United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Reeporwe
EPA.ROD R08 85,003
July 1985
SuperfunH
Record of Decision:
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. TECHNICAL REPORT DATA
(Please read Instructions on the revene before completing)
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R08-85/003
. TITLE AND SUBTITLE 5. REPORT DATE
IRECORD OF DECISION July 19, 1985
woodbury Chemical, CQ- 6. PERFORMING ORGANIZATION CODE
- -
7. AUTHORCS) 8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
J;';~.", Df'\T"\
U.S. Environmental Protection Agency 14. SPONSORING ACfENCY CODE
401 M Street, S.W. 800/00
Washington, D.C. 20460
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Woodbury Chemical Company operated a pesticide manufacturing facility at 54th Avenue
and Jackson in Commerce City, Colorado, from the late 1950s to 1965 when the facility
was destroyed by fire. Fire rubble and debris contaminated with approximately 1,565
pounds of organochloride pesticides were disposed on an adjacent empty lot which is
the designated CERCLA site. Results of the remedi al investigation show contaminated
ISOilS and sediments onsi te, contaminated sediments offsite, and pesticides in the
ground water; however, significant contamination is limi ted to the rubble piles. In
addition, several separate investigations, conducted between October 1976 and June 1985,
indicated three general types of contaminants: pesticides, metals, and other organic
compounds.
The cost-effective selected remedial action for this site includes: excavation and
offsi te transport, incineration, and ash disposal of highly contaminated rubble (total
pesticide concentration in excess of 100 ppm) at an 'EPA approved incineration/disposal
facility; excavation and offsite disposal of contaminated soils, to a cleanup level of !
3 ppm total pesticide concentration, at an EPA approved facility; backfilling wi th ;
clean soil,' regrading and revegetating the site; and ground water monitoring and site I
!
I
maintenance for a three-year period. Total capital cost for the selected remedial I
I
alternative is estimated to be $1,417,000, which includes $21,000 for a three year O&M I
period. .
i
17. KEY WORDS AND DOCUMENT ANALYStS I
b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI I-idd.Gr "
a. DESCRIPTORS " I
Record of Decision I
I
tvoodbury Chemical, CO i
contaminated Media: soil, sediments, gw !
:
Key contaminants: pesticides, heavy metals,
organics
!
;
18. DISTRIBUTION STATEMENT 19. SECURI TY CLASS, [IllS Ref',)f(, 21. NO. OF P~G~5
None dQ
20 SECURITY CL-"SS IT/,is pJ~,': 22. PRICE !
None ~
EPA Fo,m 2220-1 (R.\!. 4-77)
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INSTRUCTIONS
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2.
3.
LEAVE BLANK
- -
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TITLE AND SUBTITLE
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type or otherwise subordinate it to main title. When a report is prepared in mor~' Ihan un~' vulume, rqwat Ih~' prun;lry tille. ,111,1 h,lun",
number and include subtitle for the specific title.
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REPORT DATE
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PERFORMING ORGANIZATION CODE
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Give name(s) in ~'0nventional order (JoII" R. Doc. J, Robal 00('. (',c.). List author's affiliallon if il differs fwm th~' p~'rfmminj: d'j:ani.
zation.
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Give name, street, city, state, and ZIP code. List no more than two levels of an organilalional hireardlY,
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Use the program element number under which the report was prepared. Subonhnate number, II\OI~' he ind,"\\-d 11\ par~'lIlh,'"",
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Insert contract or grant number under whkh report was prepared.
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Include ZIP code.
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16. ABSTRACT
Include a brief (200 words or less) factual summary of the most signlfkant Informalilln ,'uIHall1l'l1 '" II,,' I "I'0rl. II II,,' '''1''''1 '"111.1111' a
significant bibliography or literature survey, mention it here.
17. KEY WORDS AND DOCUMENT ANAL YSIS
(a) DESCRIPTORS. Select from the Thesaurus of Lngll1eem:~ and 5.:1L'IIIIIIL I er"IS Ihe pruper ,lulh"'1/\'d 1,'''"' thaL IUL'I1Illy thL' 111:1)111
concept of the research and are sufficiently speCIfic and predse 10 be u,eu a' 111<..11'\ entries fur Latalll,:III~.
(b) ID[;"IjTlFlERS .-\:"0 OPL~.!::"DED TERMS. L'se Identifiers for pruJc.:t namL', _ude name\. L'ylilponent d,"lcn,II,,,'. \'Ic. L',,' "I'L'II'
ended terms wrllten in de>':rlptor form for those subjects for which no JC\L"ptur ""Is.
(c) COSATlIILLO GROl'P .I'ield and !troup assignments ,ue to be lake'n Irurn thc ''If,5 COS." II 'iul",'<:1 CJll'CIIIY I.is!. 'i'n~'l' the m,l'
jority of document> are multidis~lplinary In nature, the Primary I ield, (;roup a"lgnmellt! 'I I,\, ill he -PL'L Il'l .II\! .plone, :"L'a "' hUlI1"n
endeavor. or type of physi.:al object. The applicaliontsl ....-,11 be cfll~~-rcler~'IH;cU I,\,lIh 'Cl'undar~ 1 ",1<1 (.1<>"1' J"'~nll\l'II" III., L \L dl t..lI. 'II
the primary posting/sl.
18. DISTRIBUTION STATEMENT
Denote releasability to the publi~' or linllutlun for rea'on~ other than ,eLurtly lur e\ample "Kd,'a'" , 1I\""lll'd," ( ,'" .11'; ,,,,.d,.I'Ii,I; I,.
the public. with address and price.
19. So 20. SECURITY CLASSIFICATION
DO NOT submit das"tied reports to the "attonal Tl'lhnteallnfurmattun 'eIVl,e.
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Insert the IOlal number of page>. In,ludlng this unc and unnumbered page'. hut "dude :J1\lrthuttun ,,,I.,' any.
22. PRICE
Insert (he price set by the ~ational r,,'::nlcJIIr.folmallon SCnllL' "r lilL <;""'Inillel,t I'nntlng CJliiLC, 11 ~nll"n.
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Record of Decision
Remedial Alternative Selection
SITE:
Woodbury Chemical, Comm~rce City, Colorado
DOCUMENTS REVIEWED
I am basing my decision primarily on the following documents describing
the anlysis of cost-effectiveness of remedial alternatives for the Woodbury
Chemical site:
Woodbury Chemical Remedial Investigation, CH2M Hill
Woodbury Chemical Feasibility Study, CHZM Hill
Summary of Remedial Alternative Selection, EPA
Responsiveness Summary, EPA
Summary of Remedial Alternatives, Camp, Dresser, & McKee
Other miscellaneous documents and correspondence in the project file
DESCRIPTION OF SELECTED REMEDY
The selected remedy consists of excavation and offsite transport,
incineration, and ash disposal of highly contaminated rubble at a total
pesticide concentration above 100 ppm (250 cubic yards) at an EPA approved
incineration/disposal facility, and offsite transport and disposal of
remaining contaminated soils to a cleanup level of 3 ppm total pesticide
concentration (5470 cubic yards) at an EPA approved facility. There will be
soil replacement using clean, impermeable fill material, along with regrading,
revegetationo and monitoring.
The operation and maintenance requirements of this remedy include
development of a vegetative cover on the site over three years, and
groundwater monitoring for a minimum of three years.
-
.
DECLARATIONS
Consistent with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA), and the National Contingency Plan
(40 CFR Part 300), I have determined that the offsite incineration of hfghly
contamfnated rubble and offsfte dfsposal of remaining contaminated soils at
the Woodbury Chemical Site is a cost-effective remedy and provides adequate
protection of public health, welfare, and the environment. The State of
Colorado has been consulted and agrees with the approved remedy. In addition,
tthe action will require future operation ind maintenance activities to ensure
the continued effectiveness of the remedy. These activities will be .
considered part of the approved action and eligible for Trust Fund monies for
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-2-
I have also determined that the action being taken is appropriate when
balanced against the availability of Trust Fund monies for use at other
sites. In addition, the off-site transport, destruction, and secure .
disposition of contaminants is more cost-effective than other remedial action,
and is necessary to protect public health, welfare, and the environment.
The EPA will undertake additional studies as necessary to determine the
extent of groundwater contamination in Commerce City, Colorado. If additional
remedial actions are determined to be necessary a Record of Decision will be
prepared for approval of the future remedial action.
Date
on. Welles
onal Administrator
U. S. Environmental Protection Agency
Region VIII
JUl 1 9 1985
~. --
~ .-!
-
...
.
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
Woodbury Chemical Site
Site Location and Description
The Woodbury Chemical site is a National Priorities List (NPL) site under
CERCLA (Superfund) that has been contaminated by various organochloride,
organophosphate, and heavy-metal pesticides. The site is located at 54th
Avenue and Jackson Street in Commerce City (immediately north of Denver),
Adams County, Colorado (Figure 1). The Woodbury Chemical Company operated
a pesticide formulation facility at 54th Avenue and Garfield Street between
the late 1950's and 1965.
In 1965, the facility was destroyed by fire. The debris and rubble from
the fire were disposed of on an adjacent 2.2 acre vacant lot to the east at
the 54th and Jac~son Street location. The disposal site is a fiat vacant
-
lot approximately 550 feet 10n9 (E-W) by 115 feet wide (N-S) (Figure 2). A
number of rubble piles that resulted from disposal of the Woodbury facility
are located on the site to a height of approximately four feet.
Vegetation, primarily grasses and weeds, covers the majority of the site.
with the rubble piles and portions of drainage ditches remaining
unvegetated.
.
Several man-made drainage channels on the site drain intermittent
stormwater runoff off-site to the north and west. The runoff from the
channels discharges into a drainage ditch that runs along the northern
boundary of the site in a westerly direction for about 3,000 feet before
emptying into ~ retention pond. Water loss from the pond occurs via
evaporation and infiltration. The South Platte River is located
approximately 1 mile to the northwest of the site. Sand Creek, a tributary
of the South Platte, runs east-west about 0.5 miles north of the site. '
The Commerce City area is heavily industrialized. The site is surrounded
by light and heavy industries on all sides, with the Foremost-McKesson
Chemical Company (a solvent and etching"solution distributor located on the
-1-
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ADAMS CDUNT't
"''''''ION COUNT..
WOODBURY CHEMICAL
SITE LOCATION
A"APA..OI COUNT't
-
...
~
~
()
J~ WOODBURY
q"t CHEMICAL
~ SITE
~
~
@
@
DENVER
Figure 1 Regional Location of. Woodbury Chemical Site
-2-
.. . ~-' ..
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To A.t.ntlon
Pond 'S2000':""""'"
J/JJt1If'
'onMftO.~K...on
Chemic. I Comp.n,
,
w
,
Ar.. 0' Known Contamlnetlon
81t. Prop.,., Boundar,
-;
~
i
- U; b
en z
c ~ S
o fit
fit .~ r
J1I. ...
U to
to I: ~
.,
m
.;
en
.
o
...
c
o
~
.;
en
"
~
:0
e>
SITE PLAN
1" - 200'
MW Monitoring w.n
Figure 2 Site Plan of Woodbury Chemical Site
,
,
CULVERT
CDM
"'~'~""O<"-'\ ",.~h".
