United States
Environmental Protection
Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R08-90/031
September 1990
&EPA
Superfund
Record of Decision
-------
S0272.101
REPORT DOCUMENTATION 1'. REPORT NO.
PAGE EPA/ROD/R08-90/031
. TIle Iftd .....
! SUPERFUND RECORD OF DECISION
Sand Creek Industrial, CO
Second Remedial Action
7. AuIhor(.)
2.
:s. A8c1piMII'. AcC888Ion No.
~. Report 0818
09/28/90
6.
8. Performing Org8nIDtion ~ No.
8. ""'111'"8 0rpInIz8tI0n ...... Iftd Addrn8
10. ProjKtIT88klWortI UnIt No.
11. Contrec1(C) or Or8nt(G) No.
IC)
11. Ipon_t,.. 0rg8nIaII0n ..... end AddrM8
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
IG)
13. Type of Report. P8rtod CoWNd
.
Agency
800/000
14.
15. f/uppI8m8nt8Iy No...
11. Abenct (lImI1: 2DD _rd.)
The Sand Creek Industrial site' is chemical manufacturing facility in Commerce City,
Adams County, Colorado. Land use in the area surrounding the site is primarily
industrial and residential with 13 residents on site. Production wells north and
downgradient of the site supply drinking water to the county. The Sand Creek
Industrial site lies in the vicinity of three other Superfund sites: Woodbury Chemical,
IChemical Sales, and Rocky Mountain Arsenal. Beginning in the 1960s, the Colorado
Organic Chemical Company (COC) conducted pesticide manufacturing operations on site.
Disposal and onsite storage areas include a landfill and acid pits. Onsite fires in
1968 and 1977, as well as improper pesticide storage practices, resulted in
pesticide-contaminated soil, ground water, and surface water. In 1978, COC removed some
contaminated soil, and in 1984, COC removed drummed wastes, excess product, additional
contaminated soil, and implemented site access restrictions including fencing. The site
has been divided into six Operable Units (OU) to facilitate remediation. A 1989 Record
of Decision (ROD) addressed OU1, which included remediating some of the subsurface soil.
This second ROD addresses OUS, and includes the final response action for the 14,000
(See Attached Page)
17. ~I An8Iy8I8 .. 088atpI018
Record of Decision - Sand Creek Industrial, CO
Second Remedial Action
Contaminated Medium: soil
Key Contaminants: organics (pesticides), metals (arsenic, chromium)
b. JdenItl8r8/Op8n-fnd T-
Co COSAlI ReldlGrIq)
18. AY8II8bII1y SUI-'
18. S8cur1ty CI... (1IU8 A8por1)
None
20. S8curI1y CI... (1IU8 1'888)
Nnnp
21. No. ot p....
100
22. Price
(See ANSl-Z38.18)
SH IMITUCUOM on R.w,...
IFonnerty NTl5-35)
-------
EPA/ROD/R08-90/031
and Creek Industrial, CO
cond Remedial Action
Abstract (Continued)
cubic yards
address the
water. The
pesticides;
of contaminated soil present onsite at the COC area. Subsequent RODs will
remaining contamination including the landfill, acid pits, and ground
primary contaminants of concern affecting the soil are organics including
and metals including arsenic and chromium.
.
The selected remedial action for this site includes excavating approximately 14,000
cubic yards of surface soil above the health-based action levels, treating the soil
onsite using soil washing and subsequently backfilling the treated soil onsite; grading
and revegetating the site; incinerating the soil washing wastewater offsite; and
ground water monitoring. The estimated present worth cost for this selected remedial
action is $4,490,734, which includes an estimated annual O&M cost of $20,000 for 30
years.
PERFORMANCE STANDARDS OR GOALS: Remediation goals are based on health-based action
levels or RCRA treatability variance action levels, whichever is more stringent.
Health-based action levels were established for soil based on a 10-6 cancer risk and
include dieldrin 0.155 mg/kg and heptachlor 0.553 mg/kg. Treatability variance action
levels were established for arsenic (90-99% reduction), chromium 0.5-0.6 mg/l (TCLP),
chlordane (90-99% reduction), 2,4-D (90-99% reduction), and 4,4-DDT 0.5-20 mg/l (Total
-------
SAND CREEK SUPERFUND SITE :
OPERABLE UNIT 5
COLORADO ORGANIC CHEMICAL
AND GAlLAGHER PROPERTY
SHALLOW SOILS
-------
RECORD OF DECISION
DECLARATION STATEMENT
Sand Creek Industrial Site
Commerce City, Colorado
Operable Unit No.5
Colorado Organic Chemical and Gallagher Property Shallow Soils
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedy for remediation of shallow soils, from
Operable Unit Five (OU5) of the Sand Creek Industrial NPL Site in Commerce City,
Colorado. The remedy was developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended
by the Superfund Amendments and Reauthorization Act of 1986 (SARA) and the National
Contingency Plan. This decision is based on the Administrative Record for this site. The
State of Colorado has not yet concurred with the selected remedy. The State postpones
concurring until completion of on-site pilot testing of the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed bv
implementing the response action selected in this Record of Decision (ROD), may prese;t
an imminent and substantial endangerment to public health, welfare, or the environment.
DESCRIrnQ1i,Qf SELECTED REMEDY
The selected remedy for OU5 addresses shallow soils contaminated with pesticides and
metals in the Colorado Organic Chemical Company area at the site. This is the second
ROD for this site which consists of six operable units. This response action, when
completed will be the final response action for the Colorado Organic Chemical Company
area surface and subsurface soils. Response actions addressing the remainder of the entire
site and the groundwater underlying the entire Sand Creek Industrial site will be addressed
in separate Record of Decision documents. The ROD for OUI addressed subsurface soils,
OUs 3 and 6 concern a landfill on the site, OU4 will address the site wide groundwater
contamination and OU2 addresses the LC. Corporation acid pits.
A .
The selected remedy will. address' the principal threats posed by the shallow soils and will
protect groundwater resources and prevent direct contact risks through the treatment and
disposal of contaminated soils. The remedy will ensure the long-term protection for the
public and the environment through treatment of hazardous substances. The selected
remedy, soil washing, is an innovative treatment technology and is determined to be the
-------
.
Excavation of contaminated surface soils which are contaminated in excess
of action levels described in Table 7.
Soil washing of the excavated soil to treatment levels described in Table 8.
Incineration of wastewater.
Backfill of the treated soil.
Grading and revegetating the soil.
.
.
.
.
STATUTORY DETERMINATIONS
Consistent with CERClA as amended by SARA and the National Contingency Plan, I have
determined that the selected remedy for Operable Unit No.5 of the Sand Creek Industrial
Site is protective of human health and the environment. I have also determined that the
remedy complies with Federal and State requirements that are legally applicable or are
relevant and appropriate to the remedial action, and is cost effective. The selected remedy
utilizes permanent solutions and alternative treatment technologies to the maximum extent
practicable and satisfies the statutory preference for remedies that employ treatment that
result in the reduction of the volume, mobility, and toxicity of soil contamination at the
site as a principal element.
Because the selected remedy may possibly result in hazardous substances remaining on site
above health-based levels for a land use not anticipated for the area, a review of the
remediation will be conducted within five years after commencement of the remedial action.
to ensure that the remedy continues to provide adequate protection of human health and
the environment.
Q ~/.
J~J. Scher r
Regional Administrator
EP A Region VIII
~. ';';, IfflJ
-------
CHAPTER
I.
n.
m.
IV.
V.
VI.
VII.
VllI.
IX.
X.
TABLES
1
2
3
4
5
6
7
8
FIGURES
1
2
3
APPENDICES
A
B
TABLE OF CO~'TENTS
RECORD OF DECISION SUMMARY
°AGE
Site Name, Location and Description
1
Site History and Enforcement Activities
4
Highlights of Community Panicipation
4
Scope and Role of Operable Unit Response Action
7
Summary of Site Characteristics
8
Summary of Site Risks
10
Description of Alternatives
20
Summary of Comparative Analysis of Alternatives
23
The Selected Remedy
31
Statutory Determinations
33
Exposure Pathways .
Contaminant Routes and Sources
Assumption Summary for Risk Evaluation
Exposure Point Concentration
Risk Characterization Average Soil
Risk Characterization Hot Spot Soil
Chemicals of Concern, Maximum Soil Concentrations,
Desired Removal Efficiency and Action Levels For OU5
. Treatability Variance Requirements
12
13
14
15
16
17
21
34
. Sand Creek. Site
Location and Boundaries of COC Afea
Sand Creek Operable " Unit No.5 - Soil Volume
2
.3
9
ARARS
-------
Record of Decision
Sand Creek Industrial Site
Colorado Organic Chemical Company Area
Operable Unit No.5
Decision Summary
I.
Site Name, Location, and Description
This Recotd of Decision (ROD) describes the remedial action for hazards for OUS, located
within and immediately adjacent to the Colorado Organic Chemical Company (CaC)
property. The hazards addressed in this remedial action are shallow soils contaminated
with pesticides and metals.
The aus area is located within the Sand Creek Industrial Site, a site listed on the NPL in
December 1982. The Sand Creek Industrial Site is located in Commerce City, a city north
of Denver, Colorado (Figure 1). The site and surrounding area are industrialized and
contain trucking firms, petroleum and chemical production/supply companies, warehouses,
small businesses, and several residences. The site study area is bounded on the north by
Sand Creek, on the south by 48th Avenue, and on the east by Ivy Street. The western
boundary is approximated by Colorado Boulevard, and Vasquez Boulevard. Figure 2
illustrates the location and boundaries of OUS.
Within the Sand Creek Industrial Site study area, there are approximately 13 residences
with a total population of about 2S. The day use population, however, reaches several
hundred due to the business and industrial nature of the study area. Water users within the
site study area are served by the South Adams County Water and Sanitation District
(SACWSD). Private wells exist on the site; however, this water is used for industrial and
irrigation purposes.
Treated groundwater is the source of water supply to the SACWSD. Production wells are
located north (downgradient) of the study area. Approximately 30,000 customers in
Commerce City and Adams County are served by the SACWSD.
OUS is located above the 100-year floodplain of Sand Creek. The majority of aus is
located on a bench of relatively flat terrain that slopes down to railroad tracks to the north
and rises to an alluvial terrace to the south.
7
The Sand Creek Industrial Site lies within the vicinity of three other Superfund sites;
Woodbury Chemical, Chemical Sales, and Rocky Mountain Arsenal.
-------
I
sin
LOCATION ~
.
c 0 L 0
R A
D
o
r---
"OCICY RI80UNTAIN
A"SINAI.
I
I
I
I
I
I
I
I
o
I
~.
~'
~
2 J 4
~
~II"
SAND CREEK
INDUSTRIAL SITE
~
In
!
...
::
c
Q
r- J'4+.
S,. A'I.ETON ~ ~
INTERNATIONAL \. "i"i"..-
AI"'O"" -
't. r-~
-~
COI.FAX AVr.
DENVER
r'~1
I I.OW"y L
~AIA ~OACII
- USE ..J
1..-
-
c
z
c
>
c
::
>
~
Vi
=
...
>
!
-I
Figure 1 51t. Location. Sand Cr..k Indult,la' Sit.
-------
~
-zC:
»»
II
=i
---
Figure 2
Sand Cr
-------
II.
Site History and Enforcement Activities
The Colorado Organic Chemical Company plant was first operated at OU5 by Times
Chemical in the 19605 to manufacture pesticides. The company name was later changed
to Colorado International Company (CIC). In 1968, a fire destroyed three buildings at the
CIC plant. An inspection of CIC by Tri-County District Health Depanment personnel in
June 1974 indicated unsatisfactory waste management practices and unsatisfactory worker
safety conditions.
In March 1976, the Colorado Department of Health (CDH) conducted a field inspection
at CIC. The inspectors observed several hundred 55-gallon drums containing pesticides
stored at various places across the COC area. They observed washwater, storm drainage.
and boiler feed water draining into a common surface drainage that flowed off property
towards Sand Creek. CIC was cited for storage and handling violations. A fire occurred
at elc in December 1977, releasing parathion fumes over northeast Denver. The State of
Colorado issued an Emergency Cease and Desist Order against CIC to clean up the eoe
property and adjacent areas contaminated by the fire. CIe declared bankruptcy and re-
opened the operations as Colorado Organic Chemical (COC). cae operations were
essentially the same as CIC operations.
Soil sampling at COC in early 1978 revealed high levels of organophosphate pesticides.
chlorinated hydrocarbons, and thermally-altered pesticides. The State filed a preliminary
injunction against COC/CIC to clean up the residues of the fire. Some contaminated soil
was removed in October 1978.
COC was cited for unsafe drum storage and improper stor.age areas under RCRA
regulations in 1980. Samples of surface liquids collected during the inspection revealed that
surface water discharge contained pesticides (dieldrin, heptachlor, DOE. and DOT).
inorganics (chromium and arsenic). and other organics (chlorinated benzenes and phenols).
Subsequently, EP A filed a number of complaints against COC for other Resource
Conservation and Recovery Act (RCRA) violations. In 1982, a Consent Agreement and
Final Order were issued for the RCRA case. In March 1983. EPA referred to the
Depanment of Justice the matter of COC's RCRA violations and violation of the previous
settlement In June of 1983 a spill of the herbicide 2, 4-D resulted in an additional
Compliance Order to clean up the spill and to comply with previous orders. EP A issued
a CERCLA ~O() Order in March 1984 for cleanup of the site. Between April and
September 1984, removal action was taken pursuant to those orders by COCo which resulted
in the removal of drummed wastes and product, contaminated soil, and fencing of the site.
m.
Highlights of Community Panicipation
~
-
All requirements for public 'panicipation in Section 113(k) (2) (B) (i-v) and 117 of
CERCLA were satisfied during the remedial action process. .
-------
Community relations activities for ti:.: Sand Creek site began in April 1985 when EPA
distributed an introductory fact sheet to residents, businesses, and agencies in the area. The
fact sheet described the site and explained the Superfund process, with emphasis on the
Remedial Investigation/Feasibility Study (RI/FS). In the next few months, EP A personnel
attended a public meeting organized by Citizens Against Contamination; they also compiled
a list of people who owned property in the study area.
EPA mailed a second fact sheet in November 1985. This fact sheet provided information
typically requested during investigation and cleanup of hazardous waste sites. That same
month, EP A also provided a report on water contamination for another public meeting of
Citizens Against Contamination. - l
In January 1986, EP A contacted property owners and Commerce City officials to inform
them of activities at the site. In the spring, EP A prepared a photo display illustrating the
RI/FS process. .
Because South Adams County ground-water contamination and its effects on household
supplies were of concern, EPA surveyed South Adams County residents about their water
use habits during April 1987. Later that year, EPA spoke with residents and businesses
near the site to check the status of methane venting systems near the 48th and Holly landfill
located in the Sand Creek Industrial Superfund Site listed on the NPL, now part of Sand
C:- ~ek OU3. The landfill OWl).ers had installed these systems after an explosion in 1977
resulting from a buildup of methane that had migrated from the landfill.
A Remedial Investigation report describing the extent of contamination within the cae
area was released for public review in March 1988. In May 1988, EPA contacted property
owners to obtain permission to sample and monitor soils on those properties.
In October 1988, EP A met with Commerce City officials to inform them of plans for the
site. The Commerce City representatives also gave their reactions to the cleanup methods
being considered.
In January 1989, the Feasibility Study (FS) which focused primarily on the cae area was
completed. and a remedial alternative was proposed. The remedial action initially proposed
would have involved: excavation and off-site incineration of the most highly contaminated
surface soils; vacuum extraction of VOC's above the ground-water table; and demolition
and off-site disposal of the contaminated tanks and buildings in the COC area.
EP A took several measures to announce the proposed remedial alternative choice and to
seek comments and questions from the public on the Feasibility Study. First, EPA made
copies of the FS Report available to the public in the Adams County Public Library, the
Colorado Department of Health, and the EP A Region VIII library in downtown Denver.
At- the same time, EP A mailed itS third fact sheet, which described a proposed plan as well
as four other remedial alternatives that had been evaluated. Third, EP A announced a
public comment period during which the public was invited to submit comments and
questions. The comment period originally ran from January 13 to February 13, but at the
request of the potentially responsible parties (PRPs), EPA extended the period to February
-------
22. Founh, EP A conducted a public meeting on January 31 to describe the results of the
RI/FS and answer questions from the public. EP A published a press release and a public
notice in each of the Commerce City newspapers, The Commerce Ci~ Sentinel and ~
Commerce Ci(y Beacon. announcing all of these activities.
In response to public comment and subsequent re-examination of the site, a FS Addendum
was completed in July 1989 which presented two additional and innovative remedial
technologies for potential use on the contaminated surface soils in the COC area: biological
treatment and soil washing. It was concluded from the FS Addendum that treatability
studies would be required before implementing either of the additional alternatives.
EP A made copies of the FS Addendum report available to the public and mailed its fourth
fact sheet describing the new proposed plan. The remedy selected in the new proposed plan
included: excavation and off-site incineration of approximately 1,000 cubic yards (CY) of
shallow soils highly contaminated with HOes (.~S ft and> 1000 ppm); vacuum extraction
of the volatile organic compounds in the subsurface soils above the ground-water table;
demolition and off-site disposal of the contaminated tanks and buildings; and either
bioremediation or soil washing for the shallow soils contaminated with HOCs above action
levels. It was proposed that excavation and off-site disposal of the contaminated surface
soils be retained as a contingency remedy, since the implementation of bioremediation
and/or soil washing depended upon the results of treatability studies to be: performed
subsequent to a Record of Decision. An absence of proven bioremediarion and/or soil
washing results on soils contaminated with similar compounds funher warranted retention
of the off-site disposal option.
EPA provided a public comment period in effect from July 19 through August 21, 1989
during which the public was invited to submit comm,ents and questions regarding the FS
Addendum and the new proposed plan. EP A conducted another public meeting on August
1 to describe the new remedial alternative and answer questions from the community. Press
releases and public notice were again published in De Commerce Citv Sentinel and The
Commerce Ci(y 5eacon announcing all these activities.
Only the City of Commerce City responded in writing, and there was limited comment on
the selected remedy during the August 1 public meeting. The primary concern of the City
of Commerce City was that the cae property be remediated to residential-use standards.
A Record of Decision was subsequently prepared which addressed only the highly
contaminated surface soils and the subsurface soils contaminated with volatile organic
compounds. The decision was to implement the preferred alternative which consisted of
vacuum extraction of VOCs, demolition and off-site disposal of the contaminated tanks
and buildings and excavation and incineration of highly HOC contaminated soils.
. .
Remedial action alternatives. for the remaining contaminated surface soil were addressed
in a second feasibility study (FS OUS) which incorporated results from treatability tests.
A proposed plan which was pre'pared arid sent out to the public on July 30, 1990. A public
meeting was held August 9th, at 7:00 PM at the Commerce City community room in
Commerce City. A responsiveness summary addressing the public's comments on aU5 was
prepared and is attached to this Record of Decision.
-------
IV.
Scope and Role of Operable Unit Response Action
During the course of the remedial investigation. conducted from 1984 to 1988, EPA
determined, in accordance with 40 CFR Section 3oo.68(c), of the 1985 NCP that the
Feasibility Study should be divided into operable units in order to remediate site-specific
problems. This conforms with sections 300.5 and 300.430 of the new NCP (March 8, 1990).
Originally, the Sand Creek Industrial Site was divided into four operable units according
to the type of contamination present, type of media affected, and physical characteristics
of the units. The four original operable units are described below:
Operable Unit No.1 -
Operable Unit No.2 -
Operable Unit No.3 -
Operable Unit No.4 -
Soils contaminated by pesticides, volatile organics.
arsenic, and chromium in the Colorado Organic Chemical
(COC) area; contaminated buildings and tanks in the
COC area;
Contaminated soils and ground water in the vicinity of
the LC. Corporation property;
Gaseous emissions, contaminated surface. water and
ground water in the vicinity of the 48th Avenue and Holly
Street Landfill;
Contaminated ground water underlying the entire NPL
site.
As discussed in section III, treatability tests were required to determine the potential
effectiveness of the bioremediation and/or soil washing options for soils contaminated with
HOC's above health based action levels. In an effort to expedite remediation while the
treatability studies were being performed, the original scope of the remediation described
in the OUt proposed plan was reduced. Accordingly, OUt was reduced in scope to include
only the most highly contaminated surface soils, the tanks, buildings and other structures;
and the VOC contaminated subsurface soils. A new operable unit, OU5, was defined to
address the remaining pesticide and metals contaminated surface soils.
The redefmition of operable units will not reduce the overall plan for remediation at the
Sand Creek Industrial Site. OUs 2, 3 and 4 remain unchanged. As of the date of this
ROD, the Sand Creek Industrial Site has been subdivided into the six operable units
described below:
Operable Unit No. t -
.Within.the cae area, excavation of 10 Cy of soils highly
containinated with pesticides (concentrations ~ 1,000 ppm
Halogenated Organic Compounds); subsurface soil
contaminated with volatile organic compounds; and
contaminated buildings and tanks;
-------
Operable Unit No.2 -
Operable Unit No.3 -
Operable Unit No.4.
Operable Unit No. S .
Operable Unit No.6 -
Contaminated soils and ground water in the vicinity of
the LC. Corporation property;
Contaminated surface water and ground water (Class II
aquifer) in the vicinity of the 48th Avenue and Holly
Street Landfill;
Contaminated ground water underlying the entire site;
Within the COC area surface soils contaminated" with
arsenic, chromium and pesticides (concentrations <
1,000 ppm Halogenated Organic Compounds).
