While the level of chloride
found in MWC does not pose a threat to the public, it does indicate that
migration of contaminants from the lake is possible. The need, therefore,
is to eliminate the source of possible future contamination by eliminating
the lake water, soils and sediments as a source of potential contamination.
The other potential ways in which the pUblic could be exposed to the
contamination in the lake are direct contact with contaminated materials,
ingestion of the lake water, ingestion of the lake soils and sediments,
or inhalation of contaminants. The lake and surrounding property is
owned by ATSF. The lake area is fenced and there is no public access.
The lake ;s not used for any recreational use nor is the lake water consumed
by either people or livestock due to its poor quality. Direct contact
is, for all of these reasons, very improbable. The lake level is falling
and a portion of the lake bed is exposed to air as a ~esult. This does
increase the risk from inhalation of dust produced from exposed sediments.
As a worst-case scenario for production of dust, it was assumed that the
lake would dry up completely exposing all of the sediments. Using this
assumption, a risk of lxlO-5 from dust inhalation was found. Should no
remediation be performed, additional risk hased on future migration of
contaminants cannot be estimated with accuracy, but some probability of
migration and associated risk will remain so long as the lake water, lake
-------
TABLE TWO
ANALYTICAL RESULTS FROM LAKE SEDIMENT SAMPLES
TOTAL ANALYSIS EP TOX
(ug/g) (ug/ml )
MAXIMUr" AVERAGE MAXI U~1 AVERAGE
ARSENIC 2.5 2.1 0.01 0.007
BARIUM 180 93 0.97 0.74
BORON 340 300 0.9 0.46
CADMIUM 0.9 0.46 <0.003 <0.003
CHLORIDE 9,600 8,440
CHRmlIUM 190 108 0.043 0.035
CYANIDE NO NO
FLUORIDE 45 41
HYDROCARBONS 35,000 20,140
LEAD 89 59.2 0.40 0.24
r~ERCURY 0.10 0.092 0.0004 0.0004
NITRATE <90 75
TOTAL <1.1 0.97
PHENOLICS
SELENIUM <1.2 0.48 0.024 0.009
SILVER 1.6 1.02 0.019 0.015-
SOD I Ut1 2,000 1,880
SULF ATE 6,900 4,760
% TOC 13 . 5% 7.43%
-------
TABLE THREE
ANALYTICAL RESULTS FROM ANALYSIS OF SO I L SM1PLES
Background Maximums Lake Soils Maximums
B2-E B4-\~ B1-E B3-H
--------------------------------------------------------------------------------
Total EP Tox Tota 1 EP Tox Total EP Tox Total EP Tox
ug/g mg!l ug/g mg!l ug/g mg/l ug/g mg/l
--------------------------------------------------------------------------------
ARSENIC 17 0.011 25 0.009 24 0.010 25 0.005
BARIUM 200 0.35 380 2.9 130 0.99 3,500 1.3
BORON 60 150 120 80
CAm-1IUM 0.9 0.007 0.5 0.006 0.6 0.003 0.7 0.003
CHLORIDE 580 1,300 1,100 1,900
CHROmU~1 12 0.04 8.7 0.04 10 0.027 15 0.038
CYAN 1I)E NO NO NO NO NO NO rm NO
FLUORIDE 57 50 69 67
HYDROCARBONS 130 38 3,300 360
LEAD 7.8 0.007 6.7 0.007 9.2 0.018 10 0.01
~1ERCURY 0.10 0.0005 0.06 NO 0.13 0.0003 NO NO
NITRATE 90 93 88 90
TOTAL 0.06 0.06 0.55 0.74
PHENOLICS
SELENIUM 0.5 0.02 0.3 0.02 0.3 0.004 0.5 0.0"2
SILVER 2.8 0.034 3.4 0.043 1.9 0.049 2.7 0.031
SODIUM 1 , 100 510 480 1,000
SULF ATE . 450 830 720 4,800
TOC 0.36% 1.4% 0.63% 3.0%
-------
TABLE FOUR
ANALYTICAL RESULTS FOR GROUNDWATER
t10NITORING WELL
MWA MWB MWC MWO MWO BLANK
duplicate
(micrograms per 1 iter)
arsenic NO NO NO NO NO NO
selenium NO NO NO NO NO NO
mercury NO NO NO NO NO NO
boron NO 149 NO NO NO NO
barium 114 69 75 47 47 NO
cadmium NO NO NO NO NO NO
chromium NO NO NO NO NO NO
magnesium 69,100 72,510 125,000 63,370 64,040 355
silver NO NO NO NO NO NO
sodium 59,820 95,190 74,800 62,140 61,100 1204
phenol 5.4 6.6 <5 6.3 <5 14.3
(mi 11 i grams per 1 iter)
TOe 3.4 5.3 3.1 2.8 2.8 3.1
TDS 851 942 1,376 717 717 15
nitrate 1.92 3.6 5.44 5.7 2.59 0.27
chloride 157 224 322 91 88 1
fluoride 2.38 2.23 1.78 1.47 1.54 . 1.37
cyanide all results were less than 0.02 milligrams per 1 iter.
sulfate * 109 246 132 137 . <1
pH 7 7.04 6.91 6.9 6.9 6.2
* There was insufficient sample to run this analysis
-------
8
Enforcement Activities
The site is now, and has been since its construction, owned by ATSF.
