United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R08-90/029
September 1990
&EPA Superfund
Record of Decision:
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50272.101
REPORT DOCUMENTATION 11. REPORTNO. 12.
PAGE EPA/ROD/R08-90/029
3. Reclplent'8 Acce88lon No.
4. T11Ie md Subtitle
~UPERFUND RECORD OF DECISION
Fortland Cement Co., UT
First Remedial Action
7. Author(l)
5. Report Dlte
07/19/90
-
6.
8. Perfonnlng Or"lnlDtion Rept. No.
II. P8rf0nnlng OrgelnlDtion Name Ind Add.....
10. ProjectlTl8klWork Unit No.
.
11. Contract(C) or Grlnt(G) No.
(C)
w
(G)
12. ~orIng Orglniz8tlon Name Ind Addre..
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementery Notel
16. Abetrlct (Umlt: 200 WOrdl)
The 71-acre Portland Cement (Kiln Dust #2 & #3) site is in a primarily
industrial/commercial area of Salt Lake City, Utah, and consists of 3 separate but
adjacent properties known as Site 2, Site 3, and the West Site. Between 1965 and 1983,
the Portland Cement Co., which was purchased by Lone Star Industries in 1979, deposited
~proximately 495,000 cubic yards of waste cement kiln dust (CKD) on each of the three
operties comprising the site. Waste CKD consists primarily of heavy metals and other
~norganics and is highly alkaline. Approximately 360 tons of chromium-bearing
refractory bricks were disposed of with the waste CKD. Unlike Sites 2 and 3, the waste
CKD at the West Site is mixed with soil and debris including demolition rubble, scrap
iron, concrete slabs, asphalt, and common and the chromium bearing refractory kiln
bricks. The waste CKD has also produced a contaminant plume which is present in the
shallow ground water beneath the site and some adjacent properties. This Record of
Decision, the first operable unit, addresses removal of the waste CKD and temporary
onsite storage of the chromium bricks. A subsequent operable unit will address any
remaining soil and ground water contamination and treatment and disposal of the chromium
(See Attached Page)
17. Document An8Jy818 L Deecrlptore
Record of Decision - Portland Cement Co., UT
First Remedial Action
Contaminated Media: gw
Key Contaminants: metals (arsenic, chromium, lead), other organics
b. IcIentifler8lOpen-Ended Terms
c. COSATI Reid/Group
18. Av8l1lbiity Statement
111. Security CII.. (Thll Report)
None
20. SecurIty ClI.. (ThIs Page)
Nnnp
21. No. of Plges
156
22. PrIce
(See ANSl-Z3II.18)
See /MtruclioM on RetteIN
(4-77)
(Formerly NTlS-35)
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EPA/ROD/R08-90/029
Portland Cement Co., UT
'rst Remedial Action
stract (Continued)
bricks.
arsenic,
The primary contaminants of concern affecting the waste CKD are metals including
chromium, and lead, and other inorganics.
,
The selected interim remedial action for this site includes excavation and offsite
disposal of 495,000 cubic yards of waste CKD at a noncommercial, industrial landfill,
which will be capped; removal of 360 tons of chromium-bearing refractory kiln bricks from
the waste CKD prior to offsite disposal of the waste CKD, followed by temporary onsite
storage; ground water monitoring; and implementation of institutional controls including
well construction and deed restrictions. The estimated present worth cost for the
remedial action is $12,143,000, which includes an annual O&M cost of $5,000 for 30 years.
~
PERFORMANCE STANDARDS OR GOALS: Offsite disposal of waste CKD will eliminate fugitive
dust emissions from the site thereby contributing to compliance with Federal and state
air quality standards. Final soil and ground water cleanup levels will be addressed in a
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r~
DECLARATION FOR THE RECORD OF DECISION
..
PORTLAND CEMENT CO. (Kiln Dust #2 & #3)
Operable Unit 1
Salt Lake City. Utah
July 19. 1990
Utah Department of Health
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DECLARA TION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
..
Ponland Cement Co. (Kiln Dust #2 & #3), Operable Unit No.1, Salt Lake City, Utah.
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Ponland Cement Co.
(Kiln Dust #2 & #3) site, in Salt Lake City, Utah, which was chosen in accordance with the
requirements of the Comprehensive Environmental Response, Compensation, and Liability Act
of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA) and, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
This decision document explains the factual and legal basis for selecting the remedy for this site.
The U.S. Environmental Protection Agency (EPA) selected the remedy for the site. The
information supponing this remedial action decision is contained in the Administrative Record
for this site. The State of Utah concurs with the Selected Remedy.
ASSESSMENT OF THE SITE
The waste CKD on the site is a threat to human health and the environment because it
contains elevated levels of cenain heavy metals and other inorganic contaminants and is highly
alkaline. The most significant human health and environmental hazards are: (1) inhalation of
fugitive dust, (2) direct contact with waste CKD on Sites 2, 3, and the West Site, and (3) there
is also contaminant migration from the waste CKD to the underlying ground water, which is a
potential source of drinking water and other beneficial uses.
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare, or the environment.
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DESCRIPTION OF THE SELECTED REMEDY
TIlls operable unit (Operable Unit 1) is the flISt operable unit for the she. Operable Unit
1 will remove the source of contamination (the waste CKD) from the present site and address
the principal threats to public health and the environment posed by that waste. Any remaining
contamination will be addressed in a subsequent operable unit(s).
SELECfED REMEDY
r
The State of Utah as lead agency on this site, has identified Alternative 7C - Excavation
and Off-Site Disposal in the Vicinity of the Salt Lake Valley Landfill - as their Preferred
Alternative for Operable Unit 1. The EPA has selected the State of Utah's Preferred Alternative
(AJternative 7C) as the Selected Remedy for Operable Unit 1. Some modifications have been
made to Alternative 7C, which are described in this Record of Decision (ROD). The Selected
Remedy will remove an estimated 495,000 cubic yards of waste CKD and separate and
temporarily store about 360 tons of chromium-bearing refractory kiln brick at the site. The waste
CKD covers an area of approximately 71 acres, and is in contact with shallow ground water.
Removal of waste CKD from the site will reduce exposure to fugitive dust, eliminate the pathway
of direct exposure to waste CKD and any future human exposure pathways, and will remove the
source of ground water contamination. Additionally, the removal of the waste CKD will
facilitate the fmal remediation of the site.
The major components of the Selected Remedy include the following:
The excavation of all waste CKD from the Site, and its transportation to and
disposal in an off-site state approved, noncommercial, double-lined, industrial
landfill to be constructed at approximately 1300 South and 7200 West, in the
Vicinity of the existing Salt Lake Valley Landfill and other industrial disposal
facilities in Salt Lake City, Utah.
The new landfill for the waste CKD must be acceptable to the State of Utah and
EPA.
A layered cap will be placed over the waste CKD.
All chromium-bearing refractory kiln brick will be removed from the waste CKD
and temporarily stored at an acceptable on-site location. The treatment and
disposal of the chromium bricks will be addressed in the next operable unit.
Ground water monitoring will also be initiated.
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STATUTORY DETERMINATIONS
The Selected Remedy is protective of human health and the environment, complies with
Federal and State requirements that are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. The Selected Remedy constitutes a penn anent solution to
the maximum extent practicable for the waste CKD.
.
Two treatment alternatives involving waste solidification to reduce contaminant mobility
are considered less effective and less pennanent than the Selected Remedy. Two other
alternatives involving reuse of the waste CKD as a resource were considered nonviable because
Lone Star Industries was not able to identify or develop any markets for reuse of the waste CKD.
Therefore, treatment of the principal threats of the site was found not to be practicable and thus
this remedy does not satisfy the statutory preference for treatment as a principal element.
Because the Selected Remedy will result in hazardous substances remaining on-site which
may be above health-based levels, a review will be conducted within five years after
commencement of remedial action to ensure that the remedy continues to provide adequate
protection of human health and the environment.
Restrictions on land use and long-term monitoring would be required for the new, off-site,
industriallandiill to be constructed in the Vicinity of the Salt Lake Valley Landfill in Salt Lake
City, Utah.
This ROD will be followed by another operable unit(s) which will address the final
remediation of the site.
£ . - w.-/.--
James. erer /
Regional Administrator
EP A Region Vlll
J}?Jf I"~"
Date
"~f1/1i. tf!J;; Ui(
Kenneth L. Alkema, Director
Utah Division of Environmental Health
r 7
~l~?t':? /~~
I I
'...- Date
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.
DECISION SUMMARY FOR THE RECORD OF DECISION
Portland Cement Co. (Kiln Dust #2 & #3)
Operable Unit 1
Salt Lake City, Utah
July 19, 1990
Utah Department of Health
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THE RECORD OF DECISION
PORTLAND CEMENT COMPANY (KILN DUST #2 AND #3)
SALT LAKE CITY, UTAH
CONTENTS
(Major Sections)
.
DECISION SUMMARY
PAGE
2.
3.
4.
5.
6.
1.
SITE NAME, LOCATION, AND DESCRIPTION.. ..., ..., . .. . . . .. 1
SITE IDSTORY AND ENFORCEMENT AcnvITIES . . . . . . . . . . . . . ., 6
IDGHLIGHTS OF COMMUNITY PARTICIPATION. .. .. . .. . . .. . . .. 7
SCOPE AND ROLE OF OPERABLE
UNIT WITHIN SITE STRATEGY. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 8
SUMMARY OF SITE CHARAcrERISTICS ...................... 9
SUMMARY OF SITE RISKS
. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 23
7.
DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . .. 28
8.
SUMMARY OF COMPARATIVE
ANALYSIS OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . . . ., 62
9.
THE SELECTED REMEDY
. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 73
10.
STATUTORY DETERMINATIONS FOR
THE SELECTED REMEDY . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 76
11.
DOCUMENTATION OF SIGNIFICANf CHANGES. . . . . . . . . . . . . .. 82
RESPONSfVENESSSUMMARY
ATTACHMENT - SUMMARY OF RECENT COMMUNITY
RELATIONS ACTIVTIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 22
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DECISION SUMMARY FOR THE RECORD OF DECISION
l.
SITE NAME, LOCATION, AND DESCRIPTION
.
The Portland Cement Co. (Kiln Dust #2 and #3) site is located in Salt Lake City, Utah,
on the west side of Redwood Road (1700 West) at 1000 South (Figure I-I), within a triangular
area defIned by Indiana Avenue, Redwood Road and the Jordan River Surplus Canal. The site
is approximately one mile south of U.S. Interstate 80, and approximately 1.5 miles southeast of
Salt Lake City International Airport. The site consists of three separate but adjacent properties
known as Site 2, Site 3, and the West Site (Figure 1-2) hereafter referred to as the "site". Site
2 covers approximately 17 acres, Site 3 covers approximately 19 acres, and the West Site covers
approximately 35 acres. The entire site occupies an area of approximately 71 acres.
Approximately 495,000 cubic yards of waste CKD are present on the site, and
approximately 360 tons of chromium-bearing refractory kiln brick are disposed with the waste
CKD. In the eastern area of the site (Sites 2 and 3 on Figure 1-2) waste CKD is present on the
ground surface in thicknesses of from 3 feet to greater than 6 feet. On the West Site (Figure 1-2)
much of the waste CKD has been mixed with and covered by fill and demolition materials, but
appears to be present in pockets of up to 7 feet in thickness. A contaminant plume from the
waste CKD is present in the shallow ground water beneath the site and some adjacent properties.
Topography
The topography of the area is relatively flat with elevations varying slightly above and
below 4225 feet above mean sea level. Early surveys show that before fill was placed at the site
a grade break existed in the ground surface which bisected the triangular-shaped area along a
northwest-southeast axis. Land to the northeast of this break was relatively high ground and was
used for agricultural and residential purposes. Lands southwest of the break were low salt flats.
Adjacent Land Use
The area next to the site is primarily industrial and borders low density residential and
vacant or agricuJturallands. The immediate area surrounding the site is highly commercialized
and industrialized. Residential areas exist primarily east of the site and include single-family
dwellings, mobile home parks, and some high density multi-family residential units.
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VICINITY
MAP
REFERENCE
U. 5.G. S. QUAORANGL.E5 ENTITL.ED
"5AL.T L.AKE CITY NOR'1'1-I. UTN-f nAND
"SAL.T L.AKE CITY SOU'1'1-I. UTN-f" -
80'1'1-1 S~EETS DATED (96) AND PHOTO-
REVISED 1969 110 1975,
-------
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WASTE
CEMENT KILN. OUST
DISPOSAL SITES
-------
Suils
The natural soils underlying the site are poorly drained and are affected by salinity and
alkalinity. Uses are generally limited to range and wildlife habitat with some small areas
reclaimed for agriculture. Placement of fIll materials has raised the surface elevation of the site:
and has resulted in an uneven ground surface occasionally strewn with piles of debris. Drainage
is still poor even though the area has been filled. Occasional areas of ponded water develop in
confmed depressions east and south of Site 2, between Site 2 and Site 3, and north of Site 3.
Surface Water
The Surplus Canal and the City Drain are existing surface water features adjacent to or
passing through the site (Figure 1-2). The Surplus Canal flows along the southern boundary of
the site. It carries excess flow from the Jordan River to the Great Salt Lake in a northwesterly
direction. The City Drain carries urban storm drainage through the site on a northwesterly
course. The drain separates Sites 2 and 3 and bounds the West Site on the north. The City
Drain is part of the urban storm sewer system and is classified by the State of Utah as Class 6
surface water. Such water is protected when conventional beneficial uses do not apply, with
standards for this class being determined on a case-by-case basis.
Ground Water
Ground water under the site occurs in three divisions: (1) a shallow ground water body
overlying confining layers, (2) local perched water bodies, and (3) an artesian basin or reservoir
including the recharge area. The primary recharge area for the artesian basin is along the
benchlands on the sides of the Salt Lake Valley where the ground water is unconfmed.
The shallow or unconfined aquifer comprises the near-surface unconsolidated deposits.
They are generally lake sediments composed of interlayered clays, clayey silts and thin sand
stringers varying in thickness from less than a tenth of an inch to several feet. The "Ground
Water Quality Protection Regulations" adopted in 1989 by the Utah Department of Health
classify the shallow, unconfmed ground water in the area of the Portland Cement Site as Oass
II and Class ill ground water based on data collected in the RI.
Beneath the near-surface deposits, thicker clay layers make up the confming layer or
aquitard which separates the deep confmed aquifer from the shallow unconfined ground water
body. The deep aquifer, which is the principal ground water source in the Salt Lake Valley,
consists of high permeability sands and gravels interbedded with silts and clays.
The horizontal ground water gradient of the deep confmed aquifer in the vicinity of the
site is to the north-nonhwest toward the Great Salt Lake. Regional studies of the shallow
-------
unconfined aquifer show its horizontal gradient to be generally toward the Jordan River, or to the
nonheast. Local conditions in the shallow gquifer, however, can strongly affect the ~adient.
Although the local gradient of the shallow aquifer in the area is generally to the west, it is
strongly influenced by the Jordan River Surplus Canal, the City Drain, and a north-south trending
below-grade sewer line located along the west side Qf Sites 2 & 3.
Natural Resources
The Salt Lake City area is within the Great Basin Section of the Basin and Range
Physiographic Province, which consists of isolated mountain ranges separated by aggraded desen
plains. The vegetation of this area is characterized by a mosaic of cold desen shrub communities
of shadscale, greasewood, and big sagebrush, depending on soil salinity. Alkali flats of saltgrass
occur within this shrub matrix in conjunction with near-surface ground water and very saline-
alkaline soils.
.
Most of the area near the site consisted of saltgrass alkali flats prior to extensive
industrial development. Currently, the combination of dense patches of vegetation cover and
physical protection provided by fill material supplies suitable habitat for numerous animal
species.
A December 1983 bird count listed 57 species along the Jordan river within Salt Lake
City. Waterfowl, including several species of ducks, have been reponed to use the ponds in the
site area. The area also provides habitat for several mammal species.
The State of Utah has classified the Surplus Canal as Class 3C, 3D, and 4, protecting it
for nongame fish and other aquatic organisms; for waterfowl, shorebirds, and other water-oriented
wildlife; and for agricultural uses including irrigation of crops and stock watering. Any aquatic
organisms known to inhabit the Jordan River in the Salt Lake City vicinity could potentially
inhabit the Surplus Canal.
No listed or candidate threatened or endangered species are known to occur in the
vicinity of the site. .
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2.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
All waste CKD deposited at the sites was produced by the Portland Cement plant located
at 619 West 700 South in Salt Lake City, Utah, between 1959 and 1983. While it is not
definitely known when the first waste CKD was placed in the West Site, discussions with the:
land owners fix the date at approximately 1965. Disposal in the West Site continued until about.
the spring of 1974 when deposition in the area of Site 3 began. Disposal at Site 3 was
terminated in the winter of 1977/1978 and activities were shifted to Site 2. Initially, the material
was trucked from the plant and deposited at the site in dry form. Subsequently, precipitation and
intrusions of ground water resulted in hydration and agglomeration of the waste CKD. Dry
dumping at Site 2 was stopped in December 1980. Disposal of waste CKD at Site 2 was
continued as a wet slurry until sometime between March 1982 and December 1983 when all
disposal activity was stopped.
The total volume of waste CKD at Sites 2, 3 and the West Site is estimated to be
495,000 cubic yards. Site 2 is estimated to contain 138,000 cubic yards, Site 3 is estimated to
contain 249,000 cubic yards, and the West Site is estimated to contain 109,000 cubic yards of
waste CKD. Waste CKD was not deposited in the West Site in homogeneous thicknesses as at
Sites 2 and 3, but rather in discontinuous layers of varying thickness. The West Site waste CKD
is interlayered and mixed with a variety of demolition rubble, soils, scrap iron, concrete slabs,
asphalt, common brick, alumina kiln bricks, and common trash. In addition, a small quantity of
chronUum-bearing refractory brick (about 360 tons), are mixed with the waste CKD on the Site.
In September 1979, Portland Cement Company of Utah (PCU) was purchased by Lone
Star Industries. In September 1984, Sites 2 and 3 were proposed for inclusion on the National
Priorities List (NPL). Lone Star had voluntarily started environmental investigations at the site
in April 1984. The investigations were organized and expanded under a formal Remedial
Investigation/Feasibility Study (RIIFS). The RIlFS work plan was submitted to the State of Utah
on September 24, 1985, and was appended to a consent decree with the State. Judgment based
on that consent decree was entered on November 29, 1985. The site was formally listed on the
NPL on June 10, 1986. An additional work plan to complete the RIlFS was appended to an
Amended Partial Consent Decree dated February 13, 1989. On July 26, 1989, EPA sent a
General Notice Lener, which identified Potentially Responsible Parties (PRPs), to Lone Star
Industries, and the site land owners, Williamsen Investment Co., Lawrence D. Williamsen, Sidney
M. and Veoma H. Horman, and Horman Family Trust.
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3.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RJ/FS reports for the Ponland Cement Company Sites 2 and 3 were released to the
public for comment on September 13, 1989, and a public meeting announcing the availability of
the reports for public review was held on September 21, 1989. The Initial Proposed Plan for the'
site was released for public comment on October 16, 1989. Because the Initial Proposed Plan
did not identify a specific off-site location for disposal of the waste CKD, a Revised Proposed
Plan for the Site was issued on March 26, 1990. The RIlFS reports and the Initial and Revised
Proposed Plans are part of the Administrative Record for the Site and were made available to the
public in three infonnation repositories. One infonnation repository is in the offices of the Utah
Bureau of Enviironmental Response and Remediation, on the fourth floor of the Cannon Health
Building at 288 North 1460 West, Salt Lake City. The other infonnation repositories are
maintained at the Chapman Branch of the Salt Lake City Public Library and at the offices of the
U. S. EPA Region VITI in Denver, Colorado. The notice of availability of the RIlFS report was
published in the Deseret News and the Salt Lake City Tribune on September 11, 1989. The
notice of availability of the Initial and Revised Proposed Plans were published in the same two
newspapers on October 17, 1989, and March 25, 1990, respectively.
A public meeting to announce the availability of the RIlFS reports on the Site for public
review was held on September 21, 1989. A public cormnent period on the Initial Proposed Plan
was held from October 16 through November 6, 1989, and a public meeting on the same
document was held November I, 1989. A 60-day public comment period on the Revised
Proposed Plan was held from March 26 through May 26, 1990. The 30-day public comment
period originally set for the Revised Proposed Plan was scheduled to end on April 26, 1990, but
was extended another 30 days (through May 26) by EPA in response to a request from Mayor
Palmer DePaulis, Mayor of Salt Lake City, Utah. A public meeting on the Revised Proposed
Plan was held April 11, 1990. At these two public meetings, representatives from the U.S. EPA,
the State of Utah Bureau of Solid and Hazardous Waste, and Lone Star Industries were either
present or offered comments. A response to the cormnents received during the two public
comment periods for the Initial and Revised Proposed Plans is included in the Responsiveness
Summary, which is part of this ROD. An additional public meeting was held on June 21, 1990,
after the close of the public comment period, for the purpose of informing the residents of Magna
and West Valley City concerning the site and the State's Preferred Alternative.
-------
4.
."
SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY
.
The problems at the Ponland Cement Site are complex. This ROD addresses remediation
of Operable Unit I, which includes waste CKD and the separation and temporary storage of
codisposed chromium-bearing refractory kiln bricks on the site. Waste CKD on the site is a
threat to human health and the environment because it contains elevated levels of cenain heavy
metals and other inorganic contaminants and is highly alkaline. The most significant human
health and environmental hazards are: (I) inhalation of fugitive dust, (2) direct contact with
waste CKD, and (3) there is also contaminant migration from the waste CKD to the underlying
ground water, which is a potential source of drinking water and other beneficial uses.
The purpose of this response is to prevent current or future human exposure to the waste
CKD and to eliminat,e the source of contaminant migration into the ground water. Additonally,
the removal of the waste CKD and codisposed chroumium bricks will make it easier to
characterize the extent of any remaining contamination, including ground water contamination.
An additional operable unit(s) is planned for any remaining soil and groundwater contamination,
and will provide a fmal record of decision for the site.
-------
5.
SUMMARY OF SITE CHARACTERISTICS
Potentially Affected Population and Environmental Areas
Land surrounding the site is used primarily for industrial and commercial purposes. :
Residential areas are located east of the site, and vacant or agricultural lands are interspersed
throughout the surrounding area. The site is zoned C-2 for controlled low density commercial
and M-l for light industrial uses, and is also designated to be within the approach zone for the
Salt Lake City International Airport. Salt Lake Planning officials report that light industrial and
low density commercial use will be encouraged in the vicinity of the site. The population within
one-mile of the site was estimated to be between 6,000 and 12,200.
p
Natural soils at the site are poorly drained, saline-alkali affected, with lime accumulations
and pH values of 8.4 to 9.6 units. The vicinity also includes other fill soils or material in
addition to the waste CKD placed at the site. Uses were generally limited to range and wildlife
habitat with some areas reclaimed for agriculture.
Volume, Quantities and Concentrations of Contaminants
Constituents of waste CKD include oxygen, calcium, silicon, aluminum, iron, magnesium,
molybdenum, sodium, and potassium. Waste CKD constituents which are hazardous substances
under CERCLA Section 302.4 include arsenic, cadmium, chromium, lead, and zinc. Table 5-1
compares elemental concentration ranges of waste CKD from the site with typical concentration
ranges for western soils.
The major constituents of the chromium-bearing refractory kiln bricks taken from Site 3
are silica, magnesium, calcium iron, aluminum, chromium, manganese, zinc, and barium, with
lesser amounts of cadmium and silver. Table 5-2 shows analytical results from samples of kiln
bricks. The chromium-bearing refractory kiln bricks (chrome bricks or chromium bricks) are a
characteristic hazardous waste under the Resource Conservation and Recovery Act (RCRA).
Extent of Contamination and Affected Media
Waste CKD was deposited in all three areas of the site--Site 2. Site 3. and the West Site.
There are differences in the nature of the waste disposed at each area. The waste CKD at Sites
2 and 3 is unifonn and homogeneous compared to the waste CKD in the West Site. The waste
CKD at Sites 2 and 3 was placed in a single relatively thin lift and is fully exposed at the
surface. Waste CKD at the West Site is present in several fonns: it is pure. mixed with soil,
and intennixed with soil and rubble. Some of these waste CKD materials are exposed at the
existing ground surface while others are encountered below surface fill. Figure 1-2 shows the
locations of waste CKD disposal sites. The exact distribution and extent of the mixed and buried
-------
materials at the West Site are not fully defmed. However, based on information developed in
the Remedial Investigation these materials are discontinuous and could exist in pockets. The
waste CKD on Site 2 was disposed as a slurry, whereas the waste on Site 3 was disposed in a
dry form. Cadmium, chromium, hexavalent chromium, lead, molybdenum, arsenic, and elevated
pH were detected throughout Sites 2 and 3 and the West Site, with little variation between the
sites.
"
"
... .
,TOTAL ELEMENTAL CONCENTRATION RAN(JES1N:
, ' , ' WASTE CKD AND SOILS, mglkg' """ '
, 'ELEMENTI '
TRACE METAL
LONE STAR
WASTECKD .'
TYPICAL ~
, U .S~ SOn.s ,."" '
"600 ~, 320,000 .
300 ~ 100,000 '
500 - 100.000"
1 ,900 -:- 63,000 '."
, '
. ,". .
Calcium
Magnesium
Sodium
Potassium ,"
, '
, "
.. ..
, '
144,000 - 189,000 '
5,120 - 22,900 "
350 - 2.940 '
3,000 - 35,000
,3.0 - ,27 .
. 2.1~5.5
, 8.7- 28
, , '
, 90 -1,274 '
8.7 - 51.7 '
",,0.1 - 97
. ...'
Arsenic "
Cadmiwn:
, Chromium
Lead ,', '
Molybdenum'
. ...
:'3.0 '~2tOOO'.,
, 10 - 700 ".'
3-7
, ,
Areas of suspected waste CKD have also been noted along City Drain. A field survey
of City Drain showed that barren, light-colored soils were apparent along the bank at four
locations. Since City Drain was constructed prior to the placement of waste CKD fill material,
it is thought that the suspect material is not exposed waste CKD. Alternatively, the occurrence
of the purponed waste CKD along City Drain may be the result of isolated dumpings of material
along the embankment. In either case, the total volume of possible waste CKD along City Drain
embankments appears to be small.
-------
...
',' ~..
.
..
C6NtEN1'RATI<>~OF TOTA~ME:r ~~S~N<~!~~:~~~~K
. TABLE 5.2
. .
...
..
....
..
...
...."
..
. .
. . .
. ..
SITE 3-4:
..S-1~84
. ..
Sample 1deDtifitati~ f:..
Dale Sampled: < .:. ...
. SITE 3.2
5-18-84 .
...
SITB3.3.
5~18-84
. .
MAJOR IONS. (ppm except .~. noted) ...
. . Calcium (Ca) ... . ... .
. Magoesium (Mg)
. Sodium (Na) .
: Potassium (K).
.OnmR PARAMP:rERS. .
Lab pH (standard units)
.Lab Conductivity (umbostan).
TRACE MET ALS(ppm)
. Aluminum (AI)
. Arsenk(As) .
Barium (Ba)
. Cadmium (Cd)..
O1romiwn. Hex (Cr6x)
TOtal Quomium (el)
. Copper (OJ) . .
Iron (Fe) ..
Lead (Pb)
Manganese (Mn)
Mercury (Hg) .
Molybdeaum (Mo)
Selenium (Se) .
Silver (Ag) .
Zinc (In)
Moisture comeot (%)
. .
. . 102,000
116,000 : .232,000 ..
161.000 ... .,.", ...190,000. .: 223,000
3,320 .... 11.520.. .. 7.630
2,748.0 .3$44~()' \..S~162.8
..
11.05 11.20 11.35
1.2 1.6 23
4,'00 . 5.76J1 . 3.940
.<.05 ..<.05 11.63
75.9 .12.4. 136.0
"3.19 ::...4.02. .. 2.98
250.0 220.0 1120.0
.. 4251.0 1238,4 ::. 6976.7
90.6 .. .74.3. 86.0
. 36,680.2 2.064.0 .4,186.0
106.8 78.0 81.7
.. 1,032.0 4,186.0
.4,048.6
..0004 .rom .0004
<.05 <.05 <.05
<.OS <.~ <.OS
1.54 ~9. 1.42
561.7 4283 679.1
<.01 <.01 <.01
-------
A field survey was perfonned to discover areas of eroded waste CKD deposition which
would indicate that waste CKD could be migrating off-site. Depositional areas were .f.ound along
the north, east, and south sides of Site 2. Most of the erosion appears to occur as sheet or rill
erosion, although a shallow drainage channel has been excavated along the west boundary of the
Link Trucking propeny which has promoted gully erosion into City Drain at that location.
Detailed visual observations of ponded water at the site were made on a regular basis :
beginning in April 1984, an extremely wet spring, when the greatest areal extent of ponded water
was recorded. Areas of ponded water noted included a large area on the southern boundaries of
Sites 2 and 3, several areas on the northern edges of Sites 2 and 3, and several areas within Site
3. A summary of the analytical results for samples collected from ponded water is shown in
Table 5-3. At the time, the only known incident of off-site discharge of ponded water was noted
from the area of ponded water along the north side of Site 3. Water was observed flowing off-
site through a culven at the junction of the Union Pacific Railroad tracks and Indiana Avenue
but was not sampled to characterize its chemical characteristics. This culven drains into a ditch
which flows west into City Drain. During the Phase II Remedial Investigation ponded water was
present in the North Boundary Ditch along Site 3. This water originated primarily from
snowmelt, although analyses show that the pond may also receive seepage from the waste CKD.
Three rounds of water samples were taken from the Surplus Canal and the City Drain at
locations upgradient and downgradient of the site during Phase I of the Remedial Investigation.
The Surplus Canal generally acts as a recharge boundary for the ground water in the area, thus
greatly reducing the possibility of degradation of the Surplus Canal by ground water emanating
from within the site. No increase in concentration of any parameter was seen in the surface
water.
City Drain surface water samples collected during the Phase n RI showed increases in
chloride, sulfate, pH, TDS, and molybdenum concentrations at the downstream site boundary.
With the exception of molybdenum, these increases may indicate the discharge of water from the
site into the City Drain. The presence of molybdenum confmns that ground water from the site
discharges to the City Drain. No significant increases in other trace metals were observed at the
downstream boundary.
Sediment samples were collected at the same locations where the City Drain and Nonh
Boundary Ditch surface water sampling was conducted. The sampling was conducted in order
to evaluate the potential effects of constituent migration into each of the surface water bodies,
either as erosion of waste CKD or seepage and precipitation of constituents. In sediment samples
from the City Drain, arsenic was reponed in a range of 14 to 39 mgJkg, chromium was reported
at 3.3 to 28 mg/kg, and lead was reponed at 38 to 270 mg/kg.
-------
'. ~ .
" ,
, ,
... 0
..,
" ,
0'" .. ....
. . . . . .. .,
..
.....
.. PONDED SURFACE WATER' Q~~LITYP~AS~/~I>A.T1~tJMM,~r'..,'
. '. ' .'... . . .. .,. : ... ... . " . ..." .,. .... ';.". :.~ ::." :.' ,.' . ':,:: . ..:'.'. .::'''' .'. . ...".:'. .:...:.' ". : 0.' .:- :-::::: :>::'~:,;!:: ~~:-:::.::::.~"::-.
" ,
,."
... . ....'. ..'
.,':. . ,','. . ." ...,::0
" . ,.". .,,'.'."
',:.,MIN1MUM: ' ",
. "...
'MAJOR IONS' "
, .. 'calclum(Ca) '",
Maguesium(Mg)' ,
Sodi11iD (Na) ,":,' ,.
.':Potusium 0') , ,", ,
Bicarbonate' (HCO,) ,
CaIbooate (CO,), ," ,"
Hydroxide (OH):
CbJoride (Q):' ..
, :Plouride (P) ,,"
',,' Sulfate (SOJ :'"
"Nitmte(aS N» .
,:'Pbpspbate ,Total (PO. as P) ,','"
. ,....., '." '...'.
.. ,..
::'.---'>.:'
...... . """"
...... , ......
o .. "'.'"
, .. .
,"14.4: ,'i'
'".'<.91 "
, 380.:,,'"''
,630, "..'
<.01'
",i~~1
,"81'/:\,
,..,3J8:
,,1,100 '::":",:':,',
" '",,:<.m,
''',16
.. '
. ,. 0
. 0 , . . . "
... 0
OnmR PARAMETERS'
, "".' Lab pH (UDib) : '..", ,:", ,",
Lab Conductivity (ornboslan) "
'TotaJ SU3peDded Solids, ",
,: Total DiBsolved Solids ,
t8.30:C
4.soo ' ,
'34 '
3,100
, , ALK.ALINlTBS AS CaCO, ,
, ,M Alkalinity, ' ,
" P.A1kalinity
TRACE METALS (ppm) ,
, 'Aluminmn (AI) , ,,'
. Aaeaic (As)
", Barium (Ba), "
Cadmium (Cd), "',
Cbromimn Hex (Cr6x)'
, Total O1romium (Cr) ,
, Copper (Ce) ',' , "
,Iron (Fe) ,
Lead (Pb) ,
Manganese (Mn)
Mercury (Hg)
Molybdenll11 (Mo)
Selenium (Se)
Silver (Ag)
Zinc (Zn)
" J)48'
" <.001/
,'<.01 " ,
<.0001
, ,
'.001 '
.001 '
.01"
,...02'
<.001 '
.01
<.0002
1.19
<.001
<.0001
.01
,'. '~.' ,'.'