Gaseous emissions from the 48th Avenue and Hollv
Street La.ndfill. .
This Record of Decision addresses remediation of Operable Unit No. S. Remediation of
the remainder of the site will be addressed in separate decision documents.
The purpose of the response action for OUS is to protect surface water and ground-water
resources, and address the principal threat in this au by preventing direct contact with
contaminated soils by the public and site workers. This decision represents the second
remedial action decision for this NPL site, and upon completion, will allow the COC area
to be returned to industrial use.
v.
Summary of Site Characteristics
Contaminant C~aracteristics
The contaminants of concern at the Sand Creek Site OUS include the metals; chromium.
arsenic, and the pesticides dieldrin, heptachlor, 2,4' -p, 4-4 DDT. and chlordane. Most of
the contamination present in concentrations above action levels is localized in hOt spots
identified during the remedial investigation. Analytical results of soil samples indicated
chlorinated pesticides are" present in concentrations above action levels in the surficial
and/or shallow soils throughout the OUS area. High concentrations of arsenic have been
. detected in surficial and shallow soils on the COC property and the northern portion of
OUS in localized hot spots' within areas contaminated with pesticides above action levels.
Figure 3 shows the approximate areal extent of contamination at the 0-1', 1'-3', and 3'-5'
depth. The soil volumes to be remediated are defined by the action levels for dieldrin and
heptachlor. These compounds present the greatest risk based on their toxicities. Tbese
compounds are also reflective of the total areal extent of the other compounds. Therefore,
the remaining compoul)ds would be inherently remediated ~uring the clean-up" activities
focused on the soil volumes for dieldrin' and heptachlor. .
-------
LEGEND
Filure )
SAND CREEK OPERABLE UNIT NO.5
Extent o' Dieldrin and Heptachlor
Concentrations Above
Action Levels
~ Bulld..g. and
W LOadIng Docke
ACTION LEVEl SCENARIO
SO'l VOLUME
3,667 rd:J
~ 0 100 i
....., - . ..~.., t--...
Ilf I
I:J
r-
III
1
J
n
., ./: .." ..' . Indu.,,',,- U.. Sl8nd.rd.
'J .,. ""':":.: 0-, '001 deplh 'nl.,..,
~ Indu'lrI.,- U.. St.nd..d.
1-3 ,... ""'II8'nle...,
',000 rd:J
Indu..,',,- U.. SI.nd.rdl
3-~ ,... deplh 'n"'.I'
',050 rd)
TOTALVOLUUE
-------
Affected Matrices Characteristics
Operable Unit No. S has been defined as contaminated soils not addressed by OUl at the
COC area. The OUS soils include surface soils contaminated with arsenic, chromium, and
pesticides ( < 1,000 ppm HOC's). The contaminants are found distributed in many locations
throughout the site, mostly in localized hot spots. The surface soil is found to contain
higher concentrations of pesticides than soils at depth.
The volumes of soil to be remediated were calculated for the compounds which present the
greatest health risk. Those compounds were found to be dieldrin and heptachlor. Total
soil volume calculated for remediation of both compounds in the reasonable maximum
exposure scenario is approximately 14,000 cubic yards. Soil volumes for other compounds
were not calculated separately since they are addressed in the soil volumes for dieldrin and
heptachlor.
Potentially E~osed ~ations
The current population. at risk of exposure consists of industrial workers at the site and
surrounding business locations. The risk assessment for the site delineates the exposure
pathways and presents the potential health risks to the industrial worker. Currently, there
are no residences within the site boundaries and a relatively minor population of less than
25 residences exists in the area. The nearest residents are located three quaners of a mile
from the site. The City of Commerce City presently has this area designated for industrial
use through the year 2010, consistent with present and historic use for the surrounding
area.
~
The potential migration pathways for the contaminants include surface water run off.
airborne distribution and groundwater migration. Surface water runoff is the most probable
pathway due to the fact the surface soils are the most highly contaminated. Airborne
distribution would be possible during any high construction activities occurring at the site
but otherwise would not be considered a major migration pathway since the contaminants
are not highly volatile and natural vegetation covers much of the site. Groundwater
migration is not a primary concern due to the tendency of the contaminants of interest to
adhere to soil panicles. Downward movement of contaminants would occur slowly with
water infiltration rates common to the area.
VI.
Summary of Site Risks
An Endangel'II)ent Assessment (EA) for OUI was conducted for the Sand Creek site (CDM
1988) to evaluate the risks posed by the presence of contaminated soils in the COC area.
The results of the 1988 EA were used in the OUI ROD.
The ~990 EA for OUS utilizing the Ri* Assessment Guidance (July, 1989) identified a.
number of chemical compounds that because of health risks, are chemicals of concern for
OUS. The chemicals of concern identified in the initial RI/FS (CDM 1987) were used in
preparing the OUS endangerment assessment which incorporated new data obtained during
-------
OUI remedial design activities. New action levels and soil volumes were a result of this
effon.
The objectives of the risk assessment were to identify chemicals of concern, define exposure
pathways; determine exposure point concentrations, estimate human intakes, identify known
hazards for each chemical of concern, and determine a carcinogenic and noncarcinogenic
risk for the chemicals of concern.
The chemicals of concern were first identified in the original 1988 site wide endangerment
assessment The selection process for chemicals of concern was originally presented
separately for each medium. For the OU5 risk assessment, only contaminants identified as
chemical of concern for soils were addressed. These chemicals of concern are; arsenic,
chromium, chlordane, 2-4D, 4,4-DDT, dieldrin, and heptachlor.
The exposure pathways were identified in the risk assessment and are summarized in tables
1 and 2. The exposure route for wind erosion air-borne paniculates is inhalation. The
exposure routes for direct contact with soil are ingestion and dermal absorption.
The site assumptions used for the risk calculations including route, medium, group,
frequency, and duration are summarized in Table 3. The assumptions used for human
intake including; age, ingestion, inhalation, exposed skin, body weight, and time on-site
are also included in Table 3. Although the Reasonable Maximum Exposure Scenario for
the area is industrial, risk calculations were made for industrial and residential scenarios
for comparison purpose. The City of Commerce City has previously asked for this
comparison.
In order to address areas affected by high concentrations of pesticides and average
concentrations of pesticides, the data were separated into "hot spot" contamination and
average contamination.
Hot spot contamination represents a potential maximum exposure for the chemicals present
at high concentrations. Both maximum and average concentrations were used in risk
calculations. Exposure point concentrations for the site average and hot spots were
determined from the combined data sets of OUI and OU5. These values are presented in
Table 4.
Best estimates of the average exposure concentrations were determined by the 95%
confidence level of the arithmetic mean for each chemical of concern. Hot spots values
were determined from analytical results for the high concentration areas. These values are
presented in Table 4. These values were then used in the calculations shown on Tables
5 and 6. Table 5 shows that the site aver"' '!e risk is within the EP A's acceptable risk range
Table 6, however, shows that the hot sp~.,) on the site fall outside EP A's acceptable risk
range of 10'" to 10-'. As was shown in Figure 3, the hot spots comprise most of the OU5
area, thus requiring remediation. Soil concentrat.ions for non carcinogenic and carcinogenic
" risks of 10-' are also presented on the ta~les. By obtaining the soil concentrations through
remediation, the excess lifetime cancer risk from combined exposure to all compounds
would be within the" EP A acceptable 10-.-10-8 range. Without remediation of the hot Spots,
the baseline site risk presented by the hot spots would be 2.41xlO-\ outside the acceptable
risk range.
-------
TABLE 1
EXPOSURE PATIIWAYS IN OUS
Reasonaf2k.MMjmum E~osure Scena~ndustrial
RELEASE RELEASE TRANSPORT EXPOSURE
SOURCE MEQW!ISM MEIllilM.. MmI!lM.- ~
COC Spills Soil Surface Entire
Facility Leaks Soils Site
Contaminated Wind Air Airborne Entire
Soil Erosion, Particulates Site
Dust
Generation
Contaminated Vehicular Air Airborne Entire
Soil Traffic Particulates Site
-------
TABLE 2
CONT AMINA1\jTS, ROUTES AND SOURCES
OF EXPOSURES TO BE ADDRESSED IN THE RISK ASSESSMENT
METAlS
INSEcnCIDES
HERBICIDES
2,4-D
Arsenic
Chromium
Chlordane
4,4' -DDT
Dieldrin
Heptachlor
RECEPTOR ROUTE SOURCE
Worker Inhalation Air /Particulates
Ingestion Soil
Dermal Contact Soil
Child
Inhalation Air /Particulates
Ingestion Soil
Dermal Contact Soil
-------
TABLE 3
ASSUMPTION SUMMARY FOR RISK EVALUATIONS
ROUTE MEDIUM GROUP FREOUENCY DURATION
Inhalation Airborne Children 40 D~s ~ 5 Years
Soil Year Day
Airborne Worker ~um 30 Y rs
Soil Year Day
Airborne Resident ~ Age 70 Y rs
Soil Year Specific
Ingestion Soil Children 40 Davs 5 Years
Year
Soil Worker 240 Days 30 Y rs
Year
Soil Resident 365 Days 70 Y rs
Year
Dermal Soil Children 40 Days 5 Years
Contact Year
Soil Worker 240 Days 30 Yrs
Year
Soil Resident 365 Days 70 Yrs
Year
Intake Assumptions
Exposed
Skin Residential
Ingestion Inhalation Surface Body Time
AG ~ate m&/~ Bate m3 Ibr Area m2 Wei&ht ~ On Site f:lli
O. 1 0.0 .21 0.0 16 20
1 .6 200 .21 0.36 16 20
6.90 100 .80 0.49 25 16
9.011 100 1.QO 0.62 35 1~
11 . 17 100 ° 1.05 . 0.50 50 ° 14
Adult 100 1.05 0.50 70 14
-------
TABLE 4
EXPOSURE POINT CONCENTRATIONS
Arsenic:
Chromium
Chlordane
Dieldrin
DOT
2,4-0
Heptac:hlor
Surfac:ela)
(ppm)
18.04
55.64
20.94
3.95
89.24
1.16
3.70
(Hot Spot)
Surfac:elb)
(ppm)
355.00
343.00
38.00
10.20
a.
b.
95% confidence level of the arithmetic mean.
Maximum concentration.
-------
.
I'. C-.IIIIIA". f. - 181111 '.1... Of son (l8unllAt ...-.el)
Table S
Site Average
[[[
MI C8nfl-... hc... U f.lI. 18.. c... 18.. c...
lIMrerc '---'e Cere lneetn'e ,...I.t.he Oronlc Itonr.rc in. Indl..", .... an 1_. an
... 'n.... ... 'n.... I." (... a.ronlc 108. I"K'.: ewe I"",,'e -'-...e'n. 11-'
f... f..... Ar "'-"c "'en I". A.. ~r ror '.,.rd I,.. II.' II.' Cerel"",,'e
-.. """'''. .."".... .""'. ."""... ."""... .008.'"0. .1... . tI'.. ...,.,. .... ...,.,.
..................................~[[[~[[[
,-,,1(1
ar....c t.JtI.., 4.'21-0' 18.04 1.69( M 1.1SI-06 1-69( 01 I.'... 61.118 1.9ft
OW.... '.HI-17 4.121-0' SS.64 S.IM -M -1.14('M I.~f 01 8( 'nS.4" II(
"".CI
D''''' '.111.17 4.121-01 10.94 1.'II-M 1.421-06 1.1.-01 '.111-81 1.114 I.-
1.4" '.111.17 4.'21-0' 1.86 '.091 -06 4."'-01 '.011( 04 8( "".ltl 8(
4.4' .., '.111.17 4.12I.or 89-14 8.181 M I.S9( -~ '."-01 '.111'81 .S. '"~ '.461
I'.'.'" '."'.81 4.12I-or 1.9\ I. ", - 06 1.\9(-16 1.", -01 1.""81 I.'" 1.1"
....".. '.111-17 4.011,01 I.ro 1.411-06 "49(-06 6.9\( -01 '."'-16 It.'" I. '"~
......~ ......: (........ hpes...
-------
1111 C....[lfIIIAIIOI '01 .... CIIf.. IICIIIIOI Of SOil (1.ous1'IAl'UDlrf..
[[[
Table 6
Hot Spots
hc", l If.". Soli Cane. Soli Cane.
118rwercl,.....lc C.ctftDllnle IIot Spot [hronle IInne.re In. Inltlyl,*-' ,...., an ,.... an
--- I"'''. --- Int". Soli [ane. S*hronle Doc. If 'Kit: Cere Ift09mle lonnrcln. 11-'
'.t. '.ior ....1- [ane. Dos. Ay. owr 10 , "...rd Ind.. II,. ..,. C.rel......lc
QRIaII8 't.",.... ..,,.,.~. (""'. (",,,,,.,. (..,.".,. (00'.'"0. (108. . q'.. (..It,. II,. (..,t,.
[[[
. '~IICAIICI
.......Ic
a.r.i..
'.'.'11
'.'91'.,
4.021-01
4.0n .07
0.001 000
0.00(000
0.001000
0.00(000
0.001000
O.OOfoOO
0._.00
II[
61.110
'US.499
~... .
II[
"In
0.,---
1.4.'
,.,....
".'*In
"i.hlor
.. J9I.11 4.021 .07 JS'S . 00 )-nf'~ '.411'04 S.56f.00 '.16(,04 1.114 '."4
t. J9I.01 4.0l( 07 J8.00 ). 57f.OS '.S1I'05 J.5".OJ I[ 6114.111 I[
'.)91'., 4.0l('07 0.001 000 1.001000 0.001.00 1._.00 15.S" 1.)"
'.J9I." 4.0n ,07 )4).00 ).1l('04 1.J8f-04 6.UfoOO 1.11('OJ G.156 I..n
'.)91'01 4.0l( .07 '0.10 9 . ~II( . 06 4.101.06 1.9l('01 1.8Sf.OS 1S.561 I.U'
I.."", .ndt.: [..INet (lIp08ur.
-------
The general hazards associated with the chemicals of concern for OUS are shown below:
Arsenic
Arsenic is associated with an increased incidence of lung, liver, bladder, and skin cancer in
in~ividuals exposed via drinking water and with an increased incidence of lung cancer in
occupationally exposed workers. EPA has classified arsenic in Group A--Human
Carcinogen.
.
Acute effects of arsenic are generally seen only following a large dose. Acute arsenic
poisoning due to ingestion is manifested in gastrointestinal disturbances. The intensity and
onset of symptoms is determined by the physical form, purity and time since last eaten.
Symptoms of acute poisoning are tightness of the throat, difficulty in swallowing, and violent
abdominal pain. Arsenic consumption can also lead to severe high blood pressure and
widespread damage to the central nervous system (CNS). Death may result from cardiac
failure. In less severe cases of occupational exposure, recovery often occurs and may be
complete or show signs of chronic poisoning. Lethal doses of arsenic range betWeen 70 and
180 ug. Chronic and subchronic exposures to arsenic generally affect many of the same
organ systems as those affected by acute exposure. In most cases, effects can be seen only
after chronic low dose exposure. The skin is one of the prime targets of chronic exposures.
Chromium
Chromium is an essential micronutrient and is not toxic in trace quantities. High levels of
soluble chromium(VI) and chromium(III) produce kidney and liver damage. Chromium is
transported across the placenta and concentrated in the fetus. Chronic inhalation exposure
may lead to respiratory damage. Occupational exposures to chromium compounds cause
severe skin problems and inflammation of the larynx and liver. EP A has classified
chromium(VI) in Group A - Human carcinogen based on epidemiological studies of
workers exposed to chromium(VI) via inhalation.
Pesticides
All the pesticides at the Sand Creek Operable Unit No.5 can be classified as chlorinated
hydrocarbons. The environmental and biological persistence of chlorinated hydrocarbon
pesticides presents the special problem of chronic mammalian toxicity resulting from
repeated low-level exposure to these compounds.
Chlordane
Chlordane has been used for control of insects and agricultural use. In recent years, it has
been extensively usee! to control household pests and for certain insects. The principal toxic
effects in humans folloWing "acute, and ,chronic exposures to chlordane include central
nervous system excitation, immune system deficiencies and blood disorders. Chlordane has
not been a common cause of poisoning. All established cases have been associated with
gross exposures. . In most instances, including those with fully recovery, convulsions
appeared within 0.5 to 3.0 hours after consumption or after dermal exposure.
-------
Following ingestion, some people experienced nausea and vomiting before signs of central
nervous system over-activity. EPA's Carcinogen Assessment Group (CAG) has classified
chlordane in Group B2 - Probable Human Carcinogen.
4.4'-DDT
4,4'-DDT has been shown to be carcinogenic to mice, primarily causing liver tumors, but
also causing lung tumors and lymphomas. 4,4'-DDT is also a reproductive toxin, causing
reduced liter size, reduced groWth of offsprings, and fetal death. Chronic exposure causes
adverse effects to the liver and central nervous system. Acute exposure to large doses or
chronic exposure to lower doses may cause seizures. 4.4' -DDT is bioconcentrated and
stored in the fat tissue of most animals. In studies of workers occupationally exposed to
4,4'-DDT by inhalation, no increased incidence of cancer was reported (Ortelee 1958, Laws
et aI. 1967).
.
Experimental and accidental exposures have revealed that a single dose of 10 mgjkg
produces illness characterized by vomiting, headache, and confusion. Acute poisonings
cause a slight decrease in red blood cells and obvious neurological effects. 4,4'-DDT has
been classified by EPA's Carcinogen Assessment Group (CAG) in Group B2--Probable
Human Carcinogen.
2.4-Dichl.QfiWJ1enmcyacetic Acid
2,4-D is not believed to cause cancer, but has been shown to produce weak mutagenic
effects in cultured cells, and to cause birth defects in rats, mice, and hamsters.
Considerable uncertainty exists regarding the toxicity of 2,4-D to human; the minimal toxic
case may be as low as 80 mg/kg, with an average oral dose likely to be fatal estimated to
be 400 mg/kg. Based on clinical data, poisoning can occur following dermal exposure or
consumption. The principle acute symptoms are vomiting, fever, diarrhea, and profound
muscle weakness. Pathological changes have also occurred in the gastrointestinal tract,
liver, lungs, and kidneys. No known chronic human health effects exist.
Dieldrin
Dieldrin can be absorbed by humans from the gastrointestinal tract following ingestion of
the pesticide, and absorbed through the skin following skin exposure. Dieldrin affects the
central nervous system, producing incoordination, headache, gastrointestinal disturbances.
and convulsions. EP A has classified dieldrin in Group 82 -Probably Human Carcinogen.
~
The human toxic effects of heptachlor have not been well documented. Animal studies
indicate that hep~achlor "causes the same kind of illness as that produced by similar
pesticides such as chlordane. It has also been shown to cause chromosomal mutations.
However, DO lethal genetic changes were produced when male mice received large doses
of the pesticide. The deleterious effects of chromosomal changes in humans in inconclusive.
-------
EPA's Carcinogen Assessment Group has classified heptachlor in Group B2--Probable
Human Carcinogen.
EJ(pose~ation and Site J;llik
.
The Sand Creek site is highly industrialized. The day use population may reach several
hundred. The City of Commerce City has projected future land use for the area as
industrial. Therefore, the maximum reasonable exposure scenario for the site is considered
to be for the industrial worker. The risk to the industrial worker was calculated for each
exposure pathway, inhalation, ingestion and dermal. The ingestion pathway was considered
to present the greatest risk. Table 7 shows a comparison of the 10-' action levels to the
maximum and average concentrations found at the site.
The exposure scenarios presenting the highest risk at OU5 is incidental ingestion of
pesticide (HOC) contaminated soils. Other exposure scenarios for the site (inhalation of
contaminated dust and inhalation of compounds volatilizing from the soil) generally present
lower risks.
Two chemicals of concern, dieldrin and heptachlor, were chosen as driver compounds for
OU5 remediation due to their carcinogenicity and concentrations present at the site. If only
these tWo compounds were to be removed from the targeted surficial soils-, a 2.7x10"s
carcinogenic risk (ingestion pathway) would remain on-site for industrial workers. While
this is within the acceptable nsk range, it is important to note that the soils exceeding
dieldrin and heptachlor remediation goals largely include the extent of contamination from
other identified carcinogenic chemicals of concern (4,4'DDT, chlordane. arsenic. and
chromium concentrations did not present a site risk outside of the acceptable 10-4-10-.
range). Therefore, the remediation alternative selected in this ROD will result in the
removal or reduction in concentration of these chemicals of concern to below the 2.7x
lO-s carcinogenic risk for industrial workers.
VII.
Description of Alternatives
The detailed analysis of remedial alternatives, presented in the feasibility study for OU5,
resulted in the development of four alternatives for site remediation. These alternatives
are summarized below.
Alternative No.1 - No Action
The No Action alternative is presented as a basis for comparison with the other
alternatives. Under no action, soil would remain contaminated with toxic chemicals and the
risks described above would remain. No action could be considered feasible only if the
other alternatives could not substantially reduce toxicity, mobility, volume, or the health .risk
associated with the site. Selection of the no. action alternative would require monitoring
of ground-water for thirty years to evaluate movement of contaminants from the site. The
Public Health Evaluation (PHE) would be performed at 5-year intervals as is required
under CERClA/SARA when contaminated material is left on site. Operation and
maintenance costs of approximately 20,000 per year are projected for periodic sampling
-------
TABLE 7
CHEMICAlS OF CONCERN, MAXIMUM AND AVERAGE SOIL CONCENTRATIONS.
AND HEALTII BASED AcrION LEVELS FOR OU5
.
