United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R08-89/024
September 1989
SEP A
Superfund
Record of Decision
-------
50272-101
REPORT DOCUMENTATION 1'. REPORTNo.
PAGE EPA/ROD/R08-89/024
I ~
3. Recipient'a Acceaalon No.
4. TIDe and SubtlUe
. =TDERFUND RECORD OF DECISION
ld Creek Industrial, CO
~~rst Remedial Action
7. Aulhor(a)
5. Report Dal8
09/29/89
6.
6. Perfonnlng OrganlDtion Rept. No.
9. Perfonning Orgalnlzatlon Nama and Addre..
10. ProjectlTaak/Work Unit No.
11. Contract(C) or arant(G) No.
(C)
(G)
1~ Sponaoring Organization Nama and Addre..
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type o' Report . Period Covered
Agency
800/000
14.
15. Supplementary Notea
16. Abatract (UmJt: 200 words)
The Sand Creek Industrial site is in Commerce City, Adams County, Colorado. Land use in
the vicinity of the site is industrial, including trucking firms, petroleum and chemical
production and supply companies, warehouses, small businesses and several residences.
The site contains the property and buildings of the Colorado Organic Chemical Company
(~OC) and approximately 13 residences. Production wells north and downgradient of the
y area are the source of water supply to the county. Pesticide manufacturing
-- at ions began at COC in the 1960s. Fires in 1968 and 1977 and improper pesticide
storage practices resulted in high levels of organiphosphate pesticides, chlorinated
hydrocarbons, and thermally-altered pesticides being released at the site. In 1978 COC
removed some contaminated soil, and in 1984 COC removed drums of waste, excess product,
and contaminated soil, and installed fencing at the site in response to an EPA order.
This Record of Decision represents the first of five planned operable units for the site
and addresses soil, buildings, and tanks contaminated by pesticides, volatile organics,
and metals. The primary contaminants of concern affecting the soil, onsite buildings,
and tanks are VOCs including TCE and PCE; and other organics including pesticides.
The selected remedial action for the site includes in situ vacuum extraction to remove
VOCs from contaminated soil and onsite treatment of off-gas by air stripping; excavation
and offsite incineration of aooroximatelv 1, 000 cubic yards (Continued on next oacre)
17. Doc:umant Analyals L Deacriptors
Record of Decision -Sand Creek Industrial, CO
First Remedial Action
Contaminated Media: soil, debris
Key Contaminants: VOCs (PCE, TCE), other organics (pesticides)
b. IdentifieralOpen-Ended Terms
-
Co COSA TI Reid/Group
rability Statement
19. Security Cia.. (Thia Report)
None
20. Security Cia.. (Thla Page)
N('\n~
21. No. o' Psges
82
n PrIce
(See A~Z39.18)
See Ine/rucUone on Re".,..
272 (4-77
(Formerly NTIS-35)
-------
EPA/ROD/R08-89/024
Sand Creek Industrial, CO
.
1
Abstract (Continued)
~f soil contaminated with greater than 1000 mg/kg halogenated organic compounds (HOC),
with off site residual disposal in a RCRA landfill; backfilling of excavated areas with
clean soil; demolition and offsite disposal of buildings in conformance with land
disposal regulations; and ground water monitoring at the site for 30 years following
-------
TZ4-C08008- RD-00913
RECORD OF DECISION
DECLARATION STATEMENT
ITE NAME AND L
Sand Creek Industrial Site
Commerce City, Colorado
Redefined Operable Unit No. I
Colorado Organic Chemical Area Soils (subset), Buildings, and
Tanks
STATEME~S ANP PURPOSE
This decision documem presents the selected remedy for remediation of contaminated soii,
buildings, and tanks from the redefined Operable Unit One (OUI) of the Sand Creek
Industrial Site. The document was developed 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
Contingency Plan. This decision is based on the Administrative Record for this site. The
State of Colorado concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed bv
implementing the response action selected in this Record of Decision (ROD), may presen't
an imminent and substantial endangerment to public health. welfare, or the environment.
DESCRIPTION OF SELECTED REMEDY
The remedy selected for OUI addresses soils, buildings. and tanks contaminated with
pesticides and volatile organic chemicals. The remedies for the other operable units of the
Sand Creek Industrial Site will be addressed in separate Record of Decision documents.
The action described herein represents a remedial action to control the source of soil
contamination by addressing the principal threatS of contaminated soil to groundwater,
surrounding populace, and on-site workers. The components associated with this remedy
are:
o
Excavation and off-site incineration of approximately 1,000 cubic yards of soils
heavily contaminated with Halogenated Organic Compounds (HOCs), and
disposal of incinerated soil residuals in a RCRA Subtitle C minimum
technology landfill, in confonnance with the Land Disposal Restrictions.
o
-------
o
Vacuum extraction of volatile organics in soils.
Demolition and off-site disposal of buildings in conformance with the Land
Disposal Regulations.
The remedy selected for OU1 is consistent with overall remediation goals for the Sand
Creek Industrial Site. The remedial. action will address a significant portion of
contaminated soils from the site which are a potential source of groundwater contamination
and adjacent surface soil contamination. Present net worth cost of the remedial actions
described in this ROD to clean-up conmminated soils at OUI are $5,349,600. Groundwater
contamination (Operable Unit No.4) will be most effectively implemented when sources
of contamination have been remediated.
o
In addition to the 1000 cubic yards addressed by this ROD, approximately 38.000 cubic
yards of soil contaminated with lesser levels of HOCs within the aUI area will require
treatability srudies. Remediation of these soils (hereafter considered OU5) will proce~d
separate from OUI remediation activities. . .
The selected remedy will protect groundwater resources and prevent direct contact risks
through the removal and subsequent destruction or disposal of contaminated soils. The
selected remedy will ensure the long-.term protection for the public and the environmem
through destruction or containment of hazardous substances. Incineration will be used to
destroy highly HOC-contaminated soils.
STAllJTORY DETERMINATIONS
Consistent with CERCLA as amended by SARA and the National Contingency Plan. I have
determined that the selected remedy for Operable Unit No.1 of the Sand Creek Industrial
Site is protective of human health and the environment. I have also determined that the
selected remedy complies with Federal and State requirements that are legally applicable
or are relevant and appropriate to the remedial action, and is cost effective. The selected
remedy utilizes permanent solutions and alternative treatment technologies to the maximum
extent practicable and satisfies the statutory preference for remedies that employ treatment
that result in the reduction of the volume, mobility, and toxicity of soil contamination at the
-------
BeC:lUse this remedy will result in hazardous substances remaining on site above health-
based levels. a review of the remediation wiIl be conducted within five years after
commencement of the remedial action. to ensure that the remedy continues to provide
adequate protection of human health and the environment.
~ ~ /-. 0-
J . Sch~~
Regional Administrator
EP A Region VIII
., -..2- f -rf
. .
-------
TABLE OF CONTENTS
RECORD OF DECISION SUMMARY
CHAPTER PAGE
I. Site Name, Location and Description 1
II. Site HistOry and Enforcement Activities 1
III. Highlights of Community Participation 4
IV. Scope and Role of Operable Unit Response Action 6
V. Site Characteristics 8
VI. Summary of Site Risks 9
VII. Description of Alternatives 11
VIII. Summary of Comparative Analysis of Alternatives 15
IX. The Selected Remedy 65
x. StatutOry Determinations 66
XI. Documentation of Significant Changes 69
TABLES
VI-I
Chemicals of Concern, Maximum Soil Concentrations,
Desired Removal Efficiency and Action Levels For OUI
10
VI-2
Assumptions Used in Estimating Exposure Via Direct
Contact With Soils in the COC Area .
12
VIII -1
ARARs for Sand Creek OUI
-------
Record of Decision
Sand Creek Industrial Site
Colorado Organic Chemical Company Area
Operable Unit No.1
Decision Summary
1.
Site Name, Location, and Description
Thi3 Record of Decision (ROD) describes the remedial action for hazards located within
and immediately adjacent to the Colorado Organic Chemical Company (COC) property.
The hazards addressed in this remedial action are: 1) a portion of the pesticide
contaminated soils 2) all of the volatile organic compound (VOC) contamination in the
soils; and 3) contaminated buiidings and tanks used in the formulation and storage of
pesticides. The area subject to this ROD within and immediately adjacent [0 the cac
property will hereafter be referred [0 as the cac area.
The COC area is located within the Sand Creek Industrial Site. The Sand Creek Industrial
Site is located in Commerce City, a suburb north of Denver, Colorado (Figure 1). The site
and surrounding area are industrialized and contain trucking firms, petroleum and chemical
production/supply companies, warehouses, small businesses, and several residences. The
site stUdv area is bounded on the north bv Sand Creek, on the south bv 48th Avenue, and
on the east by Ivy Street. The western boundary is approximated by Dahlia Street,
Colorado Boulevard. and Vasquez Boulevard. Figure 2 illustrates the location and
boundaries of the cac area.
\Vithin the Sand Creek Industrial Site, there are approximately 13 residences with a [Otal
population of about 25. The day use population, however. reaches severai hundred due [0
the business and industrial natUre of the stUdy area. Water users within the site stUdy area
are served by the South Adams County Water and Sanitation District (SAC\VSD). Private
wells exist on the site: however, this water is used for industrial and irrigation purposes.
Groundwater is the source of water supply to the SACWSD. Production wells are located
north (downgradient) of the stUdy area. Approximately 30,000 custOmers in Commerce
City and Adams County are served by the SACWSD.
The cac area is located above the IOO-year floodplain of Sand Creek. The majority of
the COC area is located on a bench of relatively flat terrain that slopes down to railroad
tracks to the north and rises to an alluvial terrace to the south.
II.
Site History and Enforcement Activities
The Colorado Organic Chemical Company plant was first operated by Times Chemical in
the 1960s to manufactUre pesticides. The company name was later changed to Colorado
International Company (CrC). rn 1968, a fire destroyed three buildings at the crc plant.
-------
~\~(-~7\ /~ - -
. /
-<- 65 / I
~ / ROCKY !,~OU~Tr\ltl I
I -, ~ 'j~ ( AnS'NAL i
I C~~w X CC.',L~!f:;;CS I I
::. CIT'a' I
IsPI I I
! / 'V~ I I
I ; ~~",~~-----_-1
! .' /',:-< i I -:---- .. . "D ,.~ ;:-_.,
j /,1 ';'~~37:~ ,,\':~; I ' :::;,-.,,, c;l"\~:::.\.
" " -j . ~ i I . i ~~ 0 US -: ~ ! ,;' L :3 IT::
. ----.~ I~ \ I I
! J I ~~ i J -,-:::;!-
; // I ~ I l -... ~.;,-;., i '-../ -~
I f'~~y ~~I 1,,~J~~~,I::\~g~::~-Z,";~-I- I
,,'<: - ,.1_..."", "..~ '- ~J ~
I A ~r;.+~ ~! ~;i';:Oi-ir- _::; \\~------.........
,v ~'---- 'I '\
L" \. :! . ~ - !:.: L;:~~': .\ ,,'=, :} "" J I
J 0 = I~J 'I C [1 r - --"l ) /1 !~:,
I I \, 1-. "-
: c'/,..! I I' 'I~ -- i "-
, ) I I -....... ,/ f '.. "'" ...
..... """"", 1- ..'..11.,. '--, '-7-,-...~-.... I :21:r:""" r:',"- \ "./"'),
, I - . I"" - ,-"" -= I "'" I '- .. \",,: ..., '-"4 I ., .. /
! ~.'. 'I~ -, ::..:.S~ I ) '-~I :_'~\..:..:;~::-; t... '; \'';' ':"\)"~~'t-
---:.\~ "I c.- l ~- ~ ! "-. ,t:/- - r \ <:::-.. "-. . !
I " ~-""" ---, j I: ~\ '+-'c i" \'-:-~ "'-!
I )' C I ci I' \ ~ I ! '\'--'. L~:"'" l .. \ -::. . i
I "'j' \. <." 'I . 1\.' i ("'I >
i ~~I?; ',~~:.:; ( .1'1',> ., ,,~ '
. :.. - =: I "........( \ \...... ," I
i :'?/ .j_~1 '--.... =! ) ,". L ~\-.J \ ';"'- !,
I \ , -~ ("'I
Ii 2!' f g I' '~C'..-. ,.:.,,, :
V) "'" I """<, ~ I
I " !:: ~= I \ '" -;<-
I .' I.:J 0
oS ~ c5
Q Z U
'" ::J
I
j
2
SITE
LOCATION-"
C4
C 0 L a
,\
o
o
R
I
L
C T 2 l ~
.=--==-. =-=..:::::"'~
.~ ,', i : .: t;
I
~
. i
SAND CREE=< (COLO.) RI/FS
SAND CREE=< INDUSTRIAL
SITE LOCA nON MAP
-------
~
-.--
I EGEtlD
V / /I 5 rHUCTURE
I , I RAIL ROAD TRACK
COC AnEA
---- pnOPEnTY UOUIIDARY
"OHIEtITAI.
tlU'IIIEBY" PROPERTY /lAME
FecI
1~~LjI)
SCAI [
~
""
SAtlO CREEK ItIDUSTAIAL SITE
COlOIiADO ORGANIC CIiEMlCAL
COMPAtlV (COC) AHEA
figure
-------
An inspection of CIC by Tri-County District Health Department personnel in June 1974
indicated unsatisfactory waste management practices and unsatisfactory worker safety
conditions.
In March 1976, the Colorado Department of Health (CDH) conducted a field inspection
at CIe. The inspectOrs observed 55-gallon drums containing pesticides stored at various
places across the COC area. They observed washwater, storm drainage, and boiler feed
water draining into a common surface drainage that flowed off property towards Sand
Creek. CIC was cited for storage and handling violations. A fire occurred at CIC in
December 1977, releasing parathion fumes over northeast Denver. The State of Colorado
issued an Emergency Cease and Desist Order against CIC to clean up the COC property
and adjacent areas contaminated by the fire. CIC declared bankruptcy and re-opened the
operations as Colorado Organic Chemical (COC). COC operations were essentially the
same as CIC operations.
Soil sampling at COC in early 1978 revealed high levels of organophosphate pesticides.
chlorinated hydrocarbons. and thermally-altered pesticides. The State filed a preliminary
injunction against COC/CIC to clean up the residues of the fire. Some contaminated soil
was removed in OctOber 1978.
COC was cited for unsafe drum stOrage and improper storage areas in 1980. Samples of
surface liquids collected during the inspection revealed that surface water discharge
contained pesticides (dieldrin, heptachlor, DDE, and DDT), inorganics (chromium and
arsenic), and other organics (chlorinated benzenes and phenols).
Subsequently, EPA filed a number of complaintS against COC for Resource Conservation
and Recovery Act (RCRA) violations. In 1982. a consent agreement and final order were
issued for the RCRA case. In March 1983. EPA referred to the Department of Justice the
matter of COC's RCRA violations and violation of the previous settlement. In June of
1983 a spill of the herbicide 2, 4-0 resulted in an additional compliance order to clean up
the spill and to comply with previous order~. EP A issued a CERClA. 106 order in March
1984 for cleanup of the site. BetWeen April and September 1984, removal action was taken
by COC which resulted in the removal of drummed wastes and product, contaminated soil.
and fencing of the site.
III.
HighlightS of Community Participation
All requirementS for public participation as specified in Section 113(k) (2) (B) (i-v) of
CERClA. were satisfied during the remedial action process.
Community relations activities for the Sand Creek site began in April 1985 when EP A
distributed an introductory fact sheet to residents, businesses, and agencies in the area. The
fact sheet described the site and explained the Superfund process, with emphasis on the
Remedial Investigation/Feasibility Study (RI/FS). In the next few months, EP A personnel
attended a public meeting organized by Citizens Against Contamination; they also compiled
a list of people who owned property in the stUdy area.
-------
EP A mailed a second fact sheet in November 1985. This fact sheet provided information
typically requested during investigation and cleanup of hazardous waste sites. That same
month, EP A also provided a report on water contamination for another pubiic meeting of
Citizens Against Contamination.
In January 1986, EPA contacted property 'owners and Commerce City officials to infonn
them of activities at the site. In the spring, EP A prepared a photo display illustrating the
RI/FS process.
Because ground-water contamination and its effects on household supplies were of concern,
EP A surveyed residentS about their water use habitS during April 1987. Later that year,
EP A spoke with residentS and businesses to check the status of methane venting systems
near the 48th and Holly landfill (Sand Creek Operable Unit Three). The landfill owners
had installed these systems after an explosion in 1977 resulting from a buildup of methane
that had migrated from the landfill.
A Remedial Investigation report describing the extent of contamination within the cac
area was released for public review in March 1988. In May 1988, EP A contacted property
owners to obtain permission to sample and monitor soils on those properties.
In October 1988, EP A met with Commerce City officials to inform them of plans for the
site. The Commerce City representatives also gave their reactions to the cleanup methods
being considered.
In January 1989. the Feasibility Study (FS) which focused primarily on the cac area was
completed, and an initial remedial alternative was chosen. The remedial action initially
selected would have involved: excavation and off-site incineration of the most highly
contaminated suriac,e soils; excavation and off-site disposal of the approximateiy 38.000
cubic yards of surface soils contaminated above industrial-use action levels: vacuum
extraction for the volatile organic compounds in the subsurface soils immediately above the
ground-water table; and demolition and off-site disposal of the contaminated tanks and
buildings in the cae area.
EP A took several measures to announce the remedial alternative choice and to seek
comments and questions from the public. First, EP A made copies of the FS Report
available to the public in the Adams County Public Library, the Colorado Department of
Health, and the EP A Region VIII library in downtown Denver. At the same time, EP A
mailed its third fact sheet, which described a proposed plan as well as four other remedial
alternatives that had been evaluated. Third, EP A announced a public comment period
during which the public was invited to submit commentS and questions. The comment
period originally ran from January 13 to February 13, but at the request of the potentially,
responsible panies (PRPs), EPA extended the period to February 22. Fourth, EPA
conducted a public meeting on January 31 to describe the results of the RIfFS and answer
questions from the public. EP A published a press release and a public notice in each of
the Commerce City newspapers, The Commerce City Sentinel and De Commerce CitY
Beacon.. announcing all of these activities.
-------
In response to public comment and subsequent re-examination of the site, a FS Addendum
was completed in July 1989 which presented two additional and innovative remedial
technologies for potential use on the contaminated surface soils in the COC area: biological
treatment and soil washing. It was concluded from the FS Addendum that treatability
stUdies would be required before implementing either of the additional alternatives.
EP A made copies of the FS Addendum report available to the public and mailed itS fourth
fact sheet describing the new proposed plan. The remedy selected in the new proposed plan
included: excavation and off-site incineration of approximately 1,000 cubic yards (CY) of
hig~ly HOC-contaminated shaIlow «5ft) soils; vacuum extraction of the volatile organic
compounds in the subsurface soils above the ground-water table: demolition and off-site
disposal of the contaminated tanks and buildings; and either bioremediation or soil washing
for the approximately 38,000 CY of shallow soils contaminated with HOCs above industrial-
use aCtion levels. It was proposed that excavation and off-site disposal of the 38,000 CY
of contaminated surface soils be retained as a contingency remedy, since the
implementation of bioremediation and/or soil washing depended upon the results of
treatability studies to be performed subsequent to this Record of Decision. An absence of
proven field bioremediation and/or soil washing results on soils contaminated with similar
compounds warranted retention of the off-site disposal option.
EPA announced a public comment period in effeCt from July 19 through August 21, 1989
during which the public was invited to submit comments and questions regarding the FS
Addendum and the new proposed plan. EP A conducted anOther public meeting on August
1 to describe the new remedial alternative and answer questions from the community. Press
releases and public notice were again published in The Commerce CitY Sentinel and The
Commerce City Be::lcon announcing all these activities.
