United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R08-92/056
March 1992
PB93-964410
v°/EPA Superfund
Record of Decision:
Portland Cement (Kiln Dust
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NOTICE
The appendices listed in the index that are not found in this document have been removed at the reQuest of
the issuing agency. They contain material which supplement. but adds no further appIicabte information to
the content of the document. All supplemental material is, however, contained in the administrative record
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REPORT DOCUMENTATION I 1. REPORT NO. I ~ 3. Recipient'a Acceaaion No.
PAGE EPA/ROD/R08-92/056
4. Title and Subtitle 5. Report Date
SUPERFUND RECORD OF DECISION 03/31/92
Portland Cement (Kiln Dust #2 & #3), UT
6.
Second Remedial Action - Final
7. Author(a) 8. Perfonning Organization Rept. No'
9. Perfonning Orgainization Name and Addre.. 10. PtojectlTaaklWork Unit No.
11. Controct(C) or Grant(G) No.
(C)
(G)
12. Sponooring Organization Name and Addre.. 13. Type of Report & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 '4.
15. Supplementary Notea
PB93-964410
16. Abatract (Limit: 200 worda)
The 71-acre Portland Cement (Kiln Dust #2 & #3) site, located in a primarily
industrial/commercial area of Salt Lake City, Utah, consists of three separate but
adjacent properties known as Site 2, Site 3, and the West Site. The area surrounding
the site is characterized by dense residential and agricultural land, as well as highly
commercialized and industrialized development in the immediate vicinity of the site.
Between 1959 and 1983, the Portland Cement Company, which was purchased by Lone Star
Industries in 1979, deposited approximately 495,000 cubic yards of waste cement kiln
dust (CKD) on each of the three properties comprising the site. Waste CKD, which
consists primarily of heavy metals and other inorganics, is highly alkaline.
Approximately 360 tons of chromium-bearing refractory bricks were disposed of with the
waste CKD. In 1984, Lone Star voluntarily began environmental investigations at the
site, which included installing ground water monitoring wells. The first remedial
action (OU1) selected in 1990 addressed the removal of the waste CKD and temporary
onsite storage of the chromium bricks. The waste CKD, the primary source of
contamination of onsite soil, will be removed during the OU1 remedial action. This ROD
(See Attached Page)
17. Document Analyaia L Deacriptora
Record of Decision - Portland Cement (Kiln Dust #2 & #3), UT
Second Remedial Action - Final
Contaminated Media: soil, waste
Key Contaminants: metals (arsenic, chromium, lead)
b. ldentifiera/Open-Ended Terma
c. COSA T\ Reid/Group
18. Availability Statement 19. Security CI... (lbia Report) 21. No. of Pagea
None 48
20. Security CIa.. (lbia Page) n Price
None
VI' 272 (4-77)
. ,
50272-101
(See ANSI Z39.18)
See Instructions on Reverse
(Formet1y NTlS-35)
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EPA/ROD/R08-92/056
Portland Cement (Kiln Dust #2 & #3), UT
Second Remedial Action - Final
Abstract (Continued)
addresses the onsite contaminated soil and chrome-bearing bricks that provide a potential
source of ground water. contamination onsite. The selected remedy for the OU2 action
reduces principal threats and prevents further contamination of the ground water. Ground
water contamination will be addressed as either a separate operable unit or under the
5-year review of the OUl remedial action. The primary contaminants of concern affecting
the soil and waste CKD are metals, including arsenic, chromium, and lead.
~he selected remedial action for this site includes excavating approximately 27,000 cubic
yards of soil with concentrations greater than lead 500 mg/kg or arsenic 70 mg/kg, with
onsite solidification of soil with concentrations of lead equal to or above 5 mg/l, based
on TCLP analysis; treating approximately 360 tons of chrome-bearing bricks onsite using
chemical fixation, followed by solidification; transporting all excavated and treated
material offsite to an appropriate disposal facility; placing an l8-inch protective cover
of clean fill over the entire site; and implementing institutional controls including
deed restrictions, as necessary. The estimated present worth cost for this remedial
action is $6,400,000. O&M costs for the selected remedial action are assumed to be
negligible.
PERFORMANCE STANDARDS OR GOALS:
Treatment levels for soil are dictated by federal Land Disposal Regulations (LDRs) and
state solid waste disposal regulations. Soil will be treated to 5 ug/l lead, or less, as
measured by TCLP before land disposal; chrome-bearing bricks will be treated to 5 mg/kg
by TCLP analysis prior to disposal. Federal and state air regulations on total suspended
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RECORD OF DECISION
PORTLAND CEMENT' CO. (KilN DUST #2 & #3)
Operable Unit No.2
Salt Lake City, Utah
March 31, 1992
Prepared by:
U.S. Environmental Protection Agency
Region VIII
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DECLARATION FOR THE RECORD OF DECISION
PORTLAND CEMENT CO. (Kiln Dust #2 & #3)
Operable Unit No.2
Salt Lake City, Utah
March 31,1992"
U.S. Environmental Protection Agency
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Portland Cement Co. (Kiln Dust #2 & #3) Superfund Site
Operable Unit No.2 (OU2)
Salt Lake City, Utah
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for Operable Unit No.2 (OU2) at
the Portland Cement Co. Superfund Site (Site) in Salt Lake City, Utah. The selected remedy was
chosen in accordance with the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA), as amended by the Superfund Amendments Reauthorization Act (SARA)
and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision
is based on the administrative record for the Site. The State of Utah concurs with the selected
remedy.
ASSESSMENT 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 endangerment to public health, welfare or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The Site is currently divided into two operable units (OUs). The OU1 ROD was signed on July
19, 1990. It requires excavation of the waste cement kiln dust (waste CKD) as well as the
separation of chromium-bearing refractory bricks (chrome-bearing bricks) from the waste CKD and
their temporary storage on site. The OU1 ROD also requires the initiation of groundwater
monitoring.
The second OU (OU2) is the subject of this ROD. OU2 addresses the risk of exposure to soils
with elevated pH (high alkalinity).and lead levels. The soils are also a potential secondary source
of groundwater contamination. Additionally, OU2 addresses the final disposal of the chrome-
bearing bricks.
After the removal of the potential sources of groundwater contamination under 0 U 1 and 0 U2, the
groundwater contamination will be addressed. EPA will address remediation of the groundwater,
if necessary, under the five-year review of OU1 or as a third OU.
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The selected remedy for OU2 is On-Site Treatment and Off-Site Disposal. Under this alternative:
Contaminated soil above 500 mg/kg lead or 70 mg/kg arsenic shall be excavated;
Soil equal to or above 5 mg/l, as measured by TClP analysis, shall be identified and
treated by solidification; during the RI/FFS, it was determined that soil above 500 mg/kg
lead will likely be above 5 mg/l lead as measured by TClP analysis;
The chrome-bearing bricks shall be treated on site by a process of chemical fixation
followed by solidification;
.
The treated bricks and soil shall be transported and disposed off site; and
A protective layer of clean fill at least 18 inches thick shall be installed on the Site.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with federal
and state requirements that are legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable and satisfies the statutory preference for
remedies that employ treatment that reduces toxicity, mobility or volume as a principal element.
Because the selected remedy will leave highly alkaline soils on site, a review will be conducted
five years after commencement of the remedial action to ensure that the remedy continues to
provide adequate protection of human health and the environment.
ck W. McGraw
cting Regional Administrator
EPA Region VIII
Date
3/3/ /yz.
I /
715//?'2:
Date
Ken eth Alkema
Executive Director
Utah Department of Environmental Quality
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DECISION SUMMARY FOR THE RECORD OF DECISION
Portland Cement Co. (Kiln Dust #2 & #3)
Operable Unit No.2
Salt Lake City, Utah
March 31, 1992
U.S. Environmental Protection Agency
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DECISION SUMMARY
TABLE OF CONTENTS
I.
II.
III.
IV.
V.
VI.
VII.
VII I.
IX.
X.
XI.
Site Name, Location, and Description. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1
Site History and Enforcement Activities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 5
Highlights of Community Participation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 6
Scope and Role of Operable Units Within Site Strategy. . . . . . . . . . . . . . . . . . . .. 7
Summary of Site Characteristics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 7
Summary of Site Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 9
Description of Alternatives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 19
Summary of Comparative Analysis of Alternatives. . . . . . . . . . . . . . . . . . . . . . .. 24
Documentation of Significant Changes. . . . . . . . . . . .: . . . . . . . . . . . . . . . . . .. 29
The Selected Remedy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 29
Statutory Determinations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 31
"List of Acronyms. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . .. 34
Glossary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 35
Bibliography. . . . . . . ". . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 37
List of Tables
Summary of Chemicals of Pote"ntial Concern in Soils. . . . . . . . . . . . . . . . . . . . . " 8
Assumptions for Evaluated Exposure Pathways. . . . . . . . . . . . . . . . . . . . . . . . .. 11
Summary of Airborne Dust Concentrations, Chemicals
of Potential Concern. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 12
Summary of Metal 'Concentrations in Homegrown Produce. . . . . . . . . . . . . . . . .. 12
Toxicity Values for Chronic Exposure to Non-Carcinogens. . . . . . . . . . . . . . . . .. 14
Toxicity Values for Chronic Exposure to Carcinogens. . . . . . . . . . . . . . . . . . . . .. 15
Summary of Health Risks for Residents Potentially Exposed to Soils
Contaminated with Arsenic, Cadmium, Chromium and Molybdenum. . . . . . . . . .. 16
VI-? Summary of Health ~isks for 2 Year Old Residents Potentially
Exposed to Lead-Contaminated Soils. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 17
VII-1 Summary of Remedial Alternatives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 23
VIII-1 Summary of Estimated Costs for Remedial Alternatives. . . . . . . . . . . . . . . . . . .. 26
VIII-2 Summary of Detailed Evaluation of Remedial Alternatives. . . . . . . . . . . . . . . . .. 28
X-1 Estimated Costs of the Selected Remedy. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 32
V-1
VI-1
VI-2
VI-3
VI-4
VI-5
VI-6
List of Figures
1
2
Site Location Map. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2
Location of Waste CKD ............................................ 3
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Decision Summary for the Record of Decision
I.
Site Name, Location, and Description
Site Historv
The Portland Cement Co. (Kiln Dust #2 and #3) Superfund Site (Site) is located in Salt Lake City,
Utah, on the west side of Redwood Road (1700 West) at 1000 South, within a triangular area
defined by Indiana Avenue, Redwood Road and the Jordan River Surplus Canal (Figure 1). The
Site consists of three separate but adjacent properties known as Site 2, Site 3 and the West Site
(Figure 2). The West Site and Sites 2 and 3 cover approximately 35, 17 and 19 acres,
respectively. The area surrounding to the Site is primarily industrial and borders low density
residential and vacant or agricultural land. The immediate area surrounding the Site is highly
commercialized and industrialized. Residential areas exist primarily east of the Site and include
single-family dwellings, mobile home parks and some high density multi-family residential units.
There are no buildings on the Site. However, two underground structures, a large sewer pipe with
above-ground manholes and a natural gas pipeline, traverse the Site. A chain-link fence was
constructed around the Site in 1989 to prevent unauthorized entry.
Between 1965 and 1983, waste cement kiln dust (waste CKD) generated at the Portland Cement
Company plant in Salt Lake City was deposited on the Site, resulting in soil, surface water and
groundwater contamination. For purposes of conducting remedial efforts, the Site has been
divided into two operable units: Operable Unit 1 (OU1), which addresses on the waste CKD
deposited on the Site, and Operable Unit 2 (OU2) , which is defined as the on-site soils and other
materials potentially contaminated by the waste CKD, specifically the chromium-bearing refractory
kiln (chrome-bearing) bricks that were disposed of with the waste CKD.