Chemicals of
Concern
Maximum Average
Concentration Concentration
ppm ppm
1170 18.04
66 55.64
343 3.95
76 3.70
355 20.94
15,000 1.16
203 89.24
Action Levels Based on
Carcinogenic:
Risk
ppm
Arsenic
Chromium
Dieldrin
0.155
0.553
Heptachlor
Chlordane
24D
44 DDT
Action levels for 10-8 risk.
By remediating the soils to the carcinogenic risk levels for Dieldrin and Heptachlor, the
overall site risk is lowered to the acceptable risk range of 10-4.10-8.
-------
inspection, and performing the PHE. Assuming a monitoring period of 30 years this
equates to a present worth cost of $604,000.
Alternative No.2 - C~ppin&/Institutional Controls
Alternative No.2 would involve reducing the areal extent of contaminated soil bv
excavating approximately 140,000 cy of the surface soil contaminated above industrial use
action levels listed in Table 7, placing the excavated soil in a designated area of
contamination, and constructing a cap over the entire contaminated area. The cap.
constructed of a three-layer design to comply with RCRA requirements, would prevent
direct contact with contaminated soil, minimize airborne emissions, and minimize surface
infiltration (thereby protecting ground-water resources). Alternative No.2 would be
considered on-site containment.
.
Land use restrictions would be required to ensure long-term maintenance of the cap and
to prevent activities that would disturb the cap or result in contact with or release of
contaminated soil. The long-term effectiveness or permanence is questionable because
containment does not permanently address the contamination and the cap may ultimately
fail. Also, because no treatment would occur, toxicity and volume of contaminants would
not be reduced. Because contaminants are left on-site, monitoring of ground-water would
be required for thirty years, and re-evaluation of the PHE would be performed at 5- year
intervals. Land use would be restricted to industrial use. Institutional controls would be
implemented to maintain the integrity of the cap. Without restricting the land use of the
capped area it is highly likely the cap would fail. Restriction of on-site digging and well
installation would be probable institutional controls required to maintain the cap. The
estimated present worth cost to construct a cap at OU5 is approximately 2,547,170. The
estimated cost for maintenance of the cap is $70,OOO/yr.
Alternative ~o. 3 - Off-site t&lli!filLDisposal
Alternative No.3 involves excavation of approximately 14,000 cy of the contaminated soil
with concentrations above action levels identified in Table 7, transport and disposal at an
off-site hazardous waste landfill, backfilling the excavated area with clean soil and
revegetation of the site. Mobility of contaminants would be reduced through off-site
containment. Long-term effectiveness is considered to be high. A PHE would be required
every 5 years based on CERCLA section 121(c). The estimated present worth cost for
alternative No.3 is $4,903,000. Annual 0 & M costs of $67,000 are expected for short-
term monitoring during remediation activities.
Alternative No.3 was originally proposed as a contingency remedy to augment the
preferred remedy, which is an innovative technology, and in the event that the pH.ot test for
the selected remedy (Alternative No. .4) demonstrates that field scale soil washing is not
successful. How~ver, since the development of the FS and proposed plan, additional
requirements regarding the application of Land Disposal Restrictions to. Alternative
Numbers 3 and 4 became apparent. This information indicates that off-site disposal of soils
in a hazardous waste landfill cannot occur without treatment prior to disposal. The
required treatment for soils with most of the contaminants found at OUS is incineration,
which is the BDAT for most contaminants in the soils. Rough estimates for incineration
-------
are currently $1,000 per cubic yard of soil. This would raise the cost of Alternative No.3
by approximately $14,000,000. The total cost of Alterative No.3 would be approximately
$22,000,000. EPA decided to drop Alternative No.3 as a contingency to the selected
remedy at this time, based upon confidence in the selected remedy and the difference in
costs resulting from the different soil volumes to be incinerated.
Alternative
. .
Soil WasbinLIreatment of Contaminated Soil/Off-Site
. W .
.
Alternative No.4, involves excavation and treatment on site by soil washing of
approximately 14,000 cy of surface soil with concentrations above health risk-based
industrial action levels listed in Table 7. Excavated areas would be backfilled with treated
soil, and revegetated. The contaminated liquids generated during soil washing would be
treated off-site in accordance with Land Disposal Restrictions (LDRs) with residuals
disposed of in a subtitle C landfill.
Soil washing treatment of hazardous substances is an innovative technology. Therefore.
bench scale treatability tests were performed to evaluate the effectiveness of the process
and aid in designing the treatment system. Toxicity and volume of the contaminated soils
would be reduced through treatment (soil washing) and destruction (incineration of liquids
and residual soils). This alternative offers a permanent solution for the site. Ground-water
monitoring would be required for 30 years following completion. and the PHE would be
re-evaluated after 5 years. After additional field testing and design Alternative No.4
would take approximately 9-12 months to implement and 2-3 years to complete. The
estimated present worth cost is $4,490,734. Annual operation and maintenance costs are
expected to be $20,000 per year. This alternative will comply with the LDRs through a
Treatability Variance for the contaminated soil and debris.
VIII. Summary of Comparative Analysis of Alternatives
This section presents a comparison of alternatives using nine component criteria. These
criteria, are set fonh in OSWER Directive 9355.3-02 and the NCP (40 CFR 430(e)(9)(iii).
1.
2.
Overall protection of human health and the environment
Compliance with ARARs
3.
Long-term effectiveness and permanence
4.
Reduction of toxicity, mobility, or volume through treatment
s.
Shon-term effectiveness
6. . Implementability
7.
Cost
-------
8.
9
State acceptance
Community acceptance
CRITERION 1: PROTEcrION OF HUMAN HEALTH AND THE ENVIRONMENT
Alternative No.1- No Action
Under the No Action alternative, no remediation would take place and risk to public health
and the environment would not be reduced, eliminated, or controlled. Toxicity, mobility,
and volume of contaminants would be unchanged. Thirty-year monitoring of ground water
would be required Re-evaluation of the PHE at 5-year intervals would be necessary
because material contamin'ted above health based action levels would be left on site.
.
Alternative No.2- Capping/Institutional Controls
The cap would protect human health to the extent that it eliminates exposure via dermal
contact, ingestion, and inhalation. It would also reduce the potential for leaching of
contaminants into ground water. Because contaminants would be left on-site, reevaluation
of the PHE would be required at 5-year intervals to evaluate the continued effectiveness
of the cap, assess the remaining risks and develop necessary corrective actions to reduce the
risk if warranted.
Alternative No.3- OfT-Site Disposal or Soils
Alternative No.3 provides a high degree of protectiveness of human health and the
environment. Contaminated soils would be excavated and removed from the site.
eliminating the health threat that the contaminated soils presently pose through direct
contact and potential migration to ground water. A ponion of the risk would be transferred
to an off-site landfill that is designed and managed to contain the contaminants.
Alternative No.4- On-Site Washing Treatment or Contaminated Soil/OfT-Site Incineration
and Disposal or Soil Wash Residuals
Alternative No.4, the soil washing alternative, provides a high degree of protectiveness to
human health and the environment. The contaminated soil would be excavated and treated
on-site with a soil washing process. Once soils are treated to acceptable health risk-based
action levels, they would be backfilled and the site revegetated. Residuals from the soil
washing process would be incinerated off-site and disposed of in a RCRA Subtitle C
landfill. This alternative would reduce the health threat posed by direct contact to levels
which would safely allow reuse of the OU5 area- as an industrial area.
CRITERION 2:
CERClA Section 121 requires selection of a remedial action that is protective of human
health and the environment. The determination of protectiveness is based on compliance
of the selected remedy with ARARs and/or hea1th-base~ action levels.
. Applicable 'reQJlirements are those cleanup standards, standards of control. and other
substantive environmental protection requirements, criteria, or limitations promulgated
under Federal or State law that specifically address a hazardous substance, pollutant.
contaminant, remedial action, location, or other circumstance at a CERCLA site.
-------
Relevant and appropriate requirements are those cleanup standards, standards of control,
and other substantive environmental protection requirements, criteria. or limitations
promulgated under Federal or State law that, while not "applicable" to a hazardous
substance, pollutant, contaminant, remedial action, location, or other circumstance at a
CERCLA site, address problems or sitUations sufficiently similar to those encountered at
the CERCLA site that their use is well suited to the particular site.
The ARARs for the alternatives described above are set fonh in Appendix A. The tables
of ARARs in the appendix present the Federal and State chemical, location and action
specific ARARs and those regulations to be considered as they apply to the alternatives 1-
4.
Alternative No.1. No Action
The no action alternative at OUS does not attain ARARs, cleanup goals, or other human
health and the environment protection requirement.
Alternative No.2. Capping/Institutional Controls
Capping could be performed in compliance with ARARs. ARARs include OSHA worker
protection regulations, ambient air quality standards for paniculate and vapor emissions
and Colorado noise abatement standards. The cap would be constructed to comply with
substantive and technical requirementS of RCRA. During cap construction Federal Clean
Air Act National Air Quality Standards and State of Colorado Air Quality Regulations
necessitate the control of vapor and paniculate emissions.
Alternative No.3. OfT.Site Landfill Disposal or Soils
All ARARs penaining to Alternative No.3 can be attained. ARARs include LDRs for off-
site treatment and disposal, OSHA worker protection regulations, paniculate and vapor
emission regulations. RCRA regulations. including LDR, and the rules and regulations
governing the transponation of hazardous materials within Colorado. Federal Clean Air
Act National Air Quality Standards and State of Colorado Air Quality Regulations
necessitate the control of vapor and paniculate emissions.
Alternative No.4- On-Site Washing Treatment or Contaminated Soil/OfT-Site Incineration
and Disposal or Soil Wash Residuals
The ARARs associated with the soil washing alternative penain to excavation, stockpiling,
demolition, soil washing, and backfilling activities for on-site operations, and hazardous
waste transport, incineration emissions and LDRs for on-site and off-site activities. During
on-site activities, dust generation, excavation and incineration noise, and vapor emissions
would be of concern. Workers would have to follow OSHA health and safety regulations
during all phases of remedial action. Federal Clean Air Act National Air Quality Standards
and State of Colorado Air Quality Regulations necessitate the control of vapor and
paniculate emissions. This alternative will .comply with LDRs for soil and debris through
a treatability variance. ~ . . .
-------
LDR Comparative Analysis
Alternatives 2, 3, and 4 were evaluated for to application of the Land Disposal Restrictions
(40 CFR 268, Subpan D) to which, generally, require excavated soils to be treated using
the "best demonstrated available technology," or BDA T, prior to being "placed" on the land
or disposed of outside the area of contamination.
The NCP addresses EPA's policy regarding the Land Disposal Restriction's (LOR's)
treatment standards as applied to soil and debris and their utility at CERCLA sites. EP A
is of the belief that treatment standards developed pursuant to the RCRA LOR program
are, generally, inappropriate or unachievable when applied to contaminated soil and debris
because BDA T treatment may yield little benefit over other treatment methods. A
treatability variance to utilize a different treatment method other than BDA T is available.
A Federal Register Notice dated October 10, 1989 (54 FR 41566) was issued by EPA prior
to tbe final NCP (March 8, 1990), concerning the use of LDR's in Superfund sites. The
Final NCP also addressed the same concerns and policy. The consideration of alternatives
was in conformance with this Notice and the Final NCP (which deals expressly with
treatability variances) and the need not to undertake' a case by case demonstration that
BDAT standards are inappropriate. The principle reason" that BDAT would be
inappropriate is the complexity of the soil and debris mixtures resulting in interference with
treatability.
Under the NCP, to evaluate tbe need for the treatability variance it is necessary to conduct
an evaluation of the following factors. It is first necessary to determine if restricted RCRA
hazardous wastes are present and compare the Superfund contaminants of concern (from
the baseline risk assessment) with BDA T constituents requiring control so that all
constituents for which remediation may be required are identified. The next consideration
is to evaluate whether remedial alternatives involve "placement" to determine applicability
of the LDR's and tben whether the treatment will ensure that the respective technology
process will attain the appropriate treatment levels either through the LOR treatment
standard or a treatability variance alternative treatment level. In accordance with
Superfund goals, reduction of 90% or greater for Superfund primary contaminants of
concern should be attained. The alternatives presented in this ROD were evaluated under
this process.
Alternative 2 requires excavation of soils and construction of a cap over the contaminated
area. Consolidation of soils on-site would not constitute placement and thus the LDR's
would not be triggered.
Alternative 3 requires excavation and placement in an off-site hazardous waste landfill. The
soil would need to be treated on-site or off-site prior to placement in the landfill. BDA T
for ,contaminants in the soils includes different and conflicting treatment technologies.
Therefore, a treatability varian~e would be necessary.. '
Alternative '4 requires excavation of soil ,to' be treated by soil washing and placement of the
clean soils back to the place from which it was excavated. It also requires that the
contaminated' soil washing wastewater resulting from the soil washing process be removed
from the site, incinerated, and placed in a landfill off-site. A treatability variance is
-------
required when the soils treated by soil washing are replaced on-site. The resulting waste
water will be largely a mixture of highly contaminated (over 1,000 mgjt) fluids, silts. and
clays and will be taken off-site for incineration and disposal, as required by BDA T for
California list fluids.
CRITERION 3: REDUCTION OF TOX1CJTY. MOBILITY. OR VOLUME
.
Alternative No.1- No Action '
No reduction in toxicity, mobility, or volume would be achieved under the No Action
alternative. Contaminants would continue to move from the site, affecting surface water,
ground water, and soils.
Alternative No.2- Capping/Institutional Controls
The capping alternative would not reduce toxicity or volume because the waste would not
be treated. Mobility would be reduced to the extent that the cap prevents surface water
and soil movement from the site and to the extent that the cap prevents infiltration of
water and potential movement of contaminants to ground water. A significant reduction
in mobility is expected for the capping alternative.
Alternative No.3- OO'-Site Disposal
Alternative No.3 would achieve a significant reduction in toxicity, mobility, and volume
through transferring soils to a facility designed to contain hazardous wastes. The potential
for movement of contaminants into groundwater beneath OUS from the surface soils would
be eliminated.
Alternative No.4- On-site Washing Treatment or Contaminated Soil/OO'-Site Incineration
and Disposal or Soil Wash Residuals
The soil washing alternative would significantly reduce the toxicity and volume and mobility
of contaminantS on-site and by eliminating the source of surface soil contaminantS.
CRITERION 4:
Alternative No.1- No Action
Because contaminantS would continue to move from the site, posing a potential health
threat, the No Action alternative would not provide a long-term or permanent solution.
Continued monitoring of the, site would provide data on how natural attenuation and
chemical degradation would reduce the threat to human health and the environment and
the time period to reduce the threat.
Alterative No. Z . Capping/Institutional Controls
Capping is not considered a permanent solution because wastes would remain untreated on
site. Long-term effectiveness for protection of human health and the environment would
be related to mainten~nce and monitoring the effectiveness of the cap. Long-term
maintenance of the cap could provide' control of contan,tinant movement and prevent risk
of direct contact with contaminants an.9 exposure to airborne emissions. With proper
maintenance, the cap would be effective in preventing leaching of contaminants into the
ground water. '
-------
Alternative No.3- 0 rr-Site Disposal or Soils
Alternative No.3 cannot be considered a completely permanent environmemal solution.
because contaminantS and incinerator residuals would be transferred to an off-site facilitY.
Alternative No.3 would provide long-term effectiveness for protection of human health arid
the environment at the site.
Alternative No.4- On-Site Washing Treatment or Contaminated Soil/OfT-Site Incineration
and Disposal or Soil Wash Residuals
This alternative would achieve significant long-term effectiveness and permanence through
the soil washing process which would extract chemicals of concern from less contaminated
soils and achieve acceptable health risk-based levels on-site. This would provide a
permanent solution for the site. Off-site landfilling of all incinerated residuals would
effectively immobilize any remaining contaminants, and long-term risks would be negligible.
CRITERION 5:
Alternative No.1- No Action
The No Action alternative would not provide any short-term effectiveness.
Alternative No.2- Capping/Institutional Controls
The success of alternative No.2 to achieve shon-term effectiveness is related to the degree
that production of airborne paniculates and vapor is controlled during remediation, to
minimize exposure risk to workers and the surrounding populace. The degree of short-term
risks would be less tQan that of other alternatives due to a relatively quick construction
period. Air monitoring during implementation would be required to evaluate risk and
institute any corrective action.
Alternative No.3- OfT-Site Disposal of Residuals and Soils
Effectiveness presented by alternative No.3 would be less than that of the no action
alternative. Implementation time would be reduced because there would not be a need
to construct a landfill or backfill soils into it. The off-site landfill would have the necessary
facilities and pollution control equipment to contain soils and prevent emissions during
treatment/disposal.
Alternative No.4- On-Site Washing Treatment of Contaminated Soil/OfT-Site Incineration
and Disposal or Soil Wash Residuals
Remediation of soils at the COC area employing soil washing would take approximately 2-
3 years to complete. Workers and the nearby community could potentially be exposed to
slightly elevated risks during soil handling and treatment activities. These risks, however,
can be reduced to acceptable levels by instituting protective and preventative measures. A
site-wide air monitoring program would be in operation during remedial activities with this
alternative.
-------
CRITERION 6: IMPLEMENT ABILITY
Alternative No.1 - No Action
The No Action alternative is readily implementable.
Alternative No.2 - Capping/Institutional Controls ,
The cap alternative is highly implementable using standard construction techniques. The
alternative poses some logistical problems associated with the presence of a building,
railroad, underground pipeline, and other utilities adjacent to the site. Detailed planning
would be required,to address reconstruction or rerouting of these rights-of-way.
Alternative No.3 - Off-Site Disposal or Residuals and Soils
The construction aspects of Alternative No.3 are highly implementable using standard
construction techniques and equipment Implementability of landfill disposal would be
dependent on the capacity of these facilities at the time of remedial action. These
problems could result in a delay in remedial action, but do not preclude off-site disposal.
Alternative No.4 - On-site Washing Treatment of Contaminated Soil/OfT-Site Incineration
and Disposal of Soil Wash Residuals
This alternative combines incineration, containment, and soil washing technologies. The
limited staging and operations space at OUS would necessitate a phased construction and
treatment approach. Off-site land disposal is implementable with standard techniques and
equipment, but is dependent on the capacity of these facilities at the time of remedial
action. Although soil washing has been successfully demonstrated with certain types of
compounds, its effectiver in treating the area's complex mixture of contaminants is
uncenain. Bench scale treatability test results of the OUS soils indicates effective removal
of the contaminants is dependent upon the soil washing solution chemistry to determine
if all the contaminants can be removed and to aid in designing the treatment system. A
pilot test would be necessary to determine actual implementability.
CRITERION 7: COST
Alternative No.1 - No Action
The cost of the No Action alternative is due primarily to site operations and maintenance
which includes periodic sampling, inspection, groundwater monitoring and performance of
a PHE at S-year intervals. Annual cost is estimated at S20,OOO and present worth cost over
30 years is estimated at S604,000.
Alternative No.2 - Capping/Institutional Controls
The estimated present worth cost for construction of a cap at OUS is approximately
S2,547, 170. This cost includes construction, O&M, and periodic monitoring. AnnuaIO&M
costs are expect~d to be S67,000.
Alternative No. 3- OfT-site Disposal or Residuals and Soils ,
Th~ estimated present worth cost for Alternative No.3 is S4,903,000 plus approximately,
S14,OOO,000 to accommodate off-site incineration prior to disposal in accordance with LDRs.
The cost assumes disposal at an in-state landfill, and the cost may be higher if transport out
-------
of state is required. Annual O&M costs are expected to be $67,000 per year during
remediation activities. .
AJternative No.4- On-Site Washing Treatment of Contaminated Soil/OfT-Site Incineration
and Disposal of Soil Wash Residuals
Costs associated with the soil washing alternative are uncenain since this is an innovative
technology. The estimated present wonh cost for this alternative is $4,490,739 for an
industrial scenario. Annual O&M costs are expected to be similar to alternative 3 at
approximately $70,000 per year.
CRITERION 8:
The State has not yet concurred with the selected remedy. The State postpones concurring
. until completion of on-site pilot testing of soil washing. The State has indicated a
preference for the alternative in correspondence with EP A The correspondence is attached
to this ROD following the Responsiveness Summary.
AJternative No.1- No Action
The State finds this alternative unacceptable due to continued exposure to the public,
potential contamination of surface and groundwater, and lack of usability of the site.
Alternative No.1 - Capping/Institutional Controls
The State is not in favor of this alternative because the contaminated soil will remain on-
site and require long-term maintenance of the cap to ensure protection of public health and
containment of the waste. The land use will be excessively restrictive.
Alternative No.3. Oft-Site Disposal or Residuals and Soils
The State finds this alternative acceptable as it fulfills all the remedial objecth -.:i.
Alternative No.4- On-Site Washing Treatment of Contaminated Soil/OfT-Site Incineration
and Disposal of Soil Wash Residuals
This alternative is preferred by the State because it fulfills all the remedial objectives and
in addition minimizes waste. As the projected cost of this alternative is speculative, the
State will re-evaluate this alternative as compared to alternative No.3 when new cost
figures become available.
CRITERION 9:
Comments in writing were received from four panies, the State of Colorado, the City of
Commerce City, one of the Potentially Responsible parties, and a trust set-up by the same
PRP. The City and others who attended the August 9, 1990, pubic meeting were in
agreement with EP A's preferred and contingency remedy.
The former property owner and the trust set-up by the former prope.rty owne~ believe that
capping will :equately remedy the health risk presented .by t~e site.
. ,
Specific comments received by the EP A are listed and responded to in the Responsiveness
Summary (Appendix B).
-------
Alternative No.1- No Action
The community would prefer an alternative that reduces the risk present at the cae area.