Only the City of Commerce Ciry responded in writing, and there was limited comment on
the selected remedy during the August 1 public meeting. The primary concern or the City
of Commerce City was that the COC proper.ty be remediated to residential-use standards.
A complete response to written comments received during the public comment period and
oral comments made at the community meeting are addressed in the Responsiveness
Summary, an attachment to this Record of Decision.
Scope and Role of Operable Unit Response Action
During the course of the remedial investigation, conducted from 1984 to 1988, EP A
determined, in accordance with 40 CFR Section 300.68(c), that the Feasibility Study should
be divided into operable unitS in order to remediate site-specific problems.
IV.
Originally, the Sand Creek Industrial Site was subdivided into four operable units according
to the type of contamination present, type of media affected, and physical characteristics
of the unitS. The four operable unitS are described below:
-------
Operable Unit No.1 -
Operable Unit No.2 -
Operable Unit No.3 -
Operable Unit No.4 -
Soils contaminated by pesticides, volatile organics,
arsenic. and chromium in the Colorado Organic Chemical
(COC) area; contaminated buildings and tanks in the
COC area;
Contaminated soils and ground water in the vicinity of
the L.e. Corporation property;
Gaseous emissions, contaminated surface water and
ground water in the vicinity of the 48th Avenue and Holly
Street Landfill;
Contaminated ground water underlying the site.
As discussed in section III. treatabiliry tests are required to determine the effectiveness of
the bioremediation and/or soil washing options for soils contaminated with lesser amounts
of HOCs prior to implementation. In an effort to expedite remediation for those areas not
suitable for bioremediation and/or soil washing, the original scope of the remediation
described in the proposed plan has been reduced. Accordingly, OUI has been reduced in
scope to exclude the lesser HOC-contaminated soils and a new operable unit. OU5. has
been defined to include these soils.
Although this action reduces the original scope of the proposed plan, the change will not
reduce the overall plan for remediation at the Sand Creek Industrial Site. OUs 2. 3 and
4 remain unchanged. As of the date of this ROD, the Sand Creek Industrial Site has been
subdivided into the five operable units described below:
Operabie Gnit No.1 -
Operable Unit No.2 -
Operable Unit No.3 -
Operable Unit No.4 -
Operable Unit No.5 -
Within the cac area, 1.000 CY soils highly contaminated
with pesticides (concentrations ~ 1,000 ppm Halogenated
Organic Compounds); volatile organic compound
contaminated soil; and contaminated buildings and tanks:
Contaminated soils and ground water in the viciniry of
the L.e. Corporation property;
Gaseous emissions, contaminated surface water and
ground water in the vicinity of the 48th Avenue and Holly
Street Landfill;
Contaminated ground water underlying the site;
Within the COC area, approximately 38,000 CY soils
contaminated with pesticides (concentrations < 1,000
ppm Halogenated Organic Compounds).
-------
This Record of Decision addresses remediation of the newly defined Operable Unit No. 1.
Remediation of the remainder of the site will be addressed in separate decision documentS.
The response action for OUI will protect surface water and ground-water resources, prevent
direct contact with contaminated soils by the public and site workers, and allow remediation
of the remaining operable unitS without concern for the health threatS posed by the highly
contaminated soils, VOC contaminated soils, and contaminated buildings and tanks. This
action representS the tirst remedial action for this site.
V.
Site Characteristics
The site-wide Remedial Investigation was initiated in 1985 and completed in March 1988.
The field investigations revealed that the site is underlain by alluvial d~positS comprised of
high-permeability sands and gravels, interbedded with low-permeability clayey and silty
layers. Two ground-water unitS underlie the site, separated by a relatively impermeable
layer 10 to 20 feet thick. The upper unit is up to 40 feet thick and is primarily unsarurated
(i.e.. contains little to no ground water). The lower unit is up to 44 feet thick and
generally exists under confined conditions.
Source of Contamination
Analytical resultS of soil samples collected on the COC area indicated the following:
Chlorinated pesticides are present in the surficial and/or shallow soils
throughout the coe area.
Organophosphate pesticides, herbicides, and volatile organic compounds are
present in surficial and/or shallow soils within the eastern half and northwest
corner of the eoc property, and along the Colorado and Eastern Raiiroad
betWeen Dahlia Street and Colorado Boulevard,
Polycyclic aromatic hydrocarbons are present in surficial soils in ponions of
the COC property,
High concentrations of arsenic have been detected in surficial and shallow
soils on the coe property and the nonhern ponion of the Oriental Refinery,
Soil contamination to depths of up to 54 feet is present in some locations
beneath the Oriental Refinery site, coe, and adjacent areas. These soil
contaminantS are primarily volatile organic compounds and appear to serve
as a source of ground-water contamination.
OUI includes contaminated soil volumes of approximately 1000 CY of soil containing
HOe concentrations greater than or equal to 1,000 parts per million, an action level
dictated by the land disposal restriCtions.
-------
VI.
Summary of Site Risks
An Endangerment Assessment (EA) was conducted for the Sand Creek site (CDM 1988)
to evaluate the risks posed by the presence of contaminated soils in the COC are~. This
EA identified a number of chemical compounds that, because of health risks, are chemicals
of concern for the newly defined OUI. These chemicals, their maximum soil concentrations
and proposed action ( cleanup) levels are presented in Table VI-I.
The most significant health risk associated OUI involves contaminated soils and potential
movement of contaminants into ground water. The EA identified several potential
pathways and receptors of concern. These are:
Direct contact of industrial workers or children with surface soils (includes
dermal absorption and ingestion);
Inhalation of chemicals in soils rele:lSed by wind-entrained and/or vehicle
generated dust;
Inhalation of volatile organics released from soils;
Off-site use of contaminated ground water which has moved from OUl:
Future use of ground water on or downgradient of OUI.
For those soils highly contaminated with HOCs, the EPA Land Disposal Regulations
require incineration. The disposal of OUI hazardous substances during the course of
remedial actions is subject to the special restrictions on land disposal of hazardous waste
established by the 1984 Hazardous and Solid Waste Amendments (HSW A) to the Resource
Conservation and Recovery Act (RCRA). Land Disposal Restrictions (LDRs) are
applicable because placement will occur after November 8, 1990 (53 FR 31216).
Specifically, the California list treatment standards for HOCs are applicable to the site, if
soils are treated or land disposed. Land disposal restrictions for California list wastes
originated in California, and EP A adopted them effective July 8, 1989 for nonIiquid HOCs.
A number of the hazardous substances found on the COC area are RCRA listed wastes and
appear on the California list. The California list wastes consist of liquid PCBs, liquid and
nonliquid halogenated organic compounds, acid wastes with a pH < 2.0, liquids containing
heavy metals, and free cyanides. HOC wastes at the COC area include dieldrin,
heptachlor, chlordane, chloroform, DDT, and 2, 4-D. Under the California list treatment
standards, nonliquid hazardous wastes containing HOCs in total concentrations greater than
or equal to 1,000 mg/Kg (ppm) are prohibited from land disposal without prior treatment
by incineration. EP A projects that the incinerated soil will not meet health risk-based
criteria; however, the selected remedy still meets the CERCLA protectiveness requirements
since the incineration residuals will be disposed of in a RCRA subtitle C facility and will
require disposal in a Subtitle C facility residuals, in compliance with RCRA. As noted in
the table, risk-based action levels are not relevant for these highly HOC-contaminated soils.
.'
-------
TABLE VI-I
CHEMICALS OF CONCERN, MAXIMUM SOIL CONCENTRA TrONS,
AND ACTION LEVELS FOR OUI
Chemicals of Maximum Action
Concern Concentration . Level Risk Level
Pestiddes /herbicides
2,4-D 15,000,000 (pg/kg)* 1000 ppm N/A
Volatiles (uo/Ko)
Chloroform 820 165 10-6
Methylene Chloride 5.800 75 10-6
Tetrachloroethene 9.340 1.095 10-6
Trichloroethene 87 285 10-6
.Soil concentration may reflect hot spot.
Reference CDM RI Report 1989
10
-------
The EA determined that the exposure scenarios presenting the highest risk at OUI include
direct contact with HOC contaminated soils (ingestion and dermal absorption) and potential
ingestion of contaminated ground water for VOC contaminated subsurface soils. Other
exposure scenarios for the site (inhalation of contaminated dust and inhalation of
compounds volatilizing from the soil) generally present lower risks.
The exposure to the potential carcinogens in soil by direct contact with contaminated soils
was evaluated for industrial workers using the site and children playing at the site. The
routes of exposure considered were dermal absorption and incidental ingestion of the soil.
However, as noted above, the action levels for HOCs are not based on health risk but
rather on the LDRs.
The acceptable site-specific soil concentrations were calculated during the EA with the use
of a soil-water leaching model which assumed ground-water concentrations corresponding
to a lO-e risk for consumption of drinking water. It was assumed that a 70 Kg individual
in!!ests 2 liters of water each dav over a 70-vear lifetime. Excess lifetime cancer risks were
determined by multiplying the i~1take level ~ith the cancer potency factOr. These risks are
probabilities that are generally expressed in scientific notation (e.g., lxl0-e or 1E-6). An
excess lifetime cancer risk of 1xlO-e indicates that, as a plausible upper bound, an individual
has a one in one million chance of developing cancer as a result of site-related exposure
to a carcinogen over a 70-year lifetime under the specific exposure conditions at a site. The
assumptions used in estimating exposure are given in Table VI-2.
The soil leaching model indicated that travel times for all volatiles are much less than for
pesticides because the K~ (the partitioning coefficient) values for volatiles are much lower
than those for the pesticides. Therefore it was recommended, for volatile organic
compounds. that the risk-based soil action level based on the ground-water pathway be used
as the cleanup goal.
VII.
Description of Alternatives
The detailed analysis of remedial technologies, presented in the Feasibility Study and
Feasibility Study Addendum reportS, resulted in the development of seven alternatives and
tWo prerequisite remedial activities for site remediation. These alternatives and prerequisite
remedial activities are summarized below. Since alternatives dealing with soil
contamination < 1,000 ppm HOCs were included in the OUI FS completed before the
recent designation of OUS, they are also included in this ROD for discussion pU!poses. The
decision on remediation of the approximately 38,000 cubic yards of soil contaminated with
< 1,000 ppm HOCs will be made in the ROD for OUS, not herein.
Prerequisite Remedial Activities
For all alternatives except the No Action alternative, two remedial activities will begin prior
to any other activity: (1) in-place air stripping (i.e. vacuum extraction) will be conducted
to remove VOCs in the soil, and (2) any contaminated structures or tanks currently at the
COC area will be removed.
-------
TABLE VT-2
ASSUMPTIONS USED IN ESTIMATING EXPOSURE VIA DIRECf CONTACT
WITH SOILS IN TIlE coe AREA
Parameter l\verage ~~osure Plausible
Maximum Exposure
Children
Frequency of Exposure 10 visits/year 40 visitS/year
Duration of Exposure 5 years 5 years
l\verage Weight Over
Period of Exposure 30 Kg 30 Ka
:=
Inciden.tal Ingestion
of Contaminated Soil 50 mg/visit 250 mg/visit
\Vorkers
Frequency of Exposure 130 visits/year 130 visits/year
Duration of Exposure 10 years 20 years
Average Weight Over
Period of Exposure 70 Kg 70 Kg
Incidental Ingestion
of Contaminated Soil 20 mg/visit 100 mg/visit
Gen.eral
Percent of Organic Compounds
Absorbed from Ingested Soil 50% 50%
Soil Contact Rate 0.25 g/visit 1.5 g/visit
Percent of Organic Compound
Absorbed Dennally from Skin 2% 4%
Percent of Arsenic
l\bsorbed Dermally from Skin Negligible Negligible
Average I1fetime 70 years 70 years
Reference CDM 1989
-------
Soil vacuum extraction is a remedial process proven highly effective for the removal of
VOCs from contaminated subsurface soils. Soil vacuum extraction will be employed
primarily to reduce VOC contamination in the soils. Emissions resulting from the vacuum
extraction system will be treated via carbon adsorption.
Demolition and disposal of several contaminated structures and tanks located on the COC
area must occur prior to excavation activities. All structures, tanks and debris will be
treated in accordance with LDRs.
Alternative No.1 - No Action
The No Action alternative is presented as a basis for comparison with the other
alternatives. Under no action, soil would remain contaminated with toxic chemicals and the
risks described above would remain. No action could be considered feasible only if the
other alternatives could not substantially reduce toxicity, mobility, volume, or the health risk
associated with the site. Selection of the no action alternative would require monitOring
of ground-water for thirty years to evaluate movement of contaminants from the site. The
Public Health Evaluation (PRE) would be performed at 5-year intervals as is required
under CERCLA/SARA when contaminated material is left on site.
Alternative No.2 - Cappin~ ITnstitutional Controls
Alternative No.2 would involve reducing the areal extent of contaminated soil by
excavating approximately 6.000 CY of the contaminated soil. placing of the excavated soil
in a designated area of contamination, and constructing a cap over the entire contaminated
area. The excavation of soil would be completed to the action levels identified in the FS
and EA. The cap, constructed of a three-layer design to comply with RCRA requirements.
would prevent direct contact with contaminated soil, minimize airborne emissions. and
minimize surface infiltration (thereby protecting ground-water resources). Alternative No.
2 would be considered on-site containment. Deed restrictions would be required to ensure
long-term maintenance of the cap and to prevent activities that would disturb the cap or
result in contact with or release of contaminated soil. The long-term effectiveness is
questionable because of the possible failure of the cap. Also, because no treatment would
occur. toxicirv and volume of contaminants would not be reduced. Because contaminants
are left on-she, monitoring of ground-water would be required for thirty years, and re-
evaluation of the PHE would be performed at 5- year intervals.
AJternative No.3 - On-Site 6m1QfilLDisposal of Contaminated....smJ.LJnstitutionaJ Controls
Alternative No.3 would involve excavation of all contaminated soil with concentrations
exceeding action levels, temporary storage of contaminated soil, construction of a landfill
meeting the minimum technology requirements of RCRA Subtitle C requirements within
the excavated area, backfilling the landfill unit with contaminated soil, and construction of
a cap over the landfill unit. This alternative creates on-site containment of contaminated
soil. It would prevent long-term emissions, direct contact and leaching of contaminants into
surface water and ground water. Deed restrictions would be required to ensure long-term
maintenance of the cap. Restrictions would also be required to ensure long-term
maintenance of the cap and to prevent activities that would disturb the landfill. Although
-------
more protective than Alternative No.2, because the double landfill liner would provide
additional short-term ground water protection, the long-tenn effectiveness is similarly
questionable because of the possible failure of either the cap or liner. The alternative
would not reduce toxicity or volume of contaminants. Because contaminants are left on-
site, ground water monitoring would be required for thirty years, and re-evaluation of the
PHE would be perfonned at 5-year intervals.
Alternative !'lo. 4 - Off-Site Tncineration of> 1.000 ppm HOC Contaminated...scij/Off-Site
Landfill Disposal/Institutional Comrols
Alternative No.4 involves excavation and off-site incineration of approximately 1,000 CY
of soil contaminated with> 1000 ppm HOes, and off-site landfiIIing of the incinerated
residual soil. In addition, it includes excavation of the approximately 38,000 CY of
contaminated soil with concentrations above action levels identified in the FS and EA. but
below 1,000 ppm HOC contamination, transport and disposal at an off-site landfill,
backfilling with clean soil and revegetation of the site. Institutional comrols prohibiting
certain uses mav be reauired for the area. This alternative would reduce tOxicirv and
volume through "destruction (incineration) of a portion of site contaminams. Mobiiity of
contaminants would be reduced through off-site containmem. Long-term effectiveness is
considered high and no surface use would be restricted to industrial use. A PHE would be
required every 5 years based on the NCP proposed rule (53 FR 51430).
Alternative No.5 - On-Site Incineration of Contaminated Soils/On-Site Fixation of Treated
Residuals/On-Site Landfill of Treated Residuals/Tnstitutional Controls
Alternative No.5 would involve excavation of all contaminated soil with concemrations
above action levels. incineration of contaminated soil in an on-site incineratOr. fLxarion of
incineration residuals containing arsenic above action levels. construction of a landfill on-
site, and backfilling the landfill v,ith flxed residual and incinerated residual soil. Land use
restrictions would be required for the site to ensure long-term stability of the landfill. This
alternative would provide a significant reduction in toxicity, mobility, and volume through
destruction of most contaminants and flxation of arsenic. Long-term effectivefless would
be high but land use restrictions would be necessary. Deed restrictions would be required
to ensure long-term maintenance of the cap and to prevent activities that would disturb the
landfill. A PHE would be required every flve years based on the NCP proposed rule.
Alternative No.6 - Off-Site Incineration of> 1.000 ppm HOC Contaminated Soil/On-Site
JW2.lo~cal Treatment of ~ernaining Comaminated....sillJ..LJnstitutional Comrols
Alternative No.6, referred to as the biological treatment alternative in this document,
involves excavation and off-site incineration of the approximately 1,000 CY of soil
contaminated with ~ 1,000 pprn HOCs and disposal of the incinerated residual soil in a
Subtitle C landfill. In addition, approximately 38,000 CY of remaining soil with HOCs <
1,000 pprn, but contaminant concentrations above action levels, would be excavated,
physically pretreated to the soil grain size required for treatmen~ and biologically treated
on-site. The biological treatment would be performed in a lined treatment facility. Once
-------
the soil is remediated to health risk-based action levels. excavated areas would be .
backfilled. graded. and revegetated in order to minimize erosion and wind-blown dust.
Institutional controls may be required for the site prohibiting certain uses.
Since biological treatment of hazardous suhstances is an innovative technology, treatability
testS would have to be performed to determine: which contaminantS are amenable to
biodegradation and what their specific breakdown produCtS are, what clean-up levels can
be attained, how long remediation will take to complete, and what the spatial requirementS
of the treatment area will be. It is anticipated that it will take 5 to 7 years to complete the
remediation of OUI with this alternative. Contaminant toxicity and volume would be
reduced through destruction (incineration) and degradation (biological treatment). This
would provide a permanent solution. Ground-water monitoring would be required for 30
years following completion, and the PHE would be reevaluated every 5 years.
Alterna~e N'o. 7 - ~ff-Site Tncineration of> 1.000 ppm HOC Contaminated~/On-Site
Soil W hin~ Trea ment of Remainin~ Contaminated Soil/Off-Site Tncineration and
Disposal of Soil \Vashing Residuals/Institutional Controls
Alternative No. i, referred to as the soil washing alternative in this document. involves
excavation and off-site incineration of soil contaminated with> 1000 ppm HOCs and
subsequent disposal of the incinerated residuals in a RCRA Subtitle C landfill. In addition.
approximately 38.000 CY of remaining soil with concentrations above health risk-based
action levels would be excavated, physically pretreated to the proper soil grain size, and
treated to acceptable risk levels. Excavated areas would be backfilled. graded, and
revegetated in order to minimize erosion and wind-blown dust. The contaminated liquids
and extracted solids generated during soil washing would be incinerated off-site and
contained in an off-site landfill. Instirutional controls may be required for the site
prohibiting certain uses.
As with biological treatment. soil washing treatment of hazardous substances is an
innovative technology. Therefore. treatability testS will need to be performed to evaluate
the effectiveness of the process and aid in designing the treatment system. Completion of
the soil remediation at OUI is expected to take 5 to 6 years with this alternative. Toxiciry
and volume of the contaminated soils would be reduced through destruction (incineration)
and extraction (soil washing). This alternative would offer a permanent solution for the
site. Ground-water monitoring would be required for 30 years following completion, and
the PHE would be re-evaluated after 5 years.