.. '
:.:...":."
.. ,
,=:::':::.'..'Y,....
, ,
, ,
, ,
'.'..."'0.
, . ,. ., .
........ ..
. ' . . 0
.. ,
, , ,
... ,.
:.,~'
.... ,.,.
<~"'::,:::::):~/h:"'"
.. ,
168..
./,358>
;:I~]~\
.'. :'. 8,6S0, ',',
{:g~~:
:":,:,~,;:'..:..'.:.....,,,,:
"":"":",',6,.w?
'" ,
::"..,,: 13.0,:.
",: 6O,OOO}"
.. "'1.790 ':,
19,300""
, ..
.., ....
.'.',.'...., .'..'..."
... .. ,....
,.., ...
,...,.. ....
~~:.~.:.~;\;~.~;!;].~;:\:,:.;,./t. .: :.: :. ::(
...,
..., "
,.." :::,..:t~:,
i),'~~~;;:;tt.
":':': .,".'~t~;,':,,{
..
. . , . , . , , '
..
..
, "':!;;:.fi:." ' ,
:~456':
':':?~9.7/:
, ,',"'1 ~6S ,:::.
,. ,.
.,., .,
, ..
. . , .. ., . .
.... ,... .,
, ' ,"'.. "':' iO.28 ,
,,19,437 "
":"',336
,8.254 '
, ,
2.22":'"
".449
<.053
<.0001',
,,0.453 ,,'
':' 549
'0.26 "
,'0.39 ,
" .111
.09
<.003
18.75
'.
.
.043
. Not Meaningful- less than 2 data points above detection limit.
Note: Results are based DO 8 samples coUected April 1984. All data in mg/l except where indicated.
-------
In sediment samples collecter' in the North Boundary Ditch, the mean molybdenum
concentration at SW3-2c (See Figure 1) exceeded the nonnal trace element concentrations in
soils. All other mean values were within ranges commonly observed in soils. . Qualitative
comparisons of the sample results suggest that chromium, lead, potassium, molybdenum, and pH
are elevated in the samples from SW3-2b. The mean value of chromium at SW3-2b is 107
mglkg compared to approximately 20 mg,lkg at the other two sample locations. The mean value.
of lead is 198 mglkg at SW3-2c compared to 112 to ISO mglkg at the other two sample'
locations.
Physical-Chemical Properties and Environmental Fate of Chemicals of Concern
The physical-chemical propenies and the environmental fate of chemicals of concern,
including mobility and prevalence, are discussed below.
Arsenic
Arsenic is a naturally occurring metal that can be present in either an inorganic or organic
fonn. Generally, arsenic is readily sorbed onto clay panicles; however, under very high pH
conditions (such as at the site) adsorption tends to decrease, resulting in increased mobility. In
clay soils, arsenic has a low to moderate mobility.
In the atmosphere, arsenic dispersion and deposition is dependent on local meteorology
and the size of the panicles. The average armual atmospheric concentration of arsenic is 0.003
mg/m3. In the aquatic environment, arsenic is panitioned into sediments via sorption onto clay
minerals. Under high pH conditions, arsenic is likely to remain dissolved in solution.
Neutralization results in a change in valence state from +5 to +3 and precipitation to sediment.
Arsenic does not appear to accumulate significantly in aquatic organisms. In general,
arsenic is found in greater concentrations in lower food chain organisms (bacteria) than in higher
organisms (fIsh), primarily because of the greater surface area to volume ratio in lower
organisms. Accumulated arsenic in higher aquatic organisms is readily transformed to less toxic
arsenic forms and excreted.
Cadmium
Cadmium occurs in nature in the zero and +2 valence states. In the +2 state, cadmium
readily forms complexes with ammonia, cyanides, and halides. The dominant fate of cadmium
in the aquatic environment is sedimentation through sorption onto clays or organic matter and
coprecipitation. Lesser amounts of cadmium may persist in the aquatic phase in solution, either
as hydrated cations 'or organic complexes. The majority of cadmium in natural water is expected
to exist as the hydrated cation.
-------
-- -------- ---~--- ---
\,:"" \\ \ \ !
\ \'"'' II" \ I
\ '. ' , ' , '., I \ !
'\ \ ", .. "~I 'j' \ (IIY InHnrlLL ;
, \ [0 "-~':: :' :-::-' - "--- I I
'\ \, ~~/,;::-~'~~=-=~~::::~~~---- I I
, \ ~' " ~ -":::" ,-,"
~,.~==:-=_:-:-...: .. -:<' 1'1 ~,:::::::::,., ..- J~~Jt. '-]k I
\ ~-, ,: 'rr,'r.;-,---=::....:,'':-'':_~.,.:. -~::::-:':'-=-,'- -'-'--
'- ", I I!""!."..... IHUlnNn nVENUf I ~
\. ,J 11---, -. -:"::'...,.R.R. I
\. '" ' , -.. ---' . .
" ,,/' ~_I! II"" --,~"::::. .
'" ,,/,'/ ~=~I ---a~~:~:::.. J
,", y' 1 '['j '.J~~.:,
, ,/ t:l~-I. 1 ' ::::.
'\ ',,-;" ~, II SITE J ' "::
, , v I -:!, 5 , ~:;:.., I. ,-,! I
, " I ~" I '-30 ..~-~u ---.. --,
" ' ~ ' 'I ~ -..J
, " .~~, I Ct.-" J
" ' ,'11-( ,~,I I
,/ ' I'II-f '~ I .----- I
/", " , IIEST SITE <';~===l--------,_J I
~H~:;LUS -", I --JTj",-:iI--==-='::'::- I
, I ,-u 1 [0,'. -i!J~, (ITT I
, - ,I I '-::, I ' - i
"'" '<::., ,II \ i
" ":-" I ',-- - - .
", ", il ---I.
",,- "':"'" II [1,-1.. "
',','I, ' ,.'-1f It> '-1l6'
',',' I '-:111 '-2~ I-----~-~
. <', II Cl-21 r-<"
"''I "~'" II SITE 2 I
..., ,~, II I
''''-'I '~~~-______I .
'" '-~
, ':--...
'''"', ',,~
''-.... -~-~--
i
!
I
I
j
i
I
I
.
l>
e
.
1!1
D.... W~LL
"''''LiLA)W WCLL
"'.ZOM"~"
8Ua"ACiR. WAT8:a ."14."'0"
200
,
o
.
200
400
I
f'EET
PHASE II INVESTIGATION
SAMPLE LOCAT~NS
nGURE 5-1
-.- - -----
I!J 'C-2.
-------
The fate of cadmium in the soil is similar to its aquatic fate. Cadmium is sorbed readily
to Roil with increased sorption as the organic maner content of soil increases. At ~~treme low
pH conditions, cadmium is expected to move more readily through the soil.
Cadmium is removed from the atmosphere through deposition. The atmospheric half-life
depends on particle size distribution and the form of cadmium.
Chromium
Chromium is a naturally occurring metal, usually present in a valence state of +3 or +6.
In strongly basic conditions (such as those typical at the site) the hexavalent (+6) form
predominates. Hexavalent chromium is a strong oxidizing agent and is readily soluble in natural
water. Trivalent (+3) chromium generally forms stable complexes with negatively charged
species readily absorbing to clay particles. In the atmosphere, chromium is removed by fallout
and precipitation. Typical atmospheric chromium concentrations range from 0.01 mg/m3 to 0.03
mg/m3 in urban areas.
The mobility of chromium in ground and surface water is highly pH dependent. Under
the basic conditions of the site, chromium is typically mobile in water. Chromium (VI) may
reduce to chromium (ill), depending on the availability of oxidizable materials such as organic
maner. Chromium (ill) will precipitate or remain in solution as soluble complexes.
Concentrations of chromium in U.S. rivers range between 1 and 30 mg/l.
Lead
Lead is a naturally occurring element existing in three oxidation states: 0, +2, +4.
Naturally occurring lead compounds are generally insoluble, readily sorbing onto clay particles
or organic maner.
In the atmosphere, lead exists primarily in particulate form. Settling and transport of lead
are affected primarily by particle size. Lead concentrations range from 0.0001 mg/m3 in the
annosphere in rural areas to 10 mg/m3 in urban areas.
The concentration of soluble lead in water is related to the pH, oxidizing potential of
water, presence of competing metals (Ca+, Mg+, Fe+), and the existence of complexing and
precipitating agents. Under high pH conditions, lead is expected to be more readily soluble.
Once neutralized, however, lead is expected to remain in the undissolved form either as sorbed
or surface coatings on mineral particles. Because lead readily sorbs onto soil particles, erosive
transport of lead and other metals during runoff can occur.
Lead is present in nearly all aquatic species with primary uptake by ingestion of
suspended particulate maner containing absorbed or complexed lead. Lower species tend to
accumulate lead more readily than higher organisms and herbivores accumulate lead more readily
than carnivores.
-------
Toxicity of Waste CKD and Chemicals or Concern
Waste Cement Kiln Dust
The constitUents of human health concern in waste CKD are calcium hydroxide, :
crystalline silica, and heavy metals, including the metals described in this section. Silica exists
in several forms; however, only the crystalline forms produce the chronic pulmonary fibrosis
known as silicosis. There is no infonnation available regarding adverse effects from ingestion
exposure of silica. The waste CKD at the site was analyzed for its crystalline silica content.
Results indicate that the waste CKD from Sites 2 and 3 contains approximately 4-6% crystalline
silica.
The OSHA standard for Portland cement exposure assumes that the crystalline quartz
(composed of almost 100% silica) content is approximately 1 percent or less. The OSHA
standard for respirable crystalline quartz dust is 10 mg/m3. The American Conference of
Governmental Industrial Hygienists recommends a Threshold Limit Value of 0.1 mg/m3 for
respirable quartz, while the National InstitUte for Occupational Safety and Health (NIOSH)
recommends a SO mg/m3 (10 hour time-weighted average) for respirable free crystalline silica.
Waste CKD contains several alkaline materials such as calcium hydroxide (slaked lime).
Calcium oxide reacts exothennically with water to produce calcium hydroxide. This material in
direct contact with skin or mucous membranes can result in bums and severe irritation. Calcium
hydroxide is classified as a primary skin irritant that produces acute eczematous contact
dermatitis. The signs of contact dermatitis include sensation of burning, itching, redness and
swelling. There is also special ~oncem over exposure to the eyes. The waste CKD may react
with the moisture and protein found in the eye to form clumps of moist compound which are
very difficult to remove by nonnal irrigation. Such clumps tend to lodge deep in the cuI-de-sacs
and act as reservoirs for the liberation of Ca(OHh over long periods of time. The available
literature on occupational dermatoses does not provide information for developing quantitative
no-effect levels based on either pH or ion concentration in water.
No-effect levels for waste CKD in air are based largely on the crystalline silica levels.
Irritation due to the alkaline materials occurs at much higher concentrations, and is not as
imponant a factor as the silica materials in establishing no~ffect levels in air.
Arsenic
Available data suggest that arsenic compounds are readily absorbed in the gastrointestinal
tract. The half life of arsenic in the body is approximately 10 hours, with the arsenic being
largely excreted in the urine. The systemic toxicity of arsenic is largely associated with effects
to sulfhydryl-containing enzymes. Trivalent arsenic is the principal toxic form; pentavalent
arsenic appears to have linle effects on sulfhydryl-containing enzymes. Arsenic also inhibits
oxidative phosphorylation and other processes relating to cellular respiration.
-------
Numerous studies have indicated that high levels of exposure to arsenic are carcinogenic
in man. Cancers of the skin, liver, and endothelial linings of the blood vessels and the liver have
been documented from occupational exposure. Exposures to arsenic in drinking wate~ have been
associated with increased incidence of skin cancer. The relationships of ingestion of arsenic to
skin cancer, and of inhalation to lung cancer, are sufficient to establish arsenic as a human
carcinogen. EP A has judged arsenic to be carcinogenic by ingestion and inhalation, based on ,
occupational exposures of copper smelter workers (inhalation) and ingestion exposures of arsenic-'
contaminated drinking water.
Cadmium
The primary human health concerns associated with cadmium exposure are kidney
dysfunction and, when inhaled, carcinogenicity. There is no evidence for carcinogenicity of
ingested cadmium. EPA's Carcinogen Assessment Group (CAG) suggests that cadmium be
considered a probable human carcinogen based on lung cancer rates observed in smelter workers
as well as laboratory animals. Emphysema has also been documented as a health effect resulting
from chronic occupational inhalation of cadmium.
Cadmium absorption in the body varies with the type of exposure. Typically, inhalation
results in 2.5 percent absorption whereas ingestion results in only .5 to 6 percent absorption. EP A
has detennined that human exposure to cadmium occurs primarily from dietary intake with much
less exposure via drinking water and ambient air inhalation.
Cumulative exposure to cadmium is of great concern since body burdens of cadmium are
known to increase steadily from birth. Once absorbed into the body, cadmium depuration is
slow. Cadmium's half-life in the body is approximately 18 to 38 years.
Chromium
Several epidemiological studies have indicated that hexavalent chromium is carcinogenic
in the lung. The cancer risk is associated largely with soluble hexavalent chromium compounds.
Trivalent chromium compounds are considered much less toxic than hexavalent compounds, and
have not been associated with carcinogenic effects. Hexavalent chromium is severely irritating
and causes chronic ulceration of the skin and nasal septum, at occupational exposure levels. At
low levels of exposure to the public, however, the greatest concern is the potential cancer risk.
EP A has judged hexavalent chromium to be carcinogenic in humans by inhalation, based on
epidemiological studies of lung cancer in chromate workers. It is unlikely, however, that
hexavalent chromium is carcinogenic by ingestion.
-------
Lead
."
Human exposure to lead results in adverse impacts to the kidney, nervous system' and
hematopoietic system. Accumulation takes place primarily in bones and other hard tissues and
to a lesser degree in soft tissue and blood. Ingestion is the primary route of exposure to lead.
Absorption efficiency depends on a number of factors, among the most imponant of which is :
calcium and iron deficiency. Lead is more readily absorbed if these minerals are deficient in the '
diet.
The primary human health concern with low-level lead exposure is neuro-behavioral
effects from exposure in utero and in childhood; the fetus and young children represent the most
sensitive populations for lead exposure. Exposures to low levels of lead by children and pregnant
women reponedly have resulted in measurable reductions in standardized tests of cognitive
ability, reduced birth weight and premature births. Existing standards for lead exposure, such
as the National Ambient Air Quality Standard (1.5 mg/m3) and the Safe Drinking Water Act
Maximum Contaminant Level (50 mg/L) are intended to maintain blood-lead levels below 30
mg/dl, which has been historically considered a no-adverse-effects-level (NOAEL) for lead. Data
developed by the Centers for Disease Control (CDC) in 1985 have indicated that enzymatic
changes in red blood cells and cognitive deficits may be associated with blood-lead levels of 25
ug/dl. In a 1988 repon to Congress, A TSDR has reponed adverse health effects associated with
blood-lead levels as low as 10-15 ug/dl. The target blood-lead level used in developing clean-up
goals for this site was 12.5 ug/dl. The proposed Maximum Contaminant Level Goal (MCLG)
is 5 ug/L in water, reflecting recent concerns about no-effect levels for lead exposure.
Various factors affect the aquatic toxicity of lead including: hardness of water, oxygen
content, pH and interaction with other metals. Under high pH conditions, toxicity is generally
greater since more lead is available in the dissolved state.
Molybdenum
A complex relationship exists between molybdenum and copper in the nutrition of
livestock. Molybdenum is toxic in cattle and sheep in diets deficient in copper, whereas diets
high in copper, and low in molybdenum can potentially result in copper toxicity. Molybdenum
toxicity can be expected in cattle when the ratio of copper to molybdenum in the diet drops
below 2: 1. The effects include emaciation, diarrhea, anemia, and poor weight gain. Prolonged
exposure may resuJt in osteoporosis and bone fractures. When copper levels in feed or forages
are in the normal range of 8 to 11 ppm, cattle can be poisoned by molybdenum concentrations
of 5 to 6 ppm and sheep poisoned at concentrations above 10 to 12 ppm. When dietary copper
falls below 8 ppm, molybdenum concentrations of 1 to 2 ppm may be toxic to cattle. Increasing
dietary copper even 5 ppm above normal will protect cattle against 150 ppm dietary
molybdenum. Nonruminants such as pigs are much more tolerant to molybdenum exposure than
ruminants.
-------
Contaminant Migration Pathways
Air Pathway
.
Wind-blown dust has been observed emanating from the site during high wind episodes.
Two techniques have historically been applied to mitigate the potential for wind-blown dust: :
slurrying of thewaste CKD during disposal, and more recently the periodic application of dust
suppressant (Arnsco-Res 661). Wind-blown dust from the site has seasonally been inhibited by
the moist conditions and natural crusting propenies of the waste CKD. Application of the dust
suppressant enforces the formation of a crust which both enables the material below the crust to
retain moisture and increases the threshold to wind erosion.
In order to investigate the surface chemistry of waste CKD, the samples collected to
detennine the dry aggregate structure were also subjected to additional chemical analyses. The
chemical analysis was performed on both the entire aggregate sample and on the mass fraction
passing the finest sieve (53 J.U11).
The concentrations of chemical constituents contained in the size fraction .less than 53 J.U11
of the surface waste CKD are contrasted to the mean of analyses derived from core samples
(Table 5-4). Lead, molybdenum, and arsenic were found to be substantially lower in the surface
materials than in the core samples. In addition, the pH of the surface samples ranged from 9.9
to 10.1 as compared with a mean value of 12.1 observed in the core samples.
The moisture content of the top 10 cm of the waste CKD dries to the wilting point during
May and generally does not begin to be replenished until sometime in December. This period
of the year has historically corresponded to periods when wind-blown dust has been visually
observed emanating from the site during high wind events. During the five-month December to
April period, the materials onsite are expected to be saturated. This period also corresponds to
the period when snow cover would reduce emissions.
Surface and upper air observations were obtained from Salt Lake City Airpon during the
six year period from 1981 through 1986. Wind roses were constructed for the years 1981 to
1986. The wind regimes for these years all exhibit Strong bi-modal patterns with prevailing
winds usually being from the south-southeast or from the north-northwest.
The spatial patterns of wind-blown dust concentrations from the site, where it was
assumed that no dust suppressant was used to control dust emissions, were examined by
constructing contour plots of computer model predictions. The spatial distribution of the model
predictions closely follows the alignment of the prevailing winds. Predicted paniculate levels
generally fall off rapidly in the east-west direction due to the relative infrequent occurrence of
wind speeds above the threshold for wind erosion.
-------
N
to-
Constituent
Aluminum
, Arsenic
Barium
Cadmiwn
Chromium
Chromiwn VI
Iron
Lead
Manganese
Mercury
Molybdenum
Zinc
pH (units)
Total Solids (%)
NOTES:
Exposed
'Composite
12900
12
340
13
40
0.9
I 0400
560
160
<.05
<20
290
9.9
,99.2
TABLE 5-4
. . .. . . . .
'.' .'". " ..",
RESULTS OF W ASTECKD CHEMICAL ANALYSES ',.
SITE 2
Surface Fraction
<20
350
...,10.1 ',.,
98~9 '.
. . ,"..'., '., ,',",.. ",".',
',' SITE 3
.Surl8ce Fraction
, , ' <53 urn ',' ,
, 13300,
" 6.5
780,. '
,7
50.
,1.3
, 10300.. '
, '450
200' ,
<.05 "
<20
350
... ",
. ,-,...
..,
,WEST SITE ".
.,.,..Surface "
.,' ComPOSite ".
, ,9300 ,. ..
, ' 5.1"
660 '
,4
,,39,",',
, ' 0.4
., 17500 '
610
240 .'
'.<.05
, ,40' ,.
',.930
>99
"~:4\
..,
" '
.. ,
.. .,,"
. .. .
,'.Surfa~Ffacii~':" ,..Core
<53 om " ..', " ',.'. S8Jt1Dles
, . 13700 .,." .', ,.'.16419 '
..," .7.8. "., 33.6
.' 1600, 424 '
)<1 '.. '.,9.3 "
;l9 '..,. .' 35.1
" '..' 'lJ)" ,".' ",' 2.7
" 13500 '.':.13668 '
590 ..'.. 815
260.< ",244 .
" :': 0.01 ' <.05
",14\ ' .' , ,72 '
/ 620> .' S1:1 .
.. ,_.
'.::~.,::
,,12.2
".,100 '
.:::-:',:;'
.. ,
.." .
. ...
,". .
. ...
, '
, ..
, '
..
." "."
. ...
..'
" ,
..
-------
Concentrations below EPA's significant impacts levels (SILs) are considered by the EPA
to he insignificant durinF the regulatory permitting process. The 24-hour Sn.. suggested for the
10 micron size fraction (PM\o) is S Ug/m3. An equivalent 24-hour total suspended' particulate
(TSP) level is 12.S ug/m3 using the airborne particle disttibution assumed for estimation of the
TSP emissions. The region potentially exceeding the 24-hour SIL extended approximately 3.5
kIn nonh of Site 3.
In general, predictions for the mitigated case in which dust suppressants were assumed
to be used exhibited the same spatial patterns but were approximately 21 percent lower than those
assuming no funher application of dust suppressant on-site. The 24-hour SIL's were only
exceeded at the site boundaries.
Suiface Water Drainage from the Site
An analysis was perfonned to predict sheet and rill erosion which might result from a
single Stonn event. The objective was to estimate the maximum volume of waste CKD which
might migrate off-site due to a peak precipitation stonn event.
Simplification of the site topography for the model assumed that all waste CKD mobilized
by sheet and rill erosion would discharge off-site. Actual runoff and erosion, however, would
be intercepted and retained by local surface topography at each site so that a large ponion of the
sediment yield would not reach the City Drain or Nonh Boundary Ditch. Site 2 and Site 3 were
predicted to yield 1 and 13 tons of material, respectively, due to a 100 year 24-hour stonn, while
the West Site was predicted to yield 1.4 tons of surface materials (waste CKD and soil) during
the same event.
Migration to Ground Water
Soil-waste interaction tests were perfonned on three types of soils, (silty sand, clay, sandy
silty clay), found in the shallow aquifer to evaluate the ability of these soils to attenuate
constituents found in the ground water through buffering pH and sorption of metals. Results of
the soil attenuation tests, indicate that dissolved solids, pH, and arsenic concentrations are only
slightly attenuated by the silty sand and clay soils. The sandy silty clay, however, showed good
attenuation of arsenic and pH. Chromium and molybdenum were not attenuated by soils within
the constraints of these testS.
-------
6.
SUMMARY OF SITE RISKS
This chapter present a summary of the human health and environmental risks presented
by the site. The quantified and qualified risks, and background infonnation are presented in
greater detail in the RIlFS and Appendix A to this ROD.
Risks to Human Health
Risk Assessment Objectives
Risk assessment activities related to the site were designed to estimate potential risks to
human health under the "No Action" alternative. In accordance with EPA guidance, risk
assessment activities were divided into four parts. First, chemicals of potential concern where
identified on and near the site. Second, toxicity of these chemicals was evaluated and critical
toxicity values identified. Critical toxicity values include reference doses and slope factors used
to relate daily intake to potential adverse effects. Third, potential human exposure to chemicals
of concern was quantitated using data obtained from site characterization activities. Finally, risk
was characterized by comparing potential human exposures with critical toxicity values.
Carcinogenic risk was evaluated separately from risk of non-carcinogenic effects, since current
knowledge suggests that cancer induction may occur via non-threshold mechanisms.
Hazard Identification
. Several chemicals of potential concern for human health were identified in ground water,
surface water and waste CKD at the site. These include arsenic, cadmium, chromium, lead, and
molybdenum. In addition, the caustic nature (high pH) of the waste CKD was identified as a
potential threat.
Toxicity Assessment
Inhalation route
Three chemicals of concern were identified as potential human carcinogens following
exposure via inhalation. Both arsenic and chromium(VI) are class A (known human)
carcinogens, while cadmium is a class B 1 (probable human) carcinogen. For these three
chemicals, excessive inhalation exposure could result in an increase in lung, and possibly other
types, of cancer. Critical toxicity values (slope factors) are available for all three chemicals.
These slope factors provide a means of relating daily dose to cancer incidence. In addition to
the heavy metals present, the fme particulate nature of the waste CKD may allow it to be easily
entrained and transponed off-site, causing respitory irritation.
-------
Imz:estion route
Arsenic is also a class A carcinogen when ingested. Excessive exposure via ingestion
could result in an increased incidence of skin cancer, and perhaps of some internal cancers. A
slope factor is available for ingested arsenic.
All of the chemicals of concern may produce adverse non-carcinogenic effects either by
inhalation or ingestion. However, critical toxicity values (reference doses) are generally available
only for the ingestion pathway. Thus, quantitative assessment of non-carcinogenic risk was done
only for the ingestion pathway. (Reference doses are an estimate of a daily intake of a chemical
which will not result in adverse effects even over a lifetime of exposure.)
Dennal route
The caustic propenies of the waste CKD may cause adverse effects following direct
contact with skin, eyes or mucous membranes. Excessive acute exposure could lead to bums of
the exposed tissues. Subchronic or chronic exposure could lead to dennatitis or chronic
eczematous skin conditions. There currently are no critical toxicity values available to use in
quantifying these risks.
None of the chemicals of concern (arsenic, cadmium, chromium, lead and molybdenum)
are expected to cause adverse systemic effects following dermal exposure. In general, the skin
is an effective barrier to absorption of metals and prevents toxic quantities of these agents from
entering the body following the types of exposure expected at hazardous waste sites.
Exposure Assessment
In order for human exposure to occur, there must be, 1) a source of contaminant, 2) a
means for this contaminant to move into environmental media (air, water, soil, vegetables, etc.),
3) a point of exposure where humans can come into contact with the contaminant and, 4) a route
of exposure (inhalation, ingestion, dennal contact) through which the contaminant can enter the
body. These four elements describe an exposure pathway and, whenever all four elements are
present, or can reasonably be assumed to be present in the future, the pathway is complete and
exposure will occur. For the Portland Cement Co. Superfund site, several complete or potentially
complete exposure pathways were identified and evaluated.
Incidental ingestion of waste CKD by site trespassers
Incidental ingestion of waste CKD by workers (current and future)
Direct dennal contact with waste CKD by workers and trespassers
Inhalation of fugitive dust from waste CKD by workers or nearby residentS
-------
Ingestion of vegetables contaminated by airborne waste CKD
Ingestion of fIsh, meat and dairy products from animals which feed upon plant
material contaminated by airborne waste CKD.
To estimate the amount of each chemical taken into the body, standard EPA exposure
parameters and equations were used ( See Apeendix Table A-2). Concentrations of chemicals
of concern in soil and water were taken directly from analyses of samples collected at the site.
Concentrations of chemicals in air and amounts deposited on plants and vegetables were
estimated by modeling (Appendix pp. 10-13). The results of the exposure assessment are
provided as chronic daily intakes in Appendix A, Table A4 and A5 and are expressed as mg of
chemical intake per kilogram body weight per day.
.
Although ground water directly under the site is affected by the waste CKD (pH levels
as high as 12.2 have been detected) this exposure pathway will be addressed in subsequent
decision documents. The removal of the waste CKD will facilitate easier evaluation of these risk.
Risk Characterization
In accordance with EP A guidance, carcinogenic risks were estimated by multiplying the
slope factor for the chemical by the chronic daily intake. The resulting number is an estimate
of the probability of getting cancer as a result of exposure to the chemical. Carcinogenic risks
for the various exposure pathways are summarized in Appeindix A, Table A7 and A9.
Non-carcinogenic risks were evaluated by taking the ratio of the chronic daily intake and
the reference dose for the chemical. Since the reference dose is thought to represent an exposure
which can be borne for a lifetime without adverse effect, a ratio less than one suggests that no
adverse effects are likely (i.e. the chronic daily intake is less that the reference dose). A ratio
greater than one suggest the potential for adverse effects. Risks for non-carcinogenic effects are
summarized in Apendix A, Tables AS, and AIO - A12.
Air modeling indicated that EP A's 24-hour significant impact levels for air exposure to
paniculates was exceeded in an area extending approximately 3.5 kilometers nonh of the site
under the "No Action" scenario. Waste CKD panicles which deposit in the lungs would also
fonn an irritating high pH solution which could cause, in case of high exposure, burns in the
tissues lining the respiratory tract. Such exposures could also excacerbate chronic lung diseases
such as emphysema, asthma, and chronic bronchitis.
A major ponion of the risks on and near the site is the acute risk associated with the
caustic characteristic of the material. Caustic agents cause a range of effects from mild irritation
to severe bums in biologic tissue depending on a number of factors, including length of contact.
pH, type of tissue, individual sensitivity, etc. No guidance exiSts within the EPA risk
assessment community which would allow quantitation of this type of health effect.
-------
However, the risks due to caustic propenies of waste CKD are significant. Contact of
waste CKD with mucous membranes would produce a solution with a pH as high as 12 or 13.
Similar high pH solutions could be produced on the skin when waste CKD particles"encounter
sweat. Such solutions would be, at best, extremely initating to eyes and other moist tissues.
More severe effects such as bums or scarring cannot be ruled out. Children playing on waste
CKD, as well as workers on site, would be at risk for these acute effectS. There is also the
potential for chronic skin conditions resulting from frequent dermal exposure.
.
Uncertainties
As in all risk assessments, there are uncenainties in the risk estimates. Four areas of
uncenainty are particularly imponant in evaluating the risk at the Portland Cement Co. Superfund
site.
First, the assessment was not able to quantify risk of bums due to direct dermal contact
with waste CKD. Since there was a repon of skin rashes as a result of exposure on-site, the risk
appears to be significant. This risk is not reflected in the risk tables.
Secondly, there are approximately 360 tons of chromium bricks on site which were not
evaluated in the assessment. Thus, exposure to chromium, especially potential future exposure,
may be greatly underestimated.
. Third, no residential scenario was used in assessing risk at the site. H the assumption that
residential development will never occur on site is incorrect, risks may be substantially
underestimated.
Finally, exposure via the air pathway was based on an empirical model, rather than on
actual data. Depending upon specific conditions at the site, there may be considerable over- or
underestimation of risk due to reliance on such modeling data.
Em'ironmental Risks
Envirorunental risks are often difficult to quantify and no attempt was made at such
quantitation in the risk assessment. However, several issues were addressed qualitatively and are
summarized below.
First, the waste CKD has altered the vegetation severely on-site and the ttanspon of waste
CKD off-site has the potential to adversely impact vegetation in neighboring areas. Most of the
impact on vegetation may be due to the high pH.
Secondly, ponded water on the waste CKD may cause bums to terrestrial wildlife,
including numerous avian species which might use nearby Surplus Canal as a nesting and feeding
area.
-------
I
Thirdly, the molybdenum present in the waste CKD has the potential for causing adverse
eff~cts to any livestock which may be in the inunediate area.
Finally, fIsh in the Jordan Rivei' and Surplus Canal could be adversely effected by caustic
run-off from the waste CKD. Such effects were not evident during site characterization work.
-------
7.
DESCRIPTION OF ALTERNATIVES
INTRODUCTION
.
The purpose of this section is to describe alternatives that are technically implement able
at the site. The numbering system for the alternatives is the one used in the Feasibility Study.
Alternatives that did not pass initial screening on the basis of effectiveness, implement ability , and
cost are not described in this ROD. During the process of the development of alternatives, eight
separate options applicable to Sites 2 and 3 and the West Site, and 2 options applicable only to
the West Site were retained for detailed analysis. The State of Utah has decided to consider the
waste CKD as one operable unit, and has therefore condensed the list of alternatives
correspondingly. Eight of the alternatives identified for the West Site were conceptually
equivalent to the eight alternatives for Sites 2 and 3. However, Alternatives 3 and 4 applied only
to the West Site, and consequently do not satisfy the threshold criterion for selection of a remedy.
Therefore, alternatives 3 and 4 are not evaluated in this ROD.
Since the Revised Proposed Plan was issued, the RCRA rule, "Land Disposal Restrictions
for the Third Third Scheduled Wastes" was promulgated. Land disposal of chromium hazardous
waste above the specified treatment level is prohibited. Thus, this rule requires the treatment of
the chromium bricks prior to land disposal. Except for the "No Action" Alternative, the
alternatives described in the Revised Proposed Plan required the separation and disposal of the
bricks at a RCRA Subtitle C faciltiy. However, due to the addition of treatment, the bricks will
be separated and temporarily stored at an acceptable location under this operable unit. Treatment
and disposal of the chromium bricks will be addressed in the next operable unit.