Alternative No.2- Capping/Institutional Controls
Community acceptance of capping is expected to be greater than for no action but less than
that for a treatment alternative. However, one Potentially Responsible party indicated that
capping would be the least expensive method of addressing the problem.
Alternative No.3- Ofl'-Site Disposal or Residuals and Soils
Alternative No.3 would be acceptable to the local community and the City of Commerce
City. Contamin,nts would be removed, and the health threat would be reduced such that
cenain uses of the land would be permissible.
Alternative No.4- On-Site Washing Treatment or Remaining Contaminated Soil/OfT-Site
Incineration and Disposal or Soil Wash Residuals
It was indicated that this alternative would be preferred by the City of Commerce City since
contaminants would be removed. and the health threat would be reduced to permit
industrial use of the land.
IX.
The Selected Remedy
Based on consideration of the requirements of CERCI.A and the NCP. the detailed
evaluation of the alternatives, a statutory preference for treatment, and public comments.
EPA has selected Alternative No.4 on-site soil washing of contaminated soil/off-site
incineration and disposal of soil wash residuals.
Specifically, the selected remedy is composed of the following elements:
Excavation of surface soil contaminated above the action levels listed for the
primary contaminants of concern in Table 7.
Soil washing of the excavated soils in an on-site treatment unit to the action
levels listed in Table 7.
Off-site incineration of soil washing wastewater.
Replacement, grading, and re-vegetation of the area.
Excavation of- the approximately 14,000 CY of contaminated surface soil will be
accomplished using standard construction implements (backhoes, bulldozers, etc.). The
excavated soil will be placed in a hopper on the soil washing unit. The soil washing unit
will likely be mounted on flat-bed truck trailers and be composed of several washing and
soil separating units. The soil is separated into various size panicles to si~plify the washing
process and increase the overall efficiency. Typically, the very fine (small) panicles are not
washed very efficiently or s'eparable from the wastewater due to their physical characteristics
and are taken off-site for incineration.
-------
The remaining products from the soil washing process are the larger soil panicles treated
to action levels, and the waste water. The treated soil will then be replaced on-site and re-
vegetated. The alternative would take approximately 9-12 months to implement and 2-3
years to complete. The estimated present wonh cost is $4,490,734. Annual O&M costs are
expected to be $20,000 per year.
Because hazardous material may remain on-site above health base levels for a land use not
anticipated, a Public Health Evaluation and will be performed every 5 years for the purpose
of reevaluating the hazards posed by the site and assuring that the remedy remains
protective.
The public will likely observe some excavation activities and increased truck traffic near
52nd Avenue and Dahlia Street under this remedial effort. There will also likely be
additional fencing, storage of equipment, and some decontamination activities (truck
washing) visible from Dahlia Street.
Land Disposal Restriction Treatability Variance for the Selected Remedy
Alternative 4 concerns excavation of soil to be treated by soil washing and placement of the
clean soils back to the place from which it was excavated. It also requires that the
contaminated soil washing wastewater resulting from the soil washing process be removed
from the site, incinerated, and placed in a landfill off-site. A treatability variance is
required when the soils treated by soil washing are replaced on-site. The resulting waste
water will be largely a mixture of highly contaminated (over 1,000 mgl t.) fluids, sitts, and
clays and will be taken off-site for incineration and disposal, as required by BDA T for
California list fluids.
AlternJ.tive 4 is the selected remedy premised upon the results of treatability studies which
provided technically sound reasons to believe soil washing will perform effectively. This
innovative technology has not been tested on-site and treatment standards are not available
since actual performance data is not available to indicate that LOR treatment standards can
be meet consistently for all soils and debris. Though it is believed soil washing will achieve
reduction of contamination to levels demonstrated on Table 7, it is necessary to seek a
treatability variance due to the absence of performance data.
The need for the treatability variance resulted from a determination that restricted RCRA
wastes were present on OU5 which were compared with the Superfund constituents of
concern. The alternatives were evaluated to identify if "placement" would occur to
determine if the technology will attain LDR treatment standards, or if necessary, alternative
treatment levels established by a treatability variance. The presence of restricted RCRA
wastes, the need for placement, and the decision to employ soil washing resulted in the
need for a treatability variance for this selected alternative. During implementation of this
remedy periodic analysis using the appropriate testing procedure will be undertaken to
ensure alternate treatment levels for the BDA T constituents requiring control are being
attained and ~hus can be land disposed Without further treatment.
-------
Remediation Goals
The excavation of the contaminated soils above the health based action levels listed in
Table 7 will be guided by sampling during excavation, and accomplished through the use
of standard construction equipment. The soil will be treated to the treatment levels listed
in Table 8, which represents a combination of health based action levels and treatability
variance action levels for the chemicals of concern, which ever is more stringent.
The intention of the remediation effort is to return the area to industrial use as planned
for by the City of Commerce City. This can be accomplished, as described in the Summary
of Site Risk section of this document, by excavation and treatment of dieldrin and
heptachlor contaminated soils to the action levels listed in Table 7 (and repeated below in
Table 8). However, in compliance with LDRs and the preamble of the NCP with respect
to the use of treatability variances at Superfund sites, the treated soils cannot be replaced
on-site until the chemicals of concern have been treated to treatability variance levels.
Health based action levels for dieldrin and heptachlor are more stringent than the
treatability variance levels, and will therefore be used. However, the soils contaminated
with the remaining chemicals of concern will be treated to the treatability variance levels
indicated in Table 8 prior to replacement on-site.
The wastewater resulting from the soil washing process will be a mixture of solvents, silts,
and fine clays, all contaminated above 1,000 mg/ t HOCs. Since this fluid is a LDR
"California list" waste which requires incineration prior to disposal, the remedial action will
be performed accordingly.
Ground water on-site will be monitored for thirty years and a Public Health Evaluation
(PHE) will be performed every five years following remediation. The net present wonh
for the selected remedy is $4,490,000 and implementation will take approximately 9-12
months.
x.
Statutory Determinations
EP A's responsibility at Superfund sites is to select and implement remedial actions that are
protective of human health and the environment. In addition, Section 121 of CERCLA
provides several other statutory requirements and preferences. These statutes specify. that
the selected remedial action for the site must comply with applicable or relevant and
appropriate environmental standards established under Federal and State environmental
laws unless a waiver is granted. The selected remedy must also be cost effective and utilize
permanent treatment technologies or resource recovery technologies to the maximum extent
practicable. The statute also contains a preference for remedies that permanently or
significantly reduce the volume, toxicity, or mobility of hazardous substances. The following
sections discuss how the selected remedy for Sand Creek OUS meet these statutory
requirements. .
-------
TABLE 8
TREATMENT LEVELS
Compound Action Level Rational
Dieldrin 0.155 ppm Health Based
Heptachlor 0.553 ppm Health Based
Arsenic 90-99% reduction Treatability Variance
Chromium 0.5-6.0 (TClJP) Treatability Variance
Chlordane 90-99% reduction Treatability Variance
2,4-D 90-99% reduction Treatability Variance
4,4-DDT 0.5-20 (lW A) Treatability Variance
z
TClJP Toxicity Characteristic Leaching Procedure.
lW A: Total Waste Analysis.
-------
1.
Protection of Human Health and the Environment
This remedy will reduce the direct contact threat currently posed by soils and will minimize
the possibility of futUre adverse effectS on ground-water quality by treatment of the most
concentrated sources of waste above the water table and restricting the area to industrial
use through institUtional controls. There are some shon-term risks associated with the
selected remedy during soil handling operations, but these can be minimized with protective
and preventative measures such as dust control measures.
2.
Attainment of ARARs
Remedial actions at Sand Creek (OU5) will be undenaken in accordance with all applicable
or relevant and appropriate requirements (ARARs).
Any regulation, standard, requirement, criterion, or limitation under any federal or state
environmental law may be either applicable or relevant and appropriate to a remedial
action, but not both.
Criteria, advisories and guidelines that are not law may be used to ensure protectiveness
in the absence of ARARs, or when ARARs are not sufficient. These criteria, advisories,
and guidelines fall in the "to be considered" (TBC) category and can be used to ensure
protection.
ARARs may be classified into three .general categories:
o
Chemical-specific - related to the level of contamination allowed for a specific
pollutant in various environmental media (i.e., soil, water, and air),
o
Location-specific - related to the presence of a special geographical (e.g.,
floodplain or wetland) or archeological area at or near the site, and
Action-specific - related to a method of remedial action identified as an
alternative for the site (e.g., disposal requirements or incineration standards).
o
The selected remedy of on-site soil washing of contaminated soil/off-site incineration and
disposal of soil wash residuals would comply with all applicable or relevant and appropriate
chemical-, location-, and action-specific requirements (ARARs). The primary ARARs
peninent to the selected remedy are summarized below.
o
Chemical-specific ARARs
Land Disposal Restrictions - Threshold concentrations for treatability
variance for Alternative No.3.
BDA T for all alternatives.
-------
o
Location-specific ARARs
None
o
Action-specific ARARs
Federal
A PHE must be performed at least every 5 years (CERCLA
Occupational Safety and Health Act (OSHA)
121(c»
The requirements of 29 USC Sections 651-678, and 29 CFR 1910.120 which
regulates worker health and safety, must be followed.
Land disposal restrictions 40 CFR 268 Subpart D.
State of...CQlorado
CRS Section 25-123-101, et. seq. must be adhered to maintain compliance
with the State of Colorado noise abatement requirements.
6 CCR 1007-3 Part 99 will need to be followed. This regulation requires
notification of hazardous waste activities when hazardous waste is generated.
The manifest requirements of 6 CCR 1007-3 Part 262 Subpart B must be
followed for off-site transportation of hazardous waste.
The pre-transport regulations of 6 CCR 1007-3 Part 262.30, .31 and .33 must
be adhered to for off-site transportation of hazardous waste. .
An EP A identification number must be obtained for transporting of hazardous
waste per the requirements of 6 CCR 1007-3 Part 263.11 (A).
CCR 1001-3 Section VIB will be followed to regulate air emissions.
Appendix A presents the ARARs and TBCs for Sand Creek OU5. The ARARs as they
are pertinent to each of the four alternatives noted in the last column of the table.
3.
Cost Effectiveness
The selected remedy is cost effective in mitigating the risk posed by contaminated soils in
a reasonable period of time. ,To provide further assurance that cost effectiveness is part of
the choice of remedial action, a cost ben~fit analysis will be performed as part of 'the results
of the pilot test. The selected 'remedy effectively and permanently reduces contamination
to acceptable levels. .
-------
Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Maximum Extent Practicable
US EP A and the State of Colorado believe the selected remedy represents the maximum
extent to which permanent solutions and treatment technologies can be utilized in a cost-
effective manner for the final remedy at the Sand Creek site. Of the alternatives that are
protective of human health and the environment and comply with ARARs, US EP A and
the State have determined that the selected remedy provides the best balance of trade offs
in terms of long-term effectiveness and permanent reduction in toxicity, mobility or volume
achieved through treatment, short-term effectiveness, implementability, cos~ also considering
the statutory preference for the treatment as a principal element and considering state and
community acceptance.
4.
s.
Preference for Treatment as a Principal Element
By washing the contaminated soil with solventS and water, the selected remedy satisfies the
statutory preference for remedies that employ treatment of the principal threat which
permanently and significantly reduces toxicity, mobility or volume of hazardous substances
as a principal element.
Responsiveness Summary
The Responsiveness Summary is found in Appendix B of this document.
-------
TABLE 1
ARARs FOR SAND CREEK OU5
CONTAMINANT.SPECIFIC ARARs AND TBCs
AppIicebie or Applies
Sl8nd8rd, R",emenl. R"'anl end 10
Cd.., or UrnIIaIion Cilallon : It!scripllon Appropriale Commenl Ahem.llve
Feder.. MARl
NaIIon8l PrWn8ry Drinking Waler 40 Cfft Plrt 141 Esaablishes heaKh.b8sed sl8ndards 'or NoJNo
S88ndlrds public waler syslems (millimum
conlaminanl levelst
lOR Trealmenl Slendards 40 CFft 148 Eslablishes BOAT Irealmenl slandards 'or VeslYes 13,4
waslewaler 8nd non waslewalw and
eIIeclive dales
DIeldrin 40 CfR 148 P037 Non wlslewaler waslewaler VeslY es Eleclive dal. 8/8/90 13.4
Tolal TClP Tolal TClP
0/13 mg/t 0017 mg/t NA
BOAT ~ Biological Ireelmenl or
Incineration wet.- ollidalion toIowed
bV carbon adsorplion
H8pC8c:h1or 40 CFR.I48 P059 Non waslewaler W8slewaler VeslYes Erreclive dele 8/8180 13,4
T olal TCLP Tolal TCLP
0.066 NA 0.0012 NA
0066 0.016
(heplachlor
epOliidet
BOAT BOAT
Incineralion Biological trealmenl or
wet - oxidation toIowed
by carbon adsorplion
Arlenlc 40 CfR 148 DOO4 Non waslewaler Waslewaler Ves!Yes Eleclive dale 5/8/92 nonwaslew81er, $3,4
Tolal TClP ToialTClP 5/8/90 w8slewller
N/A 5.0 5.0NA
BDAT BOAT
-------
1
TABLE 1
ARARs FOR SAND CREEK 0U5
CONTAMINANT. SPECIFIC ARARs AND TBC.
Non waslewaler Waslewaler
Tol81 TClP Tolal TCLP
0.13 NA 00033 NA
BOAT BOAT
Incineralion Biologicaillealmeni wet
air oxidalion lolowed by
carbon adsorption
Non wastewa'. Wastewater
Total TCLP No number
10 NA devetoped
BOAT BOAT
Incineration Inclnerallon or
biodegradation or
chtlRlical oxida.ion
OOT 40 CFR D061 Non wastewa.er Wastewa'er VeslYes Etfectlve dale 8/8180 13, 4
Total TClP Tot.' TClP
0.087 NA NA
0.0039 O.PooT
0.0039 P,PooT
0.023 O.P'DDD
0.023 P.P'DOD
0.031 O.P'OOE
0.031 P.P'OOL
BOAT BOAT
Incineralion Biological trea'menl or
wet ai' oJCidation IoIowed
by carbon adsorption
2.4-0 40 CfR Y240 Non waslewaler Wastewater VestYes Ettective dale 8/8190 13.4
To'al TClP Tolal TCLP
10 NA 0.71 NA
BOAT BOAT
Indlleralion Biological 'rea'men. or
wet air oxidation toIowed
by carbon adsorplion
2
Slandard. R&CJ*emen..
Crilerla. or Lmta.ion
Cilallon
Feder.. ARARs
Chlordane
40 CFR 148 V036
2.4-0
40 CFR 148 DOli
Description
Applicable or
Relevanland
Appropriale
Comment
Applies
10
AIIemative
VeslYes
Elective dal. 8/8180
'3.4
VestY es
Elective dale 8/8180
-------
T ABl E 1
ARARs I ~ANO CREEK OU5
CONTAMINAN1.~'fCIfIC ARARs AND TOCs
Sl8nd8rd. R""""t.
c.ttn. Of linilalion
Feder.. ARARs
Ctvomlum
.v..te SIIMm Tr.lmenl,lDisposal
JIeM All Ad
Ctlallan .
40 CfR 148 0001
Clean Waler Act.
Sec:Iion 30 I 0
40 CfR 122.44(a)
40 CfR 125.100
Clean Waler Act
$ecIion 310
CM, Bal 173
40 CfR :»2.21(j)
Oes~lion
Non Waslewaler Waslewaler
Tolal TClP Tol8I TClP
N/A 5.0 50 NA
BOAT BOAT
Ctvomlum Chromium
reduclion reduclion
loIowed by IoIowed by
slaWUal1Ol'l precipilalion and
dewalering
Conlrol 01 direct discharges from poinl
sources V18 wa:.le waler Irealmenl
lechnologies.
Direcl discharye ollrealed wasle slreams
10 on.sile surlace waler.
Sialionary sources which emit > 100
lons/yr. 01 any regu!aled po"lanl.
3
Appbble or
R_8II1 and
Appropriale
VeslYes
No/No
No/No
NolYes
Comment
Applies
10
AIIemlilive
Eneclive dale 8J8I8O
13,4
No sile runollio . surface waler bodv via
ditch, culvert. slorm sewer. Of OIher
means.
No on sile surface waler.
-------
T ABI E I (continued)
ARARs fOR SAND CREEK OU5
LOCATION SPECifiC ARARs AND TBCs
SIan_d. Requlremenl.
Crt.., OIlmilalion
Federa' ARARs
Natlon8l Hisloric Presentation Act
'rcheologica'
f»resetVation Act
and
Historic
"istoric SlIes,
"'tiquiUes Act
Buildings
and.
'ish and Wildlife Coordination Acl
ndangered Species Acl
lean Water Act
oodplain
ebb
40 USC Sec. 470
40 CfR Sec. 6.301(b)
36 CfR Part 800
18 use Sec. 469
40 CfR Sec. 6301(c)
16 use Sec. 461.467
40 CfR Sec. 6.~I(a)
t6 use Sec. 661-666
40 CfR Sec. 6.302(g)
16 use 1531
50 CfR Part 200
50 CfR Part 401
33 use Sec. 1251.
1376
40 CfR 264 IIt(b)
40 ct-n 141.~
Description
Requires federal agencies to lake inlo
account Ihe enect 0' anv federally-
assisled undertaking 01 licensing on anv
diSlrict, sile, building, Slluclure, 01 object
Ihat is included In 01 eligible lor inclusion
in Ihe National Register 01 Historic Paaces.
Eslablishes procedules to provide lor
presentalion 01 historical and archeological
dala which rnrghl be destroyed through
aheralion of lerrain as a result 0' a f el1t..""
construction prolect or a f etl. ily
licensed aclivllV or program.
Requires f ederalagencies to consider Ihe
exislence and Iocalion 0' landmarks on
Ihe Nalional Ht!9istry 0' NaluralLandmarks
10 avoid undesirable impacts on each
landmark.
Requires consultalion when federal
department or agencV proposes or
authorizes anv modilication 0' any slream
or olher waler body and adequate
provision lor plotection 0' lish and wildli'e
resources.
Requires aclion to conserve endangered
species wilhin critical hablls upon which
endangered species depend. includes
consuhallon wllh Department 0' Inlerior.
Design laedllles 10 p,evenl washoul 01
halartlous wasle.
4
Applicable 01
Relevant and
Appropriale
NolNo
No/No
NolNo
NolNo
NolNo
No/No
Comment
The remedy does not effect any dslricl.
slle. building, .tructure, 01 oblecllisted on
01 ellgibIe'OI the National Regisler.
The remedy does not effect hlstoric8f or
.rcheological dB...
The remedy does not eflect anv Natural
Landmark.
Ahem.tives developed will not modify
strams.
No endangered spedes ..e present on the
COC site.
NOI ill IIootlplaJl'l.
Applies
10
-------
TABLE 1 (conlinued)
ARMs fOR SAND CHEEK OU5
LOCATION SPECifiC ARAns AND laCs
Sl8ndlld. Recpemenl,
CriI.., or Llmilalion
federal ARARs
Dredge or fil Requiremenls (Section
4(4)
CIe8n Wal. Act, Section 404 -
E.eculive Order on
Managemenl
floodplain
Wilderness Act
Nalional Wlldlile Refuge Syslem
Sc:enic River Acl
Coaslallone Managelllt!nl Acl
Cblion .
40 CfR, P8l1 8
40 CfR 264, Subpart a
40 CfR 257.3. I (a)
16 DSC 661
Executive Order 11988
40 CfR p.,.. 230, 231
33 CfR P"'s 320-330
Exec. Order No. 11,988
40 CfR Sec. 6.302(b)
Appemb A
16 use Sec. 1131
~ CfH 35.1
16 USC Sec. 668
~ CfR Pari 27
16 USC Sec. 1271
40 CfR Pari 6,302(e)
16 USC S~. 1451
Descriplion
Avoid adverse effecls, minimize harm and
avoid incompadJle devdopmenl.
Requires permils lor discharge 01 dredged
or iii malenal inlo navIgable walers,
Requires federal agencies 10 evaluale Ihe
polential effecls o. aClions Ihey may lake
in a floodplain 10 avoid, to Ihe maximum
8111elll possible, Ihe adverse impacts
aSSOclaled with direci and indireci
devetopmenl o. a Ioodplain.
Adminisler 'ederally owned wilderness
..,ea 10 leave it unimpacled.
Ht!slricls acllvilit!s wilhin a National Wddli'e
He'uye.
Prohiblls adverse t!ffecls on scenic river.
Conduct adivities in accordance wilh
slale aVI'lOvcd lllanagcllleni 1.lIoy,am.
~
Applicable or
Relevanl and
Appropriate
No/No
No/No
NolNo
No/No
No/No
No/No
No/No
Commenl
Nol in 1IoodpIain.
A permit is not required 'or onSlle
CERCLA respon.. aclions. bul
subSl8nlive requiremenls would be mer "
en alltmalive developed would involve
discharge of dredged or . malerial inlo
navigable walers. This Ia 001 anticipated.
II an "ernelNe developed lhal would
affect a ~ this would be
applicable. Oper... Unit No. , Ia Iocaled
oulside of the 100-year ~.
No wilderness ar. on-slle or adjacenllo
slle.
No wilderness ar. on.site or adjacenllo
sIte.
No scenic river in ar..
Alea IS noiln coaslalzone.
Applies
to
-------
T AOl E 1 (conlinued)
ARARs FOR SAND CREEK OU5
lOCATlON.SPECIFIC ARARs AND TOCs
Sland8rd, Requiremen.,
Crita, or LlmUlion
Federal ARARs
Wellands
Siale ARARs
Requlremen.s for Siting 01 Haz8ldous
Was.. Disposal Sites
Colorado Hazardous
Managemen. Regulallons
Wu..