VIII. Summary of Comparative Analysis of Alternatives
.'
This section presentS a comparison of alternatives using nine component criteria. These
criteria, which are set forth in OSWER Directive 93553-02.
1.
Protection of human health and the environment
2.
Compliance with ARARs
-------
3.
Reduction of toxiCity, mobility, or volume
4.
Long-term effectiveness and permanence
5.
Short-term effectiveness
6.
7.
Implementability
Cost
8.
State acceptance
9
Community acceptance
16
- -- . . -- ..~.
-------
CRITERION 1: PROTECTION OF HUMAN HEAL 11-1 AND 1HE ENVIRONMENT
Prerequisite Remedial Activities - Demolition/Disposal of Buildings and Tanks/Soil
Vacuum Extraction
The prerequisite remedial activities would be protective of human health and the
environment. Removing contaminated structures would eliminate direct contact with
contaminated materials. Vacuum extraction would reduce volatile organics from the soil
to appropriate action levels, precluding their movement into the ground water.
Alternative No.1- No Action
Under the No Action alternative, no remediation would take place and risk to public health
and the environment would not be redu~ed, eliminated, or controlled. Toxicity, mobility,
and volume of contaminantS would be unchanged. Thirty-year monitoring of ground water
would be required. Re-evaluation of the PHE at 5-year intervals would be necessary to
determine whether futUre action was warranted.
Alternative No.2- Capping/Institutional Controls
The cap would prOtect human health to the extent that it eliminates exposure via dermal
contact, ingestion, and inhalation. It would also reduce the potential for leaching of
contaminants into ground water. Because contaminants would also be left on-site, revision
of the PHE would be required at 5-year intervals to evaluate remaining risks and to develop
necessary corrective actions to reduce the risk.
Alternative No.3- On-Site Landfill Disposal/Institutional Controls
The on-site landfill would provide greater human health protection than capping because
contaminantS would be encapsulated and the landfill cap liner would significantly reduce
the potential for leachate to move into ground water. Overall protectiveness would be
related to maintenance of the cover and monitoring for failure of the liner. Because
contaminantS would remain on-site, revision of the PHE at 5-vear intervals would be
required to evaluate overall protectiveness of the alternative. .
Alternative No.4- OfT-Site Incineration/OfT-Site Disposal of Residuals and Soils
Alternative No.4 provides a high degree of protectiveness of human health. Highly
contaminated soils would be incinerated off-site, thereby destroying a significant portion of
contaminants. Remaining contaminated soils would be excavated and removed from the
site, eliminating the health threat that the contaminated soils presently pose through direct
contact and pOtential migration to ground water. A portion of the risk would be transferred
to an off-site landfill that is designed and managed to contain the contaminantS.
Alternative No.- S - On-Site Incineration/On-Site Fixation of Treated Residuals/On-Site
Landfill Disposal/Institutional Controls
Alternative No.5 would be protective of human health through destruction of organic
contamination and immobilization of remaining residuals. Long-term protectiveness would
require maintenance of the landfill and re-evaluation of the PHE at 5-year intervals.
-------
Alternative No.6 - Off-Site Incineration of Highly Contaminated Soil/On-Site Biological
Treatment of Remaining Contaminated Soil/Institutional Controls
Alternative No.6, the biological treatment alternative, provides a high degree of
protectiveness to human health and the environment. Highly contaminated soils would be
incinerated off-site, thereby destroying a significant portion of the contaminants.
The less contaminated remaining soil would be excavated and biologically treated on-site
in a lined treatment facility. Soils would be remediated to acceptable health risk-based
action levels and backfilled. This alternative would reduce the health threat posed by direct
contact to levels which would safely allow industrial use of the OUI area.
Alternative No.7 - Off-Site Incineration of Highly Contaminated Soil/On-Site \Vashing
Treatment of Remaining Contaminated Soil/Off-Site Incineration and Disposal of Soil
\Vash Residuals/Institutional Controls
Alternative No.7, the soil washing alternative, provides a high degree of protectiveness to
human health and the environment. Highly contaminated soils would be incinerated off-
site, thereby destroying a significant portion of the contaminants. The less contaminated
remaining soil would be excavated and treated on-site with a soil washing process. Once
soiis are treated to acc~ptable health risk-based action levels, they would be backfilled D.nd
the site revegetated. Residuals from the soil washing process would be incinerated off-site
and disposed of in a RCRA Subtitle C landfill. This alternative would reduce the health
threat posed by direct contact to levels which would safely allow industrial use of the OCI
area.
CRITERION 2: COMPLIANCE \VIm ARARs
CERCLA Section 121 requires selection of a remedial action that is protective of human
health and the environment. The determination of protectiveness is based on compliance
of the selected remedy with ARAR - or health-based action levels.
ADDJicabJe requirements are those cleanup standards, standards of control. and other
substantive environmental protection requirements, criteria, or limitations promulgared
under Federal or State law that specifically address a hazardous substance, pollutant,
contaminant, remedial action, location, or other circumstance at a CERCLA site.
Relevant and appropriate requirements are those cleanup standards, standards of control,
and other substantive environmental protection requirements, criteria, or limitations
promulgated under Federal or State law that, while not "applicable" to a hazardous
substance, pollutant, contaminant, remedial action, location, or other circumstance at a
CERCLA site, address problems or sitUations sufficiently similar to those encountered at
the CERCLA site that their use is well suited to the particular site.
The universe of possible ARARs for the alternatives described above is set forth in Table
VIII-I.
Prerequisite Remedial Activities - Demolition/Disposal of Buildings and Tanks/Soil
Vacuum Extraction
All ARARs pertaining to prerequisite remedial activities can be attained. OSHA health
and safety regulations would be followed during all phases of remedial activities. Air
-------
quality emission standards govern emissions resulting from vacuum extraction. Disposal of
contaminated structures must meet LDRs. The requiremems for these ARARs are found
in Table VIII-I.
Alternative No.1 - No Action
No action at OUI does not attain ARARs, cleanup goals, or the protection of human health
and the environment.
Alternative No.2 - Capping/Institutional Controls
Capping could be performed in compliance with ARARs. ARARs include OSHA worker
protection regulations, ambient air quality standards for particulate and vapor emissions
and Colorado noise abatement standards. The cap would be constructed to comply with
substantive and technical requirements of RCRA These substantive and technical
requirements for RCRA caps are found in Table VIII-I.
Alternative No.3 - On-Site Landfill Disposal/Institutional Controls
Compliance with AR~s is feasible for the on-site landfill. AR~s include construction
of the landfill to RCRA minimum technology requirements. OSHA worker protection
regulations, particulate and vapor emission regulations, Colorado noise abatement
standards, and Land Disposal Restrictions. The requirements for these AR.~s are found
in Table VIII-I.
Alternative No.4 - Off-Site Incineration/Off-Site Disposal of Residuals and Soils
. All ARARs pertaining to Alternative No.4 can be attained. ARARs include OSHA worker
protection regulations, particulate and vapor emission regulations, the rules and regulations
governing the transportation of hazardous materials within Colorado, hazardous materials
transportation regulations. and Land Disposal Regulations. The requirements for these
ARARs are found in Table vlU-I.
Alternative No.5 - On-Site Incineration/On-Site Fixation of Treated Residuals/On-Site
Landfill Disposal/Institutional CorHrols
Alternative No.5 involves a significant amount of soil handling during pret'aration for
incineratio~ and the production of on-site incinerator emissions. These activities have the
potential for the generation or significant quantities of fugitive dustS. Air qualiry emission
standards, Colorado noise abatement standards, LDRs, and RCRA destruction and removal
efficiencies for the incinerator would be critical ARARs to be met. This alternative has the
most stringent MARs of those evaluated, although it is possible to meet all requirements.
the most stringent ARARs of the alternatives evaluated. The requirementS for these
. ARARs are found in Table VIII-I.
Alternative No.6 - Off-Site Incineration of Highly Contaminated Soil/On-site Biological
Treatment of Remaining Contaminated Soil/Institutional Controls
The ARARs associated with the biological treatment alternative pertain to excavation,
stockpiling, demolition, air stripping, backfilling, and bioremediation activities for on-site
operations and hazardous waste transport, incineration emissions and land disposal for off-
site activities. During on-site activities, dust generatio~ excavation and incineration noise,
and vapor emissions would be of concern. Workers would be required to follow OSHA
health and safety regulations throughout the remediation activities as required in the
-------
lAOI.E VIII-'
ARAlls fOil SAUD CR(EK (xil
COH1A~IHAHI-SP(ClfIC ARARs AUO 10Cs
------.---.-..---..------------------------------------....----.---------------------------------------------------------------------------------------------------
Standard, Requirement,
Criteria, or Limitation
Citat ion
Oeser i pt ion
Appl icabl e or
Rclevilnt and
Appropriate
federal AURs
...--------....----------------------------------------------------------------.----------------------------------------------.----------------------------------
Coament
--.----------
Safe Drinking Uater Act
National Primary Drinking
\later Standards
N
a
~o USC Sec. 300g
~o CfR Part ,~,
Establishes health-based standards
for publ ic water systems (maXi/lUl1
contaminant levels)
IDC
lhe HCls for inorganic and
organic contaminants are to be
considered because they were used
to back-calculate acceptable soil
concentrations for contaminants
-------
TAOl~ VIII.1 (continued)
AMAAs fUA SAND CAEEK OU1
lOCATION.SPEClfIC AAAAs AND ToCs
---.-.------------.----.-----------------------------.--------------------------------------------------------------------------------------------------
Standard, Requirement,
Criteria, or limitation
Citat ion
Description
A!lpl iCilble
or Relevilnt
ilnd Appropriate
federal ARARs
-.------------------------------------------------------------.-----------------------------------------.-----------------------------------------------
COITIIIent
---.---------
National Historic
Preservation Act
N
.....
Archeological and Historic
Preservation Act
Historic Sites, Buildings
and Antiquities Act
fish and Ulldllfe
Coordination Act
1,0 USC Sec. 1,70
1,0 CFR Sec. 6.J01(b)
36 CFW Pilrt 800
16 use Sec. 1,69
1,0 efR Sec. 6301(c)
16 USC Sec. 1,61-1,67
1,0 CFR Sec. 6.301(a)
16 use Sec. 661-666
1,0 CfR Sec. 6.302(g)
"
Requires f"deral agencies to till:e
into account the ellect 01 ilny
FederollY-iissisted undertilking or
licensi~g on ilny district, site,
wi Iding. :.tructurc, or ohject Ihilt
is includ.::d in or cI igiblc lor
inclusio/\ in Ihe Nalio/\ill Register
01 Itistol Ie Places.
Establ ishcs procedures to provide
for preservation 01 historical and
ilrcheologicill datil which might be
destroyed through alteration 01
terrain as iI result of a Fed"rill
constructiun project or a Federiltly
licensed ilctivity or program.
Requi res 1 ~dcl"al ilgenci es to
consider Ihe existence and local ion
01 lilnc.."iJlks on the Niltionill
Registry of Naturill lilndnorks to
avoid unde:;irabte il~acts on eilch
lilnclmiJrks.
Requires consultation when Federill
de~artn~nt or ilgcncy proposes or
iluthorilc~ ilny modification 01 any
streilm 01" other water body ilnd
adequate provision for protection of
I/o/I/o
NO/I/o
No/llo
NO/NO
The remedy does not elf ec t ilny
district, site, building,
structure, or object listed on or
eligible for the National Rcgist~r.
The remedy does not effect
historical or archeological data.
The remedy docs not effect ilny
Natural landllark.
Alterniltives developed will not
-------
TAOlE VIII-1 (cont inued)
ARARs FOR SAND CWEEK OUI
lOCAIIOH-5PECIFIC ARARs AHD TUCs
--.----------------------..------..--......-.......-- -..............-...... -----...-..... .-- --..... -- -- ---... ......--..... ----... --........--_... ---..-....... - ---... --....... -..--------...-.........--.......---------- ---...
Standard, Requirement,
Criteria, or limitation
Ci tat ion
Description
Appl ic.oble
or Relevant
and Appropriate
..
.-----------------------..---------------------..-..-------...-.....",----........---------...-.........-----...-.......-........-------.....------------...-----........----...........-..--------------..
C OIIlIIe n t
Endangered Species Act
Clean ~ater Act
Dredge or fill
Requirements (Section '04)
N
N
Executive Order on
floodplain Hanagement
~ilderncss Act
16 use 1531
50 CfR Part 200
50 CFR Part 1,02
fish and wildlife resources.
Rcquires action to conserve
endangered species within critical
hdbits upon which endangered species
depend, includes consul tat ion wi th'
Oepartn~nt of Interior.
1251-1176
33 use Sec.
'0 CFR Parts 230,
231
Exec. Order No.
11 ,988
'0 eFR Sec. 6.302(b)
Append i x A
16 use Sec. 1131
50 CFR 35.1
Requires permi ts for discharge of
dredged or fill material into
navigable waters.
Requires FeJeral agencies to
evaluate the potent iill effects of
Dct ions they may tak.e in a
floodplain to avoid, to the maxirrr..fll
extent possible, the adverse in~acts
as;>ociatcd with direct and indirect
developnent of a floodpl~in.
Adninister federally owned
wilderness ilrea to leave it
unimpacted.
No/No
Yes/I/o
No/No
No/llo
No endangered species arc
present on the COC site.
A permit is not required for
onsite CERClA response actions,
but substantive requirements
would be met if an alternative
developed would involve discharge
of dredged or fill material into
navigilble wilters. This is not
anticipated.
If Dn alternative developed that
would affect a floodplain this
would be applicable. This is not
anticipated. Operable Unit No.1
is located outside of the 100-
year floodplain.
110 wilderness area on-site or
-------
JADlE VIII-1 (continued)
ARARs FOR SAND CREEK 001
lOCAJION-SPECIFIC ARARs AND JDCs
_...e___...---------------------------------------.---~----_.._-_.._------------------------------------------------------------------------------------
Standard, Requirement,
Criteria, or limitation
Citilt ion
Description
Appl icable
or Relevant
and Apprcpriate
Coomcnt
National Ulldlife Refuge
--------------------------------------------------------------------------------------------------------------------------------------------------------
No wilderness area on-site or
System
Scenic River Act
Coastal Zone Management
Act
N
W
State ARARs
-----------
Requirements for Siting of
Hazardous Uaste Disposal
Sites
Colorado Hazardous ~aste
Management Regulations
16 use Sec. 668
50 CFR Part 27
16 use Sec. 1271
~O efR Part 6.302(e)
16 use Sec. 1~51
6 CCR 1007-2, Pt II,
Sections 2.1, 2.~.
and 2.5
6 eCR 1007-3
Rcstricts activities within a
Nat ion,,1 IIi Idl i fc Refuge.
Prohibits adverse cffects on sccnic
river.
Conduct activitics in accordance
with state-approv~d managcmcnt
program.
Geologic/llydrologic conditions lTust
assure waste isolation from exposure
pathways for 1000 years. Siting
must assure short- and long-term
protection of hlnan health and
envi ronncllt.
Siting is restricted in vicinity of
recent faulting. No hazardous w~ste
disposal can occur in a 100 year
floodplain. Dispo~ill into or below
surfilce waster and !}ruund watcr is
prohibi tcd.
11,,/110
No/No
No/llo
Ycs/No
Yes/No
adjacent to site.
No scenic river In area.
Area is not in the ~oastal lone.
Applicable if an on-site hazardous
waste disposal facility Is planned.
Applicable if an on-site hazardous
waste dispo~al facility is
-------
'''OLE VIII-1 (continucd)
ARARs FOR SAND CREEK 0.11
LOCA'ION-SPECIFIC ARARs AND 'UCs
----.-----..--------------------------------------.-----------------------------------------------------------------------------------------------------
Standard, Requirement,
Criteria, or limitation
Citation
Dcscription
Appl ic ubI e
or Relevant
and Appropriate
Comncnt
------------------------------.---.---------------------------------------------------------------------------------------------------------------------
Regulations Pertaining to
Solid Uaste Disposal Sites
and facilities
N
~
Colorado State Historical
Society
6 CCR 1007-2,
Sections 1.3.2, 2.1,
2.2, 2.', '.1, 6.1
Sections 2'-80-201,
202,211; Scctions
2'-801-\01,102
103,10',108
Siting ml~t maximize wind protection
and minimi IC upstrci.m drainagc arca.
No sol id .,.lste disposal ciln occur in
a 100-year floodplain. Disposal
into or bclow surface water and
ground wat~r is prohibitcd.
I mpoundnent des i gn is cont roll cd by
a sitc's location in rclation to the
uppcr-most aquifcr and by water
qual i ty in thc aqui fer.
Sites within state of fedcral
historic ~rcscrvation areas will be
required to prcserve historic
character.
YeslNo
Applicable if an on-site solid
waste disposal facility is
cntemplated.
NolNo
-------
lADLI: vlll-1 (cont inued)
ARARs fOR SAND CREEK GU1
~ClION-SPEClfIC ARARs AND lDCs
----.---------------------------------------------------------------------------------------------------------------------------------------------------
Standard. Requirement.
Criteria. or Limitation
Citation
Oescr i pt ion
Appl i cabl e
or Relevant
and Appropriate
Federal ARARs
--- ----------------------------------------------------------------------------------------------------------------------------------------------------
Comnent
-------------
Land Disposal of Hazardous
\laste
California list Treatment
Standards for HOCs
N
In
Interim Treatment
Standards for Soil and
Oebr Is
Occupational Safety and
Health Act
Hazardous Haterlals
Transportation Act
Hazardous Haterials
Transportation Regulations
~o CfR Part 266.32
29 use Sec. 651-676
~9 USC Sec. 1601-1813
~9 CfR Parts 107,
171-171
lreatment 01 w..:aes subject to ban
on land dbposal.
DDAr star~..rds have not becn
developed for the P and U wastes
present in 01.11 soi Is. Interim
trcatmcnt standards should be
considercd.
RCtlulates worker hcalth ar~ safety.
Rcgul atcs transportat ion of
hazardous IIl.1tcrials.
Ycs/No
Yes/No
Yes/No
Nonliquid hazardous wastes
containing HOCs in total
concentrations greater than 1,000
RI'J/kg Rust be incin~rated prior
to land disposal. 1,000 CY of
OUl soils exceed this limit.
Thc5e soils will be incinerated
if excavated and land disposed.
TBC
See lable VIII-IA for interim
treatment standards for soil and
debris.
Undcr ~o CfR Section 300.38,
requiren~nts of this Act apply to
all response activities under the
NCP.
Applicable only if an alternative
dcveloped would involve transp.Jrta-
-------
fAIJLE VIII.1A
lAIID DISPOSAL RESTRICIIOII GIJIOElIIIES TO BE COIISIOERED
FOR SOilS III OPERAULE UIIIT 110. 1
SAIIO CREEK IIIDusrRIAL SirE
-----------------..--------........---------.....-.... ......---.. -.......... -........... ---............. -.......... --.......... -.................... .......... ....--..------...-----......--....-
Chemical of Concern
Intcrim Trcat"~nt Rangc for
Soil and Oebris Oil~e(f on LMKJ
Disposal Restrictions (a,I»
Threshold Concentration
Percent Reduction Range
......--..------..----..----------..-..---..----....-..-......... ..--....-..-... ---.............. ---........ .._---...-..-- -.. -............................ ...... --- ....----..--.......----..---...