The narratives included in the chapter have been changed to reflect the operable unit
approach for the chromium brick treatment and disposal. The specific cost listed in each
alternative were not changed. The cost for the trasportation and disposal of the bricks identifed
in the Rl/FS is approximately $60,800. The actual reduction in the cost for each alternative
(except the "No Action" Alternative) under this operable unit will be some what less than this
amount due to the cost of on-site chromium brick storage.
Additionally, all alternatives require the monitoring of ground water at the site. Ground
water monitoring is necessary to characterize the extent of the ground water contamination.
ARARs
For all response actions, the Applicable, Relevant and Appropriate Requirements (ARARs)
of primary importance are those relating to I) State solid waste disposal regulations (Utah Title
26, Chapter 14), if applicable; 2) State hazardous waste storage and disposal regulations
pertaining to RCRA Subtitle C facilities for the storage and disposal of chromium-bearing
refractory kiln brick; 3) Federal (40 CFR Part 268) RCRA regulations pertaining to land disposal
-------
restrictions; and 4) Federal (40 CFR Part 50) and State (Utah Title 26, Chapter 13) air regulations
on total suspended particulates (TSP) and nrgitive dust control. Table 7-1 summarizes all the
ARARs identified for the site. .
NO ACTION ALTERNATIVE
.
tJternative 1 (C.f(D/l) - No Action
Description
Under the "No Action" Alternative the waste CKD would remain on the site as it is now.
The results of the baseline risk assessment apply to the "No Action" alternative. The "No
Action" Alternative does not result in any reduction of site risks. The chromium-bearing
refractory kiln brick (which are a hazardous waste) remain on the site. H the current application
of the dust suppressant were halted, fugitive dust emissions would increase over time from
current levels to the level that existed before dust suppressant was used.
No environmental monitoring is proposed in conjunction with this alternative and no costs
are associated with this alternative.
Institutional controls could be implemented as a limited action supplement to the "No
Action" Alternative. Deed restrictions that would be imposed to limit future site development
are likely to prevent disturbance of the waste CKD and an increase in fugitive dust. Well
restrictions are likely to prevent the construction and use of near-surface wells on and adjacent
to the site. The range of future site uses under this alternative would be limited by the need to
provide protection against public health threats at the site.
Compliance with ARARs
The "No Action" Alternative would not meet the ARARs identified in this ROD chapter.
CONT AINMENT ALTERNATIVES
Alternative 5 (CKD/5) - Consolidation of Waste CKD on the West Site
Description
All identifiable waste CKD would be excavated from the West Site and temporarily stored
on Site 2. Excavated areas within the West Site would be backfilled using banknm fill. Rough
site grading would be performed over the approximately 24 acres affected at the West Site.
-------
.
TAB
-1
APPUCABlE OR RELEVANT AND APPROPRIATE REQUIREMENTS-
STANDARD, REQUIREMENT
CRITERIA, OR LIMITATION
CIT A TION
DESCRIPTION
APPLICABLE!
RElEV ANT AND
APPROPRIATE
SOUD WASTE DISPOSAL ACT
GuideHnes for the Land Disposal of Solid Waste
SAFE DRINKING WATER ACT
National Primary Drinking Water Standards
National Secondary Drinking Water Standards
RESOURCE CONSERVATION AND RECOVERY
ACT
Standards for Owners and Operators of
Hazardous Waste Treatment. Storage, and
Disposal Facilities
Standards Applicable to Transporters of
Hazardous Waste
Land DIspOsal Restrictions
<42 use U 6901~987
<40 CFR Part 2<41
<40 USC . 300
<40 CFR Part 1<41
<40 CFR Part 1<43
42 USC 6907(a)(3), 69<44(a) and
6949(a)
<40 CFR Part 26<4
<40 CFR Part 263
40 CFR Part 268
Minimum ,...els of performance required of any solid waste land disposal site
op8I'ation. Excludes hazardous and mining wastes.
Requirments apply to any surface water contamination which could occur during
remediation.
Healt~based standards for plblic water systems (maximum contaminant levels).
Welfare-based standards for public water systems (secondary maximum
contaminant levies). Contaminants that primarily affect aesthetic qualities of public
drinking water.
Minimum national standards which define the acceptable manag~ of
hazardous waste lor owners and operators of facilities which treat, store, or
dispose of hazardous waste (excluded are owners of treatment facilities,
elementary neutralization units, or wastewater treatment units). Manifest system,
record keeping and reporting (Subpart E), Releases from Solid Waste Management
Units (Slbpart F). Closure and postclosuoe (Slbpart G), Use and Management of
containers (Slbpart I), Tanks (Subpart J), Waste Piles (Slbpart L), Landfills
(Subpart N).
Standards established by EPAlOOT for transporters of hazardous materials withit
the U.S. per the manifest requirements.
Restrictions identilied by EPA for land disposal of hazardous wastes; Includes
prohibitions, drcumstances, and standards under which land disposal of prohibited
wastes is aDowed under the law.
30
Yes!
Nes
Nes
Yes!(bricks)
(CKD)lYes
Yes!(bricks)
-------
TABLE 7-1 (CONllNUED)
STANDARD, REQUIREMENT
CRITERIA, OR LIMITATION
CIT A TION
DESCRIPTION
APPLICABLEJ
RELEV ANT AND
APPROPRIATE
CLEAN AIR ACT
National Primary and Secondary Ambient Air
Quality Standards
National Emission Standards tor Hazardous
Pollutants
OCCUPA TIONAL SAFETY AND HEALTH ACT
CLEAN WATER ACT
National Po.utant Discharge Elimination System
Water Quality Criteria
EXECUTIVE ORDER ON PROTECTION OF
WETLANDS
DREDGE AND FILL REQUIREMENTS (t 404)
42 USC U 7401-7642
40 CFR Part 50
40 CFR Part 61
29 usc ff 651-678
29 CFR Parts 1910 and 1926
33 USC ff 1251-1376
40 CFR Parts 122-125
40 CFR Part 131 Quality Criteria
tor Water 1976, 1980, and 1986
executive Order No. 11,990 40
CFR Part 6.302(a) and
Appendix A
40 CFR Parts 230, 231; 33 CFR
Part 323
Standards for ambient air quality to protect public health and webre (including
standards for particulate matter and lead).
Emission standards for designated hazardous pollutants Including inorganic
Arsenic from any stationary source
Federal standards for safety and health in such Industries as the construction
industry and special provisions for air contaminants, and general requirements tor
personal protective equipment.
Requirements apply to any surface water contamination which could OCCU" during
remediation.
Permits tor the dischlllge of poRutants from any point source into waters of the
U.S. Includes addition of pollutants into surface water which are colleded or
channeled by man-pipes and sewers.
Criteria for water quaHty based on toxicity to aquatic organisms and ptblc heallh.
Requires Federal agencies to avoid, to the extent possible, the adverse Impacts
associated with the destruction or loss of wetlands and to avoid support of new
construction in wetlands it a practicable alternative exists.
Requires pennits for discharge of dredged or fill materials Into navigable waters or
wetlands.
Yes!
Yesl
Yes!
Yesl
rYes
YesIY es
-------
.
TABLE 7-1 ~
NtlNUED)
STANDARD, REQUIREMENT
CRITERIA, OR LIMITATION
CITATION
DESCRIPTION
APPLICABLE!
RElEV ANT AND
APPROPRIATE
DOT HAZARDOUS MATERIAL
TRANSPORTATION REGULA TlONS
ARCHEOLOGICAL AND HISTORIC
PRESERVATlON ACT
NATlONAL HISTORIC PRESERVATlON ACT
ENDANGERED SPECIES ACT
FISH AND WlLDUFE CooRDINATlON ACT
UTAH SOLID AND HAZARDOUS WASTE ACT
Utah State Department of Health Code of Solid
Waste. Disposal Regulations (Amended by
Sene. Bil 255 (1990)).
Hazardous Waste Rules.
Solid Waste Rules
49 CFR Parts 107, 171-177
16 USC g 470
40 CFR Part 6.301(b)
16 USC U 470
40 CFR Part 6.301 (b)
36 CFR Part 800
16 USC U 1531-1543
50 CFR Parts 17 and 402
40 CFR Part 6.302(h)
16 USC U 661~
40 CFR Part 6.302(g)
Utah Code Annotated; TItle 26,
Chapter 14
R450 UAC
R450-301 UAC
Procedures for transporting hazardous materials (labeling, maltUng, placarding, use
of co,..ainers. and reporting requirem&r-.s).
Procedures to provide for preservation of historical and archaeological data which
migh1 be destroyed hough alteration of terrain as a resull 01 . Federal
construction project or a Federally licensed activity or program.
Requires Federal agencies to take into account the effect of any Federally assisted
undertaking or licensing on any district, site, building, structure, or object that ..
Induded in Of eligible for Register of Historic Places.
Requires Federal agencies to inswe that any action authorized, funded, or carried
out by the agency will not jeoparcize the continued existence of any threatened or
endangered species or destroy or adversely modify critical habitat.
Requires consula11on with the Fish and Wildlife Service when anY Federal
department or agency proposes or authorizes any modification or control of any
stream or other water body and requires adequate provlslon(s) tor protection of fish
and wild&fe resources.
Minimum requirements for disposal of sand wastes in Utah. (Defines hazardous
was1es as materials considered to be excessively toxic or poisonous, corrosive,
irritating, or sensitizing...) Excluded solid waste cisposal facilities required to
oompty wi1h State or Federal hazardous was18 management regulations.
Very similar to Federal Sond Waste Disposal Act Regulations. Closure and post
dosure (S~rt 8-7), Waste piles (Subpart 8-12), Landfills (Sl,j,part 8-14),
Groundwater protection (Subpart 8-6), Containers and Tanks (Sl,j,part 8-& 8-10).
Requires s~mittal of plans for solid waste facility.
32
Yes
YMI
YMI
YMI
YMI
Yes
Yes
-------
TABLE 7-1 (CONllNUED)
STANDARD, REQUIREMENT
CRITERIA, OR LIMIT A TION
CIT A TION
DESCRIPTION
APPLICABLEI
RELEV ANT AND
APPROPRIATE
UTAH CLEAN AIR ACT
Primary and Secondary Air Quality Standards
FugitIve Dust Emissions
U.. of Best AvaHable Control Technology
UTAH CORRECTIVE ACTION CLEANUP
STANDARDS POUCY (Applicable 10 RCRA, UST,
and CERCLA SlIes)
UTAH SAFE DRINKING WATER ACT
Utah Public Water Supply Regulation.
Water Quality Department of PI.bIic Health
UTAH ANTIQUITIES ACT
ANTI.DEGRADATION
QUAUTY)
POLICY (WATER
Utah Code Annotated, 11118 26,
Chapter 13
State 1"1>lementatlon Plans and
Air Conservation Regulations,
Utah Administrative Code R446-
1
State 1"1>lementatlon Plans and
Air Conservation Regulations,
Administrative Code R446-1-4.5
Utah Administrative Code R446-
1-3.1.8
Utah Administrative Code R450-
101,101-1,101-3,101-4.
Utah Code Annotated, Title 26,
Chapter 12
Utah AdministtatiYe Code R449-
103 et seq.
Utah Code Annotated, TIle 63,
Chapter 18 8t seq.
Utah Administrative Code R224-
1 et seq.
Utah Administrative Code R448-
2-3
Standards for public health and welfare.
TSP control at construction sites.
U.. of BACT for any !OlM'ce of emissions.
Rules establishing policies 01 the Solid and Hazatdous Waste Committee.
Minimwn standards for cleanup are Melt, standards under Clean Ail Ad, and
other standards as determined applicable. Cleanup standards evaluation criteria
Include nunerical, technology~ased, or risk~ased standards or a combination.
Requirements apply to any sUltace water contamination which could OCCIM' during
remediation.
Primary and secondary standards for al public drinking wa.. systems.
Cultural resources requirements for areas 01 potential surface clsturbance.
Policy to protect and maintain quality of water. No Water Quality degradation Is
allowed unless in-streem waler uses are protected. Requirements apply to any
surface water contamination which could OCCU' during remediation.
Yes
Yes (Slale
Requirements more
slringent than
Federal Program)
Yeti
Yes
!Yes
!Yes
(Faderll
Requirements I,.
~ Stringent)
-------
.
TABLE 7-1 ~
ffiNUED)
STANDARD, REQUIREMENT
CRITERIA, OR LIMITATION
CIT A TION
Requirements apply to any surface water contamination which could OOCU' during
remediation.
UTAH WATER POLLUTION CONTROL ACT
Utah Code Annotated, Title 26.
Chapter 11 et seq.
Wast_at.r Disposal Regulations Standards 01
QuaHty for waters 01 the State
Utah Administrative Code R448-
2 et seq.
UPDES Permit and Regulations
Utah Administrative Code R448-
8 et seq.
Ground-Water Quality Protection Regulations
Utah Administrative Code R448-
6 et seq.
DESCRIPTION
APPLICABLEJ
RELEV ANT AND
APPROPRIATE
Classification and uses of State's waters.
Yes!
Any Discharge into surface waters of State requires permit. Requirements apply
to any surface water contamination which may occu' during remediation.
YesJ
(Admlnbters FedenII
Program)
Ground-water quality standards (Mels). Ground-water classification system based
on existing ground-water quality, Ground-water class protection levels. Ground-
water aquifer classification. Ground-water discharge permit program excludes
RCRA and CERCLA sites where ground-water remediation program exists. May
apply if trucks are washed down on the site,
/Yes
. NoCe: These stmstantive and procedural requirements also apply at locations other than the designated superfund site. Some requirements not listed in this table will apply for an oft-site remedy.
-------
TABLE 7-1 (CONTINUED)
APPUCABLE OR RELEVANT AND APPROPRIATE CHEMICAL-SPECIRC REQUIREMENTS
RESOURCE
ST ANDARD/CRITERIA
AIr Ouality
Ambient Air Quality Standards
Primary
Secondary
Primary
Secondary
SUBSTANCE
STATE
FEDERAL
1.5 ug'm'.
1.5 ug'm'.
75 '9'mn
260 ug'm'.
60 ugtmh
150 ug'mh
. Calendar quarter Of arithmetic average.
,. Annual geometric mean.
. Maximum 24-hour concentration not to be exceeded mOfe than once per year.
Lead (Pb)
Lead (Pb)
Particulate Maner
Particulate Maner
Particulate Maner
Particulate Matter
1.5 ug'm'.
1.5 ug'mh
75 ugtmn
260 ug'm'.
60 '9'mh
150 ug'mh
-------
West Site waste CKD temporarily stored at Site 2, and waste CKD and codisposed
nonhazardous materials loc~ted on Sites 2 and 3, would be excavated using a loader or dragline
and transponed by truck or scraper to the West Site. These materials would be placed on top
of the backft1led and graded West Site area, compacted and capped with a layered system and
revegetated. Lone Star Industries reponed that the West Site was selected for consolidation of
waste CKD because it has a slightly higher elevation than Sites 2 and 3.
After addressing any contamination of residual soils, excavated areas within Sites 2 and
3 would be restored to pre-filled contours through the placement of bankrun fill materials.
Chrome bricks would be separated during excavation, and temporarily stored. Estimated material
quantities required for this alternative are presented in Table 7-2.
. TABLE 7..2 .. . . .
. .
.. SUMMARY OF ESTIMATED QUANTITIES FOR ALTERNATIVE 5
.... . . ... " ~ . . .
. . .
Excavation and Temporary Storage of Waste CKD..
Placement of Bankrun Backfill at West Site. .
Rough Site Grading. ..
Excavation and Relocation of Wastc CKD
From Site 2
From Site 3
Replacement Fill
Site 2 .
. Site) . .
. ..
6" Site Grading Fill .
6" Low Permeability Soil .
6" Drainage/Capillary Break ...
1218 Bankrun Soil Fill
4" Topsoil
Revegetation
. . ...... .
. . .. ..
.. ..
109 ,000 Cubic Yards
109,000 Cubic Yafds
.23.88 Acres
138.000 Cubic Yards
. 249,000 Cubic Yards.
. . .
.... ."
. .. .. .
..13,300 Cubic Yards
..1S.600Cubic Yards.
...19,264 Cubic Yards .
19,264 Cubic Yards ..
... 19,264 Cubic Yards .
. 38.526 Cubic Yards
12,842 Cubic Yards .
. 23.88 Acres. .
Materials Handling Requirements and Engineering Controls
Waste CKD excavation at Site 3 and the West Site would be performed using
conventional eanhwork equipment. Excavated waste CKD would be loaded into trucks or
scrapers for transponation to and placement at the West Site. Inclement weather could require
the construction of haul roads using a geofabric for suppon. Excavation of the waste CKD at
-------
Site 2 could require ripping prior to excavation because of the cemented nature of the material.
Conv~ntional dust control methods would be -employed to minimize fugitive emissiqrys. Seven
activities that could generate fugitive emissions would be 1) excavation of waste CKD. and
codisposed nonhazardous materials from the site; 2) loading and hauling of wastes from the West
Site to and from the temporary storage area on Site 2; 3) the excavation in the bankrun borrow
stockpile; 4) the application and mixing of bentonite to construct the low permeability layer; 5) .
loading and hauling of Site 2 and 3 waste CKD to the West Site; 6) the placement and spreading'
of site restoration fill at Sites 2 and 3; and 7) consolidation of all waste CKD onto the West Site.
Dust suppressants would be used during excavation and construction activities to minimize
fugitive dust emissions. The relatively high in situ moisture content of the waste CKD would
tend to minimize emissions during excavation and placement. Construction of the layered cap
system would use conventional earthmoving equipment. Fencing and other controls would be
employed to prevent the public from entering the site during remediation.
Operation and Maintenance Requirements
The closure cover would be inspected annually. Routine maintenance including weed
control or partial revegetation would be performed as required.
Off-Site Disposal
Nonhazardous materials screened from the waste CKD would be transported and disposed
at a landfill permitted to receive such materials.
Emmisions Control
Dust supressants would be used during excavation and construction activities to minimize
fugitive dust emissions. Trucks would be covered with tarps during transport of waste materials
to the landfill site.
Institutional Controls Required
Deed restrictions would be imposed to prohibit future site development that could either
damage or disturb the closure cover. Restrictions would be imposed to prohibit the construction
of wells on or adjacent to the site and withdrawal of affected near-surface ground water.
Site-Specific Considerations
The major material movement activities would be the excavation, screening, and double-
handling of 109,000 cubic yards of waste CKD from the West Site, backfilling of the resulting
excavation, and excavation of both stockpiled West Site waste CKD and the 387,000 cubic yards
of waste CKD from Sites 2 and 3 and transport and placement at the West Site. Different
excavation methods would probably be used at Site 2 and Site 3 because of the different fOnTIS
in which the waste CKD was deposited (i.e. dry at Site 3 and slurried at Site 2).
-------
While construction of the landfill cell would limit future development at the West Site
to that which would not damage the cap, complete removal of the waste CKD from ~,ites 2 and
3 and the placement of site restoration fill would return these ponions of the site to a condition
allowing "unrestricted" future development.
Cost and Implementation Time
Since issuing the Initial Proposed Plan it was discovered that the estimated costs for
Alternative 5 presented in the Feasibility Study were incorrect. Those incorrect costs were
substantially lower than the revised costs shown below.
The corrected present value of the total cost of this alternative is estimated at $8.39
million. Capital costs are estimated at $9.14 million. Given assumed process rates, this
alternative could be constructed within three years. Cash flow for capital expenses has been
spread over the estimated tWO year period for the purpose of calculating a present value. Annual
operation and maintenance costs were assumed to be $5,000 for a 30 year period.
Compliance with ARARs
The capping system of this alternative would eliminate fugitive dust emissions from the
site, thereby contributing to site-specific long-term compliance with federal and state air quality
standards for TSP and fugitive dust conttol. The action would be conducted using appropriate
dust conttols to ensure shon-term compliance with these standards.
State solid waste regulations impose cenain requirements on solid waste disposal
operations. Such regulations are applicable or relevant and appropriate to the waste CKD. The
excavation and proposed backfilling of the West Site, prior to waste consolidation and layered
cap construction, would remove, but not completely isolate, all identifiable waste CKD from
potential future contact with site ground water. The proposed cap exceeds current landf111 final
cover requirements as stated in those regulations. Alternative 5 would comply with current State
solid waste regulations if the required distance from the maximum seasonal ground water table
were met. This alternative is expected to comply with all identified ARARs.
Alternative 6 (CKD/6) - Excavation and DisPosal On-Site
Description
Alternative 6 differs from Alternative 5 in the construction of a State approved double-
lined, noncommercial, industrial waste landfill on the West Site for containment of the
consolidated waste CKD. Waste CKD and codisposed, nonhazardous materials from the West
Site would be excavated. Nonhazardous, oversized construction debris would be separated from
waste CKD and other undersized materials. The debris would be transponed to an off-site
landfill for disposal. The undersized material would be temporarily stockpiled along with
-------
excavated waste CKD at Site 2. A double-lined industrial landfill would be constructed on the
West Site. Lone Star Industries reported that-the West Site was selected for construction of the
industrial landfill for the waste CKD because it has a slightly higher elevation that 'Sites 2 ,and
3. Waste CKD and codisposed nonhazardous materials from Sites 2 and 3 would be excavated,
hauled and placed in the landfill along with the stockpiled materials from the West Site. A
layered cover system similar to that described for Alternative 5 would be used for landfill
closure, except that a synthetic membrane would be used in place of the low permeability soil ,:
layer. Lone Star Industries reported that the West Site was selected for the construction of the
landfill because it has a slightly higher elevation than Sites 2 and 3.
The landfill cell would be approximately 25 acres in plan area and lined with a double
synthetic membrane and leak detection system. A layered cover system consisting of a synthetic
membrane would be used. The estimated quantities of materials involved are shown in
Table 7-3.
.
The chromium bricks would be handled in the same manner as described in the beginning
of this chapter.
Materials Handling Requirements and Engineering Controls
The same requirements and controls specified for Altemative 5 are also applicable to this
alternative.
As required, additional six-foot high chain link fence with a three strand barbed wire
crown would be constructed at the landfill perimeter for access control. Warning/no trespassing
signs would be posted along the entire perimeter.
OperaTion and Maintenance Requirements
The closure cover would be inspected annually, and a leak detection system for the new
landfill would be required. Routine maintenance, including weed control or panial revegetation,
would be performed as required.
Off-Site Disposal
Nonhazardous debris screened from the West Site, other than waste CKD, would be
transported and properly disposed at a permitted landfill.
Emissions C onrrol
Dust suppressants would be used during excavation and construction activities to
minimize fugitive dust emissions. Trucks would be covered with tarps during transport of waste
materials to the landfill site.
-------
Institutional Controls Required
Deed restrictions could be imposed to prohibit future site development that could either
damage or disturb the closure cover. . Restrictions would be imposed to prohibit the construction
of wells on or adjacent to the site and withdrawal of affected near-surface ground water.
Site-Specific Considerations
As described for Alternative 5, the major material movement activities for Alternative 6
would be the excavation, screening and double handling of 109,000 cubic yards of waste CKD
from the West Site, the excavation of 387,000 cubic yards of waste CKD from Sites 2 and 3, and
the transpon and placement of these materials on the West Site. Different excavation methods
would be used at Site 2 and Site 3 to address the different forms in which the waste CKD was
deposited (i.e., dry at Site 3 and slurried at Site 2). The West Site materials would be screened
to remove large construction debris that could damage the liner or cover system. No screening
of Site 2 and 3 wastes is proposed.
Cost and Implementation Time
The present value of the total cost of Alternative 6 is estimated to be $11.4 million. The
capital cost was estimated to be $12.5 million, for the estimated three year completion period.
Annual operation and maintenance costs are estimated to be $5,000 over a 30 year period.
Compliance with ARARs
The on-site industrial landfill system of this alternative would eliminate fugitive dust
emissions from the site, thereby contributing to site-specific long-term compliance with federal
and state air quality standards for TSP and fugitive dust control. The action would be conducted
using appropriate dust controls to ensure shon-term compliance with these standards.
The double lined and capped landfill would isolate all identifiable waste CKD from
potential future contact with site ground water. The proposed cap exceeds current landfill final
cover requirements as stated in those regulations. Therefore, Alternative 6 would comply with
State solid waste regulations. This alternative is expected to comply with all the ARARs.
-------
. . . .... TABLE 7.;3.p ..... .. ... ...... .. . .
. SUMMARY OF ESTIMATED QUANTITIES FOR ALTERNATIVE 6 .
: . . .' . . ," .,' .::", :',
. . . ". ", '. .
Excavation, Screening and Temporary Storage ...
. and Relocation of West Site Waste CKD p.
ConstrUCtion of Landfill Cell. P" .. .... ...........
General Excavation and Rough Grading....
Fine Grading. . ....... .....
.60 mi1 Secondary HDPE Liner. .
Leak Detection/Conection System
60 mil Primary HDPE Liner ... .. .
6 inch Protective Soil Cover .
Excavation and Relocation of Waste CKD .
Site 2 . . . .....
Site 3
. Replacement Fill
Site 2
Site 3 . .
Landffil Cover System .
6" Site Grading Fill
60 mil PrimaryHDPE
6" DrainagelCapillary Break: ..
12" Bankrun Soil.Fill
4" Topsoil. .
Revegetation. . . .
Fencing (North and east sides only) .
. . '" .
pl09'OOOCu~i~~ards. .
.. .'"'
.. .
P" . .
... p.p2S.ACres
. . .p2SAcreS .. ... ....
... 1~089.000 Square Feet/:
...1,089,000 Square Feet ...
..1.089.000.Square Feet."
20,200 CubicY ards
. ...
. . .. . ..
. .' . . . '"
.. . .. .' .
. ... . ." . .'
."," .
......138.000 Cubic Yards
249,000 CubicY ards
... . ... . ..-
'" ... . .
." . .
.. . . . .
... . . ", . ...
13,300 CubIc YardS .
. 15.600 Cubic Yards
. . 19,264 Cubic Yards
1,089,000 Square Feet
19,264 Cubic Yards
. 38,S26CubicYards
:12,842 Cubic Yards .
... ......25 Acres:. ...
: 2.700 Linear Feet.
-------
Alternative 7A (C1
-------
.. --.,;
,t-J
\' - - -...
L.
.,
'-"UDr l~T
T1S
T2S
I
\-
,
"
,,,--"" ...
,
.-
--
. ,
..
". ...."'''''''...
,e
,
, :"
\
\ \,
TO GRANTSVLLE .
I"PfI'fIOX""TB.Y I -.ul
\ I~.. \ \.
SCALE IN FEET
o 1000
2000
1000
~~~
FLUX QUARRY LANDFILL
SITE LOCATION
REFERENce-
U.S.G.S. QUADRANGLE ENTITLED
"flUX. UTA~ . 1985.
FIGURE 7-1
-------
"'t..:.,,,',
. . ..TABLE 7-4 ..,< ..H.......'
.SUMMARY OF ESTIMATED QUANTITIES FOR ALTERNATJVE.!~:'"
H .
"... '
',',"',','."
.... ,
Excavation and Rclocation of Waste CKD
. Site 2... . H.. ... .H. ... ....
. Site 3 .
. West Site
.....
. ..,138,000 6.bk'.Y~:.:>:\.>::.
. ..249,000. Cubic.YardS ..:...,.
. 109.000 Cubic Yards":;:..
Replacement Fill
. Site 2 .
Site 3 .
West Site
, , , '
13,300Cubi~yard;. :
... lS.600.Cubic.Yards:':.:.
. 20 165 CUbic YarefS .:
, , , " . ','
Landfill Cover System
6" Site Grading Fill .... .. . . .. .. .
60 mil HDPE or 6" Beritonitelsoillayer
24" Banknm Soil Fill..... . .. .. . ..
6" Annor Rock .
..., ..
" ,,'..' "
...", '..' ..
..
. .. "
. ' "
.. 19.264 CublcYuds
43S.600Square Peet.::. .
32,300 Cubic Yards.:::.
.8.100 Cubic Yards.. .
Off-Site Disposal
Excavated waste CKD and codisposed materials would be disposed off-site in a stat
approved industrial landfill.
Emissions C olltrol
Dust suppressants would be used during excavation and construction activities to
minimize fugitive dust emissions. Trucks would be covered with tarps during transpon of waste
materials to the landfill site.
blstitutional Controls Required
Temporary deed restrictions would be imposed. These restrictions would prohibit site
development that could disturb waste CKD such that fugitive dust emissions would be generated.
resulting in potential health and environmental risks. Restrictions would be imposed to prohibit
the construction of wells on or adjacent to the site and withdrawal of affected near-surface
ground water.
-------
Site-Specific Considerations
-,-
Site 2 contains waste CKD that was placed as a slurry. 'This material has developed
layers of hardened waste CKD. A bulldozer or tracked front loader equipped with a "ripping"
tooth may be required to break up the crusts before the waste CKD can be excavated.
Cost and Implementation Time
The present value of the total cost of Alternative 7 A is estimated to be $10.4 million.
Capital costs were estimated to be $15 million spread over a five year construction period.
Operation and maintenance costs were estimated to be $1,700 annually for a period of 30 years.
Compliance with ARARs
Removal of waste CKD to an off-site landfill would eliminate fugitive dust emissions
from the site, thereby contributing to site-specific long-term compliance with federal and state
air quality standards for TSP and fugitive dust control. The action would be conducted using
appropriate dust controls to ensure short-term compliance with these standards. State solid waste
regulations require disposal in a state-approved site. This ARAR would be met.
This alternative would remove, but not completely isolate, all identifiable waste CKD
from potential future contact with site ground water. The cap proposed for the off-site landfill
exceeds current landfill cover requirements as stated in those regulations. This alternative is
expected to comply with all identified ARARs.
tJtemative 7B (CKD...fl.B) - Excavation and DisPOs~ Off-Site within the Tooele County
Hazardous Waste Exclusion Zone
Description
Alternative 7B differs from Alternatives 7 A and 7C in the location of the new, off-site
industrial landfill to be constructed for the waste CKD. Alternative 7B was not in the August
18, 1989 FS submitted for this site, but was developed with addendum information to the FS
dated March 20, 1990 submitted by Lone Star Industries.
Waste CKD and codisposed nonhazardous materials would be excavated, loaded into
trucks and transported to an off-site, state approved. double-lined. noncommercial. industrial
waste landfUllocated in Tooele County. The landftll would be constructed within the designated
Tooele County Hazardous Industries Zone (MG-H) (See Figure 7-2). Except for chrome brick.
the codisposed material would be transported along with the waste CKD for disposal in the
landfill. Chrome bricks would be separated during excavation and temporarily stored on-site.
After addressing any residual soil contamination. excavated areas would be restored to pre-ftlled
contOurs through the placement of bankrun f111 material.
-------
The landfIll would be constructed on a 30 acre parcel which would have to be identified,
purchased, zoned, and pennined for industrial waste disposal. A specific site location for this
landfill has not been detennined. The landfill cell would be approximately 25 acres jfi' plan area,
surrounded by a 5 acre buffer zone, and lined with a double synthetic membrane and leak
detection system. A layered cover system consisting of a synthetic membrane would be used.
As required, a six-foot high chain link fence with a three-strand barbed wire crown would be
constructed at the landfill penniter for access control. The estimated quantities of materials
involved are shown in Table 7-5.
.
Monitoring Requirements
Visual inspection and ground water monitoring consistent with pennit requirements would
be performed. A leak detection system for the new landfill would also be required.
Off-Site Disposal
Excavated waste CKD and commingled materials would be disposed off-site in a
pennined industrial landfill.
Emissions Control
. Dust suppressants would be used during construction activities to minimize fugitive dust
emissions. Trucks would be covered with taIps during transpon of waste materials to the landfill
site.
-------
~
~ i'4 0
\
~i'18
J.....
~
I. i ~ . :..
",
". #'
"
I
I
- I
\
\-
\
Kooiis
-,
I
I
I
I
I
I
I .,
r,
-------------~--
(~
~
f!)
c;-)
4i'65
~O\
() '- '"
() ;:>., I
" .J r
...-, /~
I~ )
I -.. -'')
,. -,
~ d1,
In - "'./\1
,
POTENT1Al
100ELE COUNTY
WASTE DISPOSAL SITE
.. t
. I
8CMJI N-
.
I
i)
~
_1IIoU'~-~
or ~ .~ - IIIoU'I!Jf1'TT\J!!I)
"TO(J8~ I1UIH' . .eA. ~ ...,.,
-------
. TABLE7~ ... ...
SUMMARY OF ESTIMATED QUANTITIES FOR ALTERNATIVE 78
.
.. Construction of Landfill Cell. .
General Excavation and Rough Grading.
Fine Grading. .... . . .
. .60 mil Secondary HDPE Liner
Leak Detection/Collection System
60 mil Primary HDPE Liner
. . . .6 inch Protective Soil Cover
Excavation and Relocation of Waste CKD
Site 2 . .
Site 3 .
West Site
Replacement Fill
Site 2
Site 3
Landfill Cover System
6" Site Grading Fill
60 mil Primary HDPE Liner
6" Drainage/Capillary Break
12" Bankrun Soil Fill
4" Topsoil
Revegetation
Fencing
. ........ ...