Site Geoloav and HvdroloQV
The Site is located in the Salt Lake Valley which occupies approximately 400 square miles in
north-central Utah. The Salt Lake Valley lies on the eastern portion of the Basin and Range
physiographic province. The boundaries of the Salt Lake Valley are formed by the Great Salt
Lake on the north and by mountain ranges to the east, west and south.
In general, the Salt Lake Valley is filled with alluvial and fluvial detritus derived from the
surrounding mountains through an ongoing process of erosion and deposition. The Site is
underlain by several thousand feet of unconsolidated sediments including lake-bottom clays
interbedded with thin discontinuous sand lenses. The coarser grained sediments form aquifers
which are used as a source of irrigation and drinking water in the Salt Lake Valley.
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FIGURE 1: SITE LOCATION MAP
2
REFERENCE,
U,S.G.S. QUADRANGLES ENTITLED
"SALT LAKE CITY NORTH. UTAH 11 AND
"SALT LAKE CITY SOUTH. UTAH" -
BOTH SHEETS DATED 1963 AND PHOTO-
REVISED 1969 II< 1975.
,
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2000
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\ CITY DUMP \
I ,
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1 I
I \
I I
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I ,
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'----- :
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SCALE IN FEET
100 0 100
---
Kay
400
.. KTCNT 0... PU".
CKD CJCP08ED AT
IIU""'A.C&
CKTII:NT 0" CNO-
80IL "",X .XN.aD
AT 8U"II'ACC
ArPlloX'MATII II:X-
TaNT 0.. aU'''CD CleO
WASTE
CEMENT KILN DUST
DISPOSAL SITES
FIG' 'RE 2:
LOCATION OF WASTE CKD
3
~- ...--.......;---:
'. - ---_..._~~-......,....~,)~......
.'~~'''':~J
...~
Dames & Moore
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TOPoQraphy
The topography at the Site is relatively flat with elevations varying slightly above and below 4225
feet above mean sea level. The waste CKD addressed by OU1 is present in piles over much of
the Site, creating an uneven ground surface; it will be removed during implementation of the OU1
remedy. Early surveys show that before fill was placed at the Site, a grade break existed in the
ground surface which bisected the triangular-shaped area along a northwest-southeast axis. land
to the northeast of this break was relatively high ground and was used for agricultural and
residential purposes. land southwest of the break was comprised of low-lying salt flats. The
apparent purpose of placing the waste CKD on the Site was to raise the ground surface elevation,
enabling development of this area.
DrainaQe
Drainage on the Site is poor. Occasionally water collects in confined depressions east and south
of Site 2, between Sites 2 and 3 and north of Site 3. The Surplus Canal, which flows along the
southern boundary of the Site, carries excess flow in a northwesterly direction from the Jordan
River to the Great Salt lake. The City Drain, part of the urban storm sewer system, bisects the
Site, separating Site 3 from Site 2 and the West Site. A shallow drainage which carries surface
runoff into City Drain has been excavated along the west boundary of the link Trucking property,
which is situated between Sites 2 and 3.
Groundwater
Groundwater under the Site occurs in three divisions: (1) a shallow groundwater body overlying
confining layers, (2) local perched water bodies, and (3) an artesian basin. In general, the
aquifers are separated by a confining bed consisting of a relatively impermeable interbedded
series of clay, .silt and fine sand ranging in thickness from 40 to 100 feet.
The shallow unconfined aquifer is largely comprised of clay, silt and fine sand deposits. It is
recharged by infiltration from precipitation, canals, irrigation, and surface water. Additionally,
groundwater in the deeper aquifer typically moves upward into the shallow aquifer and is a source
of recharge for the shallow aquifer. The shallow or unconfined groundwater in the area of the Site
has been classified as . Class II and Class III groundwater by the Utah Department of
Environmental Quality.
The deep confined aquifer is composed of clay, silt, sand and gravel, all hydrologically connected,
with individual beds ranging from less than one foot to more than 50 feet thick. The maximum
thickness for the deep aquifer is approximately 1000 feet in the northern portion of the Salt lake
Valley near the Site. Water in the deep aquifer is under artesian pressure with upward flow
gradients, resulting in some recharge to the shallow unconfined aquifer. The artesian aquifer,
which flows to the north-northwest toward the Great Salt Lake, serves as the primary source of
groundwater in the Salt Lake Valley. It is used for stock watering, :rrigation and industrial supply
and public drinking consumption.
Seven municipal wells are present at distances from one to three miles from the Site. There are
67 low yield private wells within one mile of the Site. .
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VeQetation
Most of the area near the Site consisted of saltgrass alkali flats prior to industrial development.
Currently, the Site is mostly barren of vegetation. However, there is still suitable habitat for
numerous animal species on the West Site and on the Site perimeter. The State of Utah (State)
has classified the Surplus Canal as Class 3C, 3D and 4, which are protective of non-game fish
and other aquatic organisms; waterfowl, shorebirds and other water-oriented wildlife; and for
agricultural uses such as irrigation of crops and 'stock watering. According to previous
investigations, no listed or candidate threatened or endangered species are known to occur in the
vicinity of the Site.
II.
Site History and Enforcement Activities
All waste CKD deposited at the Site was produced between 1959 and 1983 by the Portland
Cement plant located at 619 West 700 South in Salt Lake City, Utah. The plant was owned and
operated by Portland Cement Company of Utah (PCU) until September 1979, when Lone Star
Industries (Lone Star) purchased the stock of PCU. At the time of purchase, the name of the
company was changed to Utah Portland Quarries, Inc. Although the waste CKD was placed on
the Site by PCU and Lone Star, neither company owns the land comprising the Site.
Dry waste CKD was reportedly placed on the West Site from 1965 until 1974. Disposal of dry
waste CKD in the area ,of Site 3 occurred from 1974 until 1978. At Site 2, waste CKD was
disposed as a dry material between 1978 and 1980 and as a wet slurry between 1980 and 1983.
In response to complaints from area residents who were concerned about windblown waste CKD,
the U.S. Environmental Protection Agency (EPA) initiated a Preliminary Assessment, which
indicated the potential for risk to the community. In April 1984, Lone Star voluntarily began
environmental investigations at the Site which included the installation of groundwater monitoring
wells to determine if groundwater contamination was present. In September 1984, Sites 2 and
3 were proposed for inclusion on the National Priorities List (NPL). In 1985, the investigation was
organized and expanded as a RemediallnvestigationfFeasibility Study (RifFS) under a Consent
Decree issued by the State. The Site was formally listed on the NPL on June 10, 1986. The
West Site was added to the Superfund Site at this time. On September 17, 1990, the EPA sent
a Special Notice Letter, which advised Potentially Responsible Parties (PRPs) of their potential
liability. The letters were sent to Lone Star Industries and the Site landowners, Williamsen
Investment Co., Lawrence D. Williamsen, Sidney M. and Veoma H. Horman, Horman Family
Trust, Calvin B. Brown and Southwest Investment, Inc. as identified PRPs.
On July 19, 1990, a Record of Decision (ROD) was issued for Operable Unit No.1 (OU1) of the
Site. The selected remedy described in the ROD addressed the principal source of contamination
at the Site through excavation and off-site disposal of the waste CKD. About 360 tons of chrome-
bearing bricks which were disposed with waste CKD are to be separated from the waste CKD,
temporarily stored at the Site and managed as part of the OU2 remedial action. In addition,
groundwater monitoring for the Site will be initiated. Negotiations with the PRPs regarding the
conductance of the remedy ended unsuccessfully. The State recently assumed the Superfund-
financed lead of OU1 Remedial Design from the EPA. Currently, the State is in the process of
selecting a consultant to conduct the OU1 remedial design work.
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'.
Environmental investigations focusing on OU2 have been conducted by the Utah Department of
Environmental Quality (UDEQ) and the EPA. In October 1991, a Baseline Risk Assessment
(BRA) which evaluated potential chemical exposure and the risks associated with contaminated
soil and bricks was completed. It was followed in November 1991 by a Remedial Investigation
(RI) Report and Focused Feasibility Study (FFS). Upon finalization and approval of this ROD, the
selected remedy will be implemented.
III.
Highlights of Community Participation
Although the community has played a role in Site activities since 1983, when the EPA responded
to complaints by area business owners who were concerned about airborne waste CKD being
blown into their offices, community participation for OU2 became most active in late 1991. Soon
after the completion of the OU2 RI and FFS, Salt Lake City representatives and Salt Lake County
Commissioners were briefed on the reports' findings and the Preferred Alternative. Copies of the
. Proposed Plan were mailed to area residents and others on the mailing list on November 8, 1991.
The notice of availability for these reports and the announcement of the Preferred Alternative
were published in the Salt Lake Tribune and Deseret News on November 10, 1991. News
coverage of the release of the Proposed Plan was also provided by other major media in the Salt
Lake City market, notifying the public of a scheduled public meeting and the public comment
period. The Preferred Alternative presented in the Proposed Plan consisted of on-site treatment
and on-site disposal of contaminated soil and chrome-bearing bricks.
A public meeting to receive comments on the Proposed Plan was held November 20, 1991 and
was attended by approximately 50 people, including concerned citizens, elected officials, State
and EPA officials and legal representatives of Lone Star and some Site landowners. A transcript
of this meeting is available for public review at UDEQ, the Chapman Branch of the Salt Lake City
Public Ubrary, and the EPA offices in Denver, Colorado. Media coverage of the public meeting
included broadcasts that night and written news reports the following day.
The 30-day public comment period, which was initially scheduled for November 12 to December
13, 1991, was extended another 30 days in response to public interest. This extension was
advertised in the Salt Lake Tribune and the Deseret News on December 8, 1991. The comments
received and responses to these comments are summarized in the Responsiveness Summary
section of this ROD.
EPA and the State have continued to keep the community and local government officials informed
regarding the status of the Site through on-going community relations activities. . Regular briefings
have been held by the UDEQ Superfund representatives for Salt Lake City and Salt Lake City-
County Health representatives to update them on Superfund sites within Salt Lake City, including
the Site. During 1991, briefings were held in March and August. In addition, the UDEQ
Community Relations staff maintained regular phone contact with the Salt Lake City Council
representative from the Site area and with Salt Lake City-County Health D'~partment Community
Relations personnel.
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:
. -
IV.
Scope and Role of Operable Units Within Site Strategy
For purposes of conducting remedial efforts, the Site has been divided into two operable units:
OU1, the remedy of which focuses on the waste CKD deposited on the Site, and OU2, which is
defined as the on-site soils and other materials potentially contaminated by the waste CKD,
specifically chrome-bearing bricks that were disposed of with the waste CKD.
Groundwater contamination will be addressed as either a separate operable unit (OU3) or under
the 5-year review of the OU1 remedial action. Investigation of the groundwater began during the
OU1 RifFS. Groundwater monitoring will occur during the OU1 remedial action. The OU1 and
OU2 remedies focus on source control and therefore do not include groundwater treatment. This
approach was based on a number of factors, including: there is no present uses of the
groundwater impacted by the Site; short-term potential use is minimal; the extent of groundwater
contamination is limited; and remedies which remove the contamination sources are expected to
accelerate improvement in the groundwater quality. If monitoring indicates that source removal
does not provide adequate protection of human health and the environment, additional
investigation and remediation will be initiated. The approach which most efficiently addresses the
problem will determine whether groundwater contamination is addressed as a third OU or under
the OU1 five-year review.
This ROD addresses OU2. The waste CKD addressed by OU1 is the primary source of
contamination of on-site soil. For this reason, the waste CKD is being removed during the OU1
remedial action. However, the on-site contaminated soil and chrome-bearing bricks also provide
a potential source of groundwater contamination on the Site; therefore, the remediation of these
sources is addressed by this ROD.
