United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R08-93/073
July 1993
SEPA Superfund
Record of Decision
Utah Power & Light/
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REPORT DOCUMENTATION 11. REPORT NO. 2. 3. R8clplent'. Acc:e881on No.
PAGE EPA/ROD/R08-93/073
4. Title and Subtitle 5. Report Date
SUPERFUND RECORD OF DECISION 07/07/93
Utah Power & Light/American Barrel, UT 6.
First Remedial Action - Final
7. Author(s) 8. Performing Organization Rapt. No.
9. Performing Organization Nama and Acldrea 10 Project TaskIWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Nama and Addrau 13. Type of Report & Period eovar8d
U.S. Environmental Protection Agency
401 M- Street, S.W. 800/800
Washington, D.C. 20460 14.
15. Supplemantary Note.
'PB94-964406
16. Abstract (Limit: 200 words)
The 4-acre Utah Power & Light/American Barrel site is an inactive coal gasification and
creosote pole treating plant located in Salt Lake City, Utah. Land use in the area is
predominantly residential, with light industrial. A single aquifer, consisting of the
shallow, unconfined and the deep, confined zones, exists beneath the site. The
unconfined zone is not utilized as a drinking water source at the site; however, the
conrined zone is utilized as a drinking water supply ip some areas of the valley. The
site is situated in the Jordan River Valley, surrounded by mountains, and near the
Great Salt Lake. The study area for this site is divided into geographic areas
consisting of the American Barrel Yard (ABY) , the Denver and Rio Grande Western
Railroad property or Southeast Area (SEA), the Union Pacific Railroad property or
Northwest Area (NWA) , the residential area, and the industrial area or Deseret Paint
Site. From 1873 to 1908, coal gasification operations occurred onsite, which included
coal storage sheds, a gas-o-meter (gas holder), tar wells, a coal tar still, the gas
works, and the purifying house. The gas plant was located on the ABY, the SEA, and a
portion of the NWA. The gas-o-meter was a buried tank used to store gas after
production and before metering-out to customers. In the early 1900s, this step was
(See Attached Page)
17. Document Analysla a. Descriptors
Record of Decision - Utah Power & Light/American Barrel, UT
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, toluene, xylenes), other organics (PAHs, PCBs,
pesticides, phenols), metals (lead)
b. Idantlft.rsIOpen-End8d Tanns
c. COSATI FlaldlGroup
18. Availability Stat.mant 19. Security Class (This Report) 21. No.o'Pag..
None 104
20. Security Class (This Page) 22. Prica
None
50272.101
f
(See ANSI-Z39.18)
Sse/nstruetlons on RllvfIfSe
OPTIONAL FORM 272 (4.77)
(Formerly NTI5-35)
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EPA/ROD/R08-93/073
Utah Power & Light/American Barrel, UT
First Remedial Action - Final
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Abstract (Continued)
eliminated by switching to a scrubber technology. The coal gasification procedures
produced by-products having commercial value, including coke, ammonia, tars and sludge,
toluene, naphthalene, anthracene, and phenols. By-products having no commercial value
included ash, clinkers, heavy tars, sludge, lime sludge, spent iron oxides, liquid wastes,
and steam condensates, which were commonly disposed of onsite in pits and offsite in
landfills. From 1909 to 1929, the site was utilized as a storage yard for equipment, wood
power poles, and other items. From 1927 to 1958, creosote pole treating operations
occurred, which included two pOle dipping tanks: one underground, semi-open tank built on
buried concrete walls, and one 400-gallon capacity steam heated tank made of welded or
riveted iron walls that was used in conjunction with a boiler house and hot well tank to
pressure treat poles in hot creosote before draining into six inches of sand. The
specific chemical composition of the creosote used onsite is unknown. However, typical
creosote compounds include PAHs, phenols, and nitrogen-,sulfur-, and oxygen-heterocyclic
components. From 1958 to 1987, American Barrel stored up to 50,000 55-gallon drums at any
one time on virtually all portions of the ABY. It is assumed that the entire ABY was
vulnerable to leaks and spills of the drum contents. In 1986, EPA conducted a site
investigation that revealed stained soil- and product-containing drums onsite. In 1987,
Utah Power & Light (UP&L), the property owner, required American Barrel to remove all
barrels and debris from the ABY as terms for their lease renewal. During the removal,
barrel contents containing pesticides, solvents, resins, paints and paint removers,
kerosene, gasoline, etc. leaked and spilled onto the ground. In 1987 and 1988, EPA
collected soil and ground water samples which indicated soil contamination by PAHs,
phenols, heavy metals, pesticides, non-aqueous phase liquids (NAPLs), styrene, and BTEX
compounds; and ground water contamination primarily consisting of LNAPLs, BTEX compounds,
and styrene. EPA concluded that contamination from historical operations and contaminant
sources left onsite at the time of the abandonment have migrated into the soil and ground
wa~er. In ~988, EPA required UP&L to repair portions of the existing fence, insta~l a new
fence to completely surround the yard, and to cut down trees and vegetation in the ABY.
This ROD addresses a final remedy for the contaminated soil and ground water in the ABY
and SEA. The primary contaminants of concern affecting the soil and ground water are
VOCs, including benzene, toluene, and xylenes; other organics, including PAHs, PCBs,
pesticides, and phenols; and metals, including lead.
The selected remedial action for this site includes excavating approximately 5,660 y~3 of
principal threat soil in the tar berm area and the gas-o-meter contents, to the" extent
feasible as determined by EPA or until the concentrations of EPA target compound list PAHs
are below 9,000 mg/kg; conducting leachability te~ts; segregating the contaminated 80il
onsite into RCRA hazardous and non-hazardous waste, and temporarily storing the waste
onsite; excavating low-level threat surface and subsurface soil on the ABY and SEA to a
depth of 10 feet and segregating them from principal threat RCRA hazardous waste onsite;
recycling approximately 13,850 yd3 of the low-level threat soil off site into a cold mix
asphalt product using solidification; incinerating the remaining RCRA hazardous soil
off site in a RCRA Permitted Subtitle C facility; segregating approximately 4,620 yd3 of
calcareous fill material uncovered or excavated during the soil removal action from other
contaminated soil, with disposal of hazardous fill material offsite in a RCRA Subtitle C
facility and non-hazardous fill offsite in a RCRA Subtitle D facility; backfilling the
excavated areas with clean fill and regrading and placing a soil cover over them;
installing an in-situ soil vapor extraction (SVE) system to remediate approximately 570
yd3 of principal threat, LNAPL-contaminated soil in the ABY and SEA using ground water
depression and vacuum blowers, with GAC treatment of recovered vapors produced from the
SVE prior to discharging them to the atmosphere; extracting and treating ground water
onsite using air stripping and/or GAC; discharging the treated ground water offsite to a
POTW for further treatment; allowing the remaining ground water contaminant plume to
naturally attenuate over 10 or more years; monitoring the ground water to evaluate the
progress of natural attenuation; and implementing institutional controls, including deed
and ground water use restrictions. The estimated present worth 'cost for this remedial
action is $10,583,000, which includes an estimated total O&M cost of $2,836,000 for 30
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EPA/ROD/R08-93/073
Utah Power & Light/American Barrel, UT
First Remedial Action - Final
Abstract (Continued)
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific 50il cleanup goals are based on health-based exposure limits (ELs) and
Federal and State ARARs, and include benzo(a)anthracene 47.7 mg/kg: benzo(b)fluoranthene
0.48 mg/kg; benzo(k)fluoranthene 47.7 mg/kg; benzo(a)pyrene 0.48 mg/kg: chrysene 47.7
mg/kg; dibenzo(a,h)anthracene 0.48 mg/kg; dieldrin 0.36 mg/kg; indeno(1,2,3-cd)pyrene 47.7
mg/kg; and lead 500 mg/kg. Chemical-specific ground water cleanup goals are based on SDWA
MCLs, the National Primary Drinking Water Regulation action level for lead, and
health-based ELs, and include acenaphtylene 2,190 ug/l: antimony 5 ug/l; benzene 5 ug/l;
cyanide 200 ug/l: 1,2-DCA 5 ug/l; 2,4-dimethylphenol 730 ug/l; lead 15 ug/l; 2-
methylnaphthalene 1,460 ug/l; 2-methylphenol 1,830 ug/l; 4-methylphenol 1,830 ug/l;
naphthalene 1,460 ug/l; phenol 21,900 ug/l: styrene100 ug/l; toluene 1,000 ug/l; and
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RECORD OF DECISION
UTAH POWER & LIGHT/AMERICAN BARREL SITE
SALT LAKE CITY, UTAH
,
JULY 7, 1993
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND WCATION
Utah Power & Light! American Barrel Site, Salt Lake City, Utah
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Utah Power &
Light! American Barrel Site in Salt. Lake City, Utah, which was chosen in accordance with the
requirements of the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA),..as amended by Superfund Amendments and Reauthorization Act of 1986 (SARA),
and, to the extent practicable, the NationB.1 Oil and Hazardous Substances Pollution Contingency
Plan (NCP). This decision is based on the admini~trative record for this site.
The Utah Department of Environmental Quality concurs with the remedy selected by the
U.S. Environmental Protection Agency (EPA).
ASSESSMENT OF THE SITE
Actual or thfeatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in the Record of Decision (ROD), may present an
imminent. and substantial danger to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The objective of this Record of Decision (ROD) is to provide a remedy to address all
contamination caused by previous site activities located on the American Barrel Yard and
adjacent properties which affect surface soils, subsurface soils, and groundwater. Contamination
~m historical opetations and contaminant SOUICeS left on-site at the tlme of abandonment have
migrated into soil and groundwater. Remediation will be to the extent of contamination
emanating from the American Barrel Yard and Denver Rio . Grande and Western properties.
\
. The response actions described in this ROD will permanently address all principal threats
through treatment. Soil contamination will be reduced to health based levels for all contaminants
of concern. These levels are based on a future. industrial use of the site but will provide for
future residential development with acceptable risks within EP A's risk range of 1 Q4 to 1~.
Groundwater remediation levels are based on the Safe Drinking Water Act maximum
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The major components of the selected remedy. include:
*
Excavation of soils which are principal threats based on visual obselVation, to the extent
possible given physical limitations resulting from locations of existing railroad lines, or
until the concentrations of EP A target compound list P AHs are below 9,000 mg/kg. The'
quantifiCation of principal threats is based on EP A guidance, II A Guide to Principal
Threat and Low Level Threat Wastes" which suggests defining principal threats as having
a risk of 1 Q-3 or greater~
Excavation of soils exceeding health based .remediation levels, based on a 1()"6 worker
exposure, that have a potential exposure pathway. Soils down to a depth of 10 feet are
considered to have an exposure pathway.
'J
*
*
Treatment of excavated soils through offsite recycling of soils into a cold mix asphalt
product suitable for paving roads. Incorporation of contaminated soils as a raw material
into the asphalt product involves treatment through solidification.
*
If any RCRA characteristic hazardous wastes are encountered, these contaminated soils
will be shipped offsite for incineration and will not be utilized in the asphalt treatment
process.
*
Soil vapor extraction (SVE) will be used to remediate principal threat light non-aqueous
phase liquid (LNAPL) contamination. Location of the SVE extraction wells will be
based on a principal ~ definition where benzene in soils exceeds lQ-3 risk levels for
residential exposure to groundwater. In conjunction with SVE, groundwater will be
extracted from vapor extraction wells to enhance the SVE procesS. Off-gas from the
SVE system will be treated prior to discharge to the atmosphere.
*.
Groundwater extracted from SVE wells, water pumped from excavations, and
decontamination water will be treated to P01W discharge standards and ~en discharged
to the Salt Lake City P01W for further treatment.
*
The dissolved phase aqueous groundwater contamination plume is expected to naturally
attenuate once the principal threat SOUICeS for groundwater contamination are remediated.
If monitoring of groundwater contamination .indicates that natural attenuation is not
restoring groundwater to remediation levels, additional somce removal or more active
groundwater remediation may be required.
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STATUTORY DETERMINATIONS
!
The selected remedy is p~tective of human health and the environment, complies with
Federal and State requirements that are legally applicable or relevant and appropriate to the
remedial action, except certain requirements for RCRA waste piles where a waiver is appropriate
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peIformance that is equivalent to that required under the otherwise applicable standard. This
remedy is cost effective, utilizes permanent solutions and alternative treatment and resource
recovery technologies to the maximum extent pmcticable, and satisfies the statutory preference
for remedies that employ treatment that reduces toxicity, mobility, or volume as a principal
element.
Because this remedy will not achieve the remediation levels for groundwater within five
years, a review will be conducted within five years after commencement of remedial action to
ensure that the remedy continues to provide adequate protection of human health and the
environment. Five-year reviews will be conducted as required under Section 121(c) of CERCLA
and 40 C.F.R. i 300.430(t)(4)(ii) of the National Oil and Hazardous Substances Contingency
Plan. .
#3
Date
I W. McGraw'
ACting Regional AdministIator
EPA Region vm
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Dianne R. N'Je1son, PhD
Executive Director
Utah Department of Environmental Quality
Date
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DECISION SUMMARY
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UTAH POWER & UGHT/AMERICAN BARREL SITE
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TABLE OF CONTENTS
I Site Name, Location, and Description. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1
1.
n Site History and Enforcement Activities. . . . . . . . . . . . . . . . . . . . . . . . . .. 4
History of Site Activities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4
History of Federal and State Site Investigations. . . . . . . . . . . . . . . . . . . .. 7
Outcome of Potentially Responsible Party Search. . . . . . . . . . . . . . . . . . .. 8
m Higblights of Community Participation. . . . . . . . . . . . . . . . . . . . . . . . . .. 9
IV Scope and Role of Response Action Within Site Strategy. . . . . . . . . . . . . . .. 10
V Summary of Site Characteristics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
SUIface and Subsurface Features . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Surface Water and Groundwater. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Known and Suspected Sources of Contamination. . . . . . . . . . . . . . . . . . . . . 12
Distribution of Contamination! Affected Media .......'............... 12
Swface and Subsurface Soils. . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
GlO'UDdwater ......... ~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
PrincipalThreatslLow Level Threats ....................... 18
Popu]ation and PnvironmentaI Areas Potentially Affected ............... 21
Potential Pathways of Contaminant Migmtion . . . . . . . . . . . . . . . . .,. . . . . . 22
VI Summary of Site Risks ...... ~ . . . . . . . . . . . . . . . . . . . . . '. . . . . . . . . 22
Contaminants of Concern. ,. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
Exposure Assessment .....................................23
Toxicity Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ . . . . . . . . 2S
Ri.skCUra.cterlza.don .....................................25
Uncertainties. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
VII Remedial Action Objectives'. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3S
Remediation Levels. . . . . '. . . . . . ". . . . . . . . . . . . . . . . . . . . . . . . . . . 3S
VIII Desaiption of Altematives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
Alternative 1 - No Action. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
Alternative 2 - Limited Action. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
Alternative 3 - Treatment andlor Disposal of Principal1breat Wastes Only;
Groundwater Remediation through Principal Threat Remediation and
Na:tIJmJ..Attenuat:i.on . . . . . . . . . . . . . . . .0 . . . . . . . . . . . . . . . . . . 39
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Alternative 4 - On-Site Thermal Desorption of Principal Threats and Low-Level
Threat Wastes; Groundwater Remediation through Principal Threat
Remediation and Natural Attenuation. . . . . . . . . . . . . .- . . . . . . . . . 41
Alternative S - Off-Site Disposal of Principal Threats and Low-Level Threat
Wastes; Groundwater Remediation through Principal Threat Remediation
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and Natural Attenuation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
Alternative 6 - Asphalt Batching of ,Principal Threats and Low-Level Threat
Wastes; Groundwater Remediation through Principai Threat Remediation
and Natural Attenuation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
Alternative 6a: Asphalt Batching of All Principal and Low-Lev~l
Threat Wastes with off site disposal of any RCRA
characteristic hazardous wastes. . . . . . . . . . . . . . 42
AsphaltBatching of Principal and Low-Level Threat
Wastes with offsite incineration of any RCRA
characteristic hazardous wastes . . . . . . . . . . . . . . 43
Alternatives 7 through 10 - Alternatives 3 through 6 with Groundwater Exttaction
,and Treatment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .'. . . . . . 44
Alternative 6b:
IX Summary of Comparative Analysis of Alternatives. . . . . . . . . . . . . . . . . .. . .45
Protection of Human Health and the Environment. . . . . . . . . . . . . . . . ~ .,. . 45
Compliance with Applicable Relevant and Appropriate Requirements (ARARs) . . 46,
Long-Term Effectiveness and Permanence. . . . . . . . . . . . . . . . . . . . . . . . . 47
Reduction of Toxicity, Mobility, or Volume through Treatment. . . . . . . . . . . 49
Short-Term Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49
Implementability, ..... '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
Cost. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51
State Acceptance ........................................ 51
CommwntyA~ce ... .......... ........ .~............. 51
X Selected ReD1edy . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . ., . . . . . . . . . 52
XI Performance Standards. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53
Principal1breat Excavation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53
Low Level1breat Soil Excavation. .. . . . . . . . . . . . . . . . . . . . . . . . . . . 54
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Asphalt Product Standards. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54
Soil Vapor Extraction of LNAPL Principal Threats .'.. . . . . . . . . . . . . . . . . 54
Performance and Coinpliance Monitoring Program . . . . . . . . . . . . . . . 55
Groundwater Restoration. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55
,Area, of Attainm.ent .................................. S5
Performan.ce Sta.D.da:rd.s ..... . .' . . . . . . . . . . . . . . . . . . . . . . . . . 56
Performan.ce and Compliance Monitoring Program . . . . . . . . . . . . . . . 57
XU Statutory Requirelnents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58
Protection of Human Health and the Environment . . . . . . . . . . . . . . . . . . . . 58
Compliance with ARARS . . . . . . . . . . . . . . . . . . . . . . . . . . .' . . . . . . . . 58
, Cost Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58
Utilization of Permanent Solutions and Alternative Treatment Technologies or
, Resource Recovery Technologies to the Maximum Extent Practicable. .. 58
Preference for Treatment as a Principal Element. . . . . . . . . . . . . . . . . . . . . 59
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LIST OF FIGURES
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Figure 1 Site Location Map ..................................... 2
Figure 2 Ownership and Principal Source Areas Map . . . . . . . . . . . . . . . . . . . . .. 3'
Figure 3 Former Coal Gasification Facilities Map . : . . . . . . . . . . . . . . . . . . . . .. 5
Figure 4 Former Creosote Wood Treating Facilities Map ................... 6
. Figure 5 Areal Extent of Aqueous Groundwater Contamination. . . . . . . . . . . . . . .. 16
Figure 6 Location of Principal1breats . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Figure 7 Location of Low Level Threats . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
LIST OF TABLES
Table 1 Surface Soil Concentrations "................................. 14
Table 2 Subsurface Soil Concentrations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Table 3 Groundwater Concentrations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Table 4 Summary of Waste' Volume Estimates . . . . . . . . . . . . . . . . . . . . . . . . . . 21
Table 5 Summary of Human Exposure Parameters ....................... 24
Table 6 Population Total Excess Cancer Risks ... . . . . . . . . . . . . . . . . . . . . . . . 26
Table 7 Cancer Risk Estimates for Contaminants of Concern. . . . . . . . . . . . . . . . . 27 .
Table 8 Summary of POpulation Total Hazard Index Valoes . . . . . . . . . . . . . . . . . . 30
Table 9 SubchroniC Hazard Index Estimates. . . . . . . . . . . . . . . . . . . . . . . . . . . 32
Table 10 Health Based Remediation Levels for Soil (0' to 10' depth) .......;.... 36
1
Table 11 Remediation Levels for GroundWater. . . . . . . . . . . . . . . . . . . . . . . . . 37
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APPENDICES
Appendix A Derivation of Media Concentrations That Define Principal Threats
Appendix B-1 Chemical Specific ARARs
Appendix B-2 Action Specific ARARs
4
Appendix B-3 Location Specific ARARs
Appendix C
Responsiveness Summary
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THE DECISIO~ SUMMARY
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I Site Name, Location, and Description
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The Utah Power and Light/American Barrel Site (up&UABS or the site) is an
approximately four-acre parcel in Township I North, Range I West, Section 36 in Salt Lake
City, Utah (Figure 1). The site is defined as the American Ba1re1 Yard and the extent of
conmmination originating from past activities on the yard. The city block bounded by North
Temple, South Temple, Sth West and 6th West streets is referred to as the study area.
The study area is divided into geographic areas consisting of the American Barrel YaId
(ABY or yard), the Denver and Rio Grande Western Railroad property or Southeast Area (SEA),
the Union Pacific Railroad property or Northwest Area (NW A), the residential area and the
industrial area or Deseret Paint Site. (Figure 2).
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The principal topographic features of the site are a gentle (1 %) slope towards the Jordan
River (one mile to the west) and a SUIface cut up to 8 feet deep for the Denver and Rio Grande
railroad track along the eastern boundary of the yard. The railroad track just outside the western
border of the ABY is at grade.
The ABY boundary is marked by a secured 'chain link fence; gates are located at the
property's southwest comer and the middle of its northem edge. The yard is sparsely vegetated
and while there are no intact buildings or large trees remaining within the fenced yard, there are
sev~ remnants of stmctures in and around the yard.
Residential lots and one light industrial lot are present along the western boundary of the
study area. Surface f~ in this area include small buildings, mixed gI3SS and gravel yards,
old shade trees in some yards, and wood or sheet metal fences. To the north lies a vacant lot,
formerly an auto wrecking property area, which is partially bounded by a woven wire fence and
covered with sparse vegetation and bare S9il.
The Union Pacific Railroad Company property comprises the area west and north of the
. ABY. This area is sparsely vegetated and the only surface features are the railroad tracks and
overhead lines. Southeast of the ABY is the Denver and Rio Grande Railroad property. There
are two sma11 buildings in this area used intermittently by railroad personnel. The lot is sparsely
vegetated and includes Stone foundation remnants and some paved portions along the eastern
boundary. The cut for the rai1road track exposes old building foundations. Gravel-size ballast
underlies all of the railroad tracks at this site.
i
City property forms a paved border around all four sides of the study area. Sixth West
Street receives modetate traffic and forms the western boundary of the study area. The North
Temple Street oveIpaSS"carries traffic along the study area's north side, with a paved but only
occasionally used right-of-way at ground level. The east and south margins of the study area
contain railroad tracks just outside the paved right-of-way.
The nearest population to the site are those residents who live in the homes which lie 200
-------
Source: USGS 7.5 minute quadrangle - Salt Lake City North, Utah
SITE LOCATION MAP
FIGURE 1
Utah Power & light
Amoric:an Barrel Site Work Plan
up&lIIiIelMc 1
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RICHARD J. HOWA COMPANY
UNION PACIfiC
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FIGURE 2
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EXPLANATION
l:,:,,:;,,:,,:::':'j - AMERICAN BARREl YARD (ABY)
°0°0°0
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THE AMERICAN BARREl SITE (ABS)
INCLUDES THE ABY AND SURROUNDING
PROPERlY WITHIN THE CITY BLOCK,
SHOWN HERE
-
POSSIBLE CREOSOTE TANK AREA
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Lakowood. CO 80228
(303) 880-6800
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UTAH POWER AND LIGHT
AlAERICAN BARREL RI/FS
SAlT lAKE CITY, UTAH
'. ..