. ... ..
. 25 Acres
. . 2S Acres. . ..
. 1,089,000 Square Feet .
1,089,000 Square Feet
1,089.000 Square .Feet.
20,200 CubicY ards
138,000 Cubic. Yards
249,000 Cubic Yards
. 109,000 Cubic Yards
13 ,300 Cubic Yards
15,600 Cubic Yards
19,264 CubiC Yards.
. 1,089,000 Square Feet
19,264 Cubic Yards
38,526 Cubic Yards
12,842 CubiC Yards.
25 Acres ....
4,600 Linear Feet ..
Institutional Controls Required
Temporary deed restrictions would be imposed. These restrictions would prohibit site
development that could disturb waste CKD such that fuigitive dust emissions would be generated,
resulting in potential health and environmental risks.
Restrictions would be imposed to prohibit the construction of wells on or adjacent to the
site and withdrawal of affected near-surface ground water.
-------
Site-Specific Considerations
The major material movement activities will be a result of the excavation of 380',000
cubic yards of waste CKD from Sites 2 and 3 and 109,000 cubic yards of waste CKD and
commingled material from the West Site. Site 2 contains waste CKD that was placed as a slurry.
This material has developed layers of hardened waste CKD. A bulldozer or tracked front loader:
equipped with a "ripping" tooth may be required to break up the crusts before the waste CKD .
can be excavated.
The commingled West Site waste CKD would require selective excavation and the
separation of large construction debris prior to shipment of the waste CKD off-site for disposal.
Cost and Implementation Time
The present value of the total cost of Alternative 7B is estimated to be $18.6 million.
Capitol costs were estimated to be $25.4 million spread over a five year period. Operation and
maintenance costs are estimated to be $5,000 annually for a period of 30 years.
Compliance with ARARs
Removal of waste CKD to an off-site landfill would eliminate fugitive dust emissions
from the site, thereby contributing to site-specific long-term compliance with federal and state
air quality standards for TSP and fiugitive dust control. This action would be conducted using
appropriate dust controls to ensure shon-term compliance with these standards. State solid waste
regulations require disposal in a state approved site. This ARAR would be met.
This alternative would isolate all identifiable waste CKD from potential future contact
with site groundwater. The cap proposed for the off-site landfill exceeds current landfill cover
requirements. This alternative is expected to comply with all identified ARARs.
Alternative 7C (CKDf7C) - Excavation and DisPosal Off-Site in the VicinitY of the Salt Lake
Valley Landfill
Description
Alternative 7C differs from Alternatives 7 A and 7B in the location of the new off-site
industrial landfill to be constructed for the waste CKD. Alternative 7C was not in the August
18, 1989 FS submitted for this site, but was developed with addendum information to the FS
dated March 20, 1990 submitted by Lone Star Industries. The addendum FS information has
been placed in the Administrative Record for this site.
-------
Waste CKD and codisposed nonhazardous materials would be excavated, loaded into
trucks and transported to an off-site, state ~proved, double-lined, noncommercial, industrial
waste landf1lllocated in the general vicinity of the Salt Lake Valley Landfill (see Figure 7-3).
Except for chrome brick, the codisposed material would be transported along with the waste CKD
for disposal in the landfill. Chrome bricks separated and would be temporarily stored on-site.
After addressing any residual soil contamination, excavated areas would be restored to pre-f1lled
contours through the placement of bankrun fIll material.
The landfill would be constructed on a 30 acre parcel which would have to be identified,
purchased, zoned, and permitted for industrial waste disposal. A specific site location for this
landfill has not been determined. The landfill cell would be approximately 25 acres in plan area
and lined with a double synthetic membrane and leak detection system. A layered cover system
consisting of a synthetic membrane would be used. As required, a six-foot high chain link fence
with a three-strand barbed wire crown would be constructed at the landfill permitted for access
control. The estimated quantities of materials involved are shown in Table 7-6.
Operating and Maintenance Requirements
The closure cover would be inspected annually. Routine maintenance, including weed
control or partial revegetation, would be performed as required.
M01zitoring Requirements
Visual inspection and ground water monitoring consistent with permit requirements would
be performed. A leak detection system for the new landfill would also be r~quired.
Off-Site Disposal
Excavated waste CKD and commingled materials would be disposed off-site in the off-
site, state approved industrial landfill.
Emissions Control
Dust suppressants would be used during construction activities to minimize fugitive dust
emissions. Trucks would be covered with tarps during transport of waste materials to the landfill
site.
InstiTutional Controls Required
Temporary deed restrictions would be imposed. These restrictions would prohibit site
development that could disturb waste CKD such that fugitive dust emissions would be generated,
resulting in potential health and environmental risks.
Restrictions would be imposed to prohibit the construction of wells on or adjacent to the
site and withdrawal of affected near-surface ground water.
-------
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-------
Sire-Specific C onsiderarions
The major material movement activities will be a result of the excavation of 380;000
cubic yards of waste CKD from Sites 2 and 3 and 109.000 cubic yards of waste CKD and
commingled material from the West Site. Site 2 contains waste CKD that was placed as a slurry.
This material has developed layers of hardened waste CKD. A bulldozer or tracked front loader:
equipped with a "ripping" tooth may be required to break up the crusts before the waste CKD
can be excavated.
..... ... .... TABLE 7-6. . . ....... ...........:...... ......
SUMMARy' OF ESTIMATED QUANTITJE.S F{)J:t CI{DnC ...
. ..
.. ........ ....
. . .
. . ......
. . . . . . .
..... . ...;;~~r::. . . ...
...1.089.000 Square Feet:.
J,089,OOOSquare Feet .
1,089,000 Square Feet
. . 20,200 Cubic Yards
. . ',., . .
.. C()nStructi()~ofI..andiillCen... .. .. . .. .....
. ...... General Excavation and Rough Grading ...
. Fme Grading"....:"... . .. . ... ...
. 60 mil Secondary HDPB Liner.
Leak Detection/CoUection System
60 inil Primary HDPB/Liner
6 inch Protective Soil Cover
Excavaton and Relocation of Waste CKD
. Site 2 . . ...... .
. Site 3 ..
.. WeSt Site
.. .
Replacement Fill <
. .. ... Site 2. . . .
.. .."Site 3.... . .
Landfill Cover SyStem
. . . 6. Site Grading Fill .
. 60 mil Primary HDPB
. 6" Drainage/Capillary .Break
12" Bankrun Soil Fill
4~ Topsoil .. ......
Revegetation
Fencing
. .138,000 Cubic Yards
:..249,000 Cubic Yards
.109.000 Cubic Yards
. .
.. ... .
. .
. J3,300 Cubic Yards
15 600 Cubic Yards
t .
. ..
19,264 Cubic Yanis.
.1:089,000 Square Feet
.." 19,264 Cubic Yards
..38.526 Cubic Yants
":12,842 Cubic Yards
. . 25 Acres
4.600 Linear Feet
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Cost and Implementation Time
The present value of the total cost of Alternative 7C is estimated to be $12.5 million.
Capitol costs were estimated to be $17.1 million spread over a five year period. Operation and
maintenance costs are estimated to be $5,000 annually for a period of 30 years.
Compliance with ARARs
Removal of waste CKD to an off-site landfill would eliminate fugitive dust emissions
from the site, thereby contributing to site-specific long-term compliance with federal and state
air quality standards for TSP and fugitive dust control. This action would be conducted using
appropriate dust controls to ensure shon-term compliance with these standards. State solid waste
regulations require disposal in a state approved site. This ARAR would be met.
This alternative would isolate all identifiable waste CKD from potential future contact
with site groundwater. The cap proposed for the off-site landfill exceeds current landfill cover
requirements as stated in those regulations. This alternative is expected to comply with all
identified ARARs.
ALTERNATIVES WITH TREATMENT AS A MAJOR COMPONENT
Alternative ~ 1 (CKP/ll) - Soli4ification with Ponland Cement and On-Site Replacement
. Description
Waste CKD would be excavated and moved to an on-site location for processing and
mixing with Portland cement. The Ponland Cement would be added in prescribed amounts
(currently targeted at 10% on a dry weight basis) and mixed. Mixed materials would be moisture
conditioned as required, placed back into excavated areas within the site, and compacted. The
codisposed West Site waste CKD may require selective excavation and the removal of large
construction debris prior to funher processing. Codisposed materials would be separated from
waste CKD using standard screening techniques. Except for chrome brick, the codisposed
material would be transponed for disposal at a local municipal landfill. The stabilized waste
CKD would be deposited on-site in a manner similar to soil cement to provide a suitable base
for future commercial development of the property, unless other beneficial uses for the stabilized
waste CKD (e.g., parking lot base material) could be developed. Excavated areas not filled with
solidified material would be restored to pre-filled contours through the placement of bankrun fill
material.
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The waste CKD and codisposed materials would be excavated using a backhoe dragline,
bulldozers or loaders at Sites 2 and 3, and .either backhoes or loaders at the We~~ Site, and
trucked to the stabilization plant. At the stabilization plant, the waste CKD would be dumped
on a stockpile pad. A front end loader would transfer the waste CKD to the feed hopper of the
treatment system. Selective excavation would separate chrome brick and temporarily stored on-
site. The treated material would be hauled back to previously excavated areas, dumped, spread
and compacted.
Excavated areas that are not fIlled with stabilized waste CKD would be restored to pre-
fIlled contours using bankrun fill materials. The same equipment used to handle the waste CKD
would be used to place the bankrun fill.
In order to avoid haulage on public roads and minimize crossing of the City Drain with
waste CKD, the mixing plant would be ponable and would be located at each site. Dust would
be controlled through the application of water or other appropriate dust suppressants.
Facility Description
The primary element of the mixing plant would be a pug mill or paddle mixer to blend
Portland cement with the waste CKD. Treatability studies indicate that the highest strengths in
the stabilized materials are achieved with little added water so water sprays in the blending
machine will provide sufficient added moisture. The waste CKD would be fed to the plant by
a front loader over a sloping grizzly (bar screen) with I-inch openings or a "Wobbler" type
feeder. 1bis screen would remove codisposed materials and large pieces of hardened waste CKD
(as found on Site 2). The large particles would fall into a bin at one side of the feed hopper.
The coarse material would be sorted manually into three categories: chrome brick, other
codisposed nonhazardous materials, and hardened pieces of waste CKD, and placed in individual
temporary stockpiles pending proper disposal.
Some waste CKD on Site 2 has hardened to a rock-like consistency. This material would
be segregated by the bar screen and fed by a front end loader to a jaw crusher after any chrome
brick or other waste has been removed. The product of the jaw crusher would be returned to the
feed hopper by front end loader. Water sprays would be used to control dust from the flOe,
crushed waste CKD. The jaw crusher would be equipped with a dust control system. All
collected dust would be fed to the mixing plant.
The feed hopper would be located directly over the end of the plant so that the waste
CKD would fall directly into the mixer. An overhead bin would feed Portland cement by gravity
flow through a rotary vane feeder. Small quantities of water would be added to allow mixing
of the Portland cement and processed waste CKD to a homogeneous condition. The Ponland
cement/waste CKD mixture would discharge by gravity onto a conveyor which would place the
material in dump trucks. The mixed material would then be hauled by dwnp trucks to the
replacement areas.
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The entire plant would be modular so that it could be disassembled and transponed to a
prepared pad at each site. .
Operation and Maintenance Requirements
The following operational scenario is assumed. The operation would handle 500,000 .:
cubic yards of waste CKD over 5 years. Operations would be conducted for 8 hours per day,
5 days per week for approximately 200 operating days per year. The plant would be designed
to process 62.5 cubic yards per hour or 500 dry tons per day of waste CKD. The total plant
design throughput would include the addition of Ponland cement at a rate of 200 pounds per dry
ton of waste CKD or 6.25 tons per hour.
..
This operation would require two front end loaders, one wheeled bulldozer, four dump
trucks, and the screening and stabilization plant. Electric power and water would be necessary
for the mixing plant. The power requirements are estimated to be less than 150 horsepower.
Water requirements of 100 gpm could be met by either utility hook up, by tanker truck, surplus
canal or site water.
The Ponland cement would be brought to the site in tank trucks and pneumatically
conveyed to a feed. bin. About thirteen 25-ton truck loads of Portland cement per week would
be required.
Once material solidification is complete at the site, no future operation or maintenance
activities would be required.
Off-Site Disposal
As described above, codisposed materials would be screened from the waste CKD.
Nonhazardous materials screened from the waste CKD would be transponed and properly
disposed at a landfill permitted to receive such materials.
Emissions Control
The application of dust suppressants during excavation and construction activities would
minimize the potential for the development of fugitive dust emissions. The Ponland cement
system and mixing plant would be enclosed and water sprays would be used to control dust. The
mixed materials would not have a high potential to generate dust due to their relatively high
water content.
Institutional Controls Required
Temporary deed restrictions would be imposed pending the completion of solidification
of all waste CKD at the site. These restrictions would prohibit site development that could
disturb waste CKD such that fugitive dust emissions would be generated, resulting in potential
health or environmental risks.
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Restrictions would be imposed to prohibit the construction of wells on or adjacent to the
site and withdrawal of affected near-surface. ground water.
Cost and Implementation Time
The present value of the total cost of Alternative 11 is estimated to be $15.1 million.
Capital cost is estimated to be $18.2 million, which would be spread over the five year .
completion period. No operation and maintenance costs are anticipated.
Compliance with ARARs
The solidification of waste CKD with Portland cement would eliminate fugitive dust
emissions from the site, thereby contributing to site-specific long-term compliance with federal
and state air quality standards for TSP and fugitive dust control. The action would be conducted
using appropriate dust controls to ensure short-term compliance with these standards.
As a "solid material resulting from industrial....operations" (Utah State Title 26, Chapter
14), solidified waste CKD may be considered a solid waste. State solid waste regulations should
be met.
Alternative 12 (CKD/12) - Solidification with Class C Av Ash and On-Site Replacement
Description
This alternative is identical to Alternative 11 except that instead of mixing the waste CKD
with Portland cement, the waste CKD would be mixed with Class C fly ash. The fly ash would
be added in prescribed amounts (currently targeted at 20% on a dry weight basis) and mixed.
The fly ash would be added at a rate of 400 pounds per dry ton of waste CKD, instead
of 200 pounds per ton of Portalnd Cement as in Alternative 11. The processing plant would be
designed to achieve the same throughput of waste CKD as for Alternative 11.
The fly ash would be brought to the site in tanker trucks and pneumatically conveyed to
a feed bin. Twenty-five 20 ton truck loads of Class C fly ash per week would be required.
Once material solidification is complete at the site, no further operation or maintenance
activities would be required.
Off-Site Disposal
As for Alternative 11, codisposed materials would be screened from the waste CKD.
Chrome bricks would be separated from other codisposed material and temporarily stored on-site.
Nonhazardous materials screened from the waste CKD would be transported and properly
disposed at a landfill permined to receive such materials.
-------
As for Alternative 11, the application of dust suppressants during excavation and
con~tmction activities would minimize the potential for the development of fugitive dust
emissions. The fly ash system and mixing plant would be enclosed and water sprays would be
used to control dust. .
Institutional Controls Required
Identical institution controls to those proposed in Alternative 11 would be implemented.
Cost and Implementation Time
The present value of the total cost of Alternative 12 is estimated to be $15.5 million. The
alternative could be completed in 5 years. No operation and maintenance costs are anticipated.
Capital cost is estimated $18.67 million.
Compliance with ARARs
Alternative 12 would meet the same ARARs identified for Alternative 11.
ALTERNATIVES RELYING ON REUSE OF WASTE CKD AS A RESOURCE
Alternative UJQ(D/13) - Use as a Resource With On-Site Processing;
Description
Waste CKD would be excavated, separated from codisposed materials, processed as
required on-site and shipped to the point of beneficial use by truck or rail. Some potential uses
of waste CKD as a resource include:
Fertilizer - Waste CKD could be applied alone or mixed with other ingredients to
utilize the potash content of the material.
Lime Substitute - Waste CKD could be used as a lime substitute in gold or silver
production and in water treatment by the lime-alum coagulation method.
Mineral Filler - Waste CKD could be used as a mmeral filler in masonry units
(concrete blocks), asphaltic roofing materials and bituminous asphaltic concrete.
Sludge Stabilization - Waste CKD could be used to stabilize waste water treatment
plant sludge. Patented processes are available whereby sludges are treated and
stabilized to produce an end product that is essentially odorless, granular and contains
many plant nutrients and valuable organic materials.
-------
Waste Stabilization - Waste CKD could be used alone or with fly ash to stabilize and
solidify various hazardous and non-hazardous waStes.
Excavated areas would be restored to pre-filled contours using bankrun fill materials. The
waste CKD processing facility would be secured as required. The chromuim bricks would be
separated and temporarily stored on-site.
For purposes of developing a cost estimate and performing detailed evaluation of this
alternative, the following excavation, processing, and distribution scenario has been assumed.
Waste CKD would be excavated and temporarily stockpiled at a processing plant located on-site.
Screening and grinding of the waste CKD would be followed by flash drying. The resultant
material would be marketed as a lime substitute. All materials would be distributed by truck an
average of 50 miles to an assumed use location. No revenue from reuse is assumed.
The materials handling requirements are similar to those described for Alternative 11 for
waste CKD excavation. Additional handling requirements would be a function of processing
requirements or ultimate beneficial use.
The following process facility has been assumed. A jaw crusher would be used for size
reduction of screened materials prior to feeding them into a gas heated flash drier at a rate of 100
tons per hour. The syStem would be equipped with a baghouse for dust control. Dried product
would be stored on-site in portable 120 ton capacity storage bins.
Operation and Maintenance Requirements
The following operational scenario has been assumed. A staff of three persons would be
required to operate the processing facility. Excavation and on-site transportation of excavated
materials would be subcontracted. Processing would be performed on the basis of a 40-hour
week for 9 months per year over a four year period.
Off-Sire Disposal
Non-hazardous materials screened from the waste CKD would be transponed and properly
disposed at a landfill permitted to receive such materials. .
Emissions Control
Emissions considerations of waste CKD excavation are similar to those discussed for
Alternative 7A, 7B, and 7C. Additional emissions considerations would be dependent on
processing alternatives selected and ultimate beneficial use.
-------
Institutional Controls Required
Temporary deed restrictions would be imposed. These restrictions would prohibit ,site
development that could disturb waste CKD such that fugitive dust emissions would be generated,
resulting in potential health or environmental risks.
Restrictions would be imposed to prohibit the construction of wells on or adjacent to the site:
and withdrawal of affected near-surface ground water.
Cost and Implementation Time
The present value of the total cost of Alternative 13 is estimated to be $16.1 million. Cash
flow for capital expenses ($19.2 million) are spread over an estimated five year period for the
purpose of calculating a present value cost. The time period may vary depending on the end
use(s) identified.
Compliance with ARARs
This alternative is expected to meet all of the identified ARARs.
Alternative 13A (CKD/13A) - Use as a Resource Without On-Site Processing;
Description
Alternative 13A is identical to Alternative 13 except that the waste CKD would not receive
any processing prior to its shipment from the site. Some potential uses of unprocessed waste
CKD as a resource could include:
Soil Stabilization - Unstable clays could be treated with waste CKD to provide
temporary or permanent stability at a construction site.
Cattle Feed - Waste CKD could be used as a binder in alfalfa pellets or as a nutrient
supplement in cattle feed.
Acid Neutralization (mine waste, etc.) - Waste CKD could be used to neutralize acid
wastes from industrial process, acid mine drainage. acid mine waste piles and leachate
from hazardous and sanitary landfills.
Paving - Waste CKD could be mixed with soil to produce a soil cement-like paving
base, mixed with construction aggregate to produce a paving base, or mixed with fly
ash to develop a paving sub-base.
-------
Sanitary Landfill Daily Cover - Waste CKD could be used for daily cover or as a
compo~ting aid for vegetable manef in a sanitary landfill. The Salt Lak~ ,,Y alley
Municipal Solid Waste Landfill has been identified as a potential user of waste CKD
for these purposes. Waste CKD could provide an economical means to satisfy or
supplement the County's future daily cover requirements.
For purposes of developing a cost estimate and performing detailed evaluation of this'
alternative option, the following excavation and use as a resource scenario has been assumed.
Waste CKD would be excavated and transponed directly to the Salt Lake County LandfIll for
use as a daily cover. About 400 cubic yards per day of waste CKD would be hauled by truck
to the landflll. For the purposes of cost estimating, it has been assumed that the cost for
excavation and transponation would be a remediation cost. No tipping fees have been
considered. The cost of funher processing of the waste CKD, such as slurrying or pelletizing
has not been considered. Waste CKD from the site, when compared to other potential sources
of daily cover materials, has a potential value as a resource to the landf1ll. This resource value
has not been considered in the analyses that follow. The chromuim bricks would be separated
and temporarily stored on-site.
Operation and Maimenance Requirements
For purposes of developing a cost estimate and performing detailed evaluation of this
alternative, the following operational scenario has been assumed. Excavation and transponation
of waste CKD to the landfill has been assumed to be on the basis of a 40-hour week for 9
months per year over a five year period.
Off-Site Disposal
Non-hazardous materials screened from the waste CKD would be transponed and properly
disposed at a landfill pennined to receive such materials.
Emissions Control
Emissions considerations for waste CKD excavation are similar to those discussed in Alternative
7 A-7C. Additional emissions considerations would be dependent on the ultimate beneficial use.
Institutional Controls Required
Temporary deed restrictions would be imposed. These restrictions would prohibit site
activities that could disturb waste CKD and generate fugitive dust emissions.
RestriCtions would be imposed to prohibit the construction of wells on or adjacent to the site
and withdrawal of affected near-surface ground water.
-------
Cost and Implementation Time
The present value of the total cost of Alternative 13A is estimated to be $7.8 million. . No
operation and maintenance costs are. anticipated. Cash flow for capital expenses ($9.3 million)
are spread over the estimated completion time of five years for the purpose of calculating a
present value cost. However, the time period may vary depending on the end use identified.
Compliance with ARARs
This alternative is expected to comply with all of the ARARs identified.
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8.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
This section of the ROD evaluates the relative perfonnance of the alternatives ~ith respect
to the nine criteria developed by the EP A to guide the remedy selection process. The criteria
against which each of the alternatives is to be compared are summarized below:
Overall Protection of Human Health and Environment addresses whether
or not a remedy will remediate a site such that the resulting risks to the
public and the environment are within an acceptable level.
Compliance with Applicable or Relevant and Appropriate Reauirements
(ARARs) address whether or not a remedy will meet all of the
requirements of environmental statutes and/or provide grounds for invoking
a waiver.
Lon2-Tenn Effectiveness and Pennanence refers to the ability of a remedy
to maintain reliable protection of human health and the environment over
time once cleanup goals have been met.
Reduction of ToxicitY. MobilitY. or Volume refers to the statutory
preference to reduce toxicity. mobility, or volume of hazardous substances
through treatment.
Shon-Tenn Effectiveness refers to concerns about protection of public
health and the environment which may arise during the construction and
implementation period until cleanup goals are met and the time required
to achieve the cleanup goals.
ImplementabilitY is the technical and administrative feasibility of a
remedy, including the availability of materials and services needed to
implement the chosen alternative.
Cost Effectiveness compares the cost of alternatives that achieve the same
protectiveness. EPA's goal is to choose the less costly of similarly
protective remedies. Cost effectiveness includes capital costs, operating
and maintenance costs, and present wonh costs.
State Acceptance evaluates the technical and administrative issues and
concerns the State of Utah may have regarding each of the alternatives.
-------
Communirv Acceptance evaluates the issues and concerns expressed by the
public in coinments received -through public hearings, letters, and other
media. Community acceptance is evaluated once public comments on the
RIlFS and Revised Proposed. Plan have been received. A thorough
summary of public comments and responses to those comments is
presented in the Responsiveness Summary of this ROD.
The first two criteria are considered "Threshold" Factors; alternatives must meet these criteria to
be retained for further consideration. The next five criteria are considered "Primary Balancing"
Factors, and are the primary criteria upon which the analysis is based. The last two criteria are
tenned "Modifying" Considerations.
~
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
A variety of remediation methods are employed in the various alternatives to reduce or
control the risks associated with the waste CKD. The "No Action" Alternative does not provide
protection of human health and the environment and therefore will not be considered in the
evaluations of the remaining criteria. Separation, temporary storage of the chromium-bearing
refractory kiln bricks will occur under all of the alternatives presented except the "No Action"
Alternative. Treatment and disposal of the chromium bricks will be addressed under subsequent
operable unit(s).
Alternatives 13 and 13A involve use of the waste CKD as a resource. Upon completion
of remedial activities all long tenn potential exposure pathways would be eliminated and there
would not be any long-tenn monitoring or maintenance requirements. Beneficial reuses would
be selected to minimize health and environmental impacts associated with the remediation. It
appears unlikely that all of the waste CKD could be remediated under this scenario in a timely
manner, since no markets for reuse of the waste CKD were identified.
Alternatives 6, 7B, and 7C provide for total containment of the waste CKD thereby
eliminating potential exposures through inhalation, ingestion, and dennal contact. These
alternatives include a bottom double-liner which should eliminate the possibility of further
contamination of groundwater resources. Alternative 7B would be located in a remote area in
Tooele county. Alternative 7C would be located in an area that already contains a number of
industrial and municipal landfills and is somewhat isolated relative to the existing site.
Alternative 6 contains the waste CKD on-site in a highly industrialized and urbanized area.
Alternatives 5 and 7 A provide for consolidation and capping of the waste CKD thereby
eliminating potential exposures through inhalation. ingestion and dennal contact. However, these
alternatives do not include bottom liners and consequently are not as protective of ground water.
Alternative 7 A involves placement and capping of the waste CKD in an unlined limestone quarry
in Tooele county, whereas Alternative 5 is consolidation and capping on-site, with no bottom
liner.
-------
Alternatives 11 and 12 involve solidification of the waste CKD through mixing with
Portland Cement and fly ash respectively.. These alternatives would apparently result in a
reduction of the long-term risks associated with the site. However, these technologies have not
been thoroughly tested for long-term physical stability and long-term resistance to leaching when
exposed to moisture, and consequently may not provide overall protection of health and the
environment in the future.
COMPLIANCE WITH ARARS
Table 7-1 lists the ARARs that have been identified for waste CKD remedial actions and
categorizes them as applicable or relevant and appropriate. An evaluation of each alternatives
ability to meet ARARs is presented in Table 8-1. All of the alternatives would comply with their
respective ARARs except Alternative 1. However, the alternatives may differ in the complexity
of the methods by which the ARARs are met. Some alternatives require more engineering
controls, institutional controls, or involve administrative and monitoring requirements that others
do not.
The primary ARARs associated with alternatives 5,6, 7A, 7B, and 7C are the Solid Waste
Disposal Regulations, the Clean Air Regulations, and State Corrective Action Oean-up Standards.
All of these alternatives would comply with these ARARs. However, in the absence of a bottom
liner, Alternatives 5 and 7 A would not be as effective in meeting the Utah Corrective Action
Clean-up standards.
The primary ARARs associated with Alternatives 13 and 13A are the Oean Air
Regulations and the Utah Corrective Action Oean-up Standards. These alternatives would
comply with these ARARs. However, the open-ended time frames potentially associated with
implementation of these alternatives could result in long term monitoring and maintenance to
ensure compliance with the ARARs.
The primary ARARs associated with Alternatives 11 and 12 are the Solid Waste Disposal
Regulations, the Oean Air Regulations and the Utah Hazardous Waste Disposal Regulations for
the disposal of the chromium-bearing refractory kiln bricks. It is expected that these alternatives
would comply with these ARARs. However, the questions regarding the long-term stability and
resistance to leaching of these remedies could result in non-compliance with the ARARs in the
future.
-------
..
TAB 1
COMPLIANCE H ARAR'S
ARAR Clm-I CKD-5 CKD-' CKD-7 A CKD-78 CKD-7C CKD-U CKD-U CKD-IJ
SOUD W ASfE DISPOSAL ACf N' yl Y Y Y Y Y Y Y
SWDA 40 CFR 241 N Y Y Y Y Y 3
-
RESOURCE CONSERVATION AND
RECOVER Y ACf
RCRA STANDARDS FOR TSD FACILITIF.S N Y Y Y Y Y Y Y Y
RCRA STANDARDS FOR TRANSPORTERS OF Y Y Y Y Y Y Y Y
HAZARDOUS WASTE
RCRA GENERAL FACILITY STANDARDS N Y Y Y Y Y Y Y Y
RCRA HAZARDOUS WASTE PERMIT N Y Y Y Y Y Y Y Y
LAND DISPOSAL RESTRIcnONS N Y Y Y Y Y Y Y Y
CLEAN AIR ACf PRIMARY AND SECONDARY N Y Y Y Y Y Y Y Y
STANDARDS
OSHA 29 USC SECf. 651 ET SEQ. N Y Y Y Y Y Y Y Y
CLEAN WATER ACf:
NATIONAL POLLUTANT DISCHARGE N
ELIMINATION SYSTEM
WATER QUALITY CRITERIA N
EXEcuTIvE ORDER ON PROTEcnON OF Y
WETI.ANDS
DREDGE AND FILL REQUIREMENTS
DOT TRANSPORT A TION REGULATIONS Y Y Y Y Y Y Y Y
AR<1tAEOLOGICAL AND HISTORIC Y Y Y Y Y Y Y Y
PRESERVATION ACT
-------
TABLE 8-1 (CONTINUED)
COMPLIANCE WITH ARAR'S
ARAR CKD-l CKD-5 CKD-6 CKD-7 A CKD-7B CKD-7C CKD-11 CKD-l1 CKD-U
NATIONAL mSTORJC PRESERVATION ACT Y Y Y Y Y Y Y Y
ENDANGERED SPECIES ACT Y Y Y Y Y Y Y Y Y
FISH AND WIlDLIFE COORDINATION ACT Y Y Y Y Y Y Y Y
tITAH SOUD AND HAZARDOUS WASTE ACT N Y Y Y Y Y Y Y Y
UTAH CLEAN AIR ACT:
STATE CAA PRIMARY AND SECONDARY N Y Y Y Y Y Y Y Y
STANDARDS
STATE CAA ruGmVE DUST CONTROL N Y Y Y Y Y Y Y Y
STATE CAA BACT REGULATIONS N Y Y Y Y Y Y Y Y
UTAH CORRECTIVE AcnON CLEAN-UP N Y Y Y Y Y Y Y Y
STANDARDS
UTAHS~DRJ~NGWATERACT Y
STATE ANTIQUITIES ACT Y Y Y Y Y Y Y Y y.
ANTI-DEGRADATION POUCY Y Y Y Y Y Y Y Y
(W~TER QUALITY)
tITAH WATER POLLUTION CONTROL ACT:
W ASTEW A TER DISPOSAL REGULATIONS
.
UPDES PERMIT REGULATIONS
GROUND-WATER QUALITY PROTEcnON N y Y Y Y Y Y Y Y
I N lnIicates the alternative does not comply with the ARAR.
2 Y Indicates the alternative does comply with the ARAR.
3 - Indicates that the ARAR is not applicable to the alternative.
-------
LONG TERM EFFECTIVENESS AND PERMANENCE
Implementation of Alternatives 13 and 13A would result in the highest degree of long-term
effectiveness and pennanence because these alternatives would result in reuse of the waste CKD
for beneficial purposes. There would be no long-tenn monitoring associated with these
alternatives and the site would be available for any future use. .
J
Remediation under Alternatives 6, .7B, and 7C would result in total containment of the waste
CKD in an engineered landfill. Proven construction and engineering techniques would be used
for implementation of these alternatives and long-tenn monitoring and maintenance would be
required. Alternative 6 would be located at the existing site which is industrialized and
urbanized. Future use of the West Site would be limited under Alternative 6 due to containment
of the waste CKD on-site. Under Alternative 6, replacement of a remedy componet would
subject an increasingly urban community to increased risks.
Alternative 5 and 7 A require capping of the waste CKD but do not include bottom liners. In
the absence of a bottom liner, these alternatives do not provide effective protection of ground
water. Long-tenn monitoring and maintenance would be required for these alternatives.
Alternatives 11 and 12 use unproven technologies and consequently their long-tenn
effectiveness and permanence are questionable. These alternatives would also require long-tenn
monitoring and maintenance, and would limit the future use of the site.
REDUCTION IN TOXICITY, MOBILITY, OR VOLUME THROUGH TREATMENT
All of the alternatives under consideration include removal of the chromium bearing refractory
kiln brick from the waste CKD. The removal of the brick will significantly reduce the
concentration and/or potential for leaching of chromium in the waste CKD. Treatment of the kiln
brick to reduce toxicity will be required prior to their disposal under a subsequent operable unit.
Through reuse as a resource, Alternatives 13 and 13A may not reduce the toxicity, mobility,
or volume of the waste CKD. However, the waste CKD will be in a state that reduces or
eliminates exposure, and provides a beneficial use for the material.
Alternatives 11 and 12 reduce the toxicity and mobility of the waste CKD through treatment.