VOLATllES(c)
-------..----
Chloroform
Mcthylene chloride
Tetrachloroethane
Trichloroethene
500 . 2,000 ppb 1,0,000 ppb 95 - 99.9
500 - 2,000 ppb 1,0,000 Pf.b 95 - 99.9
500 - 2,000 ppb 1,0,000 ppb 95 - 99.9
500 - 2,000 ppb /'0,000 ppb 95 - 99.9
PESTICIDES AND HERBICIDES(c)
-..--------------------------
N
(J\
4,4-0DT
Chlordane
Dieldrin
Hcptachlor
2,4-0
500 . 10,000 flpb 100,000 ppb 90 - 99.9
500 - 20,000 ppb 200,000 PI,b 90 - 99.9
500 - 10,OUO ppb 100,OOl) pf-I> 90 - 99.9
500 - 20,000 pph 200,000 ppb 90 - 99.9
0.01 - 50 PI,I> 500 pph 90 - 99.9
HETAlS(d)
---------
Arsenic
CaaniUl!
Chromlun
lead
Nickel
0.3 - 1. 0 ppb 10 ppb 90 - 99.9
0.2 - 2.0 ppb 1,0 ppb 95 - 99.9
0.5 - 6.0 ppb 120 ppb 95 - ~.9
0.1 - 3.0 ppb 300 rrb 99 - 99.9
0.5 - 1. 0 ppb 20 ppb 95 - 99.9
------------------------------------------------------------.-------.-.------.----.-..-----.-----------------------.------------
(II) Source: June " 1968 mcmorandun from OERR rcgarding interim treatmenl levels for soi I IInd lkl1ris.
(b) Uhen the untreated conccntratlon Is between thc treatmcnt level and the threshold concentrlltion, the t'"catment should rcduce
the concentration In the residuals to no morc than the I11
-------
lADLE VIII-1 {continued}
ARAR~ fOR SAND CRtEK 0111
ACIIO"-SPEClfIC ARARs AND IUCs
---.-------------------------------------------------.____e______------------------------------.--------------------------------------------------------.---------
Standard, Requirement,
Criteria, or limitation
Citation
Description
Appl ic.:.ble
or Relevant
and Ar-rropriate
State ARARs
-----------------------------------------------------------------------------------------------------------------------------------------------------------------
Coament
-----------
Rules and Regulations
Governing the
Transportation of
Hazardous Materials Uithin
Colorado
Colorado Noise Abatement
Statute
N
.......
10 CCA 723-'8,
HHI 1-9
Sections 2~-12-101,
102, 103, 104, 105,
106, 108
"'
EstalJlbhes specific requirements
for the trdnsportalion of hilzard~us
materials, especially regarding
label ing and placarding.
Establishes standards for
controll il1g noise.
Ycs/llo
Yes/llo
Applicable if hazardous material
is transported off site.
Applicable to alternatives that
-------
TADlE Vill-l (continued)
ARARs fOR SAIID CREEK OUI
ACTION-SPECifiC ARARs AND TDCs
----------.----------------.-.-----------------------------------.-.------..---------------------------.---------------------------------------------------------
Standard, Aequirement,
Criteria, or limitation
Cltat ion
Description
Appl icable
or Rei evant
and Appropriate
Colorado Uildllfe
Enforcement and Penalties
.-----------------------------------------------------------------------------------------------.---------------------------.------------------------------------
Coomcnt
Ulldllfe Commission
Aegulatlons
N
co
General Closure
Stationary Emissions
Sources; General controls
for remedial activities
Sections 33-6-101,
10Z, 103, 104, 105,
108, 109, 110, 111,
113, 114, 116, 117,
119, 120, IZ4, 126,
128, 129, no
2 CCA 406-0,
Articles I, III, IV,
V, VI, VII, VIII,
IX, X, XI,
6 CCA 1007-3, Part
261..111
5 CCR 1101-5,
Section IVO
Prohibits spccific actions in order
to protect wildlife.
Establishes specific requircments
for the protection of wildlife.
Colorado Hilzardolls \laHe Hanagcment
Rcgulations. Must minimize the necd
for further maintenance; control,
minimize or eliminate ( to the eA[Cnt
needed to protect hUn.:In heal th and
environment) the post'closure escape
of hazardous wastes, hazardous waste
constituents, leachate, contaminated
rainfall, or waste deconposition
products to ground wiJter, surface
water, or the atmosphere.
Source cannot calise cmissions to
cKceed any attainncllt ore a of ilny
UAAOS.
Yes/llo
Yes/Uo
Yes/llo
Yes/llo
Relevant and appropriate for
protccting wildlife near the site
during construction activities.
COC generated and managed
corrosive hazardous wastes and
spilled commercial chemical
products. COC generated and
managed RCRA hazardous wastes
after November 19, 1980.
COC site is in a non-attainment
area. The site could be
considcred a major source if it
emits more than 100 tons/year of
-------
TADLE VIII-I (continued)
AHAH:> fOH SAND CIIEEI: OIl!
ACTION-SPECifiC ARARs AND TDCs
...---..---------------------------------------------------------------.-..-------------------------------.------------------------------------------------------
Standard, Requirement,
Criteria, or limitation
Citation
Descript ion
Applicahle
or Relevant
aod Appropriate
Comnent
...--..------------------------------------..--------------------------------------------------------------------------------------------------------------------
Stationary Emission
Sources; General controls
for remedial activities
N
'4)
Tank Closure
Container Closure
5 eCR 1001-5,
Section IVD
5 ceR 1001-]
Sections 1110
5 eeR 1001-]
Section II
5 ceR 1001-1.
Section 2A
6 eCR 1007-] Part
264.197
6 ceR 1007-] Part
261. . 178
Source cannot inter fere wi th
attairvncnt and mdintenance of any
State NHOS.
Hinimize fu~itive dust emissions.
No emissions exceeding 201 capacity
arc allowed.
Oe5ign action to provide odor-free
operation.
All hazarduus wastes and residues
"'-1st be removed from tanks,
discharge control equiprnent and
discharge confinen~nt structures.
All hazardous wastes and residues
"'-1st be removed from contai~ncnt
system, if nny. Reffidining
containers, I iners, bases, and soi I
containing or contaminated with
residues IIJISt be decontaminated or
removed.
Yes/llo
Yes/flo
Yes/llo
Yes/flo
Yes/llo
Y cS/llo
eae site is in a non-attainment
arca.
Demolition and construction
activities, storage and handling
operations, and haul roads.
Specific sources "~y have other
I imi tat ions.
eomnercial chemical products in
tanks becon~ hazardous wastes
whcn closure begins. See clean
closure requirements for
generator/transporter
requirements. eoe managed their
hazardou$ wastes on tanks.
Comocrcial chemical products in
tanks become hazardous wastes
when closure begins. See clean
closure rcquiren~nts for
generator/transporter
-------
TABlE VIII-' (continued)
ARARs rOR SAUD CREEK CU'
ACTIOU-SPEClfIC ARARs AND TBCs
.----------------------------------------------..... ...... .........-.. --............ -... -................. -..- ---.... ---..-.... --.. --- -- -.. --.. ....--..- ------.....--....----.......-..---.......................
Standard, Requirement,
Criteria, or limitation
Citation
Descr ipt ion
Appl icabl e
or Rei evant
and Appropriate
Comnent
Closure of hazardous waste
management facilities
------.---...------.----------------------------..-----..---..--------------..--------------..------------..-..--..-..-----..---------------------..------......-----
Closure performance standards.
(H\lHf) :
Closing in place
(capping)
L.J
a
6 CCA 1007-3, Part
261. . 1 , 1
6 CCR 1007-3 Part
26~.310(a)
Gen~ral closure, as above- includes
waste m,magcment facilities, Waste
pi les, surface irr.poundlncnts and tank
SYSt£:ffiS.
Oesign und construct cover to:
Provide lon9 term minimizatiun of
migrat ion 01 I iqllhJs through the
cap.
funct ion wi th mininJJl11
milintenilncc.
Pron~te frainage and minimize
erosion or abrasion of the cover.
Accomnod.Jte set t ing and
suu:>idence to maintain the cover's
integrity.
!lave a permeability less than or
equal to the permcilbi Ii ty of the
bot toen I iner or Buillral sub-soi Is
present.
Yes/No
Yes/No
Spilled comncrcial chemical
products arc mixed with soils.
Design, construction and
monitoring requirements descri~d
herein olso apply to caps placed
-------
TABLE VIII-1 (continued)
ARARs fOR SAND CREEK 0111
ACIION-SPEClfIC AKARs AND 10Cs
.-.--.-----------------------------------------------------------------------------------------------------------------------------------------------------------
Standard, Requirement,
Criteria, or Limitation
CI tat ion
Description
Appl icabl e
or Relcvant
and Apprllpriate
-----------------------------------------------------------------------------------------------------------------------------------------------------------------
CCArment
W
t-'
Closure of "UHf:
Closing In place (capping)
6 CCR 1001-3 Part
261o.310(b)
6 eeR 1007-3 Part
261o.301(c)
6 eCR 1001-3 Part
264.301(<1) and (e)
6 eeR 1007-3 Part
2M.303(a)
Cap intcgrity na,st be maintained and
repaircd as necessary. leak
detection, leachate collection, and
leachate ren~val systems must be
operated and maintained. Surveyed
benchmarks ~ISt be protected and
maintained.
Run- on cont 1'01 IJ1.IS t be des i gned and
constructed to prevent flow onto the
cap during construction. The peak
discharge from at least a 100.year
storm must he controlled.
RlInoff conll'ol nalst be designed .Jnd
constructed to collect and cvntrol
the rllnoff frCAn a IOO-year 21,-hour
storm, both during cap construction
and milinten.lI1ce. Collect ion/holding
facilities associated with run-on
and rl~-off control must be designed
to C!xpcditiously maintain capacity
after storms.
During construction, cap systems
n~st be inspected for uniformity,
damage and iwpcrfeclions. Synthetic
meni)rane:; II"St be in:;pccted to
ensure tight scams and joints ilnd
the absence of tears, pur,ctures or
blbters. Soil-based and adnix~d
cup:> must b~ inspcct~J lor holes, vI'
Yc~/llo
Yes/No
Yes/llo
Yes/No
Also applies to run-on control
during fixed waste disposal cell
construction.
Also applies to fixed waste cell,
liner and cap construction.
Also applies to fixed waste cell,
-------
'ABLE VIII.' (continued)
ARARs fOR SAND CREEK OUI
ACTION-SPECifiC ARARs A"D 'DCs
---------------------------------------------------------------------.....--------------------------------------------------------------------------,-------------
Standard, Aequirement,
Criteria, or limitation
Citation
Description
Appl i cilbl e
or Relevilnt
and Appropriate
-----------------------------------------------------------------------------------------------------------------------------------------------------------------
Coomcnt
..J
~
Ctosure of HUHF:
Ctosing in place(capping)
6 CCA 1007-3, Pilrt
264.309
6 CCA 1007-3 Part
264.91(~ Part 26~.92)
Part 26~.9~(a)
Part 26~.97(a)
other structural nonuniformities
that may c.Juse an increilse in the
perlllcilbi t i ty of the cap.
'he exact location and dimension,
including uepth, of disposal cells
IIJ.ISt be shuwn on site maps rei ilt ive
to pefmilnently surveyed benchmarks.
'he contents of each cell and
location of each hazardous wilste
type must also be shown.
Implement a ground water detection
n~nitoring program to ensure that
the ground water protection stand..rd
is complied with. Concentrations of
hazardous constituents cannot
exceed;
tilble vdlues, or
buckground levels, where no t"hle
value is specified.
Ground water monitoring IWst consist
of a sufficient nUlher of wells with
appropriatc depths ond locutions to
yield s.llI'(1les capable of determining
background water qllill i ty and w..ter
qUill i t Y pa"s i n9 a p'J i nt 0 f
con-pl i ancc.
Yes/No
Yes/No
Yes/No
Also applies to fixed waste
disposal cells and caps.
Yill also apply to waste
treatment/on-site disposal
alterniltives tike fixation and
soil washing or incineration, if
residues cannot-be delisted.
Existing wett fietd wilt need to
be reviewed during remedial
-------
TABlE VII'-1 (continued)
ARARs fOR SAND CRfEK DJ1
ACTION-SPECifiC A~ARs AND TDCs
----...-----......-------------------.-----------....--.---------------------------------------------------------------------------------------------------------
Standard, Requirement,
Criteria, or Limitation
Citation
Descript ion
Appl icable
or Relevant
and Appropriate
-----------...------------------------------------------------------------------------------------------------------------------------.--------------------------
Conmcnt
w
w
Closure 01 H~F:
Closing in place (capping)
Part 26~.97(c), (d)
and (e)
Part 261,.97(h)
6 CCR 1007-2 Part 2,
Sections 2.~,
1-2.1,.5
6 CCR 1007-2 Part 2
Section 2.~.7
6 CCR 1007-2 Part 2
Section 2.~.8
6 CCR 1007.2 Part 2
Sections 2.~.9,
2.~. 10
6 CCR 1007-J Port
261, . 117
Ground water wells ~Ist be cased in
a manner ensuring well integrity,
and sarrpled using methods ensuring
sarnple/analysis integrity.
Ground water san~les ~Jst be
collecled and analyzcd at a
frequency lhilt allows for val id
statistical analysis integrity.
Design fdcility to prevent lon~"term
adverse effects on grolmd water,
surface water, air qual Ity, publ ic
heal th, and the envirorvnent.
Design runoff control system with
sufficient capacity to prevent
advese effects on grol/nd water,'
sl/rface wate, air quality, public
heal th, ilr,d the envi rorolllent.
Close filcilily 10 assure prevention
of 10ng"lerm ildverse effects.
Monitor ground water, surface water,
and provide quality control durin!)
cc,nstruct ion.
Restrict post-closure
property as necessary
cover damage.
use of
to prevent
Yes/llo
Ye~/No
Ye~/No
Ye~/No
Yes/No
YC,,/llo
Yes/No
Existing well field and any
additional wells placed at Ihe
site Irust be assessed.
Applicable to ground water
sampling at the site.
Part 2 of the State solid waste
regs contains siting and design
criteria for hazardous waste
disposal sites built after July
-------
TABLE VIII-I (continucd)
ARARs fOR SAND CIIEU: 0111
ACTION-SPECifiC ARARs AND TBCs
----...---------.----.------------------.-------------------------------------.----------------------------.-----------------------------------------------------
Standard, Requirement,
Criteria, or limitation
Citation
Description
AI~pl iCiJble
or Relcvant
and Appropriate
Clean Closure ( Removal
with off'slte disposal
-----------.-.---------------------------------------------------------------------------------------------------------------------------------------------------
Comnent
JoJ
po
Notification
Manifests
. .
6 CCR 1007-] PiJrt
261..111
5 CCR 1001-9
Section 11.0.1 anU 2
6 CCR 1007-] Part
261..111.
6 CCR 1007-] Part 99
6 CCR 1007-] Part
262, subpart B
Genercral closure, as above.
VOC source can bni t no OIore than 1,50
I bs/hour or 3000 I bs/d,IY of VOCs
without applying reasonably
available control technology (RACT).
Oi:.pose of or decon all facility
equipn~nt and structures by ren~ving
all hazardous wastes and residues.
Any person who generates or
transports hazardous wastes IIUSt
file a notification of hazardous
waste activity before beginning such
activity.
A manifest must be prepared by a
generator before it is offered for
transportation offsite. The
mani test nust ident i fy the fdci Ii ty
permi lied to h..mdle the waste
de:.cribc therelJn, and m"y dcsi!lrliltc
an al tcrnat ivc fdc i I i ty. Thc
m..lni fest format 1I.'St be consi:.tent
with those ottered by the
Yes/No
Yc~/tlo
Ye:./tlo
Yes/tlo
Ye:./No
To cstmate soil volumes,
containment concentrations above
which clcnup will occur are set
at bacl.ground or the value
corresponding to one excess
can~~r in on million cases.
Soils at COC also have VOCs in
them. Oesign to use RACT is
made after Q health:based risk
assessment using air modeling.
If tank contents, containers and
contaminated soils are being
shipped offsite as part of
closure activities.
-------
TADIE VIII.I (continued)
ARARs FOR SAUO CREEK OJI
ACTIOU'SP[CIFIC ARARs AIIO TBCs
---------.----------------------------.--------.----..-.-.-.-......-[[[--..-.--.--------...-.-..-..-..--
Standard, Requirement,
Criteria, or limitation
Citation
Oescrifltion
Appl it;abl e
or Rei ev.IIH
and I.ppropr LH e
------------------------------------------------.--.---...-..-.....-.-......-..-.-.........--....-...............-.-...-..~.._.-..._------..__._-_...._-...._.-..
COITIDCnt
Pro-transport requirements
oJ
n
Transportat ion
Clean Closure
(Removal with
di sposal)
off-site
6 CCR 1007-] Part
262 .3, . J 1, and . n
6 CCR 1007-3 Part
263.11CA)
6 CCR 1001-] Part
263_20
con~ignmcnt (dcstination) state or
gcnerator ~tate, respectively.
Generator n~Jst sign the mani fest,
obtain the signature of the initi~1
transporter, retain one copy, and
give remaining copies to the initiill
transporter.
A generator must package the waste
in accordance with PUC or Dor
regulations in ~O CPR Parts ITJ, 176
and 179. Each package must be
labeled or marked in accordance with
PUC or OOT rc~ulations in ~9 CFR
P~rt 172. lor containers of 110
yatlons or less, markings a'Jst
comply wi th requirements of ~O CPR
17Z.JO~. 'he generiltor must
plac~rd, or offer placards to the
initial transporter, in accordance
wi th ~9 CFR Part 172 Subpart f.
A transporter must not transport
hazardous wastes without an EPA 10
nLMl1bc r .
A tr~nspqrter may not receive
hazardous wa~te from a generator
unle!;s it i~ ilccOtlpanied by a
mani fest. 'he transporter must sign
and date the milOi fest, acknowll'<1ging
acceptance, and must leave on copy
\'e~/llo
\'es/llo
\'es/llo
-------
TAOIE VIII-' (continucd)
AIIARs FOR SAUD CREEK OtJ1
ACTION-SPECIFIC ARARs AND fOCs
o
--'....------------------------------------------------------------.-.----...--.---------------------------------------------------------------------------------
Standard, Requirement,
Criteria, or limitation
Citat ion
Dcscription
Appl icable
or Relevant
and Appropriate
-----------------------------------------------------------------------------------------------------------------------------------------------------------------
Currncnt
Transportat Ion
W
0\
Clean closure (removal
with treatment In tanks)
6 CCR 1007-3 Part
263, Subpart C
6 eeR 1007-3 Part
264.191(a)
with the gcnerator. Upon delivcry
to the d~signatcd facility, the
trilnsponcr n..lst olJtain thc d.!tc of
del ivcry urld thc signature of the
owner/operatur. fhe tran~poncr
rru"t rctain onc copy of the si!jncd
mani fcs t.
If D dischargc of hazardous waste
occurs during transponat ion, thc
transporter must takc appropriate
illlllcdiate act ion to protcct hum.:m
hcalth and environment. The
transportcr must report thc
dischar!jc and ult i,uatc rcsolut ion to
PUC, DOT and COHo fhc transportcr
flJJst clc.!n up thc disGharge or take
other appropriate action so that the
discharge no longer presents a
hazard to hl~n health or
cnviromlCnt.
Tanks nAlst have sufficient shell
strength, foundation strength,
structuri.1 support, and for clo~ed
tanks, prcssure controls to assure
th
-------
TABlE VIII-I (continucd)
ARAMs fOR SAND CREE~ OUI
ACT lOll-SPECifiC AMARs AIIO 10C:>
-----.-------------------------------------------------.---------------------------------------------------------------------------------------------------------
Standard, Requirement,
Criteria, or limitation
Ci tat ion
-.------------------------------------..----------------------------------------------------------------------------------.-.------------------------------------
Conrncnt
6 CCR 1007-] Part
261.. 192(a)
w
......