ATSF is the only potentially responsible party (PRP). The investigations
at the site have been conducted by ATSF under an Administrative Order on
Consent with EPA.
Community Participation
Community concerns of either the area residents or local officials are very
low. The site is fenced and visually obscured by growth. It is not in
constant view or creating an immediate problem for the neighborhood.
On August 18, 1988, EPA issued a press release and the Proposed Plan fact
sheet. The press release was mailed to all news organizations in the
Clovis/Lubbock/Amarillo area but there was no subsequent media coverage.
The fact sheet was mailed to 175 residents and local officials. Extra
copies of the fact sheet were provided to the four local repositories
for display purposes.
In accordance with CERCLA, Section 117, both the press release and the
fact sheet announced the comment period which ended September 9, 1988. A
public meeting was held on August 23, 1988, in Clovis. Seven people attended
the meeting. EPA's.discussion did not generate any comments or questions and
no ~ritten comments were received during the comment period.
Overall Site Strategy
Th~s Record of Decision covers all the media of concern, including ground-
water. One caveat is that the last round of groundwater sa~pl;ng for the
RI showe~ the presence of aliphatic hydrocarbons in one well. Three
additional rounds of sampling were performed to determine if these hydro-
carbons were present and if so, at what levels. Results from the first
two of these additional sampling episodes did not show the hydrocarbon
contaminants. If the results from the third round of sampling should
show hydrocarbon contamination in the groundwater, some additional action
may be necessary.
Description of Significant Changes in the Selected Remedy
There were no significant changes from the preferred remedy in the proposed
plan and the remedy selected: Evaporation; onsite biodegradation; and
in situ biodegradation followed by capping of the treatment area, long-term
monitoring, and site access restrictions.
Description of Alternatives
Alternatives were examined for each of the three media in which significant
conta~ination was discovered: Lake water, sediments, and soil.
LAKE WATER
1) No Action
For th1s alternative, no further remedial action would be taken for the
-------
9
This alternative does not address any present or potential public health
or environmental concerns presented by the current status of the lake
water. Consideration of the "no action" alternative is a regulatory
requirement, and 'it may be used as a baseline to which other alternatives
may be compared.
2) Evaporation
This alternative, like all of the following alternatives for lake water
remediation, involves a run-on control system encircling the contaminated
soil area. This runon control system must be able to retain a la-year
storm event (3.5 inches of rainfall). Such a storm would produce approxi-
mately one inch of run-on from a drainage area of 1.27 square miles. In
order to retain this run-on, a 4-foot deep ditch with a 20-foot wide
bottom and 2:1 side slopes will be excavated. The soil excavated from
the ditch will be used to construct a 4-foot high dike on the side of the
ditch ~earest the contaminated soil. The dike has an estimated length of
6000 feet.
Also included in this alternative is an evaporation system. In this
system, the lake water will be pumped to an i~rigator which will spray
the w~ter evenly over the 26 acre area within the dike. Using the average
monthly evaporation rate for the Clovis area, pumping and spraying will
n~ed, to continue for about two months in order to dry the lake. The.
residue deposited on the soil from the evaporated water will be
remediated with the soils.
3) Spray Irrigation
This alternative will consist of pumping the lake water directly from the
lake to nozzles or sprinklers spread out over the site outside the diked
area. The water will undergo evaporation while any metals will be
accumulated and organics ~egraded as in a land treatment system. It can
be shown through comparison with food chain crop guidelines that the
accumulation of metals will not be excessive. Food chain crop guidelines
exist for arsenic, barium, cadmium, chromium, lead and mercury. Assuming
that the water is sprayed out evenly over an area of 60 acres and all
metals are evenly retained in the top 6 inches of soil, it can be shown
that food chain crop guidelines exceed the accumulated concentrations by
a factor of 200. Using an even more conservative approach, if all metals
are retained in the top one inch of soil, this factor becomes 33. Control
over residue from the application would ,be lost, however, as it would be
spread over the irrigated area.