However, both alternatives result in an increase in volume of material and the ability of these
alternatives to maintain their effectiveness over time is unproven.
Alternatives 5, 6, 7A, 7B, and 7C reduce the mobility of the contaminants through containment
or capping of the waste CKD, but do not employ treatment techniques. None of these
alternatives reduce the toxicity or volume of the waste CKD. Alternatives 5 and 7 A, which have
no bottom liner, will be less effective in reducing mobility of contaminants in groundwater.
-------
SHORT-TERM EFFECTIVENESS
All of the alternatives under consideration require extensive excavation and earth moving,
which requires detailed attention to community and worker safety. Appropriate safety controls
will be implemented to limit all exposures during the construction phase of the remediation.
Alternatives 11 and 12 also require extensive on-site handling of the waste CKD. Under these
alternatives the waste CKD would be handled only once, and it would be entirely on-site. There
would be no off-site transponation required. These alternatives would require approximately 5
years to implement.
..
Alternatives 7A, 7B, 7C, 13, and 13A would also require the waste CKD to be handled only
once. However, these alternatives would require off-site transponation of the waste CKD. Under
Alternatives 7 A, 7B and 7C, the landfIll design, pennining, and construction would require
approximately 3 years and waste CKD movement would require about 2 years, assuming a rate
of 1400 tons/day. Alternatives 13 or 13A would require approximately 5 years to implement.
Alternatives 5 and 6 would require double handling of some. of the waste CKD, thereby
increasing the potential for short-tenn exposure to fugitive dust. These alternatives would not
require off-site transportation of the waste CKD which would eliminate the risks associated with
truck traffic. Remediation under these scenarios would require approximately 2 years for
Alternative 5 and 3 years for Alternative 6.
IMPLEMENT ABILITY
All of the alternatives under consideration employ known construction and engineering
techniques that require services and materials that are readily available. There are differences
between the alternatives in tenns of the ease of implementation, and the administrative
requirements associated with implementation of a specific alternative.
Alternatives 5 and 6 result in remediation where the waste CKD remains on the present site,
therefore no pennits would be required, but substantive pennit requirements would be met.
Materials and equipment required to implement these alternatives are readily available in the local
area. Construction activities for Alternative 6 would be somewhat more complicated than
Alternative 5.
The materials and equipment required to implement Alternatives 7 A, 7B and 7C are also
readily available. Alternative 7 A is somewhat less complicated to implement due to the absence
of a bottom liner. All of these alternatives require transport of the waste CKD to an off-site
location, which requires compliance with all pennining and administrative requirements at the
new landfIll site. The Tooele County Commission has advised the State of Utah that Alternatives
7 A and 7B are unacceptable since these disposal sites lie outside the county's Hazardous Industry
Zone for such facilities. Consequently, these two alternatives are not implementable.
-------
Alternatives 11 and 12 also employ materials and equipment that are readily available. The
technical comple;w;ity is increased due to the processing required as part of the remediation.
Because the remediation would be conducted on the present site, no permits would 'be required,
but substantive permit requirements. would be met.
4
Conventional construction and earth moving methods would be used for Alternatives 13 and
13A. The additional processing required for Alternative 13 increases the level of technical .:
complexity. Implementation of these alternatives requires the identifica~ion of users or markets
for the waste CKD, Based on current infonnation the users and markets do not apparently exist,
thereby significantly effecting the implement ability of these alternatives.
COST ANALYSIS
Cost calculations for each remedy involved a standard methodology to make comparison
possible. Capital costs in future dollars were estimated, including a contingency. Operation and
maintenance costs were calculated separately for the period beginning with the end of the
construction portion of the project. Operation and maintenance, if required, was assumed to
continue for a standard 30 year period. The present value of the total cost was calculated by
assuming the present value of the capital costs and operation and maintenance costs. Present
. value of total costs assumes a 10 percent discount rate. Capital costs were spread over the
duration of the construction period to calculate their present value. Operation and maintenance
costs (if required) were assumed for a 30-year period following completion of construction.
As explained in the beginning of chapter 7, the specific cost for the alternatives (except the
"No Action" Alternative) have not been changed to reflect the storage of the chromium bricks
under this operable unit. The cost listed in this chapter reflect the transport and disposal of the
chromium bricks at a RCRA Subtitle C facility, which was estimated to be approximately
$60,800. As described previously, the chromium bricks will be separted and temporarily stored
at an acceptable on-site location. The alternatives are presented in the order of least to greatest
cost.
Alternative 13A: Use as a Resource without On-Site ProcessinJ?:
Capital
Cost (x~OOO)
Annual 0& M
Expense (xlOOO)
Present
Value (xlOOO)
AJternative 13A (CKD/13A)
Sites 2 and 3
West Site
$ 6,340
$ 3,010
$0
$0
$ 5,290
$ 2,510
TOTAL
$ 7,800
-------
Alternative 5: Consolidation of Waste CKD at the West Site
Capital
Cost (xIOOO)
Alternative 5 (CKD/5)
Sites 2 and 3
West Site
$ 7,133
$ 2,011
Annual 0& M
~xpense (xlOOO)
$ 3.9
$ 1.1
TOTAL
Present
Value (xIOOO)
$ 6,548
$ 1.847
$ 8,395
Alternative 7 A: ~xcavation and Disposal Off-Site at the Flux QUarry Site in Tooele CountY
Capital
Cost (x,OOO)
Alternative 7A(CKD(lA)
Sites 2 & 3
West Site
$ 12,035
$ 3,008
Alternative 6: Excavation and Disposal On-site
Capital
~
Alternative 6 (CKD/6)
Sites 2 and 3
West Site
$ 7,395
S 5,070
Annual 0& M
t:xpense (xl000)
S 1.4
S 0.3
TOTAL
Annual 0& M
Expense (xU!2ID
$ 3.0
$ 2.0
TOTAL
Present
Value (xIOOO)
$ 8,338
$ 2.085
$ 10,423
Present
. Value (xIOOO)
$ 6,765
$ 4.640
$ 11 ,405
Alternative 7C: Excavation and pisPos~ Off-site in the VicinitY of the Salt Lake Valley Landfill
Capital
Cost (xIOOO)
Alternative 7C (CKD(lC)
Sites 2 and 3
West Site
$ 13.679
S 3,420
70
Annual 0& M
~xpense (xIOOO)
S 4.0
S 1.0
TOTAL
Present
Value (x 1000)
$10.015
S 2.503
-------
Alternative 11: Solidification With Ponland Cement. On-site Replacement
Capital
. Cost (xIOOO)
Alternative 11 (CKD/ll)
Sites 2 and 3
West Site
$13,935
$ 4,220
Annual O&M
Expense (xlOOO)
$0
$0
TOTAL
Alternative 12: Solidification With Flv Ash and On-site Replacement
Capital
Cost (xlOOO)
Alternative 12 (CKD/12)
Sites 2 and 3
West Site
$14,270
$4,400
Annual 0& M
~xpense (xlOOO)
$0
$0
TOTAL
Alternative 13: Use as a Resource with On-Site ProcessinJt
Capital
Cost (xlOOO)
Alternative 13 (CKD/13)
Sites 2 and 3
West Site
$14,875
$ 4,390
AnnualO&M
Expense (xlOOO)
$0
$0
TOTAL
. Present
Value (xIOOO)
$11,620
$ 3.520
$15,140
Present
Value (xlOOO)
$11,900
$ 3.670
$15,570
Present
Value (xlOOO)
$12,405
$ 3.660
$16,065
Alternative 7B: Excavation and Disposal Off-Site within the Tooele County Hazardous Waste
Exclusion Zone
Capital
Cost (x1000)
Alternative 7B(CKDJ7B)
Sites 2 & 3
West Site
$ 20.380
$ 5,095
71
Annual 0& M
Expense (xI000)
$ 4.0
$ 1.0
TOTAL
Present
Vnlue (x1000)
$ 14,900
$ 3.725
-------
The State of Utah has reviewed all of the above cost estimates, including the revised estimates
taken from the March 20, 1990 FS addendum information. The state believes that the. estimated
costs for Alternative 6 are under estimated when compared to Alternatives 7B and 7C because
the latter two alternatives include costs for items which were excluded from Alternative 6, but
which would be required.
STATE ACCEPTANCE
Alternatives 7 A, 7B, 7C would result in capping or containment of the waste CKD
thereby addressing the State's concerns regarding control of fugitive dust emissions, the potential
for ingestion or dermal contact with the waste CKD, and protection of ground water.
Alternative 6 would result in containment of the material, thereby addressing the States
concerns regarding the risks posed by the site. The waste CKD would remain on-site under this
alternative which would limit the future land use of the area.
Alternatives 13 and 13A would satisfy the State's concerns regarding the risks posed by
the site and would leave the property available for future use. However, it would be necessary
to ensure that the beneficial reuse did not result in additional health problems or environmental
damage.
Alternatives 5, 11 and 12 also involve remediation on-site, which would limit the future
land use of the area. Alternative 5 would address the concerns about blowing dust and dermal
. contact, but does not include a. bottom liner and consequently does not protect ground water
adequately. Alternatives 11 and 12 are unproven technologies that may not remediate the long-
term risks associated with the site.
.
COMMUNITY ACCEPTANCE
Community acceptance of the Preferred Alternative is evaluated and described in detail
in the Responsiveness Sununary of this Record of Decision. In summary, community comments
have been mixed. Residents near the present site have stated their desire to have the waste CKD
moved to an off-site disposal location. Residents of Magna and West Valley City oppose the
State's Preferred alternative, and would prefer that the waste CKD remain at the present site or
be moved to another off-site location. Lone Star Industries prefers that the waste CKD be
consolidated and capped on site using Alternative 5. One of the landowners, the Williamsen
Investtnent Company, has indicated a preference for the State's Preferred Alternative.
-------
9.
THE SELECTED REMEDY
Selected Remedy
Based on an analysis of the nine evaluation criteria as required by EP A guidance, the
Selected Remedy for Operable Unit 1 is Alternative 7C - Excavation and Disposal Off-Site in .
the Vicinity of the Salt Lake Valley Landfill. This alternative involves the excavation of all .
waste CKD from the Site, and its transponation to and disposal in an off-site, state approved,
double-lined;noncommercial, industrial waste landf1l1 to be constructed at approximately 1300
South and 7200 West, in the vicinity of the existing Salt Lake Valley Landf"ill and demolition
and industrial disposal facilities in Salt Lake City, Utah.
The new landfill for the waste CKD must be acceptable to the State of Utah and EP A,
and must meet all permitting requirements. All chromium-bearing refractory kiln brick will be
removed from the waste CKD and temporarily stored at an acceptable location pending treatment
and disposal, which will be addressed under a subsequent operable unit(s) for the site. Excavated
areas on the present site will be restored to pre-filled contours through the placement of bankrun
flll materials under subsequent operable unit(s). Some changes may be made to the remedy as
a result of the remedial design and construction process. Such changes generally reflect
modifications resulting from the engineering design process. The Selected Remedy allows a
maximum level of flexibility to funher optimize the remedial design with respect to the remedial
objectives for Operable Unit I and the next operable unit(s).
The remediation goals of the Selected Remedy include:
Removal of the source of soil and ground water contamination,
Reduction in the levels of risk associated with direct contact with waste
CKD and with exposure to windblown dust from the waste CKD,
Compliance with all CERCLA requirements and all identified ARARs,
including the Utah Corrective Action Cleanup Standards Rule.
The cost of the Selected Remedy ($12,518,143) is intermediate and is below the average
cost ($12.8 million) of the alternatives presented in this ROD, excluding the "No Action"
Alternative. The minimum cost of the alternatives considered (excluding Alternative 1) is
$7,800,000. The maximum cost of the alternatives considered is $18,625,000. A detailed
summary of the expected costs of the Selected Remedy is shown in Table 9-1.
The State of Utah has identified Alternative 7C as its Preferred Alternative primarily
because of its greater long-term effectiveness and permanence and the fact that the new landfill
under this alternative would be located in an area that already contains industrial and municipal
l~df1lls, and is somewhat isolated relative to the present site. The Preferred Alternative also
provides greater protection of Utah's ground water resource and by removing the source of
-------
TABLE 9.1.
'.:.
. .
. ... ... . .
. . .
. .
C?:nta~nt C~mponent ..
... Units
.,".'," .,"',", . '.','.:
. ... . ,',"'," . "," .
. Cost Per/
. ..Unit
Costs .. .
. (x1,OOO><
..
. ," . .. ,",' . ",', :-.'.'. :.,'," ,":"'" ..." "",' "',: ,'..". . .'
. .... .... .. ESTIMATED COSTS OF THE SELECTED REMEDY .
. AL TERNA 11VE 7C ~ .EXCA V ATIONANDDISPOSALOFF.SITE .
..... IN THE VICINITY OF THE SALTLA!<:EVALLEYLANDFILL.
.... ........ .
. .' .
. ... ..."'" ..... .. . . . . .
. .
. .. .
.' .'
CAPITAL COSTS: .
.Pemuts.. ..
Land Aquisition .. ..... . .
. Disposal of Chrome Brick.
. Disposal. of CKD.. .. ... ..
Reclamation. .
.1 EA
30 AC
360 TON .....
.' ...
. 496,000 CYD .....
... S9.88 AC .....
. ...." .... ..'"
.. .... ... ....'"
.. .. . ....
.. .
....... ...... '"
. .... $S(),OOO
. $12t500
$300............
.. ..
.........$22>
... $2,739
. $50....
..$375
.......$108. ......
.$10t76o,
~i
. $11;457<
. .
.. .
... .
MANAGEMENT
MOBlUZATION
ENGINEERING
496,000 CYD .
$1119 ..
, . .
$486....
~...
. $14,808.
CONTINGENCY (20%) ..
TOTAL CAPITAL COSTS .
$14.808 ..
. $17,099 .
. OPERATION AND MAINTENANCE COSTS:
. .
ANNUAL OPERATING COSTS
$5
PRESENT VALUE CALCULATED USING
A 10% DISCOUNT RATE
$12,518
the soil and ground water contamination, allows unobstructive monitoring of the ground water
at the Redwood Road site. EPA has choosen the State of Utah's Preferred Alternative as the
Selected Remedy.
-------
The volume of waste CKD excavated will be detennined from the waste CKD quantity
estimates in combination with visual and chemical and/or physical characteristic fiel~.tests to be
detailed during remedial negotaitons and design. The fmal clean-up levels, which will consider
for future uses, will be addressed in the future operable urut(s).
..
-------
10.
STATUTORY DETERMINATIONS FOR THE SELECTED REMEDY
Protection of Human Health and the .Environment
..
The Selected Remedy would remove and isolate the contaminant source from an area of .:
relatively high population that is subject to increased urbanization, thereby providing the
maximum reduction of the risks of direct contact and blowing dust, and removing the sorce of
ground water contamination. The off-site landfill for the waste CKD will be designed and
constructed to have an impervious double bottom liner and layered cap that would be protective
of human health and the environment. The area for the new landfill is near existing industrial,
demolition, and municipal landfills and has been designated as an area suitable for waste disposal
landfills with an appropriate zoning exception. The new industrial landfill would also provide
the highest degree of protection available for the groundwater and surface water in the site area.
The Selected Remedy is considered to be highly protective of human health and the environment.
The implementation of the remedy will not pose unacceptable shon-term risks. The Selected
Remedy will facilitate the fmal remediation of the site through the future operable unit(s).
Compliance with Applicable or Rele,'ant and Appropriate Requirements (ARAR's)
The primary requirements that are applicable or relevant and appropriate to the Selected
Remedy are (1) State solid and hazardous waste disposal regulations; (2) State hazardous waste
storage and disposal regulations penaining to RCRA Subtitle C facilities; (3) Federal RCRA
regulations penaining to the land disposal restrictions; and (4) Federal and State air regulations
on total suspended particulates and fugitive dust control. The Selected Remedy would meet all
applicable or relevant and appropriate requirements of Federal and State environmental laws. A
summary of ARARs and guidelines to be considered (TBCs) for the Selected Remedy is
presented in Table 10-1.
Cost Effectiveness
CERCLA Section 121 requires that the Selected Remedy afford overall effectiveness
proponional to its costs. According to the estimates provided by Lone Star Industries, the cost
of the Selected Remedy is $12,518,143. This cost will be intermediate when compared to the
costs of the other alternatives, and is below the average cost of all the alternatives presented in
this ROD.
-------
.T ABLE 10.1 . . . u .. . u
FEDERAL .AND STATE ARAR~S AND TBC1S:.
. ,
. u
. .
FEDERAL u
'. . . ..
. .
CHEMICAL-SPEcmC ARAR."
.'",.-
Cean Air Act (42USCH7401-7642)
.' '.' . ". . ,,",";. '... ",'" '. "'. ";";:>. ";',,'': ,. '':'::-'<;':-. ":>.':.,',' :'::"::-"'." ',: :'.:.;;..,". ,,', "" .','.
.. . ... ....'
40CFR Part SO, the National Primary Ambient AirStandaid for kad
-------
. . .T ABLE 10.1 . (Co~'rinu~): , .' ."..., ...." .
FEDERAL:AND ST A T~ ARAR~S ANDTBC'S
. .
H Occupati~ Safety 9J]dHealtbA~(29 UsCit6S1:6jS)\ '
" ,
... ,"
" .
.. 29CFR Parts,1910 and 1926 specify standards f(Jfsdet}'~bea1tD furwo~ ,including geoe~,.
.' requirements for personal proteCtiveeqoipmenl ,','. . ,., .. "..'. ,. ',....." .', "', '.
. . .. ", ",' ..' . ".' . . ",
,..DOT Hazardous Material TranSport Regulatiom ,.' .
" 49CPRPartS '107. 171-177 specify procedures for ~~bazardous~at~ria1s '', .. ',' '... .',' '
LOCATION SPECIF1C ARAR's.
,FEDERAL
Archeological and Historic Preservation Act (16USCG469)
4OCFRA6.301(c) describes procedures for preservation of historical and archeological dati.
-------
, '
.,", . ..' ..
, , "TABLEJO-1 (Continued) """,' ''',' "'."', ,,', ,','
FEDERAL AND STATEARAR'S ANDTBC'S
T' ,
....
'. .
",', "'.." .:',"',',.' ", ,", '. '. .:. :"',.'
N.atiOD~:Historic: PresefVatioo Act (16USC!47~ '.'.
, "
," . ,':. . ',' '. .. ,",,' .,'" ,'...' .,",'.. ""', ," . . ,.,',",",
.. . . . .
4OCFRf6.301(b) and 36CFR Part 800 require ~ralageDcieS to tab into account
'.." any' entity that is included or eligible for inclusioo in the Register of Hist~c Places., ,".
" ,
. ;':':':'...... .',":-",. .. ',. .. .: . "
. ... ..' . ..
Bndangerect Species Act (16USCU1S31-1543) ....
":... :
, "
. .. . . '. " ".," ".: .. .. . .... ,', ,'. " ",'
.. .. .. ." ..
SOCFR Parts 17 and 402 and 4OCFRI6.302(h) requires Federai agenclesto enSure tbitany
, ,federally authorized funded, or enforced action will DOt jeopardize tbe existence of any threatened ,
" .Ot endangered species, or adversely modify, ~ criticalbabitat. , " " "",' '", ' ',' ,. , "', ',' '
... .
Fish and Wild1ifeCoordinarion Act (16USCn661.666) ".
..'
'," ", . . ...,', ..'." ,"' '"' ..,", ,," ". ","" .: ,", ,'.... "'..... "".'" ::.: "':':"":-: ,':,' ,'-:".:.:-:,:"';' .:',:. .:.:' ,.
H~16302(g) requires coosultatioD betWeen agencies and the Fish and WildllieSeMCe When.'
, the modification or control or any stream or other water body is proposed. and requires adequate
,pro.visioo far protection of fisb and wildlift resources,. ,." " ,",.. ' ' ,',' "., ." "',',
STATE '
.
, State Antiquities Act (Utah Code Ann.. Title 63. O1apter 18, et seq.). Cultural resources requirements
, for areas of potential surface dmurbance., .. ' , ,,' , , ' . . '
TBCs
. .' .. .' . ,'" '. . . .
Salt ~ City Corporatioo (Salt Lake Ci1y:zonmg ~ce,~D21.66~010(33) and SeClioo "
21.66.040 (A). Tbis, ordinance regulates land use. The site is zoned M-1 and C-2. ",' ,
Salt Lake City/County Health Department. Health Regulations No.1, Solid Waste Management
Facilities. Utah Code Ann., Section 26-24-20. ' ' ' " ,
Salt Lake City Ordinance. Wastewater Control Ordinance/rules and Regulations, Title 37 Revised
Ordinances of salt Lake City. Regulations for direct and indirect coDUibutOtS to the POTW wastewater
system permit issuance and general requirements. Federal PretreatmeDt standards applicable and
numerical poDutant limitations specified in ordinance for heavy metals.
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There is no entirely objective method of evaluating cost-effectiveness because, ~.here is no
objective method of assigning a value to overall effectiveness. In addition, costs associated with
ineffectiveness may be difficult to quantify. The cost of the Selected Remedy is seen to be
relatively low with respect to the cost of each of the individual alternatives evaluated. The
Selected Remedy provides the greatest long-tenn effectiveness and overall protection of human :
health and the environment of all the alternatives evaluated. Therefore, the Selected Remedy'
appears to be cost-effective.
Utili7.ation of Permanent Solutions and Alternative Treatment (or Resource RecoveQ')
Technologies to the Maximum Extent Practicable (MEP)
The Selected Remedy will utilize containment to address the principal threats at the site.
Exposure to windblown dust and direct contact with waste CKD will be eliminated, by removing
the waste CKD from approximately 71 acres of industrial (commercial) land where it is also a
source of ground water contamination. Although four alternatives, (Alternatives 11, 12, 13 and
13A), involving treatment and/or reuse as a resource were studied in detail, they were not
considered to be viable alternatives' for remediation of the Site. For the two alternatives
involving treatment, (Alternatives 11 and 12), the pennanence of the solidified waste CKD. its
long-tenn physical stability. and its ability to resist leaching were not demonstrated. For the two
alternatives that proposed reuse of the waste CKD as a resource, (Alternatives 13 and 13A), Lone
Star Industries was not able to identify or develop any markets for the waste CKD.
The most decisive factor in the selection decision was the good perfonnance of the
Selected Remedy when evaluated with respect to long-tenn effectiveness and permanence. Waste
CKD is a hazardous substance under CERCLA because of its alkalinity in an aqueous environ-
ment, and the trace metals it contains. It is also very long-lived in the type of envirorunent that
exists at the site.
The waste CKD is currently located in an area targeted for significant future development
which will result in greater population exposure to the hazards of the waste CKD. The State of
Utah and the local community have expressed concern that the remedial alternative selected
permanently eliminate the pathways of exposure of the community to the waste CKD. Two
treatment options were evaluated that would reduce the mobility of the waste CKD by
solidification using Portland cement or fly ash as solidifying agents. However, the long-tenn
stability and effectiveness of these alternatives is not well demonstrated. There is concern that
the solidified waste CKD would deteriorate under conditions of extreme pH, and continue to be
a source of contamination of ground water through leaching in the long-tenn. The solidification
alternatives were higher in cost than most other alternatives.
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Disposal in a double-lined industrial landfill would not reduce toxicity, mobility, or
volume through treatment. but would isolate the waste CKD from the potentially exposed
population and the environment. Although the physical removal of the chromium-bearing
refractory kiln brick (which is a hazardous waste) from the waste CKD does not strictly meet the
defInition of treatment in the new National Contingency Plan, the removal of that brick will
significantly reduce the concentration and/or potential for leaching of chromium from the brick .:
into the waste CKD. Additionally, subsequent operable unit(s) for the site will address treatment
and disposal of the chromium bricks.
One of the most important long-tenn advantages of the Selected Remedy is the relatively
low impact at a relatively isolated disposal site for maintenance and repair activities to the
landfill structure. On-site maintenance and repair may be made increasingly difficult as the site
area becomes more highly developed. Replacement of a liner would be significantly more
difficult to accomplish and would involve greater risk to the surrounding community in a
developed urban setting than the disposal area of the Selected Remedy.
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11.
DOCUMENT A TION OF SIGNIFICANT CHANGES
Since the Revised Proposed Plan. the RCRA rule, "Land Disposal Restrictions for the
Third ll1ird Schedule of Hazardous Waste," was promulgated. Land disposal of chromium
hazardous waste above the specified treatment level is prohibited. Thus, this rule requires the
treatment of the chromium bricks prior to land disposal. Except for the "No Action" Alternative,:
the alternatives described in the Revised Proposed Plan required the separation and disposal of
the bricks at a RCRA Subtitle C faciliyy. However, due to the treatment requirement, the
chromium bricks will be separated and temporarily stored under this operable unit. Treatment
and disposal of the chromium bricks will be addressed in the subsequent operable unlt(s).
The method and effectiveness of the chromium brick treatment, is dependent upon the
concentration of chromium and other constituents in the bricks. Thus, a treatability study needs
to be conducted before the treattnent and disposal of the bricks is addressed in the subsequent
operable unit(s). As previously stated, the chromium bricks will not be transponed and disposed
at a RCRA Subtitle C facility under this operable unit, but will be addressed in a subsequent
operable unit(s). The cost differences resulting from this change, have been explained in
Chapters 7 and 8.
The Preferred Alternative described in the Revised Proposed Plan included a Contingency
Remedy. The Contingency Remedy is not a pan of this Record of Decision, because the Selected
Remedy is irnplementable.
Lastly, since this remedial action for Operable Unit 1, is not the final remedial action for
the site. the excavated areas of the site will not be filled and graded. Subsequent operable unit(s)
will address any remaining contamination and reclamation at the site.
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PORTLAND CEMENT CO. (KILN DUST #2 & #3)
SALT LAKE CITY, UTAH
RESPONSIVENESS SUMMARY
OVERVIEW: There has been considerable cornmunity interest and participation in public
meetings for the RIIFS and the Initial and Revised Proposed Plans for this site. The PRPs have:
also been active participants in the community relations process. Community involvement may
be high, in part, because this and another local Superfund site (Sharon Steel) have received
significant media attention. Similar issues are involved at both sites. Recent community
relations activities for this site are summarized in an attachment to this ROD.
The Preferred Alternative for Operable Unit 1 is Alternative 7C-Excavation and Disposal Off-Site
in the Vicinity of the Salt Lake Valley Landfill. This alternative involves the excavation of all
waste CKD from the site, and its transportation to and disposal in an off-site, state approved,
non-commercial, double-lined, nonhazardous industrial landfill to be constructed in the vicinity
of the existing Salt Lake Valley Landfill at approximately 1300 South and 7200 West in Salt
Lake City, Utah. All chromium-bearing refractory kiln brick will be removed from the waste
CKD and temporarily stored on-site. Treatment and disposal of the bricks will be addressed in
a subsequent operable unit. Excavated areas on the present site will be restored to prefilled
contours through the placement of bankrun fill materials during a subsequent operable unit(s).
Two different Proposed Plans were released for this site. The Initial Proposed Plan, released on
October 16, 1989, identified off-site removal of waste CKD as its Preferred Alternative. Off-Site
removal of waste CKD would have been accomplished using either or a combination of the
following two methods: (l) disposal, with or without treatment, at an off-site location that is
acceptable to the State of Utah and EPA, and/or (2) reuse as a resource. The public comment
period on this plan was from October 16, 1989 through November 6, 1989.
Because the Initial Proposed Plan did not identify a specific area or site for off-site disposal of
waste CKD, the State of Utah developed a second Proposed Plan known as the Revised Proposed
Plan, which was released 00 March 26, 1990. The "reuse as a resource" option in the Initial
Proposed Plan has been deleted from the Revised Proposed Plan because Lone Star was unable
to identify any viable options for the waste CKD. The 60-day public comment period on this
plan (which included a 30-day extension to the public comment period granted by EPA) ended
on May 26, 1990. The Revised Proposed Plan identified Alternative 7C, Excavation and
Disposal Off-Site in the vicinity of the Salt Lake Valley Landfill, as its Preferred Alternative.
It also identified a Contingency Alternative (Alternative 6-Excavation and Disposal On-Site)
which would be implemented for the site in the event the State of Utah and EP A determined that
the State of Utah's Preferred Alternative cannot be implemented. The Preferred Alternative
(Alternative 7C) became the Selected Remedy in this Record of Decision.
Citizen awareness and concern regarding this site has strongly influenced the government's
decision to recommend a remedy that would remove the waste CKD from the site. The local
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community strongly supponed the Preferred Alternative in the Initial Plan. The community
r~~nse for the Preferred Alternative and the-Contingency Alternative in the Revised ,Proposed
Plan reflected a mixed reaction. Lone Star Industries favored implementation of Alternative' 5 -
Consolidation of waste CKD on the West Site. One or the two principal owners of the present
site expressed suppon for the Preferred Alternative, but not for the Contingency Alternative.
Mayor Palmer DePaulis of Salt Lake City objected to the Contingency Alternative (Alternative
6 - Excavation and Disposal On-Site) and to Alternative 5 involving the consolidation and
encapsulation of waste CKD on the present site, but'" reluctantly agreed to the in1plernentation of
the Preferred Alternative (Alternative 7C) if other isolated off-site disposal areas are not possible.
Residents near the present site favored the Preferred Alternative. Residents of two communities
(Magna and West Valley City) nearest the new landfill site described in the Preferred Alternative
object to the Preferred Alternative, primarily because of concerns (1) regarding fugitive dust from
the construction of the new landfIll, (2) possible contamination of ground water, and (3)
interference with the future construction of 7200 West Street.
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BACKGROUND ON COMMUNITY INVOLVEMENT
Many of the members of the community moSt active in organizing public a~'areness of
the site have lived or worked in the area for many years. Community interest in waste CKD
dates to the 1950's, when the Portland Cement Company plant did not control air emission of
CKD from its cement production plant. WaSte CKD deposition was reportedly heavy in the
waste vicinity of the plant located in Salt Lake City, but was considered to be primarily a :
nuisance. Owners of the present site accepted the waste CKD as fill material until the end of
1983. Until the site was proposed for the National Priorities List in 1984, there was little public
awareness of the potential health hazard of the dust. General public awareness in envirorunental
hazards has increased recently, with some of this awareness translating into reluctance to locate
a business or induStry near a current or former waSte site. A number of public commenters living
near the present site identified lost property values, loSt tax base, or lost development opportunity
as contributing to their preference for a remedial alternative that removes the waSte CKD from
the area.
During the public cornment period for the RIlFS, the government received comments
focusing on the health effects of the waste CKD, the need to remove the waste CKD from the
site area, and the need to prevent the contamination of ground water.
Prior to and during the public comment period for the Revised Proposed Plan, Salt Lake
City officials, particularly Mayor Palmer DePaulis' office, showed considerable attention to this
project and were involved in a number of discussions with the State of Utah involving possible
remedial actions for the site.
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SUMMARY OF PUBLIC COMMENTS AND THE STATE OF UTAH'S RESPONSE
Comments presented during the Ponland Cement Co (Kiln Dust #2 & #3) public comment
periods on the Initial and Revised Proposed Plans are summarized briefly below. The public
comment period from the Initial Proposed Plan was held from October 16, 1989 through.
November 6, J 989 and the public comment period for the Revised Proposed Plan was held from'
March 26, 1990 through May 26, 1990. The comments are categorized by relevant topics.
Commenters were generally divided between (1) those who preferred removal of the waste
CKD from the site followed, by off-site disposal in an isolated, off-site location, and (2) those
who preferred construction of an on-site disposal facility. Lone Star Industries and its
representatives preferred on-site disposal and questioned the implement ability and cost
effectiveness of the Preferred Alternative. Lone Star Industries also questioned the adequacy of
the govenunent's compliance with CERCLA in the selection of the Preferred Alternative and
Contingency Alternative for the site.
Summary of Public Comments Received for the Initial Proposed Plan and Government's
Response.
Selection of Remedy Process under CERCLA
1. Lone Star Industries, through its representatives (including PSM International, Inc.; Dames and
Moore; and Pillsbury, Madison and Sutro), commented that CERCLA requires that the
Preferred Alternative be one of the alternatives evaluated in the Rl/FS, and that the State's
Preferred Alternative was not evaluated in the RIIFS.
Response: The EP A's Interim Final Guidance on Preparing; Superfund Decision Documents
indicates that the alternatives developed, screened, and analyzed in the Feasibility Study
constitute the basis for the selection of the response action. However, there is no requirement
that the Preferred Alternative be one of the alternatives described in the FS. The government
believes that adequate information has been generated during the RIIFS to form the basis for
selecting the Preferred Alternative, a hybrid of the alternatives presented in the FS, and
evaluated in an addendum to the FS. The Initial Proposed Plan is a public panicipation
document which enables the State and the EP A to evaluate community acceptance of the
Preferred Alternative, and to modify the Preferred Alternative, if necessary, before selecting
a remedy in the ROD. At the time of the issuance of the Initial Proposed Plan, the
community, including elected representatives and agency officials, almost unanimously
indicated a preference for the Preferred Alternative. With the issuance of the Revised
Proposed Plan, community and elected representatives remain committed to moving the waste
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CKD off-site but there is opposition from the community of Magna and West Valley City (the
communities nearest the offsite disposal site) and elected representatives to the off$i,te location.