6 CCR 1007-] Part
261.. 192(b)
6 CCR 1007-3 Part
2M.191.(a)(1-])
Description
Uastes and other material (c.g.,
trcat"~nt reagents) that arc
inco.r.pat ihle wi th the IIIiIteri..1 of
construction of the tank "~st not be
placed in thc tank, unless it is
pl'otected Irom acceler~ted
corrcsion, erosion, or uhrasiun
through the use 01 an inner liner or
coating that is cOf/'4)atible with tank
contents and that is free of ICill-s,
cracks, h0les, or other
deterioration, or through
alternative ffiCans of protection.
Overfilling /lJ.Jst be prevented by
including control methods or, for
uncovered tanks, maintenance of a
sufficicnt frcc-Leard to prcvent
ovcrtopping by wave or wind action,
or by prccipitation.
Daily inspections nust be conductcd
on overfilling control equipl~nt,
tank intcgrity, monitoring
<:quir..mcnt, and thc levcl of w..stes
in uncovered tanks.
Appl icabl e
or Relev.Jnt
and Appropriatc
Yes/No
Yes/No
Yes/No
Applicable if incombatible wastes
a~e placed in tanks.
Applicable if wastc is placed in
tanks.
Applicable if waste is placed in
-------
TADIE VIlI-1 (continued)
ARARs FOR SAND CREEK 01/1
ACTION-SPECIFIC ARARs AND ToCs
.....----------.------------------------------------------------.-.--------------------------------------.-.-----------------------------------------------------
Standard, Requirement,
Criteria, or limitation
Citation
Description
Appl iCilble
or Rclevant
and Appropriate
Clean closure (removal
with treatment in tanks)
-----------------------------------------------------------------------------------------------------------------------------------------.-----------------------
Coament
w
co
Clean closure (removal
with incineration onsite)
6 eCR 1007-3 Part
261,.191, (a)( I,) and
(5)
6 eeR 1007-3 Part
264.31,1; Part
100.22(c)(3) and (I,)
Part 261,.31,0
\leek I y i nspec t ions IIUS t be conduc t ed
on the construction materials of
above-ground tanks and of the area
around them for obvious signs of
tank deterioration and leakage.
Analyze the waste feed.
No further requirements, except
waste analyses and closure, apply to
incinerators that only burn wastes
listed as hazardous solely by virtue
of the characteristic or
ignitability, corrosivity, or toth;
or the characteristic of reactivity
if the wastes will not be burned
when other hazardous wastes are
present in the conbust ion zone; and
if the waSle analysis shows that the
wastes contain none of the hazardous
constituents listed in Appendix VIII
which might reasonably be expectL'd
to te pre:;cnt.
Pcrforll~nce stilndards for
incinerators:
Yes/No
Yes/llo
No/No
Applicable it waste is placed in
tanks.
Additional waste analyses will be
needed during remedial design.
Hazardous wastes at coe are
listed tor toxicity and acute
tOKicity, not ignitability or
-------
TABLE VIII-1 (continued)
ARARs fOR SAUD CREEK 001
ACTIOt/-SPECIfIC ARARs AIID TBCs
-------------------------------------..----------------.-----...-------.-.---------------------------------------------------------------------------------------
Standard, Requirement,
Criteria, or limitation
C itat ion
Description
Appl icable
or Rclevant
IInJ Appropriate
-----------------------------.-----------------------------------------------------------------------------------------------------------------------------------
Cooment
Ctean ctosure (removat
with incineration onsite)
W
\0
6 CCR 1007-3 Part
261..31,3 (a)( 1)
6 CCR 1007-3 Part
261, .31,3( a)( 2) and
Part 261,.31,3(b)
6 eCR 1007-3 Part
261,.31,3(c) also,S
eeR 1001-8, Scct.
III C.1
6 eCR 1007-3 Part
261,.3I,S(c)
Part 261, .3I,S(d)
Part 261,.371,
- Achieve a destruction and removal
efficiency of 99.9tJ percent 'or each
principal or!]anic hazardous
constituenl in the waste feed and,
- 99.9999 perccnt for f020, f021,
f022, F021, f02b, f027 wastes.
- Reduce hydro!]cn chloride
emissions lo 1.8 k!]/hr or 1 percent
of the HCI in the ~tack gases before
entering any pollut ion control
devices.
- Emissions of part iculate matter
ca~not eKceed D.Otl grains per dry
standard cubic foot when corrected
for the amount of olly!]cn in the
stack !]as.
Operate within specificd limits
during startup and shutdown.
Controt fU!litivc cmissions from thc
c~lbustiun lcnc.
Hcnitorin!l of various parameters
duriny operation of thc incinerator
is rcquired. Thesc paran~ters
i rocl "de:
Yes/No
Yes/llo
Yes/No
Yes/I/o
Ye:./llo
Yes/llo
Applicable if waste is
incineratcd.
If waste is a f020, f021, f022
f021, f027 or f029 waste.
Gcneral capacity limitation also
applies to new incineration
-------
TABLE VIII-! (continued)
ARARs FOR SAND CREEK OU!
ACTION-SPECIFIC ARARs AND TBCs
--------------------....----------...----------------------------.-.--------------------.---------------------------------------------------------------
Standard, Requirement,
Criteria, or limitation
Citation
Description
Appl i cabl e
or Relevant
and Appropri ate
--------------------------.------------------------------------------------------------------------------.-..-------------------------------------------
Comnent
Clean closure (removal
with Incineration onslte)
~
a
Clean closure (removal
with Incineration onslte)
6 CCN 1007-3 Part
264.341(a)
Part 261t.347(b)
Part 261,.347(c)
Part 264.3S1
5 CCR 1001-3 Sec.
VIS
- Combust iOIl tenpcrature
- Uaste feed rate
- An indicdlcr of cunbustion gas
velocity
- Carbon n~noxide
- Uaste ilnd exhaust emissions upon
requcs t .
Dai Iy visual inspect ions of
incinerator ard associated
equipment.
Operate with an automatic feed
cutoff system; inspect weekly
At closure, all hazardous waste and
residues, including ash, scruLVcr
water, and scrubber sludge must be
removed from the site.
Sources can emit no more than 2
tons/day of sulfur dioxide.
Yes/llo
Yes/No
Yes/llo
Yes/No
Ye~/No
Specific sources may have other
limitations. Use best available
control technology.
-------
JADIE VIII.t (continued)
ARARs fOR SAND CREEK out
ACTION-SPECIfiC ARARs AND TUCs
..-----------.---------------------------------------------------------------------------------------------------------------------------------------------------
Standard, Requirement,
Criteria, or limitation
Citation
Descript ion
Appl i cdbl e
or Relevant
and Appropriate
...--..-----------------.---------.--------...-----------------.--------------------------------------.-.-----------------.--------------------------------------
Cooment
Emission of metals from
Incinerators
~
.....
Oo-,Ito disposal of
treatment residues
On-site disposal of
treatment residues
5 eCR 1001-3 Sec.
ilIA
6 ceR 1007-3 Part
260.22(0)
6 eeR 1007-2 Part 2,
Sec. 2.~.t-2.~.5.
Cunply with particulate limitations.
Colo. Air Quality Control
C~lmission Regulation #6, Sec. 6
Anbient air quality standards for
State of Ha~sachusetts. Currently
used as guidel ine for StiHe of
Colorado.
A demonstration must be made that
the waste no longer meets any of the
criteria under which it was listed
as hazardous und~r Part 26 t, subpart
D.
Design facility to prevent long ter~
adv~rsc effects on grounds water,
surface watcr, air quality, public
heal th, and the envi,.onn:cnt.
Yes/No
TDC
Yes/No
YeslNo
TDC
functions of heat input. Applies
to the operation of fuel burning
equ i flnen t.
The 8nbient air quality standard
for lead is 1.5 ug/m (avg.
n~nthly modeled standard).
The State has metals emissions
guidelines of 0.0003 uglm for
cadmium, 0.69 ug/m ,hromium,
and 0.18 uglm for nickel.
If the waste is listed with code
"I", the petition must demonstrate
that the residues do not contain
the constituent (app. 7) that
caused it to be listed, using the
appropriate app. 7 test method; or
the waste does not meet the
criterion of Part 261.11(a)(3),
considering the factors In ~o CfR
Parts 26\.11(a)(i) through (xi).
Part 2 of the State solid waste
re9S contains siting and desi9n
criteria for hazardous waste
disposal sites built after July
t, 1981. These requirements are
applicable if a hazardous waste
-------
TABLE VIII-1 (continucd)
ARARs FOR SAND CREEK 00\
ACTION-SPECIFIC ARARs AND 'BCs
--.-.-..---.-.......---........-----------------------_._---~..-.._.-.----------_._---.__._----------------------------------------------------------------------
Standard, Requirement,
Criteria, or limitation
CiUtion
....-------.-.------------------------------------------_._----------------------~-------------------------------------------------------------------------------
Yes/No
Port 2
Sec. 2.1,.6
Part 2
Sec. 2.5.3
Part 2, Sec. 2.1,.9,
2.1,.10
.po
N
Description
Protect the 'unction and intcgrity
of I iner(s)
Isolate wastes for 1000 years.
Honi tor ground water, surface water,
and provide quality control during
conl ruc t ion.
Applicable
or Re I ev.mt
Dnd Appropriote
Comncnt
Ycs/No
-------
tADLE VIII-I (cont inued)
ARARs FOR SAND CREEK 0111
ACTION-SPECIFIC ARARs AND TDCs
----.---------------------------------------------------------------------------...-----------------------------------------------------------------------.-.----
Standard, Requirement,
Crlterl., or Limitation
Cltat i on
------------.----------------------------------------------------------------------------------------------------------------------------------------------------
Ccament
On-site disposal of
treatment residues
Part 2. Sec. 2.~.8
Part 2, Sec. 2.~.7
2.5.5
6 CCA 1007-3 Part
2M.30Ha)(1)
I:"-
..J
Description
Close facility to assure prevention
01 long- term aLiverse effects.
Design leachate and runoff control
system to prevent adverse effects on
ground water, surlace water, air
quality, public health, and the
envi rOl'lnent.
Use liner which prevents waste
migration into adj~cent soil, ground
water, surlace water, or liner
itself during the ac.tive Ii Ie 01 the
I andl i II, inc ILldi n9 cI osure.
Design and construct liner to
prevent failure due to pressure
gradients, contact with wastes,
climate, alod stress 01 imaallation
and daily operations.
The liner IIUSt be placed on a
foundation that will provide support
and resistance to pressure gradients
above and below the liner, to
prevent lailure duc to settlement,
cou.)ress i on or upl i It.
'he liner 1I1l1:>\ cover all areas
likely to be in contact with waste
or I each..tc.
Appl icable
or Relev.mt
and Appropriate
Yes/Uo
Yes/No
Yes/No
Fixation alternativ~ as now
proposed does not meet these
ARARs. Assunes treatment
-------
1 AOI.E V III. t (cont i nlled)
ARARs FOR SAND CREEK out
ACTION-SPECIFIC ARARs AND T8Cs
------..-------------------------.-.------.-.-----------~._------------------------------------------------------------------------------------------------------
Standard, Requirement,
Criteria, or Limitation
Citation
Description
Appl icilbl e
or Relevant
and Appropriate
an"llte disposat of
treatment residues
.--.-.----...------------------------------------.----.----------------------------------.-------------------------------------------------------------------~---
Cornnent
~
~
6 CCR 1007-J Part
26~.301(a)(2)
6 CCR 1007-J Part
264.JOI(c)(d)(e)
6 CCR 1007.3 Part
264.303(a)
Instatt leachate collection syst~m
shove the liner that the depth of
leachate on the lines does not
exceed thirty centin~ters (one
foot). The system n~st be
constructed 01 m~terials that are
c~at ible wi th wastes and leachate
in the Iilndlill, and thilt have
sufficient strength to prevent
collapse under pressures exerted by
overlying ~astes, caps ilnd
eqll i pmcnt. The sys t em /IUS t be
designed and operated to fl~ction
without clo~ging.
Construct rlln.on and n~off control
systems capilble of handling the peak
dischilr!Je 01 a tOO-yeilr 21,-hollr
storm. Associated collection and
holding facilities n.,st be design<:d
to expeditiously maintilin system
capacity illter storms.
During construct ion, liners nlst be
inspected for uniformity, damage and
inperfect inns. Synthet ic menlJrilnes
nust be inspected to ensure tight
seam~ and joints and the absence of
tears, punctures or bl isters. Sui 1-
based and ild-mixed caps nlst be
inspected.
Yes/No
Yes/I/o
Yes/No
Substantive stardards for
-------
TABLE VIII-1 (continued)
ARARs fOR SAND CREEK (XI1
ACTION-SPECifiC ARARs AND 10Cs
-.-.e._____---------------.-.---------------------------.-----------------------------------------------------------------------------------------------
Standard, Requirement,
Criteria, or Limitation
Chat ion
----...-.-----------------------------------------------------------------------------------------------------------------------------------------------
On-site disposal of
treatment residues
6 eeR 1007-3 Part
261,.309
6 eCR Part 261,.90
Subpart F
~
l.J'I
6 eeR Part 261,.312,
261,.313, 317
6 eeR 1007-3 Part
261, .310(a)
'.
Description
The exact location and dimensions
including depth, 01 disposal cells
,mist be shown on sile ~ps relative
to per~nenlly sllrveyed benchmarks.
The contents 0' edch cell and
location 0' each hazardous waste
type must ill so be shown.
Conduct iI 9,'ound water monitoring
and respon:;e progrilm, including
c'orrective action, ilS required.
Cooply with special requirements 'or
igni table, react ive, incOll'pat ible
wastes, and F020, f021, f022,
1021, 1026, f021 wilstes.
Design and construct cover to:
- Provide long-term minimization 0'
migration 0' liquids through the cap
- 1 IInc t i c.n wit h m i n i /run ma i n 1 cnanc c
- PrUlloOte drilinage
-------
TABLE VIII-1 (continued)
ARARs fOR SAND CREEK CU1
ACTIO"-SPEClfIC ARARs AHD IBCs
---.------.-.--.-.-------------.------------------------------------------------------------------------------------------------------------------------
Standard, Requirement,
Criteria, or limitation
Citation
--.-----------------------------------------------------------------------------------------------------------------------------------------------------
Coomcnt
On-alte disposal of
treatment residues
6 CCR 1007-3 Part
261,.310(b)
~
0\
6 CCR 1007-2 Sec.
2.1.2
6 CCR 1007-2 Sec.
1,.2
Description
- H;ave a pc/lI1cability less than or
equal to thc permeability of the
bottom liner or natural subsoils
present.
Cap integrity mllst bc maintained and
repaired as necessary. leuk
detection, leachate collection, and
leachate reo,oval systems IfAlst be
ope:rated and maintained. Surveyed
benchmarks oust be protected and
maintained.
Disposal sites shall comply during
operations with applicahle rules and
re!Juiations of the water and air
qual ity control cOfllllissions. and
with local loning laws and ordinances.
Grot/nd wo1ter shall he protected freAn
pol lut ion Ly leachate. Permanent
divcr~ion~ shall control run-on and
runoff froUl the 100-year event.
facility design shall address
ge~logic halards. Ground water
nonitoring wells shall be designed
in accord,lI)ce wi th appl icable state
engineer'!> rules anet regulations.
Sufficient ililiounts of cover nust
exi!>t on sit~ or be readily
available off!>ite. Cap design nlll:;t
d~mvnstrate tho1t two feet of cover
is sufficient to e~tahli:.h vegetation
Appl icable
or Rclevant
and Appropr i ate
Ye:;/tlo
Yes/llo
Ye:;/llo
Conpllance with these design
standards is demonstrated by
providing the data called for in
6 CCR 1007-2 sections 1,.3 through
-------
'''OLE VIII-1 (continued)
ARARs fOR SAND CREEK 0.11
AC'IO"-SPEClfIC ARARs AND 'RCs
-.-.---------------------------.-----------------------------------------..-----.-.---------------------------------------------------------------------
Standard, Requirement,
Criteria, or limitation
Cltat i on
------------------------------------------------------------------.------.------------------------------------------------------------------------------
COirment
6 eCR 1007-2 Sec.
2.1
s:-
.....
On-site disposal 01
treatment residues
6 ceR 1007-2 Sec.
2.2
Oeser i pt ion
and isolate wastes after closure.
Adequate amounts of water IIJ.Jst be
available lor construction
Operat ions shall contorl odors ilnd
prevent rodent and insects by being
ild~quately covered. Nuisance
conditions ~hall ~c minimized.
~
-------
TAUlE VII I -1
ARAR5 FOR SAND [REEK OUI
ACTION-SPECIFIC ARAR5
(cont i nued)
AND TOCs
-----.------------------------------------------------------.-------------------------------------------------------------------------------------------
Standard, Requirement,
Criteria, or limitation
Citation
DC5cript ion
Appl icabl el
Relevant And
Appropriate
...-------------------------------------------.---------------------------------------------------------------------------------------------------------
Cooments
Chemical, Physical and
8101091cal Treatment
(Soil ~8shlng and Biological
Treatment)
General Requirements for
Ignitable, Reactive, or
Incompatible wastes
~
)
"aste Pile
'0 CfR 265.'00
'0 CfR 265.17(b)
1,0 CFR 26l..251
Chemical, physical or biological
treatment of h"lardous wa5te
/lust cOllply with Section 265.17 (b)
"here specifically required by
other scctions of this part,
the trcatment, 5toragc, or disposal
of ignitable 01" rcactive waste,
and thc mixture of coorningl ing
of incollpat ible wa5tes, or
inc~npatible wa~tcs and materials,
lIaJ5t l>C conducted 50 that it does
not:
Produce uncontrolled toxic mists,
fullCs, dusts, or gases in
sufficient quontities to
threaten hun...n health;
Produce uncontroll cd II Jllluabi e
hmcs or gases in 5uft icient
qll'lI1tities to IJOSC iI rbk of
fire or explosions.
Use a singlc I incr and leachatc
collcction systcm.
Yes/tlo
Y~s/Ilc.
Yould be applicable if biological
or soil washing treatment
treatment is performed at OU1.
"ould be applicable if biological
or soil washing treatment
treatment is performed at OU1.
Yould be ~pplicable if wa~te is
held in a waste pile prior to
-------
TABLE VIII-1
ARARs fOR SAND CREEK 0.11
ACTlOII-SPECIfIC ARARs
(cont i nue
-------
TADLE VIII-1
ARARs fOR SAIW CREEK OtJ1
ACTION-SPECIFIC ARARs
(continued)
AlW TUCs
.....--.............---------------------------------------------------------------------------------------------------------------------.----------------------.
Standard, Requirement,
Criteria, or limitation
Citation
De~cription
Appl iCuble/
Relevant And
Appropriate
Coament5
Transportation (Off-Site)
---.----.-.-------.---------.-.-----------.-.-.--------------------------------.-----------------------------------------------------------.---------------------
Yes/No
Standards Applicable to
G~nerators of Hazardous Uastes
\.II
o
40 CfR 107, 171-177
Nov. 15, 1985
federal Register
40 CFR Part 262
Regulates tran~portat ion 01
hazardous ffidtcrials (Departn~nt
01 Transportat iun)
Superfund Offs i te Pol icy
Regulat ions lor Transport ing
Hazardous Uastes:
Belore an owner or generator
disposes 01 any hazardous waste, he
/l'A.Jst obtain a <.Ietailed chemical and
physical analysis 01 a
representative sanple 01 the waste.