MAP or ABS SHOWING LOCAL
PROPERTY OWNERSHIP AND
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4
transients may have had extensive contact, with on-site media. However, under, current
conditions, there is a fence around the ABY to discourage trespassers and little on site which
would attract visitors.
n Site History and Enforcement Activities
Histoty of Site Activities
Activities began at the UP&UABS as early as 1873 and continued unti11987. The first
process to be conducted on the site was coal gasification. The major features of this operation
included coal 'storage sheds, a gas-o-meter (gas holder), tar wells, a coal tar still, the gas wolks
(which included the retort house, exhauster room, condenser, lime,house, and tar scrubbers),
and the purifying house. The gas pIant was located on the American Burel Yard, the SEA, and
a portion of the- NW A. Locations of these stroctures are depicted on Figure 3 . The gas-o-meter '
was a buried tank used to store gas fon~wing production and before metering out to customers.
, It was built of 30 inch thick brick masonry, constniction tqpped, With sandstone building stone.
The process of cooling the gas produced a tar/water condensate which was separated in the ~
well. The tars were subsequently used as fuel, sold, or managed on site. The coal gasification
plant included a distillation procedure to sepuate usable oils from tars. The final purification
step in coal !'Isification involved a purifying hOuse. In this step, the gas was paSsed through
long, sha110w boxes of hydrated iron oxide, thereby producing ferric sulfide. By the early 1900s
this step was eliminated by switching to a scrubber tec1u1ology.
, .'
Normal coal gasification procedures produced a variety of by-products having some
commercial value. These included coke, ammonia, and lighter tars and sludges which were sold
to refiners . or to the public. Distillation by-products fro~ the refinement of tars included
toluene, naphthalene, anthracene, and phenols. By-products having no commercial value were
also produced: ash, clinkers, heavy tars, sludges, lime sludges, spent iron oxides, liquid wastes,
and steam condensates. These products were commonly.disposed of in onsite pits and off site
landfWs. Coal gasification operations ceased in 1908.
Creosote pole treating operations were conducted on the ABY and SEA as early as 1927.
Creosote was brought to the site in droms and stored within and just north of the northeastern
comer of the ABY. Historical infonnation shows there were two pole dipping tanks on the ABY
and possibly one tank on the SEA. Design plans indicated one was. a semi-open tank v.:ith walls
of 12-gage iron and wooden supports, buried six feet underground, and built on buried concrete
walls. The other was a 400-gallon capacity steam heated tank used in conjunction with a boiler
house and hot well tank to pressure treat poles in hot creosote. This tank was made of welded
or riveted iron walls, painted with red lead paint (on the outside), and buried at a depth of 8.5
feet underground. It was tipped at an an~ to allow for drainage into six inches of sand. No
identifiable tank stroctures from this operation remain on site. The specific chemical
composition of the creosote used at this site is unknown. However, typical creosote compounds
include a variety of polycyclic aromatic hydrocarbons (PAHs), phenolic compounds, and
nitrogen-, sulfur-, and oxygen-heterocyclic components. Locations of former creosote wood
treating structures are shown on Figure 4.
-------
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NORTH TEt.APl£ STREET
BRICK IIWEWI«I
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NORTH TEMPLE STREET
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FIGURE 4 .
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EXPLANATION
L ~ POLE STAGING AREA
l1li POSSIBLE CREOSOTE TANK AREA
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115 Union IIcMlVlnf
SuII, 5150
Lak,.GOd, co 80228
(303) 880-8800
UTAH POWER AND LIGHT
AMERICAN BARREL RI/FS
SAlT lAKE CITY, UTAH
COMPOSITE OF
FORMER CREOSOTE
WOOD-TREATING FACILITIES
-------
. .
7
When the pole treating operations ceased, the ABY was used as a storage yard for 55-
. gallon droms. Up to 50,000 drums were stored at anyone time on virtually all portions of the
ABY except for the yard margins, areas allowing for vehicles, and the extreme southwest
extension of the crescent-shaped area. While no cleaning of drums or recycling of contents was
reported to have taken place on the yard, some barrels contained' residual products and leaks
occurred. According to labels found on some of the droms, the variety of contents included:
pesticides, solvents, resins, paints and paint removers, kerosene, gasoline, acetone, etc. It is
assumed that the entire ABY was vulnerable to leaks and spills of the drum contents.
SeveIal other activities have occurred within and immediately adjacent to the UP&U ABS
study area over the past century which may have had an influence on the study area properties.
Some of these operations included: railroads, Deseret Paint Company, W.P. Fuller Oil
Company, a Chevron gasoline station, Richard I. Howa Company underground storage tanks,
and the exiSting Amoco diesel pipeline.
Histoty of Federal and State Site Investiptions
The U.S. EnvUonmental Protection Agency (EPA) Field Investigation Team (FIT)
conducted a site inspection in May of 1986 in response to discussions with the Utah Bureau of
Solid and Hazardous Waste (BSHW). The BSHW is currently the Division of EnvUonmental
Response and Remediation (DERR) and is part of the Utah Department of Environmental Quality
(UDEQ) (formerly the Utah Department of Health). The BSHW subsequently submitted a Draft .
Pre1iminary Assessment to the EPA, and the EPA Technical Assistance Team (TAT) observed
drum characterization activities at the ABY being conducted by the American Barrel and
Cooperage Company. The FIT followed up on the TAT observations of stained soils. and
product-CODtaining droms by completing a two-phase site investigation in May, 1987 and
Febmary, 1988.
The FIT collected surface and subsurface soil samples and installed three monitor wells
from which groundwater samples were .collected. Analytical results indicated an abundance of
PAHs and phenolic compounds present on-yard and extending to some undefined distance off-
yard in surface soils. Concentrations of P AHs as high as tens of thousands of micrograms per
kilogram (pglkg) were reported in soil samples. The FIT investigation report also indicated
evidence of contaminSition by some heavy metals (cadmium, copper, chromium, lead, and zinc)
and BTEX compounds (JJeDzene, toluene, ethylbeozene, and xylenes). Chlorinated pesticides
were found in some on-yard soilS, indicating that cOntamination could have occurred from
1eaIdng dmms. The investigation did not provide sufficient data to permit evaluation of the air
pathway, although preliminary reports of surface soil contamination indicated that further study
of the air pathway was warranted. Due to the diverse, toxic substances reported on many of the
drum labels, FIT recommended further investigation of an media in the study area.
-
On-yard groundwater contamination was found consisting primarily ofBTEX and styrene.
Little information was cOllected to infer the extent of off-yard contamination. However,
groundwater was determined to potentially be a principal pathway of concern. While the
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. .",
8
reJationships to underlying or adjacent aquifer material.
. Information provided by the FIT investigation indicated that surface water was not a
pathway of concern.
On June 8, 1988 Utah Power and Light entered into an Adminiqrative Order on Consent
under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA),
Section 106. Under this order, Utah Power & Light repaired portions of the existing fence and
installed new fence to completely surround the yard. In addition, they cut down. trees and
vegetation at the yard.
The Utah Power and Lightl American Barrel Site was proposed for listing on the National
Priorities List (NFL) on May 5, 1989. The Site was fina1i7,ed on the NPL on October 4, 1989.
. Pursuant to the findings of contamination by the FIT investigation, an Administrative
Order on Consent was entered into by Utah Power &. Light requiring them to conduct a
Remedial InvestigationIFeasibility Study (RIfFS) to characterize the extent of contamination and
identify altemativesfor cleaning up the site. The RI/FS report, which was completed in 1993,
concluded that the contaminants found at the UP&U ABS generally reflect the historical activities
of the site. Results of the RI are .presented in Section V.
As part of the RI/FS, EPA conducted a base)iQe risk assessment (BRA) in May of 1992
to estimate potential health and environmental risks which could result if no action were taken
'to clean up the site. The BRA indicated that if the site should be developed in the future,
exposure to groundwater and soil could result in significant risks due to the contaminants
present. Details of the BRA are summari7,ed in Section VI.
Outcome of potentia 11y Rewonsible Party Search
Under CERCLA, a search is conducted to identify those responsible for the
contamination in order to recover monetary compensation for the costs incurred to investigate ,
'and clean up the site. Results of an historical investigation are presented below.
The coal gasification pIant was first operated by the Salt lake City Gas Company from
appro~ly 1873 unti11893. 'Ibis company merged with two other utility companies in 1893
and became the Salt Lake and Ogden Gas and El.ectr:i.c Light Company, which operated the pIant
until 1897 . Another merger took place in 1897 forming the Union Light and Power Company,
which took control of the coal gasific3tion facility and operated it unti11899. That same year,
Union Light and Power became Utah Light and Power Company which had control of the
facility unti11904. The company was then reorgani7ed and merged with a rcrllway company to
become Utah Light and Railway Company. The plant was operated under this owner unti11908.
.
Railroad lines were present across the ABY and SEA throughout the operations of the
gas pIant. Rail cars were used to ~l coal to the gas plant. Figure 3 is a composite from
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'?~.~~~ :.-
9
The coal gasification plant ceased operating in 1908. From 1909 through 1929, the site
was utilized as a storage yard for equipment, w09d power poles, and other items. During this
period the site was owned by Utah Light and Traction and leased by Utah Power and Light
(UP&L) after 1917.
A creosote pole-treating facility was in operation in 1927 until the late 1950s. UP&L
was leasing the facility from Utah Light and Traction and became the owner after 1944. The
. Phoenix Utility Company operated the first pole-treating operation using a "hot-dip" process to
treat utility poles. This process was continued until 1938 when the operations were taken over
by UP&L, which used a "cold-dip" process until 1957.
Pole treating opetations ceased in 1958 and UP&L leased the crescent shaped yard to
American!!arrel and Cooperage, Inc., which used the yard for the storage of 55-gallon dnuns
awaiting refurbishing at a local facility. In 1987, Utah Power & Light notified American Barrel
of their intention to deny the renewal of their lease (which was to expire in 1988) and required
that they remove all barrels and debris from the yard. During the barrel removal it was apparent
that barrel contents had leaked and spilled onto the ground.
As a result of the hisi:orica1 investigation, the following companies are considered to be
Potentially Responsible Parties (pRPs) for the UP&U ABS and will be issued Special Notice
Letters:
American BatTeI & Cooperage Co.
Salt Lake City, Utah
Utah Power & Light Co.
Salt Lake City, Utah
Union Pacific Railroad Co.
Salt lake City, Utah
Denver & Rio Grande Western Railroad
Denver, Colorado
Boise Cascade Cmporation
Boise, Idaho
. EBASCO Services Inc.
New Y orlc:, New York
m Highlights of Community Participation
From the fall of 1986 to 1988, students from a local school, Jackson Elementary, showed
a great deal of interest in the UP&U ABS. They contacted the U.S. EPA, the Utah Department
of Health (UDOH), and the Salt lake City Health Department in regard to the barrels stored on
the yard. The students were concem.ed with the effects the chemicals in the barrels would have
on the soil and groundwater and lobbied companies in the area to provide voluntary participation
in the clean-up costs. The students' work resulted in Utah House Bill 199, the "Hazardous
Waste Fund for Voluntary Contributions". This provided a mechanism by which the UDOR
could accept and deposit contributions from companies. The students also solicited for public
contributions and were recognized both statewide and nationally for their efforts.
UDEQ has been holding periodic m~gs with the West Side Community Council to
brief them on the American Barrel Site since 1988. Fact sheets and news releases have been
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1.~~ ~~~ ":..
10.
, '
In 1990 a general mailing was made by UDOH to 240 residents within a five block radius
of the site to amiounce the RIlFS work and request theit input on the development of a
community relations plan to provide residents with site infonnation. Also included was a brief
questionnaire and a fonn to request inclusion on the mailing list for fu~re infonnation.
Generally, public interest in the site is considered to be low to moderate. Less than five percent
, of the questionnaires were returned, although those responding showed much interest in the work
being perfonned at the site. '
The adjacent neighbo~ood is primarily rental properties and few residents demonstrated
an interest in being interviewed for the community relations plan. Those who were interviewed
expressed concerns peJtaining to potential groundwater contamination and storm water mn-off.
Some residents questioned whether it was safe to grow garden vegetables due to their concern
that their property might be contaminated. All of those interviewed wanted to know what
measures would be taken to control dust during clean-up activities. One resident stated that it
is important that the fmal appearance of the site be aesthetically pleasing due to its location in
the downtown Salt Lake City area.
Local business owners seemed to be more interested in the site than local residents.
Their concerns were more towards the future development pJans of the area which may be
contingent upon the timing of the clean-up. The issue of long-term health effects was I3ised and
a number of those interviewed questioned whether the site contamination had migrated beyond
the UP&U ABS boundaries to their properties. '
A Proposed Plan, outlining EPA and UDEQ's preferred remedy and the public
participation process was lJ'Iai1ed March 26, 1993. Briefings were held for Salt Lake City and
Salt Lake County ofticia1s and the Westside Community Council. A display advertisement was
placed in the Salt Lake Tribune and Deseret News advertising the availability of the Proposed. ,
Plan and announcing the public meeting. The Jackson Elementary teacher involved' with the
initial site discovery was invited to the public meeting. '
A public meeting was held on April 22, 1993 in Salt Lake City. Several members of the
community were present, including a former Jackson Elementary student who was involved in
the early stages of UP&U ABS site activity. Numerous questions regarding the Site were asked
at the public meeting, but no formal comments were made regarding EPA and UDEQ's
preferred alternative. The public comment period closed on Apri129, 1993. Only one comment
was received from Utah Power &: Light that expressed concerns about future liability for the
,preferred alternative. A response bas been included in this ROD. The requirements of
CERCLA section 113(k)(2)(B)(i-v) and 117 were met in the remedy selection process.
IV Scope and Role of Respouse Action Within Site Strategy
,
I
The objective of this Record of Decision (ROD) is to 'provide a remedy to address all
contamination caused by site activities on the ABY which affect surface soils, ~bsurface soils,
and groundwater at the UP&U ABS. Contamination from historical operations and contaminant'
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"-"""'.;r~,
11
Principal threats found in soils and low level threats will be dealt with by the fInal remedy
discussed herein.
V Summary of Site Characteristics
Surface and SubsUlface Features
The UP&UABS is located in the Jordan River Valley within a sediment-filled basin"
surrounded by fault-block mountains characteristic of the Basin and Range Province. The
Wasatch MO\lntain~ bound the east side of the valley and the west is bordered by the Oquirrh
Mountains. The valley has been filled with lacustrine sediments deposited in ancient Lake
Bonneville (precursor to the Great Salt Lake), interlayered with coalescing alluvial fans derived
from the adjoining mountains. "
Most of the surface soils of the ABY consist of dark silty sand, typically accompanied
by variable mixtures of coal, slag, brick, concrete, wood, rusted steel barrel fragments, and
miscellaneous paper, plastic, and metal trash. Most of the surficial material within the fenced
area. of the site appears to be fill rather than native soil. Fill thickness ranges from three to
seven feet and extends up to 21 feet within the former gas-o-meter.
Holocene (10,000 years old to present) marsh deposits consisting of interfingered lenses
of silt, clay, and clayey silt deposits UI1derlie this site. These sediments typically contain
significant percentages of c1ay size fractions even if they are classified as a silt,. sandy silt or
silty sand. The cJay content results in re1atively low permeability geologic units. Additionally,
some sand and gravelJayers occur Within these deposits. The shallow section (0-30 feet) is
mostly silt and cJayey silt with discontinuous thin sand and gravel Jayers. Below this section is
a permeable sand unit (2 to 6 feet) which overlies a blue cJay aquitaId at approximately 35 to
40 feet deep.
Surface Water and Groundwater
SuIface runoff patterns for rain or snowmelt are not well developed. at the site with
infiltration. and puddling in low areas (e.g., the railroad beds) the main pathway of drainage.
The only surface water body located in the immediate vicinity of the study area is City Creek,
which flows from east to west (toward the Jordan River) in a buried storm drain located near
the northem study area boundary. The elevation.of the buried drain is above the groundwater
surface, therefore flow from groundwater into the drain is not expected.
Groundwater hydrogeology beneath the site appears to occur in a single aquifer with two
distinct zones. The first zone (the shallow or unconfined zone) extends from the surface down
to about 40 feet. The unconfined zone has variable water quality throughout the Jordan River
Valley area and is not utilized as a drinking water so~ at the Site. Groundwater flow is from
the east to west across the site, from the Wasatch Mountain Front to the Jordan River drainage.
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.'" ._-,.,~.,;/'~,
12
and extends downward over 1,000 feet. Between the shallow, unconfined zone and the deep,
confined zone is a blue clay aquitard. The aquitard contains thin gravel and sand layers. The
deeper zone is commonly artesian, providing recharge to the shallow zone by up-welling at
locali7ed areas of interconnection. Groundwater flow is generally to the west toward the Jordan
River, which flows into the Great Salt Lake. The confmed zone is utilized as a drinking water
source in some areas of the valley.
Known and Su~ Sources of CODt~mination.
There are no discrete, undistUrbed waste sources remaining at the UP&U ABS. The gas-
o-meter consists of a buried tank constIUcted of masomy walls that appears to be intact. The
gas-o-meter still contains material that was left at the time of abandonment of the gasification
operations. Contents are thought to be primarily coal gas distillate materials consisting of free-
flowing tars; wastewater contaminated with soluble organics from the tar, and a non-pumpable
coal tar sludge. These wastes are typically high in BTEX compounds, phenolic compounds,
cyanide and PARs. When operations ceased, the gas-o-meter was back-filled with site related
debris, bricks, and soil on top of the gasification re1ated wastes.
All other tanks and stmctures required for the coal gasification and creosote pole-treating
opercItions have been removed. 'However, estimates of volumes of contaminant sources which
may have been left on-site at the time of abandonment can be made from the history of site
activities and records of other sites where similar operations have occurred. The largest building
associated with the coal gasification process was the coal storage building. Coal and s~ left
on site from past railway activities are found throughout the surface soil of the site. Coal is a
source 'of P AH COl'ltam1nants and slag 'provides a source of lead. Although stnIctures have been
removed from the site, remains from their contents or from waste disposal practices can be
found in several areas. These include contam1nation found in the area of the tar stills, the gas-o-
meter and an area referred to as the tar ~rm (Figure 2). Locations of possible contam1nant
sources are depicted on Figures 3 and 4.
Barrel storage operations likely resulted in the release of contam1nants to the surface
soils. Labels from empty barrels stored on the ABY included a wide range of possible
CODtam1nants. The barrels have been removed and no sources of contamination are left on the
yard.
Distribution of Contam1natiOn/ Affected Media
Surface and Subsurface Soils
Composite surface soils samples were collected from the 0 to 0.5 foot depth throughout
the study area. Analytical-results indicate a number of organic and inorganic chemicals present
consistent with coal and slag material found throughout the ABY and SEA in shallow soils.
Semi-volatile organics are prevalent across the ABY and SEA, primarily consisting of PAH
compounds from coal and some tarry areas related to creosote pole treating and! or coal
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~.~\~.:.-
.~-
"'.'~.
13
mglkg in the vicinity of the coal tar still. Surface soils were also found to contain numerous
other contamin~nts, including: toluene, trichloroethane, chlorinated pesticides,
organophosphorus pesticides, organochlorine herbicides, inorganic compounds (primarily metals
related to the slag), and cyanide. The wide variety of pesticides and herbicides are attributed
to barrel leakage or application for weed control. Surface soils in the NW A and residential
areas did not have the coal and slag materials present and related high levels of P ABs.
Another area of contamination at the site is a layer of calcareous fill material found over
a broad area in shallow soil. This material is likely a lime sludge associated with water
treatment processes which had been commonly used at coal gasification facilities. This'
calcareous material contains cyanide, a byproduct of coal gasification operations.
The _layer of calcareous material found across a large area of. shallow soil has been
sampled, analyzed, and found to contain lead, chromium, and zinc at trace concentrations.
Cyanide was detected at concentrations as high as 427 mg/kg in a test pit excavated in the SEA
and up to 647 mg/kg in a surface soil sample collected on-yard.
The primary contaminants present in subsurface soils are PAHs, naphthalenes, and BTEX
compounds associated with the history of coal gasification and creosote pole-treating operations.
The wide range of pesticides, herbicides and trichloroethane are noticeably absent from deeper
soils. Dense non-aqueous phase liquids (DNAPLs) and light non-aqueous phase liquids
(LNAPLs) have been observed in subsurface soils during drilling and monitoring well
installation. The NAPLs are visibly present in some areas but are not in a form which is
considered free or recoverable. DNAPLs have not been recovered in any monitoring wells:
LNAPLs are present as a sheen on top of water recovered from monitoring wells.
Generally across the site, with the exception of three areas, the unsaturated sub~ace
soils are reJatively clean. The three areas of concern include the vicinity of the gas-o-meter and
tar wells; the suspected vicinity of the coal tar still; and a zone of tarry contaminanon in the
SEA. While the intermediate contaminated soil zones do not cover a large percentage of the .
site, they are important because' they have contnbuted to deeper soil and groundwater
contamination.
Styrene .and BTBX compounds are the only voJatile organic compounds (VOCs)
contaminants found at depths below 4 feet. Total xylenes are the dominant compound of the
BTEX group, reaching a maximum concentration of 17 mglkg near the gas-o-meter. Styrene
was found in areas that also contain high BTBX compounds, however, not all areas contaminaied
with BTEX also contain styrene.
soils.
Two concentration levels of P AH contamination can be described in onsite subsurface
.
Soils at intermediate depths between the surface and the water table (4 to 15 feet)
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14
.
Soils near groundwater in contaminated zones of the site contain several hundred
up to several thousand mglkg.
Investigations at the Site have determined that there are no RCRA listed hazardous
wastes. No soils tested 'have failed the toxicity characteristic leachate procedure (TCLP)
analysis. At present, no RCRA hazaIdous wastes have been found at the Site. Testing during
remediation may find some soils that are RCRA characteristic hazardous wastes.
Tables 1 and 2 list minimum, maximum and average concentrations for only the
contaminants of concern. Deriving the contaminants of concern is explained in Section VI,
Summary of Site Risks. More detailed infonnation on all contaminants found at the Site and
concentrations can be found in the Remedial Investigation Report.
Table 1 Surface Soil Concentrations
Contaminants of Concern
- :1:::::1:1::.:i.I:'::.::.::!:I..:111":!:..:.I:I:I:I.:.1:1:::':'::"::::i'.:i:!:':I:::'::::.1:1::':::::'::.::11::iii11!,18'::.i::1"':i1'::':::::.::':::::.II::11::1:1::.:':1.:::i:.::1!:::::1:::::::":':':::;':':.:::1':'.::..:..::::.:1::.::
::::.::I::'i::::..::IIII::j:)j:i'::::::::ni:."::.li::'::".I~I:'::.':::i:iiij:'H':I:::'::::'.::1:::..::il..11I':i::!.:i!:::::':'I::::':::'::
Chrysene . 130 52.000 16.255
Benzo(b )f1uoranthene .em 52.000 12.273
Benzo(k)f1uoranthene .087 34.000 12 .702
Benzo(a)pyrene .095 5 1 . ()()() 16.080
Indeno(1 ,2,3-cd)pyrene . .078 25 . 000 8 .440
Dibenzo(a,h)anthracene .054 10.000 3 . 899
Dieldrin .002 .980 . 168
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....' -~."'"'-:-~,
15
Table 2 Subsurface Soil Concentrations
Contaminants of Concern
__11&1111-
Chrysene .057 150.000 115.096
Benzo(b )fluoranthene .050 110.000 8.254
Benzo(k)fluoranthene .042 130.000 8.617
Benzo(a)pyrene .076 130.000 9.613
Indeno(1,2,3-cd)pyrene .057 77.000 7.674
Dibenzo(a,h)anthracene .060 34.000 3.824
Lead .002 1.350 .123
Groundwater
Groundwater samples were collected from beneath some of the most contamin"ted areas
of the site. Based on the results of sampling one well in the deep aquifer, the deep, confined
aquifer zone does not appear to be COD~min~ted. In addition, water from within the confiIrlng
layer, close to the shallow aquifer, was found to be free from contamination.