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former Woodbury property) to the west, a petroleum refinery and railroad
tracks to the north, a railroad and highway to the east, and several
automobile and scrap metal salvage yards to the south. Tracks of the
Colorado Eastern Railroad Company (CERC) run east~west approximately 50
feet north of the site at a grade 20 to 25 feet below the site ground
surface.
The ground water hydrology of the area is characterized by unconfined
aquifer conditions in the alluvium and semi-confined aquifer conditions in
the underlying bedrock which lies at a depth of about 30 feet. The water
table is located 20-27 feet below the ground surface. The general
direction of ground water flow is to the west and northwest, towards the
South Platte River.
Thirty industrial or residential wells are identified in the state
engineers' records as being downgradient (west to northwest) of the
Woodbury site, between the South Platte and the site. Nineteen of these
wells receive ground water from the surface aquifer and eleven from the
bedrock aquifer. The nearest downgradient well completed in the surface
aquifer is 0.5 miles away. The South Platte provides recharge to alluvial
municipal drinking water wells serving portions of the Denver Metro area.
It is also used for irrigation.
-
..
The closest residential area is a mobile home park about 0.3 miles to the
southwest. The population within 1 mile of the site is approximately
3,000.
Site History
The Woodbury Chemical Company was operated as a pesticide formulation
facility at 54th Avenue and Garfield Street in Commerce City between the
late 1950Is and 1965. In 1965, the facility was destroyed by fire with
debris and rubble being disposed of on the existing CERCLA site. No
records have been located regarding the type of pesticides actually
formul ated by Woodbury. After the 1965 fi re and subsequent disposal of
rubble on the site, no actions were taken at the site until 1976 when, in
-------
response to concern about runoff from the site being contaminated with
pesticides, the Tri-County Health Department sampled storm runoff.
Subsequently, the soil, surface water, and ground water were sampled by a
number of local, State, and Federal agencies from 1979 through the Remedial
Investigation field work in 1985. The site has not been used .or modified
since 1965 except for a Superfund Immediate Removal action in September
1983, which consisted of the installation of a six-foot chain link and
barbed wire fence around the perimeter of the site. Five monitoring wells
were installed along the perimeter of the site by EPA in 1984 as part of
EPAls Remedial Investigation. .
Shortly after the 1965 fire, the Woodbury Chemical Company rebuilt a
facility at the original location (adjacent to the CERCLA site). The
property and building were sold in 1970 to the present owner,
Foremost-McKesson Chemical Company. The CERCLA site was owned by the
Chicago, Rock Island, and Pacific Railroad Company (CRIP) at the time of
the fire and until 1984. However, in March 1975, CRIP filed for
reorganization under the Federal Bankruptcy Act. After operating in
receivership for over nine years, on June 1, 1984, the entire proceeds of
CRIP were liquidated and the Woodbury CERCLA site became a property of the
Chicago-Pacific Corporation. In December 1984, the property encompassing
the Woodbury site as well as many other former holdings of CRIP were sold
by the Chicago-Pacific Corporation to Colorado Eastern Railroad Company
(CERC), a small Colorado short line railroad.
.
Current Site Status
Information regarding contamination at the Woodbury Chemical site was
obtained from several separate investigations conducted between October
1976 and June 1985 (Table 1). These investigations indicated three general
types of contaminants: pesticides, metals, and other organic compounds~
Of these, the pesticides and one metal, arsenic, are attributed to the
Woodbury Chemical wastes disposed of on the site. A listing of the maximum
levels of contaminants found at the Woodbury site are presented on Table 2.
The concentrations presented are the "wQrst case" maximums found over the
sampling periOd 1976 to 1985. These high concentrations within the soils
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TABLE 1
SUMMARY OF SAMPLING EFFORTS
Date
Samples Collected
Chemical
Analyses Performed
Taken By
October 21, 1976
Aprl1 23, 1979
August 14, 1979
November 19, 1979
February 21, 1980
May 10-20, 1982
June 26 -
Aug. I, 1984
November 14, 1984
June 10-
June 14, 1985
1 Standing water
11 So i 1
3 Surface runoff
10 So11, 1 Pond
3 Water
26 Borehole
34 So 11
10 Surface Water
. 7 Ground water
8 Surface so11
7 Surface water
7 Ground water
21 Borehole soil
7 Ground water
10 Rubble
66 Rubbl e/so; 1
26 So11
12 On-site sediment
10 Off-site sediment
3 Off-site sol1
PP, AP
PP, AP
TCDHD
TCDHD, CDH
PP, AP
EPA, E&E
EPA, E&E
PP, AP
PP, AP
PP, PI, AP
EPA
FCHA
- .
..
PP, PI, PO, PV
AI, AO
CH2M Hill
PP, PI, PV
CH2M Hill
PP, AP
E&E
-
TCDHD--Tri-County District Health Department
CDH--Colorado Department of Health
EPA--Environmental Protection Agency, Region VIII
EIE--Ecolo91 and Environment, Inc., FIT Contractor
FCHA--Fred C. Hart Associates, Inc., FIT Contractor
PP--Priority Pollutant Pesticides
PI--Priority Pollutant Inorganics
PO--Priority Pollutant Organics (Base/Neutral and Acid Extractable)
PV--Priority Pollutant Volatiles
AP--Additional Pollutant Pesticides
AI--Additional Pollutant Inorganics
AO--Additional Pollutant Organics (Base/Neutral, Acid Extractable, and
Volat11e) .
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T ABL E 2
MAXIMUM CONTAMINANT LEVELS OB$ERVED AT THE WOODBURY CHEMICAL SITE
Rubble/
Soil/Sediment Ground Water Surface Water
Contaminant (ppm) (ppb) (ppb)
Pesticides
Aldrin 1,200 7.3
Dieldrin 88 2.2 5.0
Chlordane 380
4,4'-ODT 400 0.2 25.3
4,4'-ODE 200 3.9
4,4'-QDD 1.9
Endrin 447 4.2
Heptachlor 103
alpha-BHC 152,000 0.2 2.4
beta-BHC 57 0.2
gamma-BHC 55,000 1.8
delta-BHC 43 0.2
Toxaphene 7 ,I (j0 - ..
2.4,5-T 0.89
Malathion 68 30.3
Methoxychlor 116 5.2
Parathion 41 9.7
Metals
Arsenic 33 496
Cadmium 10 7.9 65
Chromium 33 72
Lead 263 456
Zinc 244 43 901
Barium 275 107
Iron 32,600
Manganese. 1,200 3,240 1,130
Vanadium 39
Volatile Organic Compounds
1,1-0ichloroethane 243
1,I,2-Trichloroethane 1,300
Chloroform 1,300
Methylene Chloride 0.1 7
Tetrachloroethylene 50
Toluene 88
Trichloroethylene 280
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TABLE 2
MAXIMUM CONTAMINANT LEVELS OBSERVED AT THE WOODBURY CHEMICAL SITE
Contaminant
Rubb1e/
So11/Sediment
(ppm)
Ground Water
(ppb)
Surface Water
(ppb)
"lei t.
t ~~~ "
Base-Neutra1 Extractab1e Organic Compounds
Di-n-buty1 phtha1ate 0.61
Di-n-octy1 phtha1ate 2.7
Benzo(a)anthracene 0.62
Chrysene 0.62
pyrene 0.94
Acetone 15.0
150
'.~.. ~, ,; ,.
.~
,;. -
! 'f:. -
.... Y
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and sediments are not found throughout the site, but only in "hot spots"
where rubble had been deposited. The volatile and extractable organics
(solvents) found at the site are attributable to off~site sources which are
currently under investigation by EPA.
The pesticides found at the Woodbury site can cause a wide variety of
adverse health effects, ranging from dermal irritation to cancer (Table 3).
The persistence of the organochloride pesticides (DOT, methoxychlor,
aldrin, heptachlor, chlordane, dieldrin, toxaphene, and endrin) and their
ability to bio-accumulate are widely known. Potential routes of migration
or exposure to the pesticides on site include direct human or animal
contact with the soils, sediment, wind-transported soil particles,
migration to ground water, or migration to surface water.
Contamination by the pesticides has occurred, at least to some extent, in .
four environmental media: soils, sediments, ground water, and surface
water. Of these, contamination of soils and sediments is considered the -
most significant. A brief discussion of contamination in each medium is
presented below:
,
o Soils: Investigations at the Woodbury site indicate that pesticide
contamination occurs in "hot spots" in the central portion of the
site (i.e., individual accumulations of disposed demolition rubble).
Samples taken from soil borings (MW2 and MW3 - .monitor wells
installed during the 1984 investigations) indicated pesticide
contamination of soils with depth. At MW2 contamination was noted
throughout the 35 foot depth with alpha-BHC detected at a
concentration of 0.65 ppm at about 30 feet. In MW) pesticides were
noted to a depth of 32. feet, toxaphene was detected at 12.0 ppm in
the upper 10 feet of sol1. At sample point RSO-8 (1985) a total
pesticide level of 35.12 ppm was detected at 10 feet, toxaphene
accounted for 60 percent of total pesticides in this sample. At
RSO-10 -(1985) total pesticides concentrations of 2 to 4 ppm were
found at depths ranging from 10 to 30 feet, toxaphene was the only
pesticide that occurred at concentrations exceeding 1 ppm.
. .
These findings indicate that some downward migration has occurred.
Possible explanations for the observed subsurface contamination
include" dissolution and migration through the unsaturated zone with
re-adsorption onto the soil particles, or cross-contamination within
the boring during drilling or sampling. Even if the pesticides have
migrated vertically downward through the soil, they do not appear to
have dissolved into the ground watf~ in large amounts.
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1
j
!
!
Conmtn.nt
TABU 3
IIICMI OR SUSPtCT(O RiSkS OF CIIITMIUITS
AT Tft( WOOOBURY CH£"ICAl SIT(
ChMtca1 Fo,.a
Typ. of ...t.rt.1
Rishb
A1drtn
ArSftltc
.
-
o
.
Ch10rdlM
1.2.3...IO.IO-hrx.cho10ro-
1....a.5.8.8a-hP.ahydro-.xo-
1..-.ndo-8-dl..th.no-
.ptha1.ne
Ars.ntc trtoxtdt! tn naturf
1.2...5.6.7.8.8-octach1oro-
2.3.3a...7.7a-hfxach1oro-
..7-..thanotndane
Bro.d SpPCtru8 tnseetlcldf;
ch10rtnatfd hydrocarbon
Typlca11y In th.
ppntava1.nt fo~ In
wnod pr.s.rv.ttv. s01utlon
and In preserved wood.
Prf-p1.nt InSfetlel"
uSfd to eontro1 ftrf .nd
h.rv.st.r .nts; ch10rtnatfd
hydrocarbons.
,
C.n bf Ibsorbftt througfl stln.
rfsplrttory tr.ct. tn!fstton.
Afffets C"'tra1 "'"GUs syst...
1lver. 'ldnPy. .nd s'ln.
C1.sslfl.d .s . carctft09fft by
thr ..tlona1 C.ncer Instttute.
(PA. US_So IARt. Breah cto.n
to dl.1drtn.
Us..11y Inhl1.d or Ingfstp.d
through dust or f~. (ffeets
Inc1udt! "tn eorroston .nd
.nd dt!~tltls. Pfrfor.tlon of
thP n.s.1 s"tv.. .nd
br.tosts. Pro10ft9Pd contact
can rPsu1t In ..ttt", ",d
1.t.r v.scu1.r or pustu1.r
.ruptlons. ltst.d.s.
carclno"" by (PA. USDHHS.
lAIC .