The BRA determined that conditions at the Site after implementation of the OU1 remedy will pose
a risk to human health and the environment. Specifically, the high alkalinity of the soil and the
lead levels detected in the contaminated soil pose a risk through direct contact, ingestion, and
inhalation. The selected remedy for OU2 reduces these principal threats as well as prevents
further contamination of the groundwater. Risks associated with the chrome-bearing bricks that
were excavated with the waste CKD during the OU1 remedial action are also addressed in OU2.
V.
Summary of Site Characteristics.
Nature and Extent of Contamination
The waste CKD addressed by OU1 and the chrome-bearing bricks disposed with the waste CKD
are a source of contamination of the underlying soil and groundwater. Additionally, the
contaminated soils beneath the waste CKD are a potential source of groundwater contamination.
Contaminants related to the waste CKD have been detected above background concentrations
in shallow groundwater to a depth of about 25 feet both on the Site and immediately north of the
Site. There are no known users of shallow groundwater in the immediate vicinity of the Site.
There is no evidence that groundwater from the deeper artesian aquifer has been affected by
waste CKD constituents on the Site.
-------
",
~.
Several potentially toxic metals in OU2 soils exceed local background levels: cadmium,
chromium, chromium VI (hexavalent chromium), lead and molybdenum. In addition, the high
alkalinity of the soil on Site is higher than the background, causing alkalinity to be a potential
concern as well. Statistical analysis of on-site sampling results for soils indicates that an
insufficient number of samples were analyzed to eliminate arsenic, a known human carcinogen,
as a potential contaminant. Since the waste CKD was found to contain elevated levels of arsenic,
it was suspected that the underlying soil would also contain elevated arsenic levels. Detected
concentrations of chemicals of potential concern and pH are shown in Table V-1.
Samples of contaminated soil and chrome-bearing bricks were analyzed using the Toxicity
Characteristic Leaching Procedure (TCLP). Detected concentrations in the contaminated soil
exceeded. the toxicity characteristic hazardous waste criterion for lead of 5 milligrams per liter
(mg/L), and the soil has a hazardous waste code of 0008. Chromium concentrations in the
chrome-bearing bricks ranged between 1238 mg/L and 6977 mg/L, greater than the toxicity
characteristic hazardous waste criterion for chromium of 5 mg/L. Once excavated, the chrome-
bearing bricks have the hazardous waste code of 0007. As a characteristic hazardous wastes,
treatment is required prior to disposal in accordance with the Land Disposal Restrictions (LDRs)
promulgated under the Resource Conservation and Recovery Act (RCRA). Comparison of the
results of both total chromium and hexavalent chromium indicate that most or all of the chromium
that can be leached is in the hexavalent state in these brick samples.
TABLE V-1
SUMMARY OF CHEMICALS OF POTENTIAL CONCERN IN SOILS
1l1I1I11J1
Arsenic 23/23 1.1-55.1 8.64 13.92 .002-.06 3.4-24.2
Cadmium 6/23 0.96-8.1 1.16 1.9 NA .25-2.5
Chromium 23/23 4.7-66 21.19 27.5 .01-.07 3.1-22.9
(Total)
Chromium VI 21/23 ND-3.1 0.91 1.25 NA ND
Lead 23/23 4.6-2730 420.2 772.4 .02-24.7 39.8-327
Molybdenum 22123 0.84-150 27.8 43.3 NA 1.3*
Alkalinity 23/23 1680-13100 6463 7543 NA 443*
pH 23/23 10.3-13.3 11.75 12.1 NA 8.2*
Total concentrations in milligrams per kilogram (mg/kg)
* Range not available, arithmetic mean of background values given
ND Not Detected
NA Not Analyzed
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..
. -
Soil situated between the base of the waste CKD and the top of the groundwater were
investigated under OU2. The volume of this soil is approximately 488,000 cubic yards. Of this
total volume, an estimated 27,400 cubic yards of soil exceed the health-based levels for lead, all
of which are located on Site 2.
After implementation of the OU1 remedy, the chrome-bearing bricks will be located in a temporary
storage area.
Contaminant Fate and Transport
Contaminants present in soil may potentially migrate into air, groundwater, or surface water. Soil
contaminants may leach into groundwater as a result of infiltrating water or rising groundwater
levels that contact contaminated soil. Suspended soil particles can also contribute to airborne
contamination. Contaminants could also be transported, either in solution or sorbed to sediments,
by surface water runoff or groundwater discharge. Soils may also act as the source of chemicals
taken up by vegetation or by animals. All of these types of migration mechanisms have either
been observed or could potentially occur at the Site.
The current risk of exposure to area residents is minimal since there are no nearby residences
to the north (down-gradient) and northwest (downwind) of the Site.
VI.
Summary of Site Risks
HUMAN HEALTH RISKS
As part of the RI/FFS, 23 soil samples from seven on-site locations were collected at a variety
of depths and were analyzed for 14 metals as well as pH, conductivity and alkalinity. Based on
a statistical comparison (t-test) of contaminant concentrations in Site soils to those found in
background soils, the BRA identified six chemicals of potential concern at the Site: arsenic,
cadmium, total chromium, hexavalent chromium, lead, and molybdenum. Also identified as
potential health concerns at the Site were highly alkaline soils and chrome-bearing refractory
bricks. Each of these potential health concerns was evaluated under a hypothetical exposure
scenario consisting of future residential use of the Site. Current land uses were not considered
to represent potential contaminant exposure bec.ause the Site is presently not used and is fenced
to prevent trespassing.
Exposure Pathways
Several potential exposure pathways were evaluated within the residential exposure scenario.
These consisted of:
Dermal contact;
Incidental soil ingestion;
Ingestion of indoor dust;
Inhalation of airborne dust following implementation of OU1 remedy; and
Ingestion of homegrown produce.
.
-------
, .
The pathways resulting in the largest amount of exposure to contaminants are ingestion of dust
and ingestion of produce. Of the chemicals evaluated, exposures to molybdenum are the
greatest. However, this exposure does not correspond to the greatest risk to human health due
to molybdenum's low toxicity relative to the other chemicals of concern. Groundwater was not
evaluated as an exposure pathway since it will be addressed in the future. Exposure to surface
water was not evaluated in the BRA as this pathway was considered incomplete. Risks
associated with the chrome-bearing bricks and the waste CKD were quantified during the OU1
investigations. The OU2 BRA did not re-evaluate the risk associated with the chrome-bearing
bricks.
Exposure assumptions were developed in accordance with EPA guidance documents. These
assumptions were based on a residential scenario and were time-weighted over a 30-year period
for all pathways except ingestion of indoor dust, which was evaluated only for children up to 2
years of age. Two year old children exhibit pica (soil eating) behavior and are susceptible to the
adverse effects from contaminant exposure. Specific exposure assumptions for each pathway
are presented in Table VI-1. Due to the lack of an established threshold exposure level for lead,
exposures to lead were evaluated using the U.S. EPA Integrated Uptake Biokinetic (IU/BK) model,
which evaluates exposures to the following media: air; diet; drinking water; soil and indoor dust;
paint; and maternal contribution during gestation. Three pathways were selected for site-specific
quantitative evaluation: ingestion of soils and indoor dust, inhalation of airborne dust, and
ingestion of produce. Default values provided by the IU/BK model were used for the remaining
pathways. It was assumed that children at the Site would not be exposed to lead-contaminated
paint and that fetal exposures would be comparable to the U.S. normal maternal lead level of 7.5
micrograms per deciliter (llg/dL). Additional assumptions of the IU/BK model are that
gastrointestinal absorption of lead is 50 percent, that 2-year old children have an inhalation rate
of 5 m3/day, and that the lungs absorb 32 percent of inhaled lead. Lead exposures that are
predicted by the IU/BK model are then compared with an acceptable blood level, currently set at
10 !-lg/dL.
A summary of analytical results and exposure point concentrations for contaminants in soil, air
and produce are presented in Tables V-1, VI-2 and VI-3, respectively. Exposure point
concentrations for contaminants in soil are based on the 23 soil samples collected, which included
samples collected at the surface and at depths of up to 3.92 feet below the surface. A 95-
percentile upper. confidence limit was calculated on the arithmetic mean and used as the
exposure point concentration.
Contaminant concentrations in dust were assumed to be equal to those found in soil.
Contaminant concentrations in air were estimated using several models which used contaminant
concentrations in the upper six inches of soil as well as site-specific meteorological data.
Contaminant concentrations in produce were estimated assuming airborne deposition of
contaminants onto plants and uptake of contaminants from soil by roots.
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.'
:
TABLE VI-1
ASSUMPTIONS FOR EVALUATED EXPOSURE PATHWAYS
- - 11111I111111111I11111111 - -
Exposure 350 350 52 37
Frequency
(days/yr)
Exposure Duration 30 6 30 30
(years)
Ingestion/l nhalation 1 20 mg/day 200 mg/day 1 51 g/day Vi ne 20
Rate 1 44 g/day
Leafy
1 1 4 g/day
Root
Fraction of Time O. 04 O. 74 Not Applicable
Spent Exposed via
Pathway
Fraction Ingested 0.37 0.71 1 0
from a
Contaminated
Source
Body Weight (kg) 48 1 6 48 48
Oral/l nhalation O. 8 Arsenic 0.8 Arsenic 0.8 Arsenic 0.23 Arsenic
Absorption/Retenti 1 .0 Cadmium 1 .0 Cadmium 1 .0 Cadmium 0.75 Cadmium
on 1 .0 Chromium 1 .0 Chromium 1 .0 Chromium 1 .0 Chromium
1 0 1 0 1 0 1 0
Molybdenum Molybdenum Molybdenum Molybdenum
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'.
".
TABLE VI-2
SUMMARY OF AIRBORNE DUST CONCENTRATIONS
CHEMICALS OF POTENTIAL CONCERN
:1:::I~'I'II~I::':II:':I,:i:::::::i.!.:::.::i::i!i:111::: !.:i:_III:iilglt:!lg~ill~tllll:!:~lllli:!::!::::.:::::'I.!::':':I:::::::::I.:::.I
Arsenic 8. 02 E-04
Cad mi u m 2. 02 E-04
Chromium (T ota!) 2. 04E-03
Chromium VI 7. 77E-05
Lead 3. 86E-03
Molybdenu m 1 36E-03
*
based on soil concentrations
TABLE VI-3
SUMMARY OF METAL CONCENTRATIONS IN HOMEGROWN PRODUCE
- :11::::I::i:'i:i:I:.:::::;;!li:.::i.i::I.:i!~lli:I::i:i:I:::::IIIII'!iM~11Illi.iB.:.i~I_~)ti:!:!.:!I:i:.:::!i.I:!i.!.::!II,:II.::':.::::::'i:.:..::::.:::,::':!:::!',I:::
.,,,,,,,,,,,,,,-,""""""""""'."""""""""'" .................................-................,......... ...............................................-,-........
::ii:I~~i::i:~I:::::::i:il:;:::ii:':::I::!iii:i::i:.~i.!i.i~i:j!j:iij:!ii:i'!:::::::i::' :i::.:I.~!:li;:!i:;:I:::;:::1;:ij.;ii!:i:!'!i:.!:i::111Illi:!i:::::::':,::::::I::;. :;;:ll!i:!I:::::::i::!.::!:li:~,i::::::::i:::i:i:::i::'i.:.!:':::::::::::::::!::::::!
Arseni c 5. 57E-03 2. 78 E-02 1 39E-02
Cad mium 1 71 E-02 5. 70E-02 6. 27E-02
Chromiu m (Total) 3.7 4E-02 3. 74E-02 3. 74E-02
Chromiu m VI 1 70E-03 1 70E-03 1 70E-03
Lead 2. 1 OE-01 8. 4OE-01 8. 4OE-01
Molybde num 1 1 9 E-OO 1 1 9E-OO 1 1 Q E-OO
* Estimated concentrations as a result of deposition and uptake by roots
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..