Regula.ions Pertaining '0 Solid Was.e
Disposal Sites and f acilihes
Colorado SIa.. His'orical Society
Citation
Execulive Order 11990
40 CFR, Pan 8
8 CCR 1007.2, PI II,
Sec'ions 2.1, 2.4, and
2.5
6 CCR 1007.3
6 CCR 1007,2,
Sec.ions 1.3.2,2.1,2.2,
2.4,4.',6.'
Seclions 24 80.201,
202, 211; Seclions 24.
801.101, 102, t03, 104,
108
Des' lion
Avoid impacts and conslruction in
wellands, p,eserve and enhance. .
GeoIogic/HYdrologic condilions must
assu,e wasle isolalion Irom exposure
palhways lor 1000 years. Siting must
assure short. and long 'erm prOlect,on of
human heahh and environment.
Siting is rest,icted in vicinity 01 recent
lauhing. No haza,dous waste disposal
can occu, in a 100 year IIoOdplain.
Disposal into or below surface wat. and
ground water is prohibited.
Siting must maximize wind protection and
nlll1mize upstream drllillilge area. No solid
wasle drsposal can occur in a 100year
lIoodplain. Disposal into or below surface
waler and ground water is prohibited.
Impoundmen. design Is contro-ed by a
site's location in relalion 10 'he upper mos'
aquifer and by wa.. quality in 'he aqul..
Siles within sial. or federal hisloric
preservation areas wiU be 'equired 10
p,eserve hisloric cha,acler.
tJ
Applicable or
Retevan.and
iele
Yes!No
Yes/No
Yes!No
No/No
Comment
Applies
10
Alternaliv.
Appic:able I an on.aiI. hazardous wasle
dispo881 facility Is planned. Not
Anlq)ated.
Applicable if an on.aile hazardous wasle
dispoSal facility Is pllnned.
Applicable I on.aile solid was'e disposal
facility Is conlemplaled. .
-------
TABlE 1 (continued)
ARARs fOR SAND CREEK 005
ACTlON.SPEClfIC ARARs AND TBCs
SbIndIrd. Requirement
CftIeri8. or Llmil81ion
Feder.. ARARs
Inlerim Treatmenl saandards lor Soil
and Debris. TBC July 21, 1990 .
Oc:c:upational !lalety and Health Ad
Hazardous Malerials Transportalion
Act
Hazardous Malerials T ransportaiion
R.,.lions
Land Dispoul Regulation
CAppIng
Land Tr..1menI
Corrective Action lor Solid Wasle
Man8gemenl Units
ebb
. 29 USC Sec. 651-618
49 USC Sec. 1801.
1813
49 CFR Parts 107. 171.
171 8Iso 40 CFR 262
40 CfR 268, Subpart
D. 55 FR 8160.8162,
3J8,I9O
40 CfR 264.310(a)(b)
40 CFR 264.11710120
40 CFR 264.2~(b)
40 CfR 264.211, 213,
216.218,282
Proposed regulalion 55
FR 30198
Desa1:»lion
BDA T slandards have nol been developed
tor Ihe P and U wasles present in OU5
soils.
Regulales wortler heahh and salely.
Regulales Iransportalion 01 hazardous
maleriels.
Regulales movemenl and placemenl 01
soils.
Siandards lor cap placement.
RCRA hazardous wasle being Irealed or
placed In anolher unit.
I
AppIabie or
Relevanl and
Approprilile
TBC
VesINo
VesINo
VesINo
NolYes
NolYes
TBC
CommenI
Under 40 CFR Seelion 300.38,
requiremenls of I" Act 8ppIy 10 a.
response adivllia under the NCP.
AppIic8bIe only . 8ft 8Iern.e developed
would involve lIenspor1alion of haz8rdous
malerills.
AppIicabfe 10 wasles .~ oll.sile.
II Allernative 2 selected.
II Alternative 3 Hfeded.
Applies
10
Ahernative
12,3,4
13. 4
13,4
12..3,4
12
-------
TABLE I (continued»
ARARs fOR SAND CREEk OU5
ACTION.SPECIfIC ARARs AND TBCs
SIan_d, ReQUlremenl,
Cfiler18, or Llmil8tion
State ARAns
Rule. end R.,.tlons Goveminfl the
Tr8llsp0rt8tlon 01 Hazardous Materials
Wilhin Colorado
Colorado Noise Ab8lement Stalute
CoIor8do Wildlife Enlorcemenl md
Penalties
Wildlife Convnisslon Regulalions
Gen." CIo...e
it8tionaryEmissions Sources; Gener"
:onllols for remedial activities.
Cbllon
4 CCR 723-18,
HMT 1-8
Sections 25.12.101,
012, 103, 104, lOS, 106,
108
Sections 33 6.101, 102,
103, 104, 105. 108, 109,
110, II 1,113.114.118,
117,118,120. 124. 126,
128, 129, t30
2 CCR 406 O. Mieles I,
III. IV, V, VI, VII, VIII. IX,
X. XI
6 CCR 1007.3, Part
264.111
5 CCA 1101.5. Section
IVO
5 CCH tOOl 5. Section
IYD
Description
ESlablishes spo 'Iic requirements lor Ihe
tr8nspor1ation 01 hazardous materials.
especially regarding labeling and
placarding.
ESlablishes Slandards 101 controling
noise.
Prohibits specillc actions in order to
proteel wildille.
E 51ablishes specific requirements lor the
prolection 01 wildlde.
Colorado Hazardous Waste Management
Regulalions. MuSI mimmize Ihe need lor
lurther mainlenance; conlrof. minimize or
eliminate (to Ihe extent needed 10 protect
human health and environment» the posl-
closure escape 01 hillardous w8stes,
hazardous wasle constiluents. leachate,
contaminaled rainl811. or waste
decomposillon producls 10 ground water,
surlace willer, Of the 8tmosphere.
Source cannot cause emissions to exceed
8ny allalOmenl area 01 8ny NMQS.
Source cannot IOteriere wllh allainment
alltllllilllllclldll(;~ 01 any ~Iale NMOS.
u
Applicable or
Refevant and
Appropriate
Ves/No
Ves/No
Ves/No
Ves/No
Ves/No
VeslNo
Yes/No
Commenl
Applicable. hazarduus materiaf Is
transporled on. lite.
Appticable to demaUves that would
generate noise.
Relev8ll1 end apptoprilte for prolectir'tg
wildlife n.... Ihe aite GMing construction
aClivlliea.
Relev8ll1 and approprille for proteCIirlg
wildllle n881 the lite GMing construction
8clivities.
COC gen.aled and I1I8II8ged corrosive
h8lardous wastes end spiled comrnetci81
chemic81 producl.. cae gen.aled and
man8ged RCRA hazardous W8stes after
November 18, 1880.
COC site Is In 8 non.analnment ar... The
site could be considered a major source if
it emils more than 100 tonsJvear o' CO or
YOCs.
COC sile is irI a non.allairlmenl area.
Applies
to
Alternative
13.4
12.3.4
12.3.4
13.3.4
-------
TABLE 1 (conlinued)
ARARs fOR SAND CREEK OU5
ACTlON.SPECIfIC ARARs AND TBCs
Slandard, RequWlmenl.
cneeri8. Of linitalion
Sfale ARARs
Stalionary Emission Sou,ces; Gener..
controls lor 'emedialaclivilies .
Tank Closure
Contain. Closure
Closu,e o. hazardous wasle
managemenl facililies (HWMf);
Clation
5 CCR 1001-3, Sec:Iion
1110
5 CCR 1001-3, Section
"
5 CCR 1001-4, Section
2A
I CCR 1007-3 Perl
264-187
6 CCR 1007-3 Part
264.178
6 CCR 1007-3, Part
264.111
Des' lion
Minimize IugiliYe duSI emissions.
No emissions e.ceeding 20% capacity.,e
8Iowed.
Design action 10 provide odor .,,"
optW8lions.
AI hazardous wasles and ,esidues musl
be remol/t!d from tanks, disa..,ge control
equipmenl and discharge confinemenl
struclures.
AI hazardous wasles and ,esidues musl
be removed 'rom conlall\fJlenl svslem, if
any. Rernainlllg conlainets, liners, tHlses.
and soil Conlilllling or Conldnlinaled wilh
residues musl be deconl8lTW\aled or
retool/ed.
General closure, 8S above. Includes
wasle manaY~1 facillt.es, wasle piles,
sur1ace impoundmenls and lank svslems.
:J
Applicable Of
Retevanland
o riale
Ves/No
VeslNo
Ves/No
VesINo
VeslNo
Ves/No
Comment
Demolition end construction activities,
s.orage and handing optWalions, and haul
road$.
Specilc sources
linlllalions.
may hav. OIher
CommercW chemical prOducts n 10. ....
become haz8ldaus wasl.. when dosur8
begins. See de8n closure '8CJI/rernenls
lor gen.elorltransport. '8qUa'lfIIerIls.
COC managed Iheir h8z8f'dous wasles on
tanks.
Commercial chemical prOducts In ""S
become hazardous wasles when doSUle
begins. See deen cIo.... r8ClU81f11er11s
lor uen.8IorltrenSport. 'equhmenls.
Closure Performance standards.
12,3.4
12,3,4
12,3.4
Applies
10
-------
TABLE I (conlinued)
AnARs FOR SAND CREEK OU5
ACTlON.SPECIfIC ARARs AND TBCs
Sl8nd8rd, R~emenl,
CftIeria, 01 Umilalion
~.Ie ARARs
Cilalion
Closing In place (capping)
6 CCR 1007.3, Part
264.310(a)
8 CCR 1007.3, Part
264.310(b)
6 CCR 10073, Part
264.301(C)
Closure of HWMf:
8 CCR 1007.3, P8I1
2ti4.30I(d) and (e)
DeScriplion
Design and conslrucl cover 10:
Provide long lerm minimizalion 01
miyralion 01 hquids Ih.ough Ille cap.
. function wilh ""'"IIIum mainlenance.
. Promole dralOage and minOOe erosion
or abrasIon olille cover.
. Accommodale sehing and subsidence
10 maintain Ihe cover's inlegrily.
'. Have a permeabilily less Ihan or equal 10
Ihe per.m:abrlily 01 Ihe bollom liner or
nalural sub soils prt::ienl.
Cap inlegnly musl be mainlained and
rep;lired a:i necessary. Leak deleclion.
leachale COlleclion, all ' "achale removal
syslems musl bl! uperaled and
mainlained. Sun/eyed benchmalks musl
be prolech:d and malOlalOl!d.
Run on conlrol must be designed and
conslrucll!d 10 prevenl now onlo Ihe cap
dunng conslruclion. The peak drschlUge
Irom al leasl a 100'year slorm musl be
coralroled.
Runoll conlrol musl be designed and
conslrucled 10 colee I and conlrol Ihe
runoll '.om II loo'year 24 hour slorm, bOlh
duling cap conslrucllon and mainlenance.
Coleclion/huldulg facililles IIssoclaledwilh
rUII on itlld .UII 011 conlrol must be
dC:iI!Joed 10 expedillou:ily IIIallllillO
cajJilClly allcr :ilunos.
10
Applicable or
Relevanl and
Appropriale
Yes/No
Yes/No
Yes/No
Yes/No
Convnenl
Spilled commerdaJ chemical producls are
mixed wilh ao/Ia. Design, construction and
monllonng requiremenls desaibed herein
also apply 10 caps placed over bed
wasles.
Also applies 10 run.on conlrol during fixed
wasle disposal eel construction.
Also apphs 10 bed wasle eel, liner and
QlP construction.
Applies
10 .
Ahernallve
12
12
12
-------
TABLE I (conlinued)
ARARs fOR SAND CREEK OU5
ACTION SPECifiC ARAns AND TBCs
.
Sl8nd8rd. RequWemenl.
CrtIeri8. 01 Llmilalion
Stale ARARs
CItation
8 CCR 1007.3. Par1
264.303(a)
8 CCR 1007-3. P8I1
264.309
CIosur. of HWMf:
6 CCR 1007.3, Part
264.81 (4 Part 264.92)
Part 264.97(a)
Descriplion
During conslruclion, cap svslems musl be
Inspected lor untlormilV. damage and
impetfeclions. Svnlhetic membranes musl
be inSpecled 10 ensure lighl seams and
joInls and Ihe abs..ce ollears. punclures
or blislers. Soil based and admixed caps
musl be inSpecled lor holes. or olher
slNclurai nonconlormilies Ihal maV cause
anV inaease in Ihe permeabilitv ollhe cap.
The exacl Iocalion and dimension.
Including deplh. 01 disposal eels must be
shown on site maps relalive 10
permanenlly surveved benchmarks. The
conlenls 01 each cel and Iocalion 01 each
hazardous wasle type musl also be
shown.
Implemenl a ground waler deteclion
monitoring program 10 ensure lhal Ihe
glound waler prolechon slandard is
complied with. Concenlralions 01
hazardous con51ituenls cannot exceed;
- lable values. or
- background levt!ls. where no lable value
is spt!cilled.
Ground waler monitoring musl consisl 01
a sullici~nl number 01 wels with
approprlale deplhs and locations 10 yield
sampl~s capable 01 delermining bad(.
9,ound willer qualliv and waler qualilv
passNlg a pOll II 01 compballce.
II
Applicable or
Retevlnl and
Approprilile
VesINo
VesINo
VesINo
VesINo
Commenl
Also apples 10 Ixed wasle eel, Iin. and
cap conslNction.
Also applies 10 Ixed wa". chposal eels
and caps.
W. also 8ppIv 10 wasle ".!mentlon-sile
disposal elernelives like lxalion 8nd soil
washing 0I1nclner8lion. . residues cannol
be deiSled.
EICi51ing welleld wiI need 10 be reviewed
du.ing rtm1edlal design.
Applies
10
AIIttmaliv.
@2
'2
12,3,4
-------
TABLE 1 (conllnued)
ARARs fOR SAND CREEK OU5
ACTlON.SPECIfIC ARAR. AND TDCs
Slanderd, Requhmen!,
CIIerta, Of lMniIation
~ale ARAR,
Closure o. HWMf:
Closing In place (capping)
Clean Closure Removal wilh o'f.sile
cIsposai
QaIJon
Part 264.97(c), (d) and
(e)
Part 264.97(h)
8 CCR 1007, Part 2,
Seclions 2.4, 1.2.4.5
6 CCR 1007.2, Part 2,
SectIon 2.3.7
6 CCR 1007.2, Part 2,
Section 2.4.11
8 CCR 10072. Part 2,
SecIIOnS 2.4.9, 2.4.10
6 CCR 1007.3, Part
264.117
6 CCR 1007.3, Part
264.111
5 CCR 1001 9, Seclion
11.0.1 alld 2
DeScriplion
Glound waler wels musl be cased in a
m8nner ensuring wel Inlegrity, and
.ampled using melhods ensuring
88mpIe/analysls inleglllV.
Glound waler sall,o ;:0 musl be colecled
and analyzed al a lrequl!rlC)' Ihal alows 'or
valid slalislical analysis.
Design lacililV 10 prevenllong lerm adverse
effecls on gJound waler, surface waler, air
quall'V, public heafth, and Ihe environment
Design runo/f conlrol Svslem with
su/ficie!fll capacity 10 prevenl adverse
e/fecls on ground waler, surface waler, air
quUtV, public h88llh, and Ihe 8flvironment
Close lacilllV 10 assure prevenlion o. long.
Iwm adverse effecls.
Monilor ground waler, surlace waler, and
prOVItJt! qualllV conlrol duling conslruction.
Hesllicl ,.,Isl closure use 01 property as
nece:>:.. , 10 prevenl cover damage.
General closure, as above.
VOC SOurce can emil, more Ihan 450
IJS/hour Of 3000 IJs/day ul VOCs wllhuul
applYing reasonably aVclllable cOllllol
h:!;hnoloyy IliAC I).
I~
Applicable or
Relevanl and
Approprillie
Ves/No
Ves/No
Ves/No
Ves/No
Yes/No
Yes/No
Ves/No
Yes/No
Yes/No
Commenl
EJdSling welle/d and any addillonaJ wels
placed at Ih. ... musl be assessed.
Applicable 10 ground wal. sampMg allh.
sile.
Pari 2 o. Ihe Slale SOid wasle regs
conlalns ailing end de. crilena for
hazardous wasl. disposal ailes buill an.
~tv I, 1981.
To eslimale soil vobnes, conlainmenl
concenlralions above which cleanup w.
OCCUf are set al bedtground or Ihe vakle
corresponding 10 one excess cancer In
one million cases.
Soils al COC also have VOCs in Ihem
Oesl!JO 10 use RACT is made IIher 8
heallh bllSed risk assessmenl w.ng ...
lIIullehlly.
.
Applies
10
AIIernaUv.
12,3,4
12,3,4
12,3,4
12
12
12
12
-------
TAB! E 1 (conlinued)
ARARs fOR SAND CREEK OU5
ACTION-SPECifiC ARARs AND TBCs
.
Sl8nd8rd, Requirement,
C1t18ft8, or liniIalion
Cilallon
SI.te ARARs
6 CCR 1007.3, Part
264.114
~~olilcation
6 CCR t007.3, Part 99
Manllests
6 CCR 1007.3, Part
262, Subpart B
Pr.llanspora Requiremenls
6 CCR 1007.3. Part
262.3. .3t, and .33
Descriplion
Dispose 01 or decon al facility equipment
and s!luclures by removing al hazardous
wasles and reso,es.
Any person who generales or transports
hlwlldous wasles must file a noliflcalion
of hazardous wasle activity before
beginning such aclivity.
A manifesl must be prepared by a
generator before it is ollered lor
transportation 011 site. The manliest must
identify Ihe facility pennit1ed to hande the
waste described Ihereon, and may
designale an demelive facility. The
manifest lonnat mu.t be consistent with
Ihose ollered by the consignment
(deslinalion) stale or gen.ator .tate.
respectivety. aen..tor must sign Ihe
manlle.t, oblain the signatUfe 01 the initi81
transporter. retain one copy. and give
rtmaining c'. "'5 10 Ihe ..ill8ll1ansporter.
A generalu. .....st package the waste In
accordance WIth PUC or DOT regulations
in 40 CPR Parts 173, 178 and 179. Each
package must be labeled or martled In
accOldance wnh PUC 01 OOT regulalions
in 49 CfR Pall t72. for container. 01110
galons or less, maftUngs must ~ with
requirements 01 40 CfR 172.304. The
genetalo, 'llusl placard. 01 oller placa,ds
10 Ihe ir..I0..' lfan.pOl1et', in aCCOldance
wllh 49 CF H Pall t72 Subpall f.
13
Appkable 01
Relevanl and
Appr,,"ri8le
v esINo
VesINo
Ves/No
VeslNo
Comment
Applies
10
Altl!m8tiva
II tank contenta, containers and
con......ted sol. are being shipped 011.
sne as part of cIosura activities.
fOl 01 aile lIansportalion.
for ol.aile lIansporlalion.
'2.3.4
'3. 4
'3.4
-------
TABLE 1 (conlinued)
ARARs fOR SAND CREEl< OU5
ACTION-SPECifiC ARARs AND TBCs
Slandlld, Requhmenl.
Crileri8, or llmitallon
se.'e ARARs
T ,anspol1ation
Clean Closure (,emoval with off.sile
diapos81)
T ,ansportalion
Clean closure (removal wilh Irealmenl
11 lanks)
Ctlalion
8 CCR 1001-3, Pari
263.11 (a)
8 CCR 1001.3, Part
263.20
I CCR 1001-3, Part
263, Subpart C
6 CCR 1001-3, Pari
264.191(a)
Description
A transporter musl nol Iran sport
hazardous wasles withoul an EPA ID
numbw.
A transporter may nol receive hazardous
wasle from a generalor unless. is
accompanied by a manifest The
Iransporter musl sign and dale Ihe
manifesl, acknowtedging acceplance, and
musl leave on copy with the general or.
Upon delivery 10 Ihe designaled lacilily.
Ihe transporter musl obtain the dale 01
delivery and Ihe signalu,e 0' Ihe
ownerloperalor. The Iransporter musl
.etain one copy 0' Ihe signed manilest.
II a discha.ge 0' hazardous waste OCCU'S
dumg Iransportation, Ihe Iransporter musl
lake approptiale immediale action 10
prolecl human heaMh and environment.
1 he I.ansporter musl 'eporllhe discharge
and uKimale resolullon 10 PUC, DOT and
COM. The I.ansporter musl clean up Ihe
discharge 01 like Olher appropriale acllon
so Ihal Ihe discharge no longer presenls
a hazard 10 human health or environment.
lanks must have sulficjenl shel slrenglh,
'oundallon slrenglh, slruclural suppo,,,
and '01 closed lanks, pressure conllols 10
Issure Ihal they do nol colapse or
ruplu.e.
14
Applicable or
R8evlnl Ind
Appropriale
Commenl
Applies
10
Alternative
YesINo for on-detransportaUon. 13, 4
Y lis/No for off-site tran5por18llon. '3, 4
Yes/No
YeslNo
for off site transportation.
13, 4
Soils wil be milCed with fiMing Igenls or
5011 washing sotv8\ls in tanks.
'4
~
-------
TAULE I (conli'lued)
ARARs fOR SAND CREEK OU5
ACTlON.SPECIfIC ARARa AND TBCs
,.
S&8ndard, RequWetnen',
Cril8fi8, or Limitalion
Cilalion
Descriplion
Applicable 01
Relevenl and
Appr0pri8le
Ste'e ARARs
Commenl
Applies
10
Ah"",aUve
CIe8n dosure (removal wilh Ireelmen'
8'1 lanka) .