Can fftt.r ~ thrG89h
I",.stlon. Inh.1.tlon. or stln
.bsorptton. Acut. to.letty.
prt..rl1y duf to a1tfratlon of
thP e,"tr.1 Mrvous syst...
Inc1udfs dl.rrhf.. ..tttng.
.., dfprfsslon. .nd dt!.th.
Chrontc .fffCtS Inc1udf
dP9Pnfr.tlon of thf 11..r.
S...rf ftfCrotlzlng.
bronchopMU8OftI.. .nd
dfgfMr.tfon of rf".1 tulHt1
"lth.1t... C1.sslft.d.s.
carctnogt'll by Itl. EPA. USDHMS.
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TABU J
KNOWN OR SUSPECTEO RISKS OF CniTAMINANTS
AT THE "0001".' CH£MICAI. SITE
CCONT 'D.)
Cont..tn.nt
Rhhb
Ch..tcal Fortll'
T1P~ of Matert.1
DOT
OOD. OOE
I
-
-
I
Dt~ldrtn
Endrtn
1.1 l-trtchloro-2.2-
b'slp-chloroph~nyl)
~thane
Broad- spt'c t",.
'nsect lei de.
M~tabolttes of OOT
Dphydrochlortn.ted fortll
of OUT
1.2.3.4.IO.IO-h~r.chloro-
6.7.~ry-I.4.4a.S.6.7.8.
8.-oct.hydro-endo, ero-
1.4:S.8-df~thanonaph.l~ne
Chlortn.ted hydroc.rbon
ppsttctdp; foM8Pd f~
thp ~taboltc conyerston of
of aldrtn.
1.2.3.4.10.IO-her.chloro-
6.7-~ory-I,4.4a.S.6,7.8.
8.-octohydro-I.4-~ndo
rndo-S.8. df~thanon-
.phthal~ne
A cyclodtpnP tnsectlcld~
used on cotton ftplds and
vegetable crops. and as .
rodpnttcfde agatnst ._tc~ and
ch I pIIunk s .
C.n 1M- "'sortt~ througfl tlMo
skin. tntPstlon or Inh.l.tlon.
Acutp .ffects Includp t~rs
of tht htad .nd nPCk 8Uscl~s.
tonic .nd clonic conyulstons.
cardl.c or ~splr.tOrJ f.tlu~.
.nd dNth. Chronic ~ffKts
Inclu~ h~.tlc d...,.. c8tr.1
nervous syst.. dp9Pn~r.ttoft.
.gr.nulocltosls. ~rtII.tltls.
wp.knPss. convulstons. co...
.nd ~.th. C.rctnog~ntc .SSIIS
a~ Inconclusly~.
Att.ch centr.1 nPrYOUS syst....
IIY~r. 'ldReYs. sktn and
perlph~r.1 n~rwous slst...
Absorbed frG8 the 'Istrotnt~s-
tlnll tr.ct .nd tr.nsport.d to
tht blood. brain. .nd IIY~r.
Tortc SJIIPto.S tMlu~
hud.cht. dlnlnPss. nauw..
..Its.. Yo.ltlng. .uscle
twttchtng. .,oclonlc Jerts .nd
convulstons. Oth.r SJIIPtC8s
c.n Includp Stl8UI.tlo~ hIP~r-
.ctlytty. tntortcatton .n~
dep~sston. A sllspKt~d
carclnogln.
C.n ~nt~r body thro89h
Inh.l.tlon. Ing.stlon. or
.bsorptlon through th~ skin.
Att.cks thP Ityer .nd centr.1
nervous syst... Acute ~ff.cts
Inrlude headachPs. dt"tness,
abd08tnal dtSCOMfort. nausea.
vP8tttng. InsOMnta, -ental
confusion. epllppttfo~
conyulslons, stupor. and dpath.
-------
TARtt J
KNOW OR SUSPrCT£O RISleS OF' COIITMIIAIITS
AT Tit( WOOORURY CH£MICAl SITE
(tONT '0.)
Cont.tn.nt
Chelltca1 Fo,.e
Rfltsb
T,p. 0' Mltert.l
8HC
.lph.-. bPt.-. dPlta-. g....
tS08Prs of he.achloro-
c,elohe..ne
TOXipttene
C08pOsed 0' A .t.ture of
ca8phpn. dertyattyes
.
-
N
,
lnsecttctde uspd to control
tnspct.s on ltypstock and ppts
as wpl1 as ltcp. 8OSquttoS.
and fltes rest stant to ooT.
Also used for -.dtctna1
purposes tn ya,ort,.rs.
cre~rs. lot tons. .nd
shlllpOOS
Chlortnated hydroc.rbon
tnsl'cttc tde
hpo.... lIlY oct.... ....l1y.
or.lly. or through tnhal.tton.
S,.,t08S ...sulttng 'r08 oyer-
..,osu", tncl ueIP s.tzu...s.
8Usc1e SPIS8S. w.kftPSS
conyulstons .nd. tn t~ 80St
sev.,.. c.s.s. df'.th. Oth.r
S,.,t08S tnclu'" 1 t..r .nd
ktd"", .nd pancre.s dI8Igp.
8Usc1. ftPCrosts. v08tttng. .nd
....dlChf's . 8HC ts08f'rS h.y. .
bHft dete..f...d to P",Sflnt .n
tnc....s.d c.ncer rtsk.
C... "ter body tllro.
t"'"tton. tnhal.tton. or
sktn .bsorptton. AttlCks the
cf'fttr.1 ...rvous s,stell.
Acute re.cttons tnc1ud~
saTtv.tton. Sp.58S. nlUse..
Y08tttng. ~e",.ctt.bt1tty.
trt'80rs. convu1stons. .nd
t.t.ntc conyu1stons 0' .11
skelet.l 8Uscles.
,.tlto1ogfca1 effKts 0' leut.
potsontng constst 0' petf'Chtal
(S' t n or 8ICOUS IIf'8br.ne)
hf'80rml9f's .nd conges t t on t n
the br.tn. lungs, sptnal cord,
he.rt, .nd tntestt...s.
Pu18OMr'J Pd!8. Inutd on the
1ungs) .nd foca1 .relS 0'
d~nPr.tton tn the br.tn .nd
sptn.l cord can .150 c.n bP
e.pPCtPd. Chrontc .ffp.ch .r.
1f.ttpd to cpntr,1 nPrYous
s,st.. ..cftatton And 1fYl'r
dpgrftpratfon. Data on
carcfnngpnfty are fnconc1usfYP.
: Chellfc.1 fonaa prpsl'ntpd as synon,. or equfya1l'nt.
Dl'tpnafnpd as a carcfnoqrn by N~tfon.1 CanCl'r Instft.
IIU8.n ~nfces IU!lDHH~), or IARr..
'I, EPA. U.S. Oepart..nt of Hp,1th and
t
00_.
-------
.'
Elevated levels of arsenic were observed on-site. Arsenic levels
above background were observed in some off-site soils. Soil boring
samples gave no indication of elevated inorganic constituents in the
soil at depth on the site.
o Sediments: Pesticides were detected in samples of drainage ditch
sediments in the 1984 and 1985 studies, on- and off-site to
approximately 1,200 feet west. Pesticide contamination at these
locations are likely a result of movement from sources on-site.
Possible off-site sources other than Woodbury also could account for
pesticides observed. Elevated levels of arsenic were observed in
the drainage ditch sediments on-site. No inorganic constituents
were found above background levels in the off-site downstream
drainage ditch sediments in either the 1984 or 1985 sampling.
o Ground water: The hydrogeology'of the area is characterized by
unconfined aquifer conditions in the alluvium and confined or
semi-confined aquifer conditions in the underlying Denver and
Arapahoe Formations.
The confining layers of shale and claystone are occasionally
discontinuous in both the Denver and Arapahoe Formations. Field
investigations indicate that the watertlble is 20 to 27 feet below
the ground surface at the site and that the saturated zone of
alluvium is approximately 10 feet thick. A confining layer is
indicated at 30 to 35 feet.
-
The ground water level has been rising in recent years in response
to urban development in the area. This rise is expected to continue
into the next century.
Earlier investigations (prior to 1984) found no pesticide
contamination in wells which tap the unconsolidated alluvial
aquifer. However, in July 1984 pesticides were found in two of the
five wells monitored (MW3 and MWS). Dieldrin (0.3 ug/l) and 4'4'
DDT (0.2 ug/l) were observed in MW5 and dieldrin (2.2 ug/l),
alpha-BHC (0.2 ug/l), beta-BHC (0.2 ug/l), and delta-BHC (0.2 ugfl)
were observed in MW3. In November 1984, pesticides were observed
only in MW4 (dieldrin, 0.17 ug/l, delta-BHC, at 0.06 ug/l) and in
the blank sample (gamma-BHC, 0.11 ug/l).
Pesticides observed in the ground water at on-site wells in July
1984 were not found in the ground water at the same wells in
November 1984. This observation indicates that pesticide
contamination in the ground water is limited, and may be affected by
a discontinuous source, a limited size of the plume, or possible'
sample contamination.
The nearest downgradient well completed in the surface aquifer is
0.5 miles away to the northwest. Several organic solvents (TCE and
others) were observed in most of the ground water samples,
reflecting the general low-level .contamination of ground water in
the Commerce City area. Sampling results indicate that elevated
levels of arsenic, lead, and zinc were present in 1979 in the soi1
-------
on-site. However, these inorganic contaminants do not presently
appear to be migrating from the site.
o Surface Water: The surface waters at the Woodbury site consist of
1.nterm1 ttent storm runoff, which f1 ows through the site via three
major drainage channels before emptying into a retention pond 0.5
miles west of the site. Major waterways nearby include Sand Creek
0.5 miles northeast of the site, and the South Platte River 1 mile
to the northwest.
The major inorganic constituents observed at elevated levels in the
surface water appear to be as high upstream or on-site as downstream
in the drainage ditch. This contamination may be attributable to
industrial sources upstream. The 1979 investigations indicated that
surface water in the drainage ditches was contaminated by
pesticides. The highest concentrations were for DDT (25.3 ug/l) and
malathion (30.3 ug/l). Endrin « 4.2 ug/l) was observed to exceed
its primary drinking water standard of 0.2 ug/l. One water sample
was collected in 1979 from the stormwater retention area located
ipproximately 3,000 feet west of the site. Dieldrin, endrin, and
DDT were detected in the range of 0.15 to 0.3 ug/l. .
The 1980 study did not reveal any detectable levels of pesticides. .
The 1982 sampling resulted in concentrations of arsenic, cadmium,
lead, and chromium above primary drinking water standards at various
locations upstream of, downstream of, and on the site. DDT was -.
detected (in the 1982 study) in one sample at a level of 4.15 ug/l.
No other pesticides were detected in the surface water samples
during 1982. In the 1984 study, several surface water samples were
taken. Lead was the only element found in all seven samples at
concentrations above the 50 ug/l primary drinking water standard.
Cadmium exceeded the 10 ug/l primary drinking water standard only at
the upstream sampl e.
...
The highest levels for all of the major inorganic contaminants were
observed at two upstream sample locations. The results of the
analyses for organic constituents in the surface water indicated
little contamination by pesticides. Dieldrin, endrin, and 4'4' DDT
were observed at concentrations of 0.2 ug/l. The level of endrin is
equal to the primary drinking water standard. .
