-------
.f>.
- .1="-, -+0
-- ----- - -
~~..
---- - :S:._-
--- -- -------.
UIDV AlE
SLAG
OU1 AND U
--' --
.-.
____n_-
~~\\~~
~~~~
COlA FEO[R-AJhPi~'of.R.tiiKcORPORAflol'j--
o subStdiOf'r' 01 t.;QIf'(J O,,!)SOI , U,l(ee k1t.
SHARON STEEL/YIDVALE
TAILINGS SITE
OPERABLE UNIT STUDY AREAS
r;.,..,. 2
-------
arsemc. A public education campaign was launched to warn residents about the dangers of
this practice. In addition to the residential use of the tailings, an investigation in 1988
revealed that tailings and other dusts had been blown by the wind and had contaminated the
soil with lead, cadmium, and arsenic over a 571-acre area of the City of Midvale located
downwind of the mill site. Analysis of the contaminants in the residential soil strongly
suggests that a major conttibutor to OU2 contamination was the windblown tailings from the
Sharon Steel mill site (OUl). Some of the contamination may also have originated from the
smelter at an adjacent Superfund site (Midvale Slag). Of the 571-acre residential area
contaminated by the tailings, further investigations have revealed that about a 142-acre area
(with an estimated volume of 248,300 cubic yards) contains soils which exhibit levels of lead
and/or arsenic above the action levels of 500 milligrams per kilogram (mg/kg) lead and 70
mglkg arsenic.
The Sharon SteeUMidvale tailings site, including both the mill site (OUl) and the residential
areas (OU2), was proposed for the Superfund National Priorities List (NFL) in 1984 and was
finalized on that list on August 28, 1990. The State of Utah was the lead agency for the site
between 1985 and 1987. Since 1987, the U.S. Environmental Protection Agency (EPA) has
been the lead agency. The initial Remedial Investigation (RI) for the site was completed in
June 1988. A Feasibility Study (FS) for the entire site was published in June 1989, and a
Proposed Plan issued in July 1989. A public hearing on this Proposed Plan was held in
Midvale. in August 1989. As a result of extensive public comment, EPA decided to divide
. .
the site into two operable units, with au 1 referring to groundwater. the mill site, and its
tailings, and OU2 referring to the residential soils contaminated by windblown tailings. The
decision to divide the site into two operable units was based on the threat presented by the
residential soils and the need to further investigate the groundwater beneath the mill site.
Issuance of the Record of Decision (ROD) was postpoJl~d for one year .to allow additional
studies to answer questions posed by the public. Further RIfFS studies and repons concerning
groundwater and residential soils were completed during 1989 and 1990.
LR SHNS OOl\ROD'ROD-2.FNL\l20993
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The FS for OU2 was completed and the Proposed Plan was issued on June 6. 1990. The
ROD for OU2 was issued on September 24. 1990. It required excavation and removal of
'contaminated soils on business and residential properties. Soils removed from OU2 were to
be incorporated into the OU1 remedy.
A FS and Proposed Plan for au 1 were completed in October 1990.. This FS also included an
evaluation of private sector proposals for processing of the contaminated soils and tailings. In
response to public comment. EPA enlisted the U.S. Bureau of Mines (BOM) to perform a .
study on the ability to beneficiate the tailings. EPA re-evaluated the results of the 1990 OU1
FS and incorporated the results of the BOM study and also private industry proposals for
transport and containment of the tailings into a new FS which was issued in May 1992. A
Proposed Plan for au 1 was issued in May 1992 and a public hearing was held in Midvale on
June 17, 1992.
While the Superfund process has been underway, EPA and the State of Utah have been
working with Sharon Steel to suppress the release of fugitive dust from the mill site to
prevent further contamination of the residential soils and to prevent re-contamination after
implementation of the remedy. This has been accomplished by spraying the site with a
polymer to bind the dust particles.
Three Potentially Responsible Parties (PRPs) were identified for the site. These include: (1)
Sharon Steel Corporation (Mining Remedial Recovery Company, a company formed during
bankruptcy proceedings of Sharon Steel Corporation, is the current owner of the mill site); (2)
UV Industries. Inc. and UV Industries. Inc. Liquidation Trust. the former owner and operator
of the mill site: and (3) Atlantic Richfield Company, a generator of hazardous substances
disposed of at the mill site and a potential former operator of the mill. General notice letters
were ~ ~nt to the PRPs on August 28, 1985, and requests for inforn.;:'~on were sent on May
12. 1988 (CERCLA 104e). No special notice letters were sent. EP A and the State of Utah
r.e:lched settiement with all three PRPs. Money from that settlement is being spent on
response actions at both OUs.
LR SHNS OOl\ROD'ROD-2.?o<'L\l20993
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3.
HIGHLIGHTS OF COMMUNITY P ARTICIP A TION
€ERCLA (Sections 113(k)(2)(B)(i-v) and 117) requires that EPA and the State keep the
community informed and allow the public to participate in the decision-making process iri
selecting a remedy for a Superfund site in their neighborhood. The legislation requires at a
minimum: (1) notice to potentially affected persons and the public: (2) reasonable
opponunity to comment; (3) an opponunity for public hearing; (4) response to each
significant comment submitted: and (5) a statement of the basis and purpose of the selected
action.
This section describes the specific community participation activities which occurred in the
process of selecting a remedy for the Sharon Steel OUI site. These activities not only meet
the minimum requirementS but exceed them significantly, indicating a commitment by EPA
and the State of Utah to meet both the letter of the law and the spirit of community
participation at this site. In addition, this . ROD document fulfills two requirementS of
CERCLA: (1) it contains a response to each comment submitted by the public (see the
Responsiveness Summary section of this document); and (2) it provides a statement of the
basis and purpose of the remedy.
1982 - The Utah Department of Health advised the public against removing tailings from the
site for use in landscaping, gardens. and sandboxes at their homes.
1983 - Community interv-iews were held for the purpose or' warning nearby residentS about
using tailings for sandboxes and gardens, and a press release was issued detailing the
potential for the site to be. listed on the NFL. Shortly afterwards, another press release
warned people .not to garden in soils containing tailings.
1984 - Sharon Steel site was proposed for the NPL.
LR SHNS OOI\ROD'ROD-2.FNL\120993
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1985 - A fact sheet. which briefly described the site and potential contamination. was mailed
to Midvale residentS near the site. Interviews were also conducted with residentS of Midvale.
The Midvale City Council created the Tailings Committee. later called the Community
Liaison Council. to disseminate site information to interested citizens.
1986 - The State met with local officials and the Community Liaison Council to discuss
public concerns regarding the site. As a result of these discussions. the S tate posted signs in
Asian and English languages to warn against site entry; distributed pamphletS to area residentS
warning against site access; and conducted an epidemiological survey of the neighboring
Asian population to evaluate concerns regarding health effectS.
1987 - EP A and the State of Utah met with Midvale officials to establish information
repositories. The repositories identified were the Ruth Vine Tyler Library in Midvale.
Midvale City Hall. and the Utah Department of Health. Meeting locations in Midvale were
identified as the Midvale City Auditorium. Midvale Middle School. Hillcrest High School.
. .
Utah Power and Light Auditorium. and Midvale Bowery. A fact sheet. mailed out in
September. 1987, summarized EPA's Superfund process and described the study being
conducted.
August 1988 - The Final Community Relations Plan was completed. Also a fact sheet update
was mailed to Midvale residentS in May while another fact sheet was mailed in August which
summarized the findings of the EPA's RI.
February 1989 - A press release was sent out regarding the fencing of the site.
June 1989 - Another press release clarified the decision process on cleanup of the site. In the
.same month, a press release was issued announcing the preferred alternative and Proposed
Plan. the dates of the comment period. and the public meeting date and location. Also. this
same information was advertised in the three tocal papers on June 14. The site at this time
was considered one OU.
LR SHNS 001\ROD'ROD-2.fNL\120993
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July 1989 - A fact sheet. Proposed Plan for Sharon SteellMidvale Tailin!!s Site. was mailed to
1.200 residentS in Midvale. The Community Relations Plan was revised on July 31.
August 1989 - Prior to the public meeting at the Midvale Bowery on August 17. the public
meeting was advertised and a press release issued. On August 16, a Congressional briefing,
tWo Editorial Board meetings. and a meeting of the State Health Depamnent were conducted.
September 1989 - As a result of commentS given to EP A on the Proposed Plan for the Sharon
Steel/Midvale Tailings site, the preferred alternative was not accepted by the State of Utah.
EP A extended the study period and the public comment period for the site, identified a
separate au for residential soil. and issued a press release to announce these changes.
November 1989 - Interviews were conducted on November 6. 7, and 8 with Midvale residentS
and business people to detennine what concerns they might have with regard to the Sharon
. Steel site. On the 28th of. November, EPA's Regional Administrator met with the U~
Depamnent of Health, Deseret News Editorial Board, Saito La.ke City Tribune Editorial Board.
and then Utah Governor Nonnan Bangener. The same day, EPA and the State hosted Public
Forum #1, at the Utah Power and Light Auditorium. The meeting was advertised in the local
paper. and a press release was issued. EPA and the Governor of Utah jointly sent out an
invitation to selected officials and interested parties inviting them to attend. At the meeting, a
status repon was given on site investigations and studies. A Plan for Respondin2 to Public
Comment was developed. EP A then announced that additional studies on soils and
groundwater would be conducted in response to public comment received during the August
1989 public hearing.
January 1990 - A fact sheet. Questions and Answers About Lead and Arsenic in the Soils.
was developed and mailed to over 1,200 Midvale residentS by EP A. In response to numerous
unsolicited private proposals EP A announced criteria for submittal of private industry tailings
reprocessing proposais; and a pre-proposal conference was held with reprocessors in Salt Lake
City.