I CCR 1007-3, Pari
264. 192(a)
I CCR 1007-3, Part
264. I 92(b)
I CCR 1007-3, Pari
264.I94(a)(I-3)
6 CCR 1007 3, Pari
264. I 94(a)(4) and (~)
6 CCR 1007.3, Pari
264.341; Pari
lOO.22(c)(3) and (4)
Wasles end olher malerial (e.g., 'rulmen.
reagenls) Ihal ..e incompatible wilh Ihe
RIIIaerial 01 conslmelion 0' Ihe lank musl
nol be placed i'I Ihe lank, unless iI is
prOlecled "om acceleraled corrosion,
erosion, 01 abrasion IhlUlIgh Ihe use 0' an
i'ln. liner 01 coaling It ..1 is compalible
wilh lank conlenls and thai is Ifee 0'
leeks, cracks, holes, 01 olher deterioration,
01 through alternative means 0' protection.
Overfilling must be prevented bV i'leluding
conlrol methods or, 101 uncovered lanks,
RIIIintenance of a sulticien. Iree-board to
prevent overtipping bV wave 01 wind
aClion, 01 bV precipitation.
Daily Inspectiona must be conduded on
overliling control equipment, lank 8'llegrity,
monitoring equipmenl. and Ihe level o.
wastes in uncover~d Ilinks.
Weekly inSPeclions must be conduCied on
the construction RIIIterillls o'ebove ground
tllnks and o' the ar.. around them '01'
obvious SIgnS o. lank detenoration and
leakage.
Analyze 'he waste 'eed.
1 ~)
Yes/No
YesINo
YesINo
YesINo
Yes/No
Applicable II 8'lc:Gq)8.ibIe wastes are
pllced in lanks.
Applicable II wa.le Is "cad 8'1 I8nks.
AppIIrebie II was.. Is "cad In lanks.
~~ II waal. Is pieced In lanka.
Addilional waste anatvses wiI be needed
-------
TABLE 1 (conlinued)
ARARs fOR SAND CREEK OU5
ACTlON.SPECIfIC AHARa AND TBCs
SlMdlfd, R8CII*1RI8II,
erMa, or L8ni1ation
~..e ARAR!
Clean closure (removal
Incin.ation on.de)
Clean closure (removal
Incin.ation on,"'e)
wilh
. Clallon
wilh
P811264.340
6 CCR 1001.3, P8I1
264.343(a)(l)
8 CCR t001.3, Part
264.343(a)(2) and Part
264.343(b)
8 CCR 1001.3. Part
264.343(c) also, 5 CCR
.00. -41. Seclion III C.,
6 CCR .007.3. Pall
2b4.34~(c)
DeScripiion
No ""rther requiremenls, excepl wasle
anaJvses and closure. apply 10 incineralOls
Ihal on'v burn wasles lis led as hazardous
aolefv by virtue o. Ihe characlerislic 01
Ignitabilily. COlJoslvily. or bOlh; 01 Ihe
charaClerislic o. reaclivity illhe wasles wiI
no' be burned when Olh. hazardous
wasles are presenl in Ihe Combuslion
zone; and 'Ihe wasle ana'vsis Ihowllhal
Ihe wasles conlain none o. Ihe hazardous
consliuenls lisled in Appendix VIII which
mighl reasonablv be expecled 10 be
present
Performance slandards '01 incineralors:
. Achieve a deslruclion and remov81
elfiaency o. 99.99 pl!lcenl '01 each
pnnc/pal organic hazardous conslituenl in
Ihe was'e leed and,
. 99.9999 percenl 'or r020. F021, FOn,
F023, F026, F027 wasles.
. Reduce hydrogen chloride emissions 10
UJ kgltu or I percenl ollhe HCI in Ihe
slack gases before enlenng any polulion
conl.ol devices.
. Emissions 01 particullille mailer cannol
eJlceed 0.08 gtillOS per dry Slandard cubic
1001 when correcled 'or Ihe amounl o.
oJlyyen 10 Ihe slack gas.
OjJelale wlIIlI1I specilied limits dUllny
slartujJ alld :.huhJuwn
II>
Applicable 01
Relevanl and
Appropriale
No/No
Ves/No
Ves/No
Ves/No
Yes/No
Commenl
Apphs
10
Alternalive
Hazardous waal. al cac 8Ie Is... lor
loxicity and acu..loxicly, nollunilabililv 01
corrosivlly aIon..
Applicable iI wasle Is inanera'ed.
It wasle Is a f020, fOl', fOn. F023.
F027.0I F029 was...
General capacity limitation 8150 lppIies 10
new inClneral10n sources.
-------
TABLE 1 (conlinued)
ARARs fOR SAND CREEK OU5
ACTlON.SPECIfIC ARARs AND TBC,
~
Slandlrd. R.quhmenl,
Crilert8. or Lnilation
Stale ARARa
Clean closure (removal
Ineineralion on.sile)
CI.an clolur. (removal
lncIn.ation on,"a)
wilh
with
ClaUon
P811264.345(d)
Pari 264.374
8 CCR 1007-3, Pari
264.347(8)
Pari 264.347(b)
Pari 264.347(c)
Pari 264.351
5 CCR 1001-3, Section
VlB
5 CCR 1001.3, Seclion
iliA
Descriplion
Conlrol fugilive emissions from Ihe
combustion zone.
Moniloring 01 various paramelers during
operalion 01 Ihe inciner810f is required.
These pa.amelers include:
- Combustion lemperalu.e.
. Wasle leed rale.
. An Indicalor 01 combuslion gas vefoc:ily.
- Carbon monoxide.
. Wasle and exhausl emissions upon
requesl.
Daily visual inspeclions 01 incineralor and
associaled equipmenl.
Operale with an aulomalic leed culo"
svslem; inspeci weeldy.
AI closure, al hazardous wasle and
residues, irlcludlng ash, scrubber wal.,
and scrubber sludge musl be removed
from Ihe sile.
Sources can emiI no more lhan 2 Ions/day
01 sulw dioxide.
Comply wilh particulale ~Jilillions.
II
Applicable or
Relevanl and
Appr0pri8le
VesINo
VesINo
VeslNo
VesINo
VeslNo
VesINo
Ves/No
VesINo
Conmenl
Specilc lourcaa may have olher
limitallon,. Us. besl avaMble coollol
lechnology.
funclions 01 heallnpul. Applies 10 Ihe
opl!flltion 01 luel burning equlpmenl.
ApplIes
10
-------
TABLE 1 (continued)
ARARs fOR SAND CREEK OU5
ACTlON.SPEClfIC ARARs AND TBCs
Sland8rd. Requhment.
Criteri8. Of UmIIation
SI8te ARARs
Emission 01 metals "om incineralors
On.site disposal 01 trealmenl residues
On-slle disposal 01 trulment residues
AI-slle disposal 01 Ireatment residues
Cll8110n
8 CCR 1007-3. Part
260.22(a)
.'
6 CCR 1007.2. Part 2.
Section 2.4. I .2.4.5
Part 2. Seclion 2.4.6
Part 2. Seclion 2.5.3
Part 2. Seclion 2.4.9.
2.4.10
Part 2. Section 2.4.8
Part 2. Section 2.4.7.
2.5.5
Description
Colo. Ail Quality Conlrol Commission
Regulalion 18. Section 6.
AmbIenI air quality slandards 'or Siale 01
MassachuseUs. Currenlly used as
guidetine lor Slate 01 Colorado.
A demonslralion must be made Ihal Ihe
wasle no longer meets any 0' Ihe criteria
under which it was listed as hazardous
under Part 261. Subpart D.
Design 'acility 10 prevent long.term adverse
elects on ground waler, surface waler. air
quality. public heahh. and the environment
Prolecllhe function and inlegrilV 0' liner(s)
Isolale wasles 'or 1000 years.
monitor ground water. sur1ace water. and
provide quailly conlrol during construction.
Close lacililV 10 assure prevention 01 Iong-
term adverse enects.
Design leachale and run on conlrol svslem
10 prevenl adverse enecls on ground
waler. surtace waler. air qualilv. public
heallh, and Ihe environmenl.
IIJ
Applicable or
Relevant and
Appropriale
TBC
TBC
YeslNo
Yes/No
YeslNo
Yes/No
Yes/No
Yes/No
YeslNo
Comment
The ambient air quality .tandard 'or Ie8d Is
1.5 ug/m (avg. monthIV modeled standard).
The Stale has metals emissions guidelines
0' 0.0003 ug/m IOf cadmium. 0.69 ug/m
chromium. and 0.18 ug/m lor fidei.
" Ihe wast. Is "t'" wfth code 0.0. Ihe
petition must demon.trat. lhat Ihe
residues do not contain Ihe conslituenl
(app. 7) thai caused II to be "ted. using
Ihe appropriat.lIpp. 7 test method; or the
waste does nol ...... the aiterton 01 Part
261.1 1 (a)(3). consJdering the factors in 40
CF H Parts 26 1.11 (a)(1) through (iii).
Part 2 01 Ihe State loid wasle rags
conlains ailing and design criteria lor
hazardous waste disposal sites built aner
July 1. 1981. These requiremenls are
applicable II a hazardous wasle disposal
sile Is built.
~
Applies
10
Ahemalive
-------
TABLE 1 (conlinued)
ARARs fOR SAND CREEK OU5
ACTION-SPECifiC ARARs AND TBCs
..
Sl8ndlrd, Requiremenl,
Criteria. Of LbII8Uon
Slale ARARs
On-sile disposal ollrealmenl residues
CltaUon
8 CCR 1007-3. Pari
264.301 (a)(l)
8 CCR 1007.3, Part
264.30 1 (a)(2)
8 CCR 1007-3, Part
264.301 (c)(d)(e)
Des~lion
Use liner which prevenls wasle migralion
Inlo adjacenl soil, ground waler, surlace
waler, or liner itself during Ihe aclive life 01
Ihe land'., including closure.
Design and conslrucl liner '0 prevenl
fa"re due 10 pressure gradienls, conlacl
with wasles, climale, and slress 01
Ins""lion and daily operalions.
The liner must be placed on a loundalion
Ihal wit provide support and resislance 10
pressure gra«ienls above and below Ihe
liner. 10 prevenl'a'..,e due 10 setllemenl.
compression or uplift.
The liner musl cover al areas likely 10 be
in contact wllh wasle or leachale.
Inslal leachale coIeclion syslem above
Ihe liner lhallhe deplh olleachale on Ihe
kens does not exceed Ihirty cenlimelers
(one 'oot). The syslem musl be
conslrucled 01 malerials lhal are
compalible with wasles and leachale in
Ihe landtil, and Ihal have sulficienl
slrenglh 10 prevenl coIapse under
pressures exerted by overtying wasles,
caps and equipment. The syslem must be
designed and operaled to lunclion withoul
clogging.
Conslruclion run-on and runon conlrol
syslems capable 01 handkng the peak
discharge o' a tOO-year 24 hour slorm.
Associaled coleclion and holding lacililies
must be designed 10 expe«iliously
malnlain syslem capacily alter slorms.
I!J
Applicable or
Relevanland
Appropriale
Yes/No
Yes/No
Yes/No
Commenl
Appties
10
-------
TABLE' (conlinued)
ARARs fOR SAND CREEK OU5
ACTION. SPECIFIC ARAns AND THCs
saand8rd, Requirement,
Crileri8, Of lImitallon
Siale ARARs
On.site disposal 0' Irealmen' residues
CItation
8 CCR '007-3, part
264.303(a)
8 CCR '007.3, P8I1
264.309
8 cCr Pari 264.90
Subpart F
6 CCR Pari 264.3'2,
264.313,3'7
6 CCR '007.3, Pari
264.3'0(a)
Descriplion
During con:.huction, liners must be
inspected lor uniformity, damage and
Imperleclions. Synlhelic membranes musl
be inspecled 10 ensure lighl seams and
joinls and Ihe absence ollears, punclures
or blislers. Soil-based and ad.mixed caps
musl be inspected.
The elC8c1 location and dimensions
including deplh, of disposal cels musl be
shown on slle maps relalive to
permanently surveyed benchmart
-------
TABLE 1 (conlinued)
ARAR. FOR SANO CREEK 005
ACTlON.SPECIFIC ARARs AND TBC.
St8ndlld. RequWenMlnl,
Crileri8. or Jinblion
Slate ARARs
On-sile disposat 0' llealmenl residues
Cltallon
8 CCR 1007-3. Part
264.310(b)
8 CCR 1007.2, Section
2.1.2
8 CCR 1007-2 Section
".2
Descriplion
. Have a permeabiity less Ihan or equ81 to
Ihe permeability 01 Ihe bollom liner or
natural subsoits present.
Cap InlegrilV must be maintained and
repaired as necessary. Leak detection.
leachate colection, and leachate removal
syslems must be operated and
mainlalned. Surveyed benchmarks must
be protected and mainlalned.
Disposal slles shal comply during
operations with applicable rules and
regulations 0' the waler and air qu.1ity
conlrol commissions. and with local
zoning laws and ordinances.
Ground water shal be protected !rom
polution by leachate. Permanent
diversions shal conllol run.on and runon
'rom the 100.year event. Facility design
shal address geologic hazards. Ground
waler moniloring wels shal be designed
in accordance with applicable state
engineer's rules and regula lions. Sulficient
amounls 01 cover must exisl on.site or be
readily available on.slle. Cap design must
demonstrale that two 'eet 0' cover Is
sufficienl to establish vegetalion and
isolale wasles after closure. Adequate
amounls 0' water must be available 'or
construction
;>1
Applicable or
Relevanland
Appropriate
Ves/No
Ves/No
VesINo
Conment
Compliance with these design standards
is demonstrated by providing the data
caled 'or In 6 CCR 1007.2. Sections 4.3
Ihrough 4.8.
Apple.
to
-------
T Atflt: 1 (conllnued)
ARARs fOR SAND CREEK OU5
ACTION-SPECifIC ARAna AND TBCs
Slandlrd, Requlremenl,
Crteri8. Of llmitalion
Sta.e ARARJ
Cltallon
8 CCR 1007.2. Section
2.1
On.de disposal 0' 1r8ll1men1 reslcttea
8 CCR 1007-2. Section
2.2
Chembl. Physical and Bl0logicai
Trealmenl (5011 Washing and
BioIogIc:.I Tr8ll1men1)
Gener.. requiremenls 'or ignitable,
r8llClive, or 1n~libIe wasles .
40 CfR 265.400
40 CFR 265.17(b)
Wasle pile
40 CfR 264.251
Des
lion
Operalions she. conlrol Odors and prevenl
rOdenI and Insects by being adequelely
covered. NuiS8l1ce conditions ahd be
minimized. Wasles sha. be pieCed as
densely as prac:lic8b1e. Disposal sites
ahd be adequately 'enCed.
During opereliona, Rln.on she. be dlv8led
tom Ihe wOltUng area. Ground waler she.
be monitored regulit1y upgredlenl and
downgradlenl 0' Ihe facility. Opeqlions
sha. cease when high wind warnings are
verified. Hazardous wasles and sludges
ahe. nol be dispoSed during operalions.
Chemical, phys6c81 or bi%giceJ Ir8lllmeni
0' hazardous wasle musl compfy with
Section 265.17(b).
Where sPecificdy required by olher
aeclions. 0' Ihls pert, Ihe 1r8ll1menl,
slorage. or dispos.. 0' ignilable or r8llcllve
wasle, and Ihe mildure 0' CGmrnInging 0'
IncOmpalible waSles, or IncompermJe
wasles and maleriels, musl be conducled
so lhel it does nol:
PrOduce unconlroled loxlc mlsls, fumes.
dusls, or gases In SUIficienI quanlitles 10
Ihrealen human health; produce
unconlroled llammable fumes or gases In
SUfficienl quanlilies 10 pose a risl< 0' Ire or
explosions.
Use a sinyle liner and leachale coleclion
sY:;'em.
~';!
Appliceb/e or
Relevanland
r riale
Commenl
Applies
10
Alternative
VestNo
These are mirlimurn operaling slanclards
mandaled by Ihe alalue.
VesINo
Ihese are addilJonat Gper81ion standards
for aold wasle diapol8f alea.
Ves/No
Would be 8ppicabIe . bioIogic81 or soil
washing Ir8ll1men11a P8d0nn8d.
14
Would be applcable . 1MoIogic81 or soil
washing 1r8ll1men11a prefOlJned.
14
Ves/No
Would be applicable if wasle ;s hefd in a
Wd:.le p.'e ,,"or 10 trealment.
-------
TABLE 1 (conlinued)
ARARs FOR SAND CREEK OU5
ACTlON.SPEClfIC ARARs AND THCs
S88nd8rd. R........I,
ClIo, or Llmltalion
51.le ARARs
Tr8llsporl81ion (Oll'slle)
Sl8IId8rds .\AppIIc8b1e 10 ~,,"eralors
:), H8urdous Wasles .
lequiremenls for Miscel8neous Unlls ,
Cltalon
40 CfR 101, 111-111
November 15, 1885
Feder.1 Regisler
40 CfR Part 262
'.
52 FR 46946
(December 10, 1981)
Subpart II 01 Part 264
Description
Regulales Iransportalion 0' hazardous
malerials (Departmenl 01 T ransportalion)
Super1und Oft sile Policy
Regulalions lor Transporting H.zardous
Wasles:
Before .n owner or generalor dspoS4fS 0'
any h.z.rdous wasle, he must oblain 8
delailed chemical .nd physical analysis 0'
. represenl8live sample ollhe w.sle, AI
. minimum, Ihis .nalysis must conlain ..
Ihe inlormalion which must be known 10
Ireal. slore, or dispose 01 Ihe wasle In
accordance wi1h P.rt 265 and Part 268.
A RCRA permit Is nol required lor on-sile
CERCLA .cllon; however, Ihe
requiremenls 01 Ihe permit musl b met.
The Subpart II permit requirements Include
bul is nollimiled 10:
(a) Prevenlion 01 any releases Ihal may
have .dverse eftecls on human heahh or
Ihe environmenl due 10 migration 01 wasle
conslituents in Ihe ground waler or
subsurface environment, considering:
(I) The volume and physical and chemical
characterislics 01 Ihe wasle in Ihe unit,
including ils pOlenlial lor migralion Ihrough
soil, liners, or olher con18inmenl
slruclures;
(2) The hydrologic and geologic
char aclerlslics ollhe unil and surrounding
2:.1
Applicable or
Relevanl and
Appropriate
YeslNo
YeslNo
Yes/No
YesINo
Commenl
13,4
Applicable" w.sle Is trealed In .
miscel8neous una.
Applies
10
Alternalive
-------
TABLE 1 (conlinued)
ARARs fOR SAND CREEK OU5
ACTION-SPECifiC ARARs AND TBCs
Sland8rd, Requirement.
Crileri8, or limitation
State ARARs
Cbllon
Oesalplion
area;
(3) The exisling qualilv 01 ground waler,
including olher sources 01 con lamina lion
and Iheir cumulalive impact on Ihe ground
water;
(4) The quality and direction 01 ground-
water now;
(5) The proximity to and wilhdrawal rates
o' current and potential ground-waler
users;
(6) The pallerns 01 land use In the region;
(1) The potential lor depo~n or
migralion 01 wasle conslituenls Inlo
subsurface phvsical slructures. and Into
the root zone 01 'ood chain crops and
other vegetation;
?4
Appkable or
Relevant and
Appropriate
Comment
Applies
to
-------
TABLE 1 (continued)
ARARs fOR SAND CREEK OU5
ACTION-SPECifiC ARARs AND TBCs
Sl8ndlrd, RequWemenl,
CftI..., Of Llmilallon
Stale ARARs
Description
Applicable or
Relevant and
Appropriate
CItation
(8) The potenlial 'or health risks caused by
human exposure 10 wasle constituents;
and
(9) The potential 'or damage to domestic
animals, wildlife, Gops, vegetation, and
physical slruetUle caused by exposure to
waste constituents;
(b) Prevention 0' any releases that may
have adverse effects on human health Of
Ihe environment due to migration 0' waste
constituenls In surface waler or wetlands
or on the soil surface considering;
(1) The volume and physical and chemical
characterislics 0' Ihe wasle In Ihe unit;
(2) The enectiveness and reliability 0'
conlaining. confining. and colecling
systems Id slructures in preventing
migraliol.
(3)The hydrologic characleristics 0' the
unit and Ihe sunounding area. including
the lopography 0' Ihe land around Ihe
unit;
(4) The pallerns 0' prec~itallon in the
region;
(5) The quanlity. quality. and direction 0'
ground waler now;
(6) The proximity 0' the unit to surface
walt!ls; adverse enecls 011 humiln heallh
01 Iht! environment; considering:
; '~)
Commenl
Applies
to
-------
TABLE 1 (continued)
ARMs fOR SAND CREEK OU5
ACTION-SPECIfIC ARMs AND TBCs
Sl8nd8rd, Requlremenl,
CrtIeri8, or llmitallon
;181e ARARs
Oescr1Jlion
Applicable or
Relevanl and
Appropriale
ebb
(7) The currenl and polenlial uses 01
nearby surface walers and 8ny olher waler
quality slandards eslablished lor Ihose
surface willers;
(8) The exisling quality 01 surface walers
and surface soils. including olher Sources
01 conlaminalion and Iheir cumu18live
Impacc on surface walers and surface
soils;
(9) The pallems 01 land use In Ihe region;
(10) The polenlial lor heallh risks caused
by human exposure 10 wasle constiluenls;
and
(11) The polenlial lor damage 1o domestic
animals, wklile, crops. veget811on, and
physical Slruclures caused by exposure 10
wasle consliluenls.