.
The closest ~sidential area is a mobile home park about 0.3 miles to the
southwest. The population within 1 mile of the site is approximately
3,000. The nearest downgradient well completed in the surface aquifer ~s
0.5 miles to the northwest. The ground water use in the area is projected
to increase dramatically over the next 30 years. The South Adams County
Water and Sanitation District presently serves the undeveloped portions of
the northeast Denver area. The district currently operates approximately
12 alluvial wells and 8 bedrock wells, some of which are within a one mile
-14-
........ ..-. .,~. .' .-". . ...'.
-------
0"
distance from the site. These wells currently serve approximately 30,000
people. Several new wells have been proposed and the district anticipates
a service area of 150,000 people within the next 30 years. As stated
earlier, the South Platte River is downgradient from the site. The river
serves as a source of recharge to alluvial aquifers that are presently used
for pUblic water supply for northeast Denver.
Enforcement
Region 8 has determined that the possibility of participation by
potentially responsible parties in the project is minimal. Woodbury
Chemical Company was a family owned company at the time of the fire in
1965. Subsequent to the fire and the placement of the fire debris in its
current location, both the Woodbury Chemical property and company were sold
in separate transactions to separate parties. The company ultimately was.
sold to Farmland Industries. The Woodbury Chemical Company no longer
exists. As for the property where the debris is located (the CERCLA site)!"
the owner at the time of the fire was Chicago, Rock Island, and Pacific
Railroad. In 1975, the railroad filed for reorganization under the
Bankruptcy Act. In June 1984, all of the assets of the railroad were
liquidated and the Woodbury property was sold to the Colorado Eastern
Rail road Company as part of a 1 arge transacti on. Colorado Eastern is on
notice of this project, but has indicated that it does not have the
financial resources to participate in the project. Both Colorado Eastern's
and Farmland Industries' liability will be evaluated further when the
Agency reviews its cost recovery options at the end of the prOject.
....
.
Because there is little likelihood of participation in the project by a
financially vi~ble PRP, EPA assumes that the Hazardous Substances Fund
(Superfund) be used to finance remedial action.
Pollutant Limit Value
To establish a basis for determining an effective remedial action,
pesticide cleanup levels were evaluated and delineated based on the
following considerations. The results Of prior field investigations show
-------
several areas of significantly contaminated material covering or adjacent
to less contaminated materials (i.e.. Uhot spotsM). The range of
concentrations across the site is large. from below detection limits of the
analytical equipment to up to 151.515 ppm. The higher concentrations were
in samples from rubble piles and it is these piles and adjacent
contaminated soils that present a hazard to the human health and the
environment. Once contaminated soils are removed or controlled down to a
certain concentration level. the EPA assumes th,1s 1'threa\{ ~e .~~ed. :;=~ ~~, . '1
, , t w ~" t W -',' ,',W.~ '~:.',' +~:
, ~'5:~; :' ~....':' ~'~, '
The pesticides present on the Woodbury Chemical Si te are those that Wfte' ," 'fti' '; ,
available for use in the urban environment during the 1960s through the "~,
mid-1970s to control a variety of pests. Residual soil concentrations
(i.e.. pesticides remaining in soils following application) were detected
in the so11s of most u.s. cities during the 1970S.",:1 rev-ie~~(;'the..;",~~",~_. i.,Jf')e,
literature indicates no adverse health or environ~ental eff,cts'from " ~~'!':
residual,~p.,~}iC.i'~$i-tl- &(r~9 ~l1S1~\,TA~"'fl:!t-6l-~'.&.w:\n.':-' e..i,"', .~:='::. ' .:",:
used to select the appropriate residual pesirt'Tfe 't~rat 0 :.'" pro 0 -e, ,." ~ ",' .
Pollutant Limit Value - PPLV). for cleanup of the Woodbury st :~ : ..' ~,,";!" :.,
1) , .TYP1cal~,Residua,l Soil concentr~ti,~~~S ln~, .''','' ,,-~"'" ~'~,
2) 'f,RtRA :S~4is fii'.. ~ f~,~" iI~;\4 J, ~1 " '
3) Potentia ,... Cancer 'Risk "', .'~. " ~L- :-" , -if' '. ,,~~, '. '..~, '
, ,',,,,,, '
. , '~"..r~ '1M
organochloride compounds were found below a depth of 5 feet.. ","1#'.......~ ,i~.r,
. . .. 10 . . . :(' " .
, ..".>-~ .." f -ii' \.." ,..~:'..
.. ,~, ~ ,'!!', ,
. ! ~
, .~>i
Residual $011 Concentrations - Summary data for the period 1969-1976 from
the National SOils Monitoring Program were used to develop the pesticide
cleanup level. Five cities with sufficient urban soils data were selected
to represent a western or Great Plains urban environment: Cheyenne. WY; ,
Salt Lake City. UTi Manhattan. KS; Sioux City. IA; and Bakersfield. CA.'
Specific data for the Denver urban area are not available. For each of the
, five cities. data on chlordane. heptachlor. heptac.hlor epox1de. dieldrin.
endrin. toxaphene. and total DDT (DDT+DDE+DDD) were obtained. Aldrin data
'were not available for these five c1t1e~.therefore data from Cary!!!!
-16-
-',
"
. ."
".:...;:...
"" ';!J~~:' ~'\:1~rJ;~:tr.~;::~~
. ,,'.,.,
'I,~'~~:;:
<. .'
.. .._...-_--~._...... --..--.-----...'-" .,- .
-------
"
(1979) were utilized. The National Soils Monitoring Program did not
monitor lindane so data from Edwards (1973) were used to establish a
baseline for this compound.
The results of the data review are presented in Table 4. This table sums
the ranges of minimum. maximum. and mean values for the pesticides of
interest and shows values of 0.08-0.90 ppm (minimum). 10.74-51.04 ppm
(maximum). and 0.33-2.46 ppm (mean). Maximum values were dropped from
consideration because these values resulted from abnormally high
applications of pesticides.
After consideration of the range of residual pesticide concentrations in
soils. the value of 3.0 ppm was selected as a reasonable level for a
criteria cleanup concentration for total pesticides. This value was
selected because it appears to typify an average urban total pesticide soi~
concentration based on the data reviewed.
-
...
RCRA Standards - The cleanup value of 3.0 ppm represents the total residual
pesticide concentrations in soil. By volumetric calculation. the 3.0 ppm
pesticide concentration will result in 5.0 Kg of total pesticide remaining
on the 2.2-acre site. Utilizing this volume. the potential delivery of
pesticides to the alluvial aquifer (at 20 feet) was calculated. The bases
for the calculations are as follows.
o Relative Concentrations of Pesticides in the Soil. From past
analytical results toxaphene was found to comprise approximately 90
percent of the total pesticides. chlordane approximately 3 percent,
and all others 1 percent or less. '.
o Solubility of Pesticides. The values were taken from published
data ~nd were selected and utilized to represent the most realistic
conditions.
o Pesticide Half-lives. Values from current literature were obtained
for the half-life for each pesticide. These values were integrated
with the calculated travel time to estimate degradation.
o Recharge to Site. This constituted a water balance that considered
net precipitation and permeability of the soil. Modified Darcian
equations were used to estimate recharge.
-------
" . ..., .
.",:
TABLE 4
SUMMARY OF URBAN SOIL, PESTICIDE DATA USED TO SELECT THE PPLV FOR THE
WOODBURY CHEMICAL SITE
(Values ug/g)
Ranges of Values
Chemical Minimum Maximum Mean
Chlordane 0.01-0.30 0.15-20.48 0.02-0.78
Aldrin 0.01-0.03 0.64-2.04 0.01-0.02
Dieldrin 0.01-0.01 0.06-4.17 0.01-0.12
Toxaphene 0.01-0.37 9.57-12.07 0.24-0.45
Heptachlor 0.01-0.02 0.09-0.24 0.01-0.01
.Heptachlor epoxi de 0.01-0.05 0.06-0.44 0.01-0.03
Endrin 0.01-0.06 0.03-0.06 0.01-0.01
DDT sum (DDT+DDE+DDD) 0.01-0.06 0.09-10.08 0.01-0.78-
Lindane NA 0.05-1.40 0.01-0.26
TOTAL 0.08-0.90 10.74-51.04 0.33-2 .4~ .
Source:
Aldrin - Carey et al. (1979)
Lindane - Edwards (1973)
All others - National Soils Monitoring Program (unpublished data)
-------
- .
o Dilution by the Alluvial Aquifer. This factor was considered in
the delivery calculat10ns and included such characteristics as
permeability, transmissivity, and storativity.
Empirically-derived adsorption equations were used to calculate the
concentrations in the water within the alluvial aquifer at the site
boundary, at a soil concentration of 3 ppm. Concentrations were calculated
for toxaphene, chlordane, and dieldrin, as these materials represent
maximum concentration (toxaphene-90'), relatively high concentration
(chlordane-3'), and concerns over toxicity (dieldrin-cancer risk). For
comparative purposes, similar calculations were made for soil total
pesticide concentrations of 1 ppm, 5 ppm, and 10 ppm. Table 5 shows each
of these thre~ pesticides, water quality criteria (refer to Table 5 for
definition of water quality criteria) and cancer risk, soil pesticide
concentration levels, and calculated concentrations of each pesticide in
the alluvial aquifer at the site boundary.
Of the three substances, only toxaphene has a specified RCRA concentration.
-
RCRA standards allow for "a toxaphene level of 0.005 mg/l at the point of
compliance (i.e., directly outside of site boundaries) [40 CFR
264.94(a)(1»). The calculated water concentration of 35 ng/l at a 3 ppm
soil pesticide concentration is more than two orders of magnitude less than
the RCRA concentration limits. "
..
Potential Cancer Risk - Review of Table 5 indicates that cleaning to a 3.0
ppm residual pesticide concentration in the soil will result in a minimal
impact to the underlying aquifer. The EPA document; uGuidance on
Feasibility Studies on CERCLA, II (rel eased June 1985), suggests a 10-6
target cancer risk factor while allowing an acceptable range of cancer risk
factors from ~0-4 to 10-7. Contamination from two of the three pesticides
of concern (chlordane and dieldrin) will be attained to the target leve1 of
acceptable cancer risk (less tha~ 10-6). Toxaphene, at 3.5 x 10-5, is ~el1
within the acceptable range of cancer risk levels of 10-4 to 10-7. 1n
addition, research data on the carcinogenity of toxaphene have not
conclusively proven it ;s a carcinogen.
-------
TABLE 5
COMPARISON OF SOIL CONCENTRATIONS WITH PREDICTED GROUNDWATER CONCENTRATldNS
FOR TOXAPHENE, DIELDRIN, AND CHLORDANE
Pesticide
Risk Evaluation Criteria
Ground Water I.pact Eval~ation
Resul ting Pesticide
Concentrations in
Water in Al1uvtal
Aquifer at
the Si te Boundary (ng/l )
After 50 Years
Water Qua1tty
Criteria*
Residual
So11 Pesticide
Concentration
After Remediation
Ri sk Factor
, .
N
o
,
Toxaphene
Dieldrin
Chlordane
11.0 ng/l 10-4
1.1 ng/1 . 10-5
0.71 ng/l 10-6
4.6 ng/l 10-5
0.46 ng/l 10-6
1 pp.