In addition to the actions detailed above, all lake water alternatives
include the construction of a 6-foot high chain link fence with three
strands of barbed wire around the entire 60 acre site.
Lake Sediments
1) No Action
For this alternative, no remedial action' would be taken for the sediments
-------
10
public health or environmental concerns. This alternative will not be
screened from consideration as it will serve as a baseline to which
other alternatives may be compared.
2) In Situ Fixation (Fixation)
For this alternative, a lime-based solidifying agent such as fly ash will
be added to the in-place sediments in the lake. This agent will be mixed
vigorously with the sediments at specified water content. Water may
need to be added or removed from the sediments to achieve the desired
water content. Inspection will be necessary to determine if sufficient
fixation has been achieved. Dust control and surface water diversion
measures will be required throughout this operation to minimize wind-
blown migration of contaminants and excessive surface water in the
construction zone. The recommended method for dust control consists of
regular spraying of the lake sediments with water.
3) Dredge, Onsite Biodegradation, Cap Treatment Area and Revegetate
(Biodegradation)
This alternative will require, that the sediments be dredged from the
bottom of the lake, and then spread evenly over the ground in a
designated land treatment area for biodegradation. After dredging the
bottom of the lake, the dredged area will be revegetated~ The land
treatment area will be about 840 feet by 840 feet and be surrounded by 3-
foot nigh dikes to minimize surface runon. This area will be able to
contain about one-third the total volume of sediments that need treat~ent
at anyone time. It is estimated that it will take from about 3 to 6
months to biodegrade each application of sediments; however, for the
purpose of the feasibility study, it was assumed that each application
would take one year to degrade. As a result, it is assumed that three
years will be required to complete the biodegradation process. The sediments
will be spread evenly for aerobic biodegradation, and will require monthly
aerating and additions of nutrients to ensure uniform treat~ent. The
progress of the biodegradation process will be monitored by periodic
sampling of lysimeters installed at the land treatment area and soil
corings. When it is determined that the sediments have been" treated
sufficiently, the biodegradation area will be capped.' The cap will be
sloped and have a PVC liner underlying a one-foot thick vegetated soil
layer.
4) Dredge, Dewater, Fixation, Onsite Landfill (Landfill)
This alternative will require that the sediments be dredged from the
bottom of the lake, and then stored and dewatered at the site. The de-
watered sediments will then be mixed with a solidifying agent such as fly
ash. Water may need to be added to or taken out of the sediments to
achieve the desired water content. Inspection will be necessary to deter~ine
if sufficient fixation of the sediment has occurred. The solidified
-------
11
will be designed with specifications similar to that of a RCRA landfill.
The bottom of the landfill will be 500 feet by 500 feet. The depth will
be 10 feet, with sides sloping at 2:1. The bottom will be double-lined
with a leachate ,ollection system and drainage net between the liner.
After completion of 1andfil1ing the fixed materials, the landfill will be
capped. " The cap will be sloped and have a PVC liner underlying a one-
foot soil layer which is ~egetated. After closure, the landfill will be
periodically inspected ana maintained. After dredging the lake bottom is
completed, it will be revegetated.
SOIL BELOW LAKE BOTTOM SEDIMENTS
1) No Action
For this alternative, no remedial action will be undertaken for the soil
at the site. This alternative does not address pUblic health or
environmental concerns and also fails to meet SARA" recommendations that
the mobility, toxicity, or volume of contaminants be permanently or
significantly reduced at the site. This alternative will not be screened
from consideration as it will serve as a baseline to which other
alternatives may be compared. "
2) Cap, Grade & Revegetate (Capping)
For this alternative, the soil area of concern at the site will not be
treated or moved. The soil ~i11 be covered in-place with a cap system
consisting of "an imp~rmeab~e PVC liner covered with vegetated topsoil.
The cap will be designed to minimize erosion and ponding.
3) In Situ Biodegradation
This alternative will not require removal of the soil of concern at the
site. The soil will be left in place and aerated and blended with
nutrients to promote biodegradation and, like all the biodegradation
options, the progress of biodegradation will be monitored through
1ysimeter and soil sampling. Aeration will occur on a regular basis to
ensure uniform treatment of the soils. The treatment area will be
surrounded by runon control system dikes which will minimize surface
runon. When it is determined that sufficient biodegradation has
occurred, the area will be revegetated.
4) Excavate, Onsite Biodegradation, Cap Land Treatment Area & Revegetate
Excavated Area (Onsite Biodegradation)
This alternative will require excavation of all soils of concern at the
site. The excavated soils will be spread evenly over the ground in a
designated land treatment area. The area will be approximately 640 feet
by 640 feet and be able to handle one-third the volume of soils at any
one time. It is anticipated that it will take about 3 to 6 months to
treat an application of soils. However, for the purpose of this FS, it
is conservatively assumed that it will take one year to biodegrade each
application. As a result, it should take no more than three years to
complete the biodegradation process. This land treatment area will be
-------
12
will be allowed to biodegrade aerobically in this area, and .will be
regularly aerated and blended with nutrients to ensure uniform treatment.