Contamination found in the unconfined aquifer genexaIly parallels that of the subsurface
soils in natUre and extent.. The principal CODtamin~rits are benzene, styrene, phenols, and
naphthalene, with secondary C9Dtamination by inorganic compounds, primarily cyanide. Figure
5 presents the approximate boundaries of the extent of detectable organic and inorganic aqueous
plumes.
A layer of LNAPL was also found during the site investigation. The LNAPLs occur in
the uppermost levels of the groundwater in the unconfined aquifer, primarily in the vicinity of
the gas-o-meter in thc northeast portion of the site. The presence of LNAPLs in groundwater
has been described as a ., sheen It on the very top of the groundwater, and is not considered a
free, recoverable product.
--
The DNAPLs at the site occur primarily in the form of tar-like materials, which are solid
or viscous. These wastes are saturating subsoils in some areas, yet have not been demonstrated
to enter any of the monitor wells, even those installed in visibly contaminated locations. The
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CONTAMINATION
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Groundwater concentrations of benzene exceed TCLP regulated levels in some areas.
Table 3 lists minimum, maximum and average concentrations for groundwater
contaminants of concern.
Table 3 Groundwater Concentrations
Contamin=tnts of Concern
"'.",",",".',','.','.'.',",',",".",",".'.",",'.',",',,',',',",",",',.".",",',',".',.',',',...,'"',','.,",",',,".",',',',',',',",",,".'.".",'.",'.',',',".",",""',',',"".',',',",',',","
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Benzene .002 25.000 3.832
Toluene .001. 7.700 1.303
Styrene .005 1.400 .492
Xylene .006 3.100 .784
Phenol .001 67.000 8.713
2-Methylphenol .009 35.000 9.492
4-Methylphenol .001 57.000 15.320
2,4-DimethyJphenol .002 18.000 2.573
Napthalene .001 6.800 1.132
2-MethyJnaptbalene .001 .630 .105
Acenapthalene .002 .270 .057
Antimony .022 .052 .031
Lead .003.069 .029
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Principal Threats/Low Level Threats
In order to devise clean-up strategies that are acceptable for the site-specific wastes and
conditions, EP A developed the concept of defining the waste sources as either principal threat
wastes or low level threat wastes (A Guide to Principal Threat and Low Level Threat Wastes,
EPA Publication 9380.3-o6FS, November, 1991). The defInitions of each are as follows.
- -
.
A principal threat waste has one or all of the following characteristics: it may
be highly toxic or highly mobile, generally cannot be reliably contained, or would
present a significant risk to human health or the environment should exposure
occur. Where toxicity and mobility of source material combine to pose a
potential risk of 10"3 or greater, generally treatment altematives should be
evaluated. Based on this definition, principal threats at the UP&U ABS include
- those materials within and adjacent to the gas-o-meter (excluding the surface fill
and gas-o-meter fill) and the tar berm of the southeast area. Other areas that
contain non-aqueous phase liquids (NAPLs), mobile tarry material, or visibly
conrnminated soils saturated with NAPLs are' defmed as princ4>a1 threats. A
quantified definition of principal threats is based on the 10"3 risk level (see
Appendix A).
.
A low level threat waste can generally be reliably contained and would present
only a low risk in the event of release. This would include source materials that
exhibit low toxicity, low mobili1¥ in the environment, or are found at or near
. health-based concentration levels. Low level threats at the UP&U ABS include
all soils from 0.5 to 10 feet in depth which exceed remediation levels. These
soils have a potential exposure pathway for direct ingestion of soil.
Low level threat residuaJs are also present at the UP&U ABS and include those
contaminated soils below 10 feet in depth which do not have a potential exposure
pathway. These residuals are generally viscous, immobile tarry materials that are
not migrating in the subsurface. These visibly conrnminated soils were sampled
for treatability studies and analyzed by the TCLP test. This test method showed
these soils to leach low levels of contaminants. Although conrnminants may leach
from this material to groundwater, these materials are considered to be secondary
sources and not the primary source of groundwater CO!Jrnmin:ttion.
Figi1re 6 illustIates the location of the areas where principal threat wastes have been
defined and Figure 7 depicts those areas of low leve! threat wastes. Table 4 presents estimates
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LOCATION Of . .
PRINCIPAL THREATS
FIGURE 8
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!LLLJ SURFACE SOILS (0-0.5' DEPTH)
~ APPROXIMATE LOCATION OF COAL
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SOILS (q.S'-10' DEPTH)
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LOCATION OF LOW-LEVEL THREATS
(LOW-LEVEL THREAT
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Table 4 Summary of Waste Volume Estimates
Waste Category Estimated Volume
(cubic yards)
Principal Threat W astes
Gas-o-meter contents 4,250
10% external gas-o-meter soils 425
Tar Berm 985
LNAPL west of gas-o-meter 570
LNAPL SEA included with tar berm
Low-Level Threat Wastes
Coal tar still tars and soilS 3,065
On-yard calcareous fill 3,445
Off-yard calcareous fill 750
On-yard surface soils (0 to .5 foot depth 4,600
plus gas-o-meter fill)
Off:-yard surface soils 950
PQpUlation and Environmental Areas Potentia ny Affected
The UP&U ABS is a relatively small site and is located in an urban 'area characterized
by a mixture of residential, commercial, and industrial land use. Populations most likely to be
exposed to site coornminants are trespassers on the ABY and SEA portions of the study area.
TIaDSientS and local residents would be the most likely trespassers. Local worlrers could' also
possibly be exposed to site conf2minants.
, Contamin:ated groundwater (the piume) is presently located only within the city block
which the UP&U ABS occupies and has not been demonstrated to affect other groundwater zones
or surface water. In addition, the groundwater at the site is not used as a drinking water source
at the present time. '
Based on the investigations for the Risk Assessment, there are no known threatened: or
endangered pJant or animal species in the area that are likely to be affected by direct on-site
exposure. Runoff of conf2minants to rivers or wetlands is not believed to be a significant
problem. Therefore, based on these considerations, the ecological impact of on-site
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Potential Pathways of Contaminant Migration
The RIfFS stated that organic chemical contaminants are migrating in directjons away
"from the site via groundwater and will continue to do so if the site is left in its present condition.
Under current conditions, results of analytical data from the RI suggests that the contamin~ted
plume has not migrated outside of the city block comprising the study area. Rates of migration
can be estin1atec:1 from groundwater computer models with input parameters based on the
observed extent of contamination and inferences regarding the source and age of wastes present
in the saturated soil zones. For exao:iple, it was estimated in the RI that contamination has
moved SOO feet in 100 years (S feet per year) assuming the gas-o-meter/tar wen is the principal
contaminant source. However, assuming the creosote component is a major contributor to the
observed northwesterly limit of contamination, and the suspected creosote pit locations are the
source, then organic chemical contaminants have migrated approximately 400 feet in SO years
(8 feet per y.ear). Modeling of groundwater shows biodegradation may be a significant factor
in the dynamic equilibrium of the organic contaminant plume.
Modeling of airbo~e transport of contamination in the Risk Assessment indicates that
wind blown dust is not a major Concern for off-site transport of contaminants.
VI SummAry of Site Risks
A Baseline Risk Assessment (BRA) was conducted for the UP&U ABS to determine the
potential adverse effects on humans and the environment which may result, either now or in the
future; from the presence of hazardous chemicals at the site. By definition, a BRA evaluates
the site in its current condition (that is, in the absence of any remedial activities or institutional
controls that reduce" exposure or risk).
Contaminants of Concern
Chemical contaminants of potential human health concern. were identified based on the
" results of the RI performed at the. site. Any chemical detected in any sample of surface" soil,
subsmface soil, or groundwater was included in the list of potential conhlminants of concern,
except for eight natuIaIly-occurring beneficial mineIals (calcium, iron, zinc, etc.) and nine
organic chemicals which were detected so infrequently.(only once or twice out of all samples)
that their ~ was judged to be minimal. This resulted in the identification of 74
contaminants of potential concern, including 14 volatile organic compounds, 31 semi-volatile
organic compounds (of which 17 are PAHs), 13 pesticides, 3 PCBs, and 13 inorganics.
Although some of these chemicals (especially the inorganics) may be partly or entirely
natural in origin, and others may have originated from off-site sources, chemicals were not
eliminated during the risk assessment process on the basis of comparison to "background" in
order that risk calculations would yield the best possible estimate of total risk from the site.
-------
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23
Exposure Assessment
The second step in risk assessment is to identify exposed populations and the extent to
which these populations are exposed to site related contamination. The exposed populations
include persons currently exposed and those that may be exposed in the future. CUITently
exposed populations include residents living within the study area and trespassers on the site.
Future populations potentially exposed would include resident adults and children who could
possibly live on the American Barrel Yard or workers exposed if the site is developed for
commercial use. Additionally, future potential exposure includes the use of and exposure to
contaminated groundwater.
. .
Cunently, the ABY is a fenced, vacant lot in a primarily industrial area which is zoned
for indu~ use. Under these conditions, the populations most likely to be exposed to site-
related contaminants are the residents who cUITently live along the western boundary of the study
area, as well as site visitors or trespassers who periodically go onto the vacant areas of the ABY
or SEA. These populations are most likely to be exposed to site-related contaminants by direct
contact with soil. This includes incidental ingestion, dermal contact, and inhalation of soil
particles in air. The soil ingestion and inhalation pathways were evaluated, but current risk
assessment methods do not allow for reliable evaluation of exposure and risks from dermal
contact with soil for many of the site contamin~ts, so this pathway was not quantified.
In the future, the ABY or SEA might be developed for either residential or industrial use.
Although commercial development is probably more likely, both optionS appear possible, so
risks to both future residential and industriall commercial worker populations were evaluated.
These populations would be exposed to contaminated soils by the same pathways as described
above, except that future constmction and excavation activities might bring contaminated soil
from the subsurface to the surface. Thus, exposure to both current surface soils and subsuIface
soils was assessed.
Future workers or residents could possibly be exposed to contaminants through use of
groundwater from on-yard or nearby off-yam wells. Exposure pathways of concern would
include not only ingestion of the water, but also dermal contact and inhalation of VOCs released
from the water into indoor air. As in the case for exposure to soils, both the ingestion and
inhalation pathways were evaluated for gro~dwater exposure. The dermal pathway was not
evaluated in a quantitative manner because dermal exposure to water is expected to be relatively
brief (typica1ly 7 to 12 minutes per day for residents during showering), and reliable values for
dermal permeability constants are currently available for only a small number of chemicals.
The second part of the exposure assessment is to detennine what levels of contamination
an exposed person would encounter. The dose of a chemical to which a human is exposed
depends upon the concentration of the chemical in environmental media (air, water, soil, etc.),
and the amount of time the human is in contact with each medium (how much air breathed, how
much water ingested, etc.). For the purposes of estimating exposure at this site, the study area
was divided into four areas: 1) the current residential area (CRA), located along the western
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24
between the two railroad lines; 3) the Northwest Area (NW A), located northwest of the ABY;
and 4) the Southeast Area (SEA), located southeast of the ABY. The concentration of each
chemical in each of these four areas was calculated for surface soil, subsurface soil, and
groundwater. Human exposure levels were estimated using either the upper 95th percentile
confidence limit of the arithmetic mean '(reasonable maximum exposure-RME) or the highest
detected value (whichever was smaller). For samples where a chemical was not detected, the
concentration was usually assumed to be one-half the detection limit. Table.5 summarizes the
levels of human contact with environmental media that were assumed for each population and
each pathway.
Table 5 Summary of Human Exposure Parameters
Exposed General Exposure Exposure Route
Population Parameters Medium Route Parameters (RME)
Resident Body Weight = 70 kg Groundwater Oral 21/day
Aduft Exp. Freq. ... 350
daV/yr Indoor Air Inhalation (VOCS) (five x oral intake)
Exp. Duration = 30 yr Soil Oral 100 mg/day (24
yr)
200 mg/day (6 yr)
Air (PM,oS) Inhalation 20 m3/day
Resident Body Weight = 15 kg Groundwater Oral 1 I/day
ChIld Exp. Freq. = 350
day/yr Indoor Air Inhalation (VOCS) (five x oral intake)
Exp. Duration ... 6 yr Soil Oral 200 mg/day
Air (PM,oS) Inhalation 24 m3/day
Worker Body Weight = 70 kg Groundwater Oral 1 I/day
Exp. Freq. = 250 Inhalation (VOCs) (five x oral intake)
day/yr Indoor Air
Exp. Duration = 25 yr Soil Oral 50 mg/day
.
Air (PM,oS) Inhalation 20 m3/day
Trespasser Body Weight - 43 kg Soil Oral 100 mg/day
(7-16 Exp. Freq. = 50 day/yr
years) Exp. Duration ... 10 yr Air (PM,oS) Inhalation 1.4 m3Jhr
TimeNisit - 2 hr/dav
kg ... kilogram
I/day = liter per day
m3/day = cubic meters per day
m3Jhr ... cubic meters per hour
mg/day = milligrams per day
yr = year
PM,o = particulates less than 10 microns
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25
Toxicity Assessment
The third step in risk assessment is to determine the toxic effects of exposure to site
contamination. Toxic effects are separated into cancer 'causing effects and non-cancer effects.
Cancer slope factors (SFs) have been developed by EPA's Carcinogen Assessment Group
for esrimCJting excess lifetime cancer risks associated with exposure to potentially carcinogenic
. chemicals. Table 7 lists cancer slope factors for contamin=tnts of concern and the SOUtee.
There are two sets of slope factors avallable for evaluating P AHs. One set conservatively
assumes that all P AHs are as potent as benzo(a)pyrene. The other set of slope factors is based
on the re1a!ive potency to benzo(a)pyrene, based on stroctural-activity comparisons between
P AHs~ Because of the uncertainty associated with these slope factors, cancer risks from P AHs
were evaluated using both sets of values. Slope factors presented in Table 7 are based on
relative potency relationships.
Reference doses (RIDs) have been developed by EP A for indj~ting the potential for
adverse health effects from non-carcinogenic chemicals. Reference doses are listed in Table 6
for non-carcinogenic coDt.amin~nts of concern.
Risk Characterization
The final step in the risk assessment process is to evaluate the risks, both current and
potential, to exposed populations.
Excess lifetime cancer risks are determined by multiplying the lifetime average intake
level by the cancer potency factor. These risks are probabilities that are generally expIeSsed in
scientific notation, for example 1 X 106 (or IB-(6). An excess lifetime cancer risk of 1 X 1
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Table 6 shows the estimated total excess cancer risks for the populations exposed in the
study area. Estimated risks to current residents exposed to soils in. their yards and
visitors/trespassers exposed to contaminated soils on the ABY, NW A or SEA range from about
6 X IO-S to 5 X 1{)"'. The risks are within or below EPA's range of acceptable risks (1 X lQ4
to 1 X l~. The'risks to current residents is primarily due to background levels of arsenic in
soil.
However, potential cancer risks to hypothetical future residents or workers are much
higher, .ranging from 5 X I ()"2 to 3 X 1
-------
Exposure Future Future
Point Realdent Worker SF Weight of Type of SF
Concentrat 01 01 (mglkg- Evidence Cancer Source
Ion !mgJkg-day) (mglkg-day) day)" Future Future
(mgJkg) Resident Worker
8enzo(a)pyrena 36.6 6.7 x 10" 8.0 x 1~ 1.2 X 10' 82 Stomach HEAST 7 X 10" 7 X 10.8
. I
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Table 7 Cancer Risk Estimates for Contaminants of Concern
Chamlcal
8enzola)anthracene 29.1 4.7 x 10" 4.8 x 10" 1 .2 x ~ 0" 82 (a) HEASTi'"
Chry8ene 36.8 6.7 x 10" 8.1 x 1~ 1.2 X 10" 82 (a) HEAST
Benzo(b)fluoranthena 30.2 4.8 x 10" 6.1 x 10" 1.2 x 10' 82 (a) HEAST
Banzolk)fluoranthene 27.0 4.3 x 10" 4.8 x 1 ~ 1.2)( 10" 82 la) HEAST
Indano(1,2,3-cd) 18.1 2.8)( 10" 3.1 )( 10" 1.2 X 10" 82 (a) HEAST
pyrene
0Ib8nzla,h)anthracene 7.3 1.2)( 10" 1.2 x 10" 1.2 X 10' 82 (8) HEAST
Dieldrin .47 7.6 x 10.7 8.0)( 10" 1.8 )( 10' 82 Llvar, Lung IRISc.,
. .
~7
Chemical-Specific Risk
'.'
8 X 10" 8 X 10.7
7 X 10" 7 X 10.7
8 X 10" 8 X 10"
6 X 10" 6 X 10.7
3 X 10" 4 X 10.7
1 X 10" 1 X 10"
1 X 10" 1 X 10.8
1.4 X 10" 1.4 X 10"
Total Pathway RI8k
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8enzo(a)pyrana 18.0 2.9)( 10" 3.1 x 10" 1.2 X 10' 82 Stomach HEAST 3 X 10" 4 X 10"
8anzo(a)anthracena 20.0 3.2 )( 10" 3.4 )( 1~ 1.2)( 10" 82 la) HEAST 4 X 10" 4 X 10.7 f
Chryeene 22.0 3.6 )( 10" 3.7)( 10" 1.2)( 10" 82 la) HEAST 4 X 10" 4 X 10.7
Benzo(b)fluoranthene 9.4 1.6 x 10" 1.8 )( 10" 1.2)( 10' 82 (a) HEAST 2 X 10" 2 X 10" A.. ~;;
t
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Benzolk)fluoranthene 14.0 2.2 x 10" 2.4 x 10" 1.2)( 10" 82 (0) HEAST 3 X 10" 3 X 10.7 ~~i\¥
..,
IndenoI1,2.3-cd) 10.0 1.6x10" 1.7 x 1~ 1.2)( 10" 82 (0) HEAST 2 X 10" 2 X 10.7
pyrene
6.0 8.0)( 10" 8.6 X 10.7 1.2)( 10' 82 la) HEAST 1 X 10" 1 X 10.8 .'
Dibenzla,h)anthracene , '~;f
,'\.;
Total Pathway Risk 8.1 X 10" 7.1 X 10-8
-------
28
Table 7 Cancer Risk Estimates for Contaminants of Concern (cant.)
Exp08ure Future Future I Chemical-Specific Risk
Point Resident Worker SF Weight of Type 0' SF
Chemioal Conoantrat DI DI (mglkg- Evidence Cancer Source
Ion (mglkg-day) (mglkg-dayl day)"' Future Future
(mglkgl Resident Worker
Benzola)pyrene 1 3.9 1 .9 x 10" 2.0 x 1~ 1 .2 X 10' B2 Stomaoh HEAST 3 X 1 0" 3 X 1 0"
Benzola)anthracene 1 1 .9 2.2 x 1 0" 2.4 x 1 ~ 1 .2 x 1 0" B2 la) HEAST 2 X 1 0" 2 X 1 0.7
Chrysene 1 8.2 2.8 )( 1 0" 2.8 x 1 ~ 1 .2 x 1 0" B2 lal HEAST 3 X 1 0" 3 X 1 0.7
Benzolb)fluoranthene 1 2.2 2.0 x 1 0" 2.1 x 1 ~ 1 .2 X 10' 82 la) HEAST 2 X 1 0" 2 X 1 0-1
Benzolk)fluoranthene 1 3.3 2. 1 x 1 0" 2.3 x 1 ~ 1 .2 X 10" B2 la) HEAST 3 X 10" 3 X 1 0.7
Indonol1 .2.3-cdl 9. 1 1 .6 x 1 0" 1 .6 x 1 ~ 1 .2 X' 1 0" B2 (a) HEAST 2 X 1 0" 2 X 1 07.
pyrena
Dibenzla.hlanthracone 3.8 8.0 x 1 0" 8.4 x 1 (t7 1 .2 x 1 0' B2 lal HEAST 7 X 10" 8 X 1 0"
Total Pathway Risk 6.8 X 1 0" 6.9 X 1 0-11
Banzolalpyrono 9.2 1 .6 x 1 0" 1 .8 x 1 ~ 1 .2 x 1 0' 82 Stomaoh HEAST 2 X 1 0" 2 X 1 0"
Banzolalanthracono 9. 1 1 .6 x 10" 1 .6 x 1~ 1 .2 x 1 0" B2 lal HEAST 2 X 1 0" 2 X 1 0.7
Chrysane 1 1 .0 1 .8 x 1 0" 1 .9 x 10" 1 .2 x 1 0" B2 (a I HEAST 2 X 1 0" 2 X 1 0.7
Bsnzolblfluoranthona 8.9 8.2 x 1 0" 8.7 X 1(t7 1 .2 x 1 0' 82 lal HEAST 1 X 1 0" 1 X 1 0"
Banzolklfluoranthana 7.4 1 .2 x 1 0" 1 .3 x 1~ 1 .2 x 1 0'\ B2 lal HEAST 1 X 1 0" 2 X 1 0.7
Indano(1 .2.3-cd) 4.7 7.6 x 1 0" 8.0 X 1(t7 1 .2 x 1 0" B2 la) HEAST 9 X 1 0.7 1 X 1 0.7
pyrena
Dibenz(a. hlanthracana 2.0 ' 3.2 x 1 0" 3.4 x 1 (t7 1 .2 X 10' 82 (a) HEAST 4 X 1 0" 4 X 1 0"
Total Pathway Risk 3.6 X 1 0" 3.6 X 1 0-11
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Table 7 Cancer Risk Estimates for Contaminants of Concern (cont.)
Expolure Future Future Chemic III-Specific Risk
Point Relldent Worker SF Weight of Type of SF
Chemical Concentrat DI DI Imglkg- Evidence Cancer Source
Ion Imglkg-dllYI Imglkg-dayl day)"1 Futura Futura
'malkal Resident Worker
Benzolalpyrene .26 4.0 X 1 0.7 4.3 X 1 o. 1 .2 X 1 01 82 Stomach HEAST 6 X 1 0" 6 X 1 0.7
Benzolalllnthrllcene .26 4.0 X 1 0.7 4.3 X 1 o. 1 .2 x 1 0.1 B2 lal HEAST 6 X 1 o. 6 X 1 0"
Chry\l8ne .28 4.6 x 1 0.7 4.8 x 10" 1 .2 x 1 0.1 82 lal HEAST 6 X 1 o. 6 X 1 0"
Benzolblfluoranthene 1 .0 1 .6 x 1 0" 1 .7 x 1 0.7 1 .2 x 1 01 B2 lal HEAST 2 X 1 0" 2 X 1 0"
Benzolklfluoranthene .26 4.0 x 1 0.7 4.3 x 1 0" 1 .2 x 1 0.1 B2 lal HEAST 6 X 1 0" 6 X 1 0"
IOOenol1 ,2,3-cdl 1 .0 1 .6 x 1 0" 1 .7 X 10" 1 .2 x 1 0.1 82 lal HEAST 2 X 1 0.7 2 X 1 0"
pyrene
.
Total Pathway Rilk 2.6 X 1 0" 2.6 X 1 0"
Benzene 21 .0 Img/ll 1 .6 x 10° 4.3 x 1 0" 2.9 x 1 0.2 A Leukemia IRIS 6 X 1 0.2 1 X 1 0.2
1 ,2-Dlchloroethene .3 1 2.3 x 1 0.8 6.6 x 1 0" 9. 1 x 1 0.8 B2 (Insert 1 1 IRIS 2 X 1 0.8 6 X 1 0"
Styrene 1 .4 9.7 x 1 0.2 2.9 x 1 0.2 2.7 )( 1 0.2 82 (Insert 21 HEAST 7 X 1 0" 2 X 1 0"
Total Exposure Risk: Inge8t1on and Inhalation of GroundWater 6.3 X 1 0.2 1 1 X 1 0.2
(Insert 1 I: Forestomach, circulatory system, mammary gland, lung
(Insert 21: Leukemia, lung, bronchi
29
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lal Thle PAH 18 lese well 8tudled then benzolalpyrene; however, the tumor types are assumed to be equivalent to benzolalpyrene for each route ofaxposure. . .