At a mininm, this ilnalysis /l'A.Jst
contain all the informat ion which
nlst be known to treat, store, or
dispose of the waste in accordiJOce
with Part 265 and Part 268.
Yes/No
-------
TADLE VIII-I
ARARs fOil SAUD CREEK 0111
ACTIOU-SPEClfIC ARARs
(continued)
AUD TOCs
....e______-----------------------------------------------------------------------------------------------------------------------------------------.------------
Standard, Requirement,
Criteria, or Limitation
Citation
De:.cription
Appl i co1bl e/
Rcl eVo1nt And
Appropriate
Requirements for Miscellaneous
Units
.----...-----------------------------------.---------------------------------------------------------------------------------------------------------------------
Comments
VI
t-'
52 FR ~69~6
(Dec. 10, 1987)
Subpart X of Part
26~
A RCRA permit is not required for
on-site CERClA ilction; however, the
requirements of the permit must Lc
met. The subpart)( permi t
requirements include but is not
limited to:
(a) Prevention of any releases that
may have adverse ef f ec t s on hUn.:In
health or the cnvirol"V1~nt due
to migr.ltion of w..stc constituents
in the ground w.lter or subsurface
eno/ironment, considering:
(1) The voh.ne and physical and
chemical characteristics of the waste
in the llnit, including it:> potential
for migration through soil,
I iners, or other contair.ncnt
structures;
(2) The hydrologic and geologic
characteristics of the unit
and surrounding area;
(1) The exist in'] quality of ground
water, including other sources of
contamination and their cumulative
in-pact on the ground water;
(I,) The qUillity ilnd direction of
ground- water fI ow;
(5) The prox imi Iy to and wi thclrilwal
rilte:; 01 cllrrenl ilnel potent iill
ground-water u!icrs;
Yes/tlo
Applicable if waste is treated in a
-------
TADIt: VIII-\
AIIARs fOR SAUD CIlEEK au \
ACTION-SPECifiC ARARs
(continued)
AND TOCs
................-.-.---......----------------------------------------------.-------------------------------------------------------------------------------------
Standard, Requirement,
Criteria, or limitation
Citation
Description
.....---.----.---..-.------------.----.--------------------------------------------------------------------------------------------------------------------------
(6) The pattern:; of land use in the
region;
\.II
N
(7) The potenti~1 for deposition or
migration of waste consitituents
i nt 0 sl,u:;ur f .Ice "hys i c a 1st rue t ures,
and into the rout zone of food-chain
crops and other vegetation;
(8) The potent i..1 for he...1 th rhks
caused by hunan exposure to waste
constituents; and
(9) The potential for damage to
domestic animals, wildlife, crops,
vegetation, and ~Iysical structures
caused uy exposure to waste
constituents;
(b) Prevention of any releases
that may have adverse effects
on hlman health or the
env i rOlYllent due to mi gr a t i on of was te
constituents in surface water or
wetlands or on the soil surface
considering;
(1) The voluuc and physical and
chemical characteristics of the waste
in the unit;
(2) The ef feet iveness ilf)d
of containing, confinin!,J.
collect ing systems and
reliiJhility
..nd
structures in preventing mi!,Jriltion;
Appl icablel
Relevant And
Appropriote
-------
TABLE VIII-1
ARARs FOR SAND CHEEK WI
ACfION-SP~CltIC AHARs
(continued)
AIID TBCs
----.-..----------------------.----------------------------------------------..--------..------------------------------------------------------------------------
.
Standard, Requirement,
Criteria, or limitation
Citation
Description
-----.------------..---------------------------------------------------------------------------------------------------------------------------------------------
In
W
(3) The hydrologic characteristics
of the uni t and the surroundin!j
area, including the topograr~y of the
land around the unit;
(~) The patterns of precipitation in
the region;
(5) The quantity, quality, and
direction of ground-water flow;
(6) The proximi ty of the unit
to surface waters;
adverse effects on human hcalth or
the cnvirorroent;
considcrin!j:
(7) fhe,current and potential uses
of nearby surface waters and any
other water qu..lity stano:lilrds
established for those surface waters;
(8) The existing quality fo surface
waters and surfac~ soils, including
other sources of contamination and
their cl~llative impact on surface
waters and surface soils;
(9) The patterns of land use in the
region;
(10) The potential for health
caused by hUlkin eKpopsure to
waste constituents; and
risks
Appl icahl e/
Rclevant And
Appropriate
-------
TAUI E VIII- I
ARARs fOR SAND CREEK GUI
ACTION'SPECI~IC ARARs
(continued)
AlID T DCs
......-.-------.-.--------------..-------------------.-----------------------------------------------------------------------------------------------------------
Standard, Requirement,
Criteria, or limitation
Citation
De~cription
-.---------------------------------------------------------------------------------------------------------------------------------------------------------------
(11) The potential for damage to
domestic animals, wildlife, crops,
vcgetation, and ~ysical structures
caused by exposure to waste
constitiuents.
(c) Prevcntion of any rclease that
may have ildversc elf ec t s on hUlli.ln
heal th or the elwirorvllcnt due
VI
~
to migration of waste constituents in
the air, considering;
(1) The volunc and phy:i ical and
chemical characteristics 01 the waste
in the unit, including its potential
for the emission and dispersal of
gase:i, aerosols and particulates;
(2) The effectivene~s and reliaLility
of systems and structurC:i to reduce
or prevent emissions of hazardous
constituents to the air;
(J) The operating characteri~tics of
the unit;
(~) The atmospheric, meteorologic,
and topographic choractcristics of
the unit and the surrounding area;
(5) The existillg quality 01 the air,
including other sources of
cont
-------
TAOIE VIII-1
ARAR:> fOR SAUD CREEK OU1
ACTION-SPECifiC ARARs
(cont inued)
AIID TOCs
------------------------------------------------------____e______------------------------------------------.-----------------------------------------------------
Standard, Requirement,
Criteria, or Limitation
CI tat ion
Description
-----......----------------------------.----------.-----__e______------------------------------------------------------------------------------------------------
(7) The potential for dal1\ilge
to domestic animals, wildlife, crops,
vcgctat ion, and physical structurcs
causcd by exposl/rc to waste
con!;[i[l/cnts.
.II
.II
AWl i c abl el
Relevant And
Appropriate
-------
Federal CAA National Air Qualitv Standards and State of Colorado Air Qualitv
Regulations. Treated soils would have to meet the requirements of the Land Disposal
Restrictions. The requirements for these ARARs are found in Table VIII-I.
Alternative No.7 - OfT-Site Incineration of Highly Contaminated Soil/On-Site Washing
Treatment of Remaining Contaminated Soil/OfT-Site Incineration and Disposal of Soil
\Vash Residuals/Institutional Controls
The ARARs associated with the soil washing alternative pertain to excavation, stockpiling,
demolition, air stripping, soil washing, and backfilling activities for on-site operations, and
hazardous waste transport, incineration emissions and land disposal for off-site activities.
During on-site activities, dust generation, excavation and incineration noise, and vapor
emissions would be of concern. Workers would have to follow OSHA health and saferv
regulations during all phases of remedial action. Federal CM National Air QualitY
Standards and State of Colorado Air Quality Regulations necessitate the control of vapor
and particulate emissions. The Land Disposal Restrictions would require treated soils to
reach appropriate health risk-based treatment levels. The requirements for these MARs
are found in Table VIII-I.
CRITERION 3: REDUCTION OF TOXICITI....MQill.LITY. OR VOLUME
Prerequisite Remedial Activities - Demolition/Disposal of Buildings and Tanks/Soil
Vacuum Extraction
Demolition and disposal of contaminated buildings and tanks will reduce the volume and
toxicitY of contaminated structures on-site. All fluids used in the decontamination
procedure will require further treatment or disposal. Vacuum extraction will reduce the
toxicity, mobility and volume of contaminants present in the soils at the COC area.
Alternative No.1 - No Action
No reduction in toxiciry, mobility, or volume would be achieved under the 00 Action
alternative. Contaminants would continue to move from the site, affecting surface water,
ground water, and soils.
Alternative No.2 - Capping/Institutional Controls
The capping alternative would not reduce 'toxicity or volume because the waste would not
be treated. Mobility would be reduced to the extent that the cap prevents surface water
and soil movement from the site and to the extent that the cap prevents infiltration of
water and potential movement of contaminants to ground water. A significant reduction
in mobility compared to No Action is expected for the capping alternative.
Alternative No.3 - On-Site Landfill Disposal/Institutional Controls
Because contaminants would remain on-site untreated, no reduction in toxicity or volume
would be achieved. A greater reduction in mobility would be achieved relative to capping
because the contaminants would be encapsulated instead of merely capped. A long-term
reduction in mobility would be achieved only through continuous monitoring and
maintenance of the landfill.
-------
Alternative No.4- OfT-Sit~ Incineration/OfT-Site Disposal of Residuals and Soils
Alternative No.4 would achieve a significant reduction in toxicity, mobility, and volume
through incineration (destruction) of highly contaminated soils. A large volume of less-
contaminated soil would not be treated, but the soil would be transferred to a facility
designed to contain hazardous wastes. The potential for movement of contaminants into
groundwater beneath QUI from the soils would be eliminated.
Alternative No.5- On-Site Incineration/On-site Fixation of Treated Residuals/On-Site
Landfill Disposal/Institutional Controls
Alternative No.5 would result in a significant reduction in the toxicity, mobility, and volume
of organic contaminants through destruction of the organics in the incinerator. The volume
of residual soil from the incinerator would increase slightly due to the fixative agent used
to solidify the soil. Mobility of residuals would be further decreased by containment of the
fixed mass within a landfill.
Alternative No.6- OfT-Site Incineration of Highly Contaminated Soil/On-Site Biological
Treatment of Remaining Contaminated Soil/Institutional Controls
This alternarive would result in a significant reduction in the toxicity, mobility, and volume
through destruction (incineration) and containment of highly contaminated soils. Biological
treatment of less contaminated soils would also significantly reduce the toxicity and volume
of contaminants on-site. However, implementation of biological treatment would result in
a slight increase in soil volume due to the addition of growth substrate and soil
amendments. Mobility of remaining contaminants would not be affected. but the reduction
in concentrations to acceptable levels eliminates the risk associated with mobile organic
compounds.
Alternative No.7- OfT-Site Incineration of Highly Contaminated Soil/On-site Washing
Treatment of Remaining Contaminated Soil/OfT-Site Incineration and Disposal of Soil
Wash Residuals/Institutional Controls
The soil washing alte:-native would result in a significant reduction in the tOxicity, mobility,
and volume through incineration and containment of highly contaminated soils. Soil
washing treatment of less contaminated soils would also significantly reduce the toxicity and
volume of contaminants on-site and virtually eliminate the potential for movement to
ground water.
CRITERION 4:
AND PERMAL'IEN E
Prerequisite Remedial Activities - Demolition/Disposal of Buildings and Tanks/Soil
Vacuum Extraction
Eliminating all structures provides a permanent solution for buildings and tanks
contaminated with hazardous substances. Vacuum extraction of volatile organic compounds
to action levels will provide long-term effectiveness for protection of human health and the
environrnen t.
Alternative No.1- No Action
Because contaminants would continue to move from the site, posing a potential health
threat, the No Action alternative would not provide a long-term or permanent solution.
Continued monitoring of the site would provide data on how natural attenuation and
-------
chemical degradation could reduce the threat to human health and the environment and
the time period to reduce the threat.
Alterative No.2- Capping/Institutional Controls
Capping is not considered a permanent solution because wastes would remain untreated on
site. Long-term effectiveness for protection of human health and the environment would
be related to maintenance and monitoring the effectiveness of the cap. Long-term
maintenance of the cap could provide control of contaminant movement and prevent risk
of direct contact with contaminantS an~ exposure to airborne emissions. With proper
maintenance, the cap would be effective in preventing leaching of contaminantS into the
ground water.
Alternative No.3 - On-Site Landfill Disposal/Institutional Control
A RCRA Subtitle C landfill could provide long-term effectiveness by significantly reducing
or eliminating the potential for human contact, airborne emissions, and infiltration intO
ground water. EffeCtiveness would be directly related to a stringent operations and
maintenance and monitoring program. The landfill alternative would not be a permanent
solution because contaminams would be left untreated on-site.
Alternative No.4- OfT-Site Incineration/OfT-Site Disposal of Residuals and Soils
Alternative No.4 would achieve significant long-term effectiveness through contaminant
destruction and removal, and would result in a permanent solution for a portion of the site.
However, because some confaminams and incinerator residuals would be transferred to an
off-site facility, alternative No.4 cannot be considered a completely permanent
environmental solution.
Alternative No.5- On-Site Incineration/On-Site Fixation of Treated Residuals/On-Site
Landfill Disposal/Institutional Controls
This alterative would result in an almost complete destruction of organic contaminants
through incineration. with immobilization of inorganics by fixation, and subsequerlt
placement of all residuals in an on-site landfill. Although the alternative would provide
long-term public health protection. it cannot be considered a permanent remedy because
some contamination would remain on site and there would be a need for long-term
maintenance of the landfill. -
Alternative No.6- OfT-Site Incineration of Highly Contaminated Soil/On-Site Biological
Treatment of Remaining Contaminated Soil/Institutional Controls
This alternative provides the potential for complete remediation of all contaminated soil
above action levels. Assuming the biological treatment process degrades all the
contaminantS to acceptable levels, this alternative would provide a permanent solution for
the site. The off-site incineration and disposal of highly contaminated soils in a RCRA
Subtitle C landfill would effeCtively immobilize incinerated soil residuals, and long-term risk
would be negligible.
-------
Alternative No.7- OfT-Site Incineration of Highly Contaminated Soil/On-Site Washing
Treatment of Remaining Contaminated Soil/OfT-Site Incineration and Disposal of Soil
Wash Residuals/Institutional Controls
This alternative would achieve significant long-term effectiveness and permanence through
incineration and containment of highly contaminated soils. The soil washing process would
extract chemicals of concern from less contaminated soils and achieve acceptable health
risk-based levels on-site. This would provide a permanent solution for the site. Off-site
land filling of all incinerated residuals would effectively immobilize any remaining
contaminants, and long-term risks would, be negligible.
CRITERION 5:
Prerequisite Remedial Activities - Demolition/Disposal of Buildings and Tanks/Soil
Vacuum Extraction
Destruction and demolition of structures will increase exposure risk in the short-term due
to dust and vapor generation. Monitoring would be required to ensure protection of
workers and the surrounding population. Soil vacuum extraction would slightly increase
exposure risks to on-site workers in the short-term due to related construction activities.
Alternative No.1- No Action.
The No Action alternative would not provide any short-term effectiveness.
Alternative No.2- Capping/Institutional Controls
Short-term effectiveness is related to the degree that production of airborne particulates and
vapor is controlled during remediation, to minimize exposure risk to workers and the
surrounding populace. The degree of short-term risks would be less than that of Other
alternatives due to a relatively quick construction period. . Air monitoring during
implementation would be required to evaluate risk and institUte any corrective action.
Alternative No.3 - On-Site Landfill Disposal/Institutional Controls
The landfill alternative would take approximately 2.5 years to implement and would pose
an elevated risk to workers and surrounding populace due to the need to excavate and
handle contaminated soils. MonitOring during construction would be required to ensure
that protection of worker and public health is achieved.
Alternative No.4- OfT-Site Incineration/OfT-Site Disposal of Residuals and Soils
The short-term risks presented by alternative No.4 would be fewer than those of the on-
site landfill alternative because excavated soils would not be stockpiled and would be
immediately removed from the site. Implementation time would be reduced because there
would not be a need to construct a landfill or backfill soils into it. The off-site incinerator
and landfill would have the necessary facilities and pollution control equipment to contain
soils and prevent emissions during treatment/disposal.
-------
Alternative No.5 - On-Site Incineration/On-Site Fixation of Treated Residuals/On-site
Landfill Disposal/Institutional Controls . .
This alternative poses a high health risk due to a significant amount of soil handling, on-
site incineration emissions, and the long time frame (five to $ix years) for the alternative
to be completed. Stringent dust and emissions controls would be required in order for the
alternative to maintain public health protection. Site-wide monitoring of emissions would
be necessary for this alternative.
Alternative No.6- OfT-Site Incineration ,of Highly Contaminated Soil/On-Site Biological
Treatment of Remaining Contaminated Soil/Institutional Controls
It is anticipated that remediation of the site would take 5 to 7 years to complete with the
biological treatment alternative. During early stages of remedial activities, soil handling and
treatment operations may produce fugitive dust which might slightly elevate health risks.
Stringent dust and emissions controls would be required in order to ensure public health
protection. A site-wide air monitoring program would be instituted during remedial
activities with this alternative.
Alternative No.7- OfT-Site Incineration of Highly Con~aminated Soil/On-Site \Vashing
Treatment of Remaining Contaminated Soil/OtT-Site Incineratio'n and Disposal of Soil
\Vash Residuals/Institutional Controls
Remediation of soils at the COC area employing soil washing would take approximately 5
to 6 years to complete. Workers and the nearby communiry could potentially be exposed
to slightly elevated risks during soil handling and treatment activities. These risks. however,
can be reduced to acceptable levels by instituting protective and preventative measures. A
site-wide air monitoring program would be in operation during remedial activities with this
alternative.
CRITERION 6: IMPLEMENT ABILITY
Prerequisite Remedial Activities - Demolition/Disposal of Buildings and Tanks/Soil
Vacuum Extraction
These activities are readily implementable using standard demolition and construction
techniques. The time required for implementation of vacuum extraction is highly variable
and dependent upon subsurface conditions. soil permeabiliry, contaminant characteristics.
air temperature and vacuum/blower pressure. Implementation is estimated to take 6
months to 1 year.
Alternative No.1 - No Action
The No Action alternative is readily implementable.
Alternative No.2 - Capping/Institutional Controls
The cap alternative is highly implementable using standard construction techniques. The
alternative poses logistical problems associated with tbe presence of a building, railroad,
underground pipeline, and other utilities adjacent to the site. Detailed planning would be
required to address reconstruction or rerouting of these rights-of-way.
-------
Alternative No.3- On-Site Landfill Disposal/Institutional Controls
The landfill alternative is implementable using standard construction techniques and
equipment. The alternative poses similar logistical problems as described for the cap
alternative, but through proper planning the problems can be solved. .
Alternative No.4- OfT-Site Incineration/OfT-Site Disposal of Residuals and Soils
The construction aspectS of Alternative No.4 are highly implementable using standard
construction techniques and equipment. Implementability of off-site incineration and
landfill disposal would be dependent on the capacity of these facilities at the time of
remedial action. These problems could result in a delay in remedial action, but do not
preclude off-site incineration or disposal.
Alternative No.5- On-Site Incineration/On-Site Fixation of Treated Residuals/On-Site
Landfill Disposal/Institutional Controls
Although Alternative No.5 is implementable using existing equipment and technologies, this
alternative faces the greatest challenges to be implemented successfully. The alternative
combines incineration, fIxation, and containment technologies. Due to limited staging and
operation space at the site. detailed planning would be necessary. Incineration emissions
modeling and planning would also be necessary. Implerrientability of this alternative
depends upon delisting the treated waste. Availability of specialty equipment is anOther
critical component which affectS the time required for implementation. This alternative
includes specialty equipment to prepare the soil for incineration, portable incinerators. and
fIxation equipment.