2. Clean Sites, a non-profit organiiation retained by Lone Star Industries, Inc. to perform a
review of the Initial Proposed Plan, asked when the remedy (off-site location for disposal of
the waste CKD) would be better defmed.
ReSDonse: The off-site location has been specified in the Revised Proposed Plan. The
Preferred Alternative includes components that will require further design to ensure their
implement ability but such an evaluation will occur during the Remedial Design phase.
Remedial Action Preferences
3. Lone Star Industries and their representatives preferred on-site disposal Alternatives 5 and 6.
They felt that Alternative 5 was the most cost-effective alternative and that both Alternatives
5 and 6 performed as well as Alternative 7 against the EPA's balancing criteria.
ResPonse: The government considered the trade-offs between the alternatives and decided
that off-site disposal is the most protective of human health and the environment, best fulfills
the statutory preference that treatment of the waste be used to the extent practicable, and is
cost effective. Cost-effective, as described in the ROD, does not mean least cost. Two major
advantages of off-site disposal justify additional cost. The fust is that it would move the
waSte away from a more urban to a less urban environment. The location of the disposal
facility is important since uncertainties in the effectiveness of any engineering design increase
with time, and maintenance of the disposal facility can be more easily accomplished. The
second advantage is that remediation and future protection of ground water, which will be
addressed in subsequent operable unit(s) can be better accomplished if the waste CKD is
removed from the site.
Since issuing the Initial Proposed Plan, the State of Utah has discovered that the estimated
costs presented in the FS for Alternative CKD/5 were incorrect due to computational errors
made by Lone Star. Those incorrect costs, which were substantially lower than the actual
estimated costs, showed a present value cost of $6.01 million, a capital cost of $6.14 million,
and annual operation and maintenance cost of $6,000 for a 30-year period. Corrected costs for
Alternative CKD/5 provided by Lone Star Industries show a present value cost of $8.39
million, a capital cost of $9.14 million, and annual operation and maintenance costs of $5,000
for a 30-year period.
Finally, as discussed above, community' acceptance of either of the two containment
alternatives is very low. The government cannot ignore the great preponderance of support
for an off-site disposal remedy that has been expressed by the community.
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Technical Concerns/Questions Regarding RemedialAlternath'es
4. Mark Schultheis of Dames and Moore, speaking as a consultant for Lone Star Industries,
commented that transporting the waste a distance of 40 miles to the Tooele County site would
increase the amount of dust, and increase the incidence of traffic accidents. He also
commented that the quarry is not pennitted to receive additional waste CKD.
Response: The government intends to carefully monitor the removal and transport activities
to ensure that the public is adequately protected during the implementation period. This may
include implementing methods of reducing traffic-related risks. During the Remedial Design
process, the State and local agencies will work together to ensure that adequate protective
features are built into the disposal site design. The government fully intends to take into
account concerns of the community where the disposal site is located.
5. Mr. Matt Trujillo, representing the Tooele County Health Department, said that he strongly
opposed Alternative 7 of the Feasibility Study, which is identified in the Initial Proposed Plan
as an example of the type of off-site disposal option preferred by the State. He commented
that the on-site disposal of the 360 tons of chromium would be detrimental to the health of
Tooele County residents, and expressed the Tooele County Health Department's concerns
about ground water and air contamination at the Quarry #3 site. Finally he indicated that the
County feels that there are existing facilities that could accept waste CKD.
Response: The government intends to consider the concerns of the local community in the
design and location of the disposal facility.
The 360 tons of refractory kiln bricks, which contain chromium and are hazardous waste will
be separated and treated prior to disposal. Each of the alternatives considered in the
Feasibility Study, except the "No Action" Alternative, include the same disposal requirement
for the chromium-bearing refractory kiln brick.
7. One of the property owners near the site, Mr. George Dawson, suggested leveling the mounds
of waste CKD around the perimeter of the site and treating the waste CKD with a stabilizer
to prevent blowing dust during periods of high winds.
Response: The State requested that Lone Star construct a fence around the perimeter of
the site to prevent trespassers from entering the site and coming into direct contact with the
waste CKD. In order to construct the fence, earthmoving equipment was used to move some
of the waste CKD within the site perimeter. This resulted in additional mounding of the waste
CKD and soil inside the perimeter fence. The fencing plan for the site agreed to by Lone Star
Industries states that; "Any contaminated soil that is removed for dike construction will be
placed inside the dike areas in a stable configuration. All disturbed or newly created slopes
will also be left in a stable configuration". The State Bureau of Air Quality has also been
monitoring the application of a'dust stabilizer to reduce dust emissions. To be effective, the
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waste CKD must be treated with the stabilizer at frequent intervals. The government will
investigate the problem and may recommend additional action.
8. Mr. George Dawson also raised several issues regarding the site and cleanup: (1) he
suggested that some sort of health testing of residents should be initiated, (2) he asked what
the short and long-term effects of the site on ground water would be, (3) he asked about the
cost to taxpayers, (4) he asked who is responsible for the cleanup of bordering properties .:
contaminated by the waste CKD.
ResPonse:
(I) No health testing is proposed under any of the alternatives identified for the site. Air
monitoring will be conducted during the implementation of the remedial action to ensure that
particulate levels are kept within State and Federal standards, and protective measures will be
implemented to minimize the potential health risks to the public during the cleanup.
(2) Remediation of the waste CKD at the site will eliminate the source of soil and ground
water contamination and will enable the remediation of same. Groundwater will be addressed
with a separate remedy in a selection process 1 ike the one used to select a remedy for the
waste CKD. Meanwhile, the ground water at the site is being monitored and the results of
this study will help to form the basis for a set of recommendations on how best to remediate
the ground water.
(3) The cost of the cleanup of the site is paid by the parties found to be legally responsible
for it. Under the Superfund law, tax money is not used to cover the cost of investigation or
for cleanup of sites, unless the PRPs refuses to undenake the remedial action described in the
ROD for the site. In that circumstance, EPA could order the PRPs to undertake the cleanup
at the site or undertake the designated remedial action for the site with Superfund monies, then
seek to recover those costs from the PRPs through court action after the cleanup.
(4) All of the waste CKD that is identified at the site will be excavated and removed under
the Preferred Alternative. It is difficult to identify small amounts of CKD that have been
mixed with soil. The extent of waste CKD contamination is discussed in detail in the
Remedial Investigation repon.
9. One of the commenters. representing a property owner adjacent to the site whose property is
affected by the waste CKD. expressed a concern about how the restoration of the site would
be accomplished. indicating that the waste CKD had caused water to pond behind his property.
ResPonse: Following removal of the waste CKD, the site will be filled with clean bankrun
fill. graded. compacted and restored to its original contours. The drainage of the soil will be
vastly improved because the permeability of normal soil is much greater than the permeability
of waste CKD.
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10. A commenter suggested that the waste CKD be removed to the west desert by railroad.
ResPOnse: The use of railroad cars to transport the waste off-site was investigated in the
Feasibility Study and found to be more expensive than transport by truck. This was because
loading and unloading of rail cars would require additional handling of the waste. The
proximity of a rail line to an existing or potential disposal site is therefore a critical factor.
Summary of Public Comments Received for the Revised Proposed Plan and the Government's
Response
Selection of Remed)' Process Under CERCLA
1. Lone Star's representative, Mallory May of PSM International, commented that 40 CFR
300.68(h) requires the lead agency to choose one remedy for cleaning up this site, but in fact
the State selected two remedies for that purpose.
ResPonse: In the Revised Proposed Plan, the government identified both a Selected
Remedy and a Contingency Remedy for this site. The Contingency Remedy would be
implemented fQr the site only if the State of Utah and EP A detennine that the Selected
Remedy cannot be implemented. EPA guidance on preparing Proposed Plans and RODs
(Interim Final Guidance on Preparing Superfund Decision Documents, July 1989, pages 9-15
through 9-21) clearly indicates that Contingency Remedies may be identified in those
documents.
In any event, the Record of Decision designating the Selected Remedy has deleted this
Contingency Alternative since the government believes the Preferred Alternative can be
inlplemented.
2. Lone Star representative, Mallory May, commented that Alternative 6 will cost several million
dollars less than Alternative 7C.
ResPOnse: The government does not agree with this comment. The present value cost of
Alternative 6 is $11,405,000 and the present value cost of Alternative 7C is $12,518,143 for
a difference of $1,113,143. Lone Star's original estimate of $13,342,000 for Alternative 7C
was c9rrected to the above, lower figure when the State discovered computational errors in
Lone Star's analysis. In addition, the State of Utah has reviewed the August 18, 1989 cost
estimates for Alternative 6 and the March 20, 1990 FS addendum cost estimates for
Alternative 7B and 7C and has concluded that the costs for Alternative 6 are underestimated
when compared to costs for Alternatives 7B and 7C. Alternatives 7B and 7C include costs
for items which are excluded from Alternative 6, but will be required.
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3. A comment was made that waste CKD is an exempt waste and therefore should not be
addressed under CERCLA.
ResPonse: Even though waste CKD is specifically exempt from being a hazardous waste
under RCRA, waste CKD is regulated under CERCLA because it contains hazardous
substances. The hazardous substances found in waste CKD are lead, arsenic, zinc, cadmium,
and chromium.
4. State Representatives Daniel H. Tunle and Brent H. Goodfellow commented that a public
meeting needed to be scheduled for the town of Magna and West Valley City to discuss the
State's Preferred Alternative.
ResPonse: A public meeting to inform the residents of Magna and West Valley City
concerning the Preferred Alternative was held on June 21, 1990 at 7:00 pm in the Cyprus
High School Auditorium in Magna.
Remedial Action Preferences
1. Senator Wilford R. Black, Minority Leader in the Utah State Senate, commented that it would
be a much better solution to move the waste CKD from the site to the commercial hazardous
waste disposal site (USPCI) in Tooele County.
ResPOnse: Disposal of waste CKD from the site at the commercial USPCI hazardous waste
disposal facility in Tooele County was considered in the FS (Alternative CKDI8), but was
screened out in the repon from funher detailed analysis because of the magnitude of the cost.
Disposal of the waste CKD in an industrial cell at the USPCI facility was estimated to cost
$55 million and disposal of the waste in a RCRA Subtitle C facility at USPCI was .estimated
to cost $120 million.
2. Magna resident, Pamela R. Derbidge, objected to having the waste CKD disposed of in the
Salt Lake Valley Landfill or anywhere in the Salt Lake Valley.
Response: The Preferred Alternative (Alternative 7C) involves disposal of the waste CKD
in an industrial landfill to be constructed in the vicinity of the Salt Lake Valley Landf1l1
located near 7200 West and 1300 South in Salt Lake City. The Preferred Alternative was
identified only after careful evaluation of all possible alternatives. Two other alternatives that
were not selected, Alternatives 7 A and 7B, involve the excavation and off-site disposal of
waste CKD in Tooele County. The Tooele County Commission advised the State of Utah that
Alternative 7A, which involves disposal of waste CKD at the Aux Quarry Site in Tooele
County is not acceptable and consequently not implement able or viable because it is not
within Tooele County's Hazardous Industries Zone. In addition, Lone Star's March 20, 1990
addendum to the FS indicates that Alternative 7B, which involves disposal of the waste CKD
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at a noncommercial site within the Tooele County Hazardous Industries Zone, could not be
r~adi1y implemented because of complexities and uncertainties presented by the", propeny
acquisition and permitting process.
3. Salt Lake City Mayor Palmer DePaulis expressed the desire to further discuss and negotiate
with the Tooele County Conunission on the use of the Aux Quarry Site near Grantsville for
disposal of the waste CKD.
ResPonse: The Utah Bureau of Solid and Hazardous Waste arranged a meeting between
Mayor Palmer DePaulis and the Tooele County Commission for further discussion on the
possible use of the Aux Quarry Site for disposal of the waste CKD. That meeting was held
on May 11, 1990.
4. Lone Star representative Mallory May commented that since the Revised Proposed Plan
indicated the Contingency Alternative is also considered to be protective of human health and
the environment, the State should select a remedial alternative that does not require off-site
transportation of the waste CKD. '
Response: While it is true that EP A prefers site remediations which do not involve the off-
site transportation of wastes, each site must be evaluated on its own merits. In this
instance the government considered the highly urbanized location of the present site and the
greater permanence and long-term safety offered by an isolated, off-site industrial landfill
constructed for the waste CKD to be compelling reasons for selecting the off-site remedy.
5. Mallory May, a Lone Star representative with PMS International, commented that there was
not sufficient justification for choosing Alternative 7C as the Preferred Alternative over
Alternatives 5 or 6.
ResPOnse: Alternatives 5 and 6 are similar in some respects since both involve the on-site
consolidation and disposal of waste CKD on the West Site. Although Alternative 5
(Consolidation of Waste CKD on the West Side) involves construction of a layered cap over
the waste CKD, there is no bottom liner provided that would eliminate concerns for long-term
leaching of waste CKD contaminants into the groundwater. Alternative 6 (The Contingency
Alternative - Excavation and Disposal On-Site) involves contaimnent of the waste in a double-
lined industrial landfill that would eliminate direct contact and fugitive dust, and protect the
ground water and surface water at the site.
The Preferred Alternative (Alternative 7C- Excavation and Off-Site Disposal in the vincinity
of the Salt Lake Valley Landfill) would be as equally protecuve of human health and the
environment as Alternative 6. However, in addition, and for only a slightly higher cost, the
Selected Remedy will provide greater long-tenn permanence and safety because the new, off-
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site disposal landfill will be removed from its present urban sening and located in an isolated
area, adjacent to other industrial, demolition and municipallandfllls near an area identified and
set aside by Salt Lake City for the construction of waste landfills. ' "
6. A number of Magna residents commented in a petition-like lener, that it is short-sighted to
place hazardous materials near growing population centers because it would most likely need
to be relocated again in the near futUre.
Response: The Preferred Alternative was selected using nine criteria established by EPA
and was judged to be the most protective of public health and the environment and the most
permanent. The new landfill will be located near other similar municipal and industrial waste
landfills, and will be constructed so as to be permanent, with no intentions or plans for
eventual relocation.
7. A number of Magna residents commented that they oppose moving the waste CKD to the Salt
Lake Valley Landf1l1 area within one mile of seven residential dwellings. They prefer instead,
that the waste CKD be transported to the Hazardous Waste Industries Zone in Tooele County
for disposal or left at its present site near Redwood Road in Salt Lake City.
ResPOnse: These comments have been addressed in other responses, but are restated in
brief here. The Preferred Alternative was judged to be the most protective of public health
and the environment and the most permanent of all the alternatives considered. Tooele
County will not allow the waste CKD to be disposed outside of the commercial hazardous
waste facility within its Hazardous Waste Industries Zone. Although the State has identified
on-site disposal (Alternative 6) as its Contingency Alternative, the government regards the
alternative as second best because it is less permanent and because the on-site landfill would
be located in a highly urbanized area.
8. A Magna resident suggested that the Portland Cement Company Waste CKD should be
combined with the Sharon Steel Midvale Tailings in developing a remediation for both
CERCLA sites simultaneously.
ResPonse: This alternative was not presented or considered in the Feasibility Study
prepared by Lone Star Industries. First, technical or economic advantages would be necessary
for combining the tWo wastes. Those advantages are not immediately obvious. Second, the
owners of Sharon Steel would need to accept the waste CKD as a pan of a plan for
remediation of the Midvale Tailings. Since there are liabilities associated with Superfund
Wastes, it does not appear likely, at first hearing, that the owners of Sharon Steel would allow
the waste CKD to be combined with Midvale Tailings.
9. R. Steve Creamer, President of the East Carbon Development Company, commented that the
waste CKD could be disposed in the East Carbon Development Landfill Cell #7, which is a
commercial waste disposal facility.
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ResPonse: Incomplete, non-detailed estimates for that disposal, which did not include
overhead and contingencies, showed a cost of $22.8 million for this recently.. proposed
alternative. The government believes that actual cost for this disposal would range betWeen
$25 and $30 million. This alternative was not presented or considered in the FS. The
expected cost of $25 to $30 million far exceeds the highest cost ($18.6 million) of the
alternatives considered in the FS and is approximately $12.5 to $17.5 million greater than the
cost of the Preferred Alternative, which is $12.5 million.
Technical Concerns/Questions Regarding Remedial Alternatives
1. Mark Goodmansen of Uintah FreightWays (located at 1030 South Redwood Road, Salt Lake
City) cornmented that the trucking company needs unrestricted access north and south on
Redwood Road from their entrance. The trucking company is concerned about traffic access
to the site during remediation efforts, and particularly access from Redwood Road which could
negatively impact their operations and pose safety problems due to the heavy flow of traffic
on Redwood Road. The trucking company suggests access to the site using Indiana A venue
and a road through the Williamsen's land holdings. .
ResPonse: Access to the site during remediation, and particularly truck traffic to and from
the site, will need to be conducted in a manner that will create the least impact and greatest
safety for local highway traffic. Site access details will be detennined during the Remedial
Design phase for cleanup of the site. Those details will be decided only after consultation will
Salt Lake City Traffic Department and the Utah Department of Transportation.
2. Mayor Palmer DePaulis of Salt Lake City commented that if the waste CKD from the site is
disposed in a landfill on the West Site of the present site, it would be almost impossible for
Salt Lake City to develop around the landfill waste.
ResPonse: The government agrees that it would be difficult to design future industrial
development around the landfIll waste CKD on the West Site. The height of the on-site
landfill may also impart an unusual and detracting view in the residential and industrial seeting
of the area.
3. Councilman Wayne Horrocks of the Salt Lake City Council commented that isolation of the
CKD on the West Site of the present site would deprive Salt Lake City of many acres of land
that are highly developable.
ResPonse: The governrnent agrees that the implementation of Alternative 6, Excavation
and On-Site Disposal, would porobably eliminate forever the development of prime industrial
land in an already highly urbanized area.
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4. Lone Star Industry representative Mark Schultheis commented that much of the land in the
vicinity of the Salt Lake Valley Landfill- recently evaluated by Dames and Moon: at the
request of the State of Utah would be defIned as either wetlands or special aquaiiC areas.
ResPonse: The government agrees that much of the land in the vicinity of the Salt Lake
Valley Landfill recently evaluated for developing Alternative 7C appears to be either wetlands
or special aquatic areas. Hwever, the determination has been made by EPA, based on existing:
information for the area and on two recent reconnaissance reports of the area, that more than
sufficient land exists in the area evaluated in the vicinity of the Salt Lake Valley Landfill, that
is neither wetlands nor special aquatic areas, for the implementation of the Selected Remedy
(Alternative 7C).
5. Lone Star representative Mark Schultheis commented that the State of Utah has not adequately
investigated the environmental suitability of the area in the vicinity of the Salt Lake Valley
Landfill for the disposal of waste CKD.
ResPonse: This area is the site of the largest, currently operating landfill in the Salt Lake
Valley. Many other landfills are located in this area, some of which have been closed and
others that are presently operating, including the following: Salt Lake City/County Landfills
Parcels 1 and 2, Mackay Landfill, Bland Landfill, and E.T. Technologies Landfill. The later
facility accepts industrial wastes. The area in the vicinity of the Salt Lake Valley Landfill is
the only area in the Salt Lake Valley where zoning exceptions are presently granted for waste
disPQsal landfills. Numerous hydrogologic investigations and other studies have been
conducted for the landfills in the area.
Lone Star's recent evaluation of land in the vicinity of the Salt Lake Valley Landfill was for
the purpose of developing Alternative 7C- Excavation and Disposal Off-Site in the vicinity
of the Salt Lake Valley Landfill. That evaluation became part of the March 20, 1990
addendum to the FS, and contained the same level of detail provided for the other altematives
presented in the FS. The level of detail presented for the alternatives in the FS appears to be
consistent with the requirements in the EP A "Guidance for Conducting Remedial
Investigations and Feasibility Studies Under CERCLA", Interim Final, October 1988.
6. Lone Star consultant Mark Schulthies, with Dames and Moore Incorporated, commented that
in order to transport the half million tons of waste CKD from the present site to a new landf111
nine miles away (near the Salt Lake Valley Landfill), it would require about eight to ten
trucks an hour, eight hours a day, fIve days a week, for two years.
ResPonse: The RIlFS reports prepared by Dames and Moore indicate there are
approximately one-half million cubic yards, not tons, of waste CKD on the site. Information
provided by Lone Star indicates that waste CKD has a weight/volume ratio of approximately
1755 lbs. per cubic yard.
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Considerably fewer haul trips would be needed during the two year period if 12 cubic yard
dump trucks with 6 cubic yard pup trailers- were used for the off-site transport of \y~ste CKD.
Assuming 18 cubic yards per haul load, between 6 and 7 trucks per hour could transport. the
waste CKD over the same period. In lieu of reducing the number of 18 cubic yard loads per
hour, the estimated two year period for transporting the wastes off-site could be shortened to
less than one year if 10 loads per hour were made as suggested in Mark Schultheis's above
comment.
7. Lone Star consultant Mallory May commented that the FS does not address the risk associated
with the transport of thousands of loads of waste CKD to the vicinity of the Salt Lake City
Landfill over a period of two years.
ResPonse: Comments submitted November 6, 1989 by Lone Star's attorneys Thomas P.
O'Donnell of Pillsbury, Madison & Sutro included an analysis for hauling the waste CKD a
round trip distance of 80 miles to the Flux Quarry Site in Tooele County. The analysis
assumed use of 12 cubic yard dump trucks, which required 41,000 round trips, for a total of
3,300,000 truck miles. Based on accident and injury rates provided by the Utah Department
of Transportation, 8 accidents and 16 injuries were estimated for the above transportation of
the waste.
Implementation of the Preferred Alternative (Alternative 7C) would involve hauling the waste
CKD a round trip distance of approximately 18 miles to the Salt Lake Valley Landf1ll. If 12
cubic yard dump trucks with 6 cubic yard pup trailers were used for this haul, a total of only
27,000 round trip loads and 495,000 round trip miles would be needed to move the excavated
waste CKD to the new industrial landftll. The round trip haul loads and round trip miles for
this site are considerably less than for Lone Star's above traffic accident analysis to the Flux
Quarry Site. Since the exact haul route to the Salt Lake Valley Landfill has not yet been
determined, (but will be determined during the RDIRA phase of this project) accident and
injury rates for hauling the waste CKD for this alternative cannot be calculated. However, it
appears that with the far fewer round trips and truck miles needed for hauling to the vicinity
of the Salt Lake Valley Landfill, the number of accidents and injuries will likely be less than
. those cited by Lone Star Industries for hauling to the more distant Flux Quarry Site. Accident
and injury rates for Salt Lake City Streets between the present Site and the Salt Lake Valley
Landfill are not readily available.
8. Mark Schultheis of Dames and Moore commented that although the waste CKD with
Alternative 5 would be consolidated and capped on the West Site, development of the West
Site would still be possible, although it might be limited to uses that would not disturb the cap
over the waste CKD, and may include warehouses. parking lots, truck terminals, and other
shallow footing developments.
ResPonse: The example provided in the above comment of possible future uses of the
consolidated. capped waste CKD on the West Site appears to be an overstatement of
information already presented in the FS. That information indicates that deed restrictions to
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prevent cap disturbance would prevent actions such as foundation footings that may penetrate
the cap, and site grading that would affe.ct the cap. The examples provided in the ahove
comment, including truck traffic over the underlying, uncompacted waste CKD, appear to be
unacceptable and incompatable with capped CKD wastes on the West Site.
9. Marlene Norcross of the Magna City Council wondered about the period of time necessary
to implement the Preferred AJternative (Alternative 7C) because she is concerned about
fugitive dust exposure to Magna residents living south and west of the new landfill area on
2100 South and 8000 West.
Response: The Preferred Alternative will be implemented in approximately five years.
Land acquisition and landfill design, permitting, and construction will require approximately
three years. Excavation, transportation, and placement of the waste CKD in the new landfill
will be completed within tWo years.
Fugitive dust at the present site and at the new landfill site will be effectively controlled by
water sprays or other dust suppression techniques. Waste CKD placed in the new landfill will
be secured and covered in an ongoing procedure which will immediately eliminate fugitive
dust from the waste CKD. In addition, the State will require air monitoring for fugitive dust
at both the present site and the deposition site for the new, off-site landfill.
10. Mel Ingersoll asked what the definition of a wetlands is, and if the present Redwood Road
site would be considered as wetlands.
Response: The term "wetlands" means those areas that are inundated or saturated by
surface or ground water at a frequency and duration sufficient to support, and that under
normal circumstances do support, a prevalence of vegetation typically adapted for life in
saturated soil conditions. Through their biologically diverse and productive natural habitats,
wetlands provide all the vital elements necessary to nunure and sustain many species of
plants and animals important to humankind. In many cases, wetlands provide a place for
these species, not to be found anywhere else on the earth. "Wetlands" are regulated by the
U.S. EPA and the U.S. Army Corps of Engineers through Federal Regulation 40 CFR Pans
230,231,33 CFR Pan 323 (Discharge of Dredge of fill material into waters of U.S. - Section
404 Permits).
The Rl inidcated that most of the present site which has been f1lled with the waste CKD was
originally a low, poorly drained salt flat environment. Since the waste CKD was placed in
this area prior to the adoption of the Federal Wetland Standards, a wetlands evaluation of the
site in its prefilled state was never conducted. However, it appears likely, based on the above
description of the site, that at least some of the site would have been wetlands or special
aquatic areas if it had been evaluated under todays wetland standards. The Surplus Canal,
City Drain, and North Boundary Ditch are considered to be waterways of the U.S., and as
such are regulated under the Federal Dredge and Fill Requirements.
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11. Mel Ingersoll commented that if the on-site landfill (the Contingency Remedy- Alternative
6) wil1 he 30 or even 10, 12, or 15 feet deep (high), how will industrial corpplexes be
constructed on top of that landfill.
Response: The FS indicates that deed restrictions on landf1l1 disturbance would apply to
such actions as foundation footings that" may penetrate the landfill cap, and site grading that.
would affect the landfill cap. Slab-on-grade foundations or other actions that would not.
disturb the landfill cap would not be restricted. The government has some serious reservations
about the practicality of having buildings or other structures constructed on the elevated on-
site landfill. Although the engineering of some of the suggested structures (i.e. warehouses,
parking lots, and truck terminals) may be possible from an engineering viewpoint, as a
practical matter, such structures on the landflll appear to be inadvisable. This response is
similar to an earlier response in the Responsiveness Summary dealing with Alternative 5.
12. Mayor Palmer DePaulis of Salt Lake City commented that disposal of the waste CKD at the
Aux Quarry Site south of Grantsville in Tooele County, Utah would have no negative
environmental affects. .
Response: Although an evaluation of the Aux Quarry Site was conducted by Lone Star
Industries and included in the FS for their development of Alternative 7 A (Excavation and
Disposal Off-Site at the Flux Quarry Site in Tooele County), that evaluation does not show
conclusively that no negative environmental effects will result if the alternative is
implemented. Additional study of the site will be needed to arrive at that conclusion. No
bottom liner is proposed for this alternative and the fractured, fissured nature of the
limestone/shale quarries in the area would likely be conducive to leaching of contaminants
from the waste CKD into the underlying ground water.
13. K.W. Nelson, private citizen, commented that the use of institutional controls, both currently
and in the future, will greatly reduce the risk posed to future workers and trespassers and also
reduce dust emissions.
Response: In establishing and evaluating the baseline risk posed by a site, the Superfund
program does not allow for the inclusion of institutional controls. While institutional
controls may be considered as part of the remediation, they are generally not considered
permanent and therefore do not address future potential risks effectively. The baseline risk
assessment assumes a "No Action" Alternative and then calculates reasonable and maximum
risks posed by a site.
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14. K.W. Nelson, private citizen, commented that silicosis is unlikely to result from inhalation
of the materials found on-site due to low ..inhalation potential and infrequent exposure.
ResPonse: Historically, there has been minimal dust control and significant events of
blowing dust from the site have been documented. In addition, dust suppression as an
institutional control cannot be completely guaranteed into the future. Therefore there remains
the potential for sufficient dust to be entrained so as to cause adverse health effects.
15. K.W. Nelson, private citizen, commented that detailed and extensive air monitoring should
have been conducted so as to bener quantify the air exposure route.
ResPonse: On-site environmental data is generally the most representative of true
conditions at a given site. This data, however, can be extremely time consuming and
expensive to collect, therefore, a more efficient way to characterize the air pathway at this
site was used by modelling the expected emissions. Modelling efforts provide sufficient
infonnation in order to adequately characterize the air pathway for remedial decision- making.
16. K.W. Nelson, private citizen, commented that waste CKD is only a nuisance dust, not a
hazard.
ResPonse: waste CKD contains a variety of hazardous substances including arsenic,
chromium, lead, zinc, and cadmium. Due to the large volume of material present, the caustic
nature of that material, and the proximity of a residential area, waste CKD presents a
potential for future adverse health effects.
17. K.W. Nelson, private citizen, commented that the ground water under the site is unusable due
to poor background conditions.
ResPonse: Utah is an arid state where water resources can often be the limiting factor for
growth of an area. Therefore all water resources are valuable and worthy of protection.
While the water under the site may not be suitable as direct drinking water source, there are
a variety of other uses for the water, including irrigation, manufacturing, and blending with
other sources.
18. Mayor Palmer DePaulis of Salt Lake City commented that the landfill constructed on the
West Site for Alternative 6 would be over 30 feet high.
ResPonse: Depending on the shape of the landfill and the slope of the sides, the tOtal
height of the 25-acre, on-site landfill for Alternative 6, including the cover and liner
thicknesses, could reach 30 feet, but will probably be closer to 25 feet.
The industrial landfill to be constructed for Alternative 7C (the Selected Remedy) will also
occupy 25 acres and is expected to have the same total height of about 25 feet.
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19. Romney M. Stewan of the Salt Lake Valley Solid Waste Management Council expressed
concerns regarding the State's Preferred Alternative: (l) Since the property adjCJ~ent to the
new landfill site is owned by other entities, will adequate monitoring wells and other
necessary testing equipment be iristalled to protect those properties from a release, (2) The
nearby residents, landfLIl employees, and public need to be assured that fugitive dust from
the landf1l1 will be adequately controlled, (3) The site is not "isolated" since there are
residential dwellings within one mile of the new landfill site, (4) Because of the heavy traffic
flow to the landfLIl area, truck traffic to the new landfill site should proceed west along 1-80
to 7200 West, then south to the site, and (5) The State of Utah should obtain written
documentation from the agency responsible for protection of wetlands that the new off-site
industrial landfill under the State's Preferred Alternative will not be constructed in wetlands
or in an area that will impact wetlands.
ResPonse:
(1) A leak detection and monitoring system will be installed for the new double-lined,
industrial landfill.
(2) Fugitive dust resulting from the excavation, loading, transportation and placement of
waste CKD will be controlled at both the present site and the new off-site landfill by means
of water sprays and other dust suppression techniques. Air monitoring instruments will be
established near both sites to insure adequate dust suppression methods are used.
(3) The government feels that the site for the new landf1l1 in the vicinity of the Salt Lake
Valley Landf1l1 is "isolated" in the sense that it is "set apan" from areas of human habitation.
The new landfill would be constructed near other waste landf1l1s, for municipal and industrial
wastes, that are also isolated and set apart from human habitation. Although there are seven
residential dwellings located approximately one mile from the disposal area, those dwellings
are about the same distance from other existing landfills in the area. The relative risks
associated with the new landfill site are less than for the present site, which has a population
of 6,000 to 12,000 people within one mile of the site.
(4) The safest and most efficient haul route will be established by the Utah Department of
Transponation, and by the Salt Lake City Traffic Department if city roads are used.
(5) Based on wetlands evaluation repons prepared on the area by tWo environmental
consulting firms, EP A wrote Lone Star Industries on May 22, 1990 concluding that sufficient
uplands exist on tWo of the five parcels studied to allow development of a new industrial
landfill (25-30 acres) without impacting wetlands. Although both consulting finn reports are
considered at the "reconnaissance level", they offered sufficient level and quality of data for
EPA to arrive at this conclusion on the RIIFS phase of this project.
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20. Larry Argyle, President of the Magna Area Council, expressed several concerns regarding the
State's Preferred Alternative: (1) The preliminary wetlands evaluation by Ecotone
Environmental Consulting limits consideration of propeny adjacent to 7200 West and s9uth
of 1300 South to approximately 1700 South which is within approximately one-half mile of
seven families who are totally dependent on their private wells for their source of water, (2)
the new landfill for waste CKD should not be conStructed along 7200 west because a major
thoroughfare will be built along the corridor into Magna and West Valley City, (3).:
Commissioner Bill Pitt of Tooele County has indicated a willingness on the part of Tooele
County to accept the waste CKD within its hazardous materials zone, and has suggested
possible negotiations or land swaps of State and BLM land that could cut the cost of disposal
at the Tooele Site.