(c) Prevenlion 01 any release Ihal may
have adverse elecls on human heallh or
Ihe environmenl due 10 migr81ion 01 wasle
consliluenls In Ihe air, considering;
(I) The volume and physical and chemical
characleristics 01 Ihe wasle in Ihe unit,
including ils polenlial lor Ihe emission and
disposal 01 gases, aerosols and
par1iculales;
(2) The elecliveness and refiability 01
syslems and slruclures 10 reduce or
prevenl emissions 01 hazardous
consliluenls 10 Ihe air;
;'(j
COIMWIt
Applies
10
-------
TABh .tJntinued)
ARARs fOR ~jAND CHEEK OU5
ACTlON.SPEClfIC ARARs AND TBCs
Sl8ndlrd. Recpemenl,
CrtI.., OIllmilalion
seale MARs
Cilallon
Colorado Ail Qudly Conlrol Aci
. 5 CCR 1001-9
5 CCR 100t.5, Reg. 3,
Section II
5 CCR 1001.5, Reg. 3,
Seclion IV.D
Description
(3) The operating characlerisllcs ul tho
unil;
(4) The atmospheric, meteorologic, and
lopographic characteristics 01 the unit and
Ihe surrounding area;
(5) The existing quality 01 the air. including
other sources 01 contamination and their
cumulative impact on the air;
(6) The potential lor heahh risks caused bV
human exposure to waste constituents;
and
(7) The potential lor damage to domestic
animals, wildlile, crops, vegetation, and
physical structures caused by exposure to
waste constItuents.
Establishes regulations to control
emissions 01 VOC's (new and existing
sources).
file APEN including estimalion 01 emission
rales.
Source cannot cause an exceedance in
any attainment area 01 any NMQS.
'II
Applicable 01
R_ant and
Appropriete
VeslNo
VeslNo
VeslNo
Commenl
Apply reasonably
lechnology (RACT)
anainment area.
av8ll8ble conlrol
In ozone non-
Applies 10 a. sources Including existing
unless specilicalv exempt
Applies
to
Alternallve
12,3,4
-------
TZ4.C08008.CR-03723
.
SAND CREEK INDUSTRIAL SUPERFUND SITE
OPERABLE UNIT NO.5
COKKERCE CITY, COLORADO
RESPONSIVENESS SUKKARY
September 1990
This community relations Responsiveness Summary for Operable Unit No.5 (OV5)
of the Sand Creek Industrial site contains the following sections:
A.
Overview. The overview briefly
the public I s maj or comments on
preferred alternative for OUS.
describes the site and summarizes
EPA's Feasibility Study (FS) and
B.
Summary of Community Involvement. This section gives a history of
EPA's community relations activities at the site.
C.
Summary of Comments Received Durin2 Public Comment Period.
This
section categorizes oral and written comments received concerning
the FS and EPA's preferred alternative, and provides EPA's responses
to those comments.
D.
Remainin2 Concerns.
This section describes concerns about the FS
and tells how EPA will address them.
E.
Previous Communi~v Relations Activities at the Site.
This table
"
'Usts by chronological order the community relations activities thac
have occurred to d&te.- .
A.
-OVERVIEW
The Sand Creek Industrial site is located in Commerce City, city north of
Denver I Colorado. The site and surrounding area are primarlly occupied by
-------
trucking firms, petroleum and chemical supply/production companies. warehouses.
and small businesses. There is a small residential population in the study area
and the area adjacent to the northeast border of the sice.
The site contains the following fou- -nown potential source areas, all of which
are now inactive: the Oriental Refinery, the Colorado Organic Chemical (COC)
property, the L.C. Corporation acid pits, and the 48th and Holly Landfill.
Contaminants found on the site include pesticides and herbicides, volatile
organic compounds (VOCs), and arsenic. To expedite the study and cleanup of che
contaminated areas, EPA has divided the Sand Creek site into six operable units,
The operable units were established based on the presence of different types of
contaminants or contaminated media, different source areas, and/or phys ical
constraints. This responsiveness summary presents comments on EPA's FS and the
preferred alternative for cleaning up contaminated soils in Operable Unit ~o,
5 (OU5) , which consists of the surface soils contaminated with pesticides and
metals found in the vicinity of the adjacent Colorado Organic Chemical plant
property (COC) , the Gallagher property (former Oriental Refinery), and the
Colorado and Eastern Railroad property.
Comments were received from the City of Commerce City. the original owner ~f the
COC property, a Trust set up by the owner, the State of Colorado and a small
number of individuals present at the public meeting. The majority of the
comments were focused on the issues of permanency of the cleanup and any land
use restrictions.
B.
SUMMARY OF COHKUNITY INVOLVEMENT
'"
Communicy relations activities for the Sand Creek Industrial site began in April
1985, when EPA distributed an introductory fact sheet to residents, businesses,
and agencies in the area. The fact sheet described the site and explained their
Superfund process, with'emphasis on .the RIjFS. Following the distribution of
the fact sheet, EPA attended a public meeting organized by Citizens Against
Contamination, a local group concerned about the site, and compiled a lisc of
people who owned property on the site.
-------
EPA mailed a second fact sheet in November 1985. Written in question-and-
answer format, this fact sheet provided information typically requested during
inves~igation and cleanup of hazardous waste sites. Tha~ same month, EPA also
provided a report on water contamina~ion for a second public meeting held by
the Citizens Against Contamination organization.
In January 1986, EPA contacted property owners
keep them informed of activities at the site.
photo display illustrating the RI/FS process.
and Commerce City officials to
In the spring, EPA prepared a
A Remedial Investigation report describing the extent of contamination within
the COC area was released for public review in March 1988. In May 1988, EPA
contacted property owners to obtain permission to sample and monitor soils on
those properties.
In October 1988, EPA met with Commerce City officials to keep them informed of
plans for the site. The Commerce City representatives also provided their
reactions to the cleanup methods being considered.
In January 1989, ~he FS was comple~ed and a remedial alternative was chosen.
EPA took several measures to announce the choice and to seek comments and
questions from the public. First, EPA made copies of the FS Repor~ available
to ~he public in the Adams County Public Library, the Colorado Department of
Health, and EPA's own library in down~own Denver. At the same time, EPA mailed
its third fact sheet, which described the Proposed Plan as well as four other
remedial alternatives tha~ had been evalua~ed. Third, EPA announced a public
commen~ period during which people were invited to submit commen~s and questions.
The commen~ period originally ran from January 13, to February 13, but at the
request of Some commentato7s, EPA extended the period to February 22. Fourth,
EPA conduc~ed a p~blic meeting on January 31 to de~cribe the results of the RI/FS
. and answer q~est~ons from the public.. EP~'published a press release and a public
notice in each of the Commerce City newspapers, The Commerce City Sentinel and
The Commerce City Beacon, announcing all of these activities.
-------
EPA made copies of the FS Addendum report available to the public and mailed
its fourth fact sheet describing the new proposed plan. The remedy selected in
the new proposed plan included: excavation and off -site incineration of
approximately 1,000 cubic yards (CY) of highly HOC-contaminated shallow «5 ft)
soils; vacuum extraction of the volatile organic compounds in the subsurface
soU. above the ground-water table; demolition and off-site disposal of the
contaminated tanks and-buildings; and either bioremediation or soil washing for
the surface soils contaminated with HOCs with the goal of returning the site to
residential use. It was proposed that excavation and off-site disposal of the
contaminated surface soils be retained as a contingency remedy,
since the
implementation of bioremediation and/or soil washing depended upon the results
of treatability studies to be performed subsequent to a Record of Decision- An
absence of proven bioremediation and/or soil washing results on soils
contaminated with similar compounds further warranted retention of the off-site
disposal option.
EPA announced a public comment period in effect from July 19, through August 21,
1989 during 'which the public was invited to submit comments and questions
regarding the FS Addendum and the new proposed plan. EPA conducted another
public meeting on August 1, 1989, to describe the proposed plan and answer
questions from the community. Press releases and public notice were again
published in The Commerce City Sentinel and !he Commerce City Beacon announcing
all these activities.
Only the City of Commerce City responded in writing, and there was limited
comment on the selected remedy during the August 1 public meeting. !he primary
concern of the City of Commerce City was that the COC property be remediated to
residential-use standards. A Record of Decision was subsequently prepared which
addressed only t~e highly' contaminated sol1s. Remedial design of OUl was
Initiatec:t following ROD signature. Sampl~s of the COC area were collected during
design stages. Analytical resurts from that sampling period were evs1uated in
an endangerment assessment prepared for OU5. New action levels and soil volumes
were calculated using all the OU5 data.
-------
Remedial alternatives previously identified and screened for the COC area through
the initial RI/FS (CDM, 1989) and Feasibility Study Addendum for OUl (SAlC, 1989)
were utilized in the FS for OUS. Costs of selected alternatives were revised
based on the refined 5011 volume information. A proposed plan and FS for ODS
were released to the community for public comment in July 1990.
C.
SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COKKENT PERIOD
Comments raised during the public comment period on the FS and proposed plan
are summarized below. The comment period was held from July 27 to August 27,
1990.
The comments are categorized by relevant topics.
. Remedial Alternative Preferences
Each of the commentors on the FS and proposed plan expressed a preference for
specific alternatives.
Comment 1.
The City of Commerce City feels that Alternative No.4, on-site soil
washing with off-site disposal of residuals, would be an acceptable
cleanup alternative if specific concerns are addressed. The city's
concerns included implementing an air monitoring and dust supervision
program during remediation, a restriction of access during
remediation and a notification plan for the city should any threat
to public health and safety occur.
EPA ResDonse: EPA's policy is that applicable and/or relevant and appropriate
Federal and State laws be applied to Superfund remedies to ensure adequate
protecti~n of public health, welfare and the environment. In this case, specific
laws regarding air ellissions and particulates will apply during remediation
activities. The requirements outlined on these laws will be met. The ARARs are
delineated in Appendix 8 of the aecord of Decision. Additionally, site access
will be restricted to those involved with the remediation effort.
-------
Comment 2.
The City feels that alternative .3 off.site disposal would not assure
. permanent solution to the hazards at the site due to EPA' s
inclusion of .institutional controls. in the proposed plan.
EPA Resnonse: EPA beUeves that institutional controls will not alter the City's
planned use of the area. EPA intends to return the site to industrial use based
on the City'. Comprehensive Plan for 1985 to 2010 and the historical use of the
area. Implementation of land use restrictiona will require the cooperative
efforts of State, County, and City official to be successful.
Comment 3.
Comments submitted by Holland & Hart on behalf of its client First
Interstate Bank, trustee for the Philip C. Mozer Trust indicate that
they believe capping is the more appropriate remedial alternative
for the soils at the cac site. Holland & Hart believe that capping
would be a permanent remedy, is cost effective and protective of the
environment and human health. Holland & Hart do not believe the
information presented in th~ FS on the soil washing alternative is
sufficient to allow full development and evaluation of the treatment
technology, to support remedial design, and to reduce the cost and
performance uncertainties for this treatment alternative to
acceptable levels.
EPA Resnonse: EPA believes that in spite of the significant uncertainties
associated with soil washing, it is the best alternative given the preference
for treatment under CERCLA and the permanency of the remedy. EPA believes that
capping is not acceptable because it does not reduce toxicity, mobility, or
volume of the waste, and is not a pemanent relledy. EPA plans to further
determine the effectiveness. implellentability and cost associated with soil
washing through on-site pilot testing. Should the pilot test indicate that soil
. .
washing would not be appropriate for full scale rellediation of the site, the
alternative for off-site disposal will be implemented. Holland & Hart did not
. comment o~ the off.site disposal alternative.
. ,
-------
Comment 4.
Holland & Hart believe that costs associated with capping are ~oo
high and question the need for run-off controls.
EPA ResDonse: EPA has included long-term maintenance and operation costs to
the capping alternative since it would likely fail without proper operation and
maintenance. A drainage system of some type is necessary for run-off even in
a semi-arid environment.
Technical Questions/Concerns Reiardini Remedial Alternatives
Comment S.
Some technical comments regarding the actual risks posed by the
contamination of the site were made during the public meeting by a
few individuals. Kr. Philip Mozer read a prepared speech concerning
site risk. The speech is included in the appendix to this
Responsiveness Summary along with the other comment letters.
EPA ResDonse: EPA conducted a health risk assessment following the methodology
of the EPA Risk Assessment Guidance. This methodology has been used on CERCLA
sites nationwide. The methodology takes into account the toxicity of the
contaminants, the exposure frequency and duration. the pathways of exposure and
the potential exposure receptors. A risk level -~ then calculated to determine
an acceptable contamination range for an overall site risk of 10.. to 101. The
exposure scenarios which Mr. Mozer questioned are further explained in the risk
assessment as to their relevancy in the risk calculations. Since the comments
raised were of a general nature and discuss issues :reated in the endangerment
assessment, the commentor will be will be dir:cted to that document.
Comment 6.
A question was raised about the use of bio-remediation as a viable
alternative.
EPA ResDonse:' EPA. has conducted, a preliminary study on the use ~ bio
remediation. It became apparent through this effort that the technology was not
developed to a point of implementation in a treatability study or remedial
-------
action.
Further discussion of EPA's efforts to evaluate bio remediation can be
found in the OU5 FS, pg 3-2.
D.
REMAINING CONCERNS
Comment 7.
Kr. David Busby, the Kayor of COllllerce City commented on future land
us. and who would be liable for the property in the future.
EPA ResDonse: According to CERCLA, for as long as the site is on the NPL and
possibly longer, the liability is open.
Comment 8.
Mr. Reis from the Sierra Club asked about a determination as to :he
extent of ground water contamination.
EPA ResDonse: EPA indicated that the groundwater contamination problem has not
yet been fully investigated and will be on the agenda for next year.
Comment 9.
Kayor Busby also asked about pesticide migration in groundwater and
dust contact during remediation.
EPA ResDonse: There has not been evidence of a significant amount of groundwater
contamination from the pesticides at the COC property. The pesticides are not
very mobile through the soil and tend to adsorb to the soil particles. The
greater threat is from direct contact with the soil. Concerning dust control
during remediation, EPA ~ill implement dust control measures which meet State
requirements.
E.
COMMUNITY RELATIONS ACTIVITIES
-8J\o-.I,"9 "~::'~ f:-'it. :":1:.,.
;'r..'.. "
'. c', .
.
April 1985 - EPA mailed an introductory fact sheet about the site
to residents, pusinesses, agencies, and others (including PRPs) on
the mailing list. ',P
.~ \...
,,-' - - 4.. ,.J; <
-------
.
.
.
August 27, 1985 - EPA met with PRPs.
.
September 1985 - £PA participated in a public meeting organized by
Citizens Against Contamination.
.
October 1985 - EPA developed a comprehensive list of property owners'
names and addresses.
.
November 1985 - EPA mailed another fact sheet providing answers to
questions typically asked during investigation and cleanup of
hazardous waste sites.
.
November 1985 - EPA provided information on water contamination for
a public meeting organized by Citizens Against Contamination.
.
January 1986 - EPA contacted property owners to inform them of site
activities. EPA also contacted public officials.
.
April 1986 - EPA prepared photos for use in a display illustrating
the RI/FS process.
.
February 1987 - EPA ~pdated its list of property owners.
.
April 1987 - EPA surveyed residents about water use habits.
November 1987 - EPA contacted residents and businesses to identify
and check the status of methane venting systems near the site.
. ..."
".
Kay 1988 - EPA requested and received access permission for soil
sampling on certain properties.
.,.
. ,
-------
:c
.
October 24, 1988 - EPA made a presentation to Commerce City officials
to inform them of progress and plans at the site. and to obtain their
reactions to the potential remedial alternatives developed during
the Feasibility Study (FS).
.
January 6, 1989 - EPA mailed a third fact sheet describing the
Proposed Plan for OU1. Also on the same date, EPA made the FS for
OUI available to the public at the information repositories listed
in the Proposed Plan.
.
January 1989 - EPA issued notice of a public comment period on the
FS and Proposed Plan.
.
January 31, 1989 - EPA held a public meeting at Commerce City Hall
to describe the results of the RI/FS and to respond to questions and
comments. Approximately 16 people attended, not including EPA or
contractor personnel.
.
January-February 1989 - EPA extended its public comment period on
the Proposed Plan from January 13-February 13 to January l3-February
22, as requested by some PRPs.
.
Karch-August 1989 - EPA re-evaluated alternatives and issued an
Addendum to the FS. A new Proposed Plan was issued in July 19?~.
The public comment period extended through mid-August. A public
meeting was held August 1, 1989.
- .
.
A Record of Decision was prepared in September 1989 which addressed
, , highly contaminated 8011, VOC's, and structures.
.' '0 . ."" f. -'."'. .. ~.
.
An FS and pr~posed plan for'OUS was prepare4 and released for public
comment in July 1990. ,A public meeting was held August 9. 1990.
The public comment period extended through August 27, 1990.
-------
CITYOf M\~~ COMMERCE CITY
coloudo
plopiE & illld",,1IV 'OGE ,ltu
.
Office of the
Mayor
.
August 16, 1990
Mr. Brian Pinkowski
Remedial Project Manager
U.S. Environmental Protection
999-1Sth Street
Denver, Colorado 80202
Age n c y
Re: Commerce City's Comments on EPA's Proposed Remediation Plan for
Operational Unit 5 at Sand Creek Superfund Site
T.he City has reviewed the preferred remedial proposal by E?A for
"cleaning up" Operable Unit 5 at the Sand :reek Superfund site and
provide the following comments for your review:
i .
':'he City feels that Alt.e~native No.4, E?A's preferred ;:>~an of
On-Site Soil Washing with Off-Site Disposal of Residuals, would
be an acceptable and viable cleanup alternative, if the followi~g
areas/concerns are addressed:
a.
A re:iable and effective air moni~oring program shou~d b~
instituted on the site to ensure that sur~oundi:;g
areas/populace are not exposed to hazardous materia!.s as a
result of the remediation process.
b.
An ef feet i ve dus t suppression program shou 1 d be c1eve loped
and implemented to ensure that the surrounding area and
populace is protected from fugitive emissions.
T.he operable unit, should be fenced off to restrict access
during r,emed1al act1vitie-s. .'
t:.
d.
The City should be immediately notified of any threat t,
public health and safety which occurs or may develop d~ring
the course of remediation of the unit.
The City also has reviewed EP A's proposal to imp lement A lt er na t i ve
No.3 (Off-Site Landfill Disposal and "Inst1tutional Controls") if
pilot tests reveal that soil washing 1s 1neffectiv~. The City has the
C'''"\~, -.... I~.L . -- ,~ - - ~_. ,,.. '..---....-... -'.. _...I_.......J... ~"",....,~
-------
Mr. Brian Pinkowski
Augus':. 16, 1990
Page 2
following reservations/comments
Alternative No.3:
concerning
implement at 10 n
the
of
, .
The City feels that essentially, the lan would not assure a
permanent solution to the hazards at t..e site, as indicated by
the EPA's inclusion of "institutional controls" in the plan. Why
would any type of c~ntrols be necessary if the remediation truly
was a permanent. solution? It is felt that "institutional
controls" are n~t in keeping with SARA's intent to arrive at.
permanent solutions t.~ Superfund sites.
2.
The City believes that "ins~itu':.ional controls" carry with the~
the stigma of possi~le future health risks and cont.inuing :ega:
and economic problems.
3.
EPA should re-evaluate/investigate other remedial methods (such
as vitrification, of~-site incineration, or bioremediation) to
effect a cleanup of the site. It is believed that through the use
of .these or other types of treatment technologies, a feasible
cleanup plan can be developed, eliminating the need for
restricted "institytional controls."
As Mayor of Commerce :~~y, I would liKe to take the opportunity to'
thank you and your 0 rogan i zat ion fo r pas t a nd future ef ~o rt s to
successfully remedy the contaminated soils at the Sand Creek site.'
Please feel free to contact. me or the City ~anager, Steve Crowell, if
you need additional information.
Sincerely,
J..J.k~~ltij6Jo.-"
David R.D. Busby
Mayor
cc: Jane O. Russo
Community Relations Coordinator
,
. ~,
.. . .. ..
~ .. .... '"
-------
HOLLAND & HART
...1iORNEYS AT LAw
:5A I L-
~
.,,--
.
:::f"'~t
:::f"'",U "!c" C!NTfR
'::::LOI.AOC SPtlNGS
AS;If..,
BILL.NGS
ao'Sf
C""E"'!""""f
'NAS"INGTor. ~:
SUIT! 2QOO
S5.5 SM"'T!!NT.. S~RUT
OE"'~I COlORAOO
AM'lING AOOI!SS
110 !Ox 81.9
OEN~'. COl~OC ~201
TE~E""'ON! 'XJ\ ZOS.aooo
~~!COI'IU ')OJ: .9S.e2ol
T'NX 9 IQ.Q') I ~508
("!HI... S LE.\P
~~J: :!9~ &:;'2
.
Auqust 31" 1990
VIA HAND DELIVERY
Mr. Brian Pinkowski
Remedial Project Manager
U.S. Environmental Protection
999 Eighteenth Street
Suite 500
Denver, Colorado 80202
Agency
Re:
Sand Creek Industrial Superfund Site
Comments on Feasibility Study and Proposed Plan,
Operable Unit No.5, Colorado Organic Chemical Soils
Dear Mr. Pinkowski:
These comments on the Feasibility Study and Proposed
Plan for operable unit no. 5 at the Sand Creek Industrial
Superfund Site are submitted by Holland & Hart on behalf of
its client First Interstate Bank, trustee for the Philip C.