Toxicitv Assessment
Cancer potency factors (CPFs) have been developed by the EPA's Carcinogenic Assessment
Group for estimating excess lifetime cancer risks associated with exposure to potentially
carcinogenic chemicals. CPFs, which are expressed in units of (mg/kg-day)"', are multiplied by
the estimated intake of a potential carcinogen, in mg/kg-day to provide an upper-bound estimate
of the excess lifetime cancer risk associated with exposu~e at that intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated from the CPF. Use of this
approach makes underestimation of the actual cancer risk highly unlikely. CPFs 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.
Reference doses (RfDs) have been developed by the EPA for indicating the potential for adverse
health effects from exposure to chemicals exhibiting non-carcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily exposure levels for humans,
including sensitive individuals. Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking water) can be compared to the
RfD. RfDs are derived from human epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g., to account for the use of animal data to predict effects on
humans). These uncertainty factors help ensure that the RfDs will not underestimate the potential
for adverse non-carcinogenic effects to occur.
Tables VI-4 and VI-5 summarize the toxicity values used in the BRA for non-carcinogenic and
carcinogenic effects of the chemicals of concern, respectively. Exposure to arsenic, cadmium,
Chromium VI and lead can result in carcinogenic effects as well as non-carcinogenic effects.
Chromium III and molybdenum are not considered carcinogens. Confidence levels in the toxicity
value, uncertainty and modifying factors and the critical effects for each chemical are also
presented. Toxicity data were obtained from the EPA's Integrated Risk Information System (IRIS)
profiles and the EPA's 1991 Health Effects Assessment Summary Table (HEASl). The toxicity
value for Chromium III was considered to be representative of total chromium exposure since
most of the chromium in on-site soils is in the trivalent state (Chromium III), as indicated in Table
V-1, although TCLP analyses indicated that most of the chromium that can be leached from the
chrome-bearing bricks is in the hexavalent state. Total contaminant concentrations rather than
TCLP concentrations are the principal concern in risk assessment. .
Risk Characterization
Excess lifetime cancer risks are determined by multiplying the intake level with the CPF. These
risks are probabilities that are generally expressed in scientific notation (e.g., 1x10.o or 1 E-6). An
excess lifetime cancer risk of 1 x1 0.0 indicates that, as a plausible upper bound, an individual has
a one in a million chance of developing cancer as a result of site-related exposure to a
carcinogen over a 70-year lifetime under the specific exposure conditions at a site.
-------
TABLE VI-4
TOXICITY VALUES FOR CHRONIC EXPOSURE TO NON-CARCINOGENS
- II . . :::::::::::::::::::::::::::::::::~:::::::::::::::::::::::::~:::::::::::::::::::::::::::::: [[[ ..,., .. . ..
;:::::;:::::;:;:::::;:::;:::::;:::::::::;:::;:;:::m;:;:;:;:;:;:::;: [[[
~i:il.I.I:iill ~mU~~1j~~r~@H~~t~@rfmill~~rtmrmm '"N.','.',',',',','.',,,',',".",',',",','...',',',",',",",'.' '.".".'.','.'.'.".'.'.',',',',',',',",','.".'.',",",".".",'.'.'.".'.',''''',
.~.......................................'.'...',"'.'.'.'.'.... '.',','....,'.'.,.'.'.".".'."."...'.'.'.',',...,',','.'.',','.'.',','.','.',
II [[[
,.............,.......,.,.,...,..........,.... III
j~j~~jf~~~\~~jj~~~\~~j~~~~~J~~~~~~~~~\~~~\~~;~!j~~!~~1~~~Jj~j~~~~J!~~j~!~j~
- -
- 1!!i!1~j~!1~1~i.~jl~~j~~j1~j!jj!!~1~1~
ORAL ROUTE
Arsenic 3 x 1 0-4 - Dermal toxicity U.S EPA U F = 1
Reg ion
VI I I
Cad m ium 1 0 x 1 0-3 H igh Proteinuria I R I S U F = 1 0
(food) M F = 1
5. 0 x 1 0-4
(water)
Chromium I I I 1 0 x 1 00 Low Nasal mucosa H EAST U F = 1 000
atrophy
Chrom iu m VI 5. 0 x 1 0-3 Low Nasal mucosa H EAST U F = 500
atrophy
Lead" -- -- Neurotoxicity -- --
Molybdenum 4. 0 x 1 0-3 -- Non-specific H EAST U F = 1
toxicity
IN HALATION ROUTE
Arseni c -- -- - -- --
Cad mium -- -- -- -- --
Chromium I I I 2. 0 x 1 O~ -- Non-specific H EAST U F = 300
toxicity
Chromi um VI 2. 0 x 1 O~ -- Non-specific H EAST U F = 300
toxicity
Lead" - - -- -- --
Molybdenum -- - - -- --
-- InTOrmatfon not avallacle
-
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~
TABLE VI-5
TOXICITY VALUES FOR CHRONIC EXPOSURE TO CARCINOGENS
1l1III!1II1I1I
Arsenic
1.75 x 10°
5.0 x 10'
A
Skin,
respiratory
tract
Respiratory
tract
IRIS
Cadmium 6.1 x 1 0° B1
Chromium VI 4.1 x 10' A
Lead* B2
IRIS'
Lung
Kidney, lung,
stomach
IRIS
IRIS
A
81
82
Information not available
Quantitative exposure information necessary for determining a SF is lacking (IRIS)
Human carcinogen
Probable human carcinogen, based on animal data and limited human data
Probable human carcinogen, based on animal data and Inadequate or no data on humans
*
Potential concern for non-carcinogenic effects of a single contaminant in a single medium is
expressed as the hazard quotient (HO), which is the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the contaminant's RfD. By adding the HOs
for all contaminants within a medium or across all media to which a given population may
reasonably be exposed, the Hazard Index (HI) can be generated. The HI provides a useful
reference point for gauging the potential significance of multiple contaminant exposures within a
single medium or across media. . .
Risk evaluations for arsenic, cadmium, total chromium, hexavalent chromium and molybdenum
were conducted and the results are summarized in Table VI-6. Chronic risk evaluations
conducted for non-carcinogenic effects of arsenic, cadmium, chromium and molybdenum for
Mure residents of the Site are less than one for all pathways, indicating that non-carcinogenic
adverse health effects are unlikely to occur. Exposures to cadmium, chromium (total), hexavalent
chromium and molybdenum were evaluated. Ingestion of contaminated produce and dust
represent the greatest non-carcinogenic health hazard with a combined hazard index value of
0.58. Molybdenum presents the greatest chronic health risk with a hazard risk index value of
0.43.
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TABLE VI-6
SUMMARY OF HEALTH RISKS FOR RESIDENTS POTENTIALLY EXPOSED TO
SOILS CONTAMINATED WITH ARSENIC, CADMIUM, CHROMIUM AND MOLYBDENUM
Arsenic
Cadmium B.8E-05 1.2E-02 5.3E-02 6.5E-02
Chromium (Total) 1.0E-06 1.7E-04 4.5E-05 1.5E-01 1.5E-01
Chromium VI 8.9E-06 1.6E-03 4.1 E-04 5.8E-03 7.8E-03
Molybdenum 3.9E-04 6.9E-02 3.6E-01 4.3E-01
Hazard Index Sum 1.8E-03 3.2E-01 4.6E-01 1.6E-01 9.4E-01
Arsenic
Cadmium
1.7E-08
5.8E-08
1.7E-08
Chromium VI
5.8E-08
Carcinogenic Risk
Sum
3.0E-07
1.1 E-05
1.2E-OS
2.SE-07
2.3E-OS
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..
Ingestion of produce and dust results in the greatest amount of cancer risk, with cancer risks
approximating 1 x 10-5 for each pathway. The cancer risk resulting from ingestion of soil is 3 x
10.7. Cancer risks for ingestion of contaminated media were evaluated for arsenic only as oral
cancer slope factors are not available for cadmium and hexavalent chromium. Inhalation of dust
results in a cancer risk of approximately 2 x 10.7 and these risks are attributable to the presence
of arsenic, cadmium and hexavalent chromium. The total cancer risk for all four pathways is
approximately 2 x 10.5.
A summary of risks due to lead exposure is presented in Table VI-7. The evaluation of lead risks
involved using the IU/BK model to establish daily intake levels of lead and to estimate the
distribution of blood-lead levels for two-year old children. Based on the results of the model, two
significant exposure pathways were identified: ingestion of lead in soil and indoor dust and
ingestion of contaminated produce. The mean blood-lead levels estimated for these two exposure
pathways were 4.88 !1g/dL and 6.55 !1g/dL, respectively. To ensure that lead exposure will not
be detrimental to children, no more than 5 percent of the predicted blood-lead levels can exceed
1 0 ~tg/dL. According to the IU/BK model results, exposure to soil and dust alone would result in
2 percent of exposed children having a blood-lead level exceeding 10 !1g/dL. However, 11.4
percent of exposed 2 year old children would have blood-lead levels exceeding 10 !1g/dL due to
exposure to contaminated soil, dust, and produce. Therefore, under a future residential
development scenario, exposures resulting from ingestion of lead-contaminated soil, dust and
produce are unacceptable.
Finally, highly alkaline soils represent a potential source of future health risks. Health risks could
include dermatitis, skin irritation, and possible eye damage.
TABLE VI-7
SUMMARY OF HEALTH RISKS ASSOCIATED WITH LEAD EXPOSURE FOR 2 YEAR OLD
CHILDREN
-~--
Ingestion of soil and 4.88 2.0 Acceptable
indoor dust
Ingestion of soil, indoor
dust and produce
6.55
11.4
Unacceptable
*
Health risk is considered unacceptable if percentage of children with blood-lead levels exceeding 10,ug/dL
is greater than 5 percent
Action Levels
Concentrations that would be protective of human health and the environment were determined
as part of the FFS and BRA. A soil action level for lead, which was based on acceptable blood
lead levels in children, was determined to be 500 mg/kg in Site soils. In addition, since arsenic
could not be excluded as a potential chemical of concern, a soil action level of 70 mg/kg for
arsenic was determined. Although an action level for alkalinity was not quantified, it was
determined that exposure to highly alkaline soil should be prevented.
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Uncertainty Analvsis
The risk evaluations for the Site are subject to an indeterminate amount of uncertainty. Major
areas of uncertainty include: sampling and analytical results, toxicological data, estimation of
exposure point concentrations and exposure parameters used to characterize frequency, duration
and mode of exposure. Additionally, the level of exposure depends on the future use of the Site,
which mayor may not be residential.
Summary of Human Health Risks
The unacceptable primary health hazards associated with the Site are due to the presence of lead
and potentially arsenic in soils as well as the alkalinity of the soil. Additionally, the chrome-
bearing bricks present a potential risk. Health risks associated with the remaining contaminants
of potential concern were found to be within acceptable limits. The calculated potential cancer
risk falls within EPA acceptable risk range of 1 x 10-4 to 1 x 10-6. This cancer risk is likely to be
an overestimate due to the conservative assumptions used to calculate exposure levels and risks.
Non-carcinogenic adverse health effects are not likely to occur as a result of residential exposures
to contaminated soils at the Site.
ENVIRONMENTAL RISKS
Environmental risks are often difficult to quantify. No attempt was made at such quantification
in the BRA. Environmental risks were qualitatively evaluated under OU1 and it is assumed that
the same issues will be a concern for OU2 after implementation of the OU1 remedy. These
issues are summarized below:
First, contamination on the Site has severely altered the vegetation and the transport of
contaminated dust and soil off site has the potential to adversely impact vegetation in neighboring
areas. Most of the impact on vegetation may be due to high alkalinity.