ResPOnse:
(1) The State requested that Lone Star evaluate land in a portion of Section 10 and in the
northeast comer of Section 16 near the Salt Lake Valley Landfill for possible disposal of the
waste CKD. Based on that evaluation, suitable property exists at a distance of one mile or
more from 2100 South. Since the new landfill will be double- lined and provided with leak
detection and monitoring systems, it will not impact the aquifer for the private wells serving
the nearest residents.
(2) Three landfills have already been constructed along 7200 WeSt. Two of those landfills,
Salt Lake County LandfIlls Parcels I and II are no longer in use and have been closed.
Neither of these landfIlls impart an unsightly appearance to the area in their closed, capped
state. Salt Lake County Landfill Parcel II, near the north border of Section 16 occupies 80
acres and is 30 feet high, making it both higher and larger than the new landfIll for the
waste CKD, which would occupy only 25 acres and be approximately 25 feet high. The
closed and capped condition of this higher landfill, in particular, enhances the relief and view
of the area. The Bland Landfill, located east of 7200 West, is a demolition landfill in
operation at the present time. Piles of debris awaiting burial are therefore frequently visible
from 7200 West road. The new industrial landfill for the waste CKD will not be built on
the corridor for the 7200 West Street, and will not impact in any way the construction of that
street. Finally, as a point of clarification, Mayor Palmer DePaulis' office in Salt Lake City
has informed the State that the 7200 West Street is not scheduled to be built for at least five
years.
(3) On May 11. 1990 Commissioner Bill Pitt met with officials of Salt Lake City and the
State of Utah on this issue. Although Commissioner Pitt indicated tl1ere were no
restrictions on disposing of the waste CKD in an industrial waste disposal cell at the USPCI
commercial facility in Tooele County. that alternative has been screened out earlier because
of its excessive cost (approx. $55 Million). Commissioner Pitt reiterated Tooele County' s
earlier position that (1) the Flux Quarry site is unacceptable for the disposal of waste CKD.
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and (2) Tooele County will not accept the waste CKD in the Hazardous Waste Industries
Zone if it will be outside the commercial hazardous waste facility. Lone ~t.ar's own
evaluation of this alternative (Alternative 7B) showed that it could not be readily
implemented because of complexities and uncenainties presented in the property acquisition
and pennitting process. .
21. Some Magna residents commented that (1) the implementation of the Preferred Alternative
would create an "eyesore" and either stop or hinder the construction of the 7200 West road
from the Magna area nonh to 1-80, and (2) Since the waste CKD has contaminated the
ground water at the present site, the waste CKD would defmitely contaminate the ground
water at the new landfill site near the Salt Lake Valley Landfill.
ResPonse:
(1 ) The government does not agree that the implementation of the Preferred Alternative will
stop or hinder the construction of 7200 West road. Other landfills already exist along the
7200 West corridor. Closed Salt Lake County Parcel II landfill is larger and higher than the
new landfill for the Preferred Alternative; in its capped state it is not an "eyesore", does not
detract from the view of the area, and its relief gives the appearance of a natural hill.
(2) Ground water beneath the present Redwood Road site for the Ponland Cement Co.
Superfund Site dust has been contaminated in pan because (a) the waste CKD was used as
fill in a naturally low area and has been in seasonal and/or continual contact with the ground
water 'for many years and (b) a deep, gravel encased, sewer alignment through the present
site also appears to have facilitated the contamination of the ground water on the site.
The industrial landfill under the Preferred Alternative will be completely contained with a
double bottom liner and a layered cap that will prevent contamination of ground water
beneath the site. A leak detection and ground water monitoring system will also be installed
to insure the integrity of the bottom liners and layered cap.
22. Brent Huish, District Manager of the Magna Water Company commented that (1) his
company draws some of its water from the Haynes Well Field located at approximately 5700
West 2100 South in Magna, Utah. Magna Water Company is opposed to the Preferred
Alternative because it believes that the aquifer from which the Haynes well field draws will
be compromised by off-site disposal of waste CKD near the Salt Lake Valley Landfill, and
(2) Magna Water Company believes that Alternative 11 (Solidification with Ponland Cement
and On-Site Replacement) would be a better Preferred Alternative and would cause less risk
of contanlination to the aquifer servicing the Haynes well field.
ResPonse:
(1) The new industrial landfIll constructed under the Preferred Alternative will be double-
lined and covered with a layered cap. These design features will prevent the inflltration of
precipitation into the landfilled waste CKD and the subsequent movement of the contaminated
leachate into the underlying ground water. In order, to insure the integrity of the bottom liners
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and the layered cap, leak detection and monitoring systems will be developed for the landfill.
Consequently, contamination of the groundwater beneath the landfill will not occur. In
addition, the site for the new noncommercial, industrial landfill is located hydrog~ologically
downgradient from the area of the Haynes Well Field.
(2) The government devoted a great deal of attention and study to Alternative 11 and 12
(solidification respectively with Ponland Cement and Fly Ash). Unfonunately, these
alternatives were not considered viable because the performance of the solidified waste CKD,
its long-term physical stability, and its ability to resist leaching into ground water over time
were not demonstrated by Lone Star Industries.
23. Lone Star consultant Mark D. Schultheis of Dames & Moore commented that: (1) The
presence of seven CERCUS sites in the vicinity of the Salt Lake Valley Landfill raise the
possibility that those propenies being considered for the construction of the new landf1l1 under
the Preferred Alternative may already be affected by contamination from a CERCLIS site, and
(2) A present value coSt of $13,342,000 was cited for Alternative 7C, the Preferred
Alternative.
ResPonse:
( 1 ) Several of the CERUS sites in this area have been or are being studied as a part of the
CERCLA process. The nearest CERCLIS sites to the areas being considered for the new
landfill are the Bland Landf1l1 and the Salt Lake County Landfills Parcels I and n. A recent
study on the laner tWo landfills by the Utah Bureau of Solid and Hazardous Waste concluded
there was no release of contaminants to the environment. Although it appears unlikely that
the areas being considered for the new landfill have been. contaminated by wastes in the
nearby CERCUS sites, a monitoring program to establish baseline preremediation air, soil
and groundwater quality at the new landfill site will be installed.
(2) Cost estimates for the Preferred Alternative (Alternative 7C) provided in Lone Star's
March 20, 1989 FS Addendum information showed a present value cost of $13,342,000. The
State of Utah discovered a computational error in this estimate which inflated its cost by
approximately $850,000. A revised estimate for Alternative 7C provided by Lone Star
Industries on April 13, 1990 shows a corrected present value cost of $12,518,143.
24. Don Ostler, Director of the Utah Bureau of Water Pollution Control commented that (1) His
Bureau is concerned that once the visible source of contamination is dealt with, ground water
contamination may not have a high priority when CERCLA funds are allocated in future years,
(2) Since the evaluation of the ground water on the Portland site was made using the EP A
ground water classification, a reevaluation of the ground water is needed using Utah's current
ground water classification system, and (3) The off-site industrial landfill proposed under the
State's Preferred Alternative will not be a CERCLA facility. Consequently, a ground water
discharge permit appears to be required for this new landfill since it is not "Permitted by
Rule".
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Response
(l) It is the government's position that the source of contamination on the pres~ryt site (the
waste CKD) must be controlled or removed before the contaminated ground water associated
with the site can be remediated. . Operable Unit 1 will control or eliminate that source of
contamination. Subsequent operable unit(s) will address remediation of residual soils,
treatment and disposal of the chrome bricks and cleanup of the contaminated ground water) .
associated with the site. .
(2) EPA ground water classification data was used in the RIIFS for evaluating ground water
at the site because the State's "Ground-Water Quality Protection Regulations" were not yet
adopted. Those regulations were not adopted until August, 1989. It is not possible to delay
remediation of Operable Unit 1 while reevaluation of the ground water is performed using
the State's new ground water regulation. However, that regulation will be used and cited as
an ARAR in evaluating remedial alternatives for remediation of the contaminated ground
water un the subsequent operable unit(s).
.
(3) If a ground water discharge permit is required for the new off-site, industrial landfill, that
permit, along with every other required permit, will be obtained.
25. Kathy Jenkins of Magna commented that implementation of the Preferred Alternative will
interfere with the new businesses that are being developed along 5600 West and delay
completion of the 1-215 freeway to make 7200 West a through way from 2100 South to 1-80.
ResPonse: The government does not agree with this comment. Under the Preferred
Alternative. the new landfill will be constructed near 7200 West, and not along 5600 West.
This new landfill will not have any adverse affect on business. development along 5600
West. nor will it adversely affect future business development along 7200 West, or the
construction of the 7200 West road from 2100 South to 1-80.
REMAINING CONCERNS
Issues and concerns that the government was unable to address during remedial plarming
activities include:
.
What would be the impact of the remedial decision for this site on the ultimate remedy
selection for other waste CKD sites throughout the nation?
ResPonse: Insufficient data is available at this time to assess the impacts.
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ATTACHMENT. SUMMARY OF RECENT COMMUNITY RELATIONS ACTIVITIES
The Community Relations Activities at the Portland Cement Co. (Kiln Dust #2 &' #3) s4tce
completion of the RIIFS reports and release of the Initial and Revised Proposed Plans has
included the following:
. An information repository is maintained for this site by the State of Utah, Bureau of :
Environmental Respose and Remediation, on the fourth floor of the Cannon Health
Building at 288 North 1460 West, Salt Lake City, Utah. Other repositoried for this
information are maintained at the Chapman Branch of the Salt Lake City Public Library
and at the offices of the U. S. Environmental Protection Agency in Denver, Colorado.
. The notice of availability of the RIIFS reports was published in the Deseret News and the
Salt Lake City Tribune on September 11, 1989.
. The State of Utah released the RIIFS reports for public comment on September 13, 1989.
. A public meeting to announce the availability of the RI/FS report was held on September
21, 1989. A brief summary of the RIIFS report was also presented in that meeting.
. The Initial Proposed Plan was released for public comment on October 16, 1989.
. The notice of availability of the Initial Proposed Plan was published in the Deseret News
and the Salt Lake City Tribune on October 17, 1989.
. A public comment period on the Initial Proposed Plan was held from October 16, 1989
through November 6, 1989.
. The State of Utah prepared and distributed a fact sheet on the Site on November I, 1989.
It provided background infonnation and an update on Site activities. Several earlier fact
sheets were also prepared on this Site during RIIFS activities.
. A public meeting was held on November 1, 1989 to receive public comments on the Initial
Proposed Plan. Approximately 50 people attended, including citizens, elected officials,
State and EP A officials, and technical and legal representatives of Lone Star Industries.
A transcript of this hearing is available for review at the Chapman Branch of the Salt Lake
City Library, the offices of the Utah Bureau of Environmental Resposnse and Remediation,
and the Denver offices of the U.S. EP A.
. The notice of availability of the Revised Proposed Plan was published in the Deseret News
and the Salt Lake City Tribune on March 25, 1999. A copy of this notice was mailed to
all persons on the mailing list for this Site.
. The Revised Proposed Plan was released for public comment on March 26, 1990.
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. A 60 day public comment period on the Revised Proposed Plan was held from March 26,
1990 through May 26, 1990. This public comment period was originally scheduled to end
after 30-days on April 26, 1990. However, EP A granted a 30-day extension to the public
comment period as allowed by the new National Contingency Plan.
. The State of Utah prepared and distributed a fact sheet on the Site on April 11, 1990. It :
provided background infonnation and an update on Site activities.
. A public meeting was held on April 11, 1990 to receive public comments on the Revised
Proposed Plan. Approximately 45 people attended, including citizens, elected officials,
State and EP A officials, and technical and legal representatives of Lone Star Industries.
A transcript of this hearing is available for review at the three infonnation depositories
mentioned earlier in this attachment.
. A brief presentation was made by the State of Utah to the Magna Area Community council
on May 3, 1990 regarding the State's Preferred and Contingency Alternatives for this site.
The Magna Area Community Council voted their objection to the construction of a new
landfill near 1300 S. and 7200 W. in Salt Lake City, primarily because of potential fugitive
dust problems from the site.
. A brief presentation by the State of Utah to the West Valley City Council was made on
June 7, 1990 regarding the State's Preferred and Contingency Alternatives for this site.
. At the request of State Representatives Daniel H. Tuttle and Brent H. Goodfellow, a public
meeting on the State of Utah's Preferred and Contingency Alternatives for this site was
held in the Cypress High School Auditorium in Magna on June 21,1990. The meeting was
held primarily for the purpose of infonning the residents of Magna and West Valley City
concerning the site. Approximately 60-70 people attended the meeting. Representatives
of the Utah Bureau of Enviromental Response and Remediation, EPA, and local
governments were present. Information was presented concerning the site, after which
statements and questions from those attending were addressed.
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1
. -
APPENDIX A: SUMMARY OF SITE RISKS
Human Health Risks
Contaminant Identification
Chemicals of potential health and environmental concern have been identified in ground
water, surface water, in the waste CKD and chromuim bricks at the site. Concentrations of the
chemicals of concern at the site are shown in Table A-I. The original mechanism of release to
the environment was disposal of waste CKD to surface soils. This waste CKD is the source of
contamination of ground water, surface water, and may result in off-site transpon of chemicals
by wind erosion. .
Exposure Pathways
An exposure pathway is the route a chemical constituent may take to reach a potential
receptor. The following potential exposure pathways were screened for the site:
Ingestion of waste CKD by trespassers;
Ingestion of waste CKD by workers;
Ingestion of waste CKD by future construction workers;
Dermal contact with waste CKD and ponded surface water by trespassers and future
construction workers;
Air exposure pathways including fugitive dust erosion and suspension with exposure
via 1) inhalation of or dermal contact with airborne waste CKD; 2) ingestion by
human receptors of soil or plants upon which wind-eroded waste CKD is deposited;
3) ingestion of fish, beef, or dairy products affected by wind-eroded waste CKD.
The exposure pathways and qualitative screening of each exposure pathway are described
-------
. TABLEA..1
.,;'(.. :
SUMMARY OF RI DATA.
. . W ASTECKD SITE> .. ......
..''''."., .::.;.:.', '::".' ".. '.'.-:'.";.' ",,"':,,", .:.:. :.,:. . ", ','. "." ",,' _...,"" "":':'"
PHASED SAMPLlNO~OROUND WATER
. CHEMICAL ..
. Site 2 .
pH<......
.. . Arsenic
. Cadmium
Chromium (total)
Lead.. .
Molybdenmn. .
... Site 3 ..
...pH ....
Anenic... .
"Cadmium .... ...
<:.bromimn (toW)..
Lead ... ... .....
Molybdenum ..
West Site ..
pH
Arsenic
Cadmium
Chromimn (total)
Lead
Molybdenmn
. ..
. ".
... ...
. .. ..
. ... ......,.. ... ... ...". ..". ... .",.
". . .." '",. ." " .. "', ,"','.',',",",'."..".".".".,',.',,",..
... . ...... .... ".... .. .. ".".". ...
. . . . .......
...C()N~T1c:>~~~ (~iA)
. ....
. ,". .....
... ..... . ..
. ..
.......... 7 .r~ 12.2......
... .<0.01"':11.4<
.. <0.003 ...: 0.041.
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3
.TABLE A~l.
CONTINUED ..
'..
,,"
..
. ..
...
,...
..
. . . . . .. .. . .
PHASE n SAMPLING ..~ SEDIMENTS
...
. .
. .
... .
.. .
CHEMICAL
. .
,',",..' .
..
..
. ...
...
. .
.. .
..
CONCBNTRATIONRANOE(m"JLo..\ ..
"'..:.", ", ""'""",;,:",,>,,<"":::"':~~'::
.....
...
. ....
pH
Arsenic. .
Cadmium ..
Chromium (tOt~t
.Lead. ....... ... .
MolYbdenum. .
....
. ...
..
. City Drain
. . . ." .
. . .. .
Nottb Bound8rv .
West Site
Waste CJCD..
pH
Arseaic .
Cadmium
Chromium (total)
Lead
Molybdeoum
. 8.6- 9.1 .
. 13.2 ~ 48.4
<0.76 - 5.4
17 - 61
89 - 363
3.3 - 45.7
Standard Units
North Boundary (Ponded Water)
pH
Arsenic
8.4 - 10.2
8.7
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-------
5
!n2estion of Waste tKD by TresPassers
This pathway was evaluated before the site was fenced. The site is now fully fenced and
is therefore secure from trespass. As a result, it is unlikely that nearby residents or others may
enter the site and be exposed to chemicals by disturbing the surface. It is possible that some:
contaminated soils exist just outside the fenced area.
In2estion of Waste CKD by Workers
Currently, no permanent workers are on the site. Personnel associated with sampling
activities are periodically on-site. Potential health hazards, if any, would be reduced with the
implementation of a health and safety plan. W olkers who visit the site may inadvertently ingest
waste CKD or have dermal contact during the normal course of a wolk day.
In2estion of Waste CKD by Future Construction Workers
If the site is developed for industrial or commercial use at some future date, and if waste
CKD is left in pl~ce, construction workers involved in site preparation may be exposed to
chemicals in waste CKD. Major disturbance to the waste CKD will result from site preparation
activities such as earth-moving and excavation, and construction workers may be exposed over
several years.
permal Contact with Waste CKD and ~ Surface Water by TresPassers and Future
Construction and Other On-Site Workers
Trespassers or future on-site workers may be dermally exposed to waste CKD and ponded
surface water on the site. Metals are not likely to be absorbed through the skin in significant
amounts. However, the alkalinity of the materials presents a potential dermal health concern.
Some constituents of waste CKD are alkaline hydroxides which may interact with moisture on
the surface of the skin to locally irritate the skin. Future on-site workers or trespassers who have
direct contact with waste CKD could suffer bums, occupational dermatitis, or chronic eczematous
skin conditions (from repeated exposure): Similarly, the elevated pH of ponded surface waters
may pose a potential threat to future on-site workers and trespassers. The effect of dermal
exposure to alkaline water may be an injury similar to a bum. Because the potential health
effects are local impacts rather than systemic, they are difficult to evaluate quantitatively. There
are a limited number of documented incidents where trespassers or workers have actually been
adversely affected by dermal contact with waste CKD or ponded surface water.
Air Exposure Pathways
Fugitive dust erosion and resuspension of waste CKD can lead to a number of specific
exposure pathways. Thus, an air pathway health risk assessment protocol was developed and
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6
. -
Air exposure pathways were evaluated using two emission scenarios:
A baseline ("No Action") scenario consisting of site conditions prior to the
current application of dust suppressant, and
A baseline (limited action) scenario that assumed current dust mitigating
measures are continued indefinitely.
Air pathways appropriate for the Salt Lake City area were based on local land use and
demographic data. Initial screening indicated that the primary exposure pathways would consist
of direct inhalation; soil, plant, fish, and dairy/beef ingestion; and off-site dermal contact.
Deposition of wind-blown waste CKD on off-site surface water was expected to be insignificant,
but was still considered. Exposure through human milk consumption was not considered since
highly lipophilic organic compounds such as PCDDs/PCDFs, PCBs and pesticide-related
chemicals are not found on the site. Secondary pathways that were also examined included
inhalation of resuspended dust and ingestion of food affected during preparation.
"
Air exposure pathways included:
Inhalation
Deposition followed by ingestion of soil
Ingestion of affected plants
Ingestion of affected fish
Ingestion of affected dairy products and beef
Consumption of affected human milk
Ingestion of affected surface water, and
Dermal contact.
Two potential receptor groups were identified for each pathway: a residential population
living next to the site (including a hypothetical maximally exposed individual), and an on-site
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7
. -
The following potential exposure pathways were retained for quantitative evaluation of
potential health and environmental risks:
Ingestion of waste CKD by trespassers;
Ingestion of waste CKD by future construction and other on-site workers; and,
Air exposure pathways including fugitive dust erosion and suspension with
exposure via 1) inhalation of or dennal contact with airborne waste CKD;
2) ingestion by human receptors of soil or plants on which wind-eroded waste
CKD is deposited; 3) ingestion of fIsh, beef or dairy products affected by wind-
eroded waste CKD.
The following pathways were qualitatively evaluated. The evaluation indicates that
potential health or environmental hazards may result from the following exposure pathways:
Dennal contact with waste CKD and ponded surface water by on-site workers,
trespassers, or future construction workers;
Ingestion of shallow ground water as drinking water;
Ingestion of shallow ground water by agricultural stock;
Indirect exposure to shallow ground water through crop irrigation;
Waterfowl exposure to ponded alkaline water.
The ground water pathways will be addressed in the Record of Decision for
Operable Unit 2.
Methodology for Quantitative Estimation of Potential Exposures
The algorithms used to calculate exposures due to waste CKD ingestion and waste CKD
erosion, dispersion, and inhalation are based on models described in EPA's guidance documents,
the Superfund Public Health Evaluation Manual and the Superfund Exposure Assessment Manual.
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8
Soil (Waste CKD) Inszestion Exposure Calculations
The daily uptake of a chemical via ingestion of soil (waste CKD) is estimated by:
D =
.
(C.)(S,)(Bio)(fvr)(De)(Met)(10-6 k£lmsz)
BW
(Equation 6-1)
Where:
D. = waste CKD ingestion pathway dose (mg/kg/day)
De = duration of exposure for each age group (hr/day)
SI = waste CKD ingestion rate (mg/day)
Bio = chemical bioavailability fraction (%)
Fyr = exposure fraction of 70-year period
Met = fraction of time surface waste CKD is not covered with snow
B W = average body weight (kg)
Table A-2 shows exposure scenarios that were considered in the risk assessment for the
ingestion of on-site soils. The soil ingestion rates (S\) for scenario B and E, 200 mg/day for
children and 100 mg/day for adults, are based on EPA's Exposure Factors Handbook. The soil
ingestion rates for scenarios A and D are 25 mg/day for children and 10 mg/day for adults.
These rates are taken from the Superfund Exposure Assessment Manual.
Bioavailability depends on the chemical fonn of the element, and the degree of sorption
to the soil matrix in the acidic environment of the human stomach. The bioavail'ability of arsenic
is assumed to be 29% after ingestion. This absorption rate was based on the ingestion of arsenic-
contaminated fly ash, which may exhibit properties similar to waste CKD in affecting bioavailabi-
lity. For all other chemical constituents, a conservative bioavailability of 100% is used.
Individuals with the greatest exposure potential with respect to contacting soils directly
on the site would be on-site personnel and trespassers under the "No-Action" alternative. These
populations may have direct exposure to soils via skin contact and ingestion.
Trespassers could be playing children or adults recreating or scavenging on-site. Because
access to the site would be limited and the site is not in the inunediate vicinity of residences,
only older children and adults, with greater mobility, are likely to visit the site. It is expected
that the total number of trespassers under this alternative would be small.
Persons in the 5 to 12 and the 12 to 70 age groups are assumed to trespass on the site 2
hours per day over a 70-year period. The workers (age group of 12 to 70 years) are assumed to
work on-site 40 hours per week over periods of 3 and 40 years. These periods are, respectively,
the time during which the site is assumed to be developed from some industrial or commercial
use, and the time a full-time worker is assumed to work on the site. Direct ingestion of soils
is evaluated, although older children and adults would not practice oven eating of nonfood
-------
SCENARIO
A
B
c
D
E
9
.. .
.TABLE A-2
. .
. . .
.. SCENARIOS USE)) FOR RISK CIIARACTERIZA TION ..
..OF THE ON~SrrESOILINGESTION PATHWAY..... .
EXPOSED .. EXPOSURE
POPULATIONS PERIOD (years)
. AGE GROUP
(yem)
. .
BODY WEIGlIT.. DURATION ..SOrL INGEsTION
(kg) . .. OF EXPOStJRE... ... RA~ (mg/day) .
.2 hrs/day .
.2 hrsfday
.. . .. ..
'. . . . " .
< 2 fas/cbY}
>.2. ~/,.I.:".
...:.....:. UI~uayr
"'.'." "'",,":'::;:::: ;";"':';';"::.;
.. ..40 hts/week/
. ".,' . ',' . '.." .
. . . ,"'," ',",' '."
..40 hrs~~::
...." .
.'';,' ,,' .. .'.":":'.
". ..
. .. . ...
.40 hrs/Week .,:
:.10...'
. 10:
.... .
:200...
,100.
:JO.
Trespassers 70 S - 12 32.4
12 - 70 68.5
..
.. .. :
Trespassers .. 70." 5 - 12 32.4......
.12 '~70 68.s
Construction Workers 3 12 ":70 .. 68.5<
, .. . '.'
. .. .. . . .
WorkerS " 40 .12"' 70 '.68.5...
On-Site
On-Site Workers 40 12 .. 70 .68.5
P""
..
.'..10.:.;.. .
'.100 .
-------
10
possible. However, there is considerable doubt concerning the amount of soil ingested by older
age groups. Incidental soil ingestion is often associated with eating food, an activity which is
not considered likely by trespassers while on the site.
The results of chemical analyses of surface soil samples for three area sources (Site 2, Site .:
3, and West Site), reponed in Table A-3, were used to estimate potential exposure to soils by
trespassers and workers. It should be noted that chemical characteristics may be different from
the surface to the interior of the waste CKD pile. Use of the surface concentrations will yeild
an indication of current exposure. The concentrations which are found on the interior of the pile
(which are generally higher) may be more appropriate for future worst-case scenarios.
The adjustment for meteorological conditions (Met) was conservatively taken to be 100%.
The exposure fraction (Fyr) is the period of exposure for each age group divided by a lifetime
exposure of 70 years. An exposure fraction of one was used to calculate the dose for chronic
health hazards. The actual exposure fraction for each age group was used to determine
carcinogenic dose.
Inhalation Exposure Calculations
Primary exposure to wind-blown waste CKD would occur through the inhalation pathway.
It was assumed that all inhaled particulates with an aerodynamic diameter smaller than 10 J.U11
would be completely absorbed in the lung. Inhaled particulates larger than 10 J.1.m were assumed
to be ingested via the pulmonary toilet, thus exposure would occur through the gastrointestinal
tract.
Worst-case inhalation pathway variables were based on EPA regulatory guidelines for
inhalation rate (20 m3/day), body weight (70 kg), exposure period (365 days/year for 70 years),
inhalable particulate fraction and retention (all particulate matter less than 10 J.1.m inhaled and
retained in respiratory tract), and chemical bioavailability (chemical totally absorbed in lungs).
These values were also assumed in the most plausible exposure scenario.
Inhalation of resuspended dust was also considered. It was assumed that indoor dust has
80 percent of the chemical constituent concentration of outdoor soil, and that 75 percent of the
dust would be absorbed in the lungs.
In industrial and commercially zoned areas, inhalation exposure was adjusted by a factor
of 0.14 to account for lower potential exposure to non-residential individuals. This factor is
based on worker exposure of eight hours per day, five days per week, for 40 years instead of the
normally assumed continuous 70 year exposure. This adjustment was only applied to developed
commercial/industrial areas and not to undeveloped commercial{mdustrial areas, thus allowing
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11
. ....
'. . . .. ...' . . '. .
RESULTS OF WASTE CKDCHEMl~ALANALYSES
, ,
, ..
CONSTITUENT' .
SITE 2 '
WASTE CKD
CONCENTRATIONS
(mglkg) , '
. ......
, srrB.3 :::"" ".',
WASTE CKD "
,CONCENTRATIONS
, ' , (mllkJ) ,
, '
, WEST SITE '"
, WAS1E CKD
,'.,' CONCENTRATIONS
,',' ',.. " (mglka>,' '
AIsenic , 12 4.4 '~.l
Cadmium 13 ,8, ",..,' 4
Chromium " 40 30,,' 39
Ouomium VI 0.9, t7 ' 0.4
Lead:, S60 500 610
"Molybdenum <20 <20, <40
.. ..
. . . . ..' "',,' ',' . ,'," '," ','. ."."",,' . .
. . . . .
NOte: Son ~ODS are from composited samptes of SDr&ce~baIf iDcb of waste CKD at 7:
locations 011 Site 3. 6 locatiObS on Site 2. and twO location; OIl tile West She.: ,'.. ,,' , '
Ingestion of Off-Site So~s Resulting from Airborne Emissions ExpOsure Calculations
Wind-blown waste CKD would be subject to deposition onto off-site surface soil. Waste
CKD chemical constituents would accumulate in the soil and serve as a potential route of
exposure for several ingestion pathways. Exposure could occur through inadvenent soil
ingestion, dermal exposure, and contamination of agricultural products.
Off-site soil concentrations were theoretically estimated based on panicle deposition
modeling and several conservative assumptions including average 70-year accumulation, no
removal processes, a uniform soil mixing depth of 15 em and a soil density of 1500 kg/m3.
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12
gastrointestinal bioavailability factors, and exposure frequencies. Only exposure through
ingestion of off-site soils, resulting from airborne emissions from the site, was considered.
The worst-case exposure scenario assumed an individual at the maximum event soil
ingestion rates. This soil ingestion rate of 145 mg is based on maximum soil ingestion events
and not lifetime average exposure. It was also conservatively assumed that this exposure would
occur 365 days per year which is highly unlikely given the climatic characteristics in the greater
Salt Lake City region. Periods of cold temperatures would preclude soil exposure during the
winter months.
Worst-case bioavailability factors developed by the EPA in various health effects
assessment (HEA) documents were used. For carcinogenic chemical constituents, the appropriate
bioavailability factor was used. For all other chemical constituents, 100 percent absorption was
conservatively assumed.
The more plausible exposure scenario assumed average individual event soil ingestion
rates (taken from the published literature) of 54 mg. The frequency of exposure was based on
studies that accounted for frozen ground during much of the winter, and assumed that people
would only come into contact and ingest soil for 6 months each year. The frequency of soil
ingestion for the most plausible case was 183 days per year (6 months).
Bioavailability factors for the more plausible case were based on EPA HEA documents
when available, and data from studies that examined the bioavailability of particulate-bound
inorganic chemicals for the other chemical constituents. If bioavailability data were not available
from any source 100 percent absorption was assumed.
Plant In2estion Exposure Calculations
Exposure through ingestion of produce affected by the target chemical constituents was
based on the extent to which the produce has been affected and on ingestion rates. The level of
impact to produce through root uptake and particulate deposition was estimated based on average
off-site soil chemical concentration estimates and modeled deposition rates.
Locally grown produce, commercial and backyard garden, would be subject to waste CKD
contamination through deposition and root uptake. The concentration of a chemical constituent
in crops would result from particulate deposition on the plant as well as plant root uptake of
chemical constituents in the soil.
To estimate the amount of deposition on an edible ponion of a plant surface. a weighted
deposition fraction of 6 percent was estimated. The weighted interception fraction represents the
interception of deposited particles on the edible ponions of different types of crops. The total
crop yield (2 kg/m2) is several times the edible ponion yield, indicating that deposition on the
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13
After deposition, panicles deposited on the plant swface are then affected by chemical
weathering. Assuming a plant exposure period of 45 days and a weathering half-life of 14 days
the remaining fraction of paniculates on the plant swface was estimated.
The concentration of a chemical constituent. would also be affected by washing before .:
consumption. Worst-case and most plausible removal rates of 50 and 65 percent, respectively,
were used.
Chemical constituents would be subject to accumulation in plant tissue through root
uptake. Soil chemical constituent concentrations were adjusted to account for agricultural tilling
and used with uptake factors to estimate the chemical constituent concentration in plants. The
soil mixing depth was assumed to be 30 em instead of the normal 15 em depth due to normal
agricultural tilling practices. The uptake factors were derived for both vegetative edible crops
and for reproductive edible crops. Root uptake factors were also adjusted to account for
translocation of chemical constituents from the root into the non-root ponion of the plant.
Produce consumption was based on median U.S. consumption rates and home-grown
fractions for rural and urban families. For the worst-case scenario, the higher home-grown and
consumption rates for rural families was used. The most plausible scenario assumed the urban
family consumption rates.
The ingested contaminated produce is also subject to varying degrees of bioavailability.
For the chemical constituents deposited on the surface of the plant, it was assumed that
bioavailability rates appropriate for soil ingestion applied. For the chemical constituent root
uptake ponion, the chemical constituent would be more bioavailable. Thus, 100 percent
absorption was assumed in all exposure scenarios.
Surface Water Ingestion Exposure Calculations
Nearby swface water bodies would be potentially impacted through atmospheric
deposition and soil runoff. Samples of surface water adjacent to the site (Jordan River Surplus
Canal and City Drain) have not shown elevated levels of the constituents of concern, but potential
exposure through ingestion of swface water was assessed based on estimated waste CKD
deposition rates.
Water concentrations were theoretically estimated based on aerial average waste CKD
deposition rates, water surface area, and water flow rates. To estimate water surface area, 10 krn
segments of the Jordan River and Surplus Canal were used with an approximate width of 30 m.
Water flow rates were based on average rates published by the U.S. Geological Survey. The City
-------
]4
. ."
The Jordan River and Surplus Canal do not appear to represent a source of drinking water
in the region. For the worst-case exposure scenario, it was assumed that the maximally exposed
individual consumed 2 liters of Surplus Canal water per day. The most plausible scenario
assumed no surface water consumption.