Mozer Trust. This letter discusses our general comments
regarding the Feasibility Study and Proposed Plan for
operable unit no. 5 and is not intended to address all of
our concerns related to these documents. Many of the
comments we made related to ~he Draft Feasibility Study for
operable unit no. 1 are equally applicable to operable unit
no. 5 and are incorporated by reference into these comments.
-A copy of our comments on operable' unit no. 1 dated
February 13, 1989 are attached for your convenience.
As with operable unit no. 1, we bel~eve capping is the
more appropriate remedia~ alternative for the soils at the
Colorado Organic Chemical '("COC") site, which includes soils
' within operable unit no. 5. [PA recognizes in the operable
unit no. 5 Feasibility Study ("FS") that soil contamination
is limited to a depth of 3 to 5 feet and "the contaminants
of interest have relatively high adsorption potential and
-------
1,: ~,"f:~~... ."
, .'
;.... .
). ':.~.~~..
Hr. Brian Pinkowski
August 31, 1990
Page 2
particles." FS, page 2-7. EPA's own evaluation of the
ability of the capping alternative to reduce toxicity,
mobility or volume states:
A cap reduces the mobility of the
contaminated media and significantly
reduces the risks of dermal contact,
inhalation and incidental ingestion of
soil particles. Capping also reduces
the potential for leaching of soil
contaminants into the ground water by
providing an impermeable layer over the
contaminated soil, which prevents
surface water from infiltrating below
the cap. FS, page 4-6.
.
These soils contain low concentrations of the constituents
of concern and the constituents are fairly immobile,
conditions which are favorable to a capping remedy.
Further, EPA has identified the potential for exposure
through skin contact or the ingestion of the soil as the
greatest risks posed by these soils. Capping clearly
~eliminates both of these potential exposure pathways in a
more cost effective manner. Therefore, a cap would be
protective, of not only the environment but also of human
health.
EPA has apparently not considered our previous comments
related to implementation of a capping alternative. A cap
is a permanent remedy and maintenance need not be as
continuous, time-consuminq or expensive as implied by the FS
report. The costs associated with placement of a cap have
been overestimated by requiring extension of the cap
horizontally fifty feet around all of the edges,
incorporating a drainage layer which is not necessary due to
our seai-arid environment, and requirinq annual operating
costs of $70,000. Consequently, EPA has failed to
realistically evaluate the viability of a capping remedial
action.
.J : -..~.
.. . 1 . ~ j . ';' .' -)r'
. . Of significant conc$rn to the Trust 'is EPA's selection
~f alternative 4, on-site soil washing, as the preferred
remedial alternative. There is no justification or basis in
.the FS report for selecting this alternative. One of the
reasons operable unit no. 5 was established was to further
evaluate the soil washing alternative that had been
considered in the operable unit no. 1 Feasi~ility Study
-------
Mr. Brian Pinkowski
August 31, 1990
Page 3
.
would be evaluated in a treatability study which included
providing sufficient data to allow full development and
evaluation of the treatment technoloqy, to support remedial
design, and to reduce the cost and performance uncertainties
for this treatment alternative to acceptable levels.
Operable unit no. 5 has failed to accomplish that tasK: the
results of the soil washing treatability tests and the
information provided in the FS simply do not indicate that
soil washing is a viable alternative. In fact, "final
results have not been tabulated" and EPA has made "no
quantitative determination of effectiveness" of the soi1
washing treatability study. FS, page 3-6. In spite of the
significant uncertainties, soil washing was still selected
by EPA as the preferred alternative.
Further, it is not possible to evaluate the cost
estimates presented in the FS due to the limited
documentation and information. It appears there is some
inconsistency in the costs: in particular, some of the costs
for capping appear to be inflated while costs for the soil
washing alternative may be underestimated. The FS report
states costs for soil washing are "highly speculative" (FS,
page 4-21), which makes it extremely difficult to determine
if soil washing is a cost effective alternative, a
determination required under the Superfund Amendments and
Reauthorization Act ("SARA"). In addition, EPA exposes its
bias against capping when it states that capping could be
"effective in containing the contaminated soil indefinitely"
(FS, page 4-8) but then concludes in Section 5 of the FS
that capping is not a permanent remedy. These factors
result in an incorrect determination that the soil washing
alternative is cost effective because its advantages
outweigh its "slightly" higher costs when compared to
alternative no. 2, capping.
.
There is also limited information regarding
implementation of the capping alternative. The explanation
is simply that soils are to be excavated and relocated "on-
site". We object to the placement of any contaminated soils
from other locations on coe property, if that is EPA's
. intent. A
Capping is the more cost e£fective and protective
remedial alternative and should be the alternative
implemented at the COC site. Capping meets the requirements
of SARA, is more cost effective, and is protective of human
health and the environment. Further, the soil washing
-------
Mr. Brian Pinkowski
August 31, 1990
Page 4
FS, is inappropriately evaluated in the FS and should not be
implemented at this site.
Please call me if you have any questions regarding
these comments.
.
.
-.
Sincerely,
~~a~
for Holland & Hart
cc:
William Clemmens, Esq.
Mr. Hal Wofford
Susan E. Brown, Esq.
Mr. John Corkle
Paul D. Phillips, Esq.
...
C_WP :143U
.. "'... -- ...- .
-------
HOLL~~D & H.ART
,..r:-CR,-.nS ..r 1....,..,
.
:!~.,,!I
:e'..!iI '!:- ,:!"'f!t
::L:UX .;II1I\GS
"~~'-t
!IL~ -...j3
!C':!
:-!-!.."-E
AlA$-'''-G -:... ~ :
;I.I-! :~
:.:.: ~C ~E'~::...- :-;E:-
:!',!iI ::, :...~
','" t''''':; -::iI!!3
.~.:=--C..! :':: :':~ ~:c<:
-:.:::"Ei :.:: ~f;! i::
-.'.X ;':.:: :;~
': !.=11 :-.a:
:!"'~!iI ::.:'.:-: ::::
CY-';~I.\ ~ L£.\p
::~. ~!.~=
.
Febru~ry 13, 1959
3Y ~ANC C::L:V::~Y
~r. Tony ~ecr3~0
~eme'::h al Pro j C!c t
EPA Region V::I
999 18th Street
Suite SOC
Denver, Color~co
~a:'!3;o!r
S:202-24:S
Re:
Coml"en:s on Fe:asi:ility ~~t.:~y.,
Cperable t:nit ~o. 1,
Coloraco Crg!nic Chemical Soils
Sand Creek Incustrial Si:e
C=m~erce Ci:y, Co1ora=0
Dear ~r.
'~e~ r ano :
Holl:and S Hart s~bmits :~~ ~ollowing =om~en:s on behalf 0:
its client First Interstate S!nk, tr~stee f~r :~e Phllli= C,
~oser Trust. ~e are providing these general :omments 6n'tr.e
=ra~t Feasibility Study for :perable ~n1t ~o. 1 which lnclu~~s
the Colorado Organic Chemical (-COC-) si:e. We have focused our
comments on t~e preferred reme~ial altern1tive selec:e~ by EPA,
and therefore our comments are not in~ended to address :etal1e=
concerns related to the draft Feasi:ility Study.
It 11 our understanding, b!se~ on convers3tions wi:~ yot.:,
that Alternative Numcer 4 (off-site i~cir.eration and :is?os!l ;':
a Sub~itl. C lan~fill) was t~~ ~referrec 31terna:ive present!= =y
EPA at the public meetinq on J1nU!ry 31, 1999. ~e object ~~ t~e
selection of Alternative Number ~ an= recommend ~lternative
Sumber 2 "(capping) because it is ~ore consistent with tbe
Super~lJnd Amend!r.ents a,nd Reau,thorization Act, (.SARA-) requi::e-
ments, and is equally protective of hu~an ~ealth and the, enviro~-
~ent. The =raft Feasibility Stu=y recognizes that capping is
effective and reliable, can be easily i~-lemented and 1S a co~~or.
remedial 3lternative at other Su~erfund ~tes. Capping is par-
ticularly ~ffective where the subs:ances are immobile, as ar~
pesticides and inor~anic arseni:, .hi:h ~ave been identifie~ 3':
-------
HOLL~'JD & HART
4.T':'OR:"E'rS ..,r LXN .
Fe:ruary 13, 1939
Page 2
7h~ tec~nolo~y ~n: al~ernativ~ evaluatior.s perfor~~= :y E?~
in the ::aft Feasibility Study endo's~ the c~9~ing re~e:i~l
alter~!tive because it ~as been imple~ented successfully a~ 3
number of other hazardous waste sites (inclu~ing Superfunc
sites), provi:es an imme:iate and highly effective re~e=y, is
~asily constructed ~it~ ~inimal disturbance to the soi: and
results in ! si~nificant1y reduce~ risk of exposure to wor~~rs
and the public durinq i~p1emen:ation. :apping is a150 t~~ ~O;:
COs:-eff~=tlve alt~rnative, meets t~e Applicaole and Rel~v3~: :~
Appro;r~ate Require~ents (WA?ARSW) an= :an provide ?ermar.en:
re:r.e:iatl:)n.
.
.
Because t~e constituents of c:)ncern are extremely i~~obll~
:here is little potential for any impact to groun~ water q~all:Y.
~h~ executive summary states that t~e ris~ !ssessment regardlr.g
ground .ater found the minimum travel time f:)r any of th~
COnta:r.lnants :0 reach ground wa:er is over 2,000 years. This
number was calculated without .factoring in a cap, ~hic~ woul:!
significantly reduce the travel times by preventing surface -ater
from infiltrating below the cap. To select Alternative ~u:r.=er 4
as ..,! preferred alternative =eca~se it eliminates t!':e pOSS1:ll- .
ity of ground water contamination pl~ces undue emphasis on t~e
potential for ground water contamination. r~s: results confir~
that the pesticides and arseniC have not migrated to elther t~e
shall:)w or t~e :eep aquifers.
7!':ere are few, if any, disadvantages to capping. :ne =iS3;-
vantage identified by EPA is the potential reStrictlon to ~utu:e
land ~se due to disturbance of the cap. However, ca~ping does
not restrict all land uses. For example, foundations for bUl1:-
ings could easily be con5tcuc~ed on pads of fill on top of tr.e
cap. The only use restrictions that would be necessary IS to
\ prevent ~xcavation of the cap. Another disadvantage i~entlfle~
. by the draft Feasibility Study is the possible settlement an~
- subsidence of the cap materials. Settle~ent and Subsidence 3r~
. -~only of concern when a cap is placed over compresslble and
," : uncon"solidated materials. This is not t!'1e situation at the C~C
".property, where the cap would be placed over native soils whi:~
., - would eliminate the potential for si~nificant settling. Erosio~
'can be avoided by gradinq, pl~nting native vegetation snc
.'.. installin; run-off and run-orl concrols. \
.
:- . I. r:: ';'.
Further, any concern regardinq the horizontal ~igcacicn of
wa te c in the .vadose zone ce low the cap could be remec ied by
keYing in the edges of the cap (including the geomembr~ne) co a
depth .of fiv~ feet .around the contaminated zone. This mechod is
~ore cost effective than extending the cap fifty feet around :~~
-------
HOL~~D & HART
...iiOR:-';EYS ....r L....w
February 13, 1989
Page 3
.
Alternative Sumber 4 is an ina~~quat~ an~ inappr~?ri~~e
reme~y be~!us~ it ~oes not meet SARA requirements. Cnly l' to 3\
of the contaminated soils would 3ctu~lly be incin~rate~ un~e~
this alternative. The remaining 9;' to 99' of ~he contamin!:ed
soils would be sent off-site wit~out treat~~nt. .~lternatlve
Number 4 is also t~ree ~imes t~e cost of Alternatlve Number 2 a~c
allows -orkers and t~e public to ce exposed to potentlally ha~~-
ful contaminants juring excavatlon, tr~ns~ortation .~~
recisposal. Clearly, Alternative Numcer 4 does no: ;atis~y ~~~
SARA requirements for red~c:ion of toxicity, mooili:y or vcl;~e,
long-ter~ effectlver.ess and ~er~anence, i~ple~enta=llity and
cost-effectiveness.
.
EPA assu~es cert3i~ ~aterials, inclu~ing soils, buildir.;s,
foundations and t!nks are whazardous waste" without any :Qsis for
such a determination. Because it is assumed that t~e buil~ir.~s,
found~tions and t3n~s are "hazardous waste,W EPA proposes de~ol-
isninq the structures and :isposing the ~aterials in a Subtitle C
landfill. ~~e trustee strongly objects to ~he demolition of ~ny
buildings, foundations, tanKS or other structures. E?A has r.ot
id~ntified any need or provi:ed anI Jstlfication to remove ~~e
structures and such additional COSts are ur.~arrar.:ed. ~e:o ~::
believe the buildings, f~yr.1~tions an~ tanks are whazar:ous
waste:- to the c~ntrary, they are usacle structures having eco-
nomic value.
EPA has selected a Subtitle C ~lsposal faci:ity (hazar:c~s
waste f3Cillty) for disposal of all bUlldings, foundations an:
tanks t~at are :~molisned instead of a Subtitle ~ :~s~osal ~3=1~-
ity (solid waste dispOS31), in spite of the 5190 ~ifference l~
cost per CUblC yard. This cost difference is rationalized by E?A
based on savings in time and ease of implementation. T~e tl~e
saved by SUbtitle C disposal is four days: costs are three to
four times greater. It is incomprehensible how EPA coul~ j~s:if:
such an excessive expenditure of ~oney in .or~er to save four
~ays. EPA assumes t~e waste would ~3ve to =e :eliste: :u: :oes
not explain why these w3stes are consi~ered -listed.-
Another reason EPA adv~nces .in the draft Feasibility S:u~y
for disposal at a Subtitle C facili~y is the cel~ctance of
Subtitle C facilities to acce~t. was~e from Superfund sites. !~~
draft Feasibility Study does not sug~est that EPA has cont!cte~
or even att~mpted to contact any Su~title 0 facility to i~qul~~
as to whether they are willlng to accept the wastes associated
with this op~ra:le unit. The decision to us~ a Subtitle C
disposal facility is totally unfounde~. In addition, EPA a~:lci-
-------
HOLlAl'1D & HART
...iiOR:-IE'rS ....T:""W
:ecruary 13, 19a9
Page 4
.
as h3za::~~s w3stes when ~3terials and equipm~n: used at
Superfund sltes are routinely deco~taminated and reused.
,
. w~ile we a~vocate implementation of Alter~ative Numcer ~, .~
object to the placement of cor.:amlnated soi1s fro~ c~~er loca-
tio~s on COC property. Specifically, we s:rongly object to t~e
~roposal to place 5,OOJ cubic yards from Subunit 18 on CCC pr:;-
er:v. ~e jo not believe EPA ~as :~e authority to reauire t~e
tr~stee to permit t~e disposal of h.azardous sUbSta~c~s on ~ts
property.
In conclusio~, Alternative ~u~ber 2, capping, meets tr.e
requirements of SARA, is more :o3t-effective, is ~rotective o~
h~man health anc t~e environ~ent, and (with the ~ualificatlons
noted acove) is tr.e remedy that should be implemented at tr.e C:C
site.
Please feel free to call if you ~ave any questions.
Sincerely,
~~~~ ~
\
C~ ia s. teap
for HCt~A~C ~ HAR~
CSt:sl;:
cc: Hal R. Wofford
Paul D. Phillips, Esq.
Phillip C. Mozer
Susan McIntosh, Esq.
-------
-
STATE OF COLORADO
.2' 0 EISC 111n "venue
Denver, ColorldO 60220-):"16
Pnone (J031 320.6)33
Telel,.,
dO], JZ2.9076 ,'1.1,," 8u,ldl"I..04!"Y."
,]0]\ 120.1529 ,P"'""I'" PI"., 0.",."
,]0]\ 248.7198 ,c.,,"O Iu"CIIO" -e.,o",1 Oft,C.'
.~,
~".~.'
.. - y
~. ~ -;.,
"'" ...~..-
. -. .:...;,) -' .
,- '~~ .,-
,.~/
COLORADO DEPARTMENT OF HEALTH
.
August 20, 1990
'to.. Qo"',,'
Co".""o'
r"om.~ " "ftr"o~
E...c...rl\of' iJ.r.c:o,
.
Mr. BriaD PiDkowski
EDwoameDtaJ ProtectioD AgeDcy - 8HWM.SR
999 18th Street, Suite SOO
DeDver, Colorado 80202-2405
Re: SaDd Creek Feasibiliry Study Cor OU-5
Dear Brian:
I bave reviewed the Feasibiliry Study Cor ~UoS aDd have the CoUowiDg commeDts.
Page 2.5, 2.1.4. The proposed cleaaup levels of all the coDtaminants of CODcern need to be
included in tbe fS. The level should be listed for both industrial aDd resideDtial uses. A
discussioD is also Deeded detailing how the industrial ys resideDtial senano vanes and why
remediatioa for each use eatails differeat soil volumes.
Page 3-6. Tables are aeede", l removal effectiveaess for both OCP's aDd metals. This
sectioa also needs [0 be updated to give projected waste material volumes after soil washing
when available.
Page 4-14. The State EngiDeers Office bas commUDic:ated that tbey bave no abiliry to
implemeDt iD.stitwioaal control to limit weU drilling in coa[aminated areas of ground
water. Also, tbe SACWSD bas Dot been consistent in requiring relenqushiment of well water
rights upon applicatioD for water service. This requirement was only made in the northern
area of OU-2 of Cbemical Sale. Because of these problems. this paragraph needs to be revised
to state that continue usage of well water may exist. However, a survey will be undertaken
to determine the Dumber of weU users. if any in.
ARARS's
AD appeDdiz aced to be included in this FS with the complete listing of ARARS's. I have
reviewed the ARARS's tbat are included in the origiDal fS by CDM. There are several air
poUutioa reguIatioas that were Dot included in these ARARS's. I am eDclosing a table giving
these aew ARARS's. '
LANDBAN. A disc:ussiOD of IaDdbaD requiremeDu was included in tbe original fS for the site.
This disaWion Deed to updated iD this FS with detail u to bow this OU complies witb the
-------
State Accepta.ace
Alterative No.1. The State rmds this alteraative uaacceptable due to continued exposure
to the public. potealiaJ coDWDiDatioa of surface a.ad grouad water, a.ad tbe lack of usabiliry
of the site.
Altemative No. 2. The State is DOt ill fa\'Or of this alteraative because the contaminated
soil wilJ remaia oDSite a.ad require lolli-term maiateaa.ace of tbe cap to easure prOtectioD of
public health a.ad CODtaiameDt of the waste. The la.ad use wilJ be excessively restrictive.
.
Akemarive No.3. The State f&Dds this altel1Wive ICCCpcable as it fuWlns aU tbe
remedial objec:!ives.
\
AJtenwi¥e No.4. This altema~ is preferred by the State because if fullrills aU the
remedial objectives aDd ill addition minimizes waste. As .'.. projected cost of this
a1teraativ~ is speculative, the State will .eevalauate this altl. .ative as compared to
altemative No.3 wben new cost fagures become available.
Eaviromental Epidemiology is currently reviewing the health risk assessment. I hope (0 bave
comments (0 you by August 30.
Please call if you need clarification on any of these issues.
SiD~erely.
.J' ~~ .
. 7 '
~';'~~- ,/1',*- ~~
Candace Thompson. Project M~,,;;er
Hazardous Materials and
Waste Management Division
CT:Ih:7690K
-, ,
, ..... 1
U'. < "," ..-...,
-"... -.
..
, ..:. .." ~ :.:',
.. '.. .. ~ ,
c-...J' - . .
. . :H. .
-------
Page No.
08/15/90
I
STATUTORY
AU1'HOR I TY
STATUTORY
CI.TATION
REGULATION
STATE Of COI.ORADO
SAND CR~~K 01'-5 ARARS
9/15/90
fS IU:V 1 EW
Colorado Air CRS 25-1-101 TO Regulation No.
Quality Control -512 1
Act
Colorado Air eRS 25-1-101
Quality Control -512
Act
Colorado Air CRS 25-7-101
Quality Control TP-512
Act
Colorado Air CRS 25-7-101
Quality Control -512
Act
TO Rel{lIlation I,
Slal.ionllry
E.isyiolls
Source
R~glll at ion :1,
Sl.ationftry
.:.ission9
Source
TO Regulation 3,
Slat ionftry
.;.issions
Source
Rlmlll.ATION
CITATION
5 CCR 1001-9
5 ('CR 1001-:1,
Nt.'1( I, Sec.
ILA. I
5 CCII 100 I - 5 ,
Reg :1, Sec. II
5 CCR 1001- 5 ,
Reg J, S~c.
IV.U
OF-SCRIPTION ON
RF.:QIII R~:M.:NTS
Es hh I i shrs
regulatiolls lo
cont.rol
e.issions of
VOC's 'nrN and
ex i sti nl{
sources)
Co..II)' Nil h
opaci ly
I i.i lations
Fi Ie APEN
including
est i.ation of
e.issions rat.es
Source cannot
cause an
exceedance in
any aUain.en!.
area of 811)'
NAAQS
,.
COMMENTS
Apply
Reasonably
Available
Control
Technology
( RACT ) in ozone
non-allain.enl
area
< 20 I opac ity
e.i lled,
s,tec if i c
sources .ay
have olher
J i.i tations
Appl ies lo all
sources
i ncl ud ing
existing unless
speci ficall)'
exe.pt
..
A"PI.I CABtE/
REI.EVANT AND
APPROPRI AnI.
TO BE CONSID.
A PPI.I CABI.E
APPLICABLE
APPLI CAUU:
------- |