Second, ponded water on the Site may cause burns to terrestrial wildlife, including numerous
avian species which might use the nearby Surplus Canal as a nesting and feeding area.
Third, the molybdenum present in the soil on the Site has the potential for causing adverse effects
to any livestock in the immediate area.
Finally, fish in the Jordan River and Surplus Canal could be adversely effected by caustic run-off
from the Site. Although such effects were not evident during site characterization work, they
could occur in the future. No listed or candidate threatened or endangered species are known
to occur in the vicinity of the Site.
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:
VII. Description of Alternatives
An FFS was conducted to develop and evaluate remedial alternatives for OU2. Remedial
alternatives were assembled from applicable remedial technology process options and were
initially evaluated for effectiveness, implementability, and cost. The alternatives meeting these
criteria were then evaluated and compared to nine criteria as required by the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). In addition to the remedial
alternatives, the NCP requires that a no-action alternative be considered at every site. The no-
action alternative serves primarily as a point of comparison for other alternatives.
The development of alternatives was based on the following remedial action objectives:
.
to eliminate risks associated with exposure to soils with elevated levels of lead, arsenic and
alkalinity;
to eliminate exposure to chromium and to meet the ARARs associated with storage,
treatment and disposal of the chrome-bearing bricks, which are a characteristic hazardous
waste;
to minimize restrictions on future Site use;
to reduce exposure to potential windblown contaminants; and
to eliminate a potential source of groundwater contamination.
.
Quantities of soil which were considered in the alternatives analysis were calculated using risk-
based action levels which were developed to meet the remedial action objectives. These action
levels are 500 mg/kg for lead and 70 mg/kg for arsenic. Treatment levels described under each
alternative are based on ARARs.
To eliminate the potential risk from exposure to lead in Site soils and highly alkaline soils and to
meet ARARs associated with the chrome-bearing bricks, several remediation technologies were
evaluated, including: containment; treatment via chemical fixation, chemical precipitation and
solidification; and disposal. Some of these technologies were combined to develop the following
site-specific remediation alternatives:
No Action;
limited Action involving on-site treatment and otf-site/on-site disposal of chrome-bearing
bricks along with placement of a soil cover and institutional controls;
On-Site Treatment and Off-Site Disposal of contaminated soils above action levels and
chrome-bearing bricks, with placement of a soil cover; and
On-Site Treatment and On-Site Disposal of contaminated soils above action levels and
chrome-bearing bricks.
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"
No Action Alternative
The No Action Alternative, which must be considered according to the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA) and the NCP, would involve
no additional remedial action beyond that which is planned during the cleanup of OU1. The
selected remedy for OU1 includes removal of some contaminated soil and co-disposed materials,
although the quantities are not certain. The chrome-bearing bricks would be left on site. Based
on data from the sampling of OU2 soils, it may not be possible to dispose of some of the
contaminated soils without prior treatment due to the lDRs promulgated under RCRA. There is
currently a chain-link fence around the Site to limit access to the Site. The fence would probably
be left in place during and after remediation of OU1. Finally, the selected remedy for OU1
provides for initiation of groundwater monitoring.
However, even with these limited actions in place atter completion of the remedy forOU1, the
future risks described in the BRA for OU2 under a residential development scenario will not be
mitigated or eliminated. There are no costs associated with the No Action Alternative. If the No
Action Alternative. is implemented, Ap.plicable or Relevant and Appropriate Requirements
(ARARs), as identified in Exhibit 1, would not be met.
Limited Action
The Limited Action Alternative includes minimal remedial action required to meet ARARs and
decrease Site risks. The Limited Action Alternative includes on-site treatment of approximately
360 tons of chrome-bearing bricks by chemical fixation/solidification, with subsequent off-site
disposal. Chromium levels would be reduced to less than 5 mg/l, as measured by TCl?
analysis. The FFS indicated that this treatment level could be met using these technologies. At
this treatment level, the treated bricks would not be considered a hazardous waste and could be
land-disposed in a solid waste disposal facility. However, if the chromium level in the chrome-
bearing bricks cannot be reduced to less than 5 mg/l, the treated bricks would still be classified
as a D007 hazardous waste. The land Disposal Restrictions (lDRs), as promulgated under
RCRA, prohibit land disposal of 0007 hazardous waste unless it is treated so its chromium
concentration is 5 mg/l or less, as measured by TCl? analysis.
The Limited Action Alternative also includes construction of a protective cover approximately 18
inches thick of clean fill over the entire Site and the backfilling of any excavation scars remaining
from OU1 remediation to mitigate risks from exposure to lead-contaminated and highly alkaline
soils and windblown dust. The soil cover would also allow minimal revegetation of the Site and
minimize physical hazards on the Site. Finally, institutional controls would be implemented to
ensure that future construction activities are protective of human health, maintain the soil cover
and do not result in off-site transport of contaminated materials above health-based levels.
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, .
Under this alternative, all of the exposure pathways identified in the BRA would be addressed.
This alternative would be cost-effective but would require long-term monitoring to ensure the
remedy continues to provide adequate protection. Additionally, this alternative requires issuance
and enforcement of strict zoning and deed restrictions by the local government. Agreement
regarding the placing and enforcement of restrictions would need to be obtained to ensure the
protectiveness of the remedy. Furthermore, this alternative would not eliminate the potential
source of groundwater contamination. As part of the FFS, the total present value cost associated
with this alternative was estimated to be approximately $2.93 million. This cost includes
operations and maintenance costs of approximately $113,000 over a period of 30 years and a
discount rate of 10 percent. The FFS estimated that it would take less than one year to
implement this alternative.
On-Site Treatment and Off-Site Disposal of Contaminated Soil and Chrome-BearinQ Bricks
This alternative provides permanent treatment of all surficial soils with contaminant levels greater
than 500 mg/kg lead or 70 mg/kg arsenic. The exact volume of contaminated soils requiring
treatment would be identified during the design and implementation of the remedy. During the
FFS. the volume of contaminated soil and chrome-bearing bricks to be processed were estimated
to be approximately 27,000 cubic yards and 360 tons, respectively.
Treatment of the soils would be accomplished by solidification, and the chrome-bearing bricks
would be treated using chemical fixation followed by solidification. All treatment would occur on
site. The FFS indicated that currently established treatment levels for chromium and lead of 5
mg/L, as measured by TCLP analysis, could be met using these techniques. By reducing lead
and chromium levels to less than 5 mg/L, the treated soil and chrome-bearing bricks would no
longer be considered hazardous wastes and could be land-disposed off site in a solid waste
disposal facility.
Following removal of the contaminated soil, a protective cover consisting of approximately 18
inches of clean backfill would be installed, as described under the Limited Action Alternative. The
actual thickness of the cover may need to be greater depending upon the depth of excavation and
to prevent low areas from filling with ponded water.
This alternative will comply with identified ARARs, which include LDRs. Institutional controls, if
required, would be much less stringent and lengthy than for the Limited Action Alternative, since
soils above acceptable lead and arsenic levels would be removed. The remedial action can be
designed to enhance equalization of the remaining highly alkaline soil. This would also lessen
the need for institutional controls. The type of and period of time during which institutional
controls would need to remain in place would be determined during remedial design. This
alternative would also lessen the potential release of any additional contaminants to groundwater.
The costs associated with this alternative were estimated during the FFS to be approximately $6.4
million present value. This does not include operations and maintenance costs, as they were
assumed to be negligible.
The FFS predicted that implementation of this alternative would take less than one year and could
be accommodated within the OU1 remediation schedule to take advantage of the equipment
mobilization already planned for the Site.
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"
On-Site Treatment and On-Site Disposal of Contaminated Soil and Chrome-Bearing Bricks
This alternative provides permanent treatment of all surficial soils with greater than 500 mg/kg
lead or 70 mg/kg arsenic, as well as treatment and on-site disposal of all chrome-bearing bricks.
As with the previous alternative, the exact volume of contaminated soils requiring treatment would
be identified during the design and implementation of the remedy. The volumes of contaminated
soil and chrome-bearing bricks that need to be processed were estimated during the FFS to be
approximately 27,000 cubic yards and 360 tons, respectively.
Treatment of soils would be accomplished by solidification and treatment of chrome-bearing bricks
would be by chemical fixation followed by solidification. All treatment would occur on site.
Following removal of the contaminated soil, a protective cover approximately 18 inches of clean
backfill would be constructed, as described under the Umited Action Alternative. The actual
thickness of the cover may need to be greater depending upon the depth of excavation and to
prevent low areas from filling with ponded water.
The treated material would be placed on-site in a location and form to be determined during
remedial design. Institutional controls, if required, would be less stringent than for the Limited
Action Alternative since all human exposure pathways would be addressed. Deed restrictions
may be necessary to prevent the treated material and the protective soil cover from being
disturbed. The potential source of groundwater contamination would be addressed.
Capital costs for this alternative were estimated during the FFS to be approximately $5.6 million
present value. Operations and maintenance costs were assumed to be negligible.
This alternative would comply with identified ARARs, including LDRs. The soil and chrome-
bearing bricks would be treated to a lead and chromium levels of less than 5 mg/L, respectively,
as measured by TCLP analysis.
In the FFS, i1 was estimated that this alternative could be implemented in less than one year and
could be accommodated within the OU1 remediation schedule.
Table VII-1 summarizes the remedial alternatives. For the purposes of evaluating the remedial
alternatives, volumes and quantities calculated during previous investigations were utilized. It was
assumed that a total of 27,000 cubic yards of soil contains greater than 500 mg/kg lead or 70
mg/kg arsenic; therefore, this amount will require treatment prior to disposal. Additionally, 360
tons of chrome-bearing bricks will need to be treated prior to disposal to comply with LDRs, and
170,400 cubic yards of soil will be required for an 18-inch thick protective soil cover.
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. .
, .
..
TABLE VlI-1
SUMMARY OF REMEDIAL ALTERNATIVES
_'I'
. No action will be taken at this time to address Site contaminants or LOR
ARARs.
-.
. Treatment of 360 tons of chrome-bearing bricks by chemical fixation/solidification,
with subsequent off-site disposal in a solid waste landfill;
. Placement of 1 70,400 cubic yards of soil to provide at least 1 8 inches of cover at
the Site; and
. Implementation of deed restrictions and other institutional controls as necessary to
mai ntain adequate protection from contaminants above health-based levels.
__,.,.
. Treatment by solidification of 27,000 cubic yards of soil contaminated with lead
above 500 mg/kg and/or arsenic above 70 mg/kg and off-site disposal;
. Treatment of 360 tons of chrome-bearing bricks by chemical fixation/solidification
and off-site disposal; and,
. Placement of 1 70, 400 cubic yards of soil to provide at least 1 8 inches of cover at
the Site.
. Deed restrictions and/or other institutional controls as necessary to assure
effectiveness of remedy.
. Treatment by solidification of 27, 000 cubic yards of soil contaminated with greater
than 500 mg!kg lead and/or 70 mg/kg arsenic and on-site disposal;
. Treatment of 360 tons of chrome-bearing bricks by chemical fixation/so lidification
and on-site disposal;
. Placement of 1 70, 400 cubic yards of soil to provide at least 1 8 inches of cover at
the Site; and
. Deed restrictions and/or other institutional controls as necessary to assure
effectiveness of remedy.
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, ,
"
.'
VIII. Summary of Comparative Analysis of Alternatives
The four remedial alternatives developed in the FFS were analyzed in detail using nine criteria:
1) overall protection of human health and the environment, 2) compliance with ARARs, 3) long-
term effectiveness and permanence, 4) reduction of toxicity, mobility or volume through treatment,
5) short-term effectiveness, 6) implementability, 7) cost, 8) state acceptance. and 9) community
acceptance. The evaluation of each criterion for the four alternatives is presented below. Table
VIII-2 summarizes the comparative analysis of alternatives that was conducted as part of the FFS.