The progress of .biodegradation will be periodically monitored through
lysimeter sampling and soil sampling. The land treatment area will be
closed by capping when it is determined that sufficient biodegradation
has occurred. The cap will be constructed of a PVC liner underlying
vegetated topsoil. During construction, water spraying will be employed
as a dust control measure at the site.
5) Excavate, Onsite Landfill (Landfill)
This alternative will require excavation of all soils of concern at the
site. The excavated soils will be transferred to an onsite landfill as
described in Alternative 4 under Sediments. The excavated area will be
revegetated.
6) In Situ Fixation, Cap, Grade & Revegetate (Fixation)
This alternative will not require any removal of the soils of concern at
the site.. A solidifying agent such as fly ash will be added to the soil
and mixed in. It may he necessary to add or remove water from the soil
to achieve proper water content for solidifi~ation. Inspection will be
necessary to determine if sufficient solidification has taken place.
Upon completion, the solidified soil area will be capped with a PVC liner
and topsoil and revegetated.
7) Excavate, fixation, Onsite Landfill & Revegetate Excavated Area
(Fixation and Landfill)
This alternative will require that the soils of concern at the site be
excavated and removed. The excavated soils will be mixed with a
solidifying agent at a prescribed water content. The mixture will be
placed in a landfill excavated onsite and constructed similar to the
landfill described in sediment Alternative 4. Inspections will be
necessary to determine if sufficient solidification has taken place. The
landfill will be capped and revegetated, and the excavated area will also
be revegetated.
Comparative Analysis of Alternatives
Each alternative was evaluated on the following criteria:
1. Short-term effectiveness: Protection of human health and the
environment during construction and implementation, including without
limitation, the potential threat to human health and the environment
associated with excavation, transportation, and redisposal or containment.
2. Long-term effectiveness and permanence: Effectiveness after
construction and implementation is complete. This includes, without limitation,
the long-term uncertainties associated with land disposal.
3.
Reduction of toxicity, mobility, or volume:
-------
13
of the specified treatment technologies.
4. Imp1ementabi1ity: Technical and administrative feasibility of
alternatives and the availability of required resources.
5. Cost: Cost of construction and operation and maintenance including,"
without limitation, the potential for future replacement costs.
6. Compliance with ARARs: Compliance with applicable or relevant and
appropriate requirements (abbreviated as ARARs) from existing laws and
regulations. These are standards or regulations that either apply or
at least should be considered when considering an alternative, including
without limitation, the goals, objectives, and requirements of the Solid
Waste Disposal Act.
7. Overall protection of human health and environment: How the
alternative, as a whole, protects and maintains protection of human health
and the environment.
8. State acceptance:
alternatives.
The State's preference~ or concerns about the
9. Community acceptance:
the alternatives.
The community's preferences or concerns abo~t
The following paragraphs will examine each of the alternatives for these
criteria. For comparative purposes, satisfaction of the criteria will be
rated as low, moderate, or high. These ratings are summarized in Table 5.
A.
Short-term effectiveness
All three of the no action alternatives do not address existing conditions
or potential threats to human health or the environment that will remain
if no action is taken. The no action alternatives will, therefore, be
rated as low.
When compared for protection of human health and the environment during
implementation, the two lake water alternatives, evaporation and spray
irrigation, involve use of similar equipment and little human contact with
lake water is required by either. Evaporation enjoys a. slight advantage
as the area involved in receiving the water is smaller. Both alternatives
are rated high for short-term effectiveness.
All three sediment alternatives, fixation, biodegradation and 1andfi11ing,
involve disturbance of the sediments and accompanying production 0f dust.
Dust control measures will be needed for all of these alternatives. With
appropriate handling techniques and dust control measures, all three
alternatives will have moderate short-term effectiveness.
For soils, capping will be the only alternative with a high short-term
effectiveness, as it will involve little disturbance of the soils. All of
the other soil alternatives involve extensive disturbance and handling
-------
TABLE FIVE
CRITERIA FOR SELECTION
-------
15
paragraph for sediments.
B.
Long-term effectiveness and Permanence
All three of the no action alternatives are rated low for long-term
effectiveness as they do nothing to achieve adequate protection of human
health and the environment or remove long-term threats from the contami-
nants by eliminating or mitigating the potential hazard to drinking water
posed by contaminant migration.
Both active lake water remediation alternatives will eliminate the water.