Alternative No.6- OfT-Site Incineration oC Highly Contaminated Soil/On-Site Biological
Treatment of Remaining Contaminated Soil/Institutional Controls
The construction and excavation aspects of the biological treatment alternative are highly
implementable using standard techniques and equipment. The limited staging and
operations space on-site, however. would necessitate a phased construction and treatment
approach. Implementability 0f off-site incineration and landfIll disposal would be
dependent on the capacity of these facilities at the time of remedial action. These factors
could result in a delay in remediation. but do not preclude off-site incineration or disposal.
The biological treatment process, however, is an innovative technology and has nOt been
demonstrated under full-scale conditions with the complex mixtUre of contaminants present
at OU1. The implementability and applicability of this technology for the remediation of
the COC will be determined during the treatability tests.
Alternative No.7- OfT-Site Incineration oC Highly Contaminated Soil/On-site Washing
Treatment or Remaining Contaminated Soil/Off-Site Incineration and Disposal of Soil
Wash Residuals/Institutional Controls
This alternative combines incineration, containment, and soil washing technologies. The
limited staging and operations space at OUI would necessitate a phased construction and
treatment approach. Off-site incineration and land disposal are implementable with
standard techniques and equipment, but are dependent on the capacity of these facilities
at the time of remedial action. Although soil washing has been successfully demonstrated
with certain types of compounds, itS effectiveness in treating the area's complex mixtUre of
-------
contamin~nts is uncertain. As with the biological treatment alternative, treatability tests
would be required to determine if all the contaminants can be removed and to aid in
designing the treatment system. .
CRITERION 7: COST
Prerequisite Remedial Activities - Demolition/Disposal of Buildings and Tanks/Soil .
Vacuum Extraction
The estimated costS for demolition and disposal of structures is approximately $325/CY for
buildings and foundations and $1,6oo/tank. Soil vacuum extraction is estimated to cost
$1,600,000. The costs have been included in each of the following alternatives.
Alternative No.1 - No Action
The cost of the No Action alternative includes site operations and maintenance, periodic
sampling, inspection. and performance of a PHE at 5-year intervals. Annual cost is
estimated at $53.000 and present worth cost over 30 years is estimated at 5604,000.
Alternatiye No.2- Capping/Institutional Controls
The estimated present worth cost for construction of a cap at OUI is approximately
56.529,000. This cost includes construction, O&M. and periodic monitOring.
Alternative No.3 - On-Site Landfill Disposal/Institutional Controls
The estimated cost for construction of a Subtitle C landfill at OUI is approximately
$10,807,000. This cost includes construction, O&M, and periodic monitoring.
Alternative No.4 - OfT-site Incineration/OfT-site Disposal of Residuals and Soils
The estimated present worth cost for Alternative No.4 is S 18.594,000, the fourth highest
cost for the action alternatives. The cost assumes disposal at an in-state landfill, and the
cost may be higher if transport out of state is required.
Alternative No.5 - On-Site Incineration/On-Site Fixation of Treated Residuals/On-Site
Landfill Disposal/Institutional Controls
Alternative No.5 is the most costly of the seven alternatives. The estimated present worth
cost for Alternative No.5 is 533,878,000.
Alternative No.6 - OfT-Site Incineration or Highly Contaminated Soil/On-Site Biological
Treatment of Remaining Contaminated Soil/Institutional Controls
The exact cost of this alternative is uncertain until treatability tests are performed. The
estimated present worth cost for the biological treatment alternative is $20,736,000. This
includes capital costs of $20,539,000 and annual O&M costs (excluding the required 5-year
PHE) of $40,000 per year. Major contingencies have been factored into the capital costs
to allow for complications in instituting a bioremediation technology.
Alternative No.7 - OfT-Site Incineration of Highly Contaminated Soil/On-Site Washing
Treatment of Remaining Contaminated Soil/Off-Site Incineration and Disposal of Soil
Wash Residuals/Institutional Controls
CostS associated with the soil washing alternative are uncertain since treatability testS have
not yet been performed on soils from the coe area. The estimated present worth cost for
-------
this alternative is $29,441.000. This includes capital costS for $29,254,000 and ann~al O&M
.costS (excluding the required 5-year PHE) of $40,000 per year. Major contingencies have
been factored into the capital costS to allow for complications in institUting a soil washing
technolpgy.
CRITERION 8:
The State has concurred with the remedy described in Section IX.
Prerequisite Remedial Activities - Demolition/Disposal of Buildings and Tanks/Soil
Vacuum Extraction
The S~ate has concurred with these remedial activities.
Alternative No.1. No Action
The State would prefer an alternative that reduces the risk present at the COC area.
Alternative No.2. Capping/Institutional Controls
Due to the need for long-term maintenance and several restrictions for land use. state
acceptance of the capping alternative was expected to be greater than No Action. but less
than for alternatives that destroy or remove waste.
Alternative No.3. On-Site Landfill Disposal/Institutional Controls
State acceptance of the landfill alternative was expected to be greater than for No Action.
but less than for alternatives that destroy or remove waste, due to the need for long-term
maintenance and several restrictions for land use.
Alternative No.4 - OfT-Site Incineration/OfT-Site Disposal of Residuals and Soils
It was expected that Alternative No.4 would be highly acceptable to the State.
ContaminantS would be destroyed and removed from the coe area.
Alternative No.5 - On-Site Incineration/On-site Fixation of Treated Residuals/On-Site
Landfill Disposal/Institutional Controls
State acceptance was expected to be less for this alternative due to concerns over
incinerator emissions. length of remediation time. and the presence of a landfill which
would restrict futUre use of the area.
Alternative No.6. OfT-Site Incineration of Highly Contaminated Soil/On-Site Biological
Treatment oC Remaining Contaminated Soil/Institutional Controls
It was expected that the biological treatment alternative would be highly acceptable to the
State. Contaminants would be eliminated from the site, and the area could be returned to
industrial use. The length of remediation time (5 to 7 years) may be a concern.
.'
-------
Alternative No.7 - Off-Site Incineration of Highly Contaminated Soil/On-Site Washing
Treatment of Remaining Contaminated Soil/Off-Site Incineration and Disposal of Soil
\Vash Residuals/Institutional Controls
It was expected that the soil washing alternative would be acceptable to the State.
Contaminants would be eliminated from the site, and the area could be returned to
industrial use. The relatively long remediation time (5 to 6 years) and high cost, however,
may be a concern.
CRITERION 9: COMMUNITY ACCEPTANCE
The City of Commerce City has criticized EP A's use of industrial exposure and action
levels, and has suggested EP A use only residential numbers. As set forth in the attached
Responsiveness Summary, EP A believes use of such industrial exposures and action levels
are consistent with CERClA, the NCP, and EP A guidance.
Prerequisite Remedial Activities - Demolition/Disposal of Buildings and Tanks/Soil
Vacuum Extraction
These prerequisite activities are acceptable to the communiry since VOCs will be reduced
to action levels and contaminated structures will be eliminated.
Alternative No.1 - No Action
It is assumed that the community would prefer an alternative that reduces the risk present
at the cac area.
Alternative No.2 - Capping/Institutional Controls
Community acceptance of capping is expected to be greater than for no action.
Alternative No. 3- On-Site Landfill Disposal/Institutional Controls
Communiry acceptance of the landfill alternative is expected to be greater than for No
Action, but less than for alternatives that destroy or remove waste, due to the need for
long-term maintenance and several restrictions on land use.
Alternative No.4 - OfT-Site Incineration/OfT-Site Disposal of Residuals and Soils
Alternative No.4 would be highly acceptable to the local community. Contaminants would
be destroyed and removed, and the health threat would be reduced such that certain uses
of the land would be permissible.
Alternative No.5 - On-Site Incineration/On-Site Fixation of Treated Residuals/On-site
Landfill Disposal/Institutional Controls
Community acceptance is expected to be reduced for this alternative due to concerns over
emissions from the incinerator. Costs of remediation and length of remediation time is also
expected to be of concern.
-------
Alternative No.6 - OIT-Site Incineration of Highly Contaminated Soil/On-Site Biological
Treatment of Remaining Contaminated Soil/Institutional Controls
It is anticipated that this alternative will be highly acceptable since contaminants would be
destroyed and removed. and the health threat would be reduced to the point where
industrial use of the land would be permissible. The relatively long remediation time may
be of concern.
Alternative No.7. OfT-Site Incineration of Highly Contaminated Soil/On-Site Washing
Treatment of Remaining Contaminated. Soil/OfT-Site Incineration and Disposal of Soil
Wash Residuals/Institutional Controls
It is anticipated that this alternative would be acceptable since contaminants would be
destroyed and removed, and the health threat would be reduced to permit industrial use
of the land. Both the cost and the length of remediation time may be a concern.
Minimal commentS were submitted on the second proposed plan. This plan included soil
vacuum extraction. excavation and incineration of 1,000 CY of highly HOC-contaminated
soil, and on-site biological and/or soil washing treatment of the lesser HOC-contaminated
soil.
IX.
The Selected Remedy
Based on consideration of the requirements of CERClA. the detailed evaluation of the
alternatives. a statUtory preference for treatment, and public commentS, EP A has decided
to implement the prerequisite remedial activities (including demolition and treatment of
contaminated buildings and tanks in accordance with the LDRs; and SVE for VOCs) and
the off-site incineration of soils contaminated with greater than or equal to 1.000 ppm
HOCs. The selected remedy is a portion of the preferred alternatives 6 and 7, as
referenced above and in the proposed plan. Ground water on-site would be monitOred for
thirty years and a Public Health Evaluation (PHE) would be performed every five years
following remediation. The net present worth for the selected remedy is 55,349,600 and
implementation will take approximately 18 months.
Scope and performance of the selected remedy are consistent with the proposed remedy
because the elementS of remedial actions to be implemented are the same. The difference
is that there will be an additional Record of Decision and public comment period on the
remedy for those lower level HOC-contaminated soils which are now considered OU5.
Correspondingly, the cost of the remedy selected herein is less than what was anticipated
in the FS and FS addendum; however, the cost of remediating the overall COC area, i.e.
OUI and OU5, will be approximately the same as that presented in the proposed plan.
Remediation Goals
Target clean-up objectives have been developed based on (1) ARARs, (2) concentrations
which correspond to carcinogenic health risks from lx10-7 to 1xlO-'. Except as noted below,
acceptable contaminant levels for the chemicals of concern are, in general, the 10-8 risk-
based action levels derived through the EA
-------
ARARs specify the cleanup objectives for the pesticide 2,4-D, a HOC found at the site.
As stated earlier, the LDRs dictate the treatment for concentrations of HOCs ~ 1,000 ppm.
Treatment standards have been established based on the best demonstrated available
technology (BDAT). Health-based action levels for soils contaminated with lower levels
of HOCs will be addressed in the ROD for OU5. For the pesticide 2,4-D, incineration
represents the BDA T required by the LDRs.
Pesticide contaminated soils will be excavated and hauled to an incineration facility where
high-temperature treatment will achieve 99.'99% DRE of the contaminants. Since residuals
will be above health risk-based levels, the incinerated soil and ash produced during
incineration will be disposed in a subtitle C landfill, and as, dictated by the Land Disposal
Regulations.
Any metal contamination, in the 1,000 CY of soil contaminated with HOCs ~ 1,000 ppm
to be excavated, will be addressed by disposal of incinerated soil and ash in a Subtitle C
landfill.
Soil action levels for the cleanup of volatile organics were based on the 10-6 risk due to
ground-water ingestion. The ground-water pathway is considered the most significant route
for volatiles, because of the low Kd (the partitioning coefficient) values. Treatment of the
subsurface VOC contaminated soils with soil vacuum extraction results in residual
contaminant concentrations equal to the action levels listed in Table VI-!. Carbon filters
provide treatment for the emissions created by the system.
x.
Statutory Determinations
EP A's responsibility at Superfund sites is to select and implement remedial actions that
are protective of human health and the environment. In addition, Section 121 of CERCLA
provides several other statutory requirements and preferences. These statutes specify that
the selected remedial action for the site must comply with applicable or relevant and
appropriate environmental standards established under Federal and State environmental
laws unless a waiver is granted. The select.ed remedy must also be cost effective and utilize
permanent treatment technologies or resource recovery technologies to the maximum extent
practicable. The statute also contains a 'preference for remedies that permanently or
significantly reduce the volume, toxicity, or mobility of hazardous substances. The following
sections discuss how the selected remedy for the redefined Sand Creek OU1 meet these
statutory requirements.
-------
1.
Protection of Human Health and the Environment
The selected remedy protectS human health and the environment through removal and
incineration of the highly HOC-contaminated soils, and vacuum extraction of volatile
organic compounds. This remedy will reduce the direct contact threat currently posed by
soils and will minimize future adverse effects on ground-water quality by treatment of the
most concentrated sources of waste above the water table. There are some short-term risks
"associated with the selected remedy during soil handling operations, but these can be
minimized with protective and preventatiye measures.
2.
Attainment of ARARs
Remedial actions at Sand Creek (OUl) will be undertaken in accordance with all applicable
or relevant and appropriate requirements (ARARs).
Any regulation, standard, requirement, criterion, or limitation under any federal or state
environrnentallaw may be either applicable or relevant and appropriate to a remedial
ac:ion, but not both.
Criteria. advisories and guidelines that are not law may be used to ensure prOtectiveness
in the absence of ARARs, or when ARARs are not sufficient. These criteria, advisories,
and guidelines fall in the "to be considered" (TEC) category and can be used to ensure
protection.
ARARs may be classified into three general categories:
o
Chemical-specific - related to the level of contamination allowed for a specific
pollutant in various environmental media (Le., soil, water, and air),
o
Location-specific - related to the presence of a special geographic::!.l (e.g.,
floodplain or wetland) or archeological are::!. at or ne::!.r the site, and
o
Action-specific - related to a method of remedial action identified as an
alternative for the site (e.g., disposal requirements or incineration standards).
The selected remedy of off-site incineration of soils contaminated with HOC concentrations
greater than or equal to 1,000 ppm, demolition and disposal of contaminated structUres and
tanks in a Subtitle C facility, and vacuum extraction of soils would comply with all
applicable or relevant and appropriate chemical-, location-, and action-specific requirements
(ARARs). The ARARs are presented below.
o
Chemical-specific ARARs
None
o
Location-specific ARARs
None
-------
o
Action-specific ARARs
Federal
- The Superfund Off-Si.te Policy found in the November 15, 1985 Federal Register
will be complied with concerning off-site incineration and disposal of the structures
and tanks.
- A PHE must be performed at least every 5 years (proposed NCP, 53 FR 51430)
Resource Conservation and Recovery Act (RCRA)
- RCRA requirements in 40 CFR Part 268.32(e)(2) prohibit land disposal of
nonliquid hazardous wastes containing HOCs in tOtal concentration greater than or
equal to 1,000 ppm. Off-site incineration of soils containing HOC concentrations
greater than or equal to 1,000 ppm will meet the land disposal requirement, sinc~
incineration represems BDA T required by the LDRs.
- 40 CFR 268 Subpart C (Prohibitions on L.1nd Disposal), Subpart D (Treatment
Standards) Waste specific prohibitions and treatment standards will be followed in
the land disposal of spent carbon filters used for vacuum extraction, the disposal of
debris resulting from demolition of buildings and removal of tanks, and disposal of
the ash and incinerated soil.
Occupational Safety and Health Act (OSHA)
- The requirements of 29 USC Sections 651-678, which regulates worker health and
safety, must be followed.
State of Colorado
- CRS Section 25-123-101, et. seq. must be adhered to maintain compliance with the
State of Colorado noise abatement requirements.
- 6 CCR 1007-3 Part 99 will need to be followed. This regulation requires
notification of hazardous waste activities when hazardous waste is generated.
- The manifest requirements of 6 CCR 1007-3 Part 262 Subpart B must be followed
for off-site transportation of hazardous waste.
- The pre-transport regulations of 6 CCR 1007-3 Part 262.30, .31 and .33 must be
adhered to for off-site transportation of hazardous waste.
-------
- An EPA'identification number must be obtained for transporting of hazardous
waste .per the requirements of 6 CCR 1007-3 Part 263.11 (A).
- CCR 1001-3 Section VIE will be followed to regulate air emissions.
...
oJ.
Cost Effectiveness
The selected remedy is cost effective in mitigating the risk posed by contaminated soils in
a reasonable period of time. The selected remedy effectively and permanently reduces
contamination to acceptable levels. .
Because the scope of the original Operable Unit has been reduced, the cost of this remedy
is less than the estimate in the second proposed plan. Employing one of the other
alternatives for this modified Operable Unit would greatly increase the cost without a
corresponding increase in the protection of human health and the environment.
4.
Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Maximum Extent Practicable
EP A analyzed the alternatives to determine which would utilize innovative treatment
technologies to the maximum extent practicable. J"he selected remedy will achieve the
response objectives of reducing direct contact exposure to high level HOC contaminated
soils and minimizing adverse impacts on ground water from hoth VOC and high level HOC
soil contamination.
This remedy involves destruction and treatment of contaminantS and an overall reduction
in contaminant toxicity and volume. Soils highly contaminated with HOCs will be excavated
and incinerated off site. Incineration will achieve a DRE of 99.99%. Soils contaminated
with VOCs will be subjected to SVE and will no long~r be a source of groundwarer
contamination. Therefore. a permanent remedy is achieved for those soils included in this
decision. Alternative treatment technologies and resource recovery technologies will also
be evaluated in OU5, which addresses the remainder of the COC area soils.
5.
Preference for Treatment as a Principal Element
By incinerating HOC contaminated soils and vacuum extraction of VOC-contamin:lted soils.
the selected remedy addresses the principal risks at the site through the use of remedies
that employ treatment as a principal element.
XI.
Documentation of Significant Changes
The Proposed Plan for the Sand Creek Industrial Site, original Operable Unit No.1
(Colorado Organic Chemical Soils), was released to the public in January 1989. The
Proposed Plan identified excavation and off-site incineration of soils contaminated by ~
1,000 ppm HOes, excavation and off-site disposal of soils contaminated by ~ 1,000 ppm
HOes and backfilling of excavated areas with clean soil as the agency's preferred
-------
alternative. EPA reviewed all the comments submitted verbally and in writing during the
public comment period. Based on review of those comments and subsequent re-
examination of the site, EP A released a revised Proposed Plan in July 1989 which identified
the use of bioremediation and soil washing technologies, as part of the agency's preferred
alternative. As the result of a need to perform treatability studies as a basis for reaching
the remedial action decision for the entire COC area, EP A has decided to create an
additional operable unit (OUS) in which to address the 38,000 cubic yards of soils
contaminated with < 1,000 ppm HOCs.
EP A has reviewed the comments and questions received during the latest public comment
period and responded in the attached responsiveness summary (Attachment A).
-------
TZ4-COSSO-CR -0082'+
SAND CREEK INDUSTRIAL SUPERFUND SITE
OPERABLE UNIT NO.1
COMMERCE CITY, COLORADO
RESPONSIVENESS SUM~JAR Y
Septenlher 11, 1989
This community relations responsiveness summary for Operable Unit No.1 (OU1) of the
Sand Creek Industrial site contain~ t\t,,'O sections: (A) a hrief description of the site and
EPA's selected remedial alternative for OU1, and (B) a summary of oral and \vritte!1
commems received concerning th~ Remedial T1iv~stig:ltIcnjFe:1sibility Study (RIjFS) ~nd
the ..:ele"~,." relneo'v a""d E?,'~'s r'3<;;''''on<:i3<: -" ":'.:>.-." "U-'~'l-'e..t"
.L w ~ ,-"cu ".' 11 " ... ... !,;;-!J
-------
of less~r Halogenated Organic Compound (HOC) contaminated soBs on the cac prop~rty
\\lhich are now within the recently designated OU5. .