LR SHNS OOl\ROD\ROD-2.FNL\120993
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February 1990 - Public Forum #2 was held in Midvale for the purpose of updating residents
on groundwater investigations. private industry reprocessing proposals. soils investigations.
and setting soil action levels. This was advertised in the local newspaper; EPA and the Utah
Department of Health jointly sent out invitation letters to selected officials and interested
parties: a press release was issued announcing the meeting; and the meeting was previously
highlighted in the January fact sheet. As a result of the interviews conducted in November
1989, the revised Community Relations Plan was released February 12, 1990.
March 1990 - Another fact sheet. RIlFS Prolect Status Repon, was mailed to Midvale
residents. Twelve reprocessing proposals" were received and evaluated: and numerous
telephone contacts betWeen reprocessors and EP A occurred.
May 1990 - A Soils Data letter was sent to over 200 Midvale residents giving the results of
the soil sampling on their properties. Availability sessions were scheduled all day and
evening May 22, and all day May 23, to answer and interpret the individual soil data results.
. .
A meeting was scheduled the same night to answer questions regarding the FS and to hear
concerns prior to the public meeting.
June 1990 - An advertisement was placed in the local daily papers announcing the Proposed
Plan for OU2. A few days prior to this. a fact sheet. Proposed Plan for Operable Unit 2:
Residential Soils, was mailed to Midvale residents. A public meeting on OU2 Residential
Soils was held June 14. A press release was issued announcing the meeting and
approximately 80 people attended. RIfFS reports for OU2 were placed in repositories for
public review.
July 1990 - PRPs requested an extension period for public comment. and EPA placed an
advertisement in the daily and local newspapers announcinr the additional 30-day extension
(ending August 1990).
LR SHNS OOI\ROD\ROD-2.fNL\l20993
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August 1990 - A Congressional briefmg was conducted by Congressional aides to discuss site
studies in progress with specific emphasis on the reprocessing proposal evaluation process.
"Fhe Mayor of Midvale was in attendance. and the Mayor of West Jordan was invited but did
not attend. Responses to public comments regarding OU2 were initiated.
September 1990 - A public meeting was held in Midvale. Attendees were not pleased with
EP A's conclusion that the information submitted in the reprocessing proposals was
insufficient to determine the feasibility of reprocessing at the site. In response to public
input. EP A decided to contract with the BOM to re-evaluate the feasibility of reprocessing for
the Sharon Steel tailings.
October 1990 - The FS and the Proposed Plan for OU 1 were published and the public
comment period was opened.
January 1991 - A Fact Sheet was published which postponed the previously scheduled public
meeting. The public was notified that the comment period was closed but would be reopened
at a later date.
February 1991 - A public forum was held at Midvale Middle School to update the public on
the progress on QUI and QU2. Approximately 50 people attended the forum.
April 1992 - A Fact Sheet mailed to the public summarized the resultS of the BOM study on
beneticiation.
May 1992 - A Public Forum was held at the Midvale City Auditorium to formally present the
findings of the BOM study, to review current and pending activities pertaining to the site, and
to provide an opportunity for citizens to ask questions.
June 1992 - A revised FS and Proposed Plan were published for aUI. This Proposed Plan
announced the commencement of a 30-day public comment period and also notified the
LR SHNS OOI\ROD\ROD-2..FNL\l20993
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public of a public meeting, which was subsequently held on June 17 at Midvale Middle
School. At the meeting, the public comment period was extended for an additional 30 days.
-The plan also presented a timeframe by which EPA and UDEQ agreed to evaluate a removal
alternative.
August 1992 - The State of Utah Department of Environmental Quality (UDEQ) mailed an
OU 1 update newsletter to the residentS of Midvale. A public forum was held on August 10 at
the Midvale City Auditorium to allow citizeps to comment on the Proposed Plan.
Approximately 22 people attended the meeting. The public comment period was closed on
August 14.
In addition to the above specified highlightS, EPA and the State of Utah cooperated betWeen
1989 and .1992 in conducting the following activities:
.
EPA and the State met numerous times with Midvale officials to discuss the
status of EP A and State activities.
.
A list of contactS and interested parties was made and kept updated. The list
includes Utah Federal Senators and Congressmen, State-elected officials, Utah
Department of Health Officials, area media. and interested groups and
individuals, as well as a mailing list of over 1,200 Midvale residentS.
.
A Technical Advisory Committee (T AC) was fonned October 19, 1989, in
response to commentS made at the August 17, 1989 public meeting to keep
participantS. residentS. and other interested parties infonned regarding technical
activities and project status at the Sharon SteeVMidvale Tailings site. Tn-=
T AC, which consisted of representatives from the Utah State Department of
Health. Salt Lake City and County Health Department. PRPs. representatives
from Midvale city government. U.S. Geological Survey, and the U.S. Bureau of
Reclamation. generally met one to tWo times per month. These meetings were
held to discuss project status, ongoing technical studies. future studies. and
current data interpretations in an effon (0 resolve technical differences in
opinion or approach as they arose.
.
A Technical Assistance Grant (TAG) was provided to a group of concerned
citizens in Midv::le. The TAG was used to review the technical findings
LR SHNS OOl\ROD\ROD-2.FNL\l20993
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resulting from the RIlFS process. This group has recommended the tailings be
moved.
.
4.
SCOPE AND ROLE OF THIS OPERABLE UNIT WITIHN SITE STRATEGY
As previously stated in this ROD, there are tWo operable unitS within the Sharon
SteellMidvale tailings Superfund site: OUI is the mill site with itS tailings piles. and OU2 is
the residential and commercial area of Midvale, Utah, contiguous to the site, where soils
have been contaminated with windblown mill tailings. The selected remedy for OU2 involves
excavation of the contaminated soils and temporary storage of these soils on the OUI mill
site propeny. The tailings and contaminated soils for both operable unitS are addressed by
the remedy for OU1. Since a major threat to human populations involves direct contact with
contaminated soils and tailings, removal of the contamination from people's properties and
homes (the OU2 selected remedy) will substantially reduce their current exposure. OU2 is
currently in the Remedial DesignlRemedial Action (RDIRA) stage. Cleanup has begun on the
fIrst phase of residential properties and is expected to be complete within fIve years.
The remedy for OUl, selected in this ROD, addresses contaminated soils, tailings, and
groundwater on the OUI mill site, as well as soil removed during the OU2 remedial action.
OUI poses a principal threat to human health and the environment because of the risks from
possible ingestion or inhalation of. and dermal contact with the soils and tailings. There is
also the threat of contaminant migration from the site both in the form of windblown tailings.
and by migration of contaminantS from the tailings into the underlying groundwater that either
discharges to the Jordan River or is a source of drinking water for the local residentS. The
purpose of this response is to prevent current or future exposure to the contaminated soils and
tailings, to isolate the tailings from contact with water, to reduce contaminant migration into
the groundwater, and to prevent contaminant migration offsite via groundwater. This remedy
will be the final response action for this site.
LR SHNS OOI\ROQ\R.OD-2.FNL\l20993
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5.
SUMMARY OF SITE CHARACTERISTICS
The soils and tailings at 'ou 1 and OU2 are contaminated with high levels of lead. arsenic.
cadmium. and lower levels of other tOxic metals. Only arsenic has migrated into the
groundwater beneath OU 1 to an extent sufficient to warrant an evaluation of public health
risks. Contaminated groundwatf?r has not migrated offsite. The major source of these metals
are the tailings at the Sharon Steel mill site (OU1). For many years. these tailings were
blown by the wind and then deposited in soils throughout the community (OU2). In addition.
it was reponed that unsuspecting residents were collecting the tailings and using them for fill.
sandboxes, and gardens. There are a number of ways the contamination can migrate from the
OU1 site: (1) the tailings can be blown by the wind and deposited in adjacent areas: (2) the
soil can be disturbed by human activities which could extend the depth of contamination; (3)
the dust transponed by the wind can enter homes and buildings: (4) contaminants in the soil
can be incorporated into plants during growth: (5) earthworms can redistribute the
contaminants in the soil: (6) adults and children can come in direct contact with the
contamination and transpon soil on their bodies. clothing, work boots. and tools: (7) pets can
get the contamination on their fur and carry it with them: and (8) contaminants can leach into
the groundwater which supplies drinking water for local residents.
The total volume of the tailings present in OU1 is estimated to be 9-million cubic yards. In
addition. there is an area of tailings west of the Jordan River covering 2.3 acres with a
thickness of approximately 6 feet, or approximately 22.300 cubic yards. The total volume of
soil requiring remedial action is estimated at 1,632.900 cubic yards. Tnis estimate includes
subtailings soil. mill site soil. wetland sediments, and contaminated soil and debris excavated
and transponed to the mill site from OU2.
The tailings at the mill site aver 'Te 5,470 mglkg lead and 320 mg/kg arsenic. Background
soil concentrations for this area are less than 100 mg/kg lead and less than 20 mg/kg arsenic.
In the OU2 s:udy :J.I'ea. the surface soils had le:ld concentr:lrions ranging from 33.8 mg/kg to
7,210 mg/kg with a mean of 839 mg/kg. The arsenic concentrations in the surface soils
LR SHNS OOI\ROO\ROD.2.FNL\l20993
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ranged from 3.5 mglkg to 3.520 mg/kg with a mean of 10 1 mglkg. The arsenic
concentrations in groundwater samples taken from monitoring wells on the site were found to
1'ange from 2.5 micrograms per liter (pg/L) to 246 pg/L, with an average of 28.14 pg/L. The
average onsite arsenic groundwater concenttation does not exceed the regulatory Maximum
Contaminant Level (MCL) of 50 pg/L. Monitoring wells where arsenic levels exceed the
MCL are located within the tailings. Arsenic concentrations in the Jordan River have
consistently ranged from 10 to 15 pgJL. The Federal Ambient Water Quality Criterion
(A WQC) for arsenic is 190 pg/L.
Geomettic means for contaminantS of concern in various media are given in Table 1. and
estimated volumes of contaminated media are shown in Table 2.