It is the fate of residue that differentiates the two. Spray irrigation
will result in some permanence of residue disposal through biodegradation
and the adsorption of metals onto soils. This, combined with elimination
of the water, gives this option moderate long-term effectiveness. There
would, however, be an increase the area in which the contaminants are
located to include the entire quarter section of land, not just the lake
bed. ,Evaporation will also eliminate the lake water, but will result
in the residue being consolidated with the lake sediments. This-will
allow the residue from evaporation to undergo the same remediation as the
sediments. Evaporation will, therefore, be rated high for long-term
effectiveness. -
Two of the three remaining sediment alternatives, fixation and landfilling,
are essentially containment remedies. The sediment, if fixed in situ,
would be vulnerable to deterioration through environmental effects. The
presence of hydrocarbons in the sediments may also interfere with the
permanenc~ of fixation~ Fixation will be rated low for long-te~m effec-
tiveness. The landfill alternative will have a longer effective life
than fixation, but all the contaminants will still be present and should the
integrity of the landfill be breached in some manner, the material. would
be subject to the effects of the environment. Landfilling will be held
as moderately effective in the long~term. Biodegradation offers the only
permanent destruction of contaminants. The organics will be eliminated
through biodegradation. The biodegradation option also has some of the
benefits of landfilling as the sediments will be consolidated in the
treatment area and capped after bioremediation. Biodegradation is con-
sidered highly effective in the long-term.
Soils fixation receives the same low rating as received for sediments.
The capping and landfilling options would be moderately effective, but
suffer finite useful lives because of degredation and failure of the
containing materials. The combination of fixation and landfilling would
result in greater long-term effectiveness than either alone, but again
are rated moderate because of the possibility mentioned relating to land-
filling in the preceeding paragraph. The two biodegradation alternatives
again offer permanent destruction of the primary conta~inants. The difference
between them is time for remediation and any benefits from the capping of
the treated materials after bioremediation. Both biodegradation alternatives
-------
16
C.
Reduction of Toxicity, Mobility or Volume
The three no action alternatives will be rated low as they do nothing to
satisfy this criteria. Evaporation and spray irrigation will both reduce
the mobility and volume of the lake water contaminants as the water will
be eliminated and only the solid residue will remain. Spray irrigation
would spread the residue throughout the irrigated area increasing the
surface area .of environmental effects which leads to migration (i.e.,
rainfall and leaching). Spray irrigation will be rated as moderate for
this criteria. Evaporation within the lake bed will result in the residue.
being handled with the lake sediments. As the lake sediments will undergo
further remediation to reduce toxicity and mObility of the contaminants,
evaporation will be rated high.
For the sediments alternatives, fixation and 1andfil1ing will reduce the
mobility of the contaminants through prevention of exposure to rainfall
and leaching. However, both do little to reduce the toxicity of the
contaminants; and fixation will increase the volume of contaminated
material. Both will be rated only moderate. Biodegradation will.
reduce the mobility, toxicity and volume of contaminated material through
elimination of the organic contaminants. As the treatment area will be
outside the lake bed and will be capped following completion, mObility of
the remaining contaminants will also be reduced. This option will,
therefore, be rated as high.
The evaluation of soil alternatives for reduction of mobility, toxicity
and volume is a repetition of that for sediments. .The landfill and
fixation alternatives will be rated as moderate and the biodegradation
options as high. Capping will be rated as moderate as it does reduce
mobility through the prevention of infiltration of groundwater.
D.
Imp1ementabi1ity
All of the proposed remedies use well tried and easily applied methods.
There is little difference between them and all will be rated high for
implementabi1ity with the exception of biodegradation for sediments which
is rated moderate. This is not from difficulty of the techniques, but
rather for the greater care which must be taken when applying biodegradation.
Biodegradation will require greater monitoring during use and a longer time
to implement than the other methods.
E~
Cost
A summary of costs can be found in Table 6. Costs for each type of remediation
are rated only against each other. Therefore, spray irrigation is rated moderate
when compared to evaporation, and landfilling is rated moderate when compared
to landfil1ing combined with fixation. Table 5 gives the ratings of the costs.
F.