Ibl U.S. Environmental Protection Aganoy, 1991. Office of Research and Development. Health effect8 aS8essment8 8ummary table8, Wa8hlngton, D.C. U.S. Environmental Protecftion
Agency. OERR 9200.6-303 191-1). .
Icl U.S. Environmental Protection Agenoy, 1991. Office of Health and Environmental A8se88ment. Retrieved from tha Integrated Risk Information System URISI. Decemi!er, 1991.
DI = Daily Intaka
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30
Potential concern for noncarcinogenic effects of a single contaminant in a single medium is
expressed as the hazard quotient (HQ), which is the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the contaminant's reference dose. By
adding the HQs for all contaminants within a medium or across all media to which a given
population may reasonably be exposed, the. Hazard Index (HI) can be generated. The In
provides a useful reference point for gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
In values for the populations exposed at this site are summarized in Table 8. As shown,
vatues for current onsite residents and site visitors/trespassers are all less than one, indicating
noncancer risks are not of concern under. current exposure conditions. .
HI values exceed one for all hypothetical future populations, with values ranging from 1 to
139. These risks are due to hypothetical exposures to groundwater, both by ingestion of semi-
volatile organics (phenols, naphthalenes) and inorganics (cyanide, arsenic, antimony) and by
inhalation of VOCs released to indoor air from water (toluene, xylene). Exposure to soils does
not present unacceptable non-cancer risks based on the risk assessment. Detailed information
used for the In calculations are presented in Table 9.
Table 8 Summary of Population Total Hazard Index Values
Exposed Population Exposure Location Screening Level HI Value
Current On-Site Resident Adults Current Residential 0.3
Area
Current on-Site Resident Current Residential 0.5
Children Area
Current On-Site American Barrel Yard 0.04
VlSitorfTrespasser Southeast Area 0.007
Northwest Area 0.01
Future On-Site Resident Adults American Barrel Yard 140
Southeast Area 4
Northwest Area 4
Future On-Site Resident Children American Barrel Yard 65
Southeast Area 7
Northwest Area 4
. Future On-Site Workers American Barrel Yard 55
Southeast Area 1
Northwest Area 1
Noncancer risks from exposure to soil do not appear to be of significant concern, except that
elevated levels of lead in soil would pose potentially significant risks to hypothetical future child
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national average default values for human exposure parameters, coupled with. site specific'
measurements of lead in soil and groundw~ter. Based on these data, it appears that 19 to 76%
of hypothetical future populations of resident children would have blood levels higher than
currently considered acceptable (10 pg/dl).
Based on the results of the risk assessment, actual or threatened releases of hazardous
substanCes from this site, if not addressed by implementing the response action selected in this
ROD, may present an imminent and substantial endangerment to public health, welfare, or the
environment.
Uncertainties
There are a number of steps in the risk assessment process where uncertainty exists. In
general, EPA employs conservative assumptions when uncertainties arise and data gaps exist.
For example, EP A intentionally seeks to calculate doses to humans that on average are higher
than most people would actually receive, but are still within a reasonable range. Likewise, in
order to provide an adequate margin of safety, EP A employs estimates of chemical toxicity that
are intentionally conservative; that is, they are more likely too high than too low. An example
of this is cancer slope factors in which the .upper-bound" reflects the conservative estimate of
the risks calculated from the cancer slope factor. Use of this approach makes underestimation
of the actual cancer risk highly unlikely. Cancer slope factors are derived from the results of
human epidemiologicaJ studies or chronic animal bioassays to which animal-to-human
extrapoJation and uncertainty factors have been applied. Another example is that of RIDs. RIDs
are derived from human epidemiological studies or anim91 studies to which adverse health effects
from exposure to chemicals exhibiting uncertainty factors help ensure that the RIDs will not
underestimate the potential for adverse noncarcinogenic effects to. occur. When reference doses
are not yet available for a compound, such as many of the PAHs, data gaps are filled by
extrapoJation of reference dose values for compounds having similar chemical structures.
There is often uncertainty inherent in calculating exposure point concentrations, especially
if the available data have a high frequency of non-detects, or if there are only a few data points
in the data set. Other uncertainties in the data are further discussed in the full BRA report.
Because of these uncertainties, both those which tend to overestimate and underestimate exposure
and risk, all of the risk estimates contained in the risk assessment should be considered to be
-------
32
Table 9 Subchronic Hazard Index Estimates
Exposure to Ground Water - Ingestion and Inhalation
Future Adult Residents at the ABY
I
Expolure Point
Concentration COI RfO Confidenoe RfO RfD 8aele Hazard
Chemical (mgnl (mg/ltg-day) (mg/ltg-day) Level Critical Effect Source (Vehicle) auotient
Toluene - Ingeet. 7.0 1.9 x 10"\ 2.0 X 10'\ Medium Uver, kidney weighte IRIS (a) Corn Oil 0.9
Toluene. Inhal. (VOCII 7.0 9.6 x 10'\ 6.7 X 10'\ . CNS HEAST Air 2
Xylenel 3.1 4.1 x 10'\ 8.8 X 10.2 Medium CNS, devel. effecte HEAST 6
. 1 .8 x 10-\
Naphthalene 8.8 4 x 10"' . Saveral HEAST - 40
2-Methylnaphthalene 1.8 4.2 x 10"2 4 x 10",101 - - (c) - 10
Acenephthene 1.6 4.1 X 10.2 8 x 10.2 Low Liver IRIS . 0.7
Acanaphthylene 1.4 3.7 x 10-2 8 X 10"2141 - - (d) - 0.8
Anthracene 1.6 4.2 x 10.2 3.x 10'\ Low None IRIS - 0.1
Phenanthrene 1.6 4.1 x 10.2 3 X 10.2101 - . (el - 1
Fluorene 1.6 4.1 X 10.2 4 x 10.2 Low Dec. RBC, hemoglobin IRIS Corn Oil 1
Phenol 67 1.6 x 10° 8 X 10'\. Low Devel., kidney effectl IRIS Water 3
2,4-0imethylphenol 18 4.9 x 10-\ 2 X 10.2 Low .Clinical hemato. IRIS Corn Oil 20
2-Methylphenol 33 8.9 x 10'\ 6 X 10.2 Medium Red. body wt. gain, IRIS - 20
neuro. tax.
4-Methylphenol 64 1.4 x 100 6 X 10.2 Medium Red. body wt. gain, IRIS . 30
nauro. tax.
Cyanide 3.1 8.2 x 10"2 2 X 10.2 Medium Weight loee, thyroid, IRIS Food 4
myelin degen.
Antimony .03 7.1 x1 ~ 4 x 10" Low Dec. longevity, IRIS Water 2
blood chem.
Total Expoeure Hazard Index 140.3
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Table 9 (cont.)
Subchronic Hazard Index Estimates
Exposure to Ground Water - Ingestion and Inhalation
Future Child Residents at the ABY .
Exposure Point
Concentretlon COI RfO Confldenoe RfO RfO 8eele Hezard
Chemical (mgn) (mg/kg-day) (mg/kg-day) Level Crltloal Effeot Source (Vehlole) Quotient
Toluene - Ingeet. 7.0 4.6 x 10" 2 x 10° . Liver, kidney welghte HEAST Corn Oil 0.2
Toluene - Inhel. (VOCe) 7.0 2.2 x 10° 6.7 x 10" - CNS HEAST Air 4
Xylenee 3.1 9.8 x 10". 8.8 x 10" . CNS, devel. effeote HEAST Air 10
Naphthalene 8.8 4.2 x 10" 4.0 x 10" - Severe! HEAST . 10
2-Methylnephthelene 1.6 1.0 x 10" 4.0 x 10.1101 - - (01 - 3
Aoenaphthene 1.6 9.8 x 10" 6.0 X 10" . Liver HEAST - 0.2
Acenaphthylene 1.4 8.9 x 10" 6.0 X 10"1~ - - Idl - 0.1
Anthreoene 1.6 9.8 x 10" 3.0 x 10° - None HEAST - 0.03
Phenanthrene 1.6 9.8 x 10.1 3.0 X 10"'" - . lei . 0.3
Fluor~na 1.6 9.8 x 10.1 4.0 x 10" . Deer. RIC., HEAST Corn Oil 0.2
hemoglobin
Phenol 67 3.8 x 100 8.0 X 10.1 . Oevel., kidney effecte HEAST Water 8
2,4.0imethylphenol 18 1.2 x 10° 2.0.x 10.1 - Cllnloal hemato. HEAST Corn Oil 8
2-Methylphenol 33 2.1 x 10° 6.0 x 10.1 - Rod. body wt. gain, HEAST - 4
nauro. tox.
.
4-Methylphenol 64 3.4 x 100 6.0 X 10" . Red. body wt. gain, HEAST - 7
neuro. tox.
Cyanide 3.1 2.0 x 10" 2.0 x 10" - Woight 1088, thyroid, HEAST Food 10
myelin degen.
Antimony .03 1.7 x 10" 4.0 x 10" . 000. longevity, HEAST Water 4
blood ohem.
Total Expo8ure Hazard Index 66
. .
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34
Table 9 (cont.)
Subcbronic Hazard Index Estimates
Exposure to Ground Water - Ingestion and Inhalation
. .Future Workers at the ABY
Expo8ure Point
Concentration CDI RfD Confidence RfD RfD 8a818 Hazard
Chemical (mgn) (mglkg-day) (mglkg-day) Level Critical Effect Source (Vehlcla) Quotient
Toluene - Inge8t. 7.0 8.9 x 10.2 2.0 X 10" M Uver, kidney welghte IRIS (a) Corn Oil 0.3
Toluene - Inhal. (VOCe) 7.0 3.4 x 10" 6.7 X 10.1 . CNS HEAST Air 0.6
Xylanee 3.1 1.6 x 10" 8.6 X 10.2 M CNS, devel. effecta HEAST 2
Naphthalene 8.6 6.4 x 10.2 4 x 10" . Several HEAST - 20
2-Methylnaphthalene 1.6 1.6 x 10.2 4 X 10.1 . . (c) - 4
. Acenaphthane 1.6 1.6 x 10.2 8 X 10.2 L Uver IRIS - 0.2
Acenaphthylene 1.4 1.4 x 10.2 6 x 1 0.2100 - . (d) - 0.2
Anthracene 1.6 1.6 x 10'2 3 X 10.1 L None IRIS - 0.06
Phenanthrene 1.6 1.6 x 10.2 3 x 10.2(0) - . (e) - 0.6
Fluorene 1.6 1.6 x 10.2 4 X 10.2 L Dec. RBC., hemoglobin IRIS Corn Oil 0.4
Phenol. 67 3.6 x 10" 6 x 10-' L Devel., kidney effeot8 IRIS Watar 0.9
2,4-Dlmethylphenol 18 1.8 x 10" 2 X 10.2 L Cllnioal hemato IRIS Corn Oil 9
2-Methylphenol 33 3.2 x 10" 6 X 10.2 M Red. body wt. gain, IRIS . 6
neuro. tox.
4-Methylphenol 64 6.2 x 10" 6 x 10-2 M Red. body wt. gain, IRIS - 10
neura. tox.
Cyanide 3.1 3.0 x 10.2 2 X 10.2 M Weight loe8, thyroid, IRIS Food 1
myelin degen.
Antimony .03 2.8 x 10" 4 X 10" L deo. longevity, IRIS Water 0.8
blood chem.
Total Expo8ure Hazard Index 66.8
el U.;j. ~t'A. 11181. Office 0' Heanh anet tnVlronmentel A..e..ment. Retnevel 'rom the Integreted Ri.k In'onn.t,on " - venetlon In human aen.nlVlty
Ibl
Sy.tem URIS I. December. 1991.
U.S. EPA. 1991. Office of Re...rch end Development. Health effect. e..e88ment .ummery teble.. We.hlngton,
DC: U.S. EPA. OEAR 8200.8-303181-11.
Velue estimated by using the RfD for naphthalene.
V imeted by using the RfD for ecenephthylene. leI
A - Anlmel to hum en extrepoletlon
8 - Extrepoletion from eubehronlc to chronic NOAEL
L - Extrepoletlon from LOAEL to NOAEL
CD' - Chronic Dally Intake
RfD - Reference Do.e
leI
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vn Remedial Action Objectives
..
Remedial action objectives were developed by EP A and UDEQ based on an evaluation
of the Baseline Risk Assessment. These objectives incorporate joint decisions on risk
management issues and were used to guide the development of alternatives and performance
standards. The objectives developed are: .
1. Remediate groundwater contamination on the site throughout the area of attainment
resulting from past activities on the ABY to: 1) remediation levels identified in Table 8;
and 2) levels which result in a total carcinogenic risk of less than lxl04 and a total non-
carcinogenic hazard quotient of less than one for residential exposure.
2. Remediate soil contamination resulting from past activities on the ABY to acceptable
risk based levels allowing for unrestricted exposure and unlimited use of the site. Soils
down to a depth of 10 feet are considered to have a potential exposure pathway and will
be remediated to health based remediation levels in Table 7. Soils below 10 feet do not
have a potential direct ingestion exposure pathway.
~ analysis of the Risk Assessment in Conjunction with the Remedial Action Objectives
indicates remediation is required for the following areas and media:
- American Barrel YanI: surface soils and subsurface soils
-Southeast Area(Denver Rio Grande Western property): surface and subsurface soils;
tar berm area;
-Groundwater beneath the entire site exceeding remediation levels including but not
limited to the ABY, SEA, and NW A.
Remediation Levels
Remediation levels were developed by considering the non-carcip.ogenic and carcinogenic
exposure limits (ELs), as well as applicable or relevant and appropriate requirements (ARARs).
EL& are health-based acceptable concentrations and have been calculated using standard exposure
models for workers (commercial/industrial use) and children/adults (residential use). The
ARARs used are the most stringent of the potential ARARs identified in the Site Characterization
Report.
ARARs do not exist for soils, so remediation levels are determined by the EL for future
wmkers at the risk level of 1 X 1()"6. These remediation levels will also provide an acceptable
risk to future residential exposure within the acceptable risk range of 104 to 1()"6.
The remediation level for lead in soil is based on use of the IU/BK model and national
average default values for human exposure parameters . and the goal of less than 5 % of the most
sensitive population (children) having blood lead levels exceeding 10 pg/dl.
For groundwater, the remediation level is the MCL or proposed MCL for the COCo
However, if no MCL or proposed MCL exists for the contaminant, the remediation level is the
EL for a future residential exposure through inhalation plus ingestion exposure ecluivalent to a
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National Primary Drinking Water Regulation, "Action Level" .
Remediation levels for soil and water are shown on Tables 10 and 11, respectively.
These remediation levels are the result ~f an evaluation of the risks as estimated in the risk
assessment, combined with risk management decisions. Cleaning up coDt;lmjn~tion to these
levels will result in acceptable risks to current and future exPosed populations.
Table 10 Health Based Remediation Levels for Soil (0' to 10' depth)
I Chemical I Remediation Level I
(mglkg)
Benzo(a)pyrene 0.48
Benzo(a)anthracene 47.7
Chrysene 47.7
Benzo(b)fluoranthene 0.48
Benzo(k)fluoranthene 47.7
Indeno(1 ,2,3-cd)pyrene 47.7
Dibenzo(a,h)anthracene 0.48
Dieldrin 0.36
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Table II RemediatiQn Levels for GroundWater
-
Chemical Remediation Level Basis for Remediation
(pgll) Level -
Benzene 5 MCL
Styrene 100 MCL
1 ,2-Dichloroethane 5 MCL
Toluene 1000 MCL
Xylenes 10000 MCL
Naphthalene 1460 EL
2-Methylnaphthalene 1460 EL
Aceuaphthylene . 2190 EL
Phenol 21900 EL
2,4-Dimethylphenol 730 EL
2-Methylphenol 1830 EL
4-Methylphenol 1830 EL
Antimony 5 MCL
Cyanide 200 MCL
-------
.38
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vm Description of Alternatives
A feasibility study was conducted to develop and evaluate remedial alternatives for the
contaminated soils and groundwater of the UP&UABS. Within the FS Report, many-
technologies and process options are presented. Criteria used to evaluate the alternatives for
applicability at this site and to conduct' the initial screening of the alternatives are expJained
within the FS Report. Remedial alternatives were assembled froni 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 the nine
criteria as required by the NCP. Summaries of the alternatives retained for final consideration
to address the overall site problems are listed below. More detailed descriptions can be found
within the FS Report. In addition to the remedial alternatives, the NCP requires that a no-action
and a limited action alternative be considered at every site. The no-action alternative selVes
primarily' as-a point of comparison for other alternatives.
Alternative 1 - No Action
The no-action 8J.temative includes groundwater monitoring and maintenance of the
existing fence around the UP&IJABS, but no measures to address CODtamin"ted groundwater,
or principal or low-level threat wastes. A groundwater monitoring program would be conducted
under this alternative for a period of 30 years, or until such time when the migration of
contaminants is not considered a potential threat to human health or the environment. A
groundwater sampling program would ~ developed as part of the remedial design process.
Institutional controls preventing 1and development and groundwater use would be
required. These controls woUld be through deed restrictions on property titles that would
prohibit development of the surface and the drilling of water wells. If necessary to prevent
groundwater use, water rights would be purchased from current owners in the area of
contamination. Usage of the residential portion of the property would probably continue as is
for the short teIDl.
The potential risk to the public is not mitigated by this alternative. Contaminants would
remain in soil and exposure to contaminated soilS would be restricted only by the fence on the
ABY. Exposure to contaminated soils on the SEA would not be prevented. Contaminant
transport mode~g estimates that groundwater plume CODtamination would not appreciably
change over the next 100 years by the no-action alternative. Groundwater ARARs (MCLs)
would not be achieved in the foreseeable future.
The time frame to implement Alternative 1 is 14 days. Capital costs are $26,800 for the
installation of new monitoring wells. Operation and maintenance (O&M) costs for 30 years for
the collection and analysis of groundwater samples and inspection and repair of the fence are
-------
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. 39
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'-', Alternative 2 - Limited Action
Alternative 2 includes capping of the entire ABY and SEA areas of the site with a low-
permeability clay cap and soil cover to preclude direct human contact exposure with principal
and low:level threat wastes, and to i'educe infiltration of precipitation into these source areas.
RCRA ARARs for capping would be applicable if RCRA characteristic hazardous wastes are .
present at the Site. Even if RCRA characteristic hazardous wastes are not present, RCRA
capping requirements are to be considered (TBC) and would be followed. Site closure would
include final grading and establishing vegetative cover to minimi7.e erosion. The components
of groundwater monitoring, fence maintenance, and institutional controls from Alternative 1
would also be included in this alternative.
Placement of the clay cap would act to minimi7.e exposure beyond the no-action
alternative and would aiso minimi7.e infiltration and thus leaching of contaminants to
groundwater. However, Alternative 2 offers little long-term effectiveness and permanence. This
alternative relies on natural attenuation processes for groundwater restoration, and without source
removal, groundwater ARARs would not be achieved in the foreseeable future.
The time frame to implement Alternative 2 is 36 days. The capital and O&M costs for
this alternative woUld be $1,049,000 and $1,391,000, respectively, yielding a total present worth
cost of $2,440,000.
Alternative 3 - Treatment and/or Di$posal of Principal Threat Wastes Only: Groundwater
Remediation throueh Principal Threat .Remediation and Natural Attenuation
There are three different options for treating contaminated soils under Alternative 3:
. Alternative 3a:
On-Site Stabilization/Solidification of Principal Threat Wastes
(excluding on-yard and off-yard LNAPL) and Disposal of Treated
Soils Onsite
. Alternative 3b:
On-Site ThermaI Desorption of Principal Threat Wastes (excluding
on-yard and off-yard LNAPL) and Disposal of Treated Soils
Onsite
. Alternative 3c:
Offsite Disposal of Principal Threat Wastes (excluding on-yard and
off-yard LNAPL) .
AItemative 3 includes the excavation of principal threat wastes in the gas-o-meter and
tar beIDl areas consisting of approximately 5,660 cubic yards of CODtaminated soils. Principal
threat wastes would be cbaracterized by TCLP test methods and classified and segregated into
RCRA hazardous wastes and contaminated soils.
Prior to treatment or off site shipment, CODtaminated soils would be temporarily stored
onsite in waste piles.. RCRA characteristic hazardous wastes would be subject to the applicable
sections of RCRA regulations for waste piles. Waste pile regulations would be relevant and
-------
40
.~~.:. - ~::.~.." -~.~
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pads within the area of contamination and any runoff from the pads would be collected and
treated with other waste water streams. .
Under Alternatives 3a and 3b, soils from the treatment of principal threat wastes would
be disposed onsite in excavated areas. RCRA land disposal restrictions (LDRs) are relevant and
appropriate for the onsite disposal of treated soils. Treatability testing of solidification and
thermal desoIption indicated treated soils would meet any LDR requirements. Concentrated
contaminant waste streams from thennal desoIption would be sent offsite for incineration.
Thermal desoIption treatment would be subject to Utah air emission limitations and RCRA
ARARs for treatment or storage in tanks.
After excavation of principal threat wastes, and after treated wastes are disposed onsite,
the entire ABY and SEA would be covered with a low-penneability cap to prevent direct human
contact with the treated wastes and the remaining low-level threat wastes. RCRA ARARs for
RCRA caps may be relevant and appropriate.
For Alternative 3c, principal threat wastes would be excavated and disposed at a RCRA
permitted Subtitle C or Subtitle D land disposal facility. The CERCLA Offsite Policy would
be applicable for the off site disposal. Any RCRA chaIacteristic hazardous wastes would be
subject to applicable RCRA ARARs for handling and transporting hazardous wastes.
Under all three alternatives, the LNAPL in the principal threat waste areas would be
treated by in-situ soil vapor extraction (SVB) combined with groundwater depression.
Approximately 570 cubic yards of soil are estimated to be contaminated with LNAPLs. This
is a rough estimate and further delineation of the area to be remediated will be determined
during remedial design.
. A treatability study conducted at the site revealed that SVE technology would be effective
at the UP&U ABS for removal of VOCs in the vadose zone and capillary fringe in the principal
threat waste areas. A maximum of 3.0 pounds per day (lbslday) of total petroleum hydrocarbons
(TPH) and 0.4:3 lbslday of benzene were recovered from a single vent well. The emission rate
from multiple vapor extraction wells would likely exceed Utah emission limitations of 40 lbslday
of total hydrocaIbons and 6 lbs/day of benzene, requiring off-gas treatment prior to discharge.
The off-gas produced from SVE would be processed by granular activated carbon (GAC)
treatment prior to discharge. Additional biodegmdation is expected to occur as a result of the
venting although the effects have not been measured or estimated.
Groundwater recovered by the vent well water depression pumps would be treated by air
stripping and/or GAC to meet industrial wastewater disclw:ge standards and discharged to the
Salt Lake City publicly owned treatment worlcs (P01W) for further treatment. Treatment for
cyanide in groundwater may be required to meet 'PO'IW disclw:ge standards. Utah air emission
regulations for discharges from air strippers would be applicable to the groundwater treatment.
ARARs for PO'IW discharges would be applicable to any wastewater discharges.
Removal of principal threat waste would result in significant reductions in potential risks
to the public and groundwater contamination would be expected to achieve remediation levels
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surface soils in the SEA and ABY areas are not proposed for removal under these alternatives.
These soils present potential carcinogenic risks due to direct exposure that exceed 1 X 1 ()'4.
Capping would prevent exposure.
Site closure would-include final grading and establishing vegetative cover to minimize
erosion. The components of Alternative 1, groundwater monitoring, fence maintenance, and
institutional controls would also be included for all three options of Alternative 3. For all
OptiollS of Alternative 3, long-term effectiveness is reduced by the requirements to maintain the
cap, fencing and deed restrictions.
The time frame to implement Alternatives 3a, 3b, and 3c are 127 days, 179 days, and
112 days. Capital Costs are $3,815,000, $5,420,000 and $3,266,000. Operations and
maintenance costs are $3,588,000, $3,600,000 and $3,586,000 and 30-year present worth costs
are $7,403,000, $9,020,000, and $6,852,000, respectively. .
Alternative 4 - On-Site Thennal DesoIption of Principal Threats and Low-Level Threat Wastes:
Groundwater Remediation through Principal Threat Remediation and Natural Attenuation
This alternative includes the excavation of all principal threat and low-level threat wastes
that exceed remediation levels down to a depth of 10 feet on the ABY and SEA (excluding on-
yard and off-yard LNAPL). All principal threat wastes and coal tar still tars and soils (low-
level tIm:at wastes) with an estim9ted volume of 8,725 cubic yards would be treated on site with
thermal desolption technology. The treated soils would be disposed on site. Based on
treatability studies, soils are expected to be treated to acceptable risk levels for exposure to
future workers and residents, achieve remediation levels, and also meet any RCRA LDRs.
Other major ARARs identified for Alternative 3 would apply to Alternative 4..
ContamiNlted soils not treatable by thermal desolption would be transported and disposed
at an offsite RCRA permitted land disposal facility in compliance with the CERCLA Offsite
Policy. These soils include ABY and SEA surface soils containing lead and calcareous fill
material containing cyanide excavated during remediation. A high estimate is that approximately
9,745 cubic yards of contamiNlted soils would be disposed. .
SVE of the on-yard and off-yard LNAPL would be implemented as described for
Alternative 3, including off-gas and groundwater treatment. .
Site closure would include final grading, vegetation, and groundwater monitoring as
descn"bed under Alternative 1. Institutional controls preventing the use of groundwater would
be required until groundwater is restored to remediation levels.
AItemativ~ 4 would be more effective in reducing exposures than the similar treatment'
option, Alternative 3b, as low level threat wastes (soils) are treated. Long term effectiveness
is not dependent on capping or institutional controls under this alternative.
. Significant reductions in groundwater contaminant concentrations are expected with
Alternative 4 due to natural attenuation mechanisms once the principal threat wastes are removed
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exposures because site contamin:tnts in soils with an exposure pathway would be treated to
acceptable exposure levels.' .
The time frame to implement Alternative 4 is 300 days. The capital and annual O&M
costs for this alternative are $8,744,000 and $2,879,000, respectively, yielding a 3O-year present
worth cost of $11,623,000. .
Alternative 5 - Off-Site Di$JX>sal of Principal Threats and Low-Level Threat Wastes:
Groundwater Remediation through Principal Threat Remediation an4 Natural Attenuation
This alternative includes the excavation of all principal threat and low-level threat wastes
for disposal at a RCRA permitted Subtitle C and! or Subtitle D Jand disposal facility (except for
the on-yard and off-yard LNAPL). Approximately 18,740 cubic yards of contamin:tted soils
would be dispOsed of in this alternative. Contaminated soils would be classified by TCLP as
RCRA characteristic hazardous wastes or non-hazardous wastes. Excavation, transportation and
disposal of contamin=tted soils would be in accordance with applicable RCRA regulations
including transportation of hazardous wastes, waste pile regulations, LDRs and the CERCLA
Offsite Policy.
SVE of the on:-yard and off-yard LNAPL would be implemented as described for
AJtemative 3, including off-gaS and groundwater treatment.
As in Alternatives 3 and 4, groundwater contaminant concentrations are expected to
achieve remediation levels in 10+ years due to natural attenuation mechanisms once the
principal threat wastes are removed from the site. Similarly, the level of protection offered on-
site by this alternative is high because exposure to contaminants in soils would be e1iminaten
through excavation and offsite disposal. However, long term effectiveness and permanence is
reduced because wastes that are disposed in a Jandtill require long teun monitoring to assure that
they are reliably contained. Principal threat wastes have the potential for future releases because
they are considered highly mobile.
Closure would include importing clean fin, grading, establishing vegetation, and
groundwater monitoring as deScribed under Alternative 1. Institutional controls preventing the
use of groundwater would be required until remediation levels are achieved.
The time frame to implement Alteinative 5 is 155 days. The capital and annual O&M
costs for this alternative are $5,241,000 and $2,836,000, respectively, yielding a 3O-year present
worth cost of 58,077,000.
Alternative 6 - ~halt Batc~e of PIincipal Threats and Low-Level Threat Wastes:
Grounqwater Remediation through Principal1breat Remedi:ttion and Natural Attenuation
There are two different options under Alternative 6.
. Alternative 6a:
Asphalt Batching of AU Principal and Low-Level Threat
Wastes with off site disposal of any RCRA characteristic
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Alternative 6a includes the excavatio~ of all principal threat (excluding on-yard and off-
yard LNAPL) and low-level threat wastes and incorporation of these contaminated soils into an
asphalt product. Approximately 13,850 cubic yards of contaminated soils would be treated and -
recycled through asphalt batching. Contaminated soils would be characterized by TCLP test
methods and segregated into RCRA characteristic hazardous wastes and non-hazardous wastes.
Temporary storage of contaminated soils in piles would be subject to the applicable sections of
RCRA waste pile regulations.
The contaminated soils would be transported to a local asphalt batching plant and
incorporated as raw material in the production of a cold mix asphalt product. Commercial
asphalt road products are made with petroleum based asphalt oil or -coal tar based asphalt oil.
These asphalt oils contain various.percentages of PAHs, similar to site contamination. Utilizing
site soils as a raw material mixed with virgin raw materials in the asphalt process will result in
producing a product similar or identical to commercial asphalt.
The asphalt plant would be subject to the CERCLA Offsite Policy regulations. The
Offsite Policy requires that the plant be operating in accordance with all applicable regulations
and not have any releases of hazardous wastes or constituents. The Policy allows the shipment
of non-hazardous wastes to non- RCRA facilities, as long as the facility is in compliance with all
of its applicable regulations.
Calcareous fill and contam-inated soils determined to meet the definition of a hazardous
waste (approximately 4,620 cubic yards) would be segregated from the other contaminated soils
and ~sed of at an off site RCRA Subtitle D and Subtitle C land disposal facility, respectively.
Transportation of characteristic hazardous wastes would be subject to applicable RCRA
regulations for transportation. The disposal facilities would be subject to the CERCLA Offsite
Policy .
SVE of the on-yard and off-yard LNAPL would be implemented as described under
Alternative 3, including off-gas and groundwater treatment.
Site closure would include backfilling excavations with clean soil and establishing stable
vegetation on the site. Deed restrictions requiring the proper handling of any soils below 10 feet
in depth should they be excavated would be implemented.
Onsite exposure under this alternative would be reduced. as in Alternative 4, but this
alternative has the advantage of satisfying the statutory preference of treatment and resource
recovery as a main element of the remedial action.
. Alternative 6b:
. Asphalt Hatching of Principal and Low-Level1breat Wastes
with offsite incineration of any RCRA characteristic hazardous
wastes;
Alternative 6b is similar to the description of Alternative 6a except that contaminated
soils characterized as a RCRA hazardous waste would be treated by off site incineration. Offsite
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As in Alternatives 4 and 5, significant reductions in groundwater cont~minant
concentrations are expected with Alternatives' 6a and 6b due to natural attenuation mechanisms
once the principal threat wastes are removed from the site. Additionally, since cont~minants in
soils would be removed or treated (by Alternatives 4 through 6) the level of protection offered
is high allowing for unrestricted exposure and unlimited use of the site. Site closure would
include importing clean fill, fmal grading, vegetation, and groundwater monitoring as described
under Alternative I. Institutional controls would be required to prevent groundwater use until
remediation levels are achieved.
The time frame to implement Alternatives 6a and 6b are 155 days. The capital and 30-
year O&M costs for Alternative 6a would be $6,767,000-and $2,836,000, respectively, yielding
a 30-year present worth cost for Alternative 6a of $9,603,000. The capital and 30-year O&M
costs for Alternative 6b would be $7,747,000 and $2,836,000, respectively, yielding a 30-year
present worth cost for Alternative 6b of $10,583,000.
Alternatives 7 through 10 - Alternatives 3 through 6 with Groundwater Extraction and Treatment
Alternatives 7 through 10 add groundwater extraction and treatment (pump and treat) to
the principal and low-level threat waste remedial actions as described in Alternatives 3 through
6. The pump and treat actions would include the installation of four fully penetrating extraction
wells at the western perimeter of the ABY and a means for controlling the migration of the
dissolved phase organic plume. Recovered groundwater would be combined with groundwater
recovered from SVE and dewatering operations, and the combined stream would be pretreated
onsite using air stripping andlor GAC to levels suitable for discharge to the POTW. .
As in Alternative 3, removal of the sources which contaminate groundwater would allow
the natuIal, passive attenuation processes to restore groundwater to remediation levels in 10+
years. For this option, not only would sources be removed, but in addition, soluble
CODtamin~nts in the groundwater would be removed through extraction and treatment. Pump and
treat would be expected to shorten the timeframe to achieve remediation levels by approximately
2 years.
Insta11ation of the pump and treat remedy is expected to take 30 days, but operation of .
the system would likely continue for up to 10 years. Incremental costs for the pump and treat
portion only are $151,000 in capital costs and $839,000 for 30 years of operation and
maintenance.
The 30-year present worth costs for these alternatives are as fonows:
. Alternative 7a
On-Site StabilizatioolSolidification of Principal Threat Waste and
Groundwater Extraction and Treatment, $8,393;000-
. Alternative 7b
On-Site Thermal Desoxption of Principal Threat Wastes and
Groundwater Extraction and Treatment, $10,011,000
. Alternative 7c
Off-Site Disposal of Principal Threat Waste and Groundwater
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. Alternative 8
On-Site The~ Desorption of Principal and Low-Level Threat
Wastes and Groundwater Extraction and Treatment, $12,613,000
. Alternative 9
Off-Site Disposal of Principal and Low-Level Threat Wastes and
Groundwater Extraction and Treatment, $9,503,000
. Alternative lOa
Asphalt Batching of Principal and Low-Level Threat Wastes and
Groundwater Extraction and Treatment, $10,593,000
. Alternative lOb
Asphalt Batching of Principal and Low-Level Threat Wastes and
Groundwater Extraction and Treatment, $11,573,000
IX Summary of Comparative Analysis of Alternatives
The comparative analysis provides the basis for explaining how the selected remedy
satisfies the statutory requirements as to the effectiveness and implementability of the alternative.
The remedial alternatives presented in Section vm were analyzed in detail in the FS using the
nine evaluation criteria. The nine criteria include: 1) overall protection of human health and the
environment; 2) compliance with applicable or relevant and appropriate requirements (ARARs);
3) reduction of toxicity, mobility, or volume through treatment; 4) long-term effectiveness and
permanence; 5) short-term effectiveness; 6) implementability; 1) cost; 8) state acceptance; and
9) community acceptance. The resulting comparisons of each alternative by the nine criteria are
discussed below.
Criterion 1: Protection of Human Health and the Environment
This criterion addresses whether a remedy provides adequate protection and describes
how risks posed through. each pathway are eHminated, reduced, or controlled through treatment,
engineering controls, or institutional controls;
Overall protection of human health and the environment is achieved in all of the
alternatives except Alternative 1 (No action). The highest level of protection is through
Alternative 6b (Asphalt batching with offsite incineration) and Alternative 4 (Thermal
deso1ption). Alternative 6b is preferred over Alternative 4 because less contaminated soils are
to be disposed in a Jandfill in 6b. Alternative 6a (Asphalt batching with disposal) is not as
protective because RCRA characteristic hazardous wastes are disposed in a landfill without
treatment which will require long term maintenance to ensure protection. Alternative 6b
removes all contam-inated soils exceeding remediation levels down to a depth of 10 feet, thereby
eliminating onsite exposure. Institutional controls provide further protection for exposure to
soils below 10 feet through deed requirements for proper handling should these soils ever be
excavated. Alternatives 4 through 10 provide this same protection to soil exposure, but
Alternative 5 (Disposal) utilizes offsite disposal without treatment and is not as reliable in the
long term. Alternatives 2 (Capping) and 3 (Principal Threat remediation and capping) utilize
a cap and fencing to prevent exposure to soils and rely on institutional controls for long tenn
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fencing and no action for. groundwater. rem~on.
. .
Alternative 6b utilizes contaminated soils as a r.aw material to produce a cold mix asphalt
product suitable for road paving. Asphalt normally contains PAHs, similar. to site containin~ted
soils. Incorpor.ation of contaminated soils into the asphalt product will not make the product any
more hazar.dous than normal asphalt. Contamination will be further. stabilized and solidified
when producing the asphalt product. Upon recycling contaminated soils into the asphalt product,
the product would not be a CERCLA waste. "Once the CERCLA waste is finally... treated to
substantially reduce its mobility, toxicity, or. persistence, it is no longer. considered a CERCLA
waste and subsequent ttansfel'S of the waste would not be regulated under this role," (Preamble
to 40 CFR 1300.440, proposed roling, CERCLA Off-site Response Actions). Producing the
asphalt product results in a pennanent remedy for site contaminated soils.
Alternative 4 treats contaminated soils through thenna! desoIption. Contaminants are
VOlati7ed and extracted from soils, leaving a clean soil suitable for. replacement on the site.
Treatability tests showed the process to be effective in remediating contaminated soils.
Remediation levels were achieved for. all contaminants of concern except one which was only
slightly above the remediation level. Lead in surface soils is not treatable through ther.mal
desoIption and swface soils would be disposed in a landfill. Concentr.ated contaminant waste
streams would be shipped offsite for. incineration, permanently destroying the contaminants.
-
Although Alternative S removes contaminatM soils from the site and eliminates. this
exposure, landfilling of the. soils is not as protective as ~ent.
Alternative 3a solidifies principal threat wastes and replaces the treated soils back on the
site. Protection from exposure to solidified principal threats and contaminated soils is through
a cap which is not as effective and per.manent as other treatment alternatives.
Alternatives 3 through 6 include removal of principal thIeat wastes which are sources for
groundwater contamination. This is expected to result in significant reductions in groundwater
contamination by the natural processes of adsmption, biodegr.adation, and dispel'Sion.
Groundwater is expected to be cleaned to remediation levels in approximately 10 years.
Alternatives 7 through 10, which add groundwater. extraction and treatment to the remedial
activities specified for Alternatives 3 through 6, do not offer. any significant additional overall
protection re1ative to Alternatives 3 through 6. The pump and treat option is not expected to
significantly improve the rate at which groundwater is remediated. Alternatives 1 and 2 do not
include principal threat source removal for groundwater remediation. Protection to groundwater
exposure is through institutional controls which are not as effective and reliable in the long term.
~terion 2: Compliance with Ap,plicable Relevant and ARPlQPriate Reqpirements (ARARs)
Compliance with ARARs addresses whether. a remedy will meet all Feder.al and State
environmentaIlaws and/or provide a basis for. a waiver. from any of these laws. The ARARs
are divided into chemical specific, action specific, and location specific groups.
There are no chemical quality standaI'ds for soils promulgated through Feder.al or. State
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UP&UABS. ARARs do exist for groundwater, they include Federal and State drinking water
standards such as MCLGs, or MCLs when MCLGs are zero.
Alternatives 3 through 10 would comply with all ARARs identified in Appendix B except
for the RCRA waste pile ARARs. The CERCLA Offsite Policy would be followed for ariy
off site treatment or disposal of contamin~ted soils. The CERCLA Off site Policy allows for
CERCLA wastes that are not RCRA hazardous wastes to be sent to a non-RCRA facility. Any
non- RCRA facility must be operating in accordance with all of its applicable regulations and
have no releases of hazardous substances. RCRA regulations for the transport of RCRA
hazardous wastes would be applicable for off site shipment.
RCRA land disposal restrictions would be applicable to any RCRA characteristic
hazardous wastes disposed onsite or offsite. I..DRs are not applicable or relevant and appropriate
to contaminated soils not characterized as RCRA hazardous. Contaminated soils treated onsite
and rendered no longer hazardous would not be subject to LDRs. LDRs would be complied
with for all of the Alternatives.
Contaminated soils would be temporarily stockpiled onsite for characterization prior to
treatment or off site shipment. RCRA waste pile regulations are applicable for .RCRA
characteristic hazardous wastes and relevant and appropriate for contamirulted soils. Applicable
sections of these regulations require the use of double-lined pads and leachate collection systems
for hazardous waste piles. Since the temporary waste piles will not be consttucted in accordance
with RCRA regulations but will be consttucted to provide an equivalent level of perfonnance,
an ARAR waiver is appropriate based on 40 C.F.R. i 300.430(t)(I)(ii) (C)(4). This waiver
allows for situations where "the alternative will attain a standard of performance that is
equivalent to that required under the otherwise applicable standard, requirement, or limitation
through the use of another method or approach". Waste piles will be placed on asphalt pads
witbin the area of contamination and any runoff from the pads will be collected and treated with
other waste water streams. .
Alternatives 1 and 2 do not comply with ARARs as groundwater contamination is
expected to remain above MCLs. Alternatives 1 and 2 do nothing to remove site contaminants,
thus COCs will continue to exceed ARARs for groundwater. Alternatives 3 through 6 include
remediation of principal threat wastes. The principal threats, which are sources for groundwater
contamination, would be remediated through excavation of DNAPL princiPal threats and soil
vapor extraction of LNAPL principal threats. It is difficult to predict when ARARs would be
achieved, although modeling of groundwater contamination indicates achieving remediation
. levels in approximately 10 years. Alternatives 4 through 6 include the additional treatment or
offsite disposal of low level threat wastes and therefore provide additional assurance that
groundwater ARARs should be achieved as these soils may contribute some groundwater
contamination. Alternatives 7 through 10 will comply with all ARARs, however the ability to
comply is not significantly greater than Alternatives 3 through 6, except the remediation
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Criterion 3: Lon/:- Term Effectiveness and ~rmanence
This evaluation criterion involves consideration of the risks that remain after the site has
been remediated. Items of concern are the presence of any receptors near the site, magnitude
of the remaining risk from untreated waste or treatment residuals, adequacy of cOntrols that are
used. to manage treatment residuals or untreated waste, and reliability of these controls.
Alternative 6b offers a high level of long-term effectiveness and pennanence due to the
removal of principal and low-level threat wastes from the site. CODClmin:.ted soils would be
made into a cold mix asphalt product and used for paving roads. Once these contamin=tted soils
are treated and made into a product, they are not considered a waste. Over time, the road; will
likely degrade and at solll:e point would reach the end its useful life. At that time, the road
materials would likely be paved over or recycled into new asphalt road material. Alternative
6b would require the offsite incineration of any characteristic hazardous wastes which
permanently destroys the organic contaminants.
Alternative 6a is the same as 6b except any RCRA characteristic hazardous wastes would
be disposed in a landfill. This option is less permanent and effective .than Alternative 6b.
The no-action alternative will not reduce long-term risks from exposure to site contamin:.nts and
Alternative 2 offers only a slightly higher degree of long-tenn effectiveness and risk reduction
when compared to Alternative 1~ .
Alternative 4 offers a high degree of long-term effectiveness and permanence, only
slightly less than Alternative 6b because some contamin:.tP.LI soils would be.disposed in a landfill
rather than treated. Thermal desmption was demonstrated to remove conc.minants in soils down
to acceptable risk levels, at or only slightly above remediation levels. The treated soils would
then be acceptable for disposing onstte. Contamimnts vo1arili7.ed and removed from the soils
would be further treated through offsite incineration or through carbon absoIption. Ultimately,
these contaminants would be permanently destroyed.
Alternative S bas a lower long term effectiveness and permanence than that of alternative
4 because of the disposal of untreated, principal threat and low level threat wastes. These
wastes are considered highly mobile and highly toxic which presents the problem of long term
monitoring and maintenance after disposal. .
Long-term effectiveness and permanence is improved by A1temaDve 3 over that of
Alternatives 1 and 2 because sources for groundwater contamination are addressed. Alternatives
2 and 3 rely on capping and institutional controls for preventing exposure to contamin:.ted soils
which is only moderately effective in the long term.
There would be little or no increase in long-term effectiveness and permanence for
Alternatives 7 through 10 -because groundwater extraction is a poor mass recovery process for
the sparingly soluble contaminants at the site. The addition of groundwater extraction and
treatment for Alternatives 7 through 10 is unlikely to significantly reduce the time required to
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.Criterion 4: Reduction of Toxicity. Mobilit,x. or Volume through Treatment
" .
Treatment is a component of all the alternatives with the exceptions of Alternatives 1 an~
2. It is a major feature of Alternative 4 where p~cipal threats and a significant portion of the
low level threat waste are to be thermally treated. Contaminants in soils are concentrated-
through thermal desorption and then sent offsite for incineration, resulting in reductions in
toxicity, mobility and volume.
Alternative 6b treats contaminated soils through stabilization and incorporation into a cold
mix asphalt product, thereby reducing the mobility of contaminants. Alternative 6b provides for
the additional thermal destmction of RCRA characteristic hazardous wastes which reduces the
toxicity, mobility and volume.
Alternatives.3a and 3b utilize treatment for thermal desorption and incineration (3b) or
stabilization-(3a) of the principal threat wastes; however, in both alternatives, greater than 50%
of the coDtaminated soils would remain on site without treatment.
" Alternatives 3c and 5 include offsite disposal in a secure landfill with treatment being
employed only as required to meet facility specific disposal criteria. These alternatives do not
result in any reductions in toxicity, mobility or volume. Containment in a landfill could be
considered ~ a reduction of mobility, although the contaminated soils themselves would not have
any reduction in mobility.
Alternatives 3 through 10 include additional reduction of toxicity by treatment through
SVE of principal threat wastes. Contamination is removed by SVE and extracted from the air
stream by carbon absorption. The spent carbon is then sent offsite for regeneration which
involves the thermal destmction of the contaminants.
Criterion s: Short-Tenn Effectiveness
This criterion involves investigation of the effects of the alternatives during construction
and implementation. Items of concern are the protection of the community and the worlcers
" during implementation of remedial measures, potenbal environmental impacts, and the time
requjIed to achieve remedial response objectives.
No tln=-cceptable or unmanageable short-term risks are anticipated by the any of the
alternatives.
Alternative 1 offers no incremental risk to the community above that which already "exists
due to the presence of site contaminants. The time required onsite to" install additional
monitoring wells 15 only a few days.
Placement of the cmy cap in Alternative 2 would cause some disturbances of the
contaminated soils, but dust control measures coUld be implemented to minimi7.e exposure to
nearby residents. Trucking of materials for cap construction presents short term effects from
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Short-term risks for Alternative 3 exceed those for Alternatives 1 and 2 due to excavation
and treatment of principal threat wastes on site. Excavated soils will release volatile
contaminants to the atmosphere, but onsite monitoring will be conducted to ens~ that workers
or nearby residents are not exposed to harmful levels of contaminants. Stabilization and thermal
desoxption will also result in the release of some volatiles even though thermal desoxption will
be in a sealed vessel.
Alternatives 3c, 5 and 6 involve the excavation of contaminated soils including principal
threats and low level threats. Once excavated, these soils will be transported off site for
treatment or disposal. The time to implement these alternatives is from 122 days to 155 days.
Because soil treatment activities will not occur onsite for Alternatives 3c, 5 and 6, short-term
risks are reduced, in comparison to Alternative 4, for onsite exposures. However, transporting
wastes offsite for disposal or treatment will present increased risks offsite due to truck transport
of wastes. -
The additional on-site treatment of the low-level threat wastes in Alternatives 3b and 4
pose greater short-term risks to workers and residents. Onsite treatment would range from 179
days to 300 days.
The greatest short-term risks are posed by Alternatives 7 through 10 because of
prolonged remedial activities and potential for exposure to contaminatPLI groundwater and
secondary wastes. Long term groundwater extraction and treatment through air stripping would
resuit in air emissions for up to 10 years.
Criterion 6: Implementability
This criterion refers to the technical and administrative feasibility of a remedy, including
the availability of materials and services needed to implement the chosen solution. It also
includes coordination of Federal, State, and local governments to clean up the site.
All of the alternatives evaluated were considered to be implementable, both technically
and administratively. Alternative 6b is implementable through the use of an existing asphalt
hatching plant. EP A has conducted a visit to the facilities for a pre1iminary inspection. Formal
inspection under the Offsite Policy will be conducted prior to shipping contaminated soils to the
pIant. Offsite incineIation facilities are available nearby that could accept any contaminated soils
requiring incineration.
Treatability studies were conducted to evaluate the technical feasibility of any cleanup
technologies that required further information. Studies were conducted on asphalt batching
(Alternative.6a. and 6b), solidification (Alternative 3a), thermal desmption (Alternatives 3b and
4), groundwater extraction (Alternatives 7 through 10) and soil vapor extraction (Alternatives
3 through 10). These studies showed that all of the technologies presented in the alternatives
were implementable. Additionally, air stripping and carbon absoxption: technologies
(Alternatives 3 through 10) were evaluated using site specific information.
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evaluated. No admini~trative obstacles to implementing any of the remedies were encountered.
Difficulties might be encountered in permitting air emissions from the thermal desorption unit
and gaining community acceptance. Other considerations included permits for POTW
discharges, air emissions from air strippers and soil vapor extraction systems, transportation of
hazardous wastes, offsite disposal, off site incineration and institutional controls.
Criterion 7: Cost
This criterion evaluates capital, operation and maintenance costs of each alternative, and
compare costs among similarly protective remedies.
Alternatives 6b and 4 provide the highest levels of protection, but Alternative 6b is
estilJ'lated to cost $1,100,000 less than Alternative 4. Actual costs for Alternative 6b depend on
the end useaf the asphalt product. Total costs for this alternative could be $2,100,000 less than
Alternative 4.
Alternatives 5 and 6a cost less than Alternative 6b but have lower levels of
protectiveness. Alternative 3a, 3b and 3c are generally less costly, but less contaminated soils
are treated and protection relies on capping and institutional controls which is less reliable and
effective as compared to treatment. .
With the exception of Alternatives 7 through 10, all of the other alternatives are cost
effective, that is, their costs are commensurate with their level of effectiveness. Alternatives
7 through 10 employ "pump and treat" as an additional measure for groundwater remediation
which is not expected to be significantly more effective than natural, passive groundwater
remediation once the principal threat wastes are removed.
Criterion 8: State Accc;ptance
The Utah Department of Environmental Quality has worked in partnership with EP A
throughout the RIlFS and concurs with the selected remedy for this Site.
Criterion 9: CommunitY ACCCJ)tance
The Proposed Plan was issued on March 26, 1993. A public meeting was held on April
22, 1993 at the UDEQ offices in Salt Lake City. Members of the community attended the
meeting and asked questions regarding the proposed remedy. Meeting attendees expressed no
opposition to the proposed remedy. No additional written or vernal comments were received
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X Selected Remedy
Alternative 6b, Asphalt batching of principal threats and low level threats has been
selected as the remedy for ~e Utah Power & Light! American Barrel Site.
Principal threat wastes as defmed qualitatively in Section V, Summary of Site
Characteristics of this ROD and quantitatively in Section XI, Performance Standards, shall be
excavated where found on the Site. Current information indicates two areas that contain
principal threat wastes: the gas-o-meter contents and the tar benn area. The areas where tar
wells and creosote tanks were located based on plat maps of the Site (see Figure 2) shall be
investigated further to detennine if unknown principal threat wastes are located in these areas.
Principal threat excavation shall be to the extent of the wastes as defined qualitatively and
confumed quantitatively. Excavation shall be to the extent feasible as determined by EP A, within
the limits of current site activity and stmctures, limited primarily by active railroad tracks and
a high pressure diesel pipeline. Shoring of excavations and pumping of groundwater shall be
utilized as necessary to complete the excavations. Excavated principal threat wastes shall be
tested using the TCLP test methods and segregated onsite into RCRA characteristic hazardous
wastes and non-hazardous wastes prior to offsite shipment.
Low level threats consisting of surface soils and subsurface soils on the ABY and SEA
exceeding remediation levels shall be excavated down to a depth of 10 feet. These soils sball
be segregated onsite from principal threat RCRA characteristic hazardous wastes.
All contaminated soils except soils determined to be RCRA characteristic hazardous
wastes and calcareous soils, shall be sent offsite for processing into a cold mix asphalt product.
The facility receiving these wastes shall be in compliance with the CERCLA Offsite Policy.
RCRA hazardous wastes shall be sent to an offsite RCRA Permitted Subtitle C TSD facility for
incineration that is in compliance with the CERCLA Offsite Policy.
Investigation derived wastes from the RIlFS shall be characterized by TCLP test methods
and handled in accordance with the remedial actions for other contaminated soils and wastes.
Any calcareous fill material uncovered or excavated during the soil removal actions shall
be segregated from other contaminated soils. Segregation shall be based on visual observations.
The calcareous fill material shall be tested for characteristics of reactivity as described in "Test
Methods for Evaluating Solid Waste, Physical/Chemical Methods", 1986a (EPAlSW-846, 3rd
Edition) or any subsequent fina1i7,ed editions. Characteristic hazardous wastes shall be disposed
in accordance with ARARs in an approved RCRA Subtitle C facility ~ Non-hazardous
contaminated soils shall be disposed in a RCRA Subtitle D facility.
The excavated areas shall be backfi1led with clean fill and regraded to allow proper site
dminage. A uniform and compacted layer of top soil shall be placed over the disturbed areas
to restore the soil cover in these areas to a depth suitable for supporting the gennination and
propagation of vegetative cover. Soil cover shall be compacted at a density and installed with
a grade designed to minimi7.e erosion and prevent ponding.
-------
. ,-..
.., ~ "':6
53 "
LNAPL areas located on the ABY and SEA., The system shall combine SYE with groundwater
depression- through pumping of groundwater from vapor extraction".. wells. Vapor and
groundwater collection will be accompli~hed by vent wells screened across the water table.
. Contaminated soil vapor will be collected by applying vacuum to wells using a vacuum blower.
Recovered vapor shall be treated by methods other than incineration or catalytic oxidation
to achieve the standards for off-gas treatment established by ARARs prior to discharge to the
atmosphere. Extracted groundwater shall be treated to achieve pretreatment standards
established by the Salt Lake City Publicly Owned Treatment Works (P01W) prior to discharge
to the POlW. An industrial wastewater discharge permit shall be obtained from the Salt Lake
City P01W prior to any discharges. All discharges shall be in compliance with the permit.
Decontamination water, leachate collected from waste piles, and groundwater pumped
from excavations sball also be treated to POlW pretreatment standards and dischaJ:ged to the
P01W for further treatment. .
Groundwater shall be monitored during and after remediation of sources for groundwater
contamination (principal threats) to evaluate the progress of natural attenuation in restoring
groundwater to remediation levels.
Institutional controls that prevent exposure to contaminated groundwater shall be
. implemented. The Responsible Parties, together with EPA and UDBQ, shall inform the State
Engineer for the Division of Water Rights, Utah Department of Natural Resources of the
potential risks associated with the use of ABS groundwater.
" A deed notice shall be. placed on "the chain of title to the Utah Power & Light property
and Denver and Rio Grande Western property disclosing the presence of contaminated soils
below a depth of 10 feet on these properties and the presence of CODtaminated groundwater,
further prohibiting the drilling of any water wells. Any excavation of this material will require
handling in accordance with all applicable CERCLA, RCRA and DOT regulations.
XI Performance Standards
Principal Threat Excavation
Excavation of principal threat soils sha1i begin with the' identified areas consisting of the
gas-o-meter and tar berm area. Excavation shall be primarily guided by visual observation based
on the principal threat definition of: NAPLs, mobile tarry material and soils saturated with "
NAPu. Further delineation of principal threats for excavation shall be based on a concentration
of PARs and/or bvanzene equating to a carcinogenic risk of 1()"3. The 10-3 risk level is suggested
as a guideline in II A Guide to Principal1breat and Low. Level Threat Wastes, II (OSWER
Directive 9380.3-o6FS). Contaminant concentrations that equate to a 10-3 incremental cancer
risk are denved assuming worker exposure levels for PAIls in soil and residential exposure
through ingestion of benzene in groundwater.
-------
S4
. .'-~'
..,. ',.-,
"',;.- - -..:::"
List (TCL) PAHs that equates to an incremental carcinogenic risk of 1()"3 is.: 9,000 mg/kg
. (Principal threat quantification, see Appendix A). The extent of excavation of principal threats
shall be until visibly conta~inated principal threats as defined above are removed or the
concentrations of total EPA TCL PAHs are below 9,000 mg/kg. A Sampling and Analysis Plan
shall be developed and submitted for EP A review and approval that provides for demonstration
that residual soil concentrations, as determined by composite samples collected from the walls
and floors' of the excavation do not exceed the numerical criterion of 9,000 mg/kg total TCL
PAR compounds. An analytical field screening method for measurement of total PAHs may be
utilized for cOnfirmation sampling upon demonstration of suitable correJation between TCL PAH
measurements and field screening total P AH measurements and . approval by EP A.
Additional areas of contamination outside of the identified principal threat areas may be
principal threats based on the above defmitions and shall be excavated to the extent feasible as
determined by EP A.
. Excavated principal threats shall be segregated in RCRA characteristic hazardous wastes
and contaminatM soil piles based initially on visual obseIVations, confirmed by sampling and
analysis using TCLP test methods. A sampling and analysis plan shall be developed and
submitted for review and approval by EPA that provides for demonstration to EP A's satisfaction,
that waste determinations as required under 40 CFR Subpart 262.11 accurately represent the
characteristics of the waste. The waste piles shall be constructed and operated in accordance
with the minimum operating standards for waste piles listed in 40 CFR Part 264.251.
Low Level Threat Soil Excavation
Low level threats defined as those soils from the surface down to 10 feet in depth that
exceed the remediation levels as listed in Table 7 shall be excavated and transported off-site for
processing into a cold mix asphalt product. A Sampling 'and Analysis PJan shall be developed
and submitted to EP A for review and approval that provides for demonstration that soils
exhibiting concentrations in excess of the remediation levels have been excavated.
Asphalt Product Standards
The principal threat and low level threat soils shall be processed into a cold mix asphalt
product meeting industry standards fo~ emulsified asphalt base mixtures. The emulsified asphalt
base mix shall be produced at the processing pJant location.. The finished product shall then be
suitable for road construction use and shall be utilized for road construction or private parking
lot paving. Any debris. not suitable for processing into the product shall be sent to an EPA
approved RCRA Subtitle CorD TSD facility. . '
Soil Vapor Extraction of LNAPL Principal Threats
. The SVE system shall be installed in the areas of LNAPL contamination defined as those
areas where concentrations of benzene have a potential 1 0-3 risk. The risk is based on a resident
ingesting water contaminated with benzene and is equal to a benzene concentration of 2.8 mg/l.
Using soil partitioning theory, a soil concentration that can be estimated to result in a waJer
-------
-'.":'
.~..~¥..~-:.~~-~~..:Lt:~~i~: . :.:,
... . ..~..
.',' 55 '
.'
developed that collects saturated and unsaturated soil samples and analyzes these samples for
benzene. Reported analytical results shall be calculated on a dry weight basis. Areas where
benzene concentrations exceed 8.0 mg/kg shall be remediated with SVE.
. -
The SVE system shall be operated and monitored until groundwater performance
standards are achieved or until sufficient data has been collected to demonstrate that contaminant
concentrations in the extracted soil vapors are at statistically significant asymptotic values based
on a four point moving average or other statistical test for 12 months of monthly monitoring at
each extraction well. If asymptotic conditions are reached, before operations are discontinued,
it win also be necessary to demonstrate that best efforts have been used to optimize system
performance. Best efforts shall include at a minimum,
(1) modifying the SVE system by: alternating vacuum extraction wells to eliminate
stagnation points, pulse pumping of vacuum wells allowing time for contamin~nts to
vaporize, vary extraction. rates and pressures, and installing additional vacuum extraction
wellS to facilitate or accelerate cleanup of the LNAPL plume; .
(2) identifying and remediating any additional or previously uncharacterized sources of
LNAPL contamination within the Site boundaries;
(3) modifying the groundwater extraction from vacuum extraction well~ by increasing
pumping rates to expose additional contaminat~ soil to vacuum extraction and increase
mass recovery rates of contaminatP.d groundwater.
(4) evaluating the effectiveness of biodegradation related to SVE to determine if the SVE
system should be operated to enhance natural degradation of contamin~ted soils.
Performance and Compliance Monitorinl: Proeram
A sampling program for monitoring the SVE performance and for determining
compliance with the perfOIIDance standards shall be implemented during the remedial action.
'Ibis program will be developed during remedial design and shall include, at a minimum, the
fonowing: locations of LNAPL principal threats, locations of performance monitoring points
within the SVE system including influent and effluent from the blower/treatment system;
frequency of monitoring of the performance of the SVE system, analytical parameters (focusing
on COCs, with the possible use of indicator chemicals), analytical methods for laboratory and
field chemical analysis (with possible use of non-CLP analysis), field sampling methods, and
statistical methods for evaluating data.
Groundwater Restoration
Area of Attainment. The area of attainment for the ground water restoration shall be the entire
ABS and any part of the plume exceeding ARARs or remediation levels identified in Table 8 of
-------
~~.~..,~~:f.'O~~~~~~~: . :.~.~
......-0.
''''',eo
"-..'
Perfol1l1ance Standards. Specific performance standards used to ensure attainment of the
remedial action objectives for ground water are:
1)
Over the fll'St 5 years of remedial action, benzene concentrations within the area of
- attainment, on the average, shall not deviate from the predicted concentrations presented
as modeling scenario V in Appendix F of the final Feasibility Study Report, by more
than 50 %. This determination will be made by first calculating the expected benzene
mass within the attainment area after every year, and then estimating the percent
deviation of the actual contaminant mass from the expected mass. Methods for
calcuJating benzene mass and statistics used in the analysis shall be included in the
groundwater monitoring plan and reviewed and approved by EPA. .
2)
Other organic contan'linants and cyanide within the area of attainment shall show a
significant decrease in concentration as determined by EP A over the 5 year period based
on performance monitoring. A statistical trend analysis will be. used to make this
determination. The presence of any upgradient sources of contamination would be
considered as off-setting factors in achieving this standard.
3)
Contaminants shall not migrate beyond the study area (city block) at concentrations
exceeding remediation leve1s.
4)
Contaminant leve1s in the groundwater within the area of attainment shall be ultimately
reduced to remediation levels.
In the case of non-compliance with performance standards (1) and (2), additional sources
of contamination will be investigated if they appear to be present based on the ground water
monitoring data collected. If additional sources are found to be contributing to groundwater
contamination, alternate remedial actions will be. employed to address these sources for
groundwater contamination. If additional sources do not appear to be present, revised
remediation rates will be estimated. If at any time EP A determines that there is unacceptable
protection of human health and the environment, EPA will require the implementation of more
aggressive remedial measures.
In the case of non-compliance with performance standard (2) specifically for cyanide in
groundwater, further evaluation of the calcareous material sha1l be conducted to determine the
significance of this material as a source of groundwater contami~tion.
If it is shown that performance standard (3) is not being met, EP A will reqtrlre
implementation of contaminated groundwater containment actions unless all of the following
three requirements are satisfied:
a)
deed restrictions preventing groundwater use are placed in the deeds of the
affected properties;
b)
there is no potential for exposure to the contaminated ground water; and
c)
-------
. (-~.
., ~ . ~ ..
.~..-:~---~.
:- .""'. ...- ...:.:..~::
~~~
57 ,..~.,......,
rem~on levels in a reasonable time frame as determined by. EP A.
-
EPA will determine if these conditions are being met and whether groundwater
containment actions are required.
Although this ROD refers to approval and decision making by EP A, UDEQ will have
a substantial role in the review of any decisions and plans. Specific roles and responsibilities
for UDEQ will be detailed in a Consent Decree for this Site andlGr in a Site Specific
Enfoxcement A~ent between EP A and UDEQ. Plans are for the Consent Decree to provide
UDEQ with direct reimbursement by the PRPs for any oversight expenses incurred at this Site.
Perfonnance and Compliance Monitorine Proeram
A sampling program for monitoring the remedial action performance and for determining
compliance with the perfOrmaD.ce standards shall be implemented during the remedial action.
This progrciin will be developed during remedial design and shall include, at a minimum, the
following: locations. of performance monitoring wells for water quality sampling, frequency of
monitoring of performance wells, analytical parameters (focusing on COCs with possible use of
indicator chemicals), sampling field methods, water level meaSurement frequency, analytical
methods for chemical analysis (with possible use of non-CLP analysis), locations and methods
for water level measurements, and statistical methods for evaluating the analytical data.
The performance monitoring system will be designed to provide information that can be
used to evaluate the effectiveness of the remedial action with respect to the following:
.
horizontal and vertical extent of the plume and contaminant concentration
gradients, including a mass balance calculation;
.
rate and direction of contaminant migration;
.
changes in contaminant co~centrati.ons or distribution over time;
.
effects of any modifications to the original remedial action.
The groundwater within the ABS and Area of Attainment shall be monitored for
CODtamina~ throughout the implementation of the remedy and for at least five years following
the completion of the source removal activities. Once it is statistically shown that ARARs and
remediation level concentrations of contaminants (Table 8) have been reached, the wells shall
be sampled for twelve consecutive quarters.' If contaminants are shown to statistically remain
below ARARs and remediation levels for twelve consecutive quarters, monitoring can be
-------
.... .""!'
58
'~'_..:~.-~.
~ i.:....: ..~~.~~
:.~:'':::;':''''-'
xu Sta~tory Requirem~
Protection of Human Health and the Environment
Soil exposure is eliminated through excavation and off site treatment of all soils exceeding
a 1~ risk and which have an exposure pathway. Asphalt covers and roads are not known to
present unacceptable risks to the public. Site contaminants are similar or identical to constituents
in commercial asphalt. Additionally, contaminants will be salidified in the asphalt product and
will not present additional risks to the public or environment.
Based on site modeling, groundwater is expected to achieve contaminant reductions of
99 % in 5 years through principal threat source remediation and natural attenuation. Achieving
remediation levels is uncertain given the presence of LNAPLs and DNAPLs at this site, but
modeling results imply that natural attenuation processes would reduce cont~minant
concentratiol!s to remediation levels in a reasonable time frame (10+ years). Contaminated
groundwater is not currently utilized but use restrictions will be required until remediation levels
are achieved. No unacceptable short term risks to workers or residents are anticipated. The soil
excavation actions should take approximately 155 days. Soil vapor extraction is estimated to
take up to 3 years.
As the remedy is expected to take longer than five years to achieve groundwater
remediation levels, a five-year review as required under Section 121(c) of CERCLA, 40 C.F.R.
300.430(f)(4)(ii), and applicable guidance will be conducted.
Compliance with ARARS
Actions under Alternative 6b will comply with all ARARs except RCRA waste pile
reguJations. An ARAR waiver based on 40 C.F.R. i 300.430(f)(1)(ii)(C)(4), that the remedy
will attain an equivalent standard of performance is appropriate. Following is a list of chemical
specific, action specific and location specific ARARs for the selected alternative.
Cost EffectiventS
A1temative 6b provides overall effectiveness a.s high as alternative 4 and higher than all
other alternatives. Alternative 6b is expected to cost about $1,000,000 less than alternative 4
. based on costs in the Feasibility Study, but actual costs could be $2,500,000 less depending on
the use of the recycled asphalt product.
Utilization of Permanent SolutioDS and Alternative Treatment Technologies or R~urce
Recovery Technologies"to the ]\tfgYimllm Extent Practicable
Alternative 6b maximizes treatment and the use of resource recovery technologies through
asphalt hatching. Site soils are processed into a useable product that can be utilized to make
asphalt roads. Principal threats are further treated through soil vapor extraction and off-gas
treatment. " A minimum amount of material is to be disposed of in this alternative (cyanide
bearing calcareous material). The preferred alternative provides a high level of long term
-------
......."-
-";",,~
59
removed and treated. Groundwater is expected to be restored to drinking water standards.
Preference for Treatment as a Principal Element
, All principal threats are treated under this alternative. Soils classified as principal threats
are excavated and treated offsite. Residual LNAPL at the water table is classified as a principal
threat and is treated through soil vapor extraction. Only low level threat residual tarry material
below 10 feet in depth is left in place untreated. This contamination is not expected to migrate
-------
--:---':::-..- '-:;~-
:- . ;.-. "'.: ::~-~~
-":Y"':""-~
-,"""
-
APPENDIX A
DERIVATION OF MEDIA CONCENTRATIONS
THAT DEFINE PRINCIPAL THREAT MATERIALS
The preferred remedial alternative for the ABS specifies excavation of principal threat materials
in and adjacent to the gas-o-meter structure (located on the ABY) and the tarry berm (located
in the SEA). Principal threat materials have been defined by EP A and UDEQ qualitatively as
those materials within and adjacent to the gas-o-meter and tarry berm that are liquid, non-
aqueous phase liquids (NAPLs), mobile tarry material, and visibly contaminated soils saturated
wi~ NAPLs. Principal threats are defmed quantitatively as those materials that represent an
- -
excess lifetime cancer risk of lE-03 or greater (UP&L, 1993b). The fmdings of the Baseline
Risk Assessment conclude that polynuclear aromatic hydrocarbons (PAHs) and benzene are the
contaminants of concern in soils and groundwater that, under reasonable maximum exposure
scenarios, contribute the ~ajority of the carcinogenic risk at the ABS (U.S. EPA, 1992). This
appendix. documents the derivation of soil concentrations for both P AHs and benzene that
represent a carcinogenic risk equal to or greater than lE-03 and thus defme quantitative values
for the extent of principal threat materials requiring remediation.
1.0
Derivation of -PAR Soil Concentration Eauivalent to a Carcin01~enic Risk of IE-OJ
The concentration of P AH compounds in soils that represents a principal threat was derived by
plotting the risk values associated with the carcinogenic P AHs versus the total P AH
concentrations detected in subsurface soil samples. This risk based approach was iniiliilly
developed in the context of deriving soil action levels for PAHs, and is described in "Statistical
Methods to Derive Cleanup Goals for a Multichemical Impacted Site" (Jupin and McCausland,
1992). The regression equation resulting from the log-log plot of risk versus total PAH
concentrations allows for derivation of the total PAH concentration equal to or greater than a
risk of lE-03.
Table 1 presents a summary of the site specific P AH data and resulting risk values used to
develop the plot of risk versus total PAH concentrations shown in Figure 1. The resulting
AppeDIIi& A - ROD Pcrf- StmduUa
Dcrivaliaa of Media CcaccuIntioIu That DerIDe Principal ThRat Materials
Utah Power md Light , AmcricaD Band Site RIlFS
up&I\8pppcrf.st4
May 1993
-------
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:- ''::''0- ".:'-~~~~::
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'.
Table 1
Summary of P AH Soil Data Used to
Quantify Principal Threats Containing P AHs
Sum of Carcinogenic Sum of Total Factored
Soil Sample Station PAHsb P AHsc Carcinogenic
Number' # (mglkg) (mglkg) Riskd
BHOO100l BHl 70.6 131.6 5.1E-05
BH002005 BHl 5.8 11.7 4.2E-06
BH003011 BHl 1.4 3.4 1.2E-06
- , .
BH004014 BHl '. ' . 1.5 3.6 1. 3 E-06
BHOO5021 BHl 70.9 380.1 6.1E-05
BH009001 BH4 25.4 65.7 1. 7E-05
BH010002 BJl4 22.8 59.7 1.6E-05
BHOI2001 BH4 297 1467 2.2E-04
BH013016 BH4 1.7 3.9 1.6E-06
BHOI5001 BH5 3.0 9.7 2.1E-06
BHOI6002 BH5 2.3 6.8 t'.9E-06
BHOI7003 BH5 1.4 3.4 1.2E-06
BHOI9008 BH5 1.5 3.7 1.4E-06
BH020014 BHS 1.8 4.3 1.6E-06
BH024001 BH6 8.1 12.9 5.9E-06
BH025OO3 BH6 47.6 113.2 3.2E-05
BH026004 BH6 42.8 92.6 3.1E-05
BH028OO9 BH6 6.0 41.3 4.1E-06
BH030013 BH6 10.3 75.5 7.4E-06
BH032001 BH7 50.5 101.5 3.6E-05
BH033OO3 BH7 61.0 125.0 4.2E-05
BH034OO9 BH7 0.96 2.7 8.0E-07
BH035010 BH7 1.6 3.9 1.4E-06
BH038001 BH8 718 . 1216.6 5. 7E-04
BH039002 BH8 3.9 6.4 3.1E-06
BH04OOO4 BH8 1.5 3.6 1.3E-06
BH042008 BH8 1.3 3.2 1. 2E-06
AppcacU A - ROD PI:rf~ SI8DdardI
DcriYaIiaD of Media CoaceaIraIioaJ 'Ibat Deti= Principal Threat MaIcriaJs
Utah Power aDd Licht I Ammcm BatTcI Site RJ/FS
up&I\8ppperf .lid
M3y 1993
-------
. ~.- ~ -"'-
.~
Table ~. (Continued)
0._-
Summary of PAH Soil Data Used to
Quantify Principal Threats Containing P AHs
Sum of Carcinogenic Sum of Total Factored
Soil Sample Station PAHsb PAHsC Carcinogenic
Numbe~ # (mglkg) (mglkg) Riskd
BH043013 BH8 1.6 3.9 1.4E-06
BH047001 BH9 2.7 6.3 2.3E-06
. BH048OO3 BH9 0.8 2.8 8.0E-07
BH049005 - BH9 0.7 2.2 7.0E-07
BH050010 BH9 1.5 3.6 1. 3 E-06
BH051014 BH9 1.8 4.3 1.6E-06
BH05300 1 BHIO 25.7 52.4 1.8E-05
BHOSS003 BHIO 124.2 229.4 9.2E-OS
BH057015 BHIO 21.6 198.8 1.2E-OS
BH153042 BH310 1.8 4.4 1.6E-06
BHlS6048 BH302 1.8 4.3 i.6E-06
BHl60058 BH302 1.8 4.4 1.6E-06
BH150065 BH303 1.8 4.4 1.6E-06
ll1H.TAR UlH.TAR 3597 23,099 2.3E-03
CONT.FIlL CON't FIlL 93.8 643.6 6.4E-05
CLAY WITAR CLAY WITAR 3.3 25.9 2.1E-%
TP-9 TP-9 597 4364 3.9E-04
TP-12 TP-12 772 6419 6.3E-04
TSI TS1 108.5 611.9 7.1E-05
TS2 TS2 62.2 366.8 4.3E-05
TS3 TS3 70.8 414.7 4.6E-OS
a
Subsurface soil samples collected during site characterization or treatability studies (UP&L, 1993a).
b
This value is the sum of the following carcinogenic PAH compounds which are a subset of the EPA target
compound semi-volatile organic list: .
benzo(a)anthracene
benzo(k)fluoranthene
dibenz(a,h)anthracene
chrysene
benzo(a)pyrene
benzo(b )fluoranthene
indeno( I ,2,3-c, d)pyrene
AppcIIdix A - ROD Performanc:e StaDdardI
DeriYatioa of Media COIICC:IIIraIicm That Dcfmc: Principal ThRat Materials
Utah Power aDd Lipt I American Bane1 Site IUlFS
up&l\apppcrf.std
MAY 1993
-------
,f.- ~
. -
. ....
Table 1 (Continued)
~_.
Summary of PAR- Soil Data Used to
Quantify Principal Tb~ts Containing P AHs
c
This value is the sum. of all the P AH compounds on the EP A Target Compound semivolatile organic list
including:
naphthalene
2-methyl naphthalene
acenaphthylene
acenaphthene
fluorene
phenanthrene
anthracene
fluoranthene
pyrene
benzo( a)anthracene
cbrysene
bcnzo(b )fluoranthene
bcnzo(k)fluoranthene
bcnzo(a)pyrene
indeno (1.2.3-cd)pyrene
dibenz( a.h, )anthracene
bcnzo(g,h,i)perylcne
d
Thc factored risk value is the sum of thc risks calculated for thc individual carcinogenic PAH compounds
detected in each sample (U.S. EPA. 1992 and Jupin and McCausland, 1992)
The risk for an individual carcinogenic P AH compound is calculated by:
Risk
=
(HIF) (SF) (detected concentration in soil)
where
HIP
=
Human Intake Factor. The HIP is an algorithm ~ in risk assessmcnt modeling that
incorporates several cxposure variables. Thc HIP used for the risk calculation in
Table 1 is based on a lifetimc worker oral exposure. The value is 1..7E-07 mglkg-
day.
SF
=
Slope factor (oral). The slope factor is a route specific estimate of a compound's
carcinogenic potency. Oral slope factors for carcinogenic P AHs are:
benzo(a)pyrene = 1.2E+Ol (mg/kg-day)"1
benzo(a)anthracene = 1. 2E-O 1 (mg/kg-day)"1
cbrysenc = 1.2E-Oi (mg/kg-day)"1
bcnzo(b)fluoranthene = 1.2E+Ol (mg/kg-day)"1
benzo(k)fluoranthenc = 1.2E~1 (mg/kg-day)"'
indeno(I,2,3-cd)pyrene = 1.2E-Oi (mg/kg-day)"1
dibenz(a,h)anthracenc = 1..2E+Ol (mglkg-day)"'
Appcadix A - ROD PerfOl1DlDCC StaDdatcb
Dcrivaboo of Media CoaI:Clllratioas That DcfiDe PriDcipal'IbRat Materials
Utah Power IIId Light / AmcraD Baml Site RIIFS
up&I\8pppcrf.suI
May 1993
-------
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i
,
1
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1
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-8
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2
3
4
5
LOG TOTAL PAH CONCENTRATION
Reqr...ion AnalY8i8 - Linear model: Y - a+bX
------------------------------------------------------------------------------
Dependent variable: UPUUSJ:. LCG10TRISK
Independent variable: UPUUSK.LCG1.0TP"
~._-----------------------------------------
P&n881:ar
I8U8aU
S1:&IIdarII
Error
or
ValUli
Prot».
Level
---------------.~-
-----------------
In1:8Z'C8p1:
Slope
-6.3U82
0.845856
0.0487831
0.0264134
-130.U2
31.U91
.00000
.000'00
---
----------------------
Analye18 ot Variance
.----
----------------
SO\IrC8
Model
Error
Sua ot Squar"
37.610'
1.695987
Dt
1
46
II8&n Square
37.610'
.036869
P-Ra1:10
1.020.108
Prob. Level
.00000
-------------------------------------------------------------------------------
'lotal (Corr.)
39.306614
47
Correlat1on Coetf1c1ent - 0.978188
Stnd. Error ot !at. - 0.192014
R-squ&r8d -
95.69 percent
FIGURE 1 - PLOT OF FACTORED RISK VS. TOTAL PAH CONCENTRATION
Appcadix A - ROD Pcrform8Dcc Slmdards
Dcrivatioo of Media Cooccauatioaa That DcfiDc Principal 'Ibrc8c MatcriaIa
Utah Power md Li&ht I AmcricaD Band Silc R11FS
up&I\8pppcrf.1Id
MAy 1993
-------
.:...:.-
regression equation (r = 95.7 %) was then used to calculate the concentration of total PAHs
that is equivalent to a risk of IE-03 as shown below:
Regression Equation:
where
log y
log y
log x
therefore x
=
0.845856 log x - 6;36482
-3
3.97
9,332 mg/kg (-9,000 mg/kg)
=
=
-
2.0
Derivation of Benzene Soil Concentration Equivalent to a Carcin02enic Risk of IE-03
Principal threat soils at depths great~r than 10' feet are defmed relative to their potential to
contaminate groundwater ~itha benzene concelitration that equates to a carcinogenic risk of
IE-Q3, assuming groundwater ingestion at residential exposure levels. Soil benzene
concentrations that equate to a risk of 1£-03 via groundwater ingestion are deriv~ through
soil:water partitioning relationships as follows (U.S. EPA, 1992):
Risk -
Where:
HIP -
(HIF)(SF)(Benzene Concentration in Groundwater)
Human Intake Factor. The Human Intake Factor is an algorithm used in
risk assessment modeling that incorporates several exposure variables.
The HIF for Residential groundwater ingestion is 1.2E-02 liters/kg-day.
SF
-
Slope factor (oral). The Slope Factor is a route specific estimate of a
compound's carcinogenic potency. Units are (mg/kg-day)"l. The oral SF
for benzene is 2.9E-02.
Rearranging the equation to solve for the benzene concentration in groundwater equivalent to
a carcinogenic risk of lE-Q3:
Benzene concentration in
GW @ lE-Q3 risk
=
Risk! (HIF) (SF)
lE-03
(1.2E-02)(2.9E-02)
2.9 mgli
=
=
Appcadix A - ROD PerfcmDlllCc SlaDda!ds
Dcriv8lioo of Media CoaceaInlioos That Define Principal Threat Materials
Utih Power md Light I Ame1icaD BuRl Site RVFS
up&I\appperf.std
May 1993
-------
- .(....-
"~
- -
""-":..-"".~""
~ .-"...: ::~>~}
The concentration of benzene in s6fls that ~onstitute~:"a principal threat is derived from the
soil:water sorption model presented in the document entitled "Development of Superfund Soil
Action Levels" (Truesdale, 1992). The basis for the model is the Freundlich equation:
.
(1)
Where:
Kct =
n =
Cw =
Cs =
K.s = C;CwD
Freundlich adsorption constant (t /kg)
Freundlich exponent (dimensionless)
solution concentration (mg/ t)
concentration sorbed on soil (mg/kg)
Assuming sorption is linear (n=l) and rearranging:
(2)
Cs = (K.JCw
For soils with significant inorganic and organic sorption, the following equation has been
developed to describe Kct as a function of soil organic and inorganic content:
(3)
Where:
Koc =
foc =
Ks =
fio -
Kct = (Kocf~ + (Ksf;eJ
organic carbon partition coefficient (t /kg)
fraction organic carbon (mg/mg)
surface-specific distribution coefficient
fraction inorganic material (fio + foe = 1)
K, is further defmed as Ks = (SA/200)
-------
... ..
..~..-;.-:.~.
".. ;.: ~ . ~ :~~::S!~
'0.-<:"0'.".,'
~ -, . .
Substituting equations 4 arttl 3 into 2 yields the following expression:
(5)
Cs = (
-------
. . '.
Appendix A References
.
Jupin, Robert J. and Diane McCausland. 1992. Statistical Methods to Derive Cleanup Goals
for Multichemical Impacted Site. HMC/Superfund '92 Conference Proceedings. Dec. 1
to Dec. 3, 1992. Washington, D.C.
Truesdale, Robert S. 1992. Development of Superfund Soil Action Levels. Draft Interim
Report. Hydrogeology Department, Center for Environmental Measurements and Quality
Assurance, Research Triangle Institute. Aug. 7, 1992. Research Triangle Park, North
Carolina.
U.S. EPA. 1992. Baseline Risk Assessment for the American Barrel Superfund Site. Salt
Lake:. City, Utah.
UP&L. 1993a. American Barre~ Site RI/FS, Remedial Investigation Report. Salt Lake City,
Utah. .
UP&L. 1993b. American Barrel Site RIlFS Draft Feasibility Study Report. Salt Lake City,
. Utah.
Appcadix A - ROD Pcdormmcc SIaDdards .
Derivalioo of Media Cc:a:clluaIic:m Tb:at Dcfmc PriIIcipal Thrc:at MaICrials
UI4b Power &Del Light I Amcricm Banc1 Sib: RIlFS
up&I\apppeIf.srd
May 1993
-------
, ,
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.
. . ,
I
.
Appendix B-1
Chemical-Specific ARARs
for Remedial Actions at American Barrel
Chemical Requirement Prerequisite Cilltlon ARAR. Comments
Specific AllAR ,
Safe D~nking EIIIblhhes health baaed standarda for 40 CPR Part 141 Applicable Groundwater beneath the Sito ii a
Wlter Act drinking water auppliealn public water UAC RJ09-IOI at the tsp, potential drinking water lOurce
syltema. SlIndards are established II UAC RJ09-103 RandA and is potentially interconnectect.
Mlximum Conllminant Level Goals for ground with current drinking water !~'
(MCLGs) or Maximum Conllminant water in supplies. ',!,
Levels (MCLa). !in!
Utah Air Regulatea particulates and particulste UAC RJ07-1-3.2 Applicable
Conservation monitoring.
Act
Specifiea tecbnology requiremenll for UAC RJ07-1-3.I.8(A) Applicable Applies to controlling dust from
dust control. UAC RJ07-1-4.5.2 lite after remedy is complete. ,;
,,'
Clean Air Act Establishes sllndards for particulate 40 CPR Part SO Applicable Applicable to temporary air
matter. pollution lOurces constructed at;
the Site during Remedial ActiQn,
Utah Water Eatablishes ,round water quality UCA 19-5-101, UAC R 317-6-2 Applicable g~;
Quality Act standards.
RCRA Eallbliahes criteria for identifyin, 40 CPR 261,264, and 268 Applicable
blZlrdOUI wastea, eillbliahea ground
water MCLa for relellel from SMUa,
and maximum concentration limill for
blZlrdous waite conatituenll which will d
be land diapoaed .;
.~
Corrective Lilts general requirements to be UAC R315-101 Applicable Applicable to setting cleanup i'
Action Cleanup considerod in eSllbliahing cleanup standlrds at the ADS. I .;
SlIndards Policy sllndlrds.
for RCRA,
UST, and
CERCLA Sites
,:
i~
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" , :
.
, . .
Appendix B-2
Action-Specific ARARs
for Remedial ActioDS at American Barrel
Action Requirement Prerequlaite Citation ARAR Commenta
I
Excavation Placement on or 10 land outald. unit 40 CFll268 R&A Requirements are applicable for
boundary or area of contaminatioo will UAC R315-13-1 RCRA hlZlrdoua waite.
triller land diapoul requlremeota aod Excavated lOila will be teated to
reltrictiORl. determine if they exhibit any
hlZlrdoua waste characteriatica .
and applicable land diapoul "
i
reatrictioRl will be identified II
Movement of excavated materiala to new Materiala coot8ioin, RCRA 40 CFll 268 Subpart D applicable requirementa.
According to EPA guidance, the
location and placement in or 00 land will huardoua wa.... aubject to land UAC R315-13-1 land diapol8l restrictiona will
trinar land diapoaal reltrictioDl for the diapoaal reltrictiORl are placed generally not be relevant and
excavated wa'" or cloaure requiremeota 10 aooch. unit. appropriate where wa.te. are not
for the unit in which the wa...la belog identified a. hazardoua.
placed. American Barrel principal threat
waltea are currently only
Area from which materiala are excavated RCRA hazardoua wa... placed See'Cloaure 10 thia exhibit. expected to be hlZlrdoua due to
may iequire cleanup to levela ..tabliahed at alte after th. effective date of the preaeoce of benzene (BPA
by cloaure requiremeota. the requiremema. Waite Code 0(18), which h..
not yet been addreaatid by the
land diapol8l reltrictioRl.
Treatment or Tanka muli have aufficieot ahelllUeRJtb RCM hazardoua wa... (lilted 40 CPR. 264 Subpart J R&.A Treatmerit ,and collection of
liorage in tanka (thictoeu), and, for cloaocl taob, or dlaracteriatic), held 10 I tank UAC R3IS-S.IO hlZlrdoua waste. occurs for
preaaure controla, to aalUre that they do for temporary period before Alternative 6b.
DOt COOlpM or rupture. treatment, diapoul, or atorlge
elsewhere, (40 CPR 264.10).
Waaie mud not be iocompatible with the 40 CFll264.191
tanlt material unl..a the tanlt ia protected UAC R3IS-8-IO
by I lioer or by other meaDl.
New tanka or compooenta must be 40 CFll264.193
provided with aecoodlry containment. UAC R3IS-8-IO
Tlnka mud be provided with comrola to 40 CPR. 264.194
prevent overfilliDB, Ind aufficient UAC R3IS-S.IO
freeboard maintained in open tanka to "
prevent overtopping by wive action or
precipitation.
\
Treatment or Inapect the following: overfilling 40 CPR 264.19S "
- .~
atouge in tanka comrol, control equipment, monitoring UAC R3IS-8-IO :',N'
dlta, wlate level (for uncovered tanks),
tank condition, Ibove-ground portions of
tanka, (to Isseaatheir atructuul integrity)
and the area surrounding the tsnk (to
identifY aigna of leakage).
-------
Appendix B-2 (Continued)
Action-Specific ARARs
for Remedial Actions at American Barrel
.:J
Action Requirement Prerequilite Citation I ARAR Commentl
Repair Iny conoaion, cnck, or leak. 40 CPR 264.196
UAC 1U15-1-10
Treatment or At clolUre, remove aU hlZlrdOUIWl1te 40 CPR 264.197
Slonge in, Tanka Ind huardoul Wllte reaiduea from taDb, UAC IUIS-8-IO
(con 'I) dilCbaqre control equipment and
diacharjre confinement ItruCIUrea.
Store ignitable and reactive Wille 10 al 40 CPR 264.198
to prevent the Wille from iJDitin, or UAC IUIS-8-10
reacting. lpitable or reactive willelin
covered taDb mUd comply with buffer "
zone requirementl in "Flammable and
Combuatible Liquidl Code, " Tlblea 2-1
through 2-6 (NltiOnal Fare Protection
As_illion, 1976 or 1911).
RAA ' -
Container U.. Ind management of contlinen. 40 CPR 264 Subplrtl A Vlriety of materilll (pPB,
Slonge Contllnen ofhazardolil Wille mull be: lIpent calbon, lIpent ion exchlnge
(on-lite) Ston,e of RCRA hlZlrdoul 40 CPR 264.171 reein, etc.) that may bo idenlified
. Maintained in good condition. walle (lilted or dJancterillil:) UAC IUIS-I-9.2 II hazardous wletes, will be ..
not mecdl1l amaU quantity 40 CPR 264.173 genenled Ind IIored in
. Compltible with huardoul waste genentor I:ritem held in I UAC 1U15-1-9.3 I:onfainen. Contliner IIonge
to be IIOred; Ind container for a temporary period requiremenl8 Ire considered
Jrelter thin 90 daYI before 40 CPR 264.174 Ippllcable to thil alternative.
. Cloaed duriDa IIOnge (except to treatment, dilpoaal, or IIOnge UAC 1U15-8-9.4
Idd or remove walle). elAWhere. A genentor who
Iccumulltea or IIOrea hazardou. 40 CPR 264.I7S
lnapect COntliner IIOn,e areal weeltly walle on lite for 90 claYI or Ie.. UAC IUIS-I-9.S
for deteriontion. in compliance with 40 CPR.
262.34(1)(1-4); 40 CPR. :
;
264.176, UAC 1U1S-8-9.6 i.
notlUbject to fun RCRA IIOnge '
,
"
requiremelll8. Small quantity ~;r
,enonton are not IUbjecl to the '\I,ri
9O-dlY limit [40 CFR. 262.34(1:),
(d), Ind (e); UAC IUIS-S-IO).
Container Place containen on a "oped, cnck-free 40 CFR. 264.175
Stonge bile, and protect from contlet with UAC IUIS-8-9.6
(on-site) accumulated liquid. Provide contlinment
I)'stem with a caplcity of 10" of the
volume of contlinen of free liquid..
Remove spilled or leaked walle in a
limely manner to prevenl overflow of the
contlinment 1)'8Iem.
B2-2
'f j t
, . .
-------
, I
" I l
.
, . .
Appendix B-2 .(Continued)
Action-Specific ARARs
tor Remedial Actions at American Barrel
::~
i!~Y:
':. ,'~
Action Requbemeat Prerequl.ite Citation I ARAR Commenta "y
Keep contaiaera of linitable or reactive 40 CFR. 264.176 '.
waate at leall 50 flit from the facility'. UAC R3IS-8-9.7
property 1i1lO.
Container Keep incompatible material. aepante. 40 CFR. 264.177
Stonge Sepante incompatible materi.l. Itorecl UAC R3IS-8-9.8
(on-.ite) near each ocher by a dike or other
b.rrier.
At cloaure, remove aU buardou. waate 40 CFR. 264.178
.nd reaiduea from the containment UAC R315-8-9.9
ay.tem, and decontaminate or nmov. .11
containen, linen.
Clean Clo.ure ClolUre and Poit.cloaure. 40 CFR. 264 Subp.n D R&A At the completion of remedial
Oenerat performance I18I1dard require8 RCRA buanlou. w... (tilled 40 CFR. 264.111; effon., .11 unita constructed ..
minimization of noed for further or chancteriatic) pl.ced .t .ite UAC R3IS-8-7 p.n of remediation will be
maintell811Ce and control; minimization or . .fter November 19, 1980, or UAC R-3IS-8-11.5 di.mantled .nd removed. Any
elimination of poll-clolUre eacape of movement of hazanlou. W.1Ie contamination relulting from the
hazanlou. walle, hazanlou. conatituenta, from on. unit, area of U80 of the.e unit. will aiao be::;
leachate, contaminated runoff, or contamination, or location into removed. '
hazanlou. waate decompo.itlon producta. another unit or area of
Di'polIl or decontamination of contamination. Not applicable
equipment, atlUcturea,lnd lOiI.. 10 material undilturbOd aince
November 19, 1980.
Remov.1 or decontamination 01 aU waate May apply 10 IUrf.CO 40 CFR. 264.111 Because the intent of
residuea, contaminated containment Impoundment .nd container or 40 CFR. 264.178 remedi.tionl involve. clolure
.yllem componenta (e.g., linen, ditea), tank linan and hazanlou. waste 40 CFR. 264.197 with Wille. in pllce, clean I
contaminated aublOil., and llructurea .nd reaidue.; contaminated IOU, 40 CFR. 264.228(.)(1) clo.ure will not be .!Uined and
equiPment cOntaminated with W.1Ie and includina 1011 from dredJing or and 40 CPR 264.258 thi. requirement i. not ARAR.
leach.te, and manaBement of them .. 1011 dillUrbed in the coune of UAC R3IS-8-9.9
hazanlou. w.ate. drillina or exc.vation,.nd .UAC R315-8-I1.S
returned 10 I.nd.
Meet health-based level. at unit. 40 CFR. 264.111
UAC R3IS-8-7
'.
..'"
. '
-------
Appendix B-2 (Continued)
Action-Specific ARARs
for Remedial Actions at American Barrel
'I
.;'.t
r.
'.
Action Requirement Pmequilite Citation I AltAR. Comrnenll
Off-Site In tho ca.. of 811)' removal or remedill Trenafor off-lite of CERCLA CERCLA _don Applicable Applicable to the off-lite
Treatment action iovolvlllJ tho tnDlfor of 10Y huardoul aubltlnce, poUutant, 121(11)(3) treatment, storage, or dlfIPolil of
Storage or . huardoullUbltlnco or poUutant or or contaminant. 40 CPR 300.440 (Propoaed ruling) wlltel generated during .on-slte
Disposal COotlmlDlnt off-lite, IUch huardoul remedial actions.
IUbltlnce or poUutant or contaminant
lbaU only be tranlfemd to a faciUty
which il operatina in compliance with
aoction 3004 Ind 3005 of the Solid Wlato
Dispolll Act (or where Ipplicablo, in
compliance with tho ToXic Subltlncea
Control Act or other Ipplicablo Federal
law) and all applicable State ,;
requlremeota. Such IUbll80ce or
pollutant or COotlmlD8nt may bo
tnnafemd to I land diapolll facility only
If the Prelident determinea that both of
tho foUowlng requirementa Ire met:
. The unit to which the huardoul
IUblltance or pollutant or
contaminant II tnDlferred II not
relollllll any huardoul wllte, or
conatituODt thoreof, into tho around
wlter or IUrfaCO wlter or 1011.
. AlllUch m_- from other unill
It the facility are boillJ comrolled
by I conective action proaram
IpproVed by the Adminiltntor
under Subtitle C of the Solid
, Wllte DlIPOIIl Act.
Identification RequlrOl th. identification of hIZIrdoul 40 CPR 261 R&A R.CRA characteristic huardoul
and liatin. of WlltoI throup Iiated WlltoI or teatinJ by UAC R.31S-1 to R.3IS-IOI WllteI may be found. Excavated
buardoul TCLP for cbaractoriatici of ItuardOUI lOils need to be tested ullng
Wilt- Wllte. TCLP methodl. '.
Oeneratora of Sell forth the ItIDClardl Ipplicable to Huardoul WlltoI Ire generated 40 CPR 262 R&A Onslte excavation of haurdoul
Huardoul generatora of huardoul Wllte. by operatioDl on the lite. UAC R.315-1 to R.31S-IOI lOill constitutes generation of
WI.te huardous waste.
Transporters of Sell forth the ItIndardl and requiremenll Huardoul waltol are 40 CPR 263 Applicable If hazardoul wastel are found
Hazardoul for trsnaportera of baurdoul waite. tranaported off site. UAC R.3IS-1 to R.3IS-IOI during excavation, transportation
Waste off site to an incinerator requires
compliance with thil lection.
"
..
B2-4
. '.
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, . .
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" . :
,
,
. , ,...
Appendix B-2 (Continued)
Action-Specific ARARs
for Remedial Actions at American Barrel
Action Requirement Prorequl.ite CilAltion I AllAR. Comment. "
DilChlrge to Requirea Itonn water dilChlrgOi to be Protection of IUmce waten 40 CPR 122 APplicable Applicable to the dilChlrge of
Storm Sewen permlaod undol' the Peden! (01' lUte) agllllll deJl'ldation I'UUltiDl 40 CPR 12$ Itorm waten on-.ite.
National Pollution DilChalJe ElimInation from lite dlac:halJOI UAC JU17-8
Syatoma (NPDBS) pl'O,nm. Different
requirementl are applicable for different
cll'lOI and typOi of dllChlrgOi.
DilChll'go of An NPDBS permit il required for Protection of IUmco waton 40 CPR 122 and Applicable The remedill alternative. at
Wltel' into diachlrgiDs watll' oftiite inlo IUnace aglilllt dOJl'ldation roaulting 40 CPR 12$ Americln Barrel may Include tho
Surfaco Water water bndlOi. from alto dlICbaIJOI UAC 317-8 dilCharxe of treated 01' untreat~
BodiOi .urface water. '
"
All aurfaco water dilCharxOl owlt bo in ,:1
complilnce with pl'Oowl,ated Utah .''-fl'
Stream DiachalJo SlAIndard.
DilChll'go to DiachalJe of poUulAlnta that pI" through Dlac:harxo to a PaI'W. 40 CPR 403.5 Applicablo Ol'OUndwater and other waite-
Publlcly-Owned tho PaI'W without treatmont, Intorfero UAC JUI7-8-8.4 water generated during remedill
Treatment with POTW operation, contaminate UAC R317-3thl'Ough R317-S activitiOi will be pretreated and
WorD (POTW) POTW dudgo, or ondanser health/..fety UAC JU17-10 discharxed pursuant to oxilting
(off-site activity) of POTW wOl'ken I. prohibited. indu.trial wasto pretreatment
permit with the SLC POTW,'
. DilChalJo mu.. comply with local
POTW pretreatment pl'OJI'8m,
Includins POTW apoeific
pollutantl, apill prevention.
pl'Ogram requiromentl, and
rcpol'tilJl Ind monitoring
requiromentl.
. RCRA permit-bY-Nle requirementl Tnnaport of RCRA hazardous
(includina corrective action whore waltOi to POTWI by truck, nil,
the NPDBS pormlt WI' IalUed or dedicated pipe (i.o., pipe 40 CPR 270.60(c)
Ifter Nov. 8, 1984) mu.. be IOlely dedicated for hazardoul UAC JUlS-3-18(b)
complied with for diachllJOI of waite (a. defined in 40 CPR
RCRA hazardou. Wllte8 10 264) which dlac1iIIJOI from
POTW.. within the boundariOi of the
CERCLA .ite to within the
bounclari.. of the POTW).
Ol'Oundwlter Ooverna pollutantl thlt will or are likely UAC JU17-6 R&A
Protection to enter into gl'OUndwlter.
-------
Appendix B-2 (Continued)
Action-Specific ARABs
for Remedial Actions at American Barrel
Action Requiremem Prorequiaite Citation I ARAR. Commenta
U.S. BPA The ItnteJY includOi auidelinOi on The protection ItnteJY dON not TBC Thil Itrategy il to be conlidered,
Ground-Water clal8ityiJia around water for BPA involve applicable ARARa but regarding ground water remedial
Protection decilioDl affectina ground water dON contain pollcy ltaternenta to alternativel for American Barrel.
Strategy protoc:tion and corrective actions. be considered. I
\
"
Criteria include ocoloaica1lmportaneo. ...!~
replaceability, and vuinerabillty
consideration.
New Source Standardl for now IOUrcel of air Need to determine if thOlO CM Section m R&A
Performance emiuioDl. Requirementa are soUrce- ItaDdardl apply to potential UAC R307-1-3
Standardl .pecific. remedialamoDl.
EmillioDl for Bltablishes emillioDl limita for de The protection strategy dON not UAC R307-6-1 TBC Alternative 6b includel point .'
Air Strippers minimul emillioDl from air Itrippera and involve applicable ARARa but lOuree emillions generated by
and Soil Venting lOiI ventin, and trillers the requirement dON contain policy ltatementa to lOiland/or groundwater
to obtain an air quality approval order if be considered. treatment.
the limita are exceeded.
Corrective U.ta ,enenl requiremonta to be UAC R315.IOI Applicable Applicable for CERCLA .itea.
Action Cleanup considered In OItabllshlng cleanup
Standardl Policy ltandard.. Consistent with activities ",i
for RCRA, currently being undertaken at
UST, and ADS pursuant to CERCLA.
CERCLA Sitel
Waite Treatment Treatment of restricted bazardoul waltel Wastea to be troItod must be Applicable No lilted hazardoul wastea have
prior to land dispo8l1 must attain. idontifiable al roItric:ted 40 CPR 268 (Subpart D) been identified at tho ADS.
concontrst!on-blled or tecbnoloJY-bI8ed huardOUI wutea. UAC R31S-13 Althougb not identified during
treatment ItIDdardl. the RI, it il assumed that -IOme
waltea will meet the definition of
characteristic hazardoul waite for
toxicity (D018). No concontrs-
tion or technology based
treatment ltandards have been
established for wastel newly
identified al hazardou8 by
characteristic to,ycity.
B2-6
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.
, . ,
Appendix ~2 (Continued)
Action-Specific ARARs '
for Remedial Actions at American Barrel
,;
Action Requiremenl Prerequiaito Citation I ARAR
Commenta
Placemenl of Liqulda in Landfill. Prohibition: Applicablo Applie. to the offaite diapolll of
Liquid Wallo in Iny characteriatic huardou.
Landfill No bulk or DOIKOn18ioerizod liquid Placement of. bulk or non- 40 CPR. 258,28 waite..
huardou. WI. or huardou. WI. COn18ioerizod RCRA huardou. 40 CPR. 264.314
con18lning free liquid., or IOlid WI. WllIo or IOlid WI. in . UAC R3U-8-14.8
containing free liquid, may bo diapoaod Iindfill.
of in Iindfill..
Pllcement of con18ioorizod 40 CPR. 264.314(d)
Containera holdina free liquid. may not RCRA hlZilrdou. WI. in I UAC R315-a-14.8(1)(2)
bo pllced in I landfill unie.. tho liquid i. Iindfill.
mixed with In IblOrbont or IOliditied.
Surface Wlter Prevent mnon Ind control Ind collect RCRA huardou. WI. treated, 40 CPR. 264.251 (c), (d) TBC Application of thele reqiJirementa
Control mnoff from I 24-hour, 25-year Ilona 1I0rod, or diapoaod Ifter the UAC R315-a-12.2(c)(d) repreaenta good engineering
(wllte pilea, land treatment flcilitiea, offective dlte of tho 40 CPR. 264.273(c), (d) practice.
l.nd611.). requiremen18. UAC R315-8-13.4(c)(d)
40 CPR. 264.310(c), (d)
UAC R315-8-14.2(c)(d)
Waite Pile UN. double-lioor Ind leachate collection Non-contaioorizod accumulation 40 CPR. 264.251 R&A Alternativo 6b involvea .hort-
I)'am. of IOlid, nonflammablo , UAC R3U-8-12 term (S ono year) .taging of
huardou. Willo or huardou. 40 CPR. 268.2, UAC R315-13-1 lOiI. in I pilo. 11Iele 1011. may
Wllto put into WllIo pile IUbject to land IUblllnco that i. uaod for bo identifilble I' huardoua
dilpolll reatrictiODl regulltioDl. treatment or IIorage. waste.. Accordingly, the RCRA
waste pilo requirement. Ire eith~r
appliclblo or relevlnt Ind
appropriate. However, becauN
uae of a pile will only involve
temporal}' ataging and becluse
tho pile il 10 be conltmcted on
exiating .ite .oils which may
already bo contaminated, thia
ARAR will nol be attained.
"
'.
.,'.'
, .
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I , 1
.
, . ,
Appendix B-3
Identification of Potential Location ARARs for the American Barrel Site
I Standard Requirement,
I Criteria, or Limitation Citation Description ItRAR Comment
Historic Sites, Building 16 USC Sec. 461-467 Requires Pederal agencies to consider the Relevant and UDBQ hu been notified that the gu-
and Antiquities Act existence and location of landmarb on the Appropriate o-meter may qualify for inclusion in
40 CPR Sec. 6.30(8) National Registry of Naturallandnwb to avoid the national register of historic
undesirable impacts upon such landmarks. places. Bvel}' effort will be made to
protect the structural integrity of the
gas-o-meter during remedial actions.
National Historic Preservation 16 USC Soc. 470 Requires Pederal agencies to tab into account Applicable UDBQ hu been notified that the gu-
the effect of any Pederally-usiatcd undertaking o-meter may qualify for inclusion in
40 CPR Sec. 6.301(8) or licensing on any district, site, building, the national register of historic
structure, or object that is included in or eligible places. Bvel}' effort will be made to
for inclusion in the national register of ~ric protect the structural integrity of the
places. gas-o-meter during remedial actions.
Migratol}' Bird Conservation UAC R 574 Relevant and Migratol}' birds are present in the
Act Appropriate Salt Lab City area.
Archaeological and Historic 16 USC Sec. 469 Bstablishes procedures to provido for Relevant and UDBQ hu been notified that the gu-
Preservation UAC, Title 63 preservation of historical and archaeological data Appropriate o-meter may qualify for inclusion in
Chapter 18; UAC R224 which might be destroyed Ihroup alteration of the national register of historic
terrain u a result of a Pederal construction places. Bvel}' effort will be made to
project or a Pederally-licensed activity or protect the structural integrity of the
program. gas-o-meter during remedial actions.
;~:I
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." ." "..'~~ ~..;,.~$~
APPENDIXC
-
RESPONSIVENESS SUMMARY
UTAH POWER & LIGHT/AMERICAN BARREL SITE
-
Overview
In accordance with Sections 113(k)(2)(B)(i-v) and 117 of CERCLA, a public meeting
on the Proposed PIan was held on April 22, 1993. A transcript of the meeting is in the
Administrative Record for the Site. The m~g was attended by members of the
community and representatives of Utah Power & Light. Questions were asked by a
community representative and a local family who had children attending Iackson Elementary.
The questiOJlS asked were primarily for c1arification of the proposed pIan and were answered
during the meeting. There were not any comments opposing the preferred alternative or
suggesting a different approach to remediating the Site.
A written comment was received from Utah Power & Light regarding liability for the
asphalt in the preferred alternative. A response is included in this snmmaIy.
. UDEQ has submitted a written letter regarding the extent of cleanup specifically
addressing the Deseret Paint Site and the adjacent residential properties. A response to this
letter is also included m this summaIy.
As discussed in Section ill of this ROD,. the community has expressed very little
interest in this Site and the planned cleanup. Community relations activities will continue
throughout the remedial design and remedial action to keep the community informed of
~vi~. .
Specific Comme...ts
Comment by PacifiCo:r;p. parent of Utah Power & U~ht:
...
PadfiCorp is concerned that the use of site materials in the asphalt may lead to
claims of future cleanup liability at the place where the asphfllt is installed. Because
PadfiCorp wiU hizve no control over how or where the asphfllt wiU be used, it must
be assured that it wiU not incur future cleanup expenses at the various locations
where the O.fphalt may be insttllled. It seems that PadfiCorp's concern can be
allevillled by use of a .special COVenant not to s~" as contempklted by 42 use f
9622(1)(2).
"\.
EP A I'e$POnse:
The EPA Model RDIRA Consent Decree provides for a covenant not to sue at the
Completion of the Remedial Action. The special covenant not to sue has only been
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. .....-
.' '-""""-:~,
sue are appropriate for the negotiatioBS phase of the RDIRA consent decree. A
determination on the use of a special covenant not to sue is not appropriate for the
ROD.
-
Comment by Utah Dej)artment of Environmental OuaIity:
-
The Preliminary Assessment (PA), Site Investigation (SI) and Remedial Investigation
Feasibility Study (RIfFS) investigations at the American Barrel Supeifund. Site and the
Deseret Paint CERCUS Site (DPS) indicated elevated lead levels in soils of both the
DPS and the residential area of the ABS. Concentrations of lead up to 2200 ppm in
the residential soils and up to 6100 ppm in the Deseret Paint soils have been
documented. EPA and UDEQ have held many discussions concerning this issue. The
Record of Decision (ROD) for the ABS is aboUt to be ftnalized, and it calls for no
actio~ on the soils of the residential area. Additionally, the Deseret Paint Site was
investigated during the SI stage and it is our understanding that the EPA has decided
that it does not pose a serious enough health threat to warrant any funher action. .
UDEQ disagrees with both of these positions. It is UDEQ's position that both the
residential soils of the ABS as weU as the soils on the Deseret Paint propeny contain
signiftcant levels of lead that pose a potential health risk to current or future residents
and/or workers at the mes. UDEQ feels that any remeditll action proposed should
include addressing these tWO areas..
EPA ReS1)Onse:
In assessing risks at Superfund Sites, EP A utilizes sampling techniques that combine
samples throughout potential exposure areas. For input into the IUIBK model for
assessing lead risks, EPA uses average concentrations for ~ media being sampled.
The lead values referred to in the residential area in UDEQ's letter were based on SI
samples which are biased towards visibly contaminated areas. The purpose of these
~ples is to determine if there is any contamination, and not to assess risk. As part
of the ABS RIlFS, soil samples were collected from yards throughout two residential
properties. The analytiCal results from these samples were used to estimate risk. The
estbn8ted risk for children exposed to lead levels in these properties were within
acceptable guidelines. Based in this assessment, EPA decided that cleanup of the
residential properties was not required.
The DPS bas been evallJated in the Superfund Program as a separate site. 'Ibis
property has a history of industrial use with activities that are consistent with
contamination found on the property. This property is separate and distinct from
activities that occurred on the ABS. The Superfund Site Assessment Program has
concluded that while this property is contaminated, it is not a National Priority based
on application of the Hazard Ranking System evaluation. Without a sufficiently high
score on the HRS, this site is not an NFL Superfund Site requiring cleanup activities.
-.
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Source: USGS 7.5 minute quadrangle - Salt Lake City North, Utah
SITE LOCATION MAP
FIGURE 1
Utah Power & Ugh!
Amoric:an Barr..' Sh.. Work Plan
up&l\sa..\sec; 1
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NORTH TEMPLE STREET - MUNICIPAL RIGHT-Of-WAY
~ GORDON CROFTS UNION PACIFIC
PROPERTY RAILROAD COMPANY
D
~ D RESlDEJfIW. F'ORIIER ~
N!EA , AIIIO YARD
3' 3'
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SOUTH TEMPLE STREET - MUNICIPAL RIGHT-Of-WAY
RICHARD J. HOWA COMPANY
UNION PACIFIC
RAILROAD COMPANY
FIGURE 2
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EXPLANATION
1:':":::':":::':') - AMERICAN BARREl YARD (ASY)
8.8.0.
THE AMERICAN BARREl SITE (ABS)
INCLUDES THE ABYAND SURROUNDING
PROPERlY WITHIN THE CITY BLOCK
SHOWN HERE .
~ POSSIBLE CREOSOl£ TANK AREA
~
i
SCAlE: 1 INCH - 100 F'EE1'
100' 0
11111111111
100'
I
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215 Union Boulovanl
SuItt 550
lakawaad. CO 80228
(JOJ) 980-6800
UTAH POWER AND UGHT
AMERICAN BARREL RifFS
SALT lAKE CITY. UTAH
MAP OF' ASS SHOWING LOCAL
PROPERTY OWNERSHIP AND
PRINCIPAL SOURCE AREAS
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NORTH TEMPLE STREET
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BRICk D'it'ElllNG
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DWEIJJNGS ADOBE,
DWEWNG,
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UIIE HOUS£. 1898
COAl. OFflCE
TAR WEll. PUIIPS
PURIFYING HOUSE
rORGE/BlACKSUIIH SHOP
SCAUS, 1898
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SOUTH TEMPLE STREET
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FIGURE 3
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EXPLANATION
~
a
seAL£: 1 INCH - 100 fEET
100' D
11111111111
100'
I
. ~If= FIGURE BASED ON 1889, 1898, AND 1911 I
~.
215 UnIon BouI...,nI
Suit. 550
Lob..ood, CO 80228
. (303) 980-8800
UTAH POWER AND UGHT
AMERICAN BARREl RifFS
SALT lAKE CRY, UTAH
COMPOSITE or
FORMER COAL GASIFICATION
FACILITIES
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NORTH TEMPLE STREET
WRECKlNC
YARD GARAGE
6
0<:) EX1ST1NC ~NC
rOUNDA'I1ON INFEIIR
o 10 BE 801 HOUS~
1930
RESIDENTIAl
MtA
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SOUTH TEMPLE STREET
FIGURE 4
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EXPLANATION
L .-J pOLE STAGING MfA
111m POSSIBLE CREOSOTE TANK MfA
t;j
LoI
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. SCII.£: 1 INCH a 100 FEET
100' 0
11111111111
100'
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215 Union Boulevard
Suit. 550
Lakowood, CO 80228
(JOJ) 980-eeoo
UTAH POWER AND LIGHT
AMERICAN BARREL RI/F'S
SAlT lAKE CITY, UTAH
COMPOSITE OF
FORMER CREOSOTE
WOOD-TREATING FACILITIES
....1930-1957
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NORTH TEMPLE STREET ?~. .~?~
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EXPLANATION
TW515 0
1EIIPORARY WEll
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R\Y.jJ .
PERI.WIEIIT IIONITORINC WEll
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lW517
APPROXlMA1E EX1ENI' Of AQurous CONTAIIJmllON
IN 1IIE SAtURA'Im ZONE BASm ON:
LABORATORY AND F1ElD DATA INDICAl1NG
PRESENCE Of 'It)C AND SDII-'It)C
COMPOUNDS IN GROUND WATER
".--
~
LABORAtORY RESULTS INDlCAl1NG
INORGoINIC GROUND-WATER
CONTAllJm1lON (SUlFATE. TOTAL
CYANIDE AND/Of! N!lRAtE)
~
I
SeA1£: 1 INCH a 100 FEET
11io' 0
11111111111
100'
I
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sua. 55D
lok..ood, co 80228
(303) 980-6800
. RW507
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UTAH POWER AND UGHT
AMERICAN BARREL RI/FS
SALT W
-------
NORTH TEMPLE STREET - MUNICIPAL RIGHT-OF-WAY
B GORDON CROns UNION PACIFIC
D PROPERlY RAILROAD COMPANY
CJ
D RES:rw- FORIoIER ~
~ AUTO YARD
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EXPLANATION
f~~;~~~~~{l ~rNRg~:-WtR~~~~F
(EXCLUDING SURFACE AND
(GAS-Q-METER FIll)
~
APPROXIMATE EXTENT OF lNAPL
~
a
SCAl£: 1 INCH - 100 FEEr
100' 0
11111111111
100'
I
ESTIMATED AREAL EXTENT
OF TARRY BERM PRINCIPAL TIiREATS
SOUTH TEMPLE STREET .
- MUNICIPAL RIGHT-OF-WAY
~.
215 UnIon Boulmlnl
Suit. 550
lokowood, CO 80228
(303) 980-6800
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RICHARD J. HOWA COMPANY
FIGURE 8
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UNION PACIFIC
RAILROAD COMPANY
UTAH POWER AND UGHT
AMERICAN BARREl RI/FS
SALT lAKE CITY, UTAH
LOCATION OF
PRINCIPAL THREATS
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NORTH TEMPLE STREET
GORDON CROFTS
PROPERTY
UNION PACIFlC
RAILROAD COMPANY
RESlDOOW.
Nt£A
FIGURE 7
. '.
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EXPLANATION
~
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~
~
ON-YARD AND OFF-YARD (SEA)
SURFACE SOILS (0-0.5' DEPTH)
APPROXIMA1E LOCATION OF COAl
TAR STILL AREA SUBSURfACE
SOILS (~.5'-10' DEPTH)
CAlCAREOUS FlLL
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SCAlf: 1 INCH - 100 FEET
100' 0
111111111.1
100'
I
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215 UnIon BouIovard
. Suit. 550
Lak...ood, co 80228
(303) 980-8800
UTAH POWER AND LIGHT
AMERICAN BARREL Rl/fS
. SAlT lAKE CITY, UTAH
LOCATION OF' LOW-LEVEL THREATS
(LOW-LEVEL THREAT
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