6.
SUMMARY OF SITE RISKS
Human Health Risks
Risk assessmentS (RAs) were developed in 1990 for both soils/tailings (May, 1990) and
groundwater (October, 1990) to evaluate potential human health risks associated with site
contamination in the absence of any remedial action. The risk assessmentS were completed
prior to the designation of au 1 and aU2.
Contaminant Identification
Many inorganic chemicals were detected at the Sharon Steel/Midvale Tailings site during the
RI. The resultS of an Endangerment Assessment based on data from the RI indicated that
arsenic. cadmium, and lead are the most likely chemicals to pose risks at the site. Therefore.
the RA focused on these three chemicals. The groundwater RA focused on arsenic since it is
the only chemical that has migrated into the groundwater to an extent that may pose public
health risks. and since 00 Qt;;er chemicals appear to threaten the groundwater.
LR SHNS OOl\ROD\ROD-2.fNL\l20993
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TABI.E 1
ca:OI\lEl RIC: I\IEAN OF CONTAMINANTS OF C()NC~RN IN V AIIiOUS 1\1EIIIA
!;;
~ I.ncal lIackCruunJ' Snil Contwninat~J SUlfac~ Soil Tailings
VI
8 Surface Surfuce Subsurface
~ EI~m~nt Terrace l-looJplain TelTac~ HuoJplain ResiJentiai Mill Site (Oxidized) (Dunes) (Unoxidiz~d)
~ (mg/kg)
C
~ Aluminllm 13,669.0 7,283.0 12,461.0 10,883.0 9,560.0 9,267.0 3,982.0 3.2711.0 3,002.0
.., Anlimony 6.1 <5.5 6.4 8.8 5.7 72.7 73.5 16.0 17.0
...
Ars~nic 15.2 5.7 31.5 -10.7 65.5 158.0 -125.1 320.2 -111.2
CaJmiwn 3.2 2.0 5.4 7.1 12.5 27.6 46.8 37.3 36.4
Chromium 18.0 11.9 17.8 18.6 15.8 29.8 25.4 17.0 18.3
C. 'I'P~r 81.-1 40.7 160.6 3-14.6 195.1 324.1 298.5 760.2 578.1
Lead 97.0 711.6 373.2 536.8 722.0 2,100.0 6,278.0 5,-170.0 5,209.0
Mancanese -15.1.3 2.19.5 466.0 452.8 508.9 833.7 1,199.0 1.-197.0 2,032.0
Silver 1.4 <1.4 1.9 2.8 3.0 10.4 26.9 24.9 27.1
11,allium BDLd IIDL BOL 1.6 1.4 2.0 3.3 3.2 8.0
Zinc 12-1.3 100.3 320.8 537.4 591.8 2,143.0 -1,1121.0 6,048.0 6,372.0
nb 4 5 23 11 22 31 13 22 4
..... Jordan River
0\
Sediment Surface Water urnundwaler
Deep Princ.
Perched in UI'P~r Sand & Aquiferl
Ekmenl lJp51r~am Uownslream Upslr~am Downslreanl Tailings Gravel/Shallow Residential Wdls
- (mg/kg) (Jlg/I.)
Aiumimull 1,-11)2.0 3,365.0 1,010.0 1,030.0 27.0 25.84 26.15
AllIimony <29.0 <34.0 <60.0 <60.0 <28.0 30.18 29.59
Ar1ienie 1.5 16.1 1-1.0 10.0 7.63 28.14 1.64
Cadmium <1.5 2.2 0.36 0.-14 3.0 3.0 3.0
L1nomilull 3.8 7.3 <3.0 <3.0 5.0 5.0 5.67
Copper' 4.0 15\.0 7.0 10.0 6.24 5.93 8.08
Lead 5.8 115.0 6.0 11.0 \.18 1.19 1.28
Manganese 38.2 1211.9 53.11 53.0 163.79 218.65 9.16
Silver <2.0 3.0 <0.2 <0.2 5.0 5.23 5.16
11lallillm UUt. BUL <10.0 <10.0 4.111 8.17 2.89
Zinc 16.0 331.1) 19.0 20.0 7.38 -19.96 8.26
nb 3 3 I I 8 9 5
Air Data from
December 1987 Event
Upwind
Downwind
-(IIIg/kg)---
314.0
<3.0
8.-1
24.0
37.0
438.0
25.2
108.0
787.0
3,865.0
90.0
2
5,422.0
5
. "Local Background" as defin~d in Ihe RI (19118).
b II = Number 01 samples.
. Samples w~re colleeleJ al olher luealions wilhin Ih~ ul'P~r sWld ami crawl aqllif~r.
-------
TABLE 2
VOLUMES OF: CONTAMINATED MATERIAL BY MEDIA
Tailim~s
Main Pile
(Includes Pyrite concentrate)
9,000,000 cubic yards
(84,000 cubic yards)
Piles West of Jordan River
22,300 cubic yards
Soil
Below Tailings Pile
Mill Building Vicinity
Wetland Area (SE quadrant)
OU2 Soil (and Debris)
1.134,000 cubic yards
132,000 cubic yards
43,600 cubic yards
323,300 cubic yards*
*
V olume estimate has been revised since FS report. Source: personal communication,
Wayne Rich, 1993.
.
LR SHNS OOlIT-02.TBUl208931KB:sdb
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The concentrations of the chemicals of concern on which the RAs were based are given in
Tables 3, 4, 5 and ~.
Toxicity Assessment
For RAs. chemicals are tyPically categorized as producing either carcinogenic. or non-
carcinogenic effectS.
Health Effects Criteria for Potential Carcinogens. Cancer slope factors. expressed in unitS
of (mg/kg/dayr1, are the toxicological parameters used in combination with chemical intake
estimates to derive an upperbound excess lifetime cancer risk. These slope factors are
developed by EPA's Carcinogen Assessment Group (CAG) for potentially carcinogenic
chemicals. and in the case of arsenic. was derived from the resultS of human epidemiological
stUdies. These estimates of the upper limitS on lifetime risk are unlikely to underestimate
risks. Therefore. while the actUal risks associated with exposures to potential carcinogens are
unlikely to be higher than the risks calculated using a cancer slope factor, they could be
considerably lower.
EPA also assigns weight-of-evidence classifications to potential carcinogens. Under this
system. the toxicological evidence is characterized separately for human stUdies and animal
stUdies as sufficient. limited. inadequate. no data. or evidence of no effect. Arsenic is
classified as a Group A chemical, or a human carcinogen. This classification indicates that
there is sufficient evidence to support the causal association between exposure to arsenic in
. humans and cancer. Cadmium has been classified as a Group B 1 or probable human
carcinogen for inhalation exposure only. This classification is for chemicals with sufficient
evidence of c:l1"cinogenicity in animals but limited evidence. in humans. Lead has been
classified as a GrouF B2 or probable human carcinogen. This means that there L~ufficient
evidence of carcinogenicity in animals. but inadequate evidence of carcinogenicity in humans.
However, EPA had not developed a cancer slope factor for lead at the time the RA was
performed.
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TABLE 3
SUMMARY OF
SURFICIAL MILL SITE TAILINGS CONCENTRATIONS USED FOR THE RA (a)
Concentration (mg/kg)
............... ................ ............. ...o.........- ..u........... ..............- .......... ............ .......... .......... ...........
Element Minimum Maximum Arithmetic Mean
Arsenic 96 1,596 428
Cadmium 18 405 53
Lead 1,300 17,400 6.378
(a) n = 38. See Appendix 5D, Final Draft RI (1988).
LR SHNS OOlrr.03.TBUI20893
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TABLE 4
SUMMARY OF RESIDENTIAL SOILS CONCENTRATIONS USED FOR THE RA
Element
Depth Concentration (mg/kg)
Interval ..~...u __on- ...n'''. "0".. ...._......un." ......... .......... .............-........ ............. ............... ............"
(inches) Minimum Maximum Arithmetic Mean
0-2 3.5 3,520 101
2 -.6 4.5 515 82
6 - 12 3.0 618 83
0-2 0.5 52.5 10
2-6 0.3 73.2 11
6 - 12 0.1 52.9 9
0-2 34 7,210 839
2-6 16 4,800 731
6 - 12 9 3,920 601
Arsenic
Cadmium
Lead
LR ~llNS OOlrr-04.TBUl20893
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TABLE 5
SUMMARY OF GROUNDWATER ANALYTICAL RESULTS
USED. FOR THE RA
Arsenic Concentration (Jlg/L)
. .................u u...".....""" ................. -........... ......n... .u........ ........... ........... .....0"0'''.... ....un...... .............. ...............
Maximum Minimum Average
Offsite Residential 44.5 29.0 36.8
Onsite Residentiae 258 8.51 144b
z
b
Individual well arithmetic averages were calculated fIrst. followed by arithmetic
averages for groups of essentially colocated wells.
This value represents the upper 95% confidence limit.
LR SHNS OOlfr.OS.TBLJl20893
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!;;
~
II>
o
o
~
~
t::
i
'"
...
TAlnJ~ 6
METAL CONCENTI(ATIONS IN UACKGUOLJNI> ANI> SITE SOILS'" h
(All cnncentraticms in mg/kg)
Soils Type
Estimated Local Background
Soils
Floodplain
Terrace
N
N
Estimaled Contaminated Soils
Terrace
Floodplain
Residential
Ollsitc
Arsenic Cadmium Lead
Range of Geometric Range of Geometric Range of Geometric
Detected Mean Detected Mean Detected Mean
Concent rat ions Concenl rat ions Concentrations
< 0.4 - 22 5.7 1.3 - 4.3 2:0 30 - 143 79
II - 22 15 1.6 - 4.4 3.2 26 - 143 97
0.35 - 335
16 - 715
9.5 - 787
7.9-815
32
61
66
179
2 - 9.9
3.9 - 19
3.9 - 42
3.3 - 66
5.4
7.1
13
28
169 - 2,440
184 - 5,330
158 - 2,620
3 1 ~ 10,1 no
373
537
722
2,100
a Tailings data are not included in this tahle.