EPA issued a proposed plan in January 1989. The previously proposed altern~tive for
cleaning up contaminated soil at the original aUI (Alternative No.4) combined vapor
extraction, excavation, incineration, and Institutional controls. A soil vJpor extraction
system was proposed to remove deep volatile contamination. All shallow soils conraining
comaminant levels that presented a health risk due to contact with the 50i15 '.'lere to be
excavated for disposal at an off-sire landfill. In ~ddition, approximately 1,000 cubic yards
or soiis \'iith the hights1: contamir.:.mt levels were to be incinerated off-site prior to dispos::li.
Exc:lvat;;d are:1S were to De filled with clean soil and reveget:ned, and the rest of th,~ sit~
W2.S to be gr;;.u;;d and re'leget~ted to reduce erosion :~nd windblo'.'in dust. GiOU:ld '.\":~t\?r
\'.'a5 ,0 be monitored all a quarterly basis for the first thr~e years after co:nplerion or t!l~
cle:ll1up actioii. R~~;dc!1ti2.1 use of OUI br.d ,-';mIld have been prohibited, and no ne'.'/
:['-:(7"tiO'1 c;";-e.J'''' ('- ,,,.,-"',.. or <::P"',~- 1.;~..". \'''ou!'! I...IJ'-' ~er-"'l'tt,~.1
.I. L1:::~"" 1 ...:--'. .1..) Jl ""..1..'-1 ..........\'_i .L...",.). lU ...., r' .U.l "-,,u.
EPA r~','ic\\'eJ <111 cc:mments concer:;!i1g the proposed alternativ~ and rc-e'::':'!li~Hed th-=
remedial technologies ~nJ combinations of technotogi~s, DetaiLs of th~ re-~';aluation or
remec~i~i technologies :l!1d cor:1biil:J.tions of technologies can be found in th~ Addendum to
the F5. The re-,~vaiu:ltion of technologies resulted in the incorporation of t\VO additl()!::!1
:J.ltem~Hi\'cs to the five previously prop05ed. TI;e nm additional alternati-,es include: (1)
biotr~~tment arid (2) soil washing for less HOC contamin:J.ted soils. These alternatives are
outlined in detail in the FS Addendum and \"ere summarized in a proposed pbn issued by
EP A in July 1989. Figures 2-1 and 2-2 of the FS Addendum provide a schematic of each
alternative. EP A has dedded to perform tre:ltability tests on these t\vo alternatives. If th~
results of the treatability tests indicate that the implementation of either technology would
provide successful remediationt then the technologies wiII be developed to field scale. If
. the results of treatability tests do not indicate that implementation would be successfult the
previously proposed altern~tive (Alternative 4) will be implemented. SubsequentlYt EPA
decided it was appropriate to perform the treatability studies before a remedial decision on
is made on the less HOC contarrJnated soils. AccordinglYt EPA designated a new au,
OUSt to deal with the lesser HOC contaminated soils.
-------
B. SU~...fMARY OF COMMENTS RECEIVED DURING PUBLIC COM!vIENT PERIOD
EPA solicited written and orul comments from the community during the public commem
period from July 19, 1989 through AUg11st ~2, 1989. Comments wer~ received from the City
of Commerce City and from participants of the August 1, 1989 community meeting. A
summary of these comments and EP A's responses are provided helmv.
Commenrs from the CitY of Commerce Citv
O")mi::enl: The City of Commerce City st~~ted that ~he selected rc;:"!:~di:ll ait.:rarive could
b~ :.lcceptD.bie if cleanup :-=...~ls are eSl~i)lished to meei: re:~iJemial sL.:lI1uarus. 'r:~~ Ciry f~eis
that the industrial-use model used to s~t action levels restricts future land u::.:: at ti1e sit=
~T1,l ;s foOt" perm"n >nt C'CTutl'O~ Th"r':t:l"'\r'" .:..,~ Cl't'v 1..e'j:,;1.fl=),:' .J.,,,- ..~.:Ir. !.,,~.;:\~- 1..tO .::::LI:"'"',3..~',,~:1
~. U I ., '"" - ... c. ".i'. u. .1,1.,; C~,.; '-, L1.~ J () I~~~.; l....l ..1.... ...'_..l'J ..... ;-1:0..1.....
Am.endrr:enr Reauthorization Act (S..\P...A.) is not being achic\'ed since :J. pem-:o.::;;nt solutio::
is not LJeii16 implemenred.
The City also believes th:lt technologies exist to rerneuiare the sire so that :nstitmion;::i
controls would be unnecessaL}'. Th~ Ciry fee]s th:u the use of institutiond cOi:tro!s at tl:e
site cou!d resuit in physko.l and economic dec~y since people may consider the :Irea unsaf~
!"'r "-'./ ITS"
U u.J.I.: - "-'.
EPA ResDanse: Action levels at the site \"'ere set to industrial-use stand~rds bec:luse: (1)
the operable unit is located in an area currently under indllstrialusc, (2) thc area is zoneJ
as industrial by the City of Commerce City, and (3) the City's long range land-use plans
. call for continued industrial use of the area. However, the need for and scolJe of an\'
. .
institutional controls for final remediation of the coe property area \\:ill be evaluated and
decided later under OUS.
Technologies do exist to clean up the site so that institutional controls would not be
required, Numerous technologies were evaluated in the FS and were rejected due to cost,
implementability, or effectiveness considerations. EP A feels that the selected remedy
represents the best treatment technologies for remediating the site and protecting human
health and the environment at a reasonable cost.
-------
.
.
Comment: The City of Commerc City stated that if the selected remedy could not be
modified to include residenrial-use standards, the City would accept the remedy if certain
conditions are met. The Ciry stipubted that all current PRPs and future owners/operators
should be given immunit'j from future dea~up liabilities once this particular remedial action
is completed. They felt that businesses may avoid purchasing and developing property in
the area if there were the potentbl or becoming a PRP.
Concerns about the li:.ioili::es of CUrie:!t and fmure
c.,;.~nef:i \V2:5 aIs(,)
expressed by a
participant of the August 1 cGrmm'::jity meeting.
E'DA R~"~r:(' C' . En\ ...., !"\tJn;~.""c: ..h......" r:""'~'''''; I '.~d.~;i;..... "'''p "'''!f.~1'''"..,'''\:! .,4:!:~,..t r ~."\-t."P"''':''O<::
" J. ;'''\ ..."--....t,,.Jrl...e. "'.t'"'}. L(.;C\"_41.L.'-V l,.<-;.. LJ'u~e~L.a JL"".J1~4i.' l..-., '-4o\..,\,...L~,",,\ \.4!J.'-_", r::'...OL,;.....L\,t r~._"""'"
....... oJ. 1".....
Ep ,\. ,; !:> r("\ '<:t -.. .,.,~,1:",t; -" ,: '11~' t t" -, .." "r,':"" ('r:''DCT " c::> -'
..: C::lll prO'LCe "",r a pc- -J ~ll.~ ~1..dU.. CG. ~n.."l no. .\, ~dv '.. ..,,~~l ,~..c." --,.. ....\;CL10:l
l"'l(t:\. l'o\"'~\'e'" EDA '~"''''n~ ;:::n1!,"J ar"-- "I'nl~'U1~::"" f'-ro"l aPl f"'11;i" 1'I""OI'j'I't\: "l"lf -"'~l"~'I"i
- j, J. ..... ., .L..... ""'~!...~...I.. _11 .t-'".-' =' uJ.~L .1 1...1 .....1.-..' 1.1. - ....-1.-........ ~ J - \. 1'-..1 ~I..........
cont~mination that may lem~in 0;: sire. Under "Superfund~" a p:llty C:ll1 be lio.ble for
de:mup of a site whether they ',':er= re~ponsiblc for th:~ contamin:.l~ioi1 0.- ovm t!l(:
contaminated piOp~ny, CERCL-\ l~preSeilts C.)ngrcss' jtldg~11eJ1l en how to b~st adc.:ress
the probiem of contamination by h~',zarcous subsmnces, and EPA must ahl~e by tl:~ ~-:rms
ot- th.o. c'atut.o. l:.-::p' ai's'" ;::11;:-'10"',-,- ,'" ~-":-~nm~nt"l 'llIO:;-l \':!1i,-~ m~" b" " al.>;c"';::e '1(7~ilFt
\"". wL ~. - l"'\. \.J """.':""'1,-:,'.........1...) r-..L ""UVU\.. 1 \"J. d ( 1 "1.1,,,... J. u,;r r..., u. '-'".I. ...J.... (,.,0..,::-........
future liability.
en, 't' -h" A la-,et . P, h::' \..';:apt; (1
olL.menlS rom L-:~ . .1.:;:'..... 1 .1'",,(.; ,.L_..n~
Comment: Has EPA evaluated th~ possibility of using on-sire incineration to remcdiate
soils at QUI?
EPA Respome: EP A evaluated the use of on-site ii!cineration during development of
remedial alternatives in the FS. Due to the degree of contamination and volume of
contaminated soil present at QUI, the use of on-site incineration was rejected due to
economic and environmental considerations.
,Comment: Several participants asked why dead animals have not been found at aUI and
why weeds grow there if it is contaminated.
-------
EP A Response: TIle presenc~ of dead wildlife is not the only indication of actual or
. .
potential hazards. Similarly, th~ danger to human health, welfare, and the environment
cannot be quantified by the amount cf\veeds growing. r-.-fcst of the pesticfd~s contaminating
OUI are classified as insectidde5 and may not necessarily affect plant life. Risk
information on the site is contained in the endangerment assessment documents. These
reports present, in statistical terms, what'the exposure risks are ror various contaminams
and how the risks are calculated.
.
.
Comment: One of the participants expressed doubts over the potemiai exposure ris~(S th~t
have been identified at OUI.
_1:1:>.\ R-',T'O ~",. Ep \ j,........ "de",-i;;.:1d -(",-:-~~.:"'l "''''\~''OS''l'e '1'1znf'.I'" tJ.,..,~ t"i"1"'JH .~....;I:'" "," th~ c:::~.~
_A .""'\ '-..- n~(;. ...-'1. ..,;:0 1 o!'.U- lJ".(.;"u.. -"t' \. 1.._... ...' ".., oJl...,: '_.,,-~ LLl ..- -..1.:,
nor neces~~rily currenr h~zard::. The purpo~c of c!~:lr.ir:g up soils ~! th~ si:~ is to reut;cc:
and/or eliminate
comami~w.tioI1.
DO"":),!'"
. 1__1u..."'"
ex~osures, Clnd to remove the SQ~rr.:~ of !!round\'.'at~l'
. ~
C()mmen!: Are site boundaries going to ch:lng~ to inc!u(~e prnp~rty :ldjac~iit W the sir~?
EPA Respons~: At present, site boundaries v.;iH remain as defined in tb~ FS. How~ver,
if comamir.arion is found on propeny th:lt is Icc:ltec.l ~djacent to a Superfund sirc. the site
bour.daries n1:lY be cOirespondingly eruJrged.
Cmr.me:-1t: \Vhat is the potential fOf exposure to contambateu gro!Jnd '.~'atcr that may ha\'~
migrated from the site to adjacent properties?
EPA Remonse: There should be no ct]rr~r1t exposure to contar11ir:ated ground water sinc~
residents and businesses in the are::t have been advised not to use existing groundwater
wells. The entire area is now cn a municipal v.':ner supply sy::tem.
Comment: If property is determined to contain contaminated ground water, will the owner
of that property be asked to participate in the operab!e unit that involves groundwater
contamination (OU4)?
EP A Response: Generally, if EP A identifies a contributing source of contamination, the
property owner can expect to be contacted about cleanup participation. If the property is
not a contributing source, property owners are usually not expected to p::trticipate in the
cleanup.
.'
.?
-------
..
Comment: Do attorney's comments in the August 2, 1989 Responsiveness Summary address
litig~tiol1 between EPA :!.nd PRP:;?
.
EP A Resp0nse: It is routine fer properly owners or operators to ha'.;~ attorneys represent
them and make comments on their beh~lf. TI1e comments included in the previous
responsiveness summaries are of then nature and have nothing to do with litigation. They
are simply comments made by the attorneys as representative for the property owner.
Comment: \Vere there <111:; comments received by EP.-\ tli:.H '.vere not ickntifieJ in the
Au""'s" j 101.'('\ Re-""o"C;;l"le"""'s' ~un'~'" r,'?
5U L -, ."U:,I.1. ~l-' 1.- ".'-. ~..... ..Lll!.L\....'.
:-'!).. 1:' '>'!"')'1';'" r-p... -j f'C;;""'u;)?1U{':>Q! l" r, ,11 "CJ'I'~"-!,-.!"'T;: !,..~,..>;, ,;,,;
"'-- J. .-\. .." - ... .J 1... . ..... - . - .-\. .."..... - J... - V '-io .. ~ , .. J,... '- ."'.J ., \w \., .. .. "" U .
If 1\'-.'0 or mor~ comrnen1S \','.::'e
1....... 1 .., h ' . I ..
511 .Ilc~er:tlY SllTIi!Ur, o\:/e'(/cf, tney ",.vere a<.1GleSS~Q uniy ()~ce.
C()mme:~l: \Vhat assurances C;:lI1 be given to pQi:er:ti~l buyers of property o.djo.cent tn GCl
'vl~o m'1v be COI1<;-"'ri""'l "bmH "'Ofe:,r;:ll cie~il"" !i-::;~,i!;li,~s '-'r.rl exnO<;ljres rl'r:;';:y ""c""""'d:,~1
...~. J. ""'a .\w\. '-a ::' ~ ....."'.... .. "',t" -.....,~.... ",,4...-1 ...,...a .. ""'.6 1.',::) .. .,.- ......
acrivities?
,-'!')\ Pe,~'on'e'
.L- 1 I""'\. ." ~.:-" I I. .
In situations "vhere rh~re is prior k.iOW1c:J;::; :f:at a potential problem may
exist, there is cert::lir.l'l a risk on th~ DJrt of the prOD~rlV bll',~r conccrnin!! the Dossibilirv
.. .L ~ .. .. - - l -
ot'll'''bil:tv Tt is "J.!'rel' dl"l-~':'~u1t to (L>t'>"~'ll'j"'" ['f P"Ii1np",'" ;;: ""I~t"\;--:;I'n.,r..,.,i l'ln'!,>,s .;:';-".,1c;'s ...r.>
""" ".,. -4 ... .-... \ 110 J. .J.t".. 1 a ,-_..1.,."..... ........... ~J:'-" L.} 60J '-\J ............... ""'1Io\wU """_a _.~"'.I.}i. c.. "'"
collected alid an,JIyzcd. There 11:1S b.;;:;n a tremer:dous clfon recemly by property btiye.rs
to make sur~ that :m:,r oro'Ccn1es they may Durch::!.~;c :lie !jOt contaminated. Com:-;:cH.lenti'",.
....1. 6. .. ~ J. -
many property buyers and/or s.;!krs h3:;e an environmentJ: :m:dy performed m ensure thJ~
the land is uncontaminated.
Precautionarj and preventative measures will be exe:-cised during remediai activities in
order to minimize possible releases of hazardous substances into the surrounding
community.
Comment: \¥ho performs environmental audits, and nO'.' much does one cost?
. EP A ResDonse: There are numerous engineering consulting firms that perform
environmental audits. Cost will vary greatly depending on the size of the property and the
- .
extent to which it needs to be investig:J.ted.
6>
-------
Comment: Is it anticipated that dust will migrate off site during remediaL activities, and
how long wiII cleanup take to compLete?
EPA Response: Dust is a potential exposure problem but can be dealt \vith usmg
preventative and protective measures. Dust control methods wi1I be implemented during
the remedial activities, thereby rPinimizing the risk. It is estimated that it will take aboUt
5 to 6 years to complete remediation of the site with either the biological treatment or soil
washing alternative. The gre:ltest potential for dust exposure problems would occur during
the first ye:lr or cleanup operations and would not be a concern during the rest of the
. (
remediation.
C(jmm~m: Ha'v'c all PRPs ar th~ site been identifi~d ai~d is that public information?
EPa-\ r-~C~~0ari~~e:
The PRIJs ;:lC OUI have been idemified and that is public inform:ltion~-
Cornrr.e::t: Is there a time t:l!):e for addressing contamination at the Sand Creek Ir;Gustri~d
sire othc~' than for aUI?
EPA RcsDnns,~: Ye:::. EPA has ~stablished a schedu!~ for addressing the contamination
associated \...irh the mher operable units.
The RIfFS for OU3 \viil begin Ocrober -
December 1989. Operabl~ L'nit -+ wiil be addressed during July - September of 1991. The
RIfFS fer OU2 will begin Oc~nber - Dec~mbcr of F''i 1991. TreatabiJity Studies win begin
during Octobe.[ - December of 1989.
. - .. .
.' . 'to-
0_- :.: .....- ._~~...-. "..-"- "r
'. ..-..... 0-.
. -
. . .
-' .. - '..
. . . . . .
. .
". -.",/--_,'-7 ','"' .""-:.--''''. -7,'.',-:, ...:.--:--- ~-. "-:.---- _.--.-"':_'~.":.-.''''
..,. .
..
.
Hazardous
Informatior
US EPA Ref
Philadelptt
."" ~~:.;.~:~.
.:..-~~... --.:-- .-.."':--:""'''",,:''': ..:."......~
- .." - - -..
. . .. : "-. .~-. .. -: .
. ..
.. . -. .
. .. .. .. . .. .
- - '.. --
-" - - ".- - .-: - - ':. -- '--... .-
- "- : .. .. -. .. .. .- - ......"
.. - -' . . -
.. .....
. .."
. -- ..-
....;~:.~ .;.' :~:. ~;~~~~~Xj~:;~\:~:;t ~~~~\S~':~:,- .~: .:.~...\;~~~ :~:~'~:5; ;;.~-.j:: ..::--:~~~if~~~~;:
-..- .-
- -. -- ..
'"- .. . --
- /.~-' . -,:- :'..:
. -:.~. ...
. ..
-:.,' .
. .
..-- -. .
'. .--- '. -
-':~. _.;".-'..~...'-:';'~:"'-:~...':- -: '-
. - .
.- '.- .-.
. .
-.' .~~ ".-w'" ...-
. -;..--:.:"",..:. : ...,"
.........-.
.. .4
..
~.-.' .
a
- '-. -'-
. .
.' - -- -- .-" ~-- '-'_.~ -. ,
: ,.. .-- . --
-
.' ---
. .... . .
- -' .'
.' '.
- -'. .. . ':' ~ .
. - -'
-..-: -:. . :,..."':--' '~.,~ - .- -.. -:: ~-".:: :-- : :-.. -. :.- ..~: .' . ;'P :. ..-.. ~ '..
. .
-.
.~... _.:. '..::\
. - :: ~ . ~:-~.
.:'~: -,-,-:'.r_-:".._';~- .- . -.-
'.. ....
.- ".
... -'.
".,... .. .. '.. - -. - --
-. .-...-_.- '7 _." .'.'.-
~ '. -'" - ,.
... - - - --
-. . '~.'
. .
-. . '-- -- --
." .." .
. ':" .'. .-. ."-
-' --.'.. .."':- ""'..' .; '-'...~.:,:...:-
. .
. ~'..'. .-. ~. . ',- .
- .." --'- - . .., ..
. ~. .
'. -'
-._u .-
-- -'.
-..- ~:- ,.'-'.-':._:':~'--: .
. -':.:'. -: -_: -:-:-.. 7a.'- ---or.::-
.' .-,'-
-. --'
- , . - ~- .'::--' :--' .
. .' -
7
-.-..'----
. '.-- .-'-.- .' ------
. .:".~..
--.'-'-...' ,.
-.... - -
.. ". .
- '.
------- |