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
Definition of which regulations are applicable or relevant and appropriate
-------
17
TABLE SIX
ESTIMATED COSTS
Lake Water
No Action
•uoplnf. Evaporation 1 Dltpoool of Roolduo
Piaplnf 1 Sproy Irrlootlon
Sediment
•o Action
In Situ FlMtlon
Orodgo, On-llto Kodofrodotlon, Cop lind
Trootoont Aroo 1 Rovooototo Drodood Aroo
Orodgo, DoMtor. On-Slto londfftl 4
Rovofototo Orodfod Aroo
Orodfo. DoMOtor. Mutton. On-Slto londflll
ft Rovofototo Drodfod Aroo
Soil
•o Action
Cop. firodo t Rovofototo
In Situ Ifodoflrodotfon 1 Rovofototo
CMovoto, On- 51 to llodoorodotlon. Cop lond
Trootoont Aroo 1 Rowgototo Cuovotod Aroo
Eieovoto, On- SI to LondflU 1 Rovofototo
Cxcovotod Aroo
In Situ fl notion. Cop. Grodo 1 Rovofototo
Cieovoto. riutlon. On- II to LondflU
ft Rovofototo txcovotod Aroo
>••••••«••••••*•••••••«
Dlroct
Copltol Cooto
S 1*2,000
378.000
511.000
> 0
2.669.000
672,000
2.351.000
5,020.000
s o
5.000
372.000
002,000
672.000
1,444,000
Oporotlnf ft
Nilntononco Cooto
•
S 0
10,000/OB.
10.000/00.
*
S 0
5,000/yr
•0,000/yr
2.000/yr •
7.000/yr
7,000/yr
S 0
650,000
37.000/yr
4,000/yr
»6.*00/yr
4.000/yr
•,000/yr
o.OOO/yr
f.OOOAyr
Tlov ^orlod
0
2 OM.
9 ^M^OI
0
Tro 1 - 30
Yrt 1 - S
Tro * - 30
Tro 1 - 30
Tro 1 - 30
0
4,000/yr Tro 1 - 30
Tr 1
Tro 2 - 30
Tro 1 • 3
Tro 4 - 30
Tro 1 • 30
Tro 1 • 30
Tro 1 - 30
-------
13
water within the existing lake bed should pose no violation of any
regulations as this is in fact what is now occurring naturally. Compliance
with ARARs will be rated high.
Spray irrigation outside the lake bed could cause accumulation of salts
in surface soils. New Mexico Water Quality Control Commission (NMWQCC)
regulation standards for water used for irrigation would have to be met
unless an exemption under NHWQCC Regulation 3-105.C for "irrigation for a
period not to exceed five years for the revegetation of any disturbed
land area" could be obtained.
The lake sediments do not invoke Resource Conservation and Recovery Act
(RCRA) requirements as testing has shown they 00 not meet the character-
istics of a RCRA waste, nor are they listed hazardous wastes. This includes
the so called "land ban" restrictions. The RCRA regulations for handling
hazardous wastes will be considered, however, in those cases where the
proposed methods of remediation (land treatment, capping and landfilling)
are similar to RCRA methods.
The contaminants are not volatile and should have no effect on air quality
nor be governed by air regulations. The lake is an isloated body and is '
not covered by the National Pollutant Discharge Elimination System
(NPDES) program or similar programs governing navigable waters.
G.
Overall protection of human health and the environment
The major risks posed at this site come from the lake water, contaminated
dust blowing offsite, and the potential &Jr groundwater contamination. ,
As long as the contaminated water, soils and sediments remain in place,
these risks remain. Even without the inflow of water from the discontinued
hopper car washing operation, the playa lake is the drainage point for
this area, and the discharge water from the oil/water separator continues.
The criteria by whith overall protectiveness of the alternatives will be
judged are the elimination of the presence of contaminated water, the
threat of the migration of that water into the underlying aquifer, and
elimination of the threat of migration of contaminants from the lake
sediments and soils from infiltration of the overlying lake water or
rainfall.
The three no action alternatives do nothing to remove these threats.
They will be rated low. The two remaining lake water alternatives,
evaporation and spray irrigation, both eliminate the 'lake water and are
rated high.
For the sediments, in situ fixation would reduce the mobility of the.
contaminants, but would leave them in the lake bed where they could be
released through breakdown of the fixed material. This alternative will
be rated only moderate. The remaining alternatives would remove the
contaminated sediments from the lake bed. Only biodegradation would
-------
19
The other two alternatives will be rated moderate as their landfill com-
ponents eventually will suffer environmental degredation. The soil alter-
natives will be rated similarly to the sediment alternatives. The two
options which have biodegradation as a component will be rated high for
overall protection and the four options which are basically physical
containment will be rated as moderate.
H.
State Acceptance
State preferences these center on a preference for active remediation
leading to effective 10ngterm remediation of the site.
I.
Community Acceptance
There has been limited community interest in this site. No comments were
received at the public meeting and no comments were received during the
public comment period. Judging from the lack of comments or questions,
it can be assumed that the community has no specific concerns or opposition
to the remedy in the proposed plan.
Selected Remedy.