Protectiveness of Human Health and the Environment
The On-Site Treatment and Off-Site Disposal Alternative assures the greatest protectiveness
since disposal will occur in a controlled environment such as a landfill and also employs treatment
to eliminate the principal threats associated with the contaminated soil and chrome-bearing bricks
and to stabilize hazardous levels of lead and arsenic from the contaminated soil and chromium
from the chrome-bearing bricks. Remaining Site soils would have a lead concentration of 500
mg/kg or less and an arsenic concentration of 70 mg/kg or less. Treated soil and chrome-bearing
bricks would have lead and chromium levels of less than 5 mg/L as measured by TCLP analysis.
The On-Site Treatment and On-Site Disposal Alternative is less protective than the alternative
utilizing off-site disposal since disposal would not occur in a controlled environment. However,
this alternative is still somewhat protective because, similar to the Off-Site Disposal Alternative,
it employs treatment of contaminated soil and chrome-bearing bricks.
The soil cover would eliminate the risk of direct exposure to highly alkaline soils and would also
mitigate the potential risk from ingesting produce grown in soil contaminated with lead and
arsenic. These two alternatives al~o eliminate a potential source of groundwater contamination.
However, some restrictions may be needed for the On-Site Disposal Alternative to assure that the
protective soil cover and treated soil are not disturbed.
The Limited Action Alternative would provide a barrier for direct contact with highly alkaline soils
and would eliminate the risks associated with the chrome-bearing bricks. However, the Limited
Action Alternative, specifying no treatment of soils, would leave untreated contaminated soil above
action levels. This alternative would require institutional controls to prevent exposure to the
contaminants. . Future construction activities on the Site would be subject to restrictions.
Untreated soils may continue to leach high amounts of contaminants into groundwater.
The No Action Alternative does not adequately protect human health and the environment.
Compliance with ARARs
All but the No Action Alternative can meet all identified ARARs, as shown in Exhibit 1. These
alternatives would comply with the LDRs. as appropriate.
The No Action Alternative does not address nor comply with ARARs associated with the storage,
treatment, and disposal of chrome-bearing bricks.
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"
"
Long-Term Effectiveness and Permanence
The On-Site Treatment and Off-Site Disposal Alternative would provide the greatest long-term
effectiveness and permanence since it would permanently treat all contaminated soils that are
above health-based action levels for which an existing exposure pathway is present and allow for
the disposal of the treated material in the controlled environment of a solid waste landfill. In a
landfill, release to the environment is prevented in the occurrence of a breakdown of the
treatment. The On-Site Treatment and On-Site Disposal Alternative would provide less long-term
effectiveness and permanence since disposal would be in a less controlled environment and will
rely on institutional controls to maintain effectiveness of the remedy. These two alternatives
would provide greater long-term effectiveness and permanence than the Limited Action Alternative
in which contaminated soils above action levels would remain on site.
The protective soil cover placed over the contaminated soil in the Limited Action Alternative would
provide a relatively high level of long-term effectiveness, but would require long-term maintenance
and institutional controls, .
The No Action Alternative would not address the contaminated soils nor the chrome-bearing
bricks on the Site. Soil contaminants would continue to be able to migrate to the air, surface
water, and groundwater, and would remain a threat to human health and the environment.
Potential exposure to the chrome-bearing bricks would still exist and ARARs associated with
hazardous waste storage and disposal would not be met.
Reduction of Toxicitv. Mobilitv. or Volume Throuah Treatment
All but the No Action Alternative would provide permanent reduction in toxicity and mobility of the
chromium in the chrome-bearing bricks through chemical transformation of the chromium and
solidification of the crushed brick material. The treatment of the contaminated soils in the two soil
treatment alternatives will permanently reduce the toxicity and mobility of the lead and arsenic in
the soils. The Limited Action Alternative would not reduce the toxicity or mobility of the
contaminated soils.
The No Action Alternative would not reduce the toxicity, mobility, or volume of contaminants in
the contaminated soil nor in the chrome-bearing brick.
Short-Term Effectiveness
All but the No Action Alternative involve the on-site crushing of chrome-bearing brick prior to
treatment. This activity may generate dust, which may be reduced by using engineered controls.
Workers would be required to wear appropriate protective equipment. There would be an
increase in the probability of traffic-related accidents associated with transport of backfill to the
Site, but these impacts could be minimized through implementation of appropriate transportation
safety measures. For the two contaminated soil treatment alternatives, dust generation during
excavation and treatment of contaminated soils could increase risks. Therefore, dust suppression
measures, air monitoring, and appropriate personal protective equipment for on-site personnel
would be included to mitigate potential impacts to on-site workers and surrounding populations.
All alternatives except the No Action Alternative would take less than one year to implement. The
probability of traffic-related accidents would also increase with the On-Site Treatment and Off-Site
Disposal Alternative, but those impacts could be minimized through implementation of appropriate
transportation safety measures.
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. ,
"
Under the No Action Alternative, no dust suppression methods would be employed following
completion of remedial action for OU1. Potential hazards associated with windblown dust and
airborne contaminants from the Site may be expected when surface soils dry following
remediation of OU1. Risk associated with on-site contaminants would remain.
Implementabilitv
All of the alternatives can be implemented with varying degrees of difficulty and within a similar
time period of less than one year. The equipment for treating the contaminated soils and chrome-
bearing bricks is readily available from several vendors and treatment technology is well
demonstrated for the Site soils and the contaminant levels present at the Site. Bench-scale or
pilot tests to determine relative quantities of the treatment ingredients will likely be conducted
during the remedial design phase. The soil treatment process could be accommodated within the
OU1 remediation schedule for use of equipment already planned for the Site. Preliminary
treatability studies and previous experience indicate that solidification of the brick and chemical
transformation of the chromium would be itnplementable. Equipment for crushing the bricks is
available from several vendors. Importation and installation of a clean backfill cover under all but
the No Action Alternative are easily implementable using readily available earth moving
equipment. Institutional controls such as deed restrictions, which are required by the Limited
Action and On-Site Disposal Alternatives, may be implemented, but will require the cooperation
of the local government. Presently there is sufficient capacity at existing off-site solid waste
landfills to accommodate the anticipated amounts of treated and solidified soil and bricks.
Cost
As developed iri the FFS, Table VIII-1 lists the estimated costs for each evaluated alternative in
order of increasing total cost. Capital costs include the expense of: mobilization/demobilization,
treatment, sampling and analysis, disposal and reclamation. Operations and maintenance costs
include major institutional controls and long-term monitoring and have been calculated for a period
of 30 years at a 10 percent discount rate. Costs are in thousands of dollars.
TABLE VlII-1
SUMMARY OF ESTIMATED COSTS FOR REMEDIAL ALTERNATIVES
111111111111111111111111111111111111111111111111111\11111111 11111111111111111111111I1111111111111111111111111111 - 111:lllllllllllllllrlllllllllllllllllllllllllllllll
No Action $0 $0 $0
Lim ited Action $2 ,8 1 1 $1 1 3 $2 ,926
On-8 ite Treatm ent/ $5,654 $0 $5 ,654
On-S ite Di sposal
On-S ite Treatm ent/ $6,41 8 $0 $6 ,41 8
Off-S ite Di sposal
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State Acceptance
The State conducted the RI/FFS for OU2 and issued the Proposed Plan. In the Proposed Plan,
the State identified On-Site Treatment and On-Site Disposal as the preferred alternative. Due to
the public comment received and concerns with maintaining the effectiveness of the treated
material on site, the State now considers the On-Site Treatment and Off-Site Disposal Alternative
as the best alternative.
Community Acceptance
The majority of comments received were in opposition to the No Action and Limited Action
Alternatives. Several comments supported the preferred alternative stated in the Proposed Plan,
which was On-Site Treatment and On-Site Disposal. Most area residents, business owners, and
Site land owners felt the reliance on institutional controls was not adequate and were concerned
that the development of the land would be limited by on-site disposal. In the same comments,
concern was also voiced regarding depreciated property values. Many comments questioned the
permanence' of the solidification and expressed concern about monitoring the material for the
continued effectiveness of the treatment. The majority of comments stated a preference for off-
site disposal of the treated material in a controlled landfill environment.
All local officials wanted the contaminated soils and chrome-bearing bricks treated and most
wanted the treated material disposed of off site. The Salt Lake City and County Health
Department suggested the material should be removed to a hazardous waste facility for treatment
and disposal.
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:.R~.ia(..
.:~~~~~~~v!:.
No Action
Umited
Action
. ... .
protCcti~ of H~:'", ,
Hea~ ~~" ~nd ;~nv.i~~~
. Long- term hlMllan health
and eovi rarmental threats
are not addressed.
. Current e.ll:posure
pathways are addressed.
. Contamination above
health based levels will
remain at the 5i te
requiring long-term
management.
TABLE VIII-2
SUMMARY OF DETAILED EVALUATION OF REMEDIAL ALTERNATIVES
p''''''',", ....
"'R~ti'~-'~{:': ..". .-::;::...
~. .~:~ ~ ~.t~:::,:~~.~.1~.-~~;:~~.~.;:;
. Does not
carply with
ARARs.
. Does not resul t In
any reduction.
. No short-term
in-pacts.
. Short-term i~acts
from dt reet exposure
are mit igated by
engineering controls.
. Short-term in-pacts
from increased truck
traffic may occur.
.;~~~ii;~i~~iy~.~..
. Does not provide any
long. term effectiveness
or permanence.
. Permanence depends
on ma i nteoance of
Institutional controls.
. N/A.
. Easily
;n-plemented wi th
read II y
avai lable
equi JXIlCnt and
demonstrated
technologies;
. Institutional
controls require
locel goverlYl'lCnt
cooperat i 00.
. No di rect cost.
Indirect costs Include
loss of property value,
heal th costs.
. Not
acceptable.
. Meets
ARARs.
. Reduces toxicity
and mobll i ty 01
chrome-bearing
bricks.
. Not
acceptable.
. Total capital and
OIH costs: $2.93
million.
. Not
acceptable.
. Not
occeptabl e
to majority
. Ooes not resul tin
any reduction in
soils toxicity.
OneSite . Current and future . Meets . Reduces toxici ty . Short. term impacts . Treatment provides . Eas il y . Capi tal costs: . Acceptable. . Hostly
Treatment exposure pathways are ARARs. and mobil ity 01 from direct exposure permanent and effective in-plemented with $6. ~2 mil II on. acceptable
and Off.site addressed. chrome in chrome. are mit Igated by long' term remedy. readi I y to majority
Disposal bearing bricks and engineering controls. ava; lable . O/H: 50
. lead and chromiun lead in soils. . Institutional equiJXllCnt and
contamination above controls. (f necessary, demonstrated
health-based 8ction would be less stringent technology.
levels is el iminoted. that other
alternatives. . Institutional
controls may
requi re local
goverrment
coo rat Ion.
On.Slte . Current and future . Meets . Reduces toxiGi tv . Short. term iR1Jacts . Treatment provides . Easily . Copi tal costs: . Harglnall y . Not
Treatment exposure pathways are ARARs. and mobil i ty 01 from di rect exposure permanent and effective in-plemented with $5.65 million. Acceptable. acceptable
and On- Site addressed. chrome in chrome. are mi t igated by long-term remedy. readi I y to majority
Disposal bearing bricks and engineering controls. avoi lable . O/H: $0 I
. lead and chromium lead in soils. . Requi res some equiJXllCnt and
contamination above institutional controls demonstrated
heal th-based act ion to assure effectiveness technology.
levels is el iminoted. of treatment.
. Institutional
controls may
requi re local
goverrvnent
coo fation.
28
~. :
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. .
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'.
IX.