3ppm
5 ppm
10 ppm
12.0
35.0
60.0
120.0
-11
5.3 x 10_16
1.6 x 10_16
2.6 x 10_16
5.2 x 10
-4
4.4 J( 10_3
1. 3 x 10 3
2.2 x 10-3
4.4 J( 10-
1 ppm
3ppm
5 ppm
10 ppm
1 pp.
3ppm
. 5 ppm
10 ppm
0.11 ng/l
0.011 ng/1
10-5
10-6
1
!
* This terM represents a non-regulatory, scientific assessment of ecological and publfc
heal th effects of the poll utant in any body of'.water " fncl uding groundwater. (" Ambient
water quality criteria for Toxaphene-, Document No. 440/5-80-076, October 1980).
-------
- -
. .
Proposed Pollutant limit Value - Based on the above analysis, the 3.0 ppm
cleanup level for total pesticides will provide a conservative, yet
realistic, level of cleanup for the Woodbury site. However, due to the
significant hazards posed by aldrin and dieldrin, limit values were set for
these pesticides. The literature shows a 1.0 ppm non-lethal biological
activity level for aldrin. Comparable data are not available for dieldrin.
but because it is considered more toxic than aldrin, a limit value of 0.5
ppm has been set for this pesticide. The same limit value has been set for
aldrin because it breaks down to dieldrin. Limit values have not been set
for the remaining pesticides as long as the total soil concentration does
not exceed 3 ppm.
Alternatives Evaluation
Based on the selected PLY. the following objectives have been developed fo~
this site:
-'
.
1. To minimize the potential for human or wildlife contact with
contaminants at the site.
2. To minimize the potential for the contamination of surface waters
and surface sediments in the drainage ditches at and adjacent to
the site. Contamination of the off-site ditches is caused by
release of pesticides from the CERCLA site.
3. To minimize the actual or potential downward migration of
pesticides into alluvial ground water.
With the exception of the No Action alternative, source control
alternative~ involve actions (capping and landfill) that would require
land-use restictions and continued monitoring programs in compliance with
RCRA regulations, and long-tenm operation and maintenance. The
contaminated soils and sediments are considered to be RCRA wastes and must
be dealt with according to RCRA regulations. Source removal alternatives
involving permanent cleanup solutions would not require major land-use
restrictions. long-tenm monitoring, nor long-tenm operations and
maintenance. The following alternatives were considered:
1. No action
2. Land use restrictions/continued monitoring only
-------
3. Regrade and revegetate only
4. Excavate ditch and pond as necessary and dispose offsite/RCRA clay
cap/revegetate
5. Excavate ditch and pond as necessary and dispose onsite/RCRA clay
cap/revegetate
6. Excavate rubble and contaminated 50ils 6 to 10 inches. ditch. and
pond as necessary/incinerate/backfill/revegetate
7. Excavate site (30 foot depth). ditch. and pond as
necessary/incinerate/backfill/revegetate
8. Excavate rubble and contaminated 50ils 6 to 10 inches (up to 10
feet in isolated areas). ditch. and pond as necessary/dispose
offsite/replace with clean material/revegetate
9. Excavate site (30 foot depth). ditch. and pond as
necessary/dispose offsite/replace with clean material/revegetate
10. Construct RCRA on site landfill on site/excavate 5011s and ditch.
and pond as necessary and dispose onsite/clay cap/revegetate
11. Excavate off site ditch and pond as necessary and dispose
onsite/biological in-situ treatment/RCRA clay cap
-
...
Off-site disposal alternatives (Alternatives 4. 8. and 9) include landfill
disposal and incineration of contaminants. The alternatives listed above
were screened in accordance with 40 CFR Part 300.68 (h). in order to reduce
the list of potential remedial actions for 'further deta11ed analysis. The
criteria used in the initial screening process included: (1) total system
costs. considering net present value of capital as well as operation and
maintenance costs, (2) effects of the alternative upon the environment with
eval uati on of whether the al ternatiYe wi 11 achieve source control and
mitigate threats to public health. welfare. and the environment, and (3)
acceptable engineering practices with respect to feasibility and
reliability for addressing the problem.
Using these criteria. a number of the alternatives were eliminated.
Alternatives No.2 and 3 were eliminated because they would not provide
adequate environmental or public health protection. adequate source
control. nor mitigate offsite migration of contaminants. They also would
not provi4e a reliable means of addressing the problem, thus not meeting
the requirements of CERCLA. Alternative 4 was eliminated because it would
be more costly than Alternative 5 without providing a significant increase
-22-
-------
in protection. Alternatives 7 and 9 were eliminated because they would be
much more costly than Alternatives 6 and 8. respectively. without affording
a significant increase in protection. mainly because all available data
indicate that severe contamination occurs near or at the site surface. with
only trace amounts detected in subsurface soils. Alternative 11 was
eliminated primarily because its selection would be inconsistent with the
National Contingency Plan (NCP) requirements regarding the use of
demonstrated technology. To date. this technology has not been proven to
be effective for a complex mixture of pesticides. Therefore. Alternatives
1. 5. 6. 8. and 10 were retained for futher detailed analysis. Alternative
1 is the no action alternative. Alternatives 5 and 10 are on-site source
control measures. Alternative 8 is an 'off-site disposal alternative. and
Alternative 6 is an on-site source destruction alternative.
The remaining alternatives (Alternatives 1. 5.6. 8 and 10) were subjected.
to a detailed analysis using the criteria outlined in 40 CFR 300.68 (i).
The main factors used to evaluate remaining alternatives are: (1) the use -'
of established technology; (2) cost estimation including distribution of
costs over time; (3) engineering implementation and constructability; (4)
the extent to which the alternative is expected to effectively mitigate and
minimize damage to. and provide adequate protection of. public health.
welfare. and the environment. relative to the other alternatives analyzed;
and (5) environmental impacts of the alternative. as well as methods and
costs for mitigating those impacts.
The no action alternative (Alternative 1) is not considered acceptable
because of RQtential adverse health and environmental impacts. Existing
data indicate releases to surface .and ground water which may increase as
contaminants a~e slowly leached from the source piles. The rubble piles
are not vegetated indicating toxic reactions to plants. Selection of this
alternative would therefore not prevent human. animal. or plant life
exposure to contaminants. and would allow continual release of contaminants
into the food chain. surface. or ground water.
After screening. four design alternatives (Alternatives 5. 6. 8. and 10)
were developed for detailed analysis. However. two additional
-------
.'
8Odifications to Alternative 8 were considered, resulting in six final
alternatives. For each alternative, a descriptive figure is provided
showing conceptual design features, a task flow diagram, and a summary of
.aterial moved, construction costs, and operation and maintenance (O&M)
costs. Each cost includes $231,000 for design and Corps supervision. A
brief description is provided below.
Alternative A: RCRA Cap - This alternative involves excavation of 1,100 cy
of contaminated soils (500 cy) and ditch sediments (on-site ditches. 250
cy; off-site ditches. 350 cy) and consolidating all contaminants within a
400-foot by 125-foot (50,000 ft2) area. A RCRA cap consisting of 2 feet of
compacted clay, a flexible membrane liner (FML), and 2.5 feet of natural
soils would be constructed over the contaminated zone. Imported fill would
be required to backfill excavated areas, and provide the clay and soil
portions of the cap. Site drainage would be enhanced to prevent ponding
and directed flow which could result in excessive erosion. Figure 3
presents the construction sequence, along with summaries of quantities of - '
contaminated soils to be removed, and import fill requirements. The
present value cost for this alternative is $1,150,700 including 5252,000
for 30 years of monitoring and site maintenance.(I)
...
(1) Monitoring and Site Maintenance - RCRA requires the following
monitoring program: .
o Monitor a background (upgradient) well quarterly for one year.
o Monitor three downgradient wells semi-annually for 30 years, which
would require installation of two additional wells.
o Monitor leachate collection system (RCRA landfill) semi-annually for
30 years. '
Site matntenance will include fertilization and mowing of the
vegetation to assure complete revegetation and to prevent excessive
vegetativ~ growth which could hamper site drainage.
The cost for monitoring and site maintenance for each RCRA alternate
are summarized below:
RCRA Landfill RCRA Cap
Monitor Maintenance Monitor Maintenance
First Year S 27,600 S 5,000 'S 26,600 S 5,000
2nd through 30th yr. 104,400 .145,000 '75,400 145,000
TOTAL COST S132 ,000 S150,OOO S102,OOO $150,000
-24-
_... . - "":-1~""'" ..-..-.--.' ... --.
. ...... .-~. .. . .',... ,". '.
-------
.
N
U'1
I
Tr.",port to (PA
Approw~ Kll.rdOU'
Vntt' h"dfill
TASK flOW DIAGRAM
MDb""P. (qu'P8P"t. OPcO"t..,".tlo
F""'tt., Ut'lttt., Tr.tl.r
Rp....~tlt.. Sit..
EXCAVATE CONTAl8lATED DITCH ......
. RENA.JUTATE WITH CLEAN FILL
ACRA CLAY CAP
MOVE CONTAI8IATED IOILI TO MIA
TO BE CAPPED' 8ACKFU WITH CLEAN F'I.L
Or.!!!'t!.~~-
.~---
~.... .....
fI!I!!:......
.....- .
;;,
..
o
&
:I
:it
!!
!
j
:;;
~
~
EXCAVATE CONTA"'ATED DITCH 8EDlMENT8
. 8ACKFILL WITH CLEAN FILL
SITE PlAN
1" - 200'
StAWAAY
0II8IIIItJ of Cont......t8d 8011
....... .. C8P Ar..
Que... of ConI..... led. Mow'" 10 C8p Am
1144cy
toale.
.....,. AI..
loale.
'8.',700
. 212,000
J II.
I"""" c..~-,tIoII CollI
I"""" -....,. """"0111 CollI
TOTAL EITMATED COST
'l.t50.700
Figure 3 A"ematlve A On-S"e RCRA Clay Cap
,
CUl VEAf
1
o
cr
-=
.
cr
:;; J
~ &
~ r
~ ~
DECONTAI8IATtON FACtLITY
......., ~...
~- C"y. co
AL TEANA TIVE A
ON-81TE ACAA CLAY CAP
c..... ---.........
-------
. .
Alternative B: RCRA Landfill - This alternative involves construction of a
20,000 square feet (lOO-ft by 200-ft), double-lined RCRA landfill. All
contaminated soils and ditch sediments would be excavated, transported to
the landfill, compacted in place, and the entire landfill then covered with
A RCRA cap. Imported fill would be required to construct the lower clay
barrier of the landfill, the clay portion of the RCRA cap, and to provide
fill for areas where excavation of the contaminated soil occurs. Site
grading would be designed to prevent ponding on or adjacent to the
landfill. Figure 4 presents construction sequences and quantity estimates.
The estimated present value cost for this alternative is $1,542,000
including $282,000 for 30 years of monitoring and site maintenance.(l)
Alternative C: Offsite Disposal - The off-site disposal alternative
(Figure 5) requires that all contaminated soils and ditch sediments be
excavated and transported to an EPA-approved hazardous waste landfill.
Three such landfills have been identified within a l,OOO-mile radius of th~.
Woodbury site, including landfills in Nevada, Idaho, and Louisiana. The
contaminated soils would be transported in bulk in Department of
Transportation (DOT) approved vehicles permitted for hazardous waste
transport. Imported fill would be required to reclaim the site and
ditches. An estimated cost of 52,313,000 would be required for this
alternative, including $21,000 for operation and maintenance.(2)
..
Alternative D: Offsite Incineration of Rubble Offsite Disposa' of
Remaining Contaminated Soils - This alternative (Figure 6) provides for
destruction.of the most highly contaminated rubble by transporting to an
EPA-approved incineration facility and incinerat1pn of the waste.' The
remaining SOi\5 and ditch sediments, and site reclamation would be handled
(2) Monitoring and Site Maintenance - For the disposal or destruction
alternatives (Alternatives C through F) monitoring and site maintenance
requirements will be limited to a three year period to: 1) verify that
no additional ground water contamination is occur1ng and 2) to assure
that the revegetative efforts take hold.. The cost for this effort is
S2,OOO/year for monitoring and SS,OOO/year for site maintenance, a
total cost of S21,OOO for the first. three years after remediation.
-26-
-------
TASK flOW DIAGRAM
EKCAVAft COMTAl8lAtED DffCH 8ElJ8i88T8
I REHA8IUT A TE DITCH WITH CLEAN F1LL
I'Dbtlt,. (QUI...nt. OKontltltllltion
'.(llltl.s. UtIlities. 1r"I.r
,
N
"
,
.'
EXCAvAte CONTAI8IATED 808.8. D. 081: AT
ON-8Ift LANDFILL I 8ACICFIU. WITH EXCAVAtED 8011..8
CONSTRUCT ON-.ITE ACIIA LAIIDFIU.
8". ~_... 0_.
t
o
or
..
.
a:
i
f
J
.a
DE A--noN FACILITY
EXCAVAte CONTAM88AftD DITCH 8£.....,..
I 8ACICFIU. WITH CLEAN FlU.
;;. :;
I v
!
j ..
J
.;;
~
i
x
SITE PlAN
,00 - 200.
'r'ftpclrt to (PA
-.,prowed IIlllrdovs
!lAste Llndflll
SUMMARY'
QaIIIIIy of CallI"""" ....
...... to l"""
. "Ie,
au..ety of Cant......... ...........
Mow" '0 land..
'olee,
~ a8IICAL...
~18C8 ern. co
E"""'" ~._.. C88I
E"""""". -....,oell C.
. '.280.000
. 212.000
Al TEANATtYE .
ON-8fTE RCRA LANDFI..L
TOTAl ESTIMATED COST
. '.142.000
c......... "...18C
Figure 4 Alternative BOn-Site RCRA Landfln
,
-------
'1
,
,',
j
,
,
,
j
.:;OJ .
TASK FLOW DIAGRAM
I
N
00
I
Pro.,1 dp lonq ,~...
NDnllorl"9 . ",tnl~".n(~
0' \I'~
Figure 5
EXCAVATE COIITAI8MTD DlfCH ........ I
REHA8lLITATE DlfCH WITH CLEAN FU.
IEXCAVAtI! COIITAI8IATD Dn'CH ...."'.
I 8ACKFU. WITH ClEAN FILL
lite Pf-.. ......,
.......
.=--
r--
,
.
l~. ~
!>.... "......
cii
J
CUUfA'
]
;z
..
~
%
cii
!!
11
]
u;
.;;
~
t
~
=.
~
EXCAVATE COIITAMWATED IOILI. TRAJIIItOItT
TO EPA APPROVED LAMDFU FOR DISPOSAL I
AEHABILITATE liTE WITH CLEAN FILL
SUI8IARY
DECOIITAIMATION FACILITY
SITE PlAN
." - 100'
8710Gy
0II8n8II9 .. Cant..............
........ .. ........ Oft ...
0II8n8r" W"" DII.a,"
....... .. AI" I . ~..
~I*"" ~I 1"_'" C88I
IE"""" 3 -Jr. """"'0111 CcI8t
- 0-
1"0.:,
'2,.11.000
. .'.000
WOC88IIW ~...
CVI'--=a an, co
ALTERNATIVE C
OFF-SITE DISPOSAL
CDM
TOTAL IE.TlMATED COlT
atlve C Off-Site Disposal
,
'2.313.000
-------
TASK flOW DIAGRAM
I
N
\D
I
Figure 8
'f'O.'d' '0'" f,r.
...,..1t8r"" . ",,,"~"C,
n' \.t,
EXCAVAte CONTA_ATID DITCH ...."',
a REHABLnATE DITCH WITH CUAN FlU.
EXCAVAte CONTA8IATED lOll"
DISPOSE AT EPA APPROVED LANDAU.
AND IACtCFI.l WITH IMPORTED CLEAN FLl
.... "'-" ......"
CUlVERT
i
;;; ;;, J
.;;
. 9 ~ 5
o ~ r
, ~ i
J '-' r ~
'II
EXCAVATE HIGHlY CONTA"'ATED "HOT. SPOTS" WHEM
PESTICIDE CONCENTRAnoNS ARE > 100 '*' .
TRANSPORT TO ItCWERATOR a DESTROY
DECOIITA8lATION 'ACLITY
EXCAVATE CONTA"'ATED DITCH SED8IIE"'S
a BACKFLl wnH CLEAN FLl
SITE PlAN
1" - 200'
SUlAtAAY
o.enettr of CollI""""" 8011
...... .. l8IICIIII 0" SIte
0II8IIeItr of w.... D88t1....
I4l0oy
flOc,
"'0oy
82"'0.000
8 21,000
Al TERNA TE D
on:-SrTE DISP08AlIINCtNERA TIOII
OF WORST MATERIAL
..... .. AI.' IIRIIIIa
~ CI88CAL II1'II
....-..... eny. co
E..-.... CoM"''''' Coat
E.-..... a~. .....,oa.. ColI
TOTAL ESTIMATED COST
".., 1.000
c... --........
CDII
Alternative D Off-Site Disposal/incineration of Worst Mater'a'
-------
identically to Alternative C. The estimated pre~ent value cost for this
alternative is $2.471.000 including $21.000 for monitoring and site
maintenance.(2)
". '.
Alternative E: Offsite Incineration - Offsite incineration. presented
schematically on Figure 7. follows the same construction sequence as
Alternative C. The contaminated soils and ditch sediments would instead be
transported to an EPA-approved incinerator facility. At this time, only
one such facility within an 1.1oo-mile radius of the site is equipped to
handle contaminated soils in bulk. This facility is the ENSCO incinerator
in El Dorado, Arkansas. The estimated present value cost for this
alternative is $9,158,000 including $21,000 for monitoring and site
maintenance.
Alternative F: Onsite Incineration - This alternative utilizes a mobile
soil incinerator, located onsite (Figure 8). Contaminated soils and ditch
sediments would be excavated, incinerated, and the residue utilized for
backfill. At this time, other than the EPA mobile incinerator, only one
mobile incinerator is in operation with a limited permit for hazardous
waste incineration. This unit is operated by ENSCO a~ El Dorado, Arkansas.
The estimated present value cost for this alternative is $5,613,000
including $21,000 for monitoring and site maintenance.(2)
Community Relations
Community interest in the project has been very limited through June 1985.
The three week public comment period for the Feasibility Study and
Alternative.Selection (March 11 - April I, 1985) did not generate a single
comment from ~ny members of the public. Fact sheets were mailed to persons
identified in EPAls Community Relations Plan, and a newspaper article as
well as a public notice were published in a major local newspaper to draw
attention to the public comment period. The only interest generated ca~e
from a few surrounding industries that were interested in receiving copies
of the final RI and the draft FS. Those copies were mailed out, and no
further comments were received.
-30-
-------
TASK flOW DIAGRAM
-
w
....
-
Prowld. long ,.~
Monitoring I ~int.nln(.
nf ~"..
EXCAVATE COIITAllllATID DITCH 1ID8I!1fT8 .
REHA81L1T A TE DITCH WITM ClEM F1U.
IXCAVATI COIITA...AftD 8OIL8. IICMItAft AT
EN APPROVED OFF-lITE 88ClNEAATIOM FACILITY,
. ..CKFILL WITM ..-oATED CLEAN FILL
,. ...---
..- -1.:,0';""''''
.n
.n
II
r
j
.n
~
~
[
!
I
EXCAVATE CONTA"'ATED DITCH 1EDlMENT8
. BACKFILL WITH CLEAN FILL
DlCOIIT A--TION FACILITY
SITE PlAN
tOO - 100'
SUMMARY
a...etIJ aI CuftI&JIIIII8t8d ScIIII
Mowed .. L8ndIII Off ..
-0-
~ aI ..... D..IJlaw"
..... .. AI...A Jill Jn18
'flOcl,
InOC,
... t37.ooo
. 2t,ooo
~ CII88KAL...
........~ Cfn. CO
.......... c-..-:... C888
.......-. 8 -yr. """'0111 CcI8t
ALTERNATIVE I
OFF-lITE INCINERATION
TOTAL IITIMATm COST
... "1.000
c~-_......~
CDM
figure 7 Alternative E Off-Site incineration
-------
'~
. i
..
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. ,
j
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j
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.. ..1
. . ~
'J
'<
TAlK flOW DIAGRAM
1
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N
I
. ,t '.;"
figure 8
'XCAVATE COMTAI8IATID Dm:8I ...... .
RE...8LITATE DITCH WITH I8C8mtATIOII REIIDUI
'XCAVATE COMTAI8IATID lOlL"
"'RATE. . 8ACKFU. WITH --
.... P'_I, 1_."
CUI. V£A'
f. ..-....
P'" .'.=,;...."
.;;
u; u;
~ ~
. .
~ E
3
I
'XCAVATE COMTAl8lATID DITCH 8ID8IINTI
I BACKn.L DlTCHEI WITH CLEAN BACKF8.L
COIIITRUCT tlO' / tlO' ~AD
FOR INCINEAA 110M UNIT
SITE PlAN
t" - 100'
SUMMARY
G88nIItw 08 CottI....... 8011
--8d to L"'" Off Me
0II8nIIIw 08 We'" De....811
-0-
I7tOcy
810cy
88.112,000
8 21,000
~ Ct8I8:4II. 8ft
~ttC8 ern. co
AL TEAltA TIVE F
OM-IITE INCIlEAATIOII
..... .. 1fl It' 1l1li1 ..
EIItIItt8t8d ~1N..8f~'" Co8t
......... I~. """"'0111 Co8t
TOTALIITIllATED COST
85.813,000
r~_....--..
CDM
tv. F On-Sfte incineration
-------
Community and agency interest may increase during mid-1985 as the ROD
documents are finalized and a remedial action is initiated. A revised
mailing list of local, st~te, and federal agency contacts, local
industries, interested nearby residents, and others will be developed. and
periodic mailings by EPA will be instituted to inform these parties of site
activities. This coordination and information transfer is especially
important in view of the proposed NCP revisions (February 12, 1985. 50 FR
5862-5932) concerning permitting and community relations for CERCLA sites
(see especially 50 FR 5866, 5904). A pUblic meeting is planned to brief
citizens and official s on the sel ected al ternative for the final remedy at
the site.
Consistency with Other Environmental Laws
All of the alternatives considered in detail would fully comply with
applicable Federal, State, and local environmental laws. EPAls off-site
pOlicy (1985) requires that any off-site disposal utilize only fully
-
permitted RCRA facilities in good RCRA standing. The selected alternative
will be implemented in full compliance with this policy. This compliance
includes Clean Air Act. Colorado laws (hazardous wastes. air emissions.
etc.) and local laws (landfill license). The off-site disposal
alternatives would also comply with Department of Transportation
regulations concerning the transport of hazardous wastes. The incineration
alternative would comply with Clean Air Act criteria. The recommended
alternative, described below will fully comply with all applicable
environmental laws. No waivers of compliance with other laws will be
required fo~ the selected alternative. No alternative concentration.
limits, as established by regulations, are sought.
..
The areawide ground water contamination problem (principally TCE) will be
addressed under several other NPL listings in the area. or possibly under
new site listings. EPA feels that it would be inappropriate to consider
mitigation of ground water TCE contamination under the Woodbury listing
because there is no evidence that the Woodbury site is a contributing
source of TCE. The recommended alternative would alleviate continuation of
the existing pesticide contamination problem beneath the site.
-------
ReCOMmended Alternative
According to 40 CFR Part 300.68(j), cost-effective 15 described as the
lowest cost alternative that is technically feasible and reliable and which
effectively mitigates and minimizes damages to and provides adequate
protection of public health, welfare, and the environment. Evaluation of
the six re.edial alternatives (Table 6) leads to the conclusion that
Alternative D is the most cost-effective in terms of elimination of
contaminants and long-term protection of human health.
EPA believes that, of the remaining alternatives, two (A and B) were felt
to be deficient in their ability to minimize actual or potential long-term
hazards 'at the site due to potential ground water fluctuations, did not.
destroy contaminants, and required long-term monitoring. The slightly
higher cost of the selected alternative over Alternative C is justified
under the NCP because of the significantly higher environmental benefit
associated with destruction of the most contaminated material.
Alternatives E and F were eliminated because of significantly higher costs
to allow only 28~ more contaminant destruction.
- .
..
~ ~~.:if ~
~~~~
Alternative 0 uniquely brings together the key selection criteria
recognized by the NCP:
. ...,1l.l!.jU.-;t1~-
o Total System Costs - Alternative D represents a total cost of
$2,471,000 which is 160~ of the cost of the least expensive
acceptable alternatives (RCRA Landfill). .
o Environmental and Public Health Effects
-Removal of source and 99.5' of all site contaminants.
- 72~ of waste on-site destroyed.
- Cancer risk to population for all gesticides other than toxaphene
is significantly less than the 10- risk level
- The estimated concentration of toxaphene in groundwater resulting
from a 3 ppm soil pesticide concentration is 35 ng/l, which is
two orders of magnitude less than RCRA standard of 0.005 mg/l.
- Cancer_~isk for toxaphene in ground water4after 50 years exceeds
the 10 risk l«vel, but is below the 10 r1$k limiting level-
- Achieving a 10- cancer risk level for toxaphene is not
technically practical since excavation ~f up to 20 feet across
the site would be required
- Residual pesticide concentration reflect -typical. background
levels in western urban areas
-34-
~.,.,.~
.",--.- . .' ...---- - .. .
." ",h ~....' -'.r _.. ."- - -
"---'-"'.'" '- .......-. .r"'- .... ,."'" ,," -.'
-------
T.b1e 6
SUMMARY OF [VALUATION
Cost ($ .t11ton)
R~!Ju1atton
Present Pub1fc He.1th/ [nv t ro...nt.1 C08p 11.nce OIM A1tern.tt,
A1tern.ttve C.pU.1 Worth Welfare Concerns Concerns Technica1 Concerns Concerns Consider.tions C.tegory
o. No Action Htgh potentia1 for Continued off-stte bs not cOllp 1y 5
direct contact of .igration of waste wi th C£ReLA
waste by .ateria1. Possib1e
surrounding cancer ri sk froll
popu1lce ground water
expos~~ in excess
of 10 level.
A. On sUe ReM 0.898 1.151 Reduces potentta1 Downward ~ve8ent Excavation of Certiftcate of Continued OIM on 4
Cap/Dispos.1 of for off-site to ground water drainage dUch designation f~ the cap to ensure
sons, rubb1e .igratton and stt11 possib1e. behind the Board of County Us integrity.
.nd sedi.ents on pub1fc contact. A11 waste re8atns For~st-MCKesson COI8issioners lIay long-te~
site under chy Re1ease sti11 on sUe. Possib1e COIIpany lIay be be required since ~nUoring
cap . possib1e due to cancer ri sk f~ dlfficu1t due to wastes wil1 be requ I red.
,round water ground wa ter 1 illtted access. stored on sUe.
, 1uctuatton expos!{e in excess C1Iy cap cannot be
w
Con of 10 leve1. constructed durfng
, the winter ~nths.
All cap lllateria1s
IIUSt be i~orted.
B. ReRA landfi11/ 1.260 1.542 G.-eat1y reduces the Great1y reduces the Staging of COIIp1fes with ReRA Continued 0&" on 2,3
Uisposa1 of potentfa1 for bw8an potent fal for construction ..y be and C£AClA the cap to ensure
sons, rubb1e contact with the off-site IIfgr.tton required due to p01icies. Us integrity.
and sedfllents was te ilia ter fa 1. of waste lIateria1. 1 fill ted space Certificate of Inspection and
on sUe within land use Waste retlains avai1ab1e on site. designation frOll c1e.n-out as
RCRA 1andff 11. restrictions wi11 on sUe. A11 .ateria1 s the Board of County necessary of
be requ f red to required need to be Supervisors Illy be 1each.te c011ection
protec t the i..ported. required. systell. long-terM
1andftl1. IIOnttoring
requi red.
C. Off-site 2.292 2.313 Gre.t1y reduces the Popu1ation risk to [xcavatlon of ditch Must c0llp1y with OA" wn1 be
Disposa1/ potentfa1 for huIIan cancer f~ ground lilY be difficu1t a11 DOT 1illtted.
hcavati on, contact with waste water exposure (see A). Import regu1attons. Monitoring on1y
transport, .nd on sUe. Potentta1 reduced AO 1ess fl11 required for Dlsposa1 .ust be in nt'cessary for J
disposal 0' for spi 11 and than 10- level ~or sltf rec1allatlon. RCRA Landft11. Yl'a rs.
sot1 s, rubb1e, contact with waste all cont..inants'
sedlll..nt in during transport. except toxaphene.
approved Waste will remain SOlI(' potential for
1andft 11. at approved releasl' of
Jandf" I. toxaphl'ne af~er 50
-------
, 1
I
I
,
'.b1. 6
SUMWIY OF UALUATJOII (Contfnwd)
Cost (, 811110n)
Rfguht I on
Pr.Sfnt P)lbHc fkoa1th' [fWI,.....n\a1 C..,11.nc. OUt An.m.th.
A1t.rnatl.. C.plt.1 North Urtf.re Concerns Concerns t.chnlc.1 Conc.rns Conc.rns Cons Id.r.U ons C.tegor,
D. Off-site 2.450 2.411 GrHU, muc.s the Poputatfon risk to (Sf. C) "'st c.,1, wit" OIM wt 11 be I
Inclner.tfon of pot.ntla1 for h..an cancer frG8 ground "nal,tlc.1 support .11 DOT "8n.d.
rubbl.. Off- cont.ct with Mlste w.ter I'xposur. r.qulred to regul.Uons. Monltorl", on1,
site dlspos.1 of on sit.. Pot.ntt a 1 ",duced Ao 1.ss separ.t. hl9h1, Inclner.tlon ..st nec.ssar, for J
cont.lnat.d for $pU1 and than 10- 1...1 for cont.ln.t.d be perfo"," In ,.ars.
sons .nd contact during .11 cont.ln.nts ..t.rlah for .pprowI'd
sedl-.nts. tr.nsport.tt on. .xcept toxaphene. Incin.ratfon. Inclner.tor.
121 of wlSt. Sa8e pot.ntlal for Dlspos.1 8Ust be In
cIfstroJeCl. 21.5\ rel..Sf of ReRA hndfU1.
of w.st.. dlspos.d tox.phene .f~.r 50
In .ppro.ed ,..rs at 10. risk
1 and ft 11. 11'..1.
E. Off-sUe 9.131 9.158 Gre.U, reduc.s Popu1.tlon risk to Se. C "'st cC8p1, wtt" OIM wt 11 be 1
. Inclner.t.on/ pot.ntla1 for hU8an cancer frC18 ground al1 DOT 1f.lted.
. w buu tf on , cont.ct wt th IIIIS t. w.t.r I'xposur. reguhU ons. "'st Monltorl", on1,
. 0\
I tr.nsport, and Oft sit.. AI1 wast. reduced 10 I.ss be burned In nec.ss.r, for J
off- sit. cIfstroJeCI to J p... than 10- 1...1 for .ppro.ed ,.ars.
Inclnerltlon. 1...1 - 99.5\ of a11 cont.'n.nts Incln.rator.
.11 IIIIstes. .xc.pt to..ph.n..
Potentl.1 for spl11 Sa8e potentla1 for ..''''
and contact during rel.l5. of
tr.nsport. tox.phene .ft!~ 50
,ears at . 10
risk 1...1.
r. On sUI' 5.592 5.613 ,".t1, reduc.s Popu1.tfon risk to Sl'f C. MobI1. AI r po11utlon OIM fo11owtng 2
Inclner.tlon/ potentla1 for hu8.n c.ncer frG8 ground Incinerator.., not ..Isslon notlc. .nd Inclner.tton
huutton, contact .Ith .'5te ..t.r I'.posur. be ...I1.b1.. pe~tt frC18 the Air 1f.ItI'd.
burning, and on sit.. AI1 Mist. reduced AO Il'ss OUtsld.. s..nlc. Pol1utlon Contro1 Monltorl", on1,
badfilling of cIfstroJfd to J p,. th.n 10- 11'..1 for .gencles 11.lted. Division, C010r.do nec.ss.r, for J
.11 cont.-In.ted 1...1 - 99.51 of .11 cont.'nants Deparment of ,.ars.
.lterlals. WIS tl' on s tte. except toxaphen.. ""alth required.
Offers gr.atest So8e pot..ntial for
pot..nttal for releas.. of
1ong-te~ public toxaphPne .ft!~ 50
health protrctlon. ,rars at a 10
rl sk 1.....1. Slight
'i degradation of air
t. qua I It) te
.'j durt ng
.<~ f nci n('
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Tlb1@ 6
SUtNRY OF [VALUATION (Conc1uded)
. The f0110wing fiv@ cat@gori@s .ust a11 b@ covered by the reMedi.l action .1t@rnatives:
1. Approprfate off.sfte dfspos.1 and/or treat.ent of the hazardous substances at a RCRA approved facf1fty. 4
2. On stte reledfal actfon that .ttatns all appltcable and relevant Federa1 public health and envfron8enta1 standards. gufdance or .dvfsorfes (10. rf!
l@ve1). 4
3. On sft@ re8edfal actfon that e.c~ds .11 appltcable or relevant Federal publfc health and envfron8enta1 standards. gutdance.or advfsortes (10. rfsl
1ev@1). . 4
4. ~edtal actton th.t dOes not attatn .pp1fcable or relevant publfc he.lth or environ8ent.1 standards (10. rfsk level). but wfll reduce the
ltkelihood of present or future threat f~ the hazardous substances.
S. No action.
I
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o Technical Feasibility - Alternative D is technically feasible.