-------
Health Effects Criteria for Noncarcinogens. Health effects criteria for chemicals exhibitine
. -
noncarcinogenic effects are generally developed using reference doses (RIDs) developed by
the EPA RID Work Group. or RIDs obtained from Health Effects Assessment Summary
Tables (HEAST). The chronic RID, expressed in units of mg/kg/day. is an estimate of the
. .
daily exposure to the human population (including sensitive subpopulations) that is likely to
be without an appreciable risk of deleterious effects during a lifetime. These RIDs are
usually derived either from human studies involving workplace exposures or from animal
studies. and are adjusted using uncenainty factors. The uncenainty factors used in developing
RIDs use conservative assumptions based on the differences betWeen the environmental
human exposure situation and the animal bioassay from which the data were derived. Due to
the conservative nature of these factors. a margin of safety is implicit in their use. The RID
provides a benchmark to which chemical intakes by various routes (e.g., via exposure to
contaminated environmental media) may be compared.
The chemical specific human health effects criteria for carcinogenic and noncarcinogenic
effects used in the RA are listed in Table 7. EP A has not developed a toxicity value for lead
because lead has no known toxicity threshold. Instead~ EP A has developed an Integrated
UptakelBiokinetic (IUIBK) model for lead that is .used to predict potential risks.
Effects of Exposure to Contaminants
The contaminants of primary concern at this site are lead, arsenic. and cadmium. The major
adverse health effects associated with lead are alterations in blood and nerves. Exposure to
high levels of lead results in severe lead poisoning, which may include coma. convulsions.
profound and irreversible mental retardation, seizures. and even death. Less severe effects at
lower dosages include damage to receptor nerves. anemia. delayed cognitive development.
reduced IQ, high blood pressure, and impaired hearing. Even smaller dosages have been
implicated in enzyme inhibition, changes in red blood cell chemistry, interference with
Vitamin D metabolism, cognitive dysfunction in infants. changes in the ability of nerves to
transmit signals. and reduced childhood growth. Because their nervous systems are still
LR SHNS OOI\ROD'ROo.2.FNL\l20993
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TABLE 7 .
HEALTH EFFECTS CRITERIA FOR CHEMICALS OF POTENTIAL CONCERN
Chemical
Reference
Dose (RID)
(mgfkg/day)
Safety
Factor (a)
Source (b)
Slope
Factor
(mgfkg/dayrl
Source (b)
Weight of
Evidence (c)
Oral:
Arsenic
Cadmium
InhalaIion
Arsenic
Cadmium
Lead
50
6.1
(e) A
IRIS B2
IRIS A
IRIS Bl
IE-03 (d)
5E-04 (water)
lE-03 (food.f)
1
10
10
HEAST
IRIS
IRIS
2E+OO
Lead
(a) Safety factors used to develop reference doses are the products of uncertainty and modifying factOrs.
Uncertainty factors consist of multiples of 10. with each factor representing a specific area of uncertainty in
the data available. The standard uncertainty factors include: .
a 10-foid factor to account for the variation in sensitivity among the members of the human population:
a 100fold factor to account for the uncertainty in extrapOlating animal data to the case of humans:
a lO-fold factor to account for the uncertainty in extrapOlating from less~than-chronic NOAELs to
chronic NOAELs: and .
Modifying factors are applied at the discretion of the reviewer to cover other uncertainties in the data.
(b) IRIS = the chemical files of EPA's Integrated Risk Information System: and HEAST = Health Effects
Assessment Summary Tables. Dam obtained in 1990.
(c) EP A weight of evidence classification scheme for carcinogens:
A = Human Carcinogen. sufficient evidence from human epidemiological studies:
B 1 = Probable Human Carcinogen. limited evidence from epidemiological studies and adequate evidence
from animal stUdies: and .
B2 = Probable Human Carcinogen. inadequate evidence from epidemiological stUdies and adequate
evidence from animal studies: and
C = Possible Human Carcinogen. limited evidence in animals in the absence of human data.
D = Not classified
(d) RID under review by Inter-Office Agency Workgroup at the time the RA was completed.
(e) EPA 1988. Special Repon on Ingested Inorganic Arsenic Skin Cancer Nutritional Essentiality. Risk
Assessment Forum. Wa"hington. DC. EPN62513-87/031F. July 1988.
(f) In accordance with EPA guidance. the cadmium RID for food is used for ingestion of food and other
nonaqueous materials (e.g.. soils).
- -
Criterion has not been developed for this chemical.
LR SHNS OOltr.07.TBLJI20893
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developing. fetuses and children 0 - 3 years of age are most affected by the lower doses and
are. therefore. the most sensitive population. A compilation summarizing the various effects
noted in the literatUre along with the blood lead level concentrations at which these effects
occurred is given in the Baseline Risk Assessment Repon (Appendix I) of the OU I FS.
Arsenic also is a well-known poison. Acute inhalation exposure produces severe irritation of
nasal mucosa. larynx. and bronchi. reversible effects of blood. and cardiovascular system. and
distUrbances of receptor nerves. Chronic oral exposure of humans to arsenic can produce
toxic effects on the entire nervous system, age spots and warts, thickening and darkening of
the skin. skin lesions. blood damage, and cardiovascular damage. In addition, arsenic is a
known human carcinogen. Inhalation of arsenic has been linked to lung cancer in smelter
workers. Ingestion of arsenic has been linked to a form of skin cancer and more recently to
bladder. liver, and lung cancer.
Cadmium, when ingested. has been shown to be associated with kidney disease, bone damage,
high blood pressure, anemia. and suppression of the immune system. Inhalation of cadmium
has been implicated in development of emphysema and lung cancer. The doses associated
with the following effects were used to calculate risks for the chemicals of concern; for lead.
central nervous system effects; for arsenic, skin effects; and for cadmium, kidney effects.
Exposure Assessment
The exposure assessment (EA) develops the potential pathways by which humans may be
exposed to contaminants at the site under both current and futUre use scenarios. This includes
estimation of exposure point concentrations and development of chemical intake estimates. A
variety of potential exposure pathways exis't at the Sharon Steel OUI site through which
humans (particularly children) may be exposed to contamination. These include the
following:
LR SHNS OOI\ROC'.R.OD-2.FNL\120993
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.
Ingestion of contaminated soils and tailings by children who breach the security
fence and play on the site. Although children have been shown to actUally eat
dirt. the usual method of ingestion of contaminated soil arises from eating with
dirty hands. putting dirty hands into their mouths. and putting toys or other
objects. which are dirty with soil, in their mouths.
.
Ingestion of indoor dUSL Indoor dust ingestion occurs because outdoor fugitive
d~st from the tailings and contaminated soils penetrates buildings. leaving
contaminated dusts. Again, even children playing indoors can get dirty with
these dusts and ingest the dust in the same manner as described for outdoor
tailings and soils.
.
Inhalation of contaminated soil and indoor dust. Contaminated soil and indoor
dust can become airborne and be inhaled by the residentS.
.
Ingestion of contaminated produce. Home gardens are common in residential
areas near this site. Vegetables planted near the site could contain
contaminantS and result in human exposures via consumption of produce.
The exposure pathways evaluated in detail in the RAs are summarized below. The reader
should remember that the RAs were completed prior to the designation of au 1 and OU2.
Current Use Conditions
1)
Direct contact with and incidental ingestion of site tailings in sandboxes by children;
2)
Direct contact with and incidental ingestion of residential area soils by an individual
assumed to be exposed both as a child and then as an adult (i.e., a gardener);
3)
Inhalation of wind blown particulates from the site by nearby residentS: and
4)
Ingestion of home-grown produce by nearby residentS.
Future Use Conditions
1)
Direct contact and incidental ingestion of sIte soils by an onsite resident assumed to be
exposed both as a child and an adult;
2)
Inhalation of wind blown particulates from the site by an onsite resident:
LR SHNS OOl\ROD\ROD-2.FNL\l:D993
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3)
Ingestion of home-grown produce by an onsite resident; and
4)
Ingestion of groundwater by onsite and offsite residentS.
Since au I is currently secured with an eight-foot fence and is not. an active industrial
facility. direct contact with soil/tailings on the property at the present time is not considered
to be a complete pathway. However, tailings and soil have been used in the past by residentS
in sandboxes and gardens that still exist near OUI. The fIrst current use scenario was
developed to address contact via sandboxes. Exposure to contaminated soils and dust can
also occur among children and adultS in nearby residential areas. The second current use
scenario was developed to address this exposure. Mill property (aU I) contaminantS can
become airborne from wind erosion of the tailings piles and subsequently transponed to
nearby residential or commercial areas. The third current use scenario was developed to
address this potential exposure. Finally, produce grown in home-gardens may contain site
contaminants. The last current use scenario was developed to address this exposure.
Since the groundwater pathway is. not presently complete, exposure to contaminated
groundwater under current use conditions was not evaluated. Presently, arsenic-contaminated
groundwater is limited to the mill site. No drinking water wells exist in the unconfined upper
sand and gravel aquifer in the area of contamination or downgradient of the mill site.
In the future, it is possible that au I could be redeveloped for commercial or residential
purposes. Workers or residentS could be exposed to au 1 contaminantS. Assuming a portion
of the au I site was redeveloped for residential use, it is likely that residentS would come in
direct contact with tailings/soils/dust by ingestion and dennal absorption. The fIrst future use
scenario was developed to address this exposure. The second future use scenario was
developed to address exposure to air-borne contaminantS, and the third scenario was
developed to address exposure by ingestion of horne-grown produce. Finally. the last future-
use scenario was developed to address potential exposure to contaminated groundwater. both
on the mill proper.:y, and just downgradient of the mill property. The mill site scenario
assumes residential use of the mill property, including installation of a domestic well. This
LR SHNS OOI\ROC\ROD-2.FNL\120993
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scenario is not likely based on past and present zoning and land use. The offsite scenario
assumes a domestic well is located just down gradient of the mill propeny and screened in the
unconfined upper sand and gravel aquifer.