Fish Ingestion Exposure Calculations
While exposure through ingestion of affected surface water would be small, fish have the
potential to concentrate most of the metals of concern. Based on theoretical water concentrations
discussed in the previous section, the potential exposure of fish was assessed. For this
assessment, contamination to fish in the Jordan River and Surplus Canal was considered. The
City Drain was not considered since it does not appear to represent a suitable habitat for fish.
The concentration of metals in fish was estimated using appropriate bioconcentration
factors (BCFs). Where data was not available for specific chemical constituents, the BCF for
copper was used and represents the highest BCF for paniculate metals.
Human exposure through this pathway was assessed using average fish consumption rates
and percentage of fish locally caught. In the worst-case scenario, a fish consumption rate of 6.5
g/day was used. It was also assumed that 100 percent of the fish consumed was from the Jordan
River OF Surplus Canal. The most plausible exposure assumed the same fish consumption rate,
but also assumed that only 10 percent of the fish was from the study area. Both exposure
scenarios assumed 100 percent bioavailability.
Dairy and Beef Ingestion Exposure Calculations
Wind-blown constituents would also concentrate in cattle. Therefore, human exposure
through ingestion of dairy and beef products was examined. Cattle could be exposed through
ingestion of feed and water affected by wind-blown waste CKD. A worst-case assumption that
cattle graze locally and drink affected surface water waS used even though no commercial dairy
or beef operations were identified in the study area.
Chemical constituent concentrations in cattle feed, soil, and water were estimated using
the methodologies discussed in the previous sections. Cattle were assumed to graze on locally-
grown grass and feed, as well as drink water from the Jordan River or Surplus Canal.
Constituent concentrations in dairy and beef products were based on cattle exposure to
feed, soil, and water affected by waste CKD, and chemical specific gastrointestinal absorption
efficiencies. Cattle consumption rates for grass, soil, and water of 8,2, and 15 kg, respectively.
were used. Cattle were assumed to weigh 400 kg on the average.
The amount of a chemical constituent that would transfer to the meat or milk of cattle was
based on data reponed in the literature. Where no data were available for a chemical constituent.
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15
. .
Human ~xposure would be based on average dairy and beef produce consumption rates
and the percentage produced locally. Maximum and average consumption rates for daily and
beef products published by the U.S. Department of Agriculture were used. In the worst-case
scenario, it was conservatively assumed that all ingested beef and milk were produced in the
study area whereas 10 percent of the beef and milk consumed were assumed to be produced in :
the study area for the most plausible scenario.
Ingestion of Prepared Food EXpOsure Calculations
. Waste CKD suspended in the atmosphere could also deposit on food during preparation.
The amount of contamination would be based on the time the food was exposed during
preparation, the amount of exposed surface area, indoor particulate deposition velocities, and dust
chemical constituent concentrations. Food exposure data reported in the literature were used
along with estimated soil concentrations to approximate the extent of food contamination.
Two conservative assumptions were made: that indoor air chemical constituent
concentrations generated from the site are equal to those outdoors, and that the indoor deposition
rate of chemical constituents is similar to the rate outdoors.
Dermal Exposure Calculations
Dermal exposure would be based on the off-site soil chemical concentration estimates as
well as exposed skin area, dust loading on the skin surface, chemical absorption through skin,
and population mobility.
Toxicity Assessment and Risk Characterization
Cancer potency factors (CPFs) have been developed by EPA's Carcinogenic Assessment
Group for estimating excess lifetime cancer risks associated with exposure to potentially
carcinogenic chemicals. CPFs, which are expressed in units of (mg/kg-dayrl, are multiplied by
the estimated intake of a potential carcinogen, in mg/kg-day, to provide an upper-bound estimate
of the excess lifetime cancer risk associated with exposure at that intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated from the CPF. Use of this
approach makes underestimation of the actual cancer risk highly unlikely. Cancer potency factors
are derived from the results of human epidemiological studies or chronic animal bioassays to
which animal-to-human extrapolation and uncertainty factors have been applied.
Excess lifetime cancer risks are determined by multiplying the intake level with the cancer
potency factor. These risks are probabilities that are generally expressed in scientific notation
(e.g., IxlO~ or IE-6). An excess lifetime cancer risk of IxIO~ 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
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16
Reference doses (RIDs) have been developed by EPA for indicating the ~tential. for
adverse health effects from exposure to chemicals exhibiting noncarcinogenic effects. RIDs,
which are expressed in units of mg/kg-day, are estimates of lifetime daily exposure levels for
humans, including sensitive individuals, that is not likely to be without an appreciable risk of
adverse health effects. Estimated intakes of chemicals from environmental media (e.g., the
amount of a chemical ingested from contaminated drinking water) can be compared to the RID.
RIDs are derived from human epidemiological studies or animal studies to which uncenainty
factors have been applied. The uncenainty factors account for the use of animal data to predict
effects on humans and help ensure that the RIDs will not underestimate the potential for adverse
noncarcinogenic effects.
..
Potential concern for noncarcinogenic effects of a single contaminant in a single medium
is expressed as the hazard quotient (HQ). The HQ is the ratio of the estimated intake derived
from the contaminant concentration in a given medium to the contaminant's reference dose. By
adding the HQs for all contaminants within a medium, or across all media to which a given
population may reasonably be exposed, the Hazard Index (HI) can be generated. The HI provides
a useful reference point for gauging the potential significance of multiple contaminant exposures
within a single medium, or across media.
The calculated potential cancer risk dose and chronic health hazard dose associated with
on-site migration of each chemical for the three area sources are presented in Tables A-4 and A-
5, respectively. It should be noted that surface concentrations were employed when calculating
current carcinogen risks. Exposure to deeper sections of the waste pile may result in different
risks.
Table A-6 summarizes the cancer potency slope and chronic reference dose for each
chemical for the ingestion route of exposure. The calculated cancer risks and chronic health
hazards associated with each chemical in waste CKD for trespassers and workers are presented
in Tables A-7 and A-8, respectively.
The potential for adverse health effects resulting from exposure to fugitive waste CKD
emissions is split into two distinct categories. The fIrst category includes the potential lifetime
cancer risk as a result of exposure to fugitive waste CKD emissions (referred to as the excess
cancer risk) and the associated population cancer burden (the theoretical number of potential
cancer cases). The second category includes acute and chronic noncarcinogenic health effects
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17
, TABLE A4
J" .
.' . ..
.' . .
. .
. . .
LIFETIME DOSI'S USED IN CALCULA 11N.q POTENTIAL .~ANCER 1USi((-.fkeld) ..
. .
TRESPASSERS SCENARIO A
. . .. . ..
. .. . . .' . '. .' " .
. .
CONSTRUcnON woiucBRs
. SCENARIO C ... . .
. TREsPASSERS SCENARIO B ..
CONS11TUENT ~ ~ West Sito ... &!!1 . Site 3 West Site ~ ~ . West Site.
Arsenic 4.40&08 1.61E-08 1.87B-08.. ...,.5.29£-07 I.9SS-07 ... 2.25B-07 5.19&09 1.918-09. . . 2.20&-09
Cadmium 1.648-07 1.0 1 B-07 5.0m.08 . ... i.97E-06. 1.22B-06.. .. 6.09B--07 1.93&08 . 1.91Pr08 ... 5.96£.00
Chromium 5.07E-07 3.80F,.()7 4.93B-07 6.09B-06 . 4.57B-06' 5.93&06 5.96B-08 . 4.47E-08 .. S.81E.-08
2.15&08 . .. .... t.37B--07 .
Chromium VI 1.14&08 S.078-09 .. 2.598-07 6.09E-08 1.35&09 2.53&09 .. S.~tO'.
Lead 7.08&06 6.3m.06. 1.72&06 . 8.52£-05 7.61B-05 9.28B-OS. . . 835&01 7.45B-07 9.09E-07
Molybdenum 1.27£-07 .. 1.27£-07 5.078-07 . ... 1.52£.06 1.52E-06 6.098-06 H t.49E-08.. .... 1.49&08 .. S.96&08 . .
. .
.
CONS11TUENT
Arsenic
Cadmium
OIromium
Cbromium VI
Lead
. Molybdenum
ON-SrrB WORKERS
SCENARIO A .
Site 2
6.92£-08
2.588-07
1.958-07
1.80E-OS
1.11 B-OS
1.998-07
Site 3
2.54£-08
.1.59B-07
5.96£.07
3,38&08
9.94&-06
. 1.99IW7
. . .'
. WeSt Site .
2.93£.08
7.95&08 ..
7.7SB-07..
7.95B-09 .
1.21&-05 ..
. 7.9SB-Q7:.
..
r""
ON~SITE WORKERS.
.. SCENARIO B .. .
H
.. . site 2
..6.92B-07
.2.588-06 .
..1.95&06 .
. Hl.808-07
1.11£..04 .
.1.998-06
... SiteH). ... . West Site ..
. H
. .
2.54&07 .
. 1.59&06 .
5.96B-06 '.
3.38&07 .
9.94&05
1.99B-06'
.. .
. 2.93B-07 .
1.958-07
. 1.75£-06
7.95&08 .
1.21E-04 .
...1.9Sp,06...::. ..
..
...
..
. .
. .
. .
. .
-------
CONS1TI1JENT
Arsenic
Cadmium
Chromium
Chromium VI
Lead
Molybdenum
CONS'ITI1JEJIIT
Arsenic
Cadmium
CbromiUId
Chromium VI
Lead
. 'Motybdenum
TABLE A.5
. .
. :" . . .
CALCULATED LiFETIME DAILY DOSE FOR ON-SITEINGFSnON. .. ..
OF CHEMlC~ 'fVITH f9TE~ CHRONIC BEALT!!~~: ~~d)
TRESPASSERS SCENARIO A
~
Ij2B-07
4.92B-07
1.52E-06
3.41&08
2. 12B-05
3.79B-07
Site 2
6.25&09
2.338-08
7.19&08
1.61&09
1.018-06
1.80B-08
Site 3 ..
..4.848-08 .
.. ~.03S07
.1.14&06
. 6MB-OS..
. 1.89B-05 .:
3.79£007
." .
.. ,".
.. 5.$)B.08 .
t.5m.07
lA8B-06 .
.1.518-08.
2.3 1&.05 .
t.5m.06
ON-SITB WOtKEkS :
SCENARIO A
Site 3
2.29B-09 .
1.44&09:
5.40£.08 ..
3.OSP...09
. 8.99B--01 .
... 1.808-08 .
. West Site .
.' . .
: 2.6S~
7.196-09
07.018..08
7.19B-I0
:1.10&.06
.1.19B-O&<. .
..
..
.. ..
...
.. .
. ..
. . .
. .' .
tRESPASSERS stENARIO B
. Site 2
.~.,
2.21B-07
.8.27£.06 .
~.SSt>05
. S.72E-07.
.3.S6E.04
. 6.36£006
...
6,25B..08
:.2,33&07
7.19£.07.
. 1.6t&08
tOls..oS
. .t.8OE.07 ..
. ..
Site 3
8.12&07
: 5.09'&06.
1.91&05
.. i.08£o06.
3.19&04
6.36J3;.06
Sitej"
. .. .. ",..
..2.29&08 .
. i.44B;-08
. 5.40R-07
3.0SB-08 :.
.8.99&06
l.80B4t.. .
. .
. ..
...
West Site.
. . .",
.9.40B-07
. 2.Sm.06
...2.48B-05...
. 2.55&07.
3.8SB-()4
2.5Ss..oS
W~Site
........ . . ..
.' ......
. i65£.08
..7.i9B-6s:
1.01B-01..
7.198-09.
i.1 OB-OS :
7.1~....:
...
..
..
...
. P'
n"
..
. .
... .
...,.
...
. .
. .
.. .
. .
. ,-.
..
..
18
..
.. .
..
,....
. .' . ." .. .
. . .. . .
. .CONS'IRUC110N woRKERs
. . SCENARIO C .
: Site 2
6.258-09
2.33£.08 .:.
1.19B-08
1.61B-09 :
1.018-06
1.80&08
..
...
..
..
..
..
. .
...
..
...-
. .
. .
Site 1
. . . ... '"
..2.29&09 ...
1,44B--09:
.. S.4()B-03 .:.
: 3.05E-09>
8.99U7..
1.80s..os .>
..
. .
. .
,2.6sB-09
".7.19&09 ..
\7.01&08 .
7J9B--10
>1.10&06
.1.19&08
. .
..
.."
..
..
. ..
. .
..
;.>, '.~
. .
. .
..
. .
.. .
:::~. .
..
. ~.
..
;;/',
...
:.'"
-------
19
. ',. .,'" ','.'
.. .....,. ...
..... .."
, '
, T ABLE A~6 "
,'THE CANCER POTENCY SLOPE AND CHRONIC REFERENCE OOSE."
..' , '" , FOR THE SOIL INGESTION ROUTE ,".. " ,"""..' ....
, '
, .
" ,
Arsenic ','
J.75
'~
'" "ORAL, ' '
CANCER POTENCY SLOPE
,(m£lk2ldavyl ' ,
Cadmium
o
'2.9E'" "
Chromium VI' ,
o
'1.0~
, S.O~:
Chrorriium'
0..
Lead
,0
..' 1.4E'~,\
Molybdenum "
,0
-------
20
TABLE A.7
, '
CALCULATtD ToTAL CANCER RISK DUE TO SOIL INGEsTION
CONS1TI1JENT
Arsenic
Cadmium
OmmtiUrd
Chromium VI
Lead
Molybdenum
.. ... ." .
. . . . ...
. . . .
.'CONSTRUcnONWORKERS
, ' ,SCENARIO C '
TRESPASsERS SCl!NAlUO 8
TRESPASSERS SCENARIO A '
Site 2
7.71£.08
o
o
o
o
o
Site 3 '
, '9.07B-09 " ,
, ,'0,"
0".,
()
o
o
, Site 3.. 'West Site "
, Site 2
, Site 3 '
Site 2
9.2tB-07 "
'. 0:
,0'
o
0'
o
. West Site,
, '
3.32~ '
" ""'0""
dO .
dO
o
o
d
. . . .
" 3.93&07 '
, ' ,
, '0.'
o
o
o
o
3.40&07 .',
o . '
,0
o
0'
o
,3.8m.09,
'..,0
o
,0
.,0 '
o
, '2.83B-08 '
" "0, ,',
0'
dO
0'
o
CONS1TI'UENT
Arsenic
Cadmium
OIromiurd
Cbromium VI
Lead
.Molybdenum
Site 2 '
1.21£.07 '
o
o
o
o
o
ON-SrrB WORKERS,
SCENARIO A."
, ,
Site 3 ..
',4.43B-08 ..
"0 d .'
'0",
o
.0
(}
-------
.
21
TABLE A-8
CALCULATED NON-CARCINOGENIC CHRONIC HEALTH RISK DUE TO SOIL (WASTE CKD) INGESFION . ...
CONSTRUcnON WORKERS
TRESPASSERS SCENARJO A TRESPASSERS SCENARJO B .. ' SCENARIO C
CONS1TI1JENT Site 2 Site 3 West Site Site 2 Site 3 West Site Site 2 ' Site 3 West Site'
Arsenic 1.32E-04 4.848-05 5.60&05 2.21&03 8.12&04 9.40E-04 6,2SE-06 2.29&06 2.6SE-06
Cadmium 1.69B-03 1.05&03 . 5.23B-04 2.85£-02 1.7SS-02 8.7"ffi..03 8.0SE-OS 4.96MS 2.48a.6S .
Chromium 1528-06 1.14&06 1.48B-06 2.S~E-0~ 1.91&05 2.488-05 7.1 9E-08 5.408-08 ,..1.01&08
O1romium VI 6.8 I 6-06 ' 1.29&05 3.038-06. 1.158-04 2.16B-04 5.09&OS 3.24&07 6.11&01. ' 1.44E-07
Lead 1.52£..02 1.358-02 1.65&02 2.S~1 2.27£..01 2.77£..01 7.198-04 6.43E-04 ' 7.848-04
Molybdenum 1.40B-04 1.40&04 5.61B-04 2.36E-03 2.36E-03 9.43M3 6.65E-06 6.65£..06. 2.76B-OS
ON-SITB WORKERS ON-SITE WORKERS
SCENARIO A SCENARIO B .
CONS1TI1JENT Site 2 Site 3.. ,West Site ., ' Site 2 Site 3. ,WeSt Site
, . '. 2.65E-OS '
. Atsenic 6.25£-06 ' 2.29&06 2.65&06 ' 6.2SB-OS 2.29£-05 ..
Cadmium 8.0SE-OS 4.96B-OS 2.48E-05u 8.0SE-04 ,. 4.96&04. 2.48B-04.
OIromium 7.19&08 5.40:£..08 7.01B-OS ' ' 1.19E-07 5.40&07. . 7.01&-01
Chromium VI 324E-01 6.11B-07 1.44B-07., 3.24B-06 6.11&06 1.44&06
. Lead 1.1 9&04 6.438-04 1.84&04' , ,.7.19B-03 6.43&03 ' .1.84&03
. Molybdenum 6.658-06 6.658-06 2.6m.05 .' 6.6SB-OS 6.65&05 2.67B-04
, .
. A value d indica1es that cumulative dOMI$ are unlikely CO Cause adverse health affects..
-------
22
Carcinoszenic Risks
The cancer risk evaluation considers the risk associated with exposure and intake of
carcinogens with the following weight of evidence classifications:
.
A (Sufficient human evidence)
B (Probable human carcinogen)
.
Suspected carcinogens without sufficient human evidence (weight of evidence C classifica-
tion) were not considered. Carcinogenic trace metals that were examined in the health risk
assessment included arsenic, cadmium, and hexavalent chromium.
The excess cancer risk that could potentially result from exposure to waste CKD was
estimated based on the dose of a chemical constituent through the various exposure pathways,
and the carcinogenic potency of the chemical constituent. Two exposure scenarios were used to
estimate the lifetime excess cancer risk to the maximum exposed individual (ME!). Two
emission scenario~ were also considered based on uncontrolled and controlled fugitive waste
CKD emissions.
The average daily dose was derived from equations similar to equation 6-1, except that
various factors are substituted to represent the assumptions concerning exposure rates, duration
of exposure, or bioavailability appropriate to each exposure pathway. The worst-case and most-
plausible-case excess cancer risks we~e estimated. All carcinogenic health effects were asswned
to be additive under both exposUre scenarios.
Cancer potency factors (CPF) developed by the EPA (where available) and other
regulatory agencies were utilized. Where appropriate, the oral cancer potency factors were
adjusted to account for the potential absorption in the body which is expressed as the
bioavailability .
Inhalation cancer potency factors were not adjusted, with the exception of arsenic. The
inhalation CPF for arsenic was derived by EPA from the ingestion CPF, and included a 30
percent absorption factor. Therefore, a bioavailability factor of 30 percent was used to estimate
the arsenic inhalation dose.
For the worst-case assessment it was assumed that targeted chemical constituents
identified as carcinogenic for a specific exposure route (i.e. inhalation, ingestion, dermal), were
carcinogenic via all exposure routes. Route specific cancer potency factors were used in the most
plausible scenario.
The population excess cancer burden (population weighted number of potential cancer
-------
23
data coJlected by the U.S. Census Bureau within a one mile radius of the site. The population
defmed by exposure to an excess cancer risk of 1 x 10.7 or greater was used in the cancer burden
estimates. .
Results of the cancer risk evaluation are presented in Table A-9. Eight air exposure
scenarios were evaluated using worst case/most plausible exposure parameters,
mitigated/unmitigated emission cases, and two different years of meteorological conditions: 1982
and 1985.
..
.
. ..'
. . . .on
'n . .. .
. .. .
. ... . ..TABLE A-9 . .. ...... .......... ...... .>
MAXIMUM EXCESS.CANCER RISKS VIA INHALATION
.. ..
. ... ... .
Worst-~... .. .
Unmitigated Emissions
...~ Plausible 1982 .
.... pDlriitigated EmissiODS .
Worst-~.1982 ... .
.Mitigated Emissions .
",':-.".,'" .' ,'.." "
. .
MOSt Plausible 1982
.... Mitigated Emissioos
WOIBt-Cue 1985 ..
UomitigatedEmissioos.
Most Plausible 1985 .
. Uomitigated EmissiODS
Worst Case 1985.
Mitigated Emissions
Most Plausible 1985
Mitigated Emissions
.. MAXIMUM EXPOSED.....
INDIVIDUAL RISK ....
'," ,",': . ""'."."," .,'.. ".""', . ,'.'"".'" '", .,' .
......MAXIMUMOcCuPATIOl-iAL ..
.... ..... .. .. RECEPTOR JUSK ....... ..'
, ,
,,2.41E~7
. . .. .
.. '" .... .. ..
.. ,".. ........
.. " ..
..6.6SB-08 ,..... ."
..3.21B-08 '".'
. ...
3.53~7 ..... 8.31E-08
1.t4E.07 ., 3.83B-08
'. , ..
. ,..
7~6SB-08 . 1. 77E~8 . ,
-------
24
The upper-bound excess cancer risk for the MEI from the worst-case exposUre sceAario
and uncontrolled site emissions was 3.53 x 10". Under mitigated site emissions, which are
representative of current site conditions, the upper-bound excess cancer risk from the worst-case
exposure scenario was 7.65 x 10-1. The most plausible risks associated with the two emission
scenarios were 1.14 x 10-' and 2.40 x 10-1, respectively. .
'I
.
The excess cancer risks presented above are for the maximum exposed individual located
at the site boundary. Risks for individuals at distances further from the site would be lower. The
greatest health risk would occur nearest the site. Health risks decrease significantly to the east
and west of the site due to strongly prevailing up and down valley winds.
The excess cancer burden, or the theoretical number of cancer cases that could result from
exposure to site emissions, is calculated as the product of the excess cancer risk and the number
of potentially exposed individuals. Estimated excess cancer burdens ranged from none to 3.37
x 10". An excess cancer burden of one would indicate one possible cancer case. Therefore, an
excess cancer burden of 3.37 x 10" is low. .
The reasons for the low excess cancer burden are twofold. First, the population density
around the site ranges from relatively low to a relatively high residential population east of the
site, and an extremely low population north, south and west of the site. Second, prevailing wind
patterns limit the exposure to individuals residing east or west of the site.
Noncarcinoe:enic Health Effects
Noncarcinogenic acute and chronic health effects were evaluated in relation to average
and peak fugitive waste CKD emission scenarios. Chemical constituents that were examined
included aluminum, barium, trivalent chromium, iron, lead, molybdenum, zinc, mercury,
manganese, and noncarcinogenic health effects of arsenic, cadmium, and hexavalent chromium.
The respiratory health effects resulting from exposure to particulate waste CKD was also
evaluated.
Initially, the health effects of the relatively high pH waste CKD were to be examined.
Since wind-blown waste CKD would result from surface emissions, surface pH levels were used
to characterize potential exposure. Health risks based on exposure to high subsurface pH levels
were not considered.
Chronic Health Effects
Chronic noncarcinogenic health effects were evaluated by comparing inhalation and
ingestion intake levels to appropriate EPA reference doses (RIDs) and acceptable daily intake
(ADI) v.alues. RIDs were taken from the appropriate HEA, EPA's Interactive Risk Information
System (IRIS) database, or EPA Superfund Manual. Additive health effects, or the chronic
-------
2S
initial screening, calculation of the chronic hazard index included all chemical conStituents. If
the hazard index approached unity (i.e. greater than one), then only groups of chemicals with the
same target organ, system, or when the same toxic end points are involved, would be summed.
Results of the chronic health effects evaluation are presented in Table A-IO for the 1985 :
worst case exposure and emission scenarios. The absolute worst-case chronic hazard indices for
inhalation and ingestion of 4.89 x 10.3 (1985) and 4.86 x 10.3 (1985), respectively, show that
estimated doses would remain below acceptable daily intake levels. Therefore, no chronic health
effects resulting from exposure to heavy metals present in fugitive waste CKD emissions would
be expected.
..
.
Acute Health Effects
Acute noncarcinogenic health effects due to trace metal present in the waste CKD were
evaluated for a peak fugitive dust scenario. Estimated short-term (8-hour) atmospheric
concentrations were compared to Threshold Limit Values (TL Vs) developed by the American
Conference of Governmental Industrial Hygienists (ACGIH) and the National Institute of
Occupational Safety and Health (NIOSH).
The TL V s were applied to assess potential acute health hazards resulting from exposure
to worst-case fugitive CKD events in areas of known industrial/commercial activity. In
residential or other industrial/commercial land use areas, the TL Vs were adjusted by a safety
factor of 100 to account for sensitive individuals. The potential for significant acute health
effects, resulting from exposure to peak wind-blown fugitive waste CKD events, was also
examined as total particulate loading. Cumulative pollutant health effects were estimated by
summing the ratio of the maximum 8-hour concentration to the TL V for each chemical
constituent.
Results of the acute health effects evaluation are presented in Tables 6-11 and 6-12 for
the two worst-case exposure and emission scenarios. Based on these results there is currently
no significant acute health risk from heavy metals associated with exposure to peak wind-blown
fugitive waste CKD events.
Uncertainties
As with any risk based calculations there are uncertainties associated with the conclusions
which are drawn here. Some of these uncertainties may be listed as follows:
Choice of indicator chemicals. The quantitative risk calculations at this site are
based upon the concentrations of heavy metals found in the CKD. This does not
-------
-------
" ,., ..,. ,,' ,'.'.'",..,
. T ABLEA~il..
27
..
". . ". "".. ".' . '.~' ",.,. ",."" ,'.",." ,
ACUTE HEALTH EFFECTS..OCCtJPATIONALEXPO~URE
.. . . . .UNMITIGt\TEDSITEE:1YI1~SI9~S" ........... .........
...
. CHEMICAL .
..CoNS11TUENT
,. ' ,
. Aluminum
. AJsenic .
.. Barium. ..
. Cadmium .:.
Chromium. +3
. Olromium. +6
lroo
Lead .
..~
.. Mangaoese .
. Mercury ......
.. MotybdeDUnt..
Zinc. ...
.TSP< .
.PMI0
. TLV..
.. @g/m')<.
2000
200
500
.JO
500
50
1000
!SO
5000
.50..
.500
JOOOO
10000
5000
. .
'".,.' ". , .,. . ,'..,', ,.'""",.' "
MAXIMUM 8~HOUR
... CONCENTRATION"
.. ....... .(~8Im~) ....< ....
.. ,"'"
4.20&:00
4.00&03.
4.92E-01
...2.79B-03. .
LSOB;.02 .
4.00E.04 .
4.1SE-OO
1.81B-Ol .
7.99~..
2.15£.05...
6.1SE-OS
..1.91B-Ot.
3.07E+G2 .
. .
t;23B-tm .
.,."
.
..
. .
.
...
., , " . '
..HAzARD RATIO
"",., ", ,'.',','
..(9LCIlL. y){'"
. " '" ..
2JO&03 ...
: :2.00E-05 .
..9.84B-04 ...
~79E-04
3.00E-OS. .
8.00E-06 .
4~ 15&03 ...
.1.21S.()3
1.60E-OS .
4.00B-07. .
. L23&08
... L91S.os\..:
.3.01£-02:. . .
. .
2.46E-02 ..
... '
, .,' .
, " "
ACUTE HAZARD INDEX = 6~4[E.02..
-------
'"
" ,
.
, ,
"'. .
'"
.,-;'.',
:;:':'". ": ..: .;".:;:.;."",."; . :'."
:TABLEA~12
28
, "
, , ,
, ,
, ,
.. ..
... .
. ...
.. ..
','ACUTE HEALTHEFFEcrS ."RESIDENTIALEXPbSUR,E:
""" ' "'UNMITIGATEDSITEEMJSSIONS':>""
, ,
...... .... .,.. .
MAxIMUMs-HOUR,",',.,.',.,":.,:,.""',',',""" ,,' ' ',':, ".': ' ,,','
.... ....... ...
,,~J'USTE.D:'1.'Lv,: "',"CONCENTRA'I10N.:~:,M110,
...... .
.... ..
... . ...
, , '
':'..CHBMICAL'
. ...
.,' .
"
, ,
. . ,..... .
Aluminum
" Arsenic' "
. Barium,
, Cadmium
, ,Ouomium +3
, O1romium +6 '
. ",.
,'Iron ','::,'
: Lead ,
Manganese :'
, Mercury" ",'
, Molybdenum
Zinc,'"
TS~ '
,'PM10"
, '
, "
... .
, ,
... .
, ,
, 2.30E..oo<
2.26E-Q3 ':,:'
" 2.78B-Ol'
1.S8E.03
8.48E-03 ' :
, ,
2.26B-04
, 2.358-00 "
1.03E-Ol ".'
4.53E-02,
, 1.22B-OS ,
:' 3A8B-03:",
,','I.08E-Ol' '
',1.47B+Of"
'.2.99B~I:
..." .
. . ....... .
. . . .. . .. . . . .. . .
.... .. ....
.. ..... .......... ..
'1.198-01:
. ~.~. ::: ,'; t,.13E-03 ."::~
<:., ,5~S6E-02 ,:",:
J.'SB-02 ",'
J.708-03 '
<4.52E-04
2.3SE-Ol ':
.,6.87&.02,
'," 9.06B-04,'
,,2.40E-05 '
7.00E-OS
1.08B-03,
"Z.87B-Ol,
:, t.99B-OJ'
, "
"' ..
.. ... . . . .. .. .. .
. ", ", "'. ,"," ... ",.' .," .. ". "
'AarrB HAZARD INDEX II: 9.8SE-Ol'
......-
, ,a :11ueshoidLin1it V~ C11:~) adj~ by a"safetyfact~()f:l~~~(HJJJt~~~"
, population aocheDSitive ~~ " .. ',,'," ," , " ,: '> ..":"" ":,
. The' maximD~ 24-b0ur TOC'Al Suspeoded Particuiates, (TSP)corJCe~; W~,,~~' to tbe '
, applica1be 24-bour TSP standard.:' " " , ' " " ," . ," .'" ",' ,.', . " '
. ," . .':.".' '..:. ", ." ::. "'. .' ." : . .<;."',.". :".'.. .',: . .
'. The maximum 24-bour 10 Miaon Particulate matter (PMI0)c:ooceDtratioo was complied to the
-------
29
Presence of chrome bricks. There are approximately 360 tons of chrome bricks
scattered throughout the site. It has been assured throughout this ROD that the
chrome bricks would be separated and temporarily stored at an acceptable on-site
location during Operable Unit I., Treatment and disposal of the chrome bricks:
will occur dumg a subsequent operable unit(s) for the site. Therefore, the risks'
that they pose have not been quantified.
..
Future exposure scenarios. There will always be uncenainty surrounding the
likelihood and extent of any future activity which may result in a complete
exposure scenario. These scenarios are especially difficult to quantify.
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Exposure concentrations. The surface of the waste pile has been weathered du~
to exposure to the elements. By using only surface concentrations, the extent of
future health risks may be underestimated.
Representativeness of model results. The air exposure pathway was evaluated
using an empirical model rather than based upon actual site data. While models
can provide much useful information, they may not always be a valid
representation of actual site conditions.
Due to these uncenainties, it is felt that a conservative approach is warranted at this site.
Although the risk calculations on the current exposure scenario do not show a great deal of health
risk being present, the future considerations (unrestricted residential use, constrUction activities)
warrant the remedial action proposed in this plan.
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Environmental Risks
Vegetation
Most of the project area consisted of saltgrass alkali flats prior to extensive industrial
development. Fill material presently covers most of the area, and the combination of better
drained soil and frequent disturbances has resulted in a disjunct array of plant communities
comprised predominantly of weedy species. The amount of vegetation, as measured by ground
surface coverage, ranges from zero in areas where waste CKD, common bricks, and concrete
slabs have been disposed, to about 50 percent in areas containing mineral soil. Vegetation has
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Terrestrial Wildlife
Ring-necked pheasants were prominent near Site 2 and in the West Area. Other bird
species observed in the project area include magpies, American kestrel, red-shafted flicker,
meadow lark, and burrowing owl. It is expected that numerous species would use the Surplus
Canal for nesting and migration. The project area also provides habitat for several manunal
species. Caustic bums may result if local wildlife comes in direct contaCt with ponded water
which may form on the CKD.
Aquatic Biota
Fish species collected from the Jordan River upstream of the Surplus Canal included
common carp, walleye, white bass, and Utah sucker. Downstream from the Surplus Canal, Utah
chub, green sunfish, and mountain sucker were collected in addition to the above-mentioned
species. They did not appear to be adversely affected, however.
Special Status Species
Special status species include those that are listed by the U.S. Fish and Wildlife Service
as threatened or endangered, and those species that are under consideration for such a listing.
No listed or candidate threatened or endangered species are known to occur in the vicinity
of the project area. Burrowing owls are considered a sensitive species by the Utah Division of
Wildlife due to the amount of burrow and habitat destruction that has been caused by agricultural
development and urban expansion, including that of Salt Lake City. Utah state law protects all
bird species except starling, house sparrow, and feral pigeons from being killed or injured, except
according to applicable hunting regulations. Cenain species of the area may also be protected
by the Migratory Bird Act. This Act regulates the hunting, possession, transpon, shipping, expon
and impon of migratory game birds which include such species as ducks, geese, doves, pigeons,
coots, and cranes.
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and substantial
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