Convent10nal earth moving equipment and techniques would be
employed, and the entire cleanup operation could be completed in
less than nine months.
o Institutional - No ~jor problems are envisioned concerning permit
tssues and right-of-way acquisition.
Based on these criteria, Alternative D (an off-site disposal alternative)
1s the most cost effective based on the combination of price, environmental
effects, and technical feasibility.
The components of Alternative D are technically feasible and reliable, and
when combined provide the greatest level of protection for public health,
welfare, and the environment. Excavation and offsite disposal of
contaminated soils and wastes to a secure hazardous waste management
facility or incineration facility are well established and reliable
technologies. The removal of wastes from the residential/industrial
setting will minimize public health threats posed by direct contact with -.
the waste as well as minimize the release and continued degradation of the
surface water, ground water, and sediments immediately offsite. The
monitoring of existing onsite wells for a short term following excavation
will evaluate the migration of any remnant contamination and thereby ensure
the effectiveness of the onsite remedial action.
This alternative, as previously described and shown in Figure 6, involves
the removal of 250 cubic yards (cy) of soil contaminated with greater than
100 ppm total pesticides. The removal and incineration of this amount of
soil will result in a 72 percent destruction of the pesticides that
currently exist on the Woodbury site (Figure 9). Therefore, a large
quantity of contaminants will be removed from existence, and not just
transported elsewhere with their hazard potential remaining.
The highly contaminated rubble is clearly identified by the distinct
division in sample pesticide concentrations (no values between 80 and 100
ppm). No samples with more than 100 ppm total pesticides were observed
outside of the rubble area. The quantity of rubble is clearly identified
~s2~ ~.
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100
"
. 80
t
::
.
.
c-
. g 80 I
:12-
sii
.. ~
.c I
. .
A. Co)
- c I + +
0 0 I +
-Co) I e
Ie + Q.
I Q.
. I 40 0 It) ('I)
~.. ..
&': 0
0
-,8 ..
!~ - ...
I 20
--
-- ---
--- ---
,.,.
/'
/'
/
.--.---..
o
o
1000
2000
3000
4000
6000
8000
Quantity 0' Contaminated SOll8 Treated (cy)
100+
10+
6+
3+
1+
260
8840
4410
1118
1388
Quantity 0'
Total Pesticide
Above 1 ppm Concentration
Contained In Soil
(Ibs)
1125
1611
1130
1645
1165
Total Pe.tlclde
Concenfration Leve'
(ppm)
Eatlmated Quantity
of 8011 Effected
(cy)
Figure 8 A Compariaon 0' auantlty of Materials Removed With Clean-up Levels
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Removal and off-site destruction of the rubble will be followed by off-site
disposal of the remaining contaminated soils to a 3 ppm level. This action
will (1) achieve a total reduction of over. 99 percent of residual
pesticides on the site; (2) provide positive protection against the future
contamination of ground water through leaching of toxaphene and dieldrin -
the most mobile of the contaminants; (3) provide for the destruction of the
rubble source (721 of total contaminants on site); and (4) reduce remaining
pesticide contamination within the soils. Calculated delivery of
pollutants to the public water supply aquifer at the site boundary are well
within cancer risk factor levels and within recommended water quality
criteria (refer to Table 5) following completion of the remedial action.
Maintenance Ind Monitoring Operations
Long-term maintenance for the site is limited to an intense effort for the
first three years to assure revegetation. Maintenance efforts would
include fertilizing and mowing of the low water vegetation that would be
selected for site reclamation. This effort would include fertilization
three times during the growing season and monthly mowings during the same
seven-month period. The cost for this effort is estimated at SS,OOO/year.
- .
..
Monitoring of the ground water wells would not be required. However, to
assure pUblic health protection, a limited pesticide monitoring program of
sampling the wells twice annually for a three-year period is recommended.
Two of the existing monitoring wells, one each, up and down gradient, would
be selected for monitoring. Monitoring should be coordinated prior to the
spring recharge period (Feburary) and again after the recharge period
(JulY-AuguS~). The cost for this effort is estimated at S2,OOO/year. .
The total cost for monitoring and O&M is estimated at S21,OOO for a
three-year period. .
SChedule
The following key milestone dates have been established for this project:
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- Approve Remedial Action (ROD signature)
- Award lAG for Design
July 1985
July 1985
- Initiate Design
- Award lAG for Construction
July 1985
September 1985
- Complete Design
- First Earth Movement
January 1986
- Complete Construction
May 1986
August 1986
Future Actions
The areawide ground water contamination problem,particularly with respect
to TCE and other solvents, will need to be addressed in a future action not
related to this site. Because the problem is widespread, it will be
addressed during RIIFS work associated with other Superfund sites in the
area. possibly under a new NPL listing. This will be determined when and -'
if a source of the contamination can be identified. EPA is presently
involved in an aggressive PAISI program in the general area to attempt to
identify sources and quantities of contaminants. A detailed study of the
South Adams County Water and Sanitation District's water supply wells is
currently in progress. (See Denver Post; July 14. 1985; p. 1)
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,
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
WOODBURY CHEMICAL SITE
COMMERCE CITY, COLORADO
INTRODUCTION
The purpose of the Responsiveness Summary is to document for the public
record the following items:
1. Concerns and issues raised by the public or agencies prior to the
Feasibility Study comment period.
2. Comments raised and questions asked during the comment period on
the Feasibility Study
3. The responses of EPA to these comments and concerns
CONCERNS RAISED PRIOR TO THE FEASIBILITY STUDY COMMENT PERIOD
-
~
A brief historical synopsis of community relations events pertaining to the
Woodbury Chemical Site prior to the pUblic comment period on the
Feasibility Study is in order before addressing the concerns raised during
the remedial planning process.
First, news articles in local publications in 1980 and early 1983 described
the site, its potential risks, and its Superfund status.
Second, in September 1983, EPA Region VIII conducted an Immediate Removal
action (IR) that included constructing a fence and posting bi-lingual
.
warning signs around the site to restrict access. In conjunction within
the IR, the ~PA Project Officer and the Community Relations Coordinator
visited businesses and residences near the site to explain the activities
and ask about possible concerns. They also distributed bilingual
(English/Spanish) fact sheets prepared by EPA to inform the public of the
reason for constructing the fence. A press release was also prepared and
published.
No specific concerns nor questions were raised by the public or other
agencies during this 1980-1983 perio~.
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Third, during the summer of 1984, field investigators conducted well-
drilling and sampling activities on the site. No direct comments nor
inquiries were received during this period.
Finally, in early 1985, a telephone inquiry about the potential effects of
the site was made by a representative of an out-of-state business
considering purchase of property near the site. Preliminary findings were
summarized in a verbal response and no further information was required.
Comments on the Draft RI report were received from the Colorado Department
of Health, Waste Management Division (January 1985) and the U.S. A~ Corps
of Engineers (Corps), Omaha District (March 1985). These agencies made the
. following comments:
o Colorado Department of Health
- Include more information on laboratory QA/QC and sampling plan
- Provide details to verify and determine ground water flow rates
and directions -
- Provide review and summary of historical site data in RI so that
the data can be evaluated during FS
o Corps of Engineers
- Emphasize that pesticides and heavy metals are the main site
contaminants, and characterize their general location and
impac~s
- Provide action levels for pesticides and metals on site
- Add more complete summary tables of analytical data
- Add dioxin analysis because of nature of burned facility
-
EPA responded to each of these concerns in its revisions to the Draft RI.
.
COMMENTS AND QUESTIONS DURING THE FEASIBILITY STUDY COMMENT PERIOD
A notice was published by EPA in the Rocky Mountain News and the Commerce
City Sentinel announcing the public comment period and the availability, of
the Feasibility Study documents. An informational newspaper article in the
Rocky Mountain News accompanied the notice. The formal public comment
period was then held from March 11 through April 1, 1985. however, EPA has
been receptive to public comments since that time. A fact sheet
summarizing the proposed remedial action alternatives was prepared and
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.,
. .
distributed to a mailing list of public officials and interested parties at
the beginning of the public comment period. Fact sheets and study
documents were also made available in two public repositories. No pUblic
comments on the proposed alterntatives or study documents were received.
nor were any requests made for a pUblic meeting.
The Corps had some additional comments on the Draft FS in its March 1985
letter, as follows:
o Additional sampling is needed to add quantitative precision to
remedial designs; any planned additional sampling should be
discussed with the Corps .
O' Details concerning the drainage ditch and pond ownership. and any
planned rerouting of drainage ditches around the site should be
addressed
o On-site air monitoring prior to and after construction of the
remedy should be planned and costed, in order to address worker
health and safety concerns and off-site impacts (to both CommercE: .
City to the north and City and County of Denver to the south)
...
EPA responded to these comments in the Final FS and decision documents in
the following manner:
o The additional sampling was conducted by CH2M Hill in 1985. and was
described and analyzed by the REM II Team (tDM) in their technical
memorandum of July 1985. This additional sampling provided the
necessary data for conceptual design of the alternatives. If
necessary, additional sampling will be conducted during the desi gn
phase.
o Details concerning the drainage ditch were also addressed in the
REM II technical memorandum noted above
o Additional air monitoring will be incorporated during the design
phase August 1985-January 1986, as noted in the REM II technical
memorandum .
In response to mailing list requests, EPA sent copies of the study
documents to, among others, McKesson Environmental Services, Denver
Shipping Company, and the Community Development Director for the City of
. .
Commerce City. Also. in order to ensure that the local press was
well-informed about site details, informational copies were sent to The
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Denver Post and Rocky Mountain News. EPA has since received several
requests from other parties to be added 'to the mailing list. Further. a
number of state and local agencies were contacted during June and July
1985. These agencies were informed about the project and added to the
mailing list.
Local community action groups formed or became active in early 1985 to
address hazardous waste concerns in Adams County. The groups urged local
residents to contact EPA and other agencies about their concerns. Although
the Woodbury site is in Adams County. it has received no special attention
from these groups. The groups include ACTION (Adams County Together
Improving Our Neighborhoods). CCAN (Colorado Citizens Action Network.
affiliated with the National Campaign Against Toxic Hazards). and Adams
County Residents Organization.
Finally. a Community Relations Plan has been developed and is being
implemented for the Woodbury site. Follow-up contacts. newsletters. -
information. and (if needed) public meetings will be occurring during the
next several months to respond to organized groups. affected citizens.
relevant agencies. the media. and elected officials. as EPA implements
remedial actions on the site.
.
REMAINING CONCERNS
As pointed out above. hazardous wastes and ground water contamination in
the general Adams County area remain as concerns for residents. EPA is
conducting-an areawide ground water quality survey to determine the nature
and extent of contamination and develop a remedial strategy.
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ATTACHMENT
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Floodplain Assess~t for the Nyanza Chemical Site, Ashland, tffi.
Attached a=e the floodway m~ps fo= the Town of Ashland ~hich
we=e
. p=epa::-ed by the iFe«ile=al Eme=gency ~'cinagement Agency.
These maps
clea~ly demonst~ate that the Nyanza site is outside of the 100
yea:: floodw'ay of the Sudbu::y 'Rive1:'.No -e'x'CCi'V'a'tio'n 'will 't.ake plac.e
within the floGrlplGin and no st::uctu::es a::e to be built in the
floodplain 0::- which will alte::the existing limits of the floodplain.
. \
(
HazardouS '"
Information r
US EP A Re,;ic
Philadelphia, \
~
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\
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