The exposure assumptions used in the RAs for the pathways evaluated are shown in Tables 8,
9 and 10 and 11. The values given in these tables were taken from various literature sources
referenced in the soils/tailings and groundwater RAs.
Risk Characterization
The contamination which exists at the Sharon Steel/Midvale Tailings site poses carcinogenic
and t~xic risks to human and environmental receptOrs. For OU1, both human and
environmental receptors are of concern. For OU2. human receptors are the primary concern.
This section discusses potential risks for human receptors at OU1. Environmental risks are
discussed later in this document.
For cadmium and arsenic, chemical intake estimates were combined with the health effects
criteria to estimate potential human health risks for the various exposure pathways just
described. For lead. estimated blood levels were compared to blood lead levels considered to
be of concern to human health.
For carcinogenic effects from exposure to arsenic and cadmium (inhalation only), risks are
presented as probabilities. For example. a 1 x 1006 cancer risk represents a one in one
million additional probability that an individual may develop cancer over a 70-year lifetime as
a result of the exposure conditions evaluated. EPA's acceptable cancer risk range for
Superfund sites is from 1 x 10.6 to 1 x 104. Any risk greater than 1 x 104 is not an
acceptable risk for a Superfund site. The estimated excess lifeti.'ne cancer ""isks for the
exposure pathways evaluated in the soils/tailings RA are summarized in Table 12. This table
shows thJ.t the toul excess life:ime cancer risk acro<;s all exposure pathways combined is 5 x
104 and 1 x 1003 under current and future use conditions. respectively. The higher cancer risk
LR SHNS OOl\ROINtOD-2.FNL\120993
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TABLE 8
EXPOSURE PARAMETER V ALVES FOR INHALATION
OF SUSPENDED P ARTICULATE MA TIER
Parameter
Exposure Parameter
30 years
1- 30 years
300 days/year
Duration of exposure
Age of residents
Frequency of exposure
Fraction of time spent outdoors at home
One through 30-year-olds
Two-year-old
Fraction of time spent indoors at home
One through 30-year-olds
Two-year old
Average body weight over exposure period
0.04
0.13
Inhalation rate for 1-30 year period
Inhalation rate for two-year-old
(for lead calculation) .
0.70
0.83
.48 kg
30 m3/day
5m3/day
Inhalation retention/absorption factors:
Arsenic
Cadmium
Lead
0.23
0.75
0.66
Parameter values are taken from sources referenced in the Soilsrrailings RA. .
LR SRNS OOlrr-08.TBLll20893
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TABLE 9
EXPOSURE PARAMETER VALUES FOR DIRECT SOIL
AND T All..INGS CONTACT SCENARIOS
Parameter
Exposure Parameter
Children - Sandbox play:
Frequency of exposure
Duration of exposure
Age of children
Fraction of time spent in sandbox
Average body weight over exposure period
Ingestion rate
ResidentS (current and future):
Frequency of exposure
Duration of exposure
Age of residentS .
Fraction of time spent outdoors at home
. Average body weight over exposure period
Ingestion rate
214 days/year
6 years
1-6 years
0.05
16 kg
200 mg/day
Ingestion rate for two-year-old
(for lead calculation) .
Fraction of time spent outdoors at home by
two-year-old (for lead calculation)
111 days/year
30 years
1- 30 years
0.04
48 kg
120 mg/day
200 mg/day
0.13
Oral absorption factors:
Arsenic
Cadmium
Lead
0.8
1.0
0.5
Parameter values are taken from sources referenced in the Soilsrrailings RA.
LR SHNS OOlrr-09.TBLJl20893
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TABLE 10
EXPOSURE PARAMETER VALUES FOR
PRODUCE INGESTION PATHWAY
Parameter
Exposure Parameter
30 years
1- 30 years
52 days/year
Duration of Exposure
Age .of Residents
Frequency of Exposure
Average Body Weight Over
Exposure Period
Ingestion Rate for 1-30 year period
Vine crops
Leafy crops
Root crops
Ingestion Rate for tWo-year old
(for lead calculation)
Vine crops
Leafy crops
Root crops
48 kg
151 g/day
144 g/day
114 g/day
111 g/day
102 g/day
127 g/day
Parameter values are taken from sources in the SoilsfTailings RA.
LR SHNS OOlrr-lO.TBUI20893
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TABLE 11
EXPOSURE ASSUMPTIONS FOR DRINKING WATER INGESTION PATHWAYS
Exposure Parameter
Duration of Exposure
Frequency of Exposure
Average Body Weight Over
Exposure Period
Drinking Water Ingestion Rate
Drinking Water Pathway
30 years
365 days/year
48 kg
Absorption Factor
2 Llday
1 ( unidess )
Parameter values are taken from sources referenced in the Groundwater RA.
LR SHNS OOlrr-ll.TBlJ120893
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TABLE 12
SUMMARY OF RISK CHARACTERIZATION RESULTS
FOR SOILSITAILINGS PATHWAYS
Chronic Daily Intake
Reference Dose Exce$s
(CDI:RfD) Rariola) Upperbound Blood Lead LevellC)
Lifetime
Exposure Pathway Arsenic Cadmium Cancer RisIclb) All Exposure Selected Exposure
Pathways Pathways(cI)
Cunent Site Use:
Tailings ingestion 2E-05
(sandbox)C 0.1 0.02
Soil ingestion' 0.003 0.0004 2E-06
Dust ingestionc 2 -2 4E-04
Inhalation' NA NA lE-05
Produce ingestion' 0.1 0.3 lE-04
Total 2 2 5E-04 > 30 ~g/dL > 30 ~g/dL
Future Site Use:
Tailings ingestion' 0.01 0.002 lE-05
Dust ingestionc 3 2 6E-04
Inhalation' NA NA IE-05
Produce ingestion' 0.5 2 5E-04
T ota! 4 4 lE-03 > 30 ~g/dL > 30 ~g/dL
\.,
The CDI:RfD ratio indicates whether or not exposures may result in adverse noncarcinogenic effects. A
ratio less than one indicates that adverse effects are unlikely to occur. while a ratio greater than one
indicates that such effects could occur. The RID for arsenic is 3 x 10-4 mg/kg/day. The RID for cadmium
is 1 x 10.3 mg/kg/day.
(b)
The excess upperbound lifetime cancer risk represents the additional probability that an individual may
develop cancer over a 70-year lifetime as a result of the exposure conditions evaluated. The EP A target
cancer risk range for Superfund sites ranges from lE-06 to IE-04. The oral slope factor for arsenic is 1.75
(mg/kg/dayrl. while for inhalation it is 50 (mg/kg/dayrl. The inhalation slope factor for cadmium is 6.1
(mg/kg/dayrl. Cadmium is not considered carcinogenic by the oral route.
(c)
Blood lead levels above 30 ug/dL were not predicted since the Inu~grated Uptalce/Biokinetic Model is nO[
applicable at these levels. Comparison blood levels of concern range from 10 to 15 ug/dL.
(d)
Does not include ingestion of lead from homegrown produce or from tailings in sandboxes.
(c,
Based on a child exposed from age 1 to 6.
(0
Based on a resident exposed from age 1 to 30.
N A = Not applicable
LR SHNS OOlrr.I2.TBU120893
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estimates are associated with ingestion of dust and site tailings. Both current and future risks
exceed EP A's acceptable risk.
Table 13 summarizes the estimated excess lifetime cancer risks for the groundwater pathway
combined with the soils/tailings pathways for future scenarios based on current groundwarer
quality. For these scenarios. the total excess lifetime cancer risk is 5 x 10.3 for the onsite
scenario and 2 x 10-3 for the offsite scenario. It is important to note that the future-use
groundwater scenarios are not occurring at this time, but were developed to show future risks
if the selected remedy is not implemented. Both current and future risks exceed EP A's
acceptable risk.
To evaluate the potential for adverse noncarcinogenic effects to occur. the Chronic Daily
Intakes (CD Is) estimared for arsenic and cadmium were compared to their Reference Doses
RIDs). CDI:RID ratios (Hazard QuotientS) were calculated for arsenic and cadmium
separately because these two chemicais effect different target organs (arsenic exposure can
affect the skin and central nervous system while cadmium exposure can affect the kidney and
immune system). A CDI:RID ratio that exceeds one (1.0) indicates that adverse effectS could
occur. Table 12 also summarizes the CDI:RfD ratios calculated for each exposure pathway in
the soils/tailings risk assessment, as well as the sum of the ratios across pathways (Hazard
Index). As shown in this table. the ratios exceed one for both chemicals under both current
and furore use conditions. This indicates that adverse health effects could occur. This is
primarily due to exposures via tailings and dust ingestion under current use conditions and via
dust ingestion under future use conditions. Table 13 summarizes the CDI:RID ratios for the
groundwater pathway combined with the soils/tailings pathways for furore scenarios based on
current groundwater quality. For these scenarios, the ratios for arsenic exceed one for both
the onsite and offsite residential scenarios, indicatine: that adverse health effects could occur.
- .
The potential for adverse effects from exposure to lead were evaluated differently than for
arsenic or cadmium. In this case. blood lead levels were estimated using the Integrat;:d
UptakelBiokinetic (IUIBK) model and compared to the blood lead level of concern (1990
LR SHNS OOI\ROQ'IROD-2.FNL\120993
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TABLE 13
SUMMARY OF RISK CHARACTERIZATION RESULTS FOR
SOILSrrAILINGS PATHWAYS AND GROUNDWATER PATHWAY FOR FUTURE
LAND USE SCENARIOS BASED ON CURRENT GROUNDWATER QUALITY
Exposure Scenario CDI:RfD Excess Upperbound
Ratio for Lifetime Cancer Risk
Arsenic
On-Site Residential
Soilsrrailings 13.3 1 x 10-3
Pathways
Groundwater 8.3 4 x 10.3
Pathway
TOTAL: 21.6 5 x 10-3
Off-Site Residentiae
Soilsffailings 6.7 5 x 10-4
Pathways
Groundwater 2.3 1 x 10-3
Pathway
TOTAL: 9.0 2 x 10-3
a
This scenario assumes groundwater exposure to an adult to a point from a shallow
domestic well near the site boundary, down gradient of the site. and soils/tailings exposure
from off-sire residential areas.
LR SHNS OOlrr-13.TBLJl20893
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Center for Disease Control Ad Hoc Committee) of 10-15 micrograms per deciliter (~gldL).
As shown in Table 12. the estimated blood lead levels for all exposure pathways combined
exceeded 30 pg/dL under both current and future use conditions. (The Integrated
UptakelBiokinetic model is not applicable for predicting blood lead levels above 30 pg/dL.)
For the combination of pathways assumed not to include homegrown produce ingestion or
tailings ingestion from. sandboxes, the blood lead level was greater than 30 pg/dL. The
exception was for the 500 mg/kg residential soil concentration band. for which the estimated
blood lead level was 24 pg/dL. Under current use conditions, and combining all exposure
pathways, reasonable maximum exposures via tailings ingestion in sandboxes, indoor dust
ingestion and homegrown produce ingestion all contribute to blood lead levels exceeding the
10-15 pg/dL range. Under future use conditions, and combining all exposure pathways, blood
lead levels above 10-15 pg/dL are primarily associated with tailings, indoor dust and
homegrown produce ingestion. Based on these results. it can be concluded that exposures to
lead via the pathways and scenarios evaluated in the soils/tailings baseline RA could
potentially result in adverse health effects to young children.
It is imponant to keep in mind that there are uncertainties affecting this assessment. For
example. the overall hazard index values for arsenic and cadmium exceeded one, indicating a
potential for adverse effects to occur under the exposure conditions evaluated. However.
because a safety factor of ten is incorporated into the cadmium RID. a CDI:RID ratio greater
than one does not in itself indicate that adverse effects will occur. There is still some
uncertainty surrounding this potential for a given chemical. In the case of arsenic, the overall
hazard index values are within the same order of magnitude as or greater than the RiD safety
factor of one. This indicates that there is a smaller degree of uncertainty surrounding the
potential for noncarcinogenic effects from exposure to arsenic (calculated according to the
defined exposure scenario) in comparison to cadmium. Also, input parameter values based on
field data and modeling were required to estimate concentrations in various environmental
media (e.g.. air. soil. produce. groundwater). To estimate exposures. assumptions regarding
the extent. frequency and duration of exposure and chemical bioavailability. were made. In
general. the overall approach followed in the soils/tailings baseline risk assessment was to
LR SIDiS OOl\ROD'ROD-2.FNL\J20993
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estimate reasonable maximum exposures in order to evaluate even sensitive subpopulations. in
accordance with current EPA Superfund risk assessment guidance and the policy expressed in
the National Contingency Plan.
Environmental Risks
Environmental receptors which may be at risk from exposure to the contamination at OU I
include vegetation. aquatic life and wildlife. Potential risks to the receptor and higher
receptors in the food chain are the prirriary results of exposure to contaminated soil as well as
contaminated surface water and sedimentS.
Soil lead concentrations as low as 100 mg/kg are known to be phytotoxic (toxic to
vegetation). Since soil lead exceeds this concentration on OUI, the potential for adverse
effects on vegetation and receptors consuming the vegetation are significant.
Aquatic life may be exposed to contamination in both the surface water and its sediments. Of
. .
the metals detected in the Jordan River downstream of the study area. only zinc is present at
unnaturally high concentrations (35 mg/l). However, because this concentration is below the
Ambient Water Quality Criteria (A WQC), risk to the fish population and higher species is
considered unlikely. Of greater significance are the unnaturally high concentrations of metals
in the river sediments. These sediments may act as a reservoir which presents continued risk
to aquatic life by supplying metals to the water column. or directly affecting benthic
organisms (aquatic bottom dwellers).
Wildlife in the wetlands habitat may be at risk from site-related contaminants directly through
contact with contaminated surface waters or sediments. or indirectly through consumption of
organisms living in the surface waters or sediments, or of larger insects or animals feeding on
these organisms. Some metals are known to accumulate in animal tissues and serve as a
source of exposure for large predatory birds or other terrestrial animals. Among the metals
present at the study area. lead has been shown to bioconcentrate in insects. small mammals.
LR SHNS OOl\ROD'ROD-2.FNL\120993
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and songbirds which may then be consumed by larger animals. Analysis of surface waters
and sedimentS from the wetlands adjacent to the tailings piles indicates that zinc
eoncentrations are unnaturally high in surface water and that several metals are present at
unnaturally high concentrations in sediment. It is uncertain whether wildlife in the wetlands
habitat is currently being adversely affected by the metals present at the study area; however.
the potential does exist for harm to wildlife populations.
Reduction of Risks to tluman Health and the Environment throu~h Implementation of the
Selected Remedv
The selected remedy for OU2 will achieve the human health goals of EP A by removing
contaminated soils and dust from OU2 and storing them at OU 1. However. this will only be
a temporary measure if the contaminated tailings and soils from OU1. which are the source of
contamination. are not addressed. Without a remedy for OUl, contamination will continue to
pose a threat to surrounding populations. ContaminantS would continue to migrate offsite
being carned by the wind. or leaching into groundwater and migr:ating with groundwater flow.
Either the selected remedy or the contingency alternative will remove the principal threat at
OU1. potential exposure of the public to the contaminated tailings and groundwater. Under
the selected remedy. exposure to the tailings will be removed by isolating the materials by
means of a cap and interceptor trench. Capping the tailings in place will eliminate blowing
and physical contact with the tailings. It will also reduce percolation of water through the"
tailings and thus reduce leaching of metals. The interceptor trench will funher reduce inflow
to the tailings and thus reduce leaching of metals into groundwater. The continued
monitoring of the groundwater onsite and. if necessary, extraction and treatment of the
groundwater in order to contain the groundwater, will mitigate the threat of contaminants
entering a drinking water aquifer or the Jordan River.
Under the contingency alternative. the excavation. transpon. and offsite disposal remedy will
eliminate the potential for exposure to the contaminated tailings and soils by removing the
LR SHNS OOI\ROD\ROD-2.FNL\l20993
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contaminated media from their current location. The potential for exposure at the new facility
will need to be conn-oUed. as the tailings will remain toxic. Continued groundwater
rROnitoring (and n-eatment. if necessary) will be required at OU1 to mitigate the threat of
contaminantS entering a drinking water aquifer or the Jordan River as contaminantS may
remain in groundwater beneath the tailings.
The risks to the environment will be reduced by the selected remedy in a similar manner as
the reduction of human health risks~ mainly by eliminating contaminant migration and
contaminant contact by organisms. Dredging the wetland area in OU 1 to remove
contaminated sedimentS and restoration of the area to itS natural state will eliminate
immediate wildlife contact with contaminantS. and will prevent future contact by eliminating
contaminant migration.
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 endarigennent to public health. welfare or the. environment.
7.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives (or action levels) were developed based on evaluation of the RAs
and applicable or relevant and appropriate requirementS (ARARs) for the site. These
objectives incorporate decisions on risk management issues and were used to guide the
development of alternatives and perfonnance standards. Objectives were developed for both
soils and groundwater.
The remedial action objectives established for the OU 1 site are:
1.
Prevent exposure to contaminated soil/tailings on the site by either isolating (selected
remedy) or removing (contingency alternative) tailings and soil exhibiting contaminant
concentrations exceeding health-based remediation levels (action levels) shown in
Table 14.
I.R :.'HNS OOl\ROD\ROD-2.FNL\J20993
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TABLE 14
SOIL AND GROUNDWATER ACTION LEVELS
Parameter
Action Level
Soil
Lead
Arsenic
Groundwater
500 mg/kgl
70 mg/kgl
Arsenic
50 pg/L (in wells on the nonh side of the
site)z
190 pg/L (in wells on the west side of the
sire )3
1. Based on risk assessment
2. Maximum Contaminant Limit (ARAR)
3. Ambient Water Quality Criteria (ARAR)
LR SH.."IS OOlrr-14.TBU120893
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"
...
Prevent migration of and exposure to contaminated groundwater exhibiting arsenic
concentrations greater than the action levels identified in Table 14 beyond the
boundaries of the QUI site. This will be accomplished by monitoring and containing
groundwater in the unconfmed upper sand and gravel aquifer beneath QUI.
3.
Prevent exposure to contaminated soil/tailings, reduce inflow of water to the tailings,
and reduce further contamination of the shallow groundwater by construction of a cap
and interceptor trench (selected remedy) or removal of contaminated soil/tailings for
offsite disposal (contingency alternative).
To meet these objectives, remediation will be required for the following areas and media:
.
Tailings on QUI and tailings on the western bank of the Jordan River which
were identified during the RI.
.
Soils in the mill area.
.
Wetlands sediments.
For groundwater, monitoring will be conducted to ensure that contaminated groundwater is
contained beneath au I and ARARs are. not exceeded at the point of compliance established
. .
at the QUI boundaries. Groundwater modeling conducted during the RI showed that the
maximum arsenic concentration reached in the shallow groundwater near the river would be
on the order of 100 Jlg/L, significantly less than the arsenic A WQC, which is an ARAR or
action level for the site. This model scenario included a cap and interceptor trench with no
groundwater containment. The results showed that even with no groundwater containment. it
is not likely that arsenic concentrations discharging to the river would exceed the A WQC.
Therefore. an active pump and treat system is not recommended at this time. If action levels
are exceeded at the established points of compliance. groundwater will be extracted and
treated. The goal of the pump and treat system would be to contain groundwater and prevent
migration of contaminated groundwater away from au I site boundaries.
LR SHNS OOI\ROINWD-2.FNL\1~0993
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Action Levels
Action levels were developed by. considering the non-carcinogenic and carcinogenic risks
developed in the RA. as well as ARARs. Since the exposure assessment and risk
characterization indicated that the targetS for acceptable risks were exceeded for lead. arsenic.
and cadmium. the IU/BK model for lead. the cancer risk assessment for arsenic. and the
hazard indices for arsenic and cadmium were used to predict what soil concentrations would
have to be in order to bring exposure risks to an acceptable target level. These calculations
were fully described in the FS for Sharon Steel OUI in the Recommended Health-Based Soil
Action Levels for Residential Soils section (Appendix H of the FS repon). These different
methods of calculating action levels were used because different methods were used to
evaluate risks and health effectS, as described previously. The IU/BK for lead predicted that
an action limit of 500 mg/kg lead in soils was necessary to achieve a target of 12.5 ~g
lead/dL of blood for 95% of the children 0 - 3 years of age. The cancer risk and hazard
index calculations showed that an action limit of 70 mg/kg arsenic was required to reduce the
exposure of residen~ to an acceptable level. An a~tion limit for cadmium was not calculated
since it was discovered that the distribution of all three contaminantS of concern had similar
patterns and clean up of lead and arsenic to their action levels would accomplish cleanup for
cadmium as well. These are the same action levels that have been established by the ROD
for the OU2 site.
For groundwater, pointS of compliance were established at the nonhern and western site
boundaries. The western boundary corresponds to the Jordan River. into which groundwater
from the unconfmed upper sand and gravel aquifer discharges. A nonhern boundary
compliance point was also established in the unconfmed upper sand and gravel aquifer. For
arsenic in groundwater that may migrate northward into an offsite drinking water aquifer. the
action level is the MCL (ARAR) of 50 ~g/L. This is a regulatory health-based limit set by
the EP A. For arsenic in groundwater migrating west to me Jordan River, the action level is
the A WQC (ARAR) of 190 ~g/L. This is also a regulatory limit that will be protective of
aquatic life in the river.
LR SHNS OOI\ROD'ROD-2.FNL\120993
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8.
DESCRIPTION OF ALTERNATIVES
Five remedial alternatives out of an initial six alternatives were evaluated in detail in the QUI
FS. These were Alternatives 1, 2. 3, 4, and 6. Alternative number 5 (In Situ Vitrification)
was not retained for detailed analysis due to cost and implementability concerns. Each
alternative is described briefly. below. A detailed discussion and analysis of the ARARs for
QU I is found in Section 2.2 of the FS report, and how each alternative complies with ARARs
is found in Section 4 of the FS report.
Alternative 1 - No Funher Action
This alternative provides a basis for comparison for other alternatives. The No Funher
Action alternative does not remedy or control the risk from any of the contaminated media at
the site. Under this alternative, monitoring would be conducted semi-annually for
groundwater and quanerly for air. Air particulate monitors would be located both on OUI
and on OU2, and a weather monitoring station woUld be established northeast of the site.
Four new monitoring wells. would be installed in the unconfined upper sand and gravel
aquifer.
Alternative 2 - Institutional/Site Controls
This alternative would utilize institutional controls to limit human exposure to site
contamination. Site access restrictions, such as installation of fences. posting of warning
signs, and land use restrictions would reduce human exposure to the tailings and soil.
Groundwater use would be restricted by requiring state issued permitS for wells drilled on
QUI and on OU2. Remedial measures taken under this alternative would include annual dust
suppressant application, site regrading to enhance stormwater runoff thereby reducing ponding
and tailings erosion, and riverbank. protection. Groundwater monitoring would be conducted
as described for Alternative 1.
LR SHNS OOl\RODIROD-2.Th1.\l20993
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Alternative 3 - Excavationffransuort/Containment
'This alternative includes excavation of contaminated materials (including au 1 tailings,
wetlands sedimentS, and soils and debris from aU2), and transpon of the contaminated
materials to a State and EPA approved disposal cell. This disposal cell would be designed to
comply with all ARARs. The wetlands area would be restored to itS natural state, and
groundwater monitoring, and, if necessary, treattnent would be conducted as described below
for Alternative 4.
Alternative 4 - Capping.
Under this alternative, the tailings and soils exceeding action levels would be capped with a
5-foot vegetated multi-layer modified RCRA cap (or design-based equivalent). This cap
includes 24-inches of vegetated soil underlain by geotextile fabric, a I2-inch sand drainage
layer. and a 24-inch compacted clay barrier. The cap would be installed on a graded and
compacted layer of tailings sloped at approximately three percent. Contaminated wetlands
sedimentS, and soils from the mill building area, and contaminated QU2 residential soils
would be included under the cap. Pedestrian access to the site would not be restricted;
however, significant land use restrictions would be implemented.
In order to reduce the risks associated with groundwater contamination in the upper sand and
gravel aquifer, QUI use restrictions would be implemented. and groundwater would be
monitOred at the pointS of compliance (monitoring wells) established along the northern and
western periphery of the au 1 tailings to establish the quality of groundwater migrating in the
unconfined upper sand and gravel aquifer. The monitoring well system would be designed to
also function as an extraction well system should groundwater arsenic levels exceed ARARs
at the pointS of compliance and treattnent of groundwater become necessary. Groundwater in
the unconfined upper sand and gravel aquifer mainly flows west and discharges to the Jordan
River, however, the possibility existS for flow to become more northward as a result of offsite
pumping in the deep principle aquifer to the north. Potential offsite flow to the north would
LR ~HNS OOl\ROD\ROD-2.FNL\120993
-------
be into a drinking water aquifer. Thus. the monitoring/extraction wells would be installed
along both the western and northern edges of OUI. The exact number of wells. configuration
of the system and frequency of monitoring would be determined during remedial design.
The monitoring wells would be points of compliance for the unconfined upper sand and
gravel aquifer. Groundwater would be monitored to ensure that action levels are not
exceeded at the points of compliance. For groundwater discharging to the river. the action
level is the A WQC for arsenic. For groundwater in the upper sand and gravel aquifer.
potentially migrating northward, the action level is the MCL for arsenic. These levels would
function as triggers for activating a pump and treat system. If the levels were exceeded
(based on statistical evaluations and evaluations by EPA and the State), groundwater would be
extracted and treated for arsenic removal. The goal of treatment would be to contain the
contaminated groundwater beneath the site and continue to prevent offsite migration. The
treatment system would not be constructed until the pump and treat system was triggered.
Treated groundwater would be discharged to the Jordan River.
The following monitOring would also be conducted:
.
Monitoring of water levels and metals concentrations in the deep principal
aquifer.
.
Monitoring of water levels and metals concentrations at locations other than the
compliance point wells in the upper sand and gravel aquifer.
.
Monitoring of metals concentrations in the Jordan River.
Based on the above additional monitoring, the following observations would trigger a re-
evaluation of site conditions:
.
A statistically significant decrease in water levels in the deep principal aquifer
(indicating a possible gradient reversal).
.
A statistically significant increase in shallow water levels beneath the tailings.
LR SHNS OOI\ROINWD-2.FNL\l20993
-------
.
A significant increase in arsenic concentrations in the Jordan River.
.
Significant increases in arsenic concentrations in the deep principal aquifer or
at locations other than the compliance point wells in the upper sand and gravel
aquifer.
Surface and subsurface recharge to the site would be controlled through a drainage system.
An interceptor trench would be consttUcted along the eastern boundary of the tailings to
intercept groundwater flow into the tailings from the perched terrace aquifer. This trench
would be 10 feet wide and 15 feet deep and would contain perforated pipes at its base to
drain intercepted clean groundwater to the Jordan River. By intercepting this source of water
to the tailings. net tailings inflow would be reduced by 20 percent. in turn reducing seepage
of contaminated water out of the tailings. Detailed design of the trench. including
monitoring, would be established during remedial design.
Tailings would be moved 150 feet back from the Jordan River to create a buffer zone.
Terraces would be constructed along the west side of the tailings pile to minimize cap
instability and provide flood protection.
A technical review of the proposed remedy has been conducted by. EPA Headquarters and
documented in a memorandum dated November 24, 1993. As a result of the review. EPA has
identified three issues which will require special attention and evaluation during design.
These include:
.
Potential incorporation of a flexible membrane liner (FML) into the cap to
further reduce the potential for infiltration of water.
.
Evaluation of additional geotechnical measures to reduce the potential for
seismically-induced damage to the cap and underlying tailings.
.
Evaluation of additional measures to reduce tailings slope instability along the
Jordan River.
LR SHNS OOI\ROINWD-:.FNL\l20993
-------
Based on the findings of evaluations performed during design, EP A will incorporate those
measures which it determines are appropriate to address these issues.
Alternative 6 - Fixation
Alternative No.6 would use fixation to reduce the risk of exposure to contaminated soils and
tailings on the site. Fixation consists of mixing the soils and tailings with a chemical to
immobilize the contaminants. Contaminated wetlands sediments would be excavated and
fIxed with the contaminated soils and tailings. Following fixation. a three foot vegetated
multi-layer cap would be installed over the tailings and soil.
Fixation of the tailings and contaminated soil results in an immobilized metals waste which
does not migrate to groundwater or surface water. Any existing groundwater contamination
would be treated and discharged from the site. Onsite groundwater use restrictions would
also be implemented. The wetlands would be restored.
9.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The NCP requires that each alternative be evaluated in terms of nine criteria which are
divided ~to three categories.
The first category includes the threshold criteria:
l.
2.
Overall protection of human health and the environment: and
Compliance with ARARs.
The second category includes the primary balancing criteria:
3.
4.
Long-term effectiveness and permanence;
Reduction of toxicity, mobility, or volume through treatment:
I..R SHNS 00 l\RO!JIROD-2.FNL \1:::0993
-------
5.
6.
7.
Shon-term effectiveness:
Implernentability; and
Costs.
The third category includes the modifying criteria:
8.
9.
S tate acceptance; and
Community acceptance.
An evaluation of each alternative with regard to these criteria is summarized in Table 15 and
described as follows:
Criterion I: Overall Protection of Human Health and the Environment
This criterion addresses whether a remedy is protective and describes how risks posed through
each pathway are eliminated. reduced, or controlled through treaanent. engineering controls,
or institutional controls.
Of the five alternatives, only Alternative 1 - No Further Action does not protect human health
and the environment. Alternative 3 - Excavationffransport/Containment provides long term
protection because it removes the contamination from the site. Alternative 6 - Fixation
protects human health and the environment by treating the waste to reduce its toxicity and
mobility. While capping, Alternative 4, also reduces the mobility of the contaminants, it does
so by containment and not treatment. It provides protection by eliminating the potential for
exposure. Alternative 2 - Institutional/Site Controls provides protection by separating the
contamination from the public using institutional controls and by removing the air and surface
water exposure routes. It does not address the potential for groundwater contamination
through installation of a monitoring and pump and tt"t._t system as Alternatives 3, 4 and 6 do.
LR SHNS OOl\ROC'ROD-2fNL\120993
-------
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TAln~E 15
INDIVIDUAL ANAI.YSIS OF ALTERNATIVES
Criteria
Alternative I
No Further Action
Alternative 2
Institutional/
Site Controls
Alternative 3
Excavation/
Transport/
Containment
Alternative 4
Capping
Alternative 6
Fixation
OVERALL PROTECIlVENESS
lIuman I kallh
Environmenl
COMPLIANCE WITII ARARs
Ooes not provide protcelion uf
human heallh.
Docs nol pn>lCel Ihc
environment.
.J::o
\0
Maj:nilude of Rcsidual Risk
LONG TERM EFFECTIVENESS AND PERMANENCE
Docs not lIIeet ARARs.
Adeome and surface
waler migrntion.
Docs nol meel ARARs.
Docs not reduce residual risk.
Reliability of inSlituliunai
cOnlrols and grading
mainlenanoe may not be
adc1luale.
'Ihere is no trealment process
ulilized in Ihis allemalive.
lllere is no trcatmenl process
ulilized in this allemative.
The mobility of surface tailings
is rcduced by dust suppression.
Removes dire~ conlact,
inhalation and groundwater
ingestion risk.
Removes airborne', surface water
and groundwater migralion.
MeelS ARARs.
No residual risk exisls from
tailings.
Conlrols for risk management at
OU I are not needed, risk mUll
be managed at the offsite
facilily.
Ion exchange uf conlaminanls
from shallow gruundwater
treaunenl, as re1luired only.
.5 MC,D groundwater for 30
years tif implemented).
ContanlinanlS are removed from
the site. Groundwater loxicity,
mohility and volume is reduced
at Ihe sile, Iml must b.:
cuntrollcd at thc uffsile disposal
cell.
Eliminates direct coni act and
inhalation risk and removes
groundwater ingeuion risk.
Cuntains groundwalcr
conlamination, reduces surface
waler contamination and
minimizes air contaminalion.
MeelS ARARs.
Residual risk due to pOlential
for cap breach.
Controls for risk management
are adequate.
Ion euhange of contaminanlS
from shallow groundwater
treaUnent, as required only.
.5 MOD groundwater for 30
years (if implcmenled).
l11e mobility uf sUlface tailings
and sub surface contamination is
reduced. nroundwaler tax icily,
mobility and volume is reduced.
Eliminates direct contacl and
inhalation risk and removes
groundwah:r ingeslion risk.
Minimizes surfuee water and air
contamination, reduces
groundwater contamination.
Meds ARAKs.
Residual risk due 10 unknown
long term field performance.
Conlrols for risk managemenl
are adequate.
In-silu fiutiun of tailings and
soils. Ion exchange of
contaminants 'roll1 shallow
groundwaler treatment, as
required only.
9.0 million eu ydtailings and
1.6 million cu yd ..f soils.
.5MGD groundwaler for 30
years.
Toxicity and mobililY will be
reduced but lailings volume will
likely increase. Groundwater
toxi,,;ty, mobility and v..lunlc is
-------
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10
fi
TAUI.E 15 (cuna.)
Criteria
Alternative I
No Further Action
Alternative 2
Institutional/
Site Controls
Alternative 3
Excavation/
. Transport/
Containment
Alternative 4
Capping
Alternative 6
Fixation
Degr~e 10 which TI~almcnl ;~
Irr~wrsibl~
Types and Qllanlilics of
Residuals
SIIOKT TEKM EFFECTIVENESS
Conll11lmily Proteclion
VI
o
WOIker Proleclion
EnvifOllmenlallmpacls
Tim~ IIntil Kem~dial Aclillll
Objeclives are Cumpleld
IMI'I.EMENTABII.lTY
AbililY 10 Conslrud and Op, ,,te
Reliabilily
Ease uf AdLliliunal R~lIIeLlialion
l11ere is 110 Ir~almenl process
IIlililed ill Ihis allemalive.
'111~r~ is 110 Irealm~1I1 process
ulililed in Ihis allemative.
1 here is no risk crealed Lluring
implemenlaliun of Ihis
allelllalive.
Slighl risk due lu dusl
general ion during moniluring
w~1I inslallalion.
'Ihere an: no impacls cr~aled
during implemenlalion of Ihis
allemative.
Kem~dial a.:.il~1 uhjecliv~s ar~
1101 achi~ved by Ihis all~lIIalive.
Cunslruclion and opcrali'~1 ar~
nol rell"ir~d for Ihis ult~malive.
.'nlere is nu aClion lal;en by Ihis
alt~malive.
Easy 10 implemenl.
'l1,ere is no Irealmenl process
ulililed in Ihis allelllalive.
'n,~r~ is no Ireallnenl process
ulilized in Ihis alternalive.
Moderale pOI~nlial risk due 10
dusl g~neralion.
Mod~rale pOlenlial risks due 10
dusl alld use of dJ~micals.
Polenlial surfac~ Waler nUlOff
from conlaminaied areas and
dllSl generalion.
Conlinullusly implemenled.
Dilsi suppression easily
implemenled.
Keliahilily of illSlilulionai
cllnlrols is moderale.. dusl
suppression is lemporarily
reliable.
Easy I" implemenl.
GroWidwaler Irealmenl is
irreversible.
10 cu. yd. of arsenic oxide per
year, if groundwall:r trealmelll is
r~'I"ir~d.
Moderale pOlenlial risk due 10
dusl generalion during
excavaliotl and spills Lluring
Iransplll1.
Significanl pl~enlial risk due 10
dusl generulion; transponalion
and redisposal halards.
Polenlial for surface waler
runoff, growldwal~r impacts and
dusl gen~ralion. POlenlial for
releases during Iransponalion
and r~LlispU5al.
II y~ars for all wUlk, JIJ y~ars
for grollndwakr.
Easily implcm~nled.
lIigh.
N"ne re'l"ire,\.
GroWidwaier Irealmenl is
irreversible.
10 cu. yd. of arsenic oxide Il<:r
year, if groundwaler trealmenl is
required.
Low potenlial risk Llue ", dusl
generalion.
Moderale pOlenlial risks due 10
dusl generalion.
I'oleolial surface waler nmoff
from conlaminated areas and
dUSI general ion.
2 years for cap. 30 y~ars fur
ground\Val~r.
Easily implemenled.
lIigh as long as cap is plOp~rly
mainlained.
Addilionallailings/sllil
r~medialion wUllld r~l\uire cap
deslrucliun.
Irreversible \reatmenl bUI long
lem! slabilil)' has nOI been
proven. (Jrullndwaler Irealmenl .
is irreversible.
9.0 million cu yd of fiK~d
malerial; 10 aI. yd. uf arsenic
oxide pcr year, if groundwaler
Irelmenl is required.
Low pOlenlial risk 5 due In dll"
generalion and dlemical
delivery 10 sile.
Mud~ra\e polenlial risks du~ 10
dusl generalioo and ..hemical
use and slOrage.
POlenlial surface waler n\lloff
Irom conlarninaled areas and
dusl general ion.
12 years lor lailill~s. 311 years
for groundwater.
Some difficuhy due 10
variahilily and lack uf
characleri:talion nf
. cl~lIaminalion"
ShOJl.lenn reliahililY is hi~h,
long lem! is nol plOven.
EAllemd)" Llinill.h for fiK".1
-------
TABLE 15 (cone.)
!;;
~ Alternative 3
(I>
8 Alternative 2 Excavation/
~ Alternative J Institutional/ Transport/ Alternative 4
-
'"
i1I Criteria No Further Action Site Controls Containment Capping
r::
i AbililY 10 Monitor En~cliv~neu "Illis ahernalive does nOI include Air and groundwaler qualily nrOlUldwaler Irealmenl syslem Cap inlegrily and groundwaler
... moniloring. easily monitored. easily monilored. Irealmenl syslem easily
...
;.;
< monilored.
u
~
Ahility 10 Coordinal~ and No appllIVal r~lluired. Subslantial coordinalion IeIluired Approval needed for redisposal Minimal coordination r~quired
Obtain AJ>I'roval from olh~r for instilutional conlrols. in of hi Ie local ion. including gruundwaler discharge
Agencies approval.
Availahilily of On.Sile None re(lnired. None reljuired. Siale d~signaled location None required
Treallllenl, Slor..ge and Disposal unknown.
Facililies
Availahilily of 1~II"il"II~"1 and None re'l"i. cd. Readily availahle for dusl A vailahle on It local basis. Availahle on a local hasis.
Specialisls suppression.
VI Availabilily of Tedllloingies None recluired. None required. ESluