United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R08-91/048
March 1991
&EPA
Superfund
Record of Decision
Wasatch Chemical (Lot 6),
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bn.101
REPORT DOCUMENTATION 11. REPORTNO. 12.
PAGE EPA/ROD/R08-91/048
3. Reclplent'8 ACC888Ion No.
... 1I1Ie and SUbIl1le
SUPERFUND RECORD OF DECISION
~asatch Chem~ca1 (Lot 6), UT
First Remedial Action - Final
7. Aulttor(a)
5. Report Oa..
03/29/91
6.
8. Perfonnlng Organlzadon RepL No.
8. 1Wf0nning Org8lnlzadon Name and Add....
10. ProlectlTuklWork Unit No.
11. Contnoct(C) or Grant(G) No.
(C)
(G)
12. Sponaorlng Org8nlzatlon Name and Addre..
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type 01 Report & Period Covered
Agency
800/000
14.
15. Supplementary NOlea
16. Abatrac1 (Umlt: 200 worda)
The 18-acre Wasatch Chemical (Lot 6) site is an active chemical production, storage,
and distribution facility in Salt Lake City, Utah. Land use in the area is
predominantly industrial. The site lies one-half mile east of the Jordan River,
within the center of the Jordan River Valley. The site overlies a thick aquifer that
is a regional source of potable water. Surface water runoff from. the site is drained
by a series of ditches, which ultimately discharge to the Great Salt Lake. From 1957
to 1986, Wasatch Chemical Company and other tenants used the site for production,
packaging, storage, and distribution of various chemical products, including
industrial chemicals, acids, solvents, pesticides, and fertilizers. Process wastes,
including dioxins, were directed toward an onsite evaporation pond, stored in 40
drums, and also discharged directly in the ground and possibly into the Salt Lake
City sewer system. Noncompliance with State and Federal hazardous waste storage
practices and disposal standards prompted a number of the State investigations, which
revealed elevated levels of VOCs in onsite soil and sludge, and PCE in ground water.
In 1986, as part of a removal action, EPA removed 40 drums and cylinders and other
contaminated materials offsite. This Record of Decision (ROD) addresses
(See Attached Page)
17. Document Analy8la L Deacrlptora
Record of Decision - Wasatch Chemical (Lot 6), UT
First Remedial Action - Final
Contaminated Media: soil, sludge, gw
Key Contaminants: VOCs (PCE, TC~, toluene, xylenes),
(dioxins, herbicides, pesticides)
other organics
b. Idendfiera/Open-Ended Tenna
Co COSA T1 FieIdIGroup
'vallabllty Statement
18. Security Cia.. (Thla Repor1)
None
20. Security Cia.. (Thla Page)
None
21. No. 01 Page.
102
22. PrIce
(See ANSl-Z39.18
See 'MfTUcfioM on Re-
2n (4-77)
(Formelty NTIS-35)
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~
EPA/ROD/R08-91/048
Wasatch Chemical (Lot 6), UT
. First Remedial Action - Final
stract (Continued)
contamination of onsite soil, sludge, and ground water as a final remedy. The primary
contaminants of concern affecting the soil, sludge, and ground water are VOCs including
PCE, TCE, toluene, and xylenes; and other organics including pesticides, herbicides,
and dioxins.
The selected remedial action for this site includes excavating and consolidating
3,587 cubic yards of contaminated soil and sludge and 650 gallons of liquid waste in
the former evaporation pond; treating these materials onsite using in-situ
vitrification; excavating and land farming 1,111 cubic yards of hydrocarbon-
contaminated soil; sealing the surface of the site using asphalt paving; pumping and
onsite treatment of 20.4 million gallons of contaminated ground water using air
stripping; controlling air emissions with carbon adsorption, if needed, followed by
offsite disposal of residuals; and implementing institutional controls including deed
and ground water use restrictions. The estimated present worth cost for this remedial
action is $3,900,000, which includes an estimated annual O&M cost of $33,000 for 30
years.
PERFORMANCE STANDARDS OR GOALS: Soil clean-up goals are based on health-based action
levels and include PCE 103,000 ug/kg, TCE 22,000 ug/kg and dioxin <1 ug/kg (based on
RCRA Land Disposal Restrictions). Ground water action levels are based on SDWA MCLs
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.
RECORD OF DECISION
WASATCH CHEMICAL SITE
SALT LAKE CITY, UTAH
MARCH 29,1991
.. .
. .
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-- -......_-_._-~.~'.. ""~-'-'_.~' ~-..-_.-._.,..".----...- ...-...- ...-- -----""-'.'.-" .--- ...', ...... ---',- "--'-- --. ..---.- --.'- --~, "'" -.,...
-..... .-... -..,
DECLARATION STATEMENT
WASATCH CHEMICAL SITE
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i
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Wasatch Chemical Site, Salt Lake City, Utah.
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action (RA) for the Wasatch Chemical
Site (the Site), which was chosen in accordance with the requirements of the Comprehensive
Environmenul Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA) and, to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP). Th.is decision document
explains the basis and the purpose of the selected remedy for this site.
The Utah Depanment of Health (UDOH) both concurs with and recommends the selected
remedy to the U.S. Environmental Protection Agency (EPA). The information supponing this remedial
action decision is contained in the administrative record for this site.
ASSESSME:\,. OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this Record of Decision (ROD), may present an imminent
and substantial danger to public health, welfare, and the environment.
DESCRIPTION OF THE SELECTED REMEDY
The soils and ground water response actions. described in this ROD will permanently address
the principal threats at the Site through treatment to reduce the toxicity, mobility, and volume of
contaminants. Soils contamination will be reduced to health-based soils action levels for all indicator
chemicals. These levels are based on the risk assessment and on the assumption of continued induStrial
use for the Site, which assumption is based on likely future use of the Site given itS location and land
use constraints. Action levels for ground water are based on federal Safe Drinking Water Act maximum
contaminant levels (MCLs) and proposed MCLs for site indicator chemicals. Action levels also meet
state drinking water standards, which are based on federal MCLs and proposed MCLs. It should be
recognized, however, that EP A studies have indicated that it may not always be possible to reach MCLs
or proposed MCLs through currently available technology. If it becomes apparent during implementation
or operation of the ground water extraction system that contaminant levels are remaining constant for
a significant amount of time at levels higher than the performance standards delineated in the ROD, the
system's performance standards and the remedy may be reevaluated. .
-------
The major components of the selected remedy include the following:
.
Excavation of all soils containing indicator chemicals above action levels, and sludges
from the yard and process drain systems and the septic system, and consolidation of
these materials and dioxin removal wastes (approximately 3,587 cubic yards of soils and
sludges and 650 gallons of liquid waste) in the former evaporation pond;
Treatment of staged soils, sludges, and dioxin removal wastes by thermal destruction of
contaminants through in-situ vitrification (ISV);
.
.
Excavation and land farming of approximately 1,111 cubic yards of bydrocarbon-contaminated
soils;
.
Extraction of on-site contaminated ground water until MCLs and proposed MCLs are
met, and treatment, to the extent necessary, of extracted ground water by air stripping
to meet POTW or UPDES standards; .
Surface sealing by asphalt paving;
.
.
Disposal of any residuals remaining from the treatment of ground water at an off-site hazardous
material disposal facility;
As an extra precautionary measure, implementation of institutional controls such as
deed restrictions, denial of well permits, or acquisition of water rights, as practicable
and to the extent allowable by law.
.
Both soils and ground water are to be remediated as one operable unit for the Site. The ground
water ponion of the remedy for the Site, however, is subject to possible future modification because
cenain ponions of ground water remain uncharacterized. The ground water ponion of the remedy is
final for contaminated ground water underlying the Wasatch Chemical propeny and for that ponion of
the Steeko propeny extending 80 feet north of the Wasatch Chemical propeny's northern boundary
(hereinafter referred to as the southern ponion of the Steeko propeny). However, contaminated ground
water underlying that ponion of the Steel co propeny which lies to the north of the 80 foot demarcation
(hereinafter referred to as the northern ponion of the Steelco propeny) has not been fully characterized.
No remedy will be finalized for the contaminated ground water underlying the northern ponion of the
Steelco propeny until it has been adequately characterized. Further investigations and subsequent
remedial decisions regarding ground water beneath the northern ponion of the Steel co propeny may
necessitate future modification of the ground water remedy for the Wasatch Chemical propeny and the
southern ponion of the Steel co propeny, or other remedial action.
ST A nrrORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with federal
and state requirements that are legally applicable or relevant and appropriate to the remedial action (or
justifies a waiver of any federal and state applicable or relevant and appropriate requirements that will
not be met), and is cost-effective. This remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable. It satisfies the statutory preference for remedies that
employ treatment to reduce toxicity, mobility, or volume.
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~
Because this remedy will reduce levels of hazardous substances in soils to health-based action
levels suitable for industrial use, but not for unlimited use, and because the ground water remedy may
leave residual hazardous substances above action levels (MCLs or proposed MCLs), ruling out unlimited
use of on-site ground water, a review of soils and ground water will be conducted no less often than
each five years after initiation of the remedial action for each medium to ensure that the remedy
continues to provide adequate protection of human health and the environment. However, once it is
determined that ISV treatment has resulted in attaining health-based action levels for unlimited use, there
will be no need for continued monitoring of the non-hazardous vitrified material.
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Q - 9J /~
JameQ$Cherer /
Reqional Administrator
EPA Reqion VIII
~ 1) ~'
, "~ .~.,,~
!enneth L. Alkema. Director
Utah Division of Environmental Health
Utah Department of Health
~ --2-, - 'i I
Date
:3-~-~(
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TABLE OF CONTEr-.'TS
Section
1.
2.
SITE NAME, LOCATION, AND DESCRIPTION. . . . . . . . . . . . . . . . . . . . . . .
SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . . . . . . . . . . . . . .
OPERATIONAL HISTORY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
ACTIVITIES RESULTING IN RELEASES OF HAZARDOUS SUBSTANCES. . . . . .
CERCLA ENFORCEMENT HISTORY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3.
4.
RCRA ENFORCEMENT HISTORY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
HIGHLIGHTS OF COMMUNITY PARTICIPATION. . . . . . .. . . . .. . . . . . . . .
5.
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION WITHIN
SITE STRATEGY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . . . . . . . . . . . . . . . . .
SOURCES OF CONTAMINATION. . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . .
NATURE OF CONTAMINATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6.
EXTENT OF CONTAMINATION. . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . . .
SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . ... . . . . . . . . . .
HUMAN HEALTH RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
ContaminantS and Site Media. . . . . . . . . . . . . . . . . . . . . . . . . . . .. . .
Exposure Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . ... . . . . . .
Toxicity Assessment. . . . . . . . . . ... . . . . . . . . . . . . . . . . . . . . . . . .
Risk Characterization. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Additional Toxicity Information. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
ENVIRONMENTAL RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
CONCLUSION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7.
DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
REMEDIAL ACTION AL TERN A TIVES FOR SOILS, SLUDGES, AND DIOXIN
REMOV AL WASTES. . . .' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '. . . . . .
Elements Common to Each Alternative. . . . . . . . . . . . . . . . . . . . . . . . .
Alternative No.1 - No Action
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
em
3
3
6
6
7
8
8
9
9
11
11
15
18
18
18
21
23
25
25
25
26
26
27
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Section
8.
TABLE OF CONTENTS - Continued
Alternative No.4 - In-Situ Vitrification. . . . . . . . . . . . . . . . . . . . . . . .
Alternative No.5 - Glycolate Dechlorination and Off-site Incineration of
Dioxin Removal Wastes. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Alternative No.7 - Capping an Off-site Incineration of Dioxin Removal Wastes
Alternative No.8 - Off-site Disposal and Off-site Incineration of Dioxin
Removal Wastes. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
GROUND WATER REMEDIAL ACTION. . . . . . . . . . . . . . . . . . . . . . . . . . .
No Action (Alternative GW -1) . . . . . .. . . . . . . . . . . . . . . . . . . . . . . .
Ground Water Collection and Treatment with Optional Corltainment
(Alternatives Nos. GW-2a and GW-2b) . . . . . . . . . . . . . . . . . . . . . . . . .
Ground Water Collection, Optional Containment, and Treatment with Air
Stripping (Alternative GW -2a) ....,................. . . . . . . . .
Ground Water Collection, Optional Containment, and Treatment with .
Advanced Oxidation Processes (AOP) (Alternative GW-2b) ............
Ground Water Containment, Collection, and Treatment (Alternatives GW-3a
and GW-3b) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Ground Water Containment, Collection and Treatment with Air Stripping
(Alternative GW -3a) ....................................
Ground Water Containment, collection and Treatment with Advanced
Oxidation Processes (Alternative GW-3b) ........................
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. . ; . . . . . . .
SOILS, SLUDGES, AND DIOXIN REMOVAL WASTES. . . . . . . . . . . . . . . . .
Overall Protection of Human Health and the Environment. . . . . . . . . . . . .
Compliance with Applicable or Relevant and Appropriate Requirements
(ARARs) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Long-Term Effectiveness and Permanence. . . . . . . .. . . . .. . . . . . . . . .
Reduction of Toxicity, Mobility, or Volume Through Treatment. . . . . . . . .
Shon- Term Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Implementability ......................................
Cost. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
State Acceptance
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
ii
fm
29
32
33
34
34
35
.35
35
36
37
38
38
38
39
39
40
41
42
42
44
44
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TABLE OF CONTENTS - Continued
Section
Community Acceptance. . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . .
GROUND WATER. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Overall Protection of Human Health and the Environment. . . . . . . . . . . . .
Compliance with Applicable or Relevant and Appropriate Requirements
(ARARs) '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .'. . . . . .
Long-Term Effectiveness and Permanence. . . . . . . . . . . . . . . . . . . . . . .
Reduction of Toxicity, Mobility, or Volume Through Treatment. . . . . . . . .
Shon- Term Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Implementability ......................................
Cost. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
State Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Community Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
9.
SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
REMEDY FOR SOILS, SLUDGES, AND DIOXIN REMOVAL WASTES. . . . . . .
REMEDY FOR GROUND WATER. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
COST OF THE REMEDY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
REMEDIAL ACTION OBJECTIVES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
REMEDIAL GOALS AND PERFORMANCE STANDARDS-FOR SOILS, SLUDGES,
AND DIOXIN REMOVAL WASTES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
REMEDIA TION GOALS AND PERFORMANCE STANDARDS FOR GROUND
WATER. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
COMPLIANCE SAMPLING PROGRAM. . . . . . . . . . . . . . . . . . . . . . . . . . . .
10.
STATUTORY DETERMINATIONS FOR THE SELECTED REMEDY. . . . . . . . .
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT. . . . . . . . . .
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '.
Chemical-Specific ARARs ................................
Action-Specific ARARs ..................................
iii
fw
46
46
46
46
47
47
47
47
48
48
48
48
49
50
50
50
53
54
55
55
56
56
57
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Section
Table
5.1
5.2
5.3
5.4
6.1
6.2
6.3
7.1
8.1
9.1
9.2
TABLE OF CONTENTS - Continued
Location-Specific ARARs . : . . . . . . . . . . . . . . . . . .' . . . . . . . . . . . . .
To Be Considered (TBCs) . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . .
COST-EFFECTIVENESS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES (OR RESOURCES RECOVERY TECHNOLOGIES) TO THE
MAXIMUM EXTENT PRACTICABLE. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
SOILS, SLUDGES, AND DIOXIN REMOVAL WASTES. . . . . . . . . . . . . . . . .
GROUND WATER. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
. . . . . . . . . . .
LIST OF TABLES
NATURE OF CONTAMINANTS AT THE W ASA TCH CHEMICAL SITE . . . . . . .
CONCENTRATIONS OF INDICATOR CHEMICALS FOUND IN SOURCE AREAS
(SLUDGES) AND SOILS DURING THE REMEDIAL INVESTIGATION AND
ACTION LEVELS AT THE WASATCH CHEMICAL SITE . . . . . . . . . . . . . . . .
ESTIMATED SOILS AND WASTE SLUDGES VOLUME TO BE REMEDIA TED. .
CONCENTRATION OF INDICATOR CHEMICALS FOUND IN GROUND WATER
AND ACTION LEVELS AT THE W ASA TCH CHEMICAL SITE ............
EXPOSURE SCENARIO ASSUMPTIONS - INCIDENTAL SOILS INGESTION
AND DIRECT CONTACT PATHWAYS. . . . . . . . . . . . . . . . . . . . . . . . . . . .
EPA-ESTABLISHED REFERENCE DOSES AND POTENCY FACTORS FOR
INHALATION AND INGESTION PATHWAYS .......................
SUM TOTALS OF OVERALL HEALTH RISKS FOR THE REASONABLE
MAXIMUM AND TYPICAL EXPOSURE SCENARIO. . . . . . . . . . . . . . . . . , .
RELEVANT AND APPROPRIATE RCRA LDR TREATMENT STANDARDS. . . .
COST SUMMARY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
COST SUMMARY FOR AL TERN A TIVE 4 . . . . . . . . . . . . . . . . . . . '.' . . . . .
10.1
COST SUMMARY FOR ALTERNATIVE GW-2a """""""""""
FEDERAL AND.STATE ARARs AND FEDERAL, STATE, AND LOCAL TBCs ..
iv
em
65
65
65
66
66
67
67
Page
10
12
13
16
20
22
24
31
45
51
52
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TABLE OF CONTENTS - Continued
LIST OF FIGURES
~
1. f DELINEA nON OF SITE BOUNDARIES AND CURRENT OWNERSHIP. . . . . . . .
1.2
5.1
5.2
CURRENT FACILITIES PLAN, 1972 - PRESENT. . . . . . . . . . . . . . . . . . . . . . .
EXTENT OF SOIL CONT AMINA nON (REMEDIA nON FEATURES) ........
GROUND WATER CONTAMINATION PLUME AND MONITORING WELLS. . .
v
~
2
4
14
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.
DECISION SUMMARY FOR TIlE RECORD OF DECISION
1.
SITE NAME, LOCATION, AND DESCRIPTION
The Wasatch Chemical Site is located at 1987 South 700 West Street in Salt Lake City, Utah.
The Site is approximately one-half mile east of the Jordan River, 1,000 feet west of Interstate 15, and .
adjacent to the 2100 South freeway.
The Site boundaries circumscribe those areas where contaminants from Site activities may have
been placed or may have migrated. On this basis, the current Site boundaries are as follows: to the
East, the tracks of the Denver and Rio Grande Western Railroad (DRGWR); to the South, 2100 South
Street; to the West, 700 West Street; and to the North, a line of demarcation extending across the
Steel co propeny at a distance of 80 feet from the northern edge of Lot 6. These boundaries may be
adjusted if contaminants from Site activities are found to have been placed or to have migrated to areas
outside these boundaries. As indicated in Figure 1.1, the Site contains the former Wasatch Chemical
propeny (approximately 18 acres) and ponions of adjacent propenies.
The former Wasatch Chemical propeny, much of which is currently occupied by Great Western
Chemical Company (GWCC), consists of all or ponions of Lots 2 through 6. Lot 6, which is an
unpaved 3.7-acre area located at the north end of the Site, was placed on the National Priorities List
(NPL) on February 11, 1991 (56 Federal Rel!ister 3903). A railroad right-of-way belonging to DRGWR
runs along the eastern boundary of the Site. An area directly north of Lot 6 is occupied by a steel
fabrication facility owned by Alta Industries, Inc. and known as the Steelco propeny. Because the
source of some of the ground water contamination found on Steelco propeny is unclear, the ground
water remedial actions described in this ROD are final only up to 80 feet north of the northern boundary
of Lot 6 (the southern ponion of the Steeleo propeny). This ROD addresses contaminated media on all
affected areas of the Site, not just those found on Lot 6.
The Site lies within an industrialized corridor adjacent to Interstate 15. The local topography
is generally flat and low-lying. The elevated road bed of the 2100 South freeway separates the Site
topographically from vacant, swampy land to the south. The nearest residential area is located
approximately a quaner-mile northwest of the Site. The population within a one-mile radius is
approximately 5,000. The Site does not lie within a flood zone. .
Surface water runoff in the area is drained by a netWork of ditches. One of these, the 700
West Ditch, is an unlined ditch located adjacent to the west boundary of the Site and receives surface
drainage from the Site. The ditch water is ultimately discharged to the Great Salt Lake.
The Site lies near the center of the Jordan River Valley, which is underlain by a thick aquifer
that supplies much of the region's water. This aquifer is considered a single aquifer in the Salt Lake
Valley. It consists of deep and shallow ponions separated by a discontinuous confining layer. Ground
water in the shallow ponion of the aquifer at the Site is located approximately 2 feet below the land
surface, flows towards the northwest, and is currently unclassified. Water quality in the shallow ponion
of the aquifer is highly variable, and some localized areas are suitable for use as drinking water: While
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ASSOCIA TES. JULY 1990
WAS A TCH CHENICAL SITE
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DELINEATION or SITE BOUNDARIES
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the water contained in the shallow ponion of the aquifer at the Site is not currently being used as a
source of drinking water, itS potential future use as such cannot be discounted. In addition, there is a
potential for hydraulic coMection betWeen the deep and shallow ponions of the aquifer, especially in
light of the potential for heavy pumping of the deeper ponion of the aquifer in conjunction with
increasing water demands of the region. Degradation of drinking water supplies in the deep ponion'
of the aquifer could result if contaminantS migrate down from the shallow ponion of the aquifer.
Figure 1.2 shows the locations of buildings, waste disposal features, and other peninent features
described elsewhere in this ROD.
Lot 6 contains a former concrete industrial wastewater evaporation pond (the former evaporation
pond) that has been backfilled with earthen materials and covered with a concrete cap. A buried process
drain line, originating in Buildings G and F, formerly discharged wastewater from the chemical
processing areas to this pond. An abandoned sewage septic tank and leach lines are also located in Lot
6. This tank may have received process waste material at one time.
An underground fuel tank is located in the north end of the Wasatch Chemical propeny. A
number of above-ground liquid chemical storage tanks are also located near the Chlorine Building (see
Figure 1.2). These tanks are currently used in site operations. A variety of chemical produCtS stored
in drums are also used in site operations. A system of overhead pipes located along the railroad spur
within the eastern boundary of the Site are used for unloading liquid chemicals from rail tank cars.
An enclosed storage container located in the southwestern comer of the Site contains 40 drums
used to store liquid and solid dioxin-contaminated wastes. Nineteen drums contain approximately 650
gallons of dioxin-contaminated liquid wastes. Founeen drums contain approximately one cubic yard of
dioxin-contaminated soils or investigation-derived wastes. The remaining drums are empty. These
materials were removed from Lot 6 during a removal action performed by EPA in 1986 and are referred
to herein as dioxin removal wastes.
The Study Area includes all areas where sampling or other investigative work was undenaken,
including the Site and the ponion of the Salt Lake Valley in which the hydrogeology was evaluated as
pan of the Remedial Investigation/Feasibility Study (RIIFS).
2.
SITE IDSTORY AND EI\'FORCEMEI\'T ACTIVITIES
OPERATIONAL IDSTORY
In May 1957, Wasatch Chemical Company (Wasatch Chemical) purchased LotS 4 and 5 (see
Figure 1.1). Operations included producing sodium hypochlorite, refilling and distributing chlorine
and ammonia cylinders, and packaging and distributing acids, caustics, and organic solventS. An
outdoor ferric chloride production facility was also located at the Site.
Wasatch Chemical was purchased by Mountain Fuel Supply Company, Inc. (Mountain Fuel) in
June 1968. The company was later merged into a subsidiary of Mountain Fuel, Entrada Industries Inc.
-------
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ASSOCIA TES. JULY 1990
WAS A TCH CHE..,CAL SITE
SAL T LAKE CITY. UTAH
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FIGURE 1.2
CURRENT FACILITIES PLAN
1972 - PRESENT
-------
(Entrada). Entrada, DOW a separate subsidiary of Mountain Fuel's parent Company, Questar
Corporation, is the current owner of the Wasatch Chemical property. In October 1969, Mountain Fuel
consolidated Wasatch Chemical's operations from another of its facilities which had formerl y been
located at located at 2225 South 500 East (now known as the Wasatch PIau Site) with the operations
at the Wasatch Chemical Site. In coMection with this consolidation, portions of Lots 2 and 3, and all
of Lot 6 were purchased. The other buildings currently existing at the Site were built during that
expansion. In December 1972, Wasatch Chemical completed construction of the former evaporation
pond on Lot 6. According to design drawings, all process wastewater from Site operations was directed
to the former evaporation pond.
After the 1969 consolidation and until June 1978, Wasatch Chemical formulated, blended,
and/or packaged various chemical products at the property, including pesticides, herbicides, fertilizers,
industrial chemicals, and cleaners. .
In June 1978, Entrada divested its agricultural chemical business and related assets. At the same
time, Entrada sold its industrial chemical and cleaner business and related assets to GWCC. Also in
June 1978, Entrada leased with an option to purchase Lots 2 through 5 to Huntsman Chemical and Oil
Company, which later became the Huntsman-Christensen Corporation (Huntsman-Christensen).
Huntsman-Christensen then subleased a portion of that ~ea to GWCC. From June 1978 to June 1982,
Huntsman-Christensen subleased other portions of the property to various companies, including LawnLife
Corporation, a lawn-care service business.
In November and December of 1980, the former evaporation pond was covered with a concrete
top. Its use is believed to have been discontinued in 1978.
According to a risk assessment conducted by GWCC (Risk Science International, 1985), the
following activities currently comprise the primary operations on-site:
Cylinders are filled with chlorine and anhydrous ammonia through a piping system
directly from railroad cars. Sodium hypochlorite and aqua-ammonia are packaged in
drums. Hydrochloric acid, sulfuric acid, and sodium hypochlorite are packed in 5-
gallon containers. A dry blending operation manufactures proprietary goods, primarily
cleaners and sanitizers. Outside the buildings is an aluminum nitrate reactor that uses
nitric acid, hydrated aluminum, and water as raw materials. Also outside is a drumming
area where drums are filled with hydrochloric acid, inhibited hydrochloric acid, sulfuric
acid, and nitric acid. Hydrochloric acid is received in tank trucks, diluted with water,
and transferred to drums. . .
The Site, then, was operated prior to and after November 19, 1980, the effective date of the
Resource Conservation and Recovery Act (RCRA). There are currently no on-site activities at Lot 6.
That portion of the Site on Steel co property is undeveloped and unpaved.
-------
ACTIVITIES RESULTING IN RELEASES OF HAZARDOUS SUBSTANCES
Releases of hazardous substances at the Site have occurred primarily due to disposal practices
and spills.
The former evaporation pond on Lot 6 was used for disposal of process wastewater from Site
operations. In 1980 that pond was filled with eanhen materials and capped with concrete. The
associated drain lines contain hazardous substances, as do septic and yard drain systems at the Site.
Contaminants are believed to have migrated from these drain systems into the environment.
The following excerpts from UDOH reports highlight other disposal aCtivities at the Site
resulting in releases of hazardous substances:
.
In 1969, three unlined settlement ponds were reponedly used for process
wastewater discharge. The exact locations of these ponds are unknown.
During 1969 and 1970, a new septic tank and absorption field were installed at
Lot 6.
.
.
Industrial and process waste materials were reponedly discharged to a
septic tank and drain field underneath Building C until January 5, 1970,
when waste lines were realigned. .
In 1978, the connection with the former evaporation pond was reponedly severed
and GWCC's wastewater was discharged onto the ground surface through under-
ground drains or from surface runoff.
.
.
Between June 1978 and June 1982, trucks carrying fenilizers, herbicides,
and pesticides owned by LawnLife Corporation reponedly routinely
washed out the insides of the tanks and drained this wash water into the
yard drains located next to the boiler room.
In 1982, a waste and wastewater survey written by GWCC indicated that
wastewater generated from aluminum nitrate produCtion and chlorine cylinder
reconditioning was dumped on the ground. Waste clean-out water from
Wasaclor and ammonia tanks was discharged to the railroad tracks.
.
.
In August 1983, GWCC installed a line to the Salt Lake City sewer for discharge
of waste material. Salt Lake City was not aware of this connection until it was
discovered during on-site visitS in the spring of 1986.
Numerous spills of varying hazardous substances have also occurred on various pans of the Site.
CERCLA E~TORCEME~" IDSTORY
Investigations to date by EPA and UDOH have identified ten potentially responsible panies
(PRPs) associated with the Wasatch Chemical Site. These PRPs are Entrada Industries, Inc., Mountain
Fuel Supply Company, Inc., Interstate Brick Company, and Questar Corporation (the Entrada Group);
McCall Oil and Chemical Company, d/b/a Great Western Chemical Company (the Great Western
-------
.
Group); Huntsman-Christensen Corporation, Ladd E. Christensen, and A. Blaine Huntsman, Jr. (the
Huntsman-Christensen Group); Lawnlife Corporation; and Peter Ng.
Significant CERCLA enforcement-related activities at the Site include the following:
.
On January 10, 1986, UDOH filed a complaint in U.S. District Coun requesting that
members of the Entrada, Huntsman-Cbristensen, and Great Western groups, tOgether
with Peter Ng, be compelled by the coun to appropriately dispose of drums, containers,
cylinders, and contaminated soils and waters on Lot 6. See Utah Depanment of Health
v. Peter N~. et aI., Civil No. 86-C-0023G (D. Utah).
On February 7, 1986, EPA sent notice letters to Ladd E. Christensen, Entrada, Great
Western, McCall Oil, A. Blaine Huntsman, Jr., Mountain Fuel and Peter Ng, informing
them of their liability for cleanup costs associated with removal activities conducted by
EPA on Lot 6.
.
.
On March 13, 1986, EPA issued a CERCLA Unilateral Administrative Order to Peter
Ng, Huntsman-Christensen Corporation, Ladd E. Christensen, and A. Blaine Huntsman,
Jr., ordering the removal of drums, cylinders, and containers and the sampling and
analysis of soils and water found on Lot 6. .
On April I, 1986, the Entrada and Great Western Groups signed an Administrative
Order on Consent which required those PRPs to reimburse the United States for a
ponion of the response and oversight costs associated with removal activities on Lot 6.
.
.
On June 6, 1986, EPA completed an emergency action to remove drums, cylinders, and
contaminated materials from Lot 6.
.
On July 2, 1986, UDOH amended its original complaint, seeking to compel the
defendants, including the Huntsman-Christensen, Entrada, and Great Western Groups to
conduct an RIfFS for the Wasatch Chemical Site.
On April 4, 1988, the Entrada Group entered into a partial Consent Decree with UDOH
dictating that Entrada would undenake the RIIFS for the entire Wasatch Chemical site.
The RifFS was completed in October 1990.
.
.
Effective June 26, 1990, the Huntsman-Christensen, Entrada, and Great Western Groups
entered into an Administrative Settlement Agreement with EPA. Its terms included
reimbursement of EPA response and oversight costs incurred prior to June 6, 1986 at
the Lot 6 ponion of the Wasatch Chemical Site.
RCRA.E"TORCEMENT IDSTORY
The RCRA enforcement history of the Site applies mainly to operatio~ conducted by GWCC
(Entrada ceased operations at the Site prior to the effective date of RCRA). GWCC submitted a RCRA
Part A Hazardous Waste Permit Application on November 19, 1980 and subsequently operated an
Interim Status Hazardous Waste Storage Facility at the Site. In addition to storing hazardous waste,
GWCC has also treated RCRA characteristic hazardous waste (D002) in an elementary neutralization
unit (ENU). Discharge from the ENU has been to the Salt Lake City sewer system.
GWCC has received several notices of violation (NOVs) from UDOH. Violations cited include
inadequate financial assurance guarantees (February 3, 1983), inadequate employee training and alarm
-------
.
system (May 4, 1984), and failure to submit a BieMial Repon for 1987 (August 12, 1988). On October
3, 1986, GWCC was issued a NOV and compliance order because it was storing hazardous waste in
excess of the design capacity of the storage facility as specified in the Pan A permit application. A
stipulation and consent order resolving the October 3, 1986 NOV and compliance order was signed by
GWCC on August 27, 1987.
On September 28, 1989, GWCC notified UDOH of its intent to close its RCRA Pan A Interim
Status Storage Facility. Although the storage area remains unused, GWCC bas not closed that facility
under RCRA. Closure of the storage facility will occur during the CERCLA action. All RCRA closure
requirements will be met and it is intended that formal RCRA closure will be accomplished
simultaneously through coordination with RCRA authorities. .
3.
IDGHLIGHTS OF COMMUNITY PARTICIPATION
The RifFS repon and the proposed plan for the Wasatch Chemical Site were released to the
public for comment on October 9, 1990. These two documents were made available to the public inthe
administrative record. The administrative record is maintained at three locations: on the third floor of
the CaMon Health Building in Salt Lake City; the Chapman Branch of the Salt Lake City Public
Library; and the EPA Region VIII Superfund Records Center in Denver, Colorado. The notice of
availability for the RIIFS repon, the proposed plan and other documents in the administrative record
was published in the Desen News and the Salt Lake Citv Tribune on October 7, 1990. A public
comment period on the documents was held from October 9, 1990 to November 8, 1990. In addition,
a public meeting was held on October 18, 1990 at UDOH in Salt Lake City. At this meeting, the public
was invited to provide comments on the proposed plan and to ask questions of EPA and UDOH
representatives about the Site and the remedial alternatives under consideration. A response to the
comments received during the public comment period is included in the responsiveness summary which
is pan of this ROD. This decision document presents the selected remedial action for the Wasatch
Chemical Site in Salt Lake City, Utah, chosen in accordance with CERCLA, as amended by SARA, and
the NCP. The remedial action decision for this site is based on the administrative record.
4.
SCOPE AND ROLE OF OPERABLE U1'.lT OR RFSPONSE ACTION WITIIIN SITE
STRATEGY .
Tbe principal threats posed by conditions at the Site, which include soils contamination, sludges,
dioxin removal wastes, and the ponion of contaminated ground water that is currently known to
originate from the Site, are addressed in one operable unit for the Site. The ground water ponion of
the remedy for the Site, however, is subject to possible future modification because certain ponions of
ground water remain uncharacterized. The ground water ponion of the remedy is final for contaminated
ground water underlying the Wasatch Chemical propeny and the southern ponion of the Steelco
propeny. However, contaminated ground water underlying the northern ponion of the Steel co propeny
has not been fully characterized. No remedy will be finalized for the contaminated ground water
underlying the northern ponion of the Steel co propeny until it has been adequately characterized.
Further investigations and subsequent remedial decisions regarding ground water beneath the northern
-------
ponion of the Steelco propeny may necessitate future modification of the ground water remedy for the
Wasatch Chemical propeny and the southern ponioD of the Steelco propeny, or other remedial action.
If any residual contamination present in any of the buildings on-site, or any soils or debris
resulting from demolition of the buildings on-site, is not addressed in the remedial action, UDOH plans
to address this contamination, soils or debris under other statutOry authority.
s.
SUMMARY OF SITE CHARACTERISTICS
Contamination at the Site may be divided into three categories: soils, source areas, and ground
water. . Source materials at the Site include the sludges in the former evaporation pond and three drain
systems, and the dioxin removal wastes stored in the dioxin storage trailer during the removal action
conducted by EPA in 1986. These sources of contamination are described in the subsection immediately
below. The types and nature of all contaminants found on-site are described in the next subsection,
Nature of Contamination. Finally, the extent of contamination found in soils and ground water is
described in the Extent of Contaminants subsection.
Table 5.1 contains a list of the compound classes of contaminants found at the Site, a list of
indicator chemicals used for each of those classes, and a description of the tOxicity 'Bnd mobility
characteristics of the indicator chemicals. The definition and significance of indicator chemicals is
further described in Nature of Contamination, below.
SOURCES OF COl\7 AMINA TION
The process drain system (including the former evaporation pond), yard drain system, and septic
system found on Lot 6 constitute the major sources of contamination presently found on the Site. These
systems, together with additional source material, are described below.
During site operations, the process drain system carried process wastewater from operational
areas to a sump. The wastewater was then pumped from the sump into the former evaporation pond at
Lot 6. Samples taken from the process drain system contained high levels of pesticides, herbicides,
dioxin, semivolatile organic compounds (SVOCs), and volatile organic compounds (VOCs). The former
evaporation pond, COMected to the process drain system, is considered a source area because it received
process wastewater.
Process waste material which. was discharged to the former evaporation pond may have
contained any of the chemicals used on-site. The former evaporation pond, which was constructed of
concrete, was filled with eanhen materials and covered with a concrete top at the end of 1980. The
distance between the base of the pond and the ground water table varies between o and 4 feet. The
current integrity of the pond is questionable: ground water near the pond is contaminated by solvents
which may have leaked from the pond. Solvents may also have leaked from the process drain lines.
The northern ponion of the yard drain system, which receives surface runoff from the Site, is
considered a potential source because elevated contaminant levels have been detected in the system.
-------
TABLE 5.1
~
NATURE OF CONTAMINANTS AT TIlE WASATCH CHEMICAL SITE
Chemical Class'
Indicator Chemicals
Toxicity
VOCs
Trichloroethene (TCE)
Tetrachloroethylene (PCE)
Suspected carcinogen
Suspected carcinogen
SVOCs
Hexachlorobenzene (HCD)
Pentachlorophenol (PCP)
Probable carcinogen
Suspected carcinogen
Pesticides
Chlordane
4,4' ,-Dichlorodiphenyltrichloroethane (4,4' ,-DDT)
4,4' ,-Dichlorodiphenyltrichloroethene (4,4' ,-DDE)
4,4' , -Dichlorodiphenyldichloroethane (4,4', -DDD)
Heptachlor
Suspected carcinogen
Probable carcinogen
Probable carcinogen
Probable carcinogen
Probable carcinogen
Herbicides
2,4-Dichlorophenoxyacetic acid (2,4-D)
2,4,5-Trichlorophenoxyacetic acid (2,4,5-T)
Suspected carcinogen
Suspected carcinogen
Dioxins and Furans
Dioxins (all detected congeners).
(as 2,3,7,8 Tetrachlorodibenzedioxin)
Probable carcinogen
Mobility.
1,100 mg/L
150 mg/L
6 p.g/L
20 mg/L
9 p.g/L
3 p.g/L
I p.g/L
20 Ilg/L
100 Ilg/L
19 Ilg/L
Mobility is expressed in terms of solubility in water. Compounds with high water solubilities tend to desorb from soils and
sediments, are less likely to volatilize in water, and are susceptible to biodegradation. Conversely, compounds with low solubilities
tend to adsorb onto soils and sediments, volatilize more readily in water, and bioconcentrate in aquatic organisms. Mobility values
at 25°C from Ground Water Chemicals Desk Reference by J. Montgomery and L. Welkom, 1990, Lewis Publishers.
-------
Run-off and drainage from surface chemical spi1ls are suspected origins of this contamination. The
septic system on Lot 6, which includes a leach field on that lot, also shows evidence of contamination.
Both the yard drain and septic systems contain a wide variety of contaminants at elevated levels.
Table 5.2 shows maximum concentrations of indicator chemicals in sludges found in the above-
described systems compared to action levels. The estimated volumes of material, including sludges,
requiring remediation in each area of the Site are listed in Table 5.3.
Finally, the dioxin removal wastes constitute additional source material found at the Site.
During the removal action conducted by EP A in 1986, surface soils contaminated by materials leaking
from some of the original drums found on Lot 6 were excavated and drummed. The leaking drums
were sampled and placed in overpack drums. Those drums, together with drums containing excavated
soils, were stored in the dioxin storage trailer until a final disposal method could be found. Further
sampling of soils as a result of EPA's "Make Sites Safe" initiative in August 1990 found high levels of
dioxin (2,3,7,8-TCDD) remaining in the area on Lot 6 which was the subject of the 1986 removal. A
new removal action subsequent to the August 1990 sampling event is currently underway to stabilize
contaminants found in this area until remediation occurs. No off-site disposal facility has been
permined to accept dioxin or dioxin-contaminated materials.
NAnJRE OF C01\'TAMINATION
A wide variety of contaminants was found at the Site. In order to effectively manage the
evaluation of health and environmental risks, contaminants were grouped according to chemical
classification and 'indicator chemicals were selected from each group. Indicator chemicals represent
the most prevalent, mobile, persistent, and toxic compounds found at the Site. Health-based cleanup
or action levels were calculated for these indicator chemicals. The action level for dioxin was based
on determinations at other sites that the 20 parts per billion level is protective for an industrial scenario.
The industrial scenario is appropriate for the Site, given the Site's likely use in the foreseeable future.
Indicator chemicals are used throughout the ROD to describe contamination at the Site.
E:\'TE1\'T OF COr--'T AMINAA'TS
Aside from the source areas described above, contaminants at the Site occur in soils and ground
water.
The extent of soils contamination is widespread and is depicted in Figure 5.1. Sampling by
UDOH during site investigations in 1986 and 1987 indicated that surface soils on Lot 6 were
contaminated with pesticides (notably chlordane and heptachlor), and polynuclear aromatic hydrocarbons
(PAHs). Based on the results of soils' sampling performed during the remedial investigation, it was
determined that areas of elevated concentrations of contaminants exist on Lot 6. Although Lot 6 is not
currently being used and access to it is restricted by fencing, the panern of contaminant distribution may
be the result of vehicular and foot traffic associated with the 'past use of the propeny and past storage
of drums in certain areas.
-------
TABLE 5.2
CONCENTRATIONS OF INDICATOR CHEMICALS FOUND IN SOURCE
AREAS (SLUDGES) AND SOILS DURING THE REMEDIAL INVE'STIGA TION
AND ACTION LEVELS AT THE WASATCH CHEMICAL SITE
Highest Conc. Highest Conc.
Indicator in Sludge in Soil Action Levels
Chemicals (oob) (pDb) (Dob)
Herbicides
2,4-D 634 30,768 I
-
2,4,5-T 300 1,111 I
---
Pesticides
4,4'-DDD 280 400 26,000
4,4'-DDE 6,300 4,500 19,000
4,4'-DDT 2,800 8,100 19,000
Alpha-Chlordane 520,000 520,000 7,000
Gamma-Chlordane 680,000 890,000 7,000
Heptachlor 26,000 S,3OO 2,000
Dioxins
TCDD (Total) 13 11 20
Semi-Volatile Onzanic Compounds
Hexachlorobenzene 49,000 66,000 7,000
Pentachlorophenol 460,000 250,000 _I
Volatile On~anic Compounds
Trichloroethene 440,000 1,800 103,000
Tetrachloroethene 200,000 22,000 22,000
Note: Heptachlor, 4,4'-DDT, 4,4'-DDE, and 4,4'-DDD, dioxin and hexachlorobenzene are
classified as probable human carcinogens. Chlordane, 2,4-D, 2,4,S-T, pentachlorophenol,
trichloroethene and tetrachloroethene are suspected human carcinogens.
Three of the indicator chemicals (pCP, 2-4D, and 2,4,S-T) were not considered in
developing target clean-up goaJs because concentration levels of these chemicals detected at
the site are not above any health-based criteria that would be developed for this site. In
addition, the highest concentrations of these chemicaJs are found in areas where other
indicator chemicaJs are aJso present. It is therefore expected that any remediaJ activity which
addresses the indicator chemicaJs currently having action levels will also reduce
-------
TABLE 5.3
ESTIMATED SOIL AND WASTE SLUDGE VOLUME TO BE REMEDIA TED
SYSTEM
ESTIMA.TED VOLUME
(CUBIC YARDS)
Contaminated soil
1189
19
Process drain system
Yard drain system
Lot 6 septic system
30
21
Former evaporation pond
2300
15
Waste piles in fenilizer building
Drummed soil (investigation-derived waste)
13
1,111
Petroleum hydrocarbon contaminated soil (for landfarming)
UDOH oversight derived materials
~
TOTAL
-------
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WECA rOODS
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~ODlfIED fROIot: HARDINC LAWSON
ASSOCIA TES, JULY 1990
WASA TCH CHE~ICAL SITE
SAL T LAKE CITY. UTAH
~ ,00' 150' - J¥
SCALE: t..12S"
FIGURE 5.1
EXTENT Of SOIL CONTAMINATION
REMEDIA nON FEATURES
-------
Several topographically low points on-site collect water during pan of the year. These areas lie
along the eastern boundary of the Site and represent areas in which contaminants ttansponed by runoff
or spills accumulate. Acids and bases have been spilled in the region along the rail spur during loading
and uilJoading. Because the former process drain line, which originates at the Pesticide and Fenilizer
Buildings, runs along the rail spur, this area has received a variety of contaminants. With the exception
of TCDD levels found as a result of the -Make Sites Safe- initiative, the highest levels of dioxins,
furans, and several other contaminants found at the Site were detected in soils samples collected at the
head of the process drain. Green Lake (a tOpographical depression located in the southeast corner of
the Site which sometimes contains ponded water) is believed to have accumulated contaminants carried
there by surface water runoff from the process areas of the Site.
Additionally, soils in the drum handling area are contaminated with hydrocarbons, panicularly
xylene and toluene, to a depth of approximately 4 feet.
. Concentrations and action levels for indicator chemicals .in soils are shown in Table 5.2. The
estimated volumes of soils that require remediation in each area of the Site are listed in Table 5.3.
The primary contaminants of concern in ground water are the indicator chemicals TCE, PCE,
PCP, and 2,4-D. Concentrations for ground water indicator chemicals are listed in Table 5.4.
As shown in Figure 5.2, known ground water contamination is widely dispersed throughout
the Site. The extent and origin of contaminated ground water found on the nonhero ponion of the
Steel co propeny has not been fully characterized. Funher investigations and subsequent remedial
decisions regarding ground water at the Steel co property are expected to be completed before the
initiation of the remedial action.
Because the ground water contaminants are in the aqueous phase, the venical extent of ground
water contamination is assumed to be continuous throughout the shallow ponion of the aquifer. The
shallow ponion of the aquifer is approximately 18 feet thick and extends from land surface to the
confining unit which separates the shallow and deep ponions of the regional aquifer. A monitoring well
has been installed at a depth of 40 feet. Preliminary analysis of samples from this well shows no
contamination.
Based on information obtained from field investigations and conceptual flow modeling, the
volume of ground water to be remediated is estimated at 20.4 million gallons. This does not include
uricharacterized ground water on. the nonhern ponion of the Steelco property.
Potential routes of contaminant migration and population and environmental areas that could be
affected by the contaminants are described in Section 6.
6.
SUMMARY OF SITE RISKS
This section is a summary of the information used to characterize the risks to human health
and the environment posed by conditions at the Site. Documents concerning site risks, which were
-------
TABLE 5.4
CONCENTRATION OF INDICATOR CHEMICALS' FOUND IN GROUND WATER
AND ACTION LEVELS AT THE W ASA TCH CHEMICAL SITE' .
(unitS in microgramslliter, (J,LglL»
I
COMPOUND MAXIMUM VALUE GEOMETRIC MEAN ACTION LEVEL
(monitor well) (not including third round samples) (MCL2)
Volatile Or~anic Compounds
Tetrachloroethene (PCE) 1,400 (MW-12) 21 5
Trichloroethene (TCE) 8,000 (MW.Q7 78 5
1,1-Dichloroethene4 (1, I-DCE) 230 (MW-12) 53 7
Semi volatile Oreanic Compounds
Pentachlorophenol (PCP)
630 (MW-IO)
S08
Herbicides and Pesticides
2,4-Dichlorophenoxyacetic acid
(2,4-D)
26 (MW-12)
7.6
70
For Phase I, Phase II, and Third Round Sampling
MCL - maximum contaminant level (drinking water regulations under the Safe Drinking Water Act)
J
These indicator chemicals, a subset of indicator chemicals identified for soil and waste, were selected based
on the frequency of detection, magnitude of detected concentrations, and physicochemical properties (for
example, toxicity, chemiCal fate, and persistence).
Although not listed as an indicator chemical for ground water in the FS, 1,1-DCE is a primary contaminant
of concern at the site with a frequency of occurrence of 27.3 percent and a median concentration of 100
#tg/L. It is anticipated that the selected ground water remedy for indicator chemicals will also treat 1,1-
DCE to below the MCL. .
-------
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IAODIFIED FROM: HARDING LAWSON
ASSOCIATES, JULY 1990
WAS A TCH CHEMICAL SITE
SALT LAKE CITY. UTAH
~-
'110'
,50'
-
Z5O'
--
SCALE: '.-125'
FIGURE 5.2
GROUND WATER CONTAMINATION
PLUIotE AND IotONITORING WELLS
-------
prepared by Entrada, EPA, and UDOH, may be found in the administrative record for the Site. The
information presented in this Section suppons the decision to take remedial action due to aCtUal or
threatened releases of hazardous substances.
Although current risks were analyzed, it was determined that future potential risks were of
greatest concern. In analyzing these future potential risks, the assumption was made that the integrity
of the subsurface drain system, which currently inhibits movement of contaminants contained therein to
the external environment, will be breached at some time in the future and that these contaminants will
therefore be made available for exposure to workers.
HUMAN HEALTH RISKS
Contaminants and Site Media
The following media at the Site were evaluated to determine what level of risk contamination
in each presents to human health: .
.
Soils
.
Liquids and sludges associated with the former process drain system (source
area)
Liquids and sludges present in the active storm water drainage system (source
area)
.
.
Ground water
.
Air
.
Surface water (in the 700 West ditch and areas of ponded water on-site)
Sediments (in the 700 West ditch)
.
As described in Summary of Site CharaCteristics (Section 5), soils, source areas, and ground
water have been determined to be the media of concern.
Table 5.1 lists indicator chemicals. chosen from among the contaminants detected at the Site to
represent tbe most prevalent, mobile, toxic, and persistent contaminants.
Contaminant concentrations used in potential future risk calculations were 95th percentile upper
confidence limits on the geometric mean.
Exposure Assessment
The exposure assessment was completed in tWo steps. Initially, the Endangerment Assessment
(EA) was conducted by Entrada. This document evaluated current exposure only. It was fonowed up
with subsequent work by Entrada and EPA, which evaluated potential future risk. The exposure
pathways, receptor populations, exposure point concentrations, and exposure assumptions for each step
-------
of the latter evaluation (which incorporates some assumptions from the EA evaluation) are summarized
below and shown in Table 6.1.
Three potential receptor populations were initially identified in the EA dated January 26, 1990.
These included an off-site residential population, an off-site worker population, and an on-site worker
population. Ingestion, inhalation, and direct dermal contact were investigated as exposure routes. Only
ingestion and direct dermal contact were found to be pathways of potentially significant exposure. Risk
estimates associated with inhalation indicate that inhalation would contribute little to overall site-related
risks .
In the EA, the off-site residential population was assumed to reside one-fourth mile northwest
of the Site in the predominant downwind direction from the Site and include children between the ages
of 1 and 17 and adults between the ages of 18 and 70. This population was assumed to reside at the
same location for a 7o-year lifetime. The residential population was evaluated for risks from inhalation
exposure to airborne contaminants, including fugitive dust and chemicals volatilizing from soils and
ground water. EP A used similar assumptions in evaluating risks due to the .ingestion of ground water.
Current Risks
The off-site worker population was assumed, in the EA, to work just north of Lot 6 and be
continuously exposed to inhalation of contaminants via volatilization and dust emissions.
Also for purposes of the EA, it was assumed that on-site workers do not have access to Lot 6,
which is surrounded by a cyclone fence. Therefore, dermal and incidental ingestion exposures were
-, evaluated only for contaminants on Lots 2 through 5. However, it was assumed that on-site workers
could inhale dust and volatile emissions emanating from Lot 6.
All workers were assumed to be employed for 8 hours per day for 10 years in the typical
exposure and 30 years in the reasonable maximum exposure. Incidental ingestion for on-site workers
was evaluated using on-site surface (0-6 inches) soils concentrations for all indicator chemicals. The
geometric mean surface soils concentrations for the unpaved areas on Lots 2-5 were used to evaluate
current exposures for a typical and reasonable maximum scenario.
The EA prepared by Entrada concluded there are no significant current risks at the Site.
Although not guaranteed, continued use of the Site in an industrial capacity is most likely
because of its location in an industrial area of Salt Lake City and land use constraints.
Future Potential Risks
Subsequent calculations were performed to further evaluate future on-site worker and residential
exposures, and acute exposures.
For the further evaluation of future exposures, on-site workers were assumed to have full access
to Lot 6. Therefore, the geometric mean surface soils concentrations for unpaved areas in Lots 2-6
-------
TABLE 6.1
EXPOSURE SCENARIO ASSUMPTIONS
INCIDENTAL SOIL INGESTION AND DIRECT CONTACT P A THW A YS
Scenario
Tynical
Reasonable Maximum
Receptor
On-site workers
On-site workers
Contaminant concentration (Cs)
Geometric mean
Upper 95 percent
confidence limit
Exposure duration (ED)
9 years
30 years
Exposure frequency (EF)
.175 days/year
175 days/year
Ages
18 - 26
18 - 47
Bioavailability (AB)
100 percent (oral)
chemical specific (dermal)
100 percent (oral)
chemical specific
(dermal)
Soil ingestion rate (IR)
25 mg/day
25 mg/day
Dermal contact rate (CR)
275 mg/day
275 mg/day
Body weight (BW)
70 kg
70 kg
Averaging time (AT)
(cancer risks)
.
25,550 days
25,550 days
A veraging time (AT)
(systemic toxicity)
3,285 days
10,950 days
BASIC EXPOSURE EQUATION
CDI =
CR or IR x Cs x EF x ED.x CF x AB
BW x AT
-------
were used. To more closely conform with EPA Superfund Risk Assessment guidance, the 95 percent
confidence limit of the geometric mean was used in subsequent risk calculations. Additional evaluations
were performed by EP A to assess potential acute and/or subchronic exposure risks associated with
direct exposure to contaminantS found in sludges in the process and yard drain systems. It was assumed
that the integrity of the subsurface drain system, which currently inhibitS movement of contaminantS
contained therein to the external environment, would be breached at some time in the future and that
these contaminantS would therefore be made available for exposure to workers. Exposure to these
sludges could reasonably occur for workers involved in the repair or removal of the drain systems. A
preliminary analysis indicated the potential for substantial exposure, both dermal and via incidental
ingestion. The greatest potential hazard appeared to be associated with dermal exposure to chlordane-
contaminated sludges.
The potential for dermal contact with on-site surface soils was also evaluated in subsequent
work. The same soils concentrations used in calculating ingestion exposures were used to evaluate
dermal exposures (for example, surface soils concentrations for unpaved areas in LotS 2-6).
The EA prepared by Entrada concluded that there is no existing or potential receptor population
for ground water contaminated by site contaminantS. Therefore, no ground water exposure assessment
was performed in the EA. However, EPA and UDOH disagreed with this conclusion, and determined,
based on on-site hydrogeology, that a potential for future human exposure to contaminated ground water
does exist. Therefore MCLs established under the Safe Drinking Water Act are considered to be
applicable or relevant and appropriate requirementS (ARARs) and proposed MCLs are to be considered
(TBCs). MCLs and proposed MCLs were therefore adopted as ground water cleanup standards fully
protective of human health. (See Section 8 for a full explanation of ARARs.) . The regulatory agencies
also determined that some preliminary risk analysis should be carried out to illustrate possible future
exposures and accompanying risks. This analysis evaluated future uses of ground water including
ingestion of ground water by future workers using a shallow well in the contaminated aquifer, and
household use of ground water by residentS obtaining water from the shallow ponion of the aquifer.
ResidentS would most likely be exposed via ingestion of contaminated ground water as well as by
inhaling vapors while showering and cooking.
Toxicit\. Assessment
The toxicity of chemicals is evaluated .in terms of carcinogenicity and other, noncarcinogenic
effectS. Cancer potency factors for carcinogenic chemicals and reference doses for noncarcinogenic
chemicals are used to evaluate risks posed by the exposure to chemicals.
Cancer potency factors (CPFs), also Icnown as slope factors, have been developed by EPA's
Carcinogenic Assessment Group. Slope factors estimate excess lifetime cancer risks associated with
exposure to potentially carcinogenic chemicals. Slope factors are derived from the resultS of human
epidemiological studies or chronic animal bioassays to which animal-to-human extrapolation and
uncertainty factors have been applied. EPA-established slope factors for inhalation and ingestion
exposures are presented in Table 6.2. The slope factor for a given compound is multiplied by the
estimated dose to obtain the carcinogenic risk estimate. The individual risks from each compound in
-------
TABLE 6.2
EPA-ESTABLISHED REFERENCE DOSES AND POTENCY FACTORS
FOR INHALATION AND INGESTION PATIfWAYS
Indicator Chemical
Inhalation
RfCc
(mg/m)J
Inhalation
Slope Factor
(mglkg/dr'
Ingestion
RIDc
(mglkg/d)
Ingestion
Slope Factor
(mglkg/ d)'l
TCE NDo 1. 70E~2 ND 1.IOE~2
PCE ND 3.30E~3 l.ooE~2 5.10E~2
Hexachlorobenzene ND 1.70E+00 8.ooE-D4 1.70E+00
PCP ND ND 3.ooE~2 1.20E~1..
Chlordane ND 1.30E+00 6.ooE~5 1.30E+00
Heptachlor ND 4.50E+00 5.ooE-D4 4.50E+00
4,4-DDT ND 3.40E~1 5.ooE-D4 3.40E~1
4,4-DDD ND ND ND 2.40E~1
4,4-DDE ND ND ND 3.40E~1
2,4-D ND ND l.ooE~2 ND
2,4,5-T ND ND l.ooE~2 ND
Dioxins ND 1.56E+05 ND 1.56E+05
(2,3,7 ,8-TCDD)
HxCDD ND 6.20E+03 ND 6.20E + 03
. ND None developed (to date)
-------
a panicular exposure pathway are then summed to obtain an estimate of the overall carcinogenic risk
posed .
Reference doses (RIDs) have been developed by EPA. RIDs indicate the potential for adverse
health effects caused by exposure to contaminants exhibiting noncarcinogenic effects. RIDs are derived
from human epidemiological studies or animal studies to which uncenainty factors have been applied.
These uncertainty factors help ensure that the RIDs will DOt underestimate adverse noncarcinogenic
effects. EPA-established RIDs for inhalation and ingestion exposures are presented in Table 6.2. The
RID for a given compound is divided into the estimated dose to obtain the hazard quotient (HQ). The
HQs for each compound in a panicular exposure pathway are then summed to obtain a hazard index
(HI), which is the estimate of the overall non-carcinogenic risk.
Risk Characterization
The cancer risks and non-carcinogenic risks for all contaminants associated with on-site worker
exposure are presented in Table 6.3. On-site workers are shown because they are most likely to be
exposed to on-site contaminants. The risks presented are based on levels of contamination with no
remediation.
The acceptable carcinogenic risk range is between 10~and 10~. The value shown in Table 6.3
for the reasonable maximum scenario, which is 2.62 x 10'" exceeds these limits. Thus, these values
pose an unacceptable risk. Note that in the EA, less-than-lifetime cancer risks were estimated using
Crump and Howe's (1984) method which adjusts EPA slope factors based on exposure duration.
Independent calculations by EPA Region VnI indicate that there was little difference between the results
of calculations based on Crump and Howe adjustments and those based on standard lifetime averaging
(lADD) methods. Thus, in subsequent risk calculations, LADD calculations were used to estimate
risks. It is the laner estimates that are reponed in Table 6.3.
Table 6.3 shows the non-carcinogenic hazard index calculated for the future on-site worker
population, which is 2.12. An HI over 1.0 indicates that there may be a risk posed by the exposure
to non-carcinogenic compounds. Because the values for the reasonable maximum scenario exceed one,
the potential for hepatotoxicity in exposed workers exists. Exposure factors are the same as those
described for carcinogenic risks above.
Risk estimates for scenarios involving exposures to ground water were not provided in the EA.
However, subsequent preliminary exposure estimates made by EPA Region VIII indicate the potential
for high levels of exposure to future users of ground water. Standard quantitative risk characterization
methods suggest that chronic exposures to contaminated ground water could result in unacceptable risks
of cancer in either workers drinking from contaminated wells or in future residents using the ground
water for drinking, bathing, and cooking. Substantial potential risk is associated with exposures to
TCE and PCE. A potential risk from dioxins and HCB in around water was also suggested in this
assessment. However, this risk was based on high detection limits for water analyses and the presence
of dioxins and HCB on-site. No analyses of on-site ground water detected any dioxin or HCB. In
addition, the potential exposure concentration for PCP in ground water exceeded the proposed MCL
based on the new slope factor for ingested PCP. This slope factor, as explained below, was not
-------
TABLE 6.]
StM TOTALS Of ..IAll ':AlTI IlsrS
fOl TIlE IEASOWILE ....1.... All) TYPICAL EXPOSUIE salAliO
CAlCI8OIiE1IC ':AlTI IlsrS
Scenario IKeptor . hital at ion Ingest ion
Population (yeers)
Dusts (Air Vapors (Air Dusts & Vapors SoH
fIodI! ling) Model ing) (Air
Monitoring)
Typical Atill t Worker 18 . 65 --------- .-....-..........- .-................... 2.05E-05
leasonable AdJi t Worker 18 . 65 .-.....-............ ..............--.....- .................... 1.83E-03
MaJIi-
DefWli
s... Tot.I ff'C18
...1 tiple lautes
of hpos48"e
SoH
8.71£-06
2.92E-05
7.86E-04
2.62E-03
_-CAlCI8OIiE1IC IIAlAID IIIJEX
Scenario leceptor Age lria.lation Ingestion DefWli s... 'ot.I ff'C18
Popul.tion (reers) ...atiple lautes
of ElIpOSUre
(ag)
Dusts (Air Vapors (Air Dust. & Vapors SoH SoH
...1 ing) ...1 ing) (Air
Monl torlng)
Typicat Atill t Worker 18 . 65 .-..........-- -----..---.. ---------- 2.97(-02 1.31£-02 4.28£-02
leasonable AdJtt Worker 18 ~ 65 -----............- ---..--...-...- --..-...-.--- 1.47(+00 6.48£-01 2. 12E+00
MaJli-
EJlposure Assumptions are found in Table 6.1.
'he eJlposures presented here are for potential risks under various future uses of the Site, end not risks posed by current use of the Site.
Health risk estimates from potential acute eJlposure events and potential eJlposure to ground Mater Mere qualitatively perfonmed end found to be
-------
available at the time the ground water assessment was written. This assessment of the ground water
pathway can be found in the administrative record.
Of all the populations and exposure routes evaluated, with the possible exception of acute and/or
subchronic exposure risks, the future ingestion of contaminated soils by on-site workers would contribute
the greatest risk. The future direct dermal contact by on-site workers would also contribute significantly
to risks at the Site. In this regard, acute exposure to contaminants, especially chlordane, in the process
and yard drain sludges was examined by EPA Region vm. Estimated exposures to future workers
appear to be high enough that acute toxicity might be expected even after a single exposure event.
Quantitative risk estimates were not made in the analysis of acute risks.
The greatest uncertainty associated with the characterization of risk at this Site involves the
accurate evaluation of exposure to the site contaminants. These exposure factors include time spent on-
site, bioavailability, amount of soils ingestion, and definition of n appropriate future land use. Overall,
a conservative approach was taken in order to insure adequate protection of public health and the
environment.
Additional Toxicitv Information
Subsequent to the completion of all risk assessment work, an oral carcinogenic slope factor was
verified for the indicator chemical PCP (no slope factor was available during the time the EA and
subsequent calculations were completed). The slope factor is large enough (0.12 mglkg/d-l) to
dominate risks from PCP exposure in most scenarios. Since the RIfFS and ROD do not set an action
level for PCP, this indicator chemical is not included in the evaluation of areas where remediation is
necessary. The highest concentrations of PCP, however, are found in areas where other indicator
chemicals are also present. It is therefore expected that any remedial activity which addresses the
indicator chemicals currently having action levels will also reduce PCP concentrations to acceptable
levels. In light of the PCP slope factor having been recently verified, residual PCP concentrations will
be assessed during remedial action to ensure no unacceptable risk due to this contaminant will remain
at the Site.
ENVIRONMENTAL RISKS
No critical wildlife habitats, endangered species, or habitats of endangered species are affected
by site contaminants. Pesticides, herbicides, and metals were analyzed in vegetation samples and tissue
samples taken from mice and pigeons collected at the Site. Neither herbicides nor pesticides were
detected in the animal tissue samples. There was no evidence of organ tissue abnormality in the pigeons
that were sampled. In addition, dioxins and fur~ were analyzed in aquatic and upland vegetation
samples. The contaminants were not found to be impacting biota at or near the Site.
CONCLUSION
Actual or threatened releases of hazardous subslnces from this Site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment. The hazardous nature of this site is
-------
illustrated by the values presented in Table 6.3. Under the reasonable maximum exposure scenario for
an on-site adult worker, the overall carcinogenic risk was estimated to be 2.62 x 10') and the non-
carcinogenic HI to be 2.12. A cancer risk of 2.62 x 10') means that for every 1,000 persons exposed
as a worker on the Site, between 2 and 3 (2.62) of them will develop cancer as a result of that
exposure. A HI of 2.12 indicates that a worker at the Site is being exposed to a little over twice the
level (2.12 times the level) that the EPA considers .safe. for those compounds which do not cause
cancer. These risks are for potential future uses of the Site, and not risks posed by current use of the
Site. Remediation of the Site to the concentrations proposed in this ROD will result in risks which are
within the acceptable range as established by EP A guidance.
7.
DESCRIPTION OF ALTERNATIVES
A Feasibility Study (FS) was conducted to develop and evaluate remedial alternatives for soils,
sludges, dioxin removal wastes, and ground water at the Wasatch Chemical Site. Remedial alternatives
were assembled from applicable remedial technology process options and were initially evaluated for
effectiveness, implementability, and cost. The alternatives passing this screening were then evaluated
based on nine criteria required by the NCP. In addition to remedial alternatives, the NCP requires a
no action alternative be considered at every site. The no action alternative serves primarily 'as a point
of comparison for other alternatives. .
Following the detailed screening analysis in the FS, five remedial alternatives (including the no
action alternative) remained for treatment of soils, sludges, and dioxin removal wastes and five
alternatives remained for treatment of ground water. These alternatives are described below with the
original alternative numbering sequence from the FS repon and proposed plan. The remedial
alternatives for soils, sludges, and dioxin removal wastes are described first, and ground water
alternatives are described second in a separate section.
REMEDIAL ACTION ALTERNATIVES FOR SOILS, SLUDGES, AND DIOXIN REMOVAL
WASTES
Action levels were developed to provide remediation goals in the absence of any chemical-
specific applicable or relevant and appropriate requirements (ARARs) promulgated for soils, sludges.
and dioxin removal wastes. The potential risks to human health and the environment identified in the
risk assessment process provide the basis for establishing these action levels which are presented in
Table 5.2. .
The estimated volume of site soils and sludges requiring remediation was calculated using the
soils action levels and the soils boring data collected during the RI. The estimated total volume of soils
exceeding action levels is 1189 cubic yards: 964 cubic yards of the surface soils and 225 cubic yards
of soils surrounding the process drain. In addition, 1,111 cubic yards of petroleum hydrocarbon
contaminated soils will be excavated and treated with landfarming techniques. There are an additional
estimated 15 cubic yards of waste material piled in the fenilizer building, and 13 cubic yards of
investigation-derived material. .
-------
Sludges are present in the process drain system, the yard drain system, the Lot 6 septic
tank/sump system and the former evaporation pond. The estimated sludges volume is 2,370 cubic
yards. The total estimated volume of soils and sludges to be remediated is therefore approximately
4,698 cubic yards. The results of verification sampling to be conduCted during remedial aCtion may
affect the actual volume to be remediated.
Finally, 1 cubic yard of miscellaneous conwninated material and 650 gallons of liquid waste
material contained in drums in the dioxin storage area will also be remediated with soils and sludges.
Elements Common to Each Alternative
Each alternative presented for soils, sludges, and dioxin removal wastes (including the no action
alternative) addresses cleanup of the dioxin removal wastes contained in the dioxin storage facility.
Excluding the no action alternative, each alternative also in~udes the following common elements
(except that landfarming is not a part of Alternative 7) :
.
Institutional controls - As an extra precautionary measure, institutional controls such as
deed restriCtions, denial of well permits, or acquisition of water rights, will be
implemented as practicable and to the extent allowable by law. Institutional controls
such as deed restrictions will be used to prevent the Site from being used for non-
industrial purposes and to maintain access restrictions; Direct costs will be minimal.
Landfarming - Approximately 1,111 cubic yards of petroleum hydrocarbon-conwninated
soils will be excavated and aerated to promote biolo,-ical degradation and enhance
volatilization of contaminants. The landfarming w1l1 involve construction of a
landfarming cell on-site, excavation of soils, and operation and maintenance such as
tilling and nutrient application. Air emissions generated during landfarming would be
subject to State best available control technology (BACT) requirements, (unless standards
for exemptions from those requirements are met). Relevant and appropriate
requirements for releases from RCRA Solid Waste Management Units (SWMUs) will
be complied with. Relevant and appropriate RCRA minimum technology requirements
for land treatment will also be complied with. The implementation time is
approximately one to three months at an estimated cost of 581,000.
.
.
Possible dewatering of the former evaporation pond contents, if necessary to facilitate
treatment of soils, sludges, or dioxin removal wastes, and treatment of the resulting
liquids.
Additional characterization of the former evaporation pond contents if alternate disposal
of materials not exceeding aCtion levels is decided upon during remedial design. .
.
.
Paving of all unpaved areas as an extra precautionary measure.
Closure of the RCRA storage facility during the CERCLA action. All RCRA closure
requirements will be met. It is intended that formal RCRA closure will be accomplished
simultaneously through coordination with RCRA authorities.
.
The types of treatment options available for soils, sludges, and dioxin removal wastes were
limited due to restrictions on the treatment and disposal of dioxin-conwninated waste material which
cannot currently be treated or disposed at any off-site facility in the nation. An assumption was made
in the FS that an off-site incinerator would eventually be permitted to accept dioxin removal wastes.
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Meanwhile, dioxin removal wastes would be stored on-site. The remedial alternatives for soils, sludges,
and dioxin removal wastes are described below and are numbered consistently with alternatives
presented in the FS. Alternatives 2 (Institutional Controls), 3 (Off-Site Incineration), and 6 (On-Site
Incineration) were eliminated during the FS screening process and are therefore not presented here.
Each alternative description below includes a brief analysis of ARARs. In order to clarify the
ARARs analyses, two distinctions are made. First, compliance with ARARs differs for activities
conducted on~site, as opposed to activities conducted off-site. On-site, each ARAR is determined to
be either applicable (in which case all of itS requirementS are to be complied with), or relevant and
appropriate (in which case only those requirementS deemed appropriate are to be complied with). This
distinction, however, is not made for off-site activities, for which requirementS are either applicable or
not. Off-site activities contemplated under each alternative will need to comply with the Revised
Procedures for Implementing Off-Site Response Actions, OSWER Directive 9834.1 I, dated November
13, 1987 (the off-site policy). This ROD provides that for cenain off-site activities, requirementS which
are not applicable will be complied with in the interest of assuring protectiveness to human health and
the environment. These instances are noted in the text.
Second, and more specifically, ponions of RCRA have been determined to be relevant and
appropriate, but not applicable, for on-site activities. RCRA is applicable to listed or characteristic
wastes. In order to be listed, it is necessary to know the origin of a waste. However, because
documentation regarding the origin of wastes is not available, it must be assumed that the wastes are
not RCRA listed wastes. Funhermore, no waste material at the Site has been verified to be RCRA
characteristic. It is assumed in this ROD that no RCRA characteristic wastes are present at the Site.
The absence or presence of RCRA characteristic wastes will be reexamined during remedial design. If
it is determined during remedial design that the Site does contain characteristic wastes, the remedy will
be adjusted accordingly.
Thus, RCRA has been determined to be not applicable to the on-site activities. For the same
reasons, RCRA would not be expected to apply to off-site activities. However, contaminated material
found at the Site is sufficiently similar to RCRA wastes such that RCRA requirementS have been
evaluated to determine whether they are relevant and appropriate based upon the circumstances of the
releases, nature of the hazardous materials, site characteristics, and nature of the requirementS. In many
instances, the similarity between waste material found on-site and RCRA wastes, and the similarity
between actions contemplated and activities regulated under RCRA, makes cenain RCRA requirements
relevant and appropriate
Alternath'e No.1. No Action
The No Action Alternative must be evaluated for baseline comparison as pan of the Feasibility
Study process. Under the No Action Alternative, remediation goals would not be met because no
remedial action would be undenaken to treat, contain, or remove soils and sludges with contaminants
exceeding action levels. No reduction of toxicity, mobility, or volume associated with site. soils or
sludges would occur. However, dioxin removal wastes would be incinerated at an off-site incineration
facility as mandated by past removal activities (Administrative Order on Consent, In the matter of
Wasatch Lot 6, Docket No. CERCLA VIII-86~). An incineration facility permitted to accept and
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incinerate dioxins from this Site would have to be identified. No such facility is currently known to
exist.
Incineration involves the controlled combustion of organic material under conditions in which
the oxygen content in the incinerator chamber (furnace) is greater than zero. Several types of
incineration processes are available. Incineration processes, in general, achieve organics destruction
through the proper combination of retention time, turbulence, and temperature.
As noted above, RCRA would not be applicable to off-site incineration. However, the dioxin
removal wastes which would undergo incineration are similar to RCRA wastes, and the resulting
incinerated material would undergo placement during its disposal. In order to ensure the protectiveness
afforded by RCRA, the incineration of dioxin removal wastes and the subsequent disposal of the
resulting ash material would comply with RCRA LDRs. Disposal of ash would comply with the off-
site policy. During implementation of this portion of the alternative, on-site activities would comply
with OSHA health and safety requirements. RCRA requirements pertaining to pre-transportation and
transportation off-site of the dioxin removal wastes for incineration also would be met. Off-site
incineration is a component of all alternatives except Alternative 4. .
The 30-year present worth for Alternative 1 is $24,000. This includes estimated costs for
transportation and incineration of dioxin removal wastes. The time required to implement this
alternative would be dependent on the availability of.an incinerator for dioxin removal wastes.
Alternative No.4 - In-Situ Vitrification
This alternative involves staging soils exceeding action levels, sludges, and dioxin removal
wastes in the former evaporation pond and treating the staged materials using an i~-situ vitrification
(1SV) process. This is the alternative preferred by EPA and UDOH.
ISV is a thermal process which converts contaminated materials into chemically inert, stable
glass and crystalline materials. Field application requires the insertion of large electrodes into
contaminated materials containing significant levels of silicate material and the generation of heat by
passing electric current through the electrodes. At the high temperatures produced by ISV, any soils
or rock components of the staged material will melt, organic compounds will be destroyed, and many
metallic materials will either fuse or vaporize. Any gases and vapors produced are collected by placing
a hood above the affected area and are subsequently treated.
The advantages of ISV include reducing the toxicity, mobility, and volume of contaminants
throughout treatment, and producing a highly durable product with an extremely low leach rate. The
disadvantages include special equipment requirements and personnel training, the potential for soils
moisture to increase operation time and process cost, and the technology's potential to cause vaporized
contaminants to migrate away from the treatment area instead of to the surface for collection and
treatment.
A treatability test on a representative sample of soils and sludges from the Site was performed.
The ISV process, applied to site soils, resulted in significant reduction in toxicity, mobility, and volume
-------
through the destruction and vitrification of contaminants. The overall DRE for the ISV process was
determined to be in the range of 99.997 to 99.99995 percent for the organic compounds of concern,
which meets the soils aCtion levels at the Site. However, the results also indicate increased
concentrations of dioxins and furans in clean soils surrounding the melt zone. The quantities of dioxins
and furans found around the melt zone are suspected to have been created by movement of moisture,
partially saturated with PCP, into pretest soils surrounding the contaminated zone, followed by a
thermally-induced reaCtion of PCP to dioxins during ISV processing. Such dioxin formation, if
attributed to minor capillary moisture movement, would not present a concern during full-scale
operations because clean soils adjacent to contaminated materials will be vitrified in subsequent ISV
settings.
The primary concern with the implementation of ISV is the phenomenon of vapor retreat. The
possibility exists for vaporization, migration, and condensation of organic compounds away from the
ISV melt zone. This would result in increased concentrations and mobility of contaminants during and
after ISV processing. Currently, there are not enough data' available to conclusively resolve this
concern, although preliminary results from other studies suggest that contaminants were destroyed by
ISV and did not migrate into surrounding, cleaner soils. However, contaminant fate and transport are
chemical- and site-specific processes which will differ at the Wasatch Chemical Site. Site-specific
conditions, and the phenomenon of vapor retreat, will be examined with a second treatability study
during remedial design (RD).
During implementation ofISV, soils and sludges exceeding aCtion levels will be excavated and
staged in or over the former evaporation pond. Dioxin removal wastes will also be placed in the pond.
Liquid dioxin removal wastes will be solidified or otherwise immobilized prior to placement. A berm
of clean soils will be built around the material in the former evaporation pond prior to treatment.
As noted earlier, RCRA contains numerous aCtion-specific requirements which are not
applicable, but are relevant and appropriate. RCRA LDRs are imponant to Alternative 4 because of
activities involving placement of the dioxin removal wastes. Since contamination within the Site
boundaries is relatively contiguous, the entire Site is considered an area of contamination (AOC).
Consolidation of waste material in the former evaporation pond within the AOC is, by definition, not
placement. However, movement of the dioxin removal wastes to the former evaporation pond prior to
treatment is restricted because these waste materials, which contain indicator chemicals at levels
exceeding LDR treatment standards, are in a ~iscrete area and so are not included in the AOC. An
Interim Measure Waiver (JMW) to allow the temporary placement of the restriCted hazardous materials
from outside the AOC into the former evaporation pond without pretreatment, prior to re~ediation by
means of in-situ vitrification, is therefore necessary. Details of the IMW are described funher in
Section 10 (Statutory Determinations). This alternative would be in full compliance with the LDR
treatment standards listed in Table 7.1 upon completion of the remedial aCtion. The interim measure,
i.e. consolidation, would be conduCted so as not to directly cause migration of contaminants, complicate
the remedial aCtion, or present any immediate threat to human.health or the environment. Funhermore,
the interim measure would not interfere with, preclude, or delay the final remedial aCtion.
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TABLE 7.1
. RELEV~'T ~1> APPROPRIATE RCRA LDR TREATME~'T STANDARDS
COMPOUND
EQUIV ALENT
RCRA HAZARDOUS WASTE
CODE
NON WASTEWATER
TREATMENT STANDARD
msz/ke or m~fL *
Trichloroethene
U228
5.6
Tetrachloroethene
U210
5.6
H exachlorobenzene
U127
37.
Pentachlorophenol
F027
< 0.01*
Chlordane
U036
0.13
Heptachlor
P059
0.066
4,4' -Dichlorodipnenyltrichloroethane
U061
.087
4,4' -Dichlorodiphenyldichloroethane
U061
.087
4,4' -Dichlorodiphenyldichloroethene
U061
.087
2,4-Dichlorophenoxyacetic acid
U240
10
2,4,5- Trichlorophenoxyacetic acid
N/A
N/A
Dioxins and Furans
F020; F021; F022; F023
F026; F027; F028
< Ippb*
* Concentration in waste extract
NP = standard not promulgated to date
N/A = not applicable
U and P wastes are discarded commercial chemical produCtS, off-specification species, container
residues, and spill residues thereof .
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An equivalent method petition for treatment with ISV will not be necessary because LDRs
prescribe treatment concentrations, not treatment technologies, for those R.CRA wastes to which Site
contaminants are similar.
Cenain RCRA minimum technology requirements are relevant and appropriate to the extent that
migration of contaminants consolidated in the former evaporation pond must be prevented. Appropriate
measures will be taken under this alternative to ensure migration does DOt occur during implementation
of the remedy.
Any off-site disposal or treatment of filters used in the off-gas treatment or of other
contaminated materials will comply with the off-site policy. This alternative is DOt expected to generate
emissions of air contaminants and will fully comply with Federal and State air quality regulations such
as the Clean Air Act primary and secondary air quality standards and the Utah Air Conservation
regulations. Air monitoring will be performed during the remediation.
Should de-watering of the former evaporation pond contents be necessary, the resulting water
would be treated with charcoal filtration, and discharged similarly as treated ground water, as described
below.
The 30-year present worth of Alternative 4 is $3,300,000. The estimated implementation time
is six months.
Alternative No.5 - Glycolate Dechlorination and Orr-site Incineration or Dioxin Removal Wastes
This alternative reduces toxicity and mobility, and permanently treats the site materials to
provide long-term, permanent protection of human health and the environment. Under this remedial
action alternative, soils exceeding action levels, sludges, and dioxin removal wastes would be treated
on-site by glycolate dechlorination (alkaline polyethylene glycolate, or APEG process). APEG is an
innovative technology capable of achieving high DREs for chlorinated organics. The reaCtion replaces
a chlorine atom on the target molecule, forming a polyethylene glycol ether which may undergo further
dechlorination reactions. The replacement of a single chlorine on a dioxin molecule produces a
nonhazardous compound. Limited pilot-scale data on PCBs, dioxin, and dibenzofuran treatment with
the APEG process indicate that implementation of the process at the Site may be technically feasible.
A treatability study demonstrated the process to be effective in reducing the toxicity, mobility, and
volume of contaminants in soils and sludges at the Site. ACtion levels for all indicator chemicals were
attained in the treated soils and sludges with the possible exception of herbicides for which no action
levels have been established (see Table 5.2 for an explanation). The effectiveness of the APEG process
in treating herbicides is not clear as all analytical results of herbicides in treated and untreated soils were
below deteCtion limits. The DRE for dioxins was determined to be 99.96 percent.
To implement the APEG process, soils and sludges would be excavated or removed, treated in
an on-she reactor system, and returned to their original place. Although the Site is one AGC,
placement under R.CRA LDRs would occur because the waste material, which is similar to RCRA
waste, would be placed back onto the Site after treatment. However, since the effeCtiveness of APEG
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in attaining some treatment standards is questionable, a soils and debris treatability variance might be
necessary for this alternative.
The APEG process, and panicularly the off-gas treatment system, is not expected to generate
emissions of air contaminants and would fully comply with Federal and State air quality regulations such
as the Clean Air Act primary and secondary ambient air quality standards and Utah Air Conservation
regulations.
Dioxin removal wastes would first be treated on-site. Following destruction of dioxins by the
APEG process, the dioxin removal wastes would be incinerated at an off-site incineration facility to
destroy any high levels of herbicides present in the residuals and would fully meet LDR standards as
described under Alternative 1.
The 30-year present worth for Alternative S is 54,100,000. The estimated implementation time
is six months.
Alternative No.7 - Cappin~ and orr-site Incineration or Dioxin Removal Wastes
This remedial action alternative would consist of paving all unpaved areas of the Site (asphalt
pavement was assumed for cost estimates), and incinerating dioxin removal wastes at an off-site
incineration facility as described in Alternative 1. A cap would provide a low-permeability cover over
the contaminated area to prevent human/animal contact with soils, minimize airborne contamination, and
minimize infiltration of precipitation, which may contribute to contaminant migration. Construction of
the cap would be performed using conventional construction methods.
Overall protection of human health and the environment is provided under this alternative. The
cap would reduce the risk associated with soils and sludges through elimination of exposure pathways.
The alternative, as proposed, does not contemplate any activities that would trigger RCRA LDRs.
However, depending on the type of cap, the landfill requirements under RCRA might be relevant and
appropriate.
Off-site incineration, included in this alternative, would be carried out as described under
Alternative 1.
The 30-year present worth for Alternative 7 is S660,OOO. The time to implement this alternative
is one month, excluding incineration of dioxin removal wastes.
Alternative No.8 - orr-site Disposal and Orr-site Incineration or Dioxin Remova1 Wastes
Under this remedial action alternative, both soils exceeding action levels and sludges would be
disposed of at an off-site disposal facility. The dioxin removal wastes would be incinerated at an off.
site incineration facility as described for Alternative 1. Because soils exceeding soils action levels,
sludges, and dioxin removal wastes would be removed from the Site, the overall protection of human
health and the environment at the Site would be met by this alternative.
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Off-site disposal involves excavation of materials that exceed action levels and transpon of these
materials to a landfill that is licensed to accept hazardous waste materials under RCRA Subtitle C.
RequirementS of the off-site policy would be met. There is a RCRA-permitted disposal facility in Utah
that may accept hazardous materials. However, it is possible that no facility could be identified that
wo~ld accept the dioxin contaminated waste. In fact, no such facility has been identified to date.
Alternatively, excavation of soils and debris containing dioxin may require temporary storage on the
Site, pending development of an adequate disposal technology.
RCRA requirements pertaining to pre-transportation and transportation off-site of contaminated
material for disposal would be met to ensure protectiveness during that phase of the remedy.
The 30-year present worth for Alternative 8 is $1,700,000. The time to implement this
alternative is two to four months, excluding incineration of dioxin removal wastes.
GROID-."D WATER REMEDIAL ACTION
The action levels for ground water are the National Primary Drinking Water Standards, or
MCLs and proposed MCLs, set by EPA. These standards are also used for State drinking water
standards. The ground water alternatives described below are designed to meet these standards. The
action levels for indicator chemicals present in grourid water at the Site are shown in Table 5.4.
Attainment of these levels will be protective of human health and the environment.
For estimating the size and cost of ground water remediation components, it was assumed that
the volume of ground water to be remediated is approximately 20.4 million gallons, which includes the
shallow ground water beneath the Wasatch Chemical Propeny and beneath the southern ponion of the
Steelco propeny. Preliminary data suggest that the deeper ponions of the aquifer are not presently
contaminated. As described in other pans of this ROD, the ground water remedial alternatives
presented here do not address contaminated ground water underlying the nonhern ponion of the Steel co
propeny.
Each of the following ground water remedial alternatives, except the No Action Alternative,
includes, as practicable and to the extent allowable by law, and as an extra precautionary measure,
institutional controls such as deed restrictions on the use of around water, the denial of well permits.
and the acquisition of water rights. Except for the No Action Alternative, each alternative also assumes
ground water contamination sources have been controlled by reduction of toxicity, mobility, and volume
of contaminant sources in soils and sludges. Additionally, periodic ground water monitoring shall take
place in conjunction with ground water remediation. The monitoring program shall be developed during
RD, and shall be designed to monitor the effectiveness of the remedial action and the long-term
maintenance of around water action levels.
Three general ground water alternatives were evaluated in the Feasibility Study, including the
No Action Alternative. However, since the two alternatives requiring action are each further s1,1bdivided
based on two treatment options, a tQtal of five alternatives are discussed. The remedial alternatives for
ground water, and their component technologies, are described below. The primary characteristics of
the alternatives are described first and the treatment options for each alternative are described separatel)'.
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No Action (Alternative GW-J)
The No Action Alternative provides a baseline against which other alternatives can be compared.
No action would result in leaving affected ground water in the aquifer. No construction or operation
of-remedial mwures would be required.
The No Action Alternative would not meet the remediation goals for the Site. The Site would
remain at its existing level of risk. There would be no reduction in toxicity or mobility of contaminants.
Because this alternative would result in contaminants remaining in the ground water, CERCLA
would require that the Site be reviewed every five years. The 30-year present worth for Alternative
GW.l is 5130,000. The time to implement this alternative is indefinite as continual monitoring would
be required.
Ground Water Collection and Treatment with Optional Containment (Alternatives No. GW.2a and
GW-2b)
The principal objective of these alternatives is' ground water restoration. These alternatives
involve the collection of ground water, treatment, if necessary to meet POTW (Publicly-Owned
Treatment Works, or city sewer system) or UPDES (Utah Pollution Discharge Elimination System)
requirements, and subsequent discharge of the extracted ground water. Treatment would be either
(1) air stripping, or (2) advanced oxidation processes (AOP). Treatment would reduce contaminant
levels to standards which allow for discharge to the POTW or, under UPDES, to the 700 West ditch.
Contaminated ground water would be collected using a series of wells (well field) and/or
subsurface drains placed to capture plumes of affected ground water. A well.field simulation was
conducted to provide a preliminary evaluation of the number and configuration of ground water
extraction wells needed to maintain capture of affected ground water. Preliminary designs for the well
field collection system indicate that 10 wells located at l00-foot intervals along the northern and western
boundaries of the Site, extracting ground water at a rate of 2 gallons per minute (gpm), is optimal for
capture of contaminated ground water. Ground water collection would continue until performance
standards were attained.
An optional containment' structure, such as a slurry wall, may be added to these alternatives
during the Remedial Design/Remedial Action (RDIRA) phases if it is determined that a containment
or partial containment structure would enhance the efficiency of flushing and capture of the ground
water or if it becomes clear during the design or implementation phases that ground water must be
physically contained to prevent further migration of contaminants.
Ground Water Collection. Optional Containment. and Treatment with Air Strippine (Alternative
GW-2a)
Under Alternative GW-2a, extracted ground water would be treated, if it does not meet POTW
or UPDES standards, with an air stripper. Air stripping is a gas transfer process in which a liquid
-------
containing volatile solutes is brought into contact with air and an exchange of gases occurs between the
air and water containing the volatile contaminants. The process is effective for removal of VOCs from
water. Air stripping is most efficiently accomplished in a packed tower. Contaminated water is pumped
to the top of the tower and distributed uniformly across the packing. Air is forced into the base of the
tower and flows upward, contacting the water. VOCs are transferred from the water to the air and are
carried out the top of the column. Treatment of the ground water using air stripping is a well-
demonstrated and proven method for removing VOCs from extracted ground water.
Air emissions would comply with air quality ARARs such as the Clean Air Act and the Utah
Air Conservation regulations. The off-gas resulting from air stripping can be treated with catalytic
conveners or granular activated carbon (GAC), if necessary, to meet air quality standards.
Similarly, additional polishing of the treated water using GAC may be required if all
contaminants are not removed by air stripping. Activated carbon removes many organic compounds
and is very effective for many of the indicator chemicals that may not be removed from ground water
through air stripping, including chlorinated phenols, pesticides, and herbicides.
Off-site disposal of filters containing contaminants would be carried out in accordance with the
off-site policy.
This alternative provides substantial overall protection of human health and the environment
through active remediation of the shallow ponion of the aquifer. The collection of ground water and
treatment, as necessary for discharge, is an effective method of aquifer remediation and would continue
until performance standards were attained. Institutional controls described above are extra precautionary
measures to prevent use of contaminated ground water. .
The ground water extraction (with optional containment) and treatment with air stripping
contemplated under this alternative is expected to attain the action levels for the Site. This alternative
is therefore expected to meet requirements of the State and Federal Safe Drinking Water Acts, the Clean
Water Act, Utah Water Quality Standards regulations, and the RCRA Ground Water Corrective Action
Requirements.
The 3D-year present wonh of this alternative is $550,000. The estimated implementation time
is five years for substantial reduction of contaminant levels.
Ground Water Collection. ODtional Containment. and Treatment with Advanced Oxidation
Processes (AOP\ (Alternative GW-2b\
Under AJternative GW-2b, extracted ground water would be treated, if it does not meet pon'
or UPDES standards, with advanced oxidation processes. Two types of AOPs are commercially
available for ground water remediation: (1) ozone with ultraviolet (UV) radiation, and (2) hydrogen
peroxide with UV radiation: These treatment technologies are based on the addition of hydrogen
peroxide or ozone to oxidize organic compounds with UV enhancement of reactions. Previous pilot-
scale tests and treatment applications have shown that UV oxidation, using either ozone or hydrogen
peroxide, is successful for treating gro,",nd water affected with contaminants such as those found on the
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Wasatch Chemical Site. Removal levels bave been reponed to be in the 80 to 99 percent range for
VOCs. Bench-scale treatability tests are recommended to determine dosage rates, reaction times, and
expected effluent quality. Additionally, the ability to achieve discharge treatment or pretreatment
requirements can be more readily assessed with results of laboratory treatability studies.
The overall protection of human health and the environment is identical to Alternative No. 2a
(Collection and Treatment with Air Stripping). Treatment of the extracted ground water with AOP, if
necessary, is an effective process for VOC removal, and is expected to meet either discharge or
pretreatment standards.
As with Alternative 2a, this alternative would meet or exceed the action levels mentioned above.
Ground water extraction (with optional containment) and treatment with AOP would continue until
performance standards were attained.
-.
The 30-year present wonh for Alternative GW-2b is 5980,000. The estimated implementation
time is five years for substantial reduction of contaminant levels.
Ground Water Containment. Collection. and Treatment (Alternatives GW-3a and GW-3b)
The principal objective of these alternatives is containment of ground water to prevent it from
migrating funher off-site, with a secondary objeCtive being extraction and, if necessary, treatment.
These alternatives involve the containment of affected ground water by constructing a subsurface
soils-bentonite slurry wall, the collection of ground water by subsurface drains and/or a series of
extraction wells, and treatment, if necessary, of the extracted ground water with (1) air stripping or (2)
AOP, and subsequent discharge to the 700 West Ditch or POTW.
The subsurface soils-bentonite slurry wall would completely surround the characterized area of
ground water contamination adjacent to the Site extending to near the railroad tracks east of the Entrada
property and including the southern portion of the Steel co propeny (see Figure 5.2). The soils-
bentonite slurry wall would be constructed by excavating a trench using a bentonite slurry to shore the
trench during excavation. The trench would then be backfilled with a blended mixture of soils and
bentonite. A containment wall is effective for limiting ground water migration because its low
permeability severely restricts downgradient water movement and prevents widespread migration.
This containment wall adds flexibility to a pumping and collection system by providing an
additional means of controlling ground water flow. However, in some instances, full containment of a
site can inhibit flushing of the ground water, thereby inhibiting long term effectiveness by prolonging
the time necessary to achieve action levels. Soils-bentonite slurry walls are easily constructed with
conventional equipment. The site hydrogeology and topography are favorable for construction and no
difficulties are anticipated with implementation.
Ground water within the boundary of the slurry wall would be pumped and, if necessary, treated
with air stripping or AOP as described for alternatives GW-2a and GW-2b.
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Ground Water Containment. Collection. And Treatment with Air StriDpin2 (Alternative GW-3a)
Ground water within the boundary of the slurry wall would be pumped and, if necessary, treated
with air stripping as described for Alternative GW -2a. The 30-year present worth of Alternative
GW-3a is 5960,000. The estimated time for implementation is five years for substantial reduction of
contaminant levels.
Ground Water Containment. Collection. and Treatment with Advanced Oxidation Pr~esses
(Alternative GW-3b)
Ground water within the boundary of the slurry wall would be pumped and, if necessary, treated
with advanced oxidation processes as described for Alternative GW-2b. The 30-year present worth 0:"
Alternative GW-3b is 51,200,000. The estimated time for implementation is five years for substantial
reduction of contaminant levels.
8.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The alternatives identified in the FS were evaluated against the nine key criteria established in
the NCP. These criteria are:
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)"
Overall protection of human health and the environment;
Compliance with applicable or relevant and appropriate requirements;
Use of treatment to achieve a reduction in the toxicity, mobility or volume of
contaminants ;
Long-term effectiveness and permanence in protecting human health and the
environment;
Short-term effectiveness in protecting human health and the environment;
Implementability;
Cost effectiveness;
State acceptance; and
Community acceptance.
Criteria 1 and 2 are threshold criteria which must be met by the selected remedial action alternative.
Criteria 3, 4, S, 6 and 7 are balancing criteria. The fmal tWo modifying criteria are used to evaluate
the alternatives based on UDOH and local concerns.
The strengths and weaknesses of the alternatives were weighed to identify the alternative
providing the best balance among the nine criteria. A discussion of the comparative analysis of
alternatives for soils, sludges, and dioxin removal wastes is provided below, followed by a discussion
of the comparative analysis of alternatives for ground water.
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SOILS, SLVDGES, AND DIOXIN REMOVAL W ASI'ES
Overall Protection or Human Health and the Environment
All of the remedial alternatives for soils, sludges, and dioxin removal wastes, with the exception
of Alternative 1 (No Action), are protective of human health and the environment. Alternatives 4 (In
Situ Vitrification), 5 (Glycolate Dechlorination and Off-site Incineration of Dioxin Removal Wastes) and
8 (Off-site disposal and Off-site Incineration of Dioxin Removal Wastes) achieve protection by removal
and/or destruction of contaminants. Alternative 7 (Capping and Off-site incineration of Dioxin Removal
Wastes) would prevent exposure to contaminants by capping. The landfarming of soils contaminated
with xylene and toluene provides an extra measure of protection under Alternatives 4, 5 and 8 by
reducing the levels of these hydrocarbons through biological degradation and volatilization. .
Alternative 4 is the most protective of the alternatives because the site contaminants could be
permanently destroyed and rendered harmless using a single technology applied on-site. This method
will destroy dioxins and all other chemical contaminants that present a hazard to human health at the
Site, and involves minimal shon-term risks.
The APEG process in Alternative 5 also treats dioxins and most other contaminants found at the
Site, but there is some unceruinty regarding its effectiveness in the treatment of herbicides in
concentrated dioxin removal wastes. Alternative S, however, provides for the off-site incineration of
herbicide-contaminated residuals that may result from the glycolate dechlorination process. This
incineration would ensure adequate overall protectiveness.
Alternative 7 results in no reduction in contaminant volume or toxicity, except to the extent
that dioxin removal wastes would eventually be incinerated. Mobility of the contaminants would be
reduced through placement of the cap. Protectiveness would be achieved by means of consiructing a
cap which serves as a barrier between the contaminants and potential human receptors and by applying
institutional controls. Unforeseen exposure scenarios, the need to provide long-term maintenance of the
cap, and the potential for continued releases to ground water, present three sources of unceruinty in the
overall protectiveness of this alternative.
Alternative 8 would not permanently destroy contaminants, except for dioxin removal wastes
which would be incinerated off-site. Contaminated media would be removed from the Site and thus
would no longer present a risk. to the populations. currently threatened, but the contaminated media
would require long-term management at the disposal facility.
Alternatives 1, 7 and 8 rely on off-site incineration of dioxin removal wastes, which is not
currently implementable. This material would remain stored on-site for an indefinite period. Therefore,
Alternative 4 would achieve protectiveness from these hazardous materials more quicldy than Alternative
7 or 8.
The No Action Alternative would not provide any protection against the existing threat to human
health and the environment from site contaminants, except that dioxin removal wastes would be
incinerated off-site. Many of the site contaminants are very persistent in the environment, and natural
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dispersion processes will continue to increase the area affected by site contaminants for many years.
With no action, human exposure to site contaminants would continue at present levels. For these
reasons, the No Action Alternative is only briefly considered in this evaluation.
Because the soils action levels established in this ROD are bealth-based standards for industrial
use of the Site, and not unlimited use with unrestricted exposure, each remedial action aJternative will
require a five-year review under Section 121(c) of CERCLA, Section 300.430(f)(4)(ii) of the NCP, and
applicable guidance, to assure the long-term effectiveness of the remedy.
Compliance "ith Apolicable or Relevant and Appropriate Requirements (ARARs)
Applicable requirements are those cleanup standards, standards of control, and other substantive
requirements, criteria, or limitations promulgated under Federal or State law that specifically address a
hazardous substance, pollutant, contaminant, remedial action, or location, at a CERCLA site. Relevant
and appropriate requirements are similar requirements that, while not applicable, clearly address
problems or situations sufficiently similar to those encountered at a CERCLA site such that their use is
well suited to the panicular site.
All the remedial action aJternatives except Alternative 1 would comply with ARARs. Some
alternatives require interim waivers or variances in order to comply with ARARs. These instances are
described below.
Alternative 7, Capping and Off-site Incineration of Dioxin Removal Wastes, would meet all
ARARs identified in Table 10.1. Construction of the cap would meet relevant and appropriate RCRA
capping requirements. The alternative would be carried out to meet RCRA relevant and appropriate
landfill requirements. Off-site incineration of dioxin removal wastes would follow the off-site policy.
Alternative 8, Off-site Disposal and Off-site Incineration of Dioxin Removal Wastes, would
meet all ARARs identified in Table 10.1. Disposal off-site of hazardous material from the Site would
follow the off-site policy. As an added measure of protectiveness, RCRA pre-transportation and
transportation requirements would be complied with, I1though RCRA would not be applicable off-site.
Off-site incineration of dioxin removal wastes would. follow the off-site policy.
Alternative 4, In-Situ Vitrification, would meet all ARARs identified in Table 10.1, but would
require an IMW for the relevant and appropriate LDRs during staging of the waste materials prior to
treatment. Upon completion of this alternative, however, the IMW would no longer be needed, since
LDR requirements would be met. Relevant and appropriate RCRA minimum technology requirements
would be met during staging to prevent contaminant mi&ration prior to treatment. This alternative will
fully comply with Federal and State air quality regulations such as the Clean Air Act primary and
secondary air quality standards and the Utah Air Conservation regulations. Off-site disposal of any
filters used in this alternative would follow the off-site policy. Discharge of water resulting from de-
watering the fonner evaporation pond would meet UPDES or POTW requirements.
.Alternative 5, Glycolate Dechlorination and Off-site Incineration of Dioxin Removal Wastes,
would meet all ARARs identified in Table 10.1, but a soils and debris treatability variance might be
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needed to comply with relevant and appropriate LDRs. This alternative would fully comply with
Federal and State air quality regulations such as the Clean Air Act primary and secondary air quality
standards and the Utah Air Conservation regulations. Off-site incineration of dioxin removal wastes
would foJlow the off-site policy.
The landfarming ponion of Alternatives 4, S and 8 would comply with ARARs listed in Table
10.1. RCRA LDRs would not be relevant and appropriate because the landfarming would take place.
within one AOC. ARARs related to land ueatment are also discussed in Sections 7 and 9 of this ROD.
An evaluation of all Federal and State ARARs is provided in Table 10.1.
Lon2-Term Effectiveness and Permanence
Long term effectiveness and permanence refers to an alternative's ability to . maintain reliable
protection of human health and the environment over time. Thts criterion includes the consideration of
residual risk and the adequacy and reliability of conuols.
AJl of the remedial action alternatives for soils, sludges, and dioxin removal wastes, with the
exception .of Alternatives 1 and 7, result in minimal residual risk. Alternatives 4 and S have the greatest
degree of effectiveness and permanence because both result in a permanent reduction in risk through
destruction of contaminantS. Alternative 4 is slightly more effective in the long term than Alternative
S, since the glycolate dechlorination process would result in slightly higher residual levels of
contamination after processing.
Alternative 8 representS a permanent remedy for dioxin removal wastes but not for other
hazardous materials, since these materials would require long-term management at an off-site disposal
facility. However, removal of these materials from the Site would result in the same permanent
reduction in risk to on- and off-site workers and off-site residentS that would be achieved by Alternatives
4 and S.
Landfarming conducted under Alternatives 4, S and t would reduce risk .associated with
hydrocarbon contaminated soils by permanently reducing contaminant levels through biological
degradation and volatilization. This action adds to the long-term effectiveness and permanence of these
alternatives. .
No permanent reduction in risk would be achieved by Alternative 7. The degree of long-term
effectiveness of the capping alternative would depend upon the long-term maintenance of the cap and
on the effectiveness of institutional controls. In addition, since contaminated soils and sludges would
continue to be potential sources of ground water contamination, the capping alternative would require
long-term management of ground water.
Because the soils action levels established in this ROD are health-based standards for industrial
use of the Site, and not unlimited use with unrestricted exposure, each remedial action alternative will
require a five-year review under Section 121(c) ofCERCLA, Section 300.430(t)(4)(ii) of the NCP, and
applicable guidance, to assure the long-term effectiveness of the remedy. However, once it is
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determined that ISV treatment in Alternative 4 has resulted in attaining health-based action levels for
unlimited use, there will be no need for continued monitoring of the non-hazardous vitrified material.
Reduction or Toxicity. Mobilitv. or Volume Throu2h Treatment
Congress has expressed a preference under CERCLA, as amended by SARA, for selecting
remedial actions that employ tteatment technologies that permanently and significantly reduce toxicity,
mobility, or volume of hazardous substances as their principal element.
The ISV, APEG process, and off-site disposal/incineration alternatives (Alternatives 4, S, and
8) would greatly reduce toxicity, mobility, and volume of soils and sludges exceeding action levels at
the Site. Only under Alternatives 4 and S would the reductions in toxicity through tteatment extend to
contaminated site media other than the dioxin removal wastes and hydrocarbon contaminated soils to be
land farmed. In the case of Alternative 4, which best meets this criterion, ISV tteatability studies using
site media have demonstrated that destruction and .removal efficiencies in the range of 99.997 percent
to 99.99995 percent can be achieved for all site contaminants, including dioxins. In the case of APEG,
used in Alternative S, a destruction and removal efficiency of 99.96 percent for dioxin was obtained
during treatability testing on soils and sludges. Substantial reductions in the levels of other highly
chlorinated compounds, such as pesticides, were also observed during APEG tteatability testing. The
effectiveness of glycolate dechlorination in treating some herbicides has not been confirmed, and
treatment of material with high concentrations of herbicides might require off-site incineration. Because
Alternative 8, off-site disposal, does not employ treatment for soils and sludges, except for land
treatment of hydrocarbon contaminated soils, the statutory preference for treatment as a principal
element is not fully addressed.
Alternative 7 would reduce the mobility of contaminants in the soils by minimizing surface
water infiltration, but would not reduce toxicity or volume. Alternative 1 would not reduce the toxicity,
mobility, and volume of contaminants in the soils and sludges.
Under all of the alternatives, the dioxin removal wastes would be treated to permanently reduce
their toxicity. This would occur by destruction through pyrolysis (thermal decomposition) in the case
of Alternative 4, through chemical reaction in the case of Alternative S, and through off-site incineration
under the remaining alternatives. The glycolate dechlorination treatment of the dioxin removal waste
under Alternative S might result in residual levels of herbicides following treatment. These residuals
would be incinerated. Any residual volatile contaminants collected in the volatile emission control
systems provided under Alternatives 4 and S would be disposed of off-site at a RCRA treatment~
storage, or disposal facility.
Short-Term Errectiveness
Short-term effectiveness refers to the period of time needed to complete the remedy, and any
adverse impacts on human health and the environment that may be posed during the construction and
implementation of the remedy.
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Alternative 7 involves the least significant short-term impactS. AJternative 4 presents the next
lowest risk during implementation. AJternative 5 poses funher complications due to increased handling
of contaminated media, and Alternative 8 has the greatest short-term impactS because it involves the
transport of all media contaminated above action levels.
.'
Alternatives 7 and 8 would require the least amount of time to implement, one month and two
to four months, respectively. These alternatives, however, require incineration of material containing
dioxin, which is not currently implementable. It is not known when this incineration could take place,
since no incinerators are currently permitted to accept this type of hazardous material. AJternatives 4
and 5 are expected to require six months for implementation. Implementation of the landfarming
component of Alternatives 4, 5 and 8 is expected to require three months for completion.
None of the alternatives is without short-term impactS. However, AJternative 7, which involves
capping of unpaved areas, would probably involve the least significant short-term impactS. Under this
alternative, short-term impacts would be limited to exposure of workers to dust, and direct contact with
soils from earthmoving activities in preparing the Site for capping. Alternatives 1,5, and 7 require off-
site transport of dioxin removal waste for incineration and Alternative 8 requires off-site transport of all
contaminated media above action levels. Although the probability of traffic accidents and spills
associated with off-site transport is small, such incidents could potentially involve a large population and
unknown environmental risks.
Alternatives 4, S,and 8 all require excavation of the same volume of soils and would result in
an increased level of risk to workers from potential exposure to . dust and direct contact with
contaminants .
. Alternatives 4 and 5 involve short-term risks related to the construction and implementation of
the treatment process. Most of these risks would impact only workers involved in the remedial action.
The active site operations would be discontinued by the time remedial action is implemented, so only
trained remedial action workers would be at risk during the action. Short-term risks from handling the
contaminated media prior to treatment would be somewhat greater for the APEG process because the
method requires crushing material larger than 4 inches in diameter prior to processing in the batch
reactor. The crushing process may generate fugitive dust, requiring dust control measures. In addition,
excavation and transport of contaminated soils for Alternatives 4, 5 and 8 (including those soils to be
landfarmed) may cause some of the volatile contaminants to be released to the air. Appropriate
protective clothing will be worn and air monitorinl performed to reduce exposures to workers.
In addition, Alternatives 4 and S employ innovative technologies which have. not been widely
used at full scale to remediate sites. However, both processes have been fully tested at pilot scale. For
both processes, volatile emissions would be captured in a hood and the effluent air stream would be
scrubbed by activated carbon filters. Ambient air and the treatment system exhaust would be monitored
to verify that unacceptable levels of particulates and volatile contaminants are not released to the
atmosphere. .
The former evaporation pond contents would be dewatered by pumping prior to removal or
treatment under Alternatives 4, 5 and 8. Prior to discharge to the sewer or to the 700 West ditch, the
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,.
water removed from the former evaporation pond would be treated, if necessary, to meet UPDES or
POTW standards.
ImDlementabilitv
Implementability refers to the technical and administrative feasibility of a remedy, including
the availabil ity of materials and services needed to implement the chosen remedy.
Alternative 4, although using an innovative technology, is the most readily implemented overall.
As mentioned above, the implementation of this alternative would require an IMW of LDRs in order to
place the dioxin removal wastes into the former evaporation pond prior to treatment. Alternative 5
might r'equire a soils and debris treatability variance due to the uncenainty in its treating some
contaminants. Off-site incineration of treated residuals of dioxin removal wastes from the APEG
process of Alternative 5 should be more easily implemented than off-site incineration proposed as part
of Alternatives 7 and 8 since concentrations of dioxin and other hazardous constituents in the dioxin
removal wastes will be greatly reduced by APEG. Although Alternatives 4 and 5 involve iMovative
technologies that are not yet in full scale commercial produCtion, the vendors of both technologies have
indicated that their equipment and services will be available when needed, if seleCted.
Alternatives 7 and 8 are the most technically feasible because they rely on simple earthmoving
and construction technologies. However, both alternatives may encounter difficulty in administrative
implementation due to lack of a permined off-site incinerator to accept the dioxin removal wastes.
The administrative and technical aspects of landfarming hydrocarbon contaminated soils are not
expected to affect the implementability of Alternatives 4, 5 and 8.
~
This criterion evaluates capital, operation and maintenance costs of each alternative, and
compares costs among similarly protective remedies.
Cost estimates for each of the alternatives are based on information provided by vendors or on
published standard construCtion coSt data, and are expeCted to be accurate within a range of -30 percent
to + 50 percent. Since this is a wide range, it is likely that aCtUal costs will differ from estimates. A
10 percent ,discount rate was applied to future expenditures to enable comparison of present value. The
present value of an alternative's cost is the amount of money that would have to be allocated today in
order to pay the costs of the alternative for its duration. Two types of costs are calculated: capital
costs, and annual operation and maintenance costs. Cost summaries for each alternative, including
capital wonh, are shown in Table 8.1.
Of the alternatives requiring aCtion, Alternative 7, at S660,OOO, has the lowest present wonh
cost. Alternative 8, which like Alternative 7 does not involve treatment of soils, sludges and debris
(except for that portion of soils to be landfarmed), has a present wonh cost of $ 1,700,000. The two
alternatives requiring treatment of all contaminated soils, sludges, and dioxin removal wastes,
Alternatives 4 and 5, have present wonh costs of $3,300,000 and $4,100,000, respectively.
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'ABLE 8.1
005' SUlWtY
SOil AID ~S'E .~IAl Al'EIIA'IVES
AIt-tive 110. 1 AIt~mBtive .0. 4 Alt~mBtive .0. 5 AIt_tive 110. 7 AIt_tive 110. 8
Crit~ria 110 Actian .... Off- In-Situ GI\'Colate r:.ppi ng end Of f - Off-.ite Disposel
site Inci~ratiana Vi tr if icat ian DKhtorinatian sit~ Inci~.tian end Off-sit~
Inci~atian
Capital S24,OOO S3, 300,000 S4,100,ooo 1656,000 SI,700,ooo
b -0- -0- -0- S805.
o&M (y~arly) -0-
Pr~s~t Worth S24,OOO S3,3OO,OOO S4,1oo,Ooo S660, 000 SI,700,ooo
GIt(UI) ..n. IEREDIAl AlnllATiVES
Alt_tlve GU-1 Alt_tive OY-Za Alt-tive GU-Zb Alternative GU-]a \. AIt_tive GtI-]b
Crlt~ia 110 Actlan CoIIKtlan end CotlKtian end .. Shrry ...1 I Shrry ...1 I
Air Stripping Canteir8ft1t. CotlKtlan. tantai_t. tollKtlan.
end Air Stripping end ..
Capitat -0- S26O,OOO 1420,000 1690,000 S840,ooo
b S14,OOO S33,OOO S59,OOO SZ9, 000 49,000
o&M (~arty)
Pr~s~t Worth S 130 ,000 S550,OOO S980,OOO S9'60,OOO S1,Zoo,ooo
8
Cost shown Is for off-slt~ Inci~ration.
evatuat ion.
The cost does not include 8 public health evaluation, which NY be r~lred ~very 5 ~ars at S31,Ooo per
b
Duration of o&M costs is 30 years.
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State Acceptance
UDOH and EP A agree on Alternative 4 as the preferred alternative for remediation of soils,
sludges, and dioxin removal wastes. Both agencies have panicipated in the development of the proposed
plan and the ROD.
Communitv Acceotance
Community input on the alternatives for remedial action at the Wasatch Chemical Site was
solicited by EPA and UDOH during the public comment period from October 9, 1990 to November
8, 1990. Comments received from the community indicate no opposition to the preferred alternative,
although several questions regarding its implementation were raised. Responses to community comments
are found in the attached responsiveness summary.
GROUND WATER
Overall Protection or Human Health and the Environment
With the exception of Alternative 1 (No Action), all of the ground water alternatives are
protective of human health and the environment. The four ground water alternatives (GW-2a,
GW-2b, GW-3a and GW-3b) differ primarily in the anticipated rate at which ground water would be
remediated and in terms of shon-term risks. The emphasis of Alternatives GW-2a and GW-2b is on
complete remediation in the minimum amount oftime, while the emphasis of Alternatives GW-3a and
GW-3b is on containment rather than treatment. The installation of a slurry wall in Alternatives
GW-3a and GW-3b involves shon-term risks that would not be present under Alternatives GW-2a and
GW -2b, and. may decrease the effectiveness of the collection system by limiting the rate of ground
water collection, thereby slowing the ultimate cleanup of ground water.
GW-I, the No Action Alternative, does not provide adequate overall protectiveness of human
health and the environment and would result in continued dispersion of contaminated ground water and
expansion of the ground water contamination area. Alternative GW -I is therefore not considered further
in this evaluation.
Compliance "ith Aoolicable or Relevant and Approoriate Requirements (ARARs) .
Alternatives GW-2a, GW-2b, GW-3a and GW-3b would all equally comply with Federal and
State ARARS. Action levels (Table 5.4) for contaminants are Federal and State Safe Drinking Water
Act MCLs or proposed MCLs. Discharge of air pollutants for any of the alternatives would comply
with State Best Available Control Technology (BACT) standards to assure protectiveness. Discharge
of treated water to the 700 West ditch or to the POTW through the sewer system would comply with
UPDES or POTW standards.
An evaluation of Federal and State ARARs for ground water alternatives is found in Table
10.1.
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Lone-Term Effectiveness and Permanence
Alternatives GW-2a, GW-2b, GW-3a and GW-3b would all offer a high degree of permanence
in the reduCtion of risk associated with ground water if combined with Alternatives 4, S or 8 for soils,
sludges, and dioxin removal wastes because the combination of these alternatives would clean up ground
water and remove contaminant sources. However, if source areas are not remediated, as would be the
case under Alternative 7 for soils, sludges, and dioxin removal wastes, none of the ground water
alternatives could be considered permanent remedies.
The long-term effectiveness of Alternatives GW-2a and GW-2b is better than that of Alternatives
GW-3a and GW-3b because of the possible degradation of the slurry wall in Alternatives GW-3a and
GW-3b through time and subsequent migration of contaminants.
Remedial actions conducted under all four alternativ~ would require five-year reviews and
periodic monitoring to assure the long-term effectiveness of these remedies.
Reduction or Toxicitv. Mobilitv. or Volume Throueh Treatment
Alternatives GW-2a, GW-2b, GW-3a, and GW-3b would all result in reduction of toxicity,
mobility and volume of contaminants in ground water through tteatment. Alternatives GW -2a and
GW-2b would remove a larger volume of affected ground water more rapidly than Alternatives
GW-3a and GW-3b, thereby reducing toxicity and volume more quickJy. The slurry wall in
Alternatives GW-3a and GW-3b would more effeCtively reduce mobility of contaminants.
Short-Term Effectiveness
Alternatives GW -2a and GW -2b rank higher in shon-term effectiveness than Alternatives
GW-3a and GW-3b. Alternatives GW-2a and GW-2b would achieve cleanup more rapidly because
greater volumes of water can be extraCted in the absence of the slurry wall. Shon-term effects
associated with Alternatives GW-3a and GW-3b may result from construction of the slurry wall trench,
particularly if contaminated media are exposed during the excavation and problems with emissions of
fugitive dust and. volatile organic compounds ensue. Other shon-term problems associated with
Alternatives GW-3a and GW-3b are expeCted to be related to operation of construCtion equipment.
Since slurry wall construction is optional (but not likely) for Alternatives GW-2a and GW-2b, much less
construction aCtivity is anticipated for them than for Alternatives GW-3a and GW-3b.
Imolementabilitv
All ground water alternatives, along with their component treatment options, would be
implementable at the Site. Materials and services for any of alternatives are readily available. In
particular, Alternatives GW-2a and GW-3a rely on proven technology for treatment of contaminated
ground water. Alternatives GW-2b and GW-3b, however, are less favorable from a technical
implementability standpoint because advanced oxidation processes are iMovative and require a
treatability study demonstrating their effectiveness.
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Installation of a slurry wall under Alternatives GW-3a or GW-3b would r~uire obtaining access
agreements with adjacent propeny owners. Similarly, access agreements would be r~uired for
insullations of extraction and monitoring wells off the Wasatch Chemical propeny under all of the
alternatives. Obtaining access agreements may cause delays in implementation, but is unlikely to.
prevent it.
Institutional controls are generally difficult to implement. Controls relating to ground water are
expected to be particularly difficult, for administrative reasons. It should be noted, however, that
institutional controls are not relied upon as part of the remedy, but are used as extra precautionary
measures.
QW
Cost estimates for ground water alternatives were calculated in the same manner as those for
soils, sludges, and dioxin removal wastes alternatives. Costs are shown in Table 8.1.
Excluding the No Action Alternative, Alternative GW-2a bas lowest present wonh cost,
5550,000. The other three alternatives in order of increasing present worth costs are GW-3a at
5960,000, GW-2b at 5980,000, and GW-3b at 51.2 million. Tbe low cost of Alternative GW-2a
relative to the other alternatives is primarily attributable to two factors: (1) advanced oxidation processes
for ground water treatment are much more expensive than the air stripping used in GW -2a; and (2) that
alternative does not include the cost of a slurry wall. .
Stale AcceDtance
UDOH and EP A agree on Alternative GW -2a as the preferred alternative for ground water
remediation. As stated above, both agencies have participated in the development of the proposed
plan and ROD.
Communitv AcceDtance
As noted earlier, the public comment period for the Wasatch ChemiCal proposed plan was held
from October 9, 1990 to November 8, 1990. The public was invited to comment on all ground water
alternatives during that period. Based on the comments received, the community has no opposition to
the preferred alternative. Some questions regarding the extent and implementation of the ground water
remedial action were raised, however. Responses to community comments are found in the anached
responsiveness summary.
9.
SELECTED REMEDY
After consideration of the statutory r~uirements of CERCLA, the detailed analysis of the
alternatives, and public comments, EPA and UDOH have determined that the most appropriate remedy
for the Site is ISV treatment of soils, sludges, and dioxin removal wastes and landfarming of
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hydrocarbon contaminated soils (Alternative 4), and collection and, to the extent necessary to meet
discharge standards, treatment by air stripping, of contaminated ground water (Alternative GW-2a).
REMEDY FOR SOILS, SLUDGES, AND DIOXIN REMOVAL WASTES
Alternative 4 for the remediation of soils, sJudges, and dioxin removal wastes will involve
consolidation of soils and sludges contaminated above soils action Jevels and dioxin removal wastes into
the former evaporation pond, and vitrification of the former evaporation pond and its contents.
Certain actions will be taken as part of the remedy to ensure compliance with RCRA, some of
whose requirements are relevant and appropriate, as shown in Table 10.1. In particular, appropriate
measures will be taken, such as the instaJlation of an impermeable liner, to satisfy the relevant and
appropriate ponions of RCRA minimum technology requirements. These measures will be taken to
prevent any migration of contaminants out of the evaporation pond to the adjacent subsurface soils or
ground water or surface water from the time the former evaporation pond is uncovered, during
consolidation of contaminated materials in the pond, and until vitrification has been completed. Toward
the same end, liquid dioxin removal wastes will be solidified prior to placement in the former
evaporation pond to counter its mobile nature.
In addition, if it is determined during remedial design that excess water within the former
evaporation pond must be removed to facilitate treatment by ISV, the water will be extraCted and treated
by filtering it with granular activated carbon to remove contaminants, as necessary to meet POTW or
UPDES standards, and will be subsequently discharged to the sewer system or the 700 West ditch. The
spent carbon will be vitrified, regenerated, or appropriately disposed of in compliance with the off-site
policy.
After preparation of the materials to be treated, a layer of clean soils will be placed over the
material within the former evaporation pond and the entire pile will be vitrified. Vitrification will meet
the performance standards specified in this section. An off-aas collection hood will be placed over the
area being vitrified to colleCt emissions. Air emissions from the ISV process will be monitored to
ensure that air quality ARARs are met. It is estimated that vitrification will require approximately six
months to complete.
A treatability test was conducted to verify ISV's effectiveness in treating contaminants found in
soils. A second treatability test will be conducted on the dioxin removal wastes during RD to verify
ISV's effectiveness on this type of hazardous material which contains contaminants at levels higher than
soils. In addition, this treatability test will examine whether vapor retreat occurs during vitrification of
the contaminants found at this Site. This test will be conducted, and its results evaluated, prior to
implementing ISV at the Site.
Soils contaminated with toluene and xylene will be excavated from an area between the Chlorine
Building and the Warehouse Building. A bermed area will be prepared on the asphalt pavement west
of the Warehouse Building where the excavated soils will be spread and remediated by aeration and
enhanced biodegradation over a period of approximately three months. This landfarming will meet
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relevant and appropriate RCRA SWMU and land treatment requirements. Air monitoring will be
conducted to ensure'that air quality ARARs are met.
As an extra precautionary measure, all unpaved areas of the Site will be paved to prevent future
occupants' direct exposure and ingestion of residual contaminants that may remain in soils on-site. As
an extra precautionary measure, institutional controls such as deed restrictions will be used to prevent
the Site from being used for non-industrial purposes and to maintain access restrictions. Agreements
to implement these controls will be made by EPA, UDOH, and the PRPs during RDIRA negotiations.
These controls will remain in place for a period of time to be determined during RD, depending upon,
among other factors, practicability and the extent allowable by law, This period of time may later be
modified based on the effectiveness of the remedy.
REMEDY FOR GROm.1> WATER
Alternative OW -2a, for remediation of contaminated ground water, will use extraction wells
and/or trenches to capture and extract ground water contaminated at concentrations above MCLs and
proposed MCLs. The extracted ground water will be treated using air stripping, to the extent necessary,
to meet UPDES requirements for discharge to the 700 'Yest ditch or POTW requirements for discharge
to the sewer system. Carbon adsorption will be used if necessary to remove contaminants not.removed
by air stripping. Monitoring of treatment effluent streams, both air and water, will be conducted.
Carbon adsorption treatment of the air emissions will be used, if necessary, to ensure air quality
requirements are met. The remedial design will specify the appropriate number and location of wells
and system parameters such as flow rates for the ground water collection and treatment system.
As an extra precautionary measure, institutional controls such as deed restrictions, denial of well
permits, or acquisition of water rights will be implemented as practicable and to the extent allowable by
law to prevent the use of contaminated ground water. Agreements to implement these controls will be
made by EPA, UDOH, and the PRPs during RDIRA negotiations to ensure that the controls are
implemented. These controls will remain in place for a period of time to be determined during RD,
depending upon, among other factors, practicability and the extent allowable by law. This period of
time may later be modified based on the effectiveness of the remedy,
COST OF THE REMEDY
Table 9.1 shows the detailed cost summary for Alternative 4, while Table 9.2 shows the same
for Alternative GW-2a. These two alternatives together comprise the selected remedy with a total
estimated cost of 53.9 million. Some changes may be made to the remedy as a result of the remedial
design and construction processes. For example, the amount of soils and sludges to be treated will
depend on verification sampling, and the extent of the ground water extraction system will depend on
aquifer testing and ground water sampling.
REMEDIAL ACTION OBJECTIVES
The objectives of this remedial action are to control present and future risks posed by direct
contact with and ingestion of soils, sludges, and ground water; to control the migration of contaminants
-------
TABLE 9.1
COST SUMMARY FOR ALTERNATIVE 4
Iwn
Direct Capital CostS
In-Situ Vitrification'"
Asphalt Cap Installation
Land Farming
Suppon and Services
Total Direct Capital Cost
Indirect Capital Costs
Contractor Permits, Insurance, Performance Bond
(3 percent of Direct Capital Costs)
Engineering and Design (5% of Direct Capital Costs)
Contingency (15% of Direct Capital CostS)
Total Indirect Capital Costs
TOTAL COST OF ALTERNATIVE 4 (IN-SITU VITRIFICATI01'l)
(II
~
S 2,334,369
244,000
81,000
~
S 2,719,869
S 81,596
135,993
407.980
625,569
$ 3,345,438
In addition to in-situ vitrification treatment, this cost includes stan-up, eanhwork, health and
-------
TABLE 9.2
COST SUMMARY FOR ALTERNATIVE GW-2a
Iwn
Direct Capital Costs
Ground Water Collection
Treatment by Air Stripping
Total Direct Capital Costs
Indirect Capital Costs
Contractor Permits, Insurance, Performance Bonds
(3 % of Direct Capital Costs)
Engineering and Design (5% of Direct Capital Costs)
Contingency (15 % of Direct Capital Costs)
Total Indirect Capital Costs
Estimated Annual Operation and Maintenance
Present Worth of Annual Operation and Maintenance Costs
(10% Discount Rate)
TOTAL COSTS OF ALTERNATIVE GW-2A
~
S 125,657
~
S 214,719
S 6,442
10,736
JUm
S 49,385
$ 32,700
$ 287,659
-------
from soils and sludges to ground water; and to prevent future human exposure to residual contamination
in soils and dioxin removal wastes. The objectives will be met by attaining remedial action goals.
REMEDIATION GOALS AND PERFORMANCE STANDARDS FOR SOILS, SLUDGES, AND
DIOXIN REMOVAL WASTES
For soils, sludges, and dioxin removal wastes, the remedial goal is treatment so that the level
of contaminants remaining in these materials poses no unacceptable risk to human health or the
environment. Since no Federal or State chemical-specific ARARs exist for soils and sludges, action
levels were determined for indicator chemicals through a site-specific risk analysis. Because the
location, characteristics, and use of the Site make its future use for residences unlikely, action levels to
be met by the remedial action for soils, sludges, and dioxin removal wastes will result in 10"
carcinogenic risk for an industrial use scenario and a 10.5 for a residential use scenario.
Specific performance standards, used to ensure attainment of the remedial goal for these
materials, are:
1.
Stage, for treatment, all soils, sludges, and dioxin removal wastes within the Site
containing indicator chemicals at levels in excess of the soils action levels listed in Table
5.2;
2.
Vitrify all staged soils and sludges so that the levels of contaminants remaining in the
vitrified soils and sludges do not exceed the soils action levels listed in Table 5.2, and
vitrify all staged dioxin removal wastes so that the levels of contaminants remaining in
the vitrified dioxin removal wastes do not exceed the LDR treatment standards listed in
Table 7.1; and
Meet all other ARARs identified in this ROD for the remediation of soils, sludges, and
dioxin removal wastes.
3.
The ISV process will destroy or remove from 99.997 to 99.99995 percent of all organic
contaminants of concern considered together, and, in particular, is expected to destroy or remove
99.9999 percent of dioxins. These destruction and removal efficiencies are sufficient to lower the
concentrations of site contaminants to below action levels for soils, and therefore below the risk levels
described above.
The dioxin removal wastes, which are subject to the relevant and appropriate LDRs because
they will undergo placement, will be treated to the LDR treatment standards listed in Table 7.1.
An additional area of soils contaminated with toluene and xylene, approximately 7,500 feet
square and 4 feet deep, will be excavated, land fanned on-site, and returned to the excavation after
treatment. The area containing these soils lies between the Chlorine Building and Warebouse. Since
these petroleum hydrocarbons are non-carcinogenic and their soils concentrations are below health-
based levels, no action levels have been established for them. However, action levels will be established
during remedial design so that the boundaries of material to be treated can be defined. Land farming
will be performed to meet these action levels. This remedial action will be an extra measure of
pro~ection at the Site.
-------
Sampling will be performed during remedial action to verify that all material contaminated
above soils action levels is being treated. Additional contaminated material will be moved to the
treatment areas prior to the start of vitrification or land farming, as necessary, until attainment of soils
action levels and protectiveness of human health and the environment are ensured. This sampling
program shall be developed during remedial design.
REMEDIATION GOALS AND PERFORMANCE STANDARDS FOR GROUND WATER
Remediation goals for ground water are: (1) restoring the contaminated ground water to its
potential future uses, (2). protecting uncontaminated ground water by minimizing the migration of
contamirtants within the ground water, and (3) ensuring that the level of contaminants remaining in
ground water poses no unacceptable risk to human health and the environment. Since UDOH and EP A
consider the ground water at the Site to be a potential future source of drinking water, specific action
levels for ground water are MCLs and proposed MCLs as estaltlished by the Safe Drinking Water Act.
Attainment of these action levels will be protective of human health and the environment and will restore
the ground water to potential beneficial uses.
Specific performance standards, used tQ ensure attainment of the remediation goals for ground
water, are: .
I.
Reduce contaminant levels in ground water (within the area of attainment) to MCLs and
proposed MCLs (action levels) for all contaminants for which MCLs and proposed
MCLs exist, including those MCLs and proposed MCLs listed in Table 5.4;
Within the first five years of ground water remedial action, reduce, by at least 50
percent, the levels of contaminants found in ground water, as compared to the levels
found at the time ground water remedial action begins;
2.
3.
Meet all other ARARs identified in this ROD for the remediation of ground water; and
The area of attainment is currently the Wasatch Chemical propeny and the southern
ponion of the Steelco propeny.
4.
The ground water ponion of the remedy for the Site, however, is subject to possible future
modification because cenain ponions of ground water remain uncharacterized. The ground water
ponion of the remedy is final for contaminated ground water underlying the Wasatch Chemical propeny
and the southern ponion of the Steel co propeny. However, contaminated ground water underlying the
nonhern ponion of the Steelco propenyhas not been fully characterized. No remedy will be finalized
for the contaminated ground water underlying the nonhern ponion of the Steelco propeny until it has
been adequately characterized. Funher investigations and subsequent remedial decisions regarding
ground water beneath the nonhern ponion of the Steelco propeny may necessitate future modification
of the ground water remedy for the Wasatch Chemical propeny and the southern ponion of the Steel co
propeny, or other remedial action.
Ground water will be. extracted until action levels are achieved. It should be recognized,
however, that EP A studies have indicated that it may not always be possible to reach MCLs or proposed
MCLs through currently available technology. If it becomes apparent during implementation or
-------
operation of the ground water extraction system that contaminant levels bave ceased to decline and are
remaining constant at levels bigher than those set out in the performance standards, the system's
performance standards and the remedy may be reevaluated by EPA and UDOH.
Performance of the ground water remedy will be carefully monitored on a regular basis and
adjusted as warranted by the performance data collected during operation. The operating system may
include discontinuing operation of extraction wells in areas where performance standards bave been
attained, alternate pumping of the wells to eliminate stagnation points, pulse pumping to allow aquifer
equilibration and encourage adsorbed contaminants to partition into ground water for extraction and
treatment, and installation of additional extraction wells to facilitate or accelerate cleanup of the
contaminant plume.
COMPLIANCE SAMPLING PROGRAM
A sampling program for monitoring the remedial action and determinina compliance with the
performance standards shall be implemented during the remedial action. In addition, to ensure that
ground water performance standards are maintained, it is expected that ground water will be monitored
at least twice annually during the ground water seasonal high and low for a period of at least 3 years
following discontinuation of ground water extraction. ' These monitoring programs will be developed
during RD and shall include, at a minimum, the following: analytical parameters (focusing on indicator
chemicals, but analyzing other contaminants, if any, that are not indicator chemicals and are determined
to be occurring at levels exceeding MCLs or proposed MCLs), sampling points, sampling frequency and
duration, and statistical methods for evaluating data. Specific performance monitoring points shaH be
specified during remedial design.
Because the soils action levels established in this ROD are health-based standards for industrial
use of the Site, and not unlimited use with unrestricted exposure, and because the ground water remedy
may leave residual hazardous substances above action levels (MCLs or proposed MCLs), ruling out
unlimited use of on-site ground water, the selected remedy will require a five-year review under Section
121(c) of CERCLA, Section 300.430(t)(4)(ii) of the NCP, and appl'icable guidance, to assure the long-
term effectiveness of the remedy. However, once the effectiveness of the ISV ponion of the remedy
in anaining health-based action levels for unlimited use is confirmed, there will be no need for continued
monitoring of the non-hazardous vitrified material.
10.
STATVTORY DETERMINATIONS FOR TIlE SELECTED REMEDY
The selected remedy meets the statutory requirements of Section 121 of CERCLA. The statute
requires that remedial action undenaken at Superfund sites be protective of human health and the
environment. The statute also mandates that the selected remedy comply with applicable or relevant and
appropriate environmental standards established under Federal and State environmental laws unless a
statutory waiver is justified. In addition, the selected remedy must be cost-effective and utilize
permanent solutions and alternativ'e treatment technologies or resource recovery technologies to the
maximum extent practicable. The statute also includes a preference for remedies that employ treatment
that permanently and significantly reduces the volume, toxicity, or mobility of hazardous substances as
-------
their principal element. The following sections describe how the selected remedy meets these statutory
requirements .
PROTECTION OF HUMAN REALm AND THE ENVIRONMENT
The remedy selected for soils, sludges, and dioxin removal wastes at the Wasatch Chemical
Site protects human health and the environment by treating these materials with ISV to destroy and
immobilize contaminants. Contaminants levels in these materials will be reduced to, or below, health-
based action levels following treatment. Reduction of contaminants to these clean up levels will reduce
the carcinogenic risk to 10" given continued industrial use of the Site. This level of risk falls within
EPA's acceptable risk range of 10-' to 10", Following the remedial action for soils, sludges, and dioxin
removal wastes, the hazard index for non-carcinogens will be less than one.
As extra precautionary measures, deed restrictions on future use of the site, access control
measures, and capping will all act to minimize human exposure to any residual contaminants.
The remedy selected for ground water at the Wasatch Chemical Site protects human health and
the environment by reducing the levels of contaminants found in the shallow ponions of the aquifer
underlying the Site to MCLs and proposed MCLs. In addition, the ~tracted ground water will be
treated with air stripping to the extent necessary to meet the appropriate standards prior to discharge,
as further explained below in the ARARs discussion. Restoration of ground water to MCLs and
proposed MCLs w.ilI ensure that ground water at the Site will comply with the Safe Drinking Water Act,
thereby providing protectiveness in the case of ingestion of or contact with the water, Although the
shallow ground water at the Site is not currently being used as a drinking water source, attainment of
MCLs or proposed MCLs for contaminants of concern will assure that Site risks from this potential
pathway fall within the EPA acceptable risk range. As extra precautionary measures, institutional
controls will be applied as practicable and to the extent allowed by law. Deed restrictions on ground
water use, denial of well permits, and acquisition of ground water rights would reduce the possibility
of human exposure to contaminated ground water.
Of the alternatives evaluated for cleaning up soils, sludges, dioxin removal wastes, and ground
water, the selected remedy provides the best protection of human health without significant adverse
impact to the environment. No unacceptable shon-term risles or cross-media impacts will be caused by
implementing this remedy.
COMPLIANCE WIm APPLICABLE OR RELEVANT AND APPROPRIA TE REQUIREME~'TS
Under Section 121(d)(l) of CERCLA, remedial actions must attain standards, requirements,
limitations, or criteria that are "applicable or relevant and appropriate" under the circumstances of the
release at a site. All ARARs would be met upon completion of the selected remedy at the Wasatch
Chemical Site.
Federal ARARs control unless State standards are more stringent than Federal requirements.
If, however, the Federal program under RCRA, the Clean Water Act, the Clear Air Act, and the Safe
Drinking Water Act, has been delegated to, and administered by UDOH, then State ARARs control.
-------
Those Federal requirements which have not yet been adopted by the State under a delegated program
control for purposes of determining ARARs for the site. Federal and State ARARs and to-be-
considered (TBC) items for the selected remedy are listed in Table 10.1.
Chemical-Spednc ARARs
The selected remedy will comply with chemical-specific ARARs related to ground water and
ambient air quality at the site.
The principal chemical-specific ARARs for the remedy are primary drinking water standards
established by the Safe Drinking Water Act (and adopted under Utah law), which are relevant and
appropriate. MCLs have been designated for some contaminants at the Site. MCLs have been proposed
for other contaminants. Proposed MCLs are "to be considered" (TBC) and will also be complied with.
Concentrations of contaminants in ground water will be reduced to MCLs and proposed MCLs through
implementation of the ground water extraction and treatment system.
Utah Ground Water Protection Regulation requirements will be met through source control.
Ground water treatment and landfarming are likely to produce air emissions. Controls will be
implemented as required to ensure compliance with national ambient air quality standards (NAAQS),
new source performance standards (NSPS), and national emissions standards for hazardous air pollutants
(NESHAPs), all of which are relevant and appropriate.
Action-Specinc ARARs
The selected remedy will comply with action-specific ARARs, primarily RCRA, the Utah
Pollutant Discharge Elimination System (UPDES), Utah air quality requirements, and pretreatment
standards for POTWs.
RCRA has been determined not to be applicable to the remedial action. However, RCRA
requirements have been evaluated to determine whether they are relevant and appropriate based upon
the circumstances of the releases, nature of the hazardous materials, site characteristics, and nature of
the requirements.
LDRs are relevant and appropriate requirements under RCRA because, as part of the selected
remedy, hazardous materials similar to RCRA listed wastes will be consolidated in a manner that falls
within the RCRA definition of "placement." As described earlier, these dioxin removal wastes are
found in a discrete area and therefore are not considered part of the AOC that includes all contamination
at the site. Since consolidation of the dioxin removal wastes in the former evaporation pond prior to
treatment will not meet the LDR treatment standards prior to placement, the treatment requirement is
being temporarily waived using an IMW, granted through the signing of this ROD. The IMW is being
used because placement of these materials will be followed by treatment with ISV. This remediation
process will anain soils and debris variance treatability standards and the more stringent LDR treatment
standards (a treatability study conducted with contaminated soils demonstrated the ability of ISV
technology to attain both standards; the same results are expected for the dioxin removal wastes and will
-------
CIT A TION
TABLE 10.1
FEDERAL AND STATE ARARS AND FEDERAL, STATE, AND LOCAL TBCS
Ch...mical SpKilic ARAR'Ii (Federal)
DF.5CRIPTION
40 CFR Part 141
40 CFR Part 143
40 CFR 141.50
40 CFR Part 131
(Quality Criteria
for Water, 1916,
1980, 1986)
40 CFR Part 129
40 CFR Part 264
40 CFR Part 61
40 CFR Part 50
40 CFR Part 60
Establishes health-based standards for puhlic
drinking water systems (maximum contaminant
levels (MCU»
E.-;tablishes welfare-based standards for puhlic
water systems (secondary maximum contaminant
levels)
Establishes drinking water quality goals set at
levels of no known or anticipated adverse health
effects, with an adequate margin of safety
(maximum contaminant level goals (MCLGs»
E.-;tablishes criteria for ambient water quality
based on toxicity to aquatic organisms and
human health
E.-;tablishes effluent standards or prohibitions for
certain toxic pollutants: aldrin, dieldrin, DOT,
endrin, toxaphene, benzidine and PCBs.
E.-;tablishes maximum chemical concentrations
that can be released from solid waste
management units (Subpart F)
Establishes national emission standards for
hazardous air pollutants (NESHAPs)
National primary and secondary Ambient Air
Quality Standards (NAAQS)
NSPS
EVALUATION
Relevant and appropriate since the shallow portion of the aquifer beneath the.
Site is a potential drinking water source. MCLs are action levels for ground
water remediation. Proposed MCLs are to be considered.
Relevant and appropriate since the shallow portion of the aquifer beneath the
Site is a potential drinking water source.
Relevant and appropriate for contaminants of concern with an MCLG
greater than zero.
Relevant and appropriate since the shallow portion of the aquifer is a
potential drinking water source.
Applicable with regard to the discharge of ground water or surface
water runoff into the 100 West Ditch.
ReleVant and appropriate to the land fanning activities and to the former
evaporation pond. .
Relevant and appropriate to the construction, modification, installation,
or operation of air emission sources resulting from remedial activities.
Relevant and appropriate to temporary air pollution sources constructed at
the Site during remedial action.
Relevant and appropriate since temporary air pollution sources will be
-------
CITATION
TABLE 10.1 (CONTINUED)
FEDERAL AND STATE ARARS AND FEDERAL, STATE, AND LOCAL TBCS
DESCRIPTION
Chm1ical SPKifi~ ARARs (State)
U.A.C. R450-IOI-1
et sc.!l.
U.A.C. R448-2-1
et seq.
U.A.C. R448~-1
et seq.
U.A.C. R446-1-3
U.A.C. R446-1-3.1.8
U.A.C. R446-I-4.9
U.A.C. R446-I-4.12
U.A.C. R446~-1
lJ.A.C. R449-IOJ-1
ct ~l'~I.
Corrective action clean-up standards for
RCRA, UST and CERCLA sites.
Standards for quality for water of the State
Ground-water quality protection
Natural ambient air quality standards
(NAAQs)
Use of best available control technology
(BACT) for air emission sources.
New Source Performance Standards
(NSPS)
National Emission Standards for
Hazardous Air Pollutants (NESHAPs)
De minimis emissions
Drinking water ami sanitation rules
EVALUATION
The suhstantive provisions of the clean-up policy are
applicahle to the selected remedy. The rule specifies
minimum standards for clean-up (e.g. MCLs and ACLs) or
other standards 1..0; determined. Clean-up standards evaluation
criteria include numerical, technology-based, or risk-based .
standards or a combination.
Applicahle for any discharge or surface water run-off into the
700 West Ditch.
To the extent the preferred remedial alternative involves the
construction, modification, installation, or operations of a
new or existing facility which discharges or would probahly
result in a discharge of pollutants into the ground water, then
the regulations would be applicahle.
Relevant and appropriate to temporary air pollution sources
constructed at the Site during remedial action.
Unless otherwise exempt by regulation (e.g., de minimus
emissions from air strippers and soil venting projects,
R446-6-1 ~.), this rule is applicable to air emission sources
which are constructed or in.o;talled at the Site in conjunction with
the treatment of soils and ground water.
This rule is relevant and appropriate to the temporary or
permanent air pollution sources to be constructed at the Site
in conjunction with the treatment of soils and ground water.
Relevant and appropriate to the construction, modification,
installation, or operation of air emission sources resulting from'
remedial activities. .
Exempts .de minimis. emissions from air-strippers or land farms
used to clean soil or water contaminated with hydrocarhons.
Relevant and appropriate since the shallow portion of the aquifer
beneath the Site is a potential drinking water source. MCLs arc
action levels for ground water remediation. Proposed MCI_o; are
-------
CITATION
TABLE 10.1 (CONfiNUED)
FEDERAL AND STATE ARARS AND FEDERAL, STATE, AND WCAL TBCS
DF.sCRIPTION
Action Spt't"ilic ARARc; (Federal)
40 CFR Part 122-125
40 CFR Part 403
40 CFR Part 60
40 CFR Part 251
40 CFR Part 262
40 CFR Part 264
40 CFR Part 264,
Subpart F
40 CFR Part 264,
SubpartG
Nationai Pollutant Discharge Elimination
System (NPDES). Requires permits for
the discharge of pollutants from any point
source into waters of the United States.
Establishes standards to control pollutants
that pass through or interfere with
treatment proce.c;ses in publicly-owned
treatment works or that may impact
sewage sludge
Establishes emission standards for new air
emission sources
Establishe.c; criteria for use in determining
which solid waste disposal facilities and
practices pose a reasonable probability of
adverse effects on human health or the
environment and thereby constitute
prohibited open disposa sites
Establishes standards for generators of
hazardous waste
Establishes minimum national standards
that define the acceptable management of
hazardous waste for owners and operators
of facilities which treat, store, or dispose
hazardous waste
Releases from Solid Wa.c;te Management
Units
Closure and post closure of SWMUs or
TSOs
EVALUATION
All requirements are applicable to discharge of ground water or
surface runoff into the 700 West Ditch.
Applicable to discharge of ground water to the sewer system.
Relevant and appropriate to air pollution sources which will be
constructed in conjunction with the treatment of soils and ground
water.
Relevant and appropriate to land farming activities and the former
evaporation pond.
Relevant and appropriate for hazardous wastes which are similar in
chemical composition to RCRA hazardous wa.c;tes will be generated
by excavation or consolidation during remedial activities.
Some requirements are relevant and appropriate for treatment,
storage, or disposal of
waste material similar to RCRA waste.
Relevant and appropriate to land farming activities and the former
evaporation pond.
Relevant and appropriate to land farming activities and the former
-------
TABLE 10.1 (CONTINUED)
FEDF.RAL AND STATE ARARS AND FEDERAL, STATE, AND LOCAL TBCS
CITATION
DESCRIPTION
Adinn SDft"inc ARAR~ 'Federal) - cnntinuf'd
40 CFR Part 264,
Suhpart I
40 CFR Part 264,
Suhpart L
Use and management of containers
Wa.c;te pile.c;
40 CFR Part 264,
Suhpart M
40 CFR Part 264,
Suhpart N
Land treatment
Landfills
40 CFR Part 268
Establishes a timetahle for restriction of
land disposal of hanned wastes
29 CFR Part 1910
Regulates worker health and safety
Adion Spedfic ARARs 'State)
Utah Code Ann.
A 13-3-25
Standards for drilling and ahandonment of
wells. including such requirements as
performance standards for casing joints
and requirements for ahandoning wells
Utah Occupational Safety and Health
Standards. Regulates worker health and
safety.
Utah Code Ann.
fifi 35-9-1
EVALUATION
Relevant and appropriate in the use of containers or drums to store
hazardous substances similar to RCRA hazardous wa.c;te.c;.
Relevant and appropriate to ISV and land fanning.
Relevant and appropriate since the selected remedy involves
land treatment (land farming) of contaminated soils.
Relevant and appropriate to ISV, particularly for minimum
technical requirements during consolidation of wastes in the former
evaporation pond. Not applicable or relevant and appropriate to
land farming activities.
Relevant and appropriate for placing dioxin removal wastes
into the former evaporation pond. An interim measure waiver
will he granted to allow the remedial action to proceed. Also
relevant and appropriate to the treatment of dioxin removal wastes
in the former evaporation pond. Treated dioxin removal wastes
must meet BOAT staAdards for similar RCRA wastes.
Health and safety requirements are applicable to all remedial
actions.
These provisions are applicahle to any licensed well driller
who is hired to drill wells at the Site.
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CITATION
TARLE 10.1 (CONTINUED)
FEDERAL AND STATE ARARS AND FEDERAL, STATE, AND WCAL TBCS
DFSCRIPTION
Action SPKinc ARAR~ (Stale) - Conlinuf'CI
Utah Code Ann.
fifi 26-14-1 et seq.
U.A.C. R450-5-1
et seq.
U.A.C. R450-7-S
el seq.; R450-S-1 ~.
U.A.C. R450-7-13;
R450-S~
U.A.C. R45O-7-14;
R450-S-7
U.A.C. R4So-7-16;
R4So-S-9
U.A.C. R4S0-7-20;
R450-S-13
U.A.C. R4S0-7-2t;
R450-S-14
U.A.C. R450-7-23
through 25
Solid and Hazardous Waste Act. The Act
e5tablishes a regulatory scheme de...igned
to facilitate the promulgation and
implementation of substantive
requirements.
Establishe5 standards for generators of
. hazardous waste
Establishes standards that define acceptable
management of hazardous waste for
owners or operators of facilities which
treat, store, or dispose of hazardous waste
Ground water protection and monitoring at
solid waste management units
Closure and post-closure requirements for
TSDs or SWMUs
Use and management of containers to
store hazardous waste
Land treatment requirements
Landfill requirements
Interim status requirements for thermal
treatment; chemical, physical. and
biological treatment; and underground
in.jectinn
EVALUATION
This Act provides authority for promulgating rules under R450
specified in this Tahle.
To the extent that RCRA hazardous wastes or hazardous
substances sufficiently similar to RCRA hazardous wastes are
generated during remedial activities, these rules would be
applicahle relevant and appropriate.
Relevant and appropriate for treatment, storage, or disposal of
waste material similar to RCRA waste.
Relevant and appropriate to land farming activities and the former
evaporation pond.
Relevant and appropriate to land farming activities and the former
evaporation pond.
Relevant and appropriate in the use of containers or drums to store
hazardous substances similar to RCRA hazardous wastes.
Relevant and appropriate since the .selected remedy involves land
treatment (land farming) of contaminated soils.
Relevant and appropriate to ISV, particularly for minimum
technical requirements during consolidation of wastes in the former
evaporation pond. Not applicable or relevant and appropriate to
land farming activities.
Since the selected remedy involves thermal treatment of hazardous
substance... sufficiently similar to RCRA hazardous wastes, these
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CITATION
TARLE 10.1 (CONTINUED)
FEDERAL AND STATE ARARS AND FEDERAL, STATE, AND LOCAL TOCS
DESCRIPTION
Action Sp«inc ARAR~ (State) - Continut'd
U.A.C. R450-13-1
et seq.
Utah Code Ann.
U 26-11-1 et seq.
U.A.C. R448-3-t
~.
U .A.C. R448-8-1
et seq.
U.A.C. R448-8-8
Utah Code Ann.
fifi 26-13-1 ~.
U.A.C. R446-I-4. t
U.A.C. R446-1-4.5
U.A.C. R 446-1-5.1
Rules regarding restrictions on land
disposal of hanned waste
Water Pollution Control Act. The Act
e5tablishes a regulatory scheme designed
to facilitate the promulgation and
implementation of suhstantive
requirements.
Sewers and wastewater treatment works
Utah Pollution Discharge Elimination
System (UPDES)
Pretreatment Standards for publicly-owned
treatment facilities
Utah Air Con~ervation Act. The Act
establishes a regulatory scheme designed
to facilitate the promulgation and
implementation of suhstantive requirements
Visible emissions
Fugitive dust emissions
Temporary closure of air pollution sources
in the event (If an air pollution emergency
episode
EVALUATION
Relevant and appropriate for placing dioxin removal wastes into
the former evaporation pond. An interim measure waiver will be
granted to allow the remedial action to proceed. Also relevant and
appropriate to the treatment of dioxin removal wastes in the
furmer evaporation pond. Treated dioxin removal wastes must
meet 8DA T standards for similar RCRA wastes.
The statute is applicable to the extent that it contains
suhstantive provisions.
This rule is applicable to the construction of the ground water
treatment facility which would be part of the selected remedy.
These rules would be applicable to the discharge of any waste
water into the 700 West Ditch.
These rules would be applicable to the discharge of any waste
water into the sewer system which sends its water to a
POTW.
This act provides authority for promulgating rules under R446
specified in this table.
To the extent that implementation of the selected remedy
involves the construction, modification, installation, or
operation of an air emission source, the rules would be
applicable.
To the extent that implementation of the selected remedy
involves fugitive dust emissions the rules would be applicable.
To the extent that implementation of the selected remedy
involves the construction, modification, installation, or
operation of an air emission source, the rules would be
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CITATION
-...
TARLE 10.1 (CONTINUEO)
FEOERAL AND STATE ARARS AND FEDERAL, STATE, AND WCAL TRCS
Action Spt't"ific ARARs (State) - Continul'd
DF.5CRIPTION
EVALUATION
Title 37 Revised
Ordinances of Salt lake
City
Location-Specific ARARs
None identified
Tc.-8e-Considerl'd
40 CFR Part 141
40 CFR Part 141.50
Wa.4;tewater control ordinance rules and
regulations for direct and indirect
contrihutions to the POlW wastewater
system, permit issuance and general
requirements
All requirements of these local rules are applicahle if any
extracted ground water is discharged to the sewer system.
Proposed MCLs
Proposed MCLt; for contaminants found in ground water are to he
considered.
MClGs equal to zero
MClGsequal to zero for contaminants found in ground water are
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be verified through an additional treatability study using these materials). The IMW will not cause
additional migration of contaminants, complicate the site response, present an immediate threat to public
health or the environment, or interfere with or delay the final remedy.
The material resulting from the ISV treatment is not expected to be hazardous or require
maintenance.
Relevant and appropriate RCRA requirements also prescribe that material consolidated in the
former evaporation pond for treatment will not migrate out of that pond. Specific measures will be
taken, such as installation of an impermeable liner in the pond prior to consolidation, to prevent the
migration of contaminants placed there. This alternative will fully comply with Federal and State air
quality regulations such as the Clean Air Act primary and secondary air quality standards and the Utah
Air Conservation regulations through treatment of ISV off-gas.. Off-site disposal of any filters used in
this alternative will comply with the off-site policy. Discharge ,of water resulting from any de-watering
of the former evaporation pond will meet UPDES or POTW requirements.
In addition, the RCRA storage facility closure will occur during the CERCLA action. All
RCRA closure requirementS will be met and it is intended that formal RCRA closure will be
accomplished simultaneously through coordination with RCRA authorities.
The ground water ponion of the remedy will comply with MCLs and proposed MCLs by
extracting ground water contaminated above these levels. Discharge of treated water to the 700 West
ditch or to the POTW through the sewer system will comply with UPDES or POTW standards. Air
releases from ground water treatment will comply with ARARs through the use of filters and treatment
of the air effluent stream, to the extent necessary.
Location-Specific ARARs
No location-specific ARARs have been identified.
To Be Considered (TBCs)
While not ARARs, TBCs should be considered with regard to remediation. Proposed MCLs,
which in contrast to final MCLs have not been promulgated, are TBCs. Proposed MCLs will be
complied with, as they are included in the ground water aCtion levels.
COST-EFFECTIVENESS
The selected remedy is cost effective in mitigating the risks posed at the site by contaminated
soils, sludges, dioxin removal wastes, and ground water. Section 300.430(f)(ii)(D) of the NCP states
that once a remedial action satisfies the threshold criteria set forth in Section 300.430(f)(1)(ii)(A) and
(B) (Le., overall protection of hum.an health and the environment and compliance with ARARs), cost-
effectiveness is determined by evaluating three of the five balancing criteria noted in Section
300. 430(f)(1 )(i)(B) to. determine overall effectiveness: long-term effectiveness and permanence,
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.
reduction of toxicity, mobility, or volume through tr~tment, and shon-term effectiveness. Overall
effectiveness is then compared to cost to ensure that the remedy is cost-effective.
The selected remedy for soils, sludges, dioxin removal wastes, and hydrocarbon contaminated
soils provides the best overall effectiveness of all alternatives considered proponional to its cost. The
selected remedy will gr~tly reduce the toxicity, mobility, and volume of soils exceeding target cleanup
goals, sludges containing hazardous material, and the dioxin removal wastes. Also, the implementation
of this remedy will result in long-term effectiveness by reducing residual carcinogenic risks to I
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.
difficult. While Alternatives 4 and S treat contaminated materials, Alternative 4 has been demonstrated
to meet treatment standards for all site contaminants, while Alternative S has not.
\
Alternatives 4 and S also best meet the long-term effectiveness criteria because they destroy
contaminants. Implementability, the third critical evaluation criterion, is a tradeoff with regard to
Alternatives 4 and S because they are both iMovative technologies. Treatability studies were therefore
conducted for these technologies, with encouraging results. Alternatives 7 and 8 on the other hand, are
easily implementable but fall shon will regard to treaanent and long-term effectiveness.
GROUND WATER
For the alternatives for remediating ground water, the more critical evaluation criteria were
protection of human health and the environment and implementability.
Since ground water at the site is a resource that needs'to be protected for potential future use,
its restoration, rather than simply containment of contaminants, is preferable. Alternative GW-2a is
better suited for remediation than Alternatives GW-3a and GW-3b which rely more heavily on
containment with a slurry wall. Implementability is better with regard to Alternative GW-2a because
the other alternatives rely on iMovative technologies for which no treatability studies were conducted
during the RIIFS, or rely on a slurry wall that may be difficult to maintain over a long period of time.
UDOH and EP A are in agreement with regard to the remedial alternative selected for soils,
sludges, dioxin removal wastes, and ground water for the Wasatch Chemical Site. The community was
invited to comment on the selected alternatives, as well as all other .alternatives. No opposition to
Alternatives 4 and GW-2a (which comprise the selected remedy) was voiced.
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
The selected alternatives for remediation of contaminated soils, sludges, dioxin removal wastes
and ground water satisfy the staNtory preference for remedies that employ treatment as a principal
element. By treating contaminated soils, sludges, and dioxin removal wastes through ISV, the selected
remedy addresses one of the principal threatS posed by the site - contaminants found in these materials -
- through the use of treatment technologies. Additionally, ground water will be extraCted until water
remaining in the aquifer meets MCLs and proposed MCLs for contaminants found in eround water.
ExtraCted ground water will be treated to the extent necessary with air stripping to reduce contaminants
in the extraCted water to levels acceptable for discharge to a POTW or the 700 West Ditch. .
Therefore, the statutory preference for remedies that employ treatment as a principal element is
satisfied .
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RESPONSIVENESS SUMMARY
W ASA TCH CHEMICAL SITE
SALT LAKE CITY, UTAH
TABLE OF CONTENTS
INTRODUCTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... . . . .
COMME~7S OF ENTRADA INDUSTRIES, INC. ...........................
OVERALL. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
REGULATORY. . . . . . . . . . . . . . . . . . . . . . : . . . . . . . . . . . . . . . . . . . . .
PROPOSED PLAN. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
HAZARD RANKING SYSTEM SCORING. . . . . . . . . . . . . . . . . . . . . . . . . . .
ADMIKISTRA TIVE RECORD. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
COMMEt-.7S OF GALSON REMEDIATION CORPORATION (GRC) ..............
APEG PROCESS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
OFFICIAL TRANSCRIPT COMMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
COMMEKTS OF MR. FRED FIFE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
COM\IE~7S OF MR. PETE SUAZO. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
ATIACHME~T A
COMMUNITY RELATIONS ACTIVrnES AT THE WASATCH
CHEMICAL SITE
"t
Ew
1
2
2
2
4
8
10
14
14
15
15
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.'
RESPONSIVENESS SUMMARY
WASATCH CHEMICAL SITE
I~JRODUCTION
Sections 113(k)(2)(B)(i-v) and 117 of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) require that the U.S. Environmental Protection Agency
(EPA) and the State of Utah Depanment of Health (UDOH) keep the community informed and
encourage them to panicipate in the decision-making process in selecting a remedy for a Superfund
site. At a minimum, the legislation requires (1) notice to potentially affected persons and the public,
(2) a reasonable opponunity to comment, (3) an opponunity for public bearing, (4) a response to
each significant category of comment submitted, and (5) a statement of the basis and purpose of the
selected action.
This section describes the specific community panicipation activities that occurred in the
process of selecting a remedy for the Wasatch Chemical site (milestone dates are listed in Attachment
A) and contains an abbreviated version of this community relations process. These activities exceed
the minimum requirements, indicating a commitment by EPA and UDOH to meet both the letter of
the law and the spirit of community panicipation at this site. This responsiveness summary fulfills
one of the key public panicipation requirements of CERCLA by incorporating a response to each
comment submitted by the public. The foJlowing paragraphs are a chronology of the community
relations activities from 1986 through the present.
In 1986, a community relations profiJe was completed. Two press releases were issued in
March 1986 on chemical wastes removed from the site and dioxin found on the site. A fact sheet
was issued in May 1986. Press briefings were held in Ma)' and June 1986. A press release was
issued in July of that year. The mailing list was updated during the summer. A briefing for Salt
Lake City and County elected officials was held in September regarding treatment of dioxin.
. A press release for proposed National Priorities List (NPL) inclusion was issued in January
1987. A notice was published on relocation for the interim storage facility in July 1987, and a fact
sheet update on the site was released in November of that year.
In April 1988, a press release and fact sheet announcing the begiMing of Remedial
Investigation/Feasibility Study (R]/FS) work were issued. Interviews were conducted in the summer.
Another fact sheet was issued in October of that year. Information repositories at the Chapman
Branch Library, Cannon Health Buiiding, and EPA Superfund Records Center in Denver were
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I'
Comment 2.
Response.
Comment 3.
Response.
COMMENTS OF ENI'RADA INDUSTRIES, INC.
Record of Decision (ROD). Movement of waste from the dioxin storage area into
the former evaporation pond does constitute placement of waste, because the waste is
similar to a Resource Conservation and Recovery Act (RCRA) bazardous waste and
the storage area constitutes a discrete area. Thus land disposal requirements (LDRs)
under the RCRA Section 3004(k) are relevant and appropriate to the movement of the
dioxin removal wastes.
The movement of soils exceeding soil target cleanup levels, sludges, and the dioxin-
removal wastes in the dioxin storage facUity from the sire iNO the former evaporation
pond. and subsequent rreatmeN of these materials in the former pond, constitutes
consolidation rather than placementofmateriais within a single ..1Oe, and therefore
the land disposal restrictions are 1U!ither applicable nor relevaN and appropriate.
EP A and UDOH agree that movement of soils and sludges into the former
evaporation pond constitutes consolidation, rather than placement, of materials within
a single AOC. Therefore, with respect to those media, LDRs would be neither
applicable nor relevant and appropriate requirements. However, as stated in the
response to Comment I above, the movement of dioxin removal wastes from the
dioxin storage area into the former evaporation pond constitutes placement, and
therefore land disposal of those materials. Since the bazardous wastes to be
remediated are similar in chemical composition to RCRA hazardous wastes, LDRs
would be relevant and appropriate requirements with respect to those materials.
In the event. however, movement of soils exceeding soil target cleanup levels, sludges.
and the dioxin-removal wastes in the dioxin storage facility is legally determined to
constitute placement rather than consolidarion, the Record of Decision should provide
for an Interim Measure Waiver to allow for the placement of these materials into the
former evaporarion pond, withoUt pretreatment, prior to remediation by means of ill:
Jim vitrificarion.
EP A and UDOH have determined that movement of soils and sludges on-site for
purposes of implementing the remedy is not subject to LDR requirements because the
site constitutes a single AOC. However, movement of dioxin removal wastes from
the dioxin storage area into the former evaporation pond constitutes placement and
therefore land disposal. This ROD provides for an Interim Measures Waiver to
allow the placement of dioxin removal wastes into the former evaporation pond.
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Delistin2
"
COMMEr-.7S OF D-IRADA INDUSTRIES, INC.
Delisting of the residual material from the in:WY vitrification process is DOt required under'
state hazardous waste regulations.
Comment 4.
Response.
Comment 5.
Response.
Under Seerion R45O-2.1.2(d) oftM Utah Administrarive Code, lUswning soil and
debris ar tM Site are RCRA listed htJ:Ardous ~es or htJ:Ardous subStances
sufficiently similar to RCRA listed htJ:Ardous ~es to begin with, tMy would cease
to be hazardous wastes after iIJ=mM vilrificarion because tM glassy resid~ will
contain no deteCtable quantities of organic IwArdous co~nts and will not ahibit
any hazardous charaCteristics. This provision identifies delisting lU an alternative
way 10 exclude a material from hazardous wasie Status, not tM exclusive way.
Accordingly, it will nOI be necessary to delist tM soil and debris at tM sile.
The contaminantS in soil and debris at the Wasatch Chemical site are not considered
RCRA listed hazardous substances to begin with. Therefore, the soil and debris at
the site will not have to be delisted. .
If the slate and EPA determine thar tM iIJ=mM vilrificarion residUDl must be delisted in
order 10 remain in place, tMn a delisting petition pursuant to 40 CFR 1260.22 and
Utah Administrative code R45O-2-7 should be approved or granted prior to
implemenration of this remedial alternative. Entrada believes, however, the bener
alternative is to recognize tM state regularion as the controlling ARAR. and provide
in Ihe record of decision thaI if tM iIJ=mM vitrification residual lesls non-hazardous.
then the residual shall no longer be considered to be either a RCRA hazardous waste
or a hazardous substance sufficiently similar to a RCRA hazardous waste.
See response to comment 4.
PROPOSED PLAN
Comment 6.
Although Entrada acknowledges thar funMr tnveStigarion and subsequent remedial
decisions concerning ground warer beneath tM Steeleo properry may require
modification of the proposed ground water remedial alternative ar the Wasatch
Chemical site. Enrrada does nor agree thar tM Remedial Design should include
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,
Response.
Comment 7.
Response.
COMMENTS OF ENTRADA INDUSTRIES, INC.
further investigation of the ground water beneath the Steelco properry beyond the area
of remJ!diation proposed in the FiTUJl Feasibility Study Report and Proposed Plan.
The current EP A and UDOH position is that the Jfound water ponion of the remedy
.. for the Site, is subject to possible modification because certain ponions of ,round
water remain uncharacterized. The Jfound water ponion of the remedy is final for
contaminated ground water underlyini the Wasatch Chemical property and the
southern ponion of the Steelco property. However, contaminated ifound water
underlying the northern ponion of the Steelco property has not been fully
characterized. No remedy wiJI be finalized for the contaminated Jfound water
underlying the northern ponion of the Steelco propeny until it bas been adequately
characterized. Further investigations and subsequent remedial decisions regarding
ground water beneath the northern ponion of the Steelco property may necessitate
future modification of the ground water remedy for the Wasatch Chemical propeny
and the southern ponion of the Steelco property, or other remedial action.
Pesticide, herbicide, and fertilizer formulation, blending and/or packaging was not
relocated to the 700 West site until approximarely 1972. 1he Proposed Plan provides
a brief description of historical operations at the site. In particular, the Proposed
Plan, at page 3, seems to imply that pesticides, herbicides, and fertilizers were
. .
formulated. blended and/or packaged at the site between 1969 and 1978. Entrada
disagrees with an)' notion that formulation, blending, and/or packaging of pesticides.
herbicides or fertilizers took place prior to 1972. 1he Administrative Record,
together with the voluminous documents produced in discovery in the subject
litigation, support the proposition that pesticides, herbicides, and fertilizers were not
formulated. blended and/or packaged at the site unti/1972-1973.
The information on the hist.orical activities at the site was extracted directly from the
final RJ and FS repons. These repons state that the Mountain Fuel Supply Company
consolidated and relocated Wasatch Chemical's operations from another site to the
700 West site in 1968. The RJ/FS repons further state that after relocation in 1968
and until June 1978, Wasatch Chemical formulated, blended, and/or packaged various
chemical produCtS at the property including pesticides, herbicides, fenilizers,
industrial chemicals, and cleaners~
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Corrvnenr 8.
Response.
~
COMMENTS OF ENTRADA INDUSTRIES, INC.
,
The sire does 1IOt pose any presenl or future risk to drinking water supplies in the Salt
Lake Valley. Nor does the sire pose either a preseru or realiStic future risk to the
deep confined drinking water aquifer. heseruly, the difference in hydraulic head
berween the shallow unconfined aquifer and the deep confined aquifer, together with
the sepQTation of the aquifer I1y a relatively impermeable day layer, prn'tnl the wazer
of the shallow Imconfined aquifer from truering the deep confined aquifer beneazh the
site. In theory, the presenl upward gradienl at the site could be rn'trsed in the
furure by massive valley-wide pumping of the deep confined drinking wazer aquifer
and some conrami1Ul1ion could n't1ltUQJly permeaze the stparating clay layer. Thus.
with prudenr managemeru of the deep confined.aquifer IInder aisting water rights and
water quality laws and regulazions, proteCtion 'of the deep confined aquifer is fully
assured.
EPA and UDOH disagree with Entrada's position regarding future risk to drinking
water supplies. The agencies' view is that there is a single aquifer in the valley
consisting of deep and shallow ponions and that it is essential to protect both ponions
of this aquifer. The clay layer referred to in the comment is not a true .confining
layer" because there is communication betWeen the upper and lower ponions of the
aquifer. Studies at the nearby Vitro site have demonstrated that, contrary to earlier
assenions that the deeper ponion of the aquifer could not be contaminated because of
the presence of a confining layer in combination with an upward aradient, substantial
contamination of the principal water supply had occurred. Therefore, this type of
confining layer is one through which contaminants can and do migrate, which means
that there is real potential for degradation of drinking water supplies in the deep
ponion of the aquifer. .
The comment notes that in theory the present upward gradient at the site could be
reversed by massive pumping and some contamination could eventually reach the
drinking water aquifer. In fact, the Wasatch Chemical Endangerment Assessment
. acknowledges that water levels in wens near the site dropped when a large municipal
water well was installed to the south. Because of increased demand on ground water,
Salt Lake City had to lower the pumps in at least five of its public water supply wells
in 1989. This increase in demand and resulting reduction of anesian pressure
demonstrates the potential for localized drawdoWD from the shallow ponion of the
aquifer to the deeper ponion. Therefore, EPA and UDOH believe that contaminants
at the' site do pose a potential future risk to drinking water supplies.
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#
Comment 9.
Response.
Comment 10.
Response.
Commenr 11.
COMME~7S OF E~A INDUSTRIES, INC.
The shallow unconfined aquifer benearh the site is neither a present 1IOr a realistic
future source 01 drinking water. The shallow unconfined aquifer throughour the Salt
Lake Valley is generally 1IOt used as a source 01 drinldng water because 01 Its low
yield. poor quality, continuing susceptibility to biological and chemical
contamination, and the availability 01 better quality and more reliable supplies.
EPA and UDOH disagree with Entrada's assertion regarding the shallow ponion of
the aquifer. Water quality in the shallow ponion of the aquifer is highly variable,
with some localized areas being suitable for drinking water purposes. Although the
water contained in the shallow pomonof the aquifer at the site may not be currently
used as a source of drinking water, its potential future use as such cannot be
discounted. While the ground water remains contaminated, it cannot be used for
drinking water or other potential beneficial use. Therefore, it is imponant to
implement the selected remedy in order to restore potential beneficial uses.
However, if it should become necessary to use the shallow unconfined aquifer as a
source of drinking warer, the ground Water flowing under the site could be used by
treating it ;n the same way that warer in other ponions of the shilliow unconfined
aquifer would have to be rreated or blended to ",. It suiuible for drinking. If
necessary. ground warer flowing under the site could also be inrercepted before it
reaches the site. For the reasons articulared above, and more particularly stared in
the Final Endangerment Assessment Reponfor the Wasarch Chemical site, the
shallow unconfined aquifer immediately benearh the site is not a realistic source of
drinking water.
EP A and UDOH believe that the ground water remedy should be implemented as
soon as possible in order to restore the water to potential beneficial use rather than to
delay treatment until it becomes necessary to use the water. Contaminated ground
water at the site, if not remediated, may migrate and affect presently uncontaminated
areas of the shallow aquifer. Drinking water supplies may be affeCted direCtly
through contaminant communication betWeen the aquifer zones and indirectly through
restriCtions on pumping rates.
The non-hazardous Jill material in the upper ponion of the fOT'71ler evaporarion pond
may be used to minimize off-gases from the ilJ=1iIM virrificarion process. Based on
analytical results from the remedial investigarion (Rl), confirmed by recent testing by
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Response.
...
COMMENTS OF Di'TRADA INDUSTRIES, INC.
U.S. Pollution Co1llTollnc. (USPCI), tM fill nuueriaJ in W upper portion of the
fOmJl!r n'aporarion pond may, if Mcessary, be ltmdjilled as a 1IOn-NzzArdow waste tll
USPCI's Grassy Mou1Jlainfaciliry. Alterrumwly, assuming l1J::lJ1M vinijicarion is
selected as parr of tM preferred remedial alterrumw, if it is determind during the
Remedial Design phase thar placemt1Jl of clean soil or fill nuuerilll over the
consolidtlled nuuerials in tM former n't1pOrarion pond is Mcessary to minimize oJ!-
gases, rMn tM jill nuueriaJ in tM upper portion of tM former pond may be wed lor
thar purpose. Accordingly, tM record 0/ dedsion should briefly articultlle rhis
particular aspect 0/ tM m:m vilrijicarion process, if tM alterrumw is ultimately
selected as parr 0/ rM pre/erred remedial alrenultiw lor tM site.
EP A and UDOH agree that the fill material in'the upper ponion of the former
evaporation pond could be landfilled if confirmed Don-hazardous. However, EPA.
and UDOH are concerned that the material may be contaminated as a result of water
level fluctuations within the evaporation pond and the presence of contaminated
sludge at the bonom of the pond. Similarly, EPA and UDOH are concerned that the
distinction between clean and contaminated fill material in the pond is not clear,
although confirmation testine should help clarify the boundary. Finally, because the
majority of material in the pond is fully saturated, EPA and UDOH believe that it is
not appropriate to use the fill material over consolidated material until the fill has
been dewatered. At this point, it is not necessary to aniculate this aspect of the in-
situ vitrification process in the ROD, although the option can be evaluated funher
during remedial design.
HAZARD RAJ\1OSG SYSTEM SCORISG
Commenr 12.
Response.
EPA erroneously proposed rM sire lor listing on rhe Nari01llll Priorities Ust.
Accordingly, tM sire should be dropped from consideration/or the NPL. E1Jlrada
submined detailed comme1JlS to EPA on w proposed NPL lisrtng 0/ tM site. The .
purpose 0/ the NPL comme1lls was to dtmonstrate that the HRS score recetved by the
sire was based on rechnically invalid data and incorrect assumprtons, resulting in
overestimares of the thretll ro human Malrh and the environme1ll posed by the site.
All commentS regarding HRS scorinl were addressed in the final determination for
the listing of Lot 6 on the NPL (56 Federal Re2ister 3903).
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"
Commenr 13.
Response.
Comment 14.
Response.
Comment 15.
Response.
COMMEr-.7S OF ENTRADA INDU~ES, INC.
Because of the relatively Impt~able clay layer and upward gradie1l1 berween the
sMllow unconjined and deep conjined aIluifers, the sMllow IUIconjiMd aIluifer is the
only -aquifer of concern - for purposes of scoring the sileo Based on the correCted
assumption thai the sMllow IUICOnjined aIluifer Is the only -alluifer of concern, - the
ground water route score for the sile decreases signijica1l1ly.
See response to comment 12.
Surface water does not flow from the 700 West Ditch i1l10 the Jordan River but rather
from the 700 West Ditch i1l10 the city drain. Contrary to UDOH's mistaken
assumption thanhe 700 West Ditch is upsrrean4 from and drains into the Surplus
Canal and the Jordan River, the 700 West Dilch flows i1l10 the ciry drain, which flows
through a conduit Jl!JIil!. the Jordan Riwr. Thus, neither the Surplus Canal,
which is divened from the Jordan River, nor the Jordan River is conneCted with or
receive drainage water from the 700 West Ditch. Tht Rl Phase 1 field investigation
conjirmed the flow pattern of the 700 West Ditch. Funhermore, the 700 West Ditch
flow pattern is clearl)' shown on the Salt ~ ciry Mosquito Abateme1l1 DistriCt Maps,
drawn in May 1935, copies of which are attached hereto as Appendix H. To the best
of Entrada's knowledge, the flow pattern of the 700 West Ditch has not been altered.
Thus, the Jordan River and the Surplus Canal and their respective uses are unrelared
to the scoring of the sire.
See response to comment 12.
The volumt of hazardous materials in the former Lor 6 evaporation pond is
overestimated. UDOH's proposed HRS score for the site is based, in pan, on the
assumption that the four{oot deep, 125{00t by 125{oot former concrete evaporation
pond on Lot' 6 is completel)' filled with Iw.ardous materials. In fact, prior to the
. encapsulation of the former pond, It was reponed thai only eight inches. of sludge
remained on the bottom of the pond. The quanriry of hazardous wastes or htu.ardous
substances sufficie1l1ly similar to Iw.ardous wastes i1l the fo~r pond is substa1l1ially
less than 2,315 cubic yards, as assened i1llhe HRS scoring package. Accordingl)',
the HRS score should be modijied to. refleCt the acrutJ1 volume of hazardous materials
in the former evaporarion pond.
See response to comment 12.
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Comment 16.
Response.
Comment 17.
Response.
..
COMME~"S OF E~7RADA INDUSTRIES, INC.
Finally, there is 110 evidence tha1 the risk posed, if fJIfy, by 1M site constitUtes a
significant threat to the public health or the environment. Indeed, portions of the
Wasatch Chemical site are currently operated by Great Western Chemical Company.
There is no ~ence to suggest tha1 the site is posing a health threat to either on-sire
or off-site MIOrkers. Furthermore, 1M site is located in a highly-Industrialized area.
The nearest resident is over one-quarter mile from the site. Again, there is 110
~ence to suggest tha1 the site is posing a health threat to off-site residents.
Additional information produced by EPA and included in the AR indicates that, under
certain exposure scenarios, the site may pose an unacceptable health risk. Also see
response to Comment 12.
Based on the foregoing. Entrada submits tha1 the site should be dropped from
consideration for the NPL, as well as the Utah Hazardous Substances Prioril)' List
(HSPL) under Urah Administrative Code. R45()..4()1.
The site has been listed in the Federal Register (56 Federal Re~ister 3903). EP A and
. UDOH believe that sufficient risk has been demonstrated by past investigations to
justify placing the site on the NPL and on the Utah HSPL despite the alleged
inaccuracies in the HRS scoring package enumerated by Entrada in several of the
previous comments. Therefore, EPA and UDOH disagree with Entrada's position
that the site should have been dropped from consideration for the NPL and Utah
HSPL. Also see response to Comment 12.
ADMI:\lSTRA TIVE RECORD
Entrada objects to the exclusion or inclusion of certain remedial investigation/feasibility stud)'
repository documents in the Administrative Record.
Comment 18.
In September 1990. EntTada submined to UDOH and EPA numerous documents from
the RIffS repository for inclusion in the Adminisn-ative Record. Several of these
documents apparently have 1IOt been included in 1M Adminisn-ative Record. Entrada
requests that all of its repository submissions be incorporated into the Administrative
Record as part of Entrada's comments on the Proposed Plan.
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~
Response.
Comme1l119.
Response.
Commeflt 20.
Response.
COMMEro-.'TS OF ENTRADA INDUSTRIES. INC.
EP A and UDOR will include Entrada's repositOry submission in the Administrative
Record.
Entrada objeCts to several dOCJl1M1I1s in the Adminisrratiw kcord ptrraining to
EPA's rmew of the Fi1lll1 Endangerment Assessme1l1 Reporr prepared by Harding
Lawson Associates on behalf of E1I1rada. Stt t. fl.. Adminisrratiw kcord. at
001261. 001262. 001263. OOJ425. OOJ426. and 001797. In particular. Entrada
disagrees with the comments prepared on the Fi1lll1 Endangerment Assessment Repon
on the basis thar several of the assumptions advanced by EPA are uverly-conservative
and do not present realistic exposure considerations. Moreover. EPA's comments
were prepared tWO m01l1hs after the Fi1lll1 Endq"gtrme1l1 Asstssmtnt Reporr was
submitted to the state and EPA. and therefore were &l1I1imely.
The comments prepared "by EPA and UDOR are consistent with current guidance and
the NCP, and do not present unrealistic"exposure conditions. Thus, EPA and UDOH
believe that the Administrative Record should contain the comments on the fiiul
Endangerment Assessment (EA) and the information developed subsequent to the
submission of the final EA. Since these documents were used by the regulatory
agencies in their decision making process, it is essential that they be included as part
of the Administrative Record. The additional information was intended to provide
insight into the site risles beyond those presented in the EA. It was not intended to
amend the quantitative conclusions reached in the EA.
Efltrada disagrees with several of the assumptions and the conclusions prese1l1ed in
EPA's -Evaluation of Pote1l1ial Risks from Exposure to Contaminared Ground Water
at the Wasatch Chemical Site. Salt Lake City, Utah. - Administrative Record. at
OJ 7976. The ~aluation addresses poteNial risks due to chronic ingestion of ground
water and acute exposure to waste sludges at the site. Although the purpose was to
~aluate hypothetical future risk sceMrios. Interal of the exposure risk assumptions
are overly-conservative. unrealistic, and c01l1rary to EP A risk assessment guidance.
In shorr. the risk ~aluation was improper. IncorreCt. and Inconsistent with the
requirements of the NCP.
EPA clearly defines the purpose and scope of the above-mentioned document as a
limited analysis -not" intended to take the place of a complete risk assessment for
groundwater at the Wasatch Chemical site: Instead, the document was prepared to
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Comment 21.
Response.
"
COMME1I.'TS OF ENI'RADA INDUSTRIES, INC.
-demonstrate EPA's concern for around water- [which was not satisfactorily
addressed in the final EA] -and to outline EPA's preferred approach to around water
issues. - In view of this scope and purpose. the analysis was neither overly
conservative nor incorrect. Moreover. deviations from leneral JUidance were
justified in the analysis.
EPA disagrees with Entrada's contention that the -Evaluation of Potential Risks from
Exposure to Contaminated Ground Water at the Wasatch Chemical Site. Salt Lake
City. Utah - was inconsistent with the requirements of the NCP. In fact, the NCP
requires that a baseline risk assessment be performed to determine whether the
contaminants of concern identified at a site pose a current or potential risk to human
health and the environment. 55 Federal Re,ister 8709 (March 8. 1990). EPA's risk
evaluation met those requirements where Entrada's FinaJ EA report did not.
Professional judgment is an integral part of the risk assessment process. While there
may be some difference in interpretation of the conditions at the site. it is felt that the
additional information was sufficiently conservative. This conservatism was
necessary in order to insure adequate protection of public health and the environment
both now and in the future. .
The Administrative Record also contains (at (01133) a document prepared by
Crescent Engineering, Inc. ~ntitled -Hazardous Waste PrelimiTUJry Site Survey, . dared
May 19, 1986. The purpose of the survey was to determine ifformer ponds on the
Steelco properry, which appear on aerial photographs produced in conneCtion wirh
the litigation, were formerly used as metal pickling ponds associated with previous
activities on the Steelco pro perry. The report concludes that the ponds constituted
mere ponding of surface runoff rather than former pickling ponds; hoWtVtr, aTUJ/)'tical
results from the RI suggeSt otherwise. Entrada disagrees with the conclusions in the
report.
Although EP A agrees that the document prepared by Crescent Engineering presents
insufficient data to conclude that the ponds coDStituted mere pondina of surface
runoff. the document provides other useful ~ormation relatina to site contamination.
EP A emphasizes the need for inclusion in the Administrative Record of all pertinent
documents relating to site contamination as these form the basis for the selection of
the remedy.
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..
Comment 22.
Response.
Comment 23.
Response.
Comment 24. .
COMMENTS OF ENTRADA INDUSTRIES, INC,
The Administrative Record contains a document, entitled *Draft Report Interim Report
for Wasatch Chemical Comparry* (Interim Report). Administrative kcord, at 00896.
The purpose of the report, prepared by Tech/aw, Inc. on EPA's behalf, was to focus
on identifying PRPs for the site lU&d to nGlUlIe the potenMJ liabiliry of the
Huntsman-Christensen related parties. EPA's effort in identifying PRPs QI the site,
particularly as late as OCtober 1988. as refleCted in the Interim Report. is untimely,
iNlppropriate. ucessive. lU&d therefore Inconsistent with the NCP.
EP A has been delegated the authority by the President of the United States to enforce
the provisions of CERCLA. Under that statUte, EPA is authorized to generate, or to
task its contractors to generate, any information necessary to identify Potentially
Responsible Parties (pRPs) who may be liable for the costs of cleanup at a site. The
described document was generated so that EPA could accurately identify PRPs
responsible for costs of response incurred at the Lot 6 portion of the site. The
parties' cost recovery settlement was memorialized in Administrative Settlement
Agreement, Docket No. CERCLA-VIn-9Q-17, which was signed by the parties in
June 1990. EPA therefore disagrees with Entrada's contentions regarding EPA's
effort in identifying PRPs at the site.
The Administrative Record contains several memoranda prepared by either EPA or
UDOH representatives concerning meetings held with representatives of Entrada in
connecrion with performing the RIfFS at the site. 'these memoranda do nor
accurately refleCt. ilJ.1QIQ. discussions berween the parties, or necessarily refleCt the
recolleCtions of Entrada's representatives at these various meetings.
EPA and UDOH are not aware of any inaccuracies contained in any EPA- or UDOH-
generated memoranda which are part of the Administrative Record.
'the Administrative Record contains a memorandum regarding the justification for the
seleCtion of Triangle Labs to provide Qlla/ytical services. within a tWO-week
IIlrnaround. in conneCtion with the investigation of the former drum Storage area on
Lot 6 in AuguSt 1990. Administrative Record at OOJ401. Entrada hereby reaffirms
its objeCtions to the scope of the investigation. as well as the necessity of such an
investigation in view of the ongoing RIffS. In summary. Entrada beli~s the
investigation was not warranted and inconsistent with the NCP.
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Response.
..
COMMEl\'TS OF ENTRADA INDUSTRIES, INC.
The investigation of the former drum storage area on Lot 6 in AUlUSt 1990 was
warranted and conducted under the EPA MaJce-Sites-Safe Initiative.
COMMENTS OF GALSON REMEDIATION CORPORATION (GRC)
APEG PROCESS
. GRC appreciates the efforts of UDOH and the U.S. EPA in review of this project. We offer
the following comments as points of clarification concerning the APEG process (~ternative No. S).
Commenr 25.
Response.
GRC conduCted a successful trealabUiry StUdy 6n lhe primmy cMmlcals of concern
from the site. The resulting aNJIyses showed a sllbstQlJliDJ reduCtion In all of lhe
contami1Ulnts, with one uception. Neither the GRC laboralory IIOr the lhird-parry
laboratory hired by Entrada analyzed for herbicides. Although this OVtrsight was
clearly unforru1Ulte, we 'WOuld IIOte lhat, given the success In treating the other
contami1Ulnts, the expeCtation is high that the herbicides were also destroyed. The
treated samples have been returned to the site.
Therefore, the stalement on page 8 of lhe Proposed Planlhat .the (APEG) process is
not completely effeCtive in trealing herbicides. may be misleading. InfaCt, the
a1Ull)'sis for herbicides did not take place, and lhe questions of APEG's effeCtiveness
on the herbicides at this site remains open. The liming for submitra/ of /cry
documenrs to the agencies did not allow for a repeal of the study and resulting
a1Ull)'ses with a focus on herbicides.
The statements made in this comment regardina samplina for herbicides during the
ueatability study are not entirely accurate. Hardina Lawson had a number of
. samples analyzed for herbicides, includina treated and untreated soil/sludae.
However. aU herbicide results were below detection (the detection limit was very
hiah for untreated soil/sludae). Therefore. a comparison of treated and unueated
samples was meaningless. In the absence of any other evidence reaarding the
effectiveness of herbicide treatment. UDOH informed Entrada that any aJtemative in
the FS which utilized the APEG process would have to assume that herbicides were
not ueated. EPA and UDOH recoll1ize GRC's concern and have included language
in the ROD to indicate the APEG process showed effective results to the extent the
process was demonstrated.
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.
Comment 26.
Response.
Comment 27.
Response.
COMMENTS OF GALSON REMEDIATION CORPORATION (GRC)
'/he starement, also 011 page 8, that -vaporized contaminants would be colleCted ill all
aCtivared carboll filter to prevent emissions to the armosphere - is true. III additioll,
each reaCtor vessel is linked to a condensare colleCtioll syStem, which traps volari/es,
makillg them available to be decQllled from the APEG system for recyclillg or final
disposal.
EPA and UDOH acknowledge the additional information from GRC.
Finally, GRC's APEG process hils beell proven successful arID sites throughout the
U.S. III additioll. GRC hils conduCted close to 3D successful trearabiliry Studies 011 a
varieo' of contaminanrs, illcludillg dioxill, pesncides, pentachlorophenol, and PCBs.
EPA and UDOH acknowledge the additional information from GRC.
OFFICIAL TRANSCRIPT COMMEI\,.S
COMME~"S OF MR. FRED FIFE
Comment 28.
Response.
I'm a residenr. I have property 111 the area there. conduCt my business there. 17rh
South .and 700 West. 011 Figure 3 there is a boundary shown for areas of ground
water contamination, and arleast 011 Lot 6, arleast 011 the left-hand side of that
figure there are some questions marks indicared with that contour or boundary.
The question marks in the boundaries delineating areas of ground water contamination.
indicate the present uncertainty of the extent of the volatile oraanic compound (VOC)
concentrations above ground water target cleanup levels. The primary uncertainty is
the relationship between the VOC plume in the vicinity of the former evaporation
pond, and the VOC contan)ination detected in around water beneath the Steel co
propeny.
Comment 29. Is there any detenninatioll as to how far this contaminatioll of the ground warer
around the site has migrared?
Response.
The position on Steelco around water is that the around water remedy for the .
Wasatch Chemical propeny and extending 80 feet nonh of that propeny's nonhern
boundary is final. However, the overall ground water remedy for the site is subject
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.
OmCIAL TRANSCRIPT COMMENTS
to possible future amendment because of uncertainty regarding Steel co around water.
Funher studies to investigate the nature and extent of around water contamination
beneath the Steelco property will be conducted by EPA and UDOH during remedial
design activities. In panicular, the source of the Steelco around water contamination
and its relationship to Wasatch Chemica] site activities will be investigated.
Q)mmenr 30. Has any of the ground waler conramirum01l shown up 111 the ditch there 011 the west
side of the properry?
Response.
Based on sampling of water in the ditch during ~e RI investigation and comparison
to background water "upstream" of the site, tM EPA does not believe the ditch has
been adversely impacted by activities at the Wasatch Chemical site or associated
ground water contamination.
COMMEJ\,.S OF MR. PETE SUAZO
Q)mment 31. Does Entrada know what their end use for the 18-acre site Is goi1lg to be after the
cleaTlup?
Response.
Entrada stated at the public meeting that they are contemplating a number of uses for.
the site ranging from warehousing to manufacturing. Entrada intends to use the site
as pan of their business following cleanup.
Q)mment 32. Is there a1l estimate of what the time would be for the ~1JtUQ/ cleanup?
Response.
The cleanup of soils, sludges, and dioxin-contaminated wastes with the selected
remedy (in-situ vitrification) wiU take about 6 months after starting remedial action.
Since negotiations concerning remedial design/remedial action (RDIRA) bave not yet
begun, .it is difficult to pinpoint a date wben remedial action will begin. However,
such action will probably not begin before the second half of 1991.
For ground water treatment, the selected remedy will substantially reduce the
contaminant levels within S years. However, it is not clear bow long the ground
. water will have to be treated to achieve complete reduction of contaminants. If the
site contains residual contamination, the S-year review provision under CERCLA is
triggered and the remedial action is Dot completed. Only in rare instances, when no
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~
omClAL TRANSCRIPT COMMEf't.'TS
hazardous substances remain at the site and no residual ground water contamination is
present, is it possible to avoid post-remedy ground water monitoring.
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ATTACHMENT A
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t
ATI'ACHMENT A
COMMUNITY RELATIONS ACTIVITIES AT THE WASATCH CHEMICAL SITE
The community relations activities performed to date by the Utah Deparunent of Health
(UDOH) at the Wasatch Chemical site are listed below:
.
Completed a community relations profile (February 1986)
Issued press releases on .Wasatch Chemical Wastes to be Removed" and "Dioxin
Found at Wasatch Chemical Site" (March 1986)
.
.
Released a fact sheet on Wasatch Chemical Site (Lot 6) removal activities (May
1986)
Held a press briefing on Wasatch Chemical Site (Lot 6) removal activities (May
1986)
.
.
Held a press briefing on Wasatch Chemical Site (Lot 6) removal site status (June
1986)
Issued a press release on "State Files New Complaint on Wasatch Chemical" (July
1986)
.
.
Compiled mailing list for community relations plan (Summer 1986)
Held elected official briefing that included UDOH Bureau Directors, Salt Lake City-
County Health Department, and Salt Lake City officials regarding ueatment of
Wasatch dioxin (September 1986)
.
.
Press release announcing the site proposed for inclusion on the National Priorities
List (January 1987)
Notice published on relocation for the interim storage facility (July 1987)
.
.
Fact sheet released on update on Wasatch Chemical Site (November 1987)
Press release and fact sheet announcing that the RIIFS work was beginning (April
1988)
~
.
Interviews held with business, residents, and others for the community relations plan
(Summer 1988)
Fact sheet update (October 1988)
.0
.
Information repository sites selected (November 1988) .
Mailing list updated (November 1988)
Fact sheet released with update on contamination problem and current status
(February 1989)
.
.
.
Held briefing for Salt Lake City Councilman Wayne Horrocks, Westside Community
Council (February 1989)
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.
.
Community relations plan approved and implemented \rebruary 1989)
Fact sheet announcing RIfFS pro&!,ess at site (April 1989)
Fact sheet announcini RIfFS progress at site (September 1989)
Mailini Jist updated for community relations plan (September 1989)
Press release 8 Acid Spilled, 6-Block Area Evacuated8 (September 1989)
j
.
.
.
.
.
Elected officials briefing held for Salt Lake City and Salt Lake County officials (June
1990)
Fact sheet released announcing the RIfFS completion and findings (August 1990)
.
.
Elected official briefing held with U.S. Congressional deleiation (AulUst 1990)
Mailing lists updated for community relations plan (September 1990)
.
Elected officials briefing held with Salt Lake City and Salt Lake County officials
(September 1990)
.
.
.
Proposed plan fact sheet released announcing the preferred alternative and public
comment period
Legal notice published announcing the RIfFS completion, the proposed plan, and the
public comment period dates (October 1990)
.
.
Public meeting held; transcript prepared and placed in AR (October 1990)
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