The selected remedy has three main parts: Lake water-evaporation; sediments-
dr-edge, onsite biodegradatiqn, capping of the l~nd treatment area, and
revegetation; and soils - in situ biodegradation, capping of the land
treatment area, and revegetation. The evaporation of lake water includes
run-on controls. Access restrictions through a new fence are also required.
The following is a more complete description.
A run-on control system. consisting of ~ dike and ditch will be constructed
around the circumference of the contaminated soils area. Thls 6,000 foot
long dike will need to be constructed prior to the start of remedial
action. Figure 3 shows a cross-section of the runon control ditch and
dike. The construction of the system is expected to take two to three
months. Other site preparation activities include erection of a 6-foot
high chain link security fence with three strands of barbed wire around
the site, and clearing of the land treatment and soil stock pile areas.
These activities should take place during construction of the run-on
contol system.
A sprinkler system will be installed within the perimeter dike. Water
will be pumped from the lake and sprayed over the contaminated 50ils
within the dike to enhance evaporation of the lake water. This process
is expected to take approximately two months, but may take longer if it
takes place during a wet season.
The land treatment area, constructed for onsite biodegradation of the
sediments, has been previously discussed. The soils will be excavated to
a depth of 3 feet below the existing surface. The excavation will follow
the natural slope of 2 percent.. Dikes will be built around the perimeter
of the area us i ng the excavated soil s. The di kes will be 5 feet hi gh
(above the existing ground surface) and have side slopes of 2-to-1. The
-------
20
The sediments remaining on the lake bottom, after the lake water is
removed, will be. dredged and biodegraded at the land treatment area. The
sediments will be placed in 12 inch layers within the diked land
treatment area. Due to space limitations, the sediments will need to be
treated in five layers. It is anticipated that each layer can be
biodegraded in about 3 to 6 months; however, it is conservatively assumed
that it will take one year for each layer. Thus, sediment biodegradation
will take no more than five years. During the same time that the sediments
are being treated, the soils will be biodegraded in situ. 50il treatment
is expected to take no more than one year.
The next step will be implemented after the in situ biodegradation of the
soils and onsite biodegradation of the sediment are complete. The
biodegraded soil will be excavated and placed in the diked, onsite land
treatment area used for the sediments after the fifth layer of sediments
has been biodegraded. The soil layer will be sloped at 2 percent and
covered with a PVC liner. The liner will be anchored in 2 foot deep
trenches along the tops of the dikes. A one foot thick layer of soil
(from the soil stockpile) will. be placed over the liner and vegetated.
Figure 4 shows the conceptual design of the capped land treatment area.
This moving of the soils to the onsite treatment area for closure essentially
combines the important elements of the two highly rated soils alternatives
(in situ Biodegradation, Cap Land Treatment Area and Revegetate Excavated
Area). The prime advantage of this step is that all contaminants from
the three areas of concern; lake water, lake sediment and affected soils,
will have been degraded and ~uhsequently contained within the onsite
treatment area. .
The areas from which the soils and sediments were excavated will be
graded to remove any excessive slope changes resulting from excavation.
In addition, the perimeter dike material will be used to fill in the
ditch. The entire area will be revegetated and allowed to return to
natural conditions.
No groundwater remediation is proposed, but groundwater monitoring will
continue semi-annually during remediation and annually after remediation
for the contaminants of concern for groundwater. Monltoring through
lysimeters of the land treatment area will continue after closure on an
annual basis. .
During design of this alternative, tests will be performed to support
assumptions made during the risk assessment regarding the speciation of
chromium and the make up of the hydrocarbons in the lake sediments.
This remedy was selected based upon the satisfaction of the nine criteria
shown most plainly in Table 6. In particular, the selected remedy
satisfies the preference for permanent treatment, long-term
effectiveness, overall protection of human health and the environment, and
-------
FIGURE THREE
RUNON CONTROL
~
20'
"I
. ~:,:,::::--~----
f
__I'
-- --------
10'
-------
FIGURE FOUR
CROSS SECTION 'OF
LAND TREATMENT AREA AT
CLOSURE
.OIL '''Oil STOCK "Ll
---
--
---
-- .
---
--
--
--
,I
TitIATI. 'O'L
. LA".'" 01' '..'.."Te
8'0'
-------
23
v
No expected risk level from the implementation of the selected remedy was
determined. The threats from the lake water and blowing dust will be '
eliminated. The potential for future contamination will have also been
greatly reduced though this reduction,cannot be quantified. The total
estimated cost' for the selected remedy are $2t840tOOO.
Statutory Determinations
The selected remedy is protective of human health and the environment
through the elimination of present and future risks posed by the site.
The elimination of the lake water through evaporationt and of the opportunity
for fugitive dust through capping of the treatment areat removes the
current threat from the site. Future risks from the site through
additional migration of contaminants are also eliminated through the
permanent destruction of the organic materials through biodegradation and
with the isolation of the remaining contaminants in the treatment area.
The potential for migration of contaminants is also reduced through the
elimination of the hydraulic head on the lake soils and sediments through
evaporation of the lake watert through removal of the contaminated materials
from the lake bedt and through the consolidation of the treated material
in the onsite treatment area. No unacceptable short-term risks or cross
media impacts will be caused by implementation of the remedy.
. ,
Few ARARs are actually applicable or relevant and appropriate to this
sitet as the materials in question are not, RCRA wastest the lake
is not a navigable water of the United States nor is it connected to a
flowing stream. The actions involved in the remedy are primarily aimed
at preventing contamination of the groundwater aquifer under the site.
The selected remedy will meet all primary State and Federal standards for
drinking water. ' One.State non-human health standardt that for chloride,
is slightly exceeded in two monitoring wells, but these wells are immedi-
ately adjacent to the lake and well within the site boundaries. Chloride
levels in the nearest wells used for human consumption are below the
standard. The source of the chlorides is being removed from the lake bed.
The property is owned by ATSF and no wells for consumption will be placed
within site boundaries.
There are some guidelines that are in the catagory of lito be considered"
guidance. The primary ones are those regulations regarding land
treatment and will be used in monitoring the biodegradation area.
The selected remedy is cost-effective when its components are compared to
alternatives which provide similar levels of overall effectiveness.
The selected remedy was picked from among the alternatives evaluated by
the nine criteria as seen in Table Five. The selected remedy provides
for elimination of the lake water and organic contaminantst and for the
removal of the inorganic contaminants from the lake bed and their
subsequent isolation. This is done in a cost-effective manner while
giving the best long-term effectiveness through destruction of the organic
contaminants. The elimination of the lake water and the destruction of
the organic contaminants through biodegradation satisfies the preference
for treatment that reduces toxicitYt mobility or volume.
Responsiveness Summary
-------
ATTACH~1ENT ONE
-------
~~
Post Office Box sse
Santa F., New M8XJCO B7504-0968
CiA=:I=:Ie..... CA~RUT'HE=:I6
Ge"g"''''Qr
ENVIRONMENT AL.IMPROVEMENT OIVISION
Richird Mitzelfelt
Director
Carla Muth
S.C;:r".ta~
Michael J. Bur'
C.guCV S.o"'.t.
rt
""" ,I,If)QCO
HEAlTH AHCI ENVlP.ONMENT
XPAAtMi."iT
September 22. 1988
Allyn M. Davi., Dirlctor
Hazardou. WaIte Management Division (6H)
US Enviro~ental Protection Agency
1445 Rou AVlnul
Dalla., Texa. 75202-2733
Dear Mr. Dav18:
The State of New Mexico !nvironmental Improvement Divilion hu reViewed
the Draft Record of Dech10n for the ATSF (Santa Pe Lake) .ite in
Clovi., New Mlxico. lID concur. that thl propo.ed remedy will
adequately protlct human h.alth and the env~ronment. .
Sincerely.
~~t
RMIACldlr
xc:
Doug Jon.., lID Ground Water Section
-------
ATTACHMENT THREE
-------
u
Atchison, Topeka, and Santa Fe (ATSF) C10vis
Community Re1ations Responsiveness Summary
This Community Relations Responsiveness summary has been prepared t
provide written responses to comments submitted regarding the proposed
plan of action at the Atchison, Topeka, and Santa Fe (ATSF) Clovis
hazardous wasste site. The summary is divided into two sections:
Section II: Summary of Major Comments Received. The comments (both
oral and written) are summarized and EPA's responses are provided.
1. ~ound of Community Invo1vement
Individual interest or attnetion to the contamination in Santa Fe Lake
has been very 10w~key and unorganized. Since the lake itself is
partiallY hidden by topography and growth, area residents seem to ignore
it. The acerage is also fenced and locked which has reduced casual
trespassing. .
Press coverage of the site has been very limited and the majority of the
articles were status oriented for all sites within the state.
EPA interviewed area citizens and local officials in August 1986. A
project update regarding the status of. the site was issued in September
1986. No concerns/questions were generated as a result of these two
activities.
11. Summary of Major Comments Received
The press release and proposed plan fact sheet announcing the publiC
comment period and public meeting were distributed on August 18, 1988.
The comment period began on August 15 and ended September g, 1988. A
public meeting was held with area residents and local officials on August
23, 1988, at the Clovis Holiday Inn. the purpose of this meeting was to
explain the results of the remedial investigation and to outline the
various alternatives presented in the feasibility study. Eight people
attneded the meeting, but no oral statem.nts or questions Were asked. No
------- |