Documentation of Significant Changes
The preferred alternative identified in the Proposed Plan was On-Site Treatment with On-Site
Disposal. Under this alternative, the treated material would be left on site in an uncontrolled
environment. The Proposed Plan preferred alternative relied on institutional controls to maintain
the effectiveness of the treatment. The treated material would be subject to changing
environmental conditions on the Site. The selected remedy, On-Site Treatment and Off-Site
Disposal, provides greater permanence and assured effectiveness than the on-site disposal
conditions previously described. Additionally, the cost difference between the on-site and off-site
disposal.of the treated material is relatively small. These factors, which were brought out during
the public comment period, influenced the decision to choose on-site treatment with off-site
disposal as the selected remedy over the proposed plan preferred alternative.
The Proposed Plan also discussed the possible use of a treatability variance to modify treatment
levels required for land disposal. Further review of EPA guidance regarding treatability variances
indicates that the variance is not applicable to the types of hazardous waste present at the Site.
As a result of public comments, the use of institutional controls is more thoroughly explained in
the Description of Alternatives and Selected Remedy sections of this ROD. Additionally, limiting
controls restricting use of the Site was added to the remedial action objectives. For the Proposed
Plan preferred alternative, institutional controls would be needed to assure the treated material
disposed of on site is not disturbed, thereby changing the treatment effectiveness. Institutional
controls would also be necessary to prevent exposure to the remaining highly alkaline soils
remaining on site. The selected remedy only requires institutional controls to prevent exposure
to the remaining highly alkaline soils. The protective soil cover could be designed to limit the
necessity for and/or duration of institutional controls. The length of institutional controls that are
needed will be determined during the remedial design. However, the required controls are
anticipated to be minimal compared to those required by the other remedial alternatives.
X.
The Selected Remedy
Based upon consideration of the requirements of CERCLA, the detailed analysis of alternatives
and public comments, both the EPA and the State of Utah have determined that On-Site
Treatment and Off-Site Disposal is the most effective remedy for OU2 at the Site.
The On-Site Treatment and Off-Site Disposal Alternative requires:
.
. soil above 500 mglkg lead and/or 70 mg/kg arsenic shall be excavated;
soil equal to or above 5 mglL, as measured by TCLP analysis, shall be identified and
treated by solidification; during the RI/FFS, it was determined that soil above 500 mg/kg
lead will likely be above 5 mglL lead as measured by TCLP analysis;
the chrome-bearing bricks shall be treated by chemical fixation followed by solidification;
all excavated and treated material shall be transported off site to an appropriate disposal
facility; and
a protective cover of clean fill at least 18 inches thick shall be installed over the Site.
.
.
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"
Institutional controls, if needed. will likely be imposed during or after design and implementation
of the remedy. The length of time during which controls are needed will be determined during
remedial design.
Remedial Action Obiectives
The conditions that will exist at the Site after the implementation of the OU1 remedy will
potentially present unacceptable risk from lead and potentially arsenic through soil, dust and crop
ingestion. The potential of skin bums or eye damage from the highly alkaline soils will present
an acute risk. There will also be risks at the Site that are associated with the chrome-bearing
bricks. Additionally, treatment of the bricks is necessary to meet ARARs associated with storage.
treatment and disposal of a hazardous waste.
The purposes of this remedial action are:
.
to eliminate risks associated with exposure to soils with elevated levels of lead, arsenic and
alkalinity;
to eliminate exposure to chromium and to meet the ARARs associated with storage,
treatment and disposal of the chrome-bearing bricks, which are a characteristic hazardous
waste;
to minimize restrictions on future use of the Site;
to reduce exposure to potential windblown contaminants; and
to eliminate potential sources of groundwater contamination.
.
.
Remediation Goals/Action Levels
The action level for lead in soil is based upon an acceptable blood-lead level in children exposed
to the soil through ingestion and has been rounded to 500 mg/kg. The rounded action level will
provide an easy analytical determination 01 when sufficient removal of soil has occurred. At this
concentration, a significant number of children should not have a blood-lead level above the
acceptable level of 10 J.tg/dL.
An action level for arsenic of 70 mg/kg is also provided. Although arsenic levels above 70 mg/kg
were not detected on site, the action level is provided because arsenic could not be ruled out by
statistical analysis as a contaminant of concern. At this arsenic concentration, there is a 2 x 10-5
risk of cancer for the ingestion of soil and a 5 x 10-5 risk of cancer through ingestion of produce
grown in Site soil.
Since an action level for alkalinity was not determined, the selected remedy does not require
removal of soil exceeding a specific pH or alkalinity. However, the clean layer 01 fill placed as
part of the selected remedy shall provide protection from exposure to the highly alkaline soils
remaining on site. The fill layer, as designed, should enhance remaining soil pH equalization to
levels near background and limit the restrictions on future use of the Site.
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"
f"
Institutional Controls
Institutional controls necessary to protect exposure to the remaining highly alkaline soils will be
determined during or after the design and implementation of the remedy, The time period during
which controls that are needed shall be part of the determination. Methods for limiting the
number and type of conditions or length of time needed shall also be considered in the remedial
design. The controls shall remain necessary as long as there is potential for exposure to highly
alkaline soils. Additionally, the controls needed under OU2 shall consider actions taken under
other OUs on the Site.
Treatment Levels
Treatment levels for soil ar~ dictated by LDRs. These restrictions require all hazardous wastes
to have a lead level of 5 mg/L or less, as measured by TCLP analysis, before land disposal can
occur. The 5 mg/L lead concentration, as measured by TCLP analysis, is also used to determine
if a solid waste is a D008 characteristic hazardous waste. -Solid waste with lead TCLP levels
equal to or greater than 5 mgIL are defined as characteristic hazardous wastes with the waste
code designation D008. Soils above this level were found on site. Thus, all soil above this level
will be treated to below the 5 mg/L lead level, as measured by TCLP analysis so it will no longer
be classified as a hazardous waste and can be managed as a solid waste.
Treatment levels for the chrome-bearing bricks are also dictated by LDRs. The chrome-bearing
bricks are a characteristic hazardous waste for chromium, with a waste code of 0007. The
chrome-bearing bricks must be treated to a chromium level, as measured by TCLP analysis, '
below 5 mg/L prior to land disposal. When the chrome-bearing bricks are treated to below this
level, they will no longer be considered a hazardous waste and can be managed as a solid waste.
Volumes and Cost
The estimated volumes and cost associated with implementation of the selected remedy are
presented in Table X-1. The costs associated with Item 5 are based on figures supplied in the
original FS conducted by Lone Star and have been updated to 1991 dollars at a 7 percent interest
rate.
XI.
Statutory Determinations
EPA's primary responsibility at Superfund sites is to select remedial actions that are protective
of human health and the environment. CERCLA also requires that the selected remedial action
for the Site comply with applicable or relevant and appropriate environmental standards
established .under Federal and State environmental laws, unless a waiver is granted. The
selected remedy must also be cost-effective and utilize permanent treatment technologies or
resource recovery technologies to the maximum extent practicable. The statute also contains a
preference for remedies that include treatment as a principal element. The following sections
discuss how the selected remedy for OU2 meets these statutory requirements.
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Protection of Human Health and the Environment
The selected remedy would remove two contaminant sources from an area of relatively high
population that is subject to increased urbanization, thereby providing the maximum reduction of
the risks of direct contact and exposure to blowing dust and removing a potential source of
groundwater contamination. The contaminated soil and chrome-bearing bricks will be treated to
eliminate or reduce associated health risks both on the Site and at the off-site disposal facility.
The selected remedy is considered to be highly protective of human health and the environment.
The implementation of the remedy will not pose unacceptable short-term risks. The selected
remedy will enable the final remediation of the Site by removing potential sources of groundwater
contamination.
TABLE X-1
ESTIMATED COSTS OF THE SELECTED REMEDY
On-Site Treatment and Off-Site Disposal
(1991 Dollars)
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Item Descri ption Un it U nit Cost Tota I Cost
1 Treatment of chrom e-bearing 360 Tons 1 80 $ 65, 000
bri cks
2 Ge neral Lu mp S u m 5, 000 $ 5 , 000
mobilization/demobilization
3 M obile sam piing/analysis 1 0 days 850 $ 8, 000
4 Treat soi I 27, 000 c.y. 80 $ 2 , 1 60, 000
5 Haul, dispose treated material oft 44,550 tons 1 3 $ 579, 000
site at a city/county landfill
6 Haul , grade, compact clean fill 1 70, 400 c.y. 1 2 $ 2 , 045, 000
.
S u btotal $ 4, 862 , 000
Conti ngency (20%) $ 972, 000
Su btotal $ 5, 835, 000
Engineering/ Admi nistrative (1 0%) $ 583, 000
Total Capital Cost $ 6 , 41 8, 000
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Attainment of Applicable or Relevant and Appropriate Requirements (ARARs) of
Environmental Laws
The primary requirements that are applicable or relevant and appropriate to the selected remedy
are:
.
Federal and State solid waste disposal regulations;
Federal land disposal restrictions pertaining to storage of hazardous waste;
Federal land disposal restrictions pertaining to the treatment of hazardous waste prior to
land disposal; and
Federal and state air regulations on total suspended particulates and fugitive dust control.
.
The selected remedy will meet all ARARs. A summary of ARARs and guidelines to be considered
(TBCs) for the selected remedy is presented in Exhibit 1.
Cost-Effectiveness
CERCLA. requires that the selected remedy afford overall effectiveness proportional to its costs.
According to the estimates provided in the FFS, the cost of the selected remedy will be
approximately $6:4 million. This cost is the highest of the four alternatives. However, there is
no entirely objective method of assigning a value to overall effectiveness and it is difficult to
quantify costs associated with ineffectiveness. The selected remedy provides the greatest long-
term effectiveness and overall protection of human health and the environment of all the
alternatives evaluated. The additional cost over the On-Site Disposal Alternative assures that the
remedy remains effective.
Utilization of Permanent Solutions and Alternative Treatment Technoloqies
The selected remedy utilizes permanent solutions to the maximum extent possible. The selected
remedy reduces the toxicity and mobility of the chrome-bearing bricks and soil through treatment.
The treatment renders the material a non-hazardous waste, which eliminates the requirement to
manage and monitor the material according to the hazardous waste regulations. By requiring the
off-site disposal in a controlled environment, such as a landfill, the selected remedy assures
greater permanence than if on-site disposal occurred. Under on-site disposal the material would
be left in an uncontrolled environment with little or no monitoring of the continued treatment
effectiveness. The cost of attaining this assurance of treatment permanence and addressing the
concerns of the public is relatively small. Finally, the selected remedy is easily implemented and
could be accommodated within the OU1 remediation.
Preference for Treatment as a Principal Element
The selected remedy will utilize treatment as a principal element to address the principal threats
at the Site. Contaminated soil and the chrome-bearing bricks will be treated using proven
technologies to reduce hazardous levels of lead and chromium, respectively. Planned treatment
levels of below 5 mg/L lead and chromium, as measured by TCLP analysis, will enable the
treated material to be removed from classification as a hazardous waste and to be land disposed
as a solid waste.
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List of Acronyms
ARAR:
BRA:
CERCLA:
CKD:
CPF:
EPA:
FFS:
HEAST:
HQ:
IRIS:
IU/BK:
LDR:
m':
MF:
mg/L:
NCP:
NPL:
au:
PCU:
PRP:
RCRA:
RfD:
RI:
SARA:
SF:
TCLP:
UDEa:
UF:
pg/dL:
Applicable or Relevant and Appropriate Requirement
Baseline Risk Assessment
Comprehensive Environmental Response, Compensation and Liability Act
Cement Kiln Dust
Cancer Potency Factor
U.S. Environmental Protection Agency
Focused Feasibility Study
Health Effects Assessment Summary Table
Hazard Quotient
Integrated Risk Information System
Integrated Uptake/Biokinetic (Model)
Land Disposal Restriction
cubic meter
Modifying Factor
milligrams per liter
National Oil and Hazardous Substances Pollution Contingency Plan
National Priorities List
Operable Unit
Portland Cement Company of Utah
Potentially Responsible Party
Resource Conservation and Recovery Act
Reference Dose
Remedial Investigation
Superfund Amendments Reauthorization Act
Slope Factor
Toxicity Characteristic Leaching Procedure
Utah Department of Environmental Quality
Uncertainty Factor
micrograms per deciliter (1 0-6 grams per 010 liter)
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Glossary
Action Levels: Levels of contamination in soil, air or water above which there is an
unacceptable risk. Action levels vary from site to site and even within sites, based on potential
exposure.
Administrative Record: A file which contains all information used by the lead agency to make
its decision on the selection of a response action.
Alkalinity: A chemical property of certain substances which have a pH greater than 7.
Applicable or Relevant and Appropriate Requirements (ARARs): Refers to the federal and
state requirements that a selected remedy is required to attain. They include requirements such
as allowable air emission limits and allowable levels of contaminants in site soils and surface
water.
Chemical Fixation: A chemical treatment process whereby chromium is made less toxic. The
process occurs prior to the solidification of the crushed brick material.
Groundwater: Water contained in sand, soil, rock or gravel particles beneath the earth's surface.
Rain that does not evaporate 'or immediately flow to rivers, streams and lakes seeps into the
ground, forming a groundwater reservoir. Typically, groundwater flows more slowly than surface
water and often discharges to streams, rivers and lakes.
Hazardous Waste: Under RCRA, a solid waste or combination of solid wastes which because
of quantity, concentration or physical, chemical or infectious characteristics may pose a threat to
human health or the environment.
Hazardous Substance: Under CERCLA, any element, compound, mixture, solution or substance
which, when released to the environment, is found by the EPA to present substantial danger to
public health, welfare or the environment.
pH: Used in expressing both acidity and alkalinity on a scale from 0 to 14, with 7 representing
neutrality. Numbers less than 7 indicate increasing acidity and numbers greater than 7 indicate
increasing alkalinity.
Institutional Controls: Controls, either legal or physical, which restrict individuals from coming
into contact with contaminated portions of a Superfund site. These controls include fencing,
warning signs and deed restrictions.
Mobility: The ability of a chemical to move through the environment.
National Priorities List (NPL): EPA's list of top priority hazardous waste sites that are eligible
for investigation and cleanup under the federal Superfund Program.
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Plume: The body of groundwater which has detectable concentrations of contaminants and
extends away from a source area of contamination, usually moving parallel to groundwater flow
direction.
Potentially Responsible Party (PRP): An individual(s) or company(ies) potentially responsible
for, or contributing to, the contamination problems at a Superfund site. Whenever possible, EPA
requires PRPs, through administrative and legal actions, to clean up hazardous waste sites they
have contaminated.
Record of Decision (ROD): A public document that records and explains the remedial
alternatives to be used at a Superfund site. The ROD is based on information from the Remedial
Investigation, Feasibility Study, Baseline Risk Assessment, public comments and community
concerns.
RemedlallnvestigationfFeasibillty Study (RIfFS): These are two separate but related studies.
During the RI, the types, amounts and locations of contamination at a site are identified. In the
FS, alternatives for cleaning up the contamination are identified, screened and compared.. The
FS for OU2 is called a focused FS because it is more narrow in scope and therefore few
alternatives need to be considered.
Solidification: The on-site process whereby contaminated soil and crushed chrome-bearing
bricks are made into solid, transportable units using cementing agents.
Toxicity: The degree to which a poison is toxic.
Treatment Level: The concentration of a contaminant to be achieved by treatment of air, soil,
water or bricks.
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Bibliography
Dames and Moore. 1986. Remedial Investigation, Cement Kiln Dust Waste Disposal Sites,
Geohydrologic Investigation Report. Prepared for Lone Star Industries, Inc. Dames and Moore,
Salt Lake City, UT.
Dames and Moore. 1989. Feasibility Study, Portland Cement of Utah Site. Prepared for Lone
Star Industries, Inc. Dames and Moore, Salt Lake City, UT.
National Archives and Records Administration, Office of the Federal Register. 1991. Code of
Federal Regulations, Parts 260 to 299. U.S. Government Printing Office, Washington, D.C.
Tetra Tech. 1991. Portland Cement Sites 2 and 3, Operable Unit 2, Baseline Risk Assessment.
Prepared for Utah Department of Environmental Quality, Division of Environmental Response and
Remediation. Tetra Tech, San Francisco, CA.
Tetra Tech. 1991. Focused Feasibility Study, Portland Cement Sites 2 and 3, Operable Unit 2.
Prepared for Utah Department of Environmental Quality, Division of Environmental Response and
Remediation. Tetra Tech, San Francisco, CA.
U.S. Environmental Protection Agency. 1989. Guidance on Preparing Superfund Decision
Documents: The Proposed Plan, The Record of Decision, Explanation of Significant Differences,
The Record of Decision Amendment. U.S. EPN540/G-89/007. U.S. EPA, Office of Emergency
and Remedial Response, Washington, D.C. .
U.S. Environmental Protection Agency. 1989. Risk Assessment Guidance for Superfund, Volume
I, Human Health Evaluation Manual (Part A), Interim Final. U.S. EPA/540/1-89/002. U.S. EPA,
Office of Emergency and Remedial Response, Washington, D.C.
U.S. Environmental Protection Agency. 1991. Portland Cement Company of Utah Waste Cement
Kiln Dust Disposal Site, Salt Lake City, Utah, Remedial Investigation Report, Operable Unit 2.
Utah Department of Health and U.S. Environmental Protection Agency. 1990. Record of
Decision, Portland Cement Co. (Kiln Dust #2 & #3), Operable Unit 1, Salt Lake City, Utah.
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Exhibit 1: ARARs Evaluation
A list of ARARs was developed for the selected remedy for OU1 and can apply to remediation
goals established at OU2. The ARARs which are relevant to the Site are listed below.
Chemical-Specific ARARs
40CFR 261 - Identification and Listing of Hazardous Waste:
. Defines solid wastes subject to regulation as hazardous waste.
40CFR 261.24 - Toxicity Characteristic:
. Describes use of the TClP test method to determine if a solid waste is a hazardous
waste by the characteristic of toxicity.
40CFR 268.2(g) - Definition of Inorganic Soil and Debris (includes chrome-bearing bricks).
40CFR 268.35 - Waste Specific Prohibition - Third Third Wastes:
. 0008 will require treatment prior to land disposal effective August 8, 1990.
. Inorganic soil and debris will require treatment prior to land dispos~1 effective May 8.
1992.
40CFR 268.41 - Treatment Standards Expressed as Concentrations in Waste Extract:
. The treatment standards for lead and total chromium are both 5.0 mg/I as measured
in the TClP extract.
Utah Clean Air Act (Utah Code Annotated, Title 26. Chapter 13):
. R-446-1-4.5 U.A.C. (Regulations governing fugitive dust emissions. including total
suspended particulates (TSP) at construction sites).
. R-446-1-3.1.8 U.A.C. (Requires the use of Best Available Control Technology for any
source of emissions).
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40CFR 50 - National Primary and Secondary Ambient Air Quality Standards:
. Standards for ambient air quality to protect public health and welfare (including
stan~ards for particulate matter and lead).
40CFR 61 - National Emission Standards for Hazardous Pollutants:
. Emission standards for designated hazardous pollutants including inorganic arsenic
from any stationary source.
R450-101 et seq. - Utah Corrective Action Cleanup Standards Policy (Applicable to RCRA,
UST, and CERCLA Sites):
. Rules establishing policies of the Solid and Hazardous Waste Committee. Minimum
standards for cleanup are MCLs, standards under Clean Air Act, and other standards
as determined applicable. Cleanup standards evaluation criteria include numerical,
technology-based, or risk-based standards or a combination.
Location-Specific ARARs
40CFR 6.301 (c) - Archaeological and Historic Preservation Act:
. Procedures to provide for preservation of historical and archaeological data which
might be destroyed through alteration of terrain as a result of a federal construction
project or a federally licensed activity or program.
40CFR 6.301 (b), 36CFR 800 - National Historic Preservation Act:
. Requires federal agencies to take into account the effect of any federally assisted
undertaking or licensing on any district, site, building, structure, or object that is
included in or eligible for Register of Historic Places.
40CFR 6.301 (a) - Historic Sites, Buildings, and Antiquities Act: .
. Requires federal agencies to consider the existence and location of landmarks on the
National Registry of Natural Landmarks to avoid undesirable impacts upon such
landmarks.
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50CFR 17 and 402, 40CFR 6.302(h) - Endangered Species Act:
. Requires federal agencies to insure that any action authorized, funded, or carried out
by the agency will not jeopardize the continued existence of any threatened or
endangered species or destroy or adversely modify critical habitat. .
40CFR 6.302(g) - Fish and Wildlife Coordination Act:
. Requires consultation with the Fish and Wildlife Service when any federal department
or agency proposes or authorizes any modification or control of any stream or other
water body and requires adequate provision(s) for protection of fish and wildlife
resources.
Executive Order No. 11,988, 40CFR 6.302(b) and Appendix A - Executive Order on
Floodplain Management:
. Requires federal agencies to evaluate the potential effects of actions they may take
in a floodplain and to avoid, to the maximum extent possible, the adverse impacts
associated with direct and indirect development of a floodplain.
Executive Order No. 11,990, 40CFR 6.302(a) and Appendix A - Executive Order on
Protection of Wetlands:
. Requires federal agencies to avoid, to the extent possible, the adverse impacts
associated with the destruction or loss of wetlands and to avoid support of new
construction in wetlands if a practicable alternative exists.
Action-Specific ARARs
29CFR 1910 and 1926 - OSHA Standards for Worker Health and Safety.
40CFR 265 Subpart Q - Chemical, Physical and Biological Treatment.
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40CFR 268.50 - Prohibition on Storage of Restricted Wastes:
. Requirements for accumulation of restricted wastes, relevant and appropriate to on-
site staging, prior to remediation, of chrome-bearing bricks.
40CFR 107 and 171-177 - DOT Regulations for Transport of Hazardous Waste.
40CFR 262 - Standards for Hazardous Waste Generators.
40CFR 263,; Standards Established by EP A/DOT for Transporters of Hazardous Waste Per
Manifest Requirements.
40CFR 270 - Hazardous Waste Permit Program.
To Be Considered Regulations
Salt Lake City Corporation (Salt Lake City Zoning Ordinance, Section 21.66.010 (33) and
Section 21.66.040 (A).
. This ordinance regulates land use. The Site is zoned M-1 and C-2.
Salt Lake City/County Health Department - Health Regulations No.1, Solid Waste
Management Facilities. Utah Code Ann.. Section 26-24-20.
Salt Lake City Ordinance. Wastewater Control Ordinance/Rules and Regulations. Title 37
Revised Ordinances 0' Salt Lake City.
. Regulations for direct and indirect contributors to the publicly-owned treatment works
(POTW) wastewater system permit issuance and general requirements. Federal pre-
treatment standards applicable and numerical pollutant limitations specified in this
ordinance for heavy metals.
40CFR 268.44 - Variance From a Treatment Standard, According to: "Obtaining a Soil and
Debris Treatability Variance for Remedial Actions", September 1990.
. Alternate treatability variance levels and technologies are provided for chromium and
lead in water. For concentrations in the TCLP extract less than 120 mg/I for
chromium, the acceptable TCLP concentration range for the treated waste is 0.5 to
6.0 mg/I. For lead in the TCLP extract less than 300 mg/l, the acceptable TCLP
concentration range for the treated waste is 0.1 to 3.0 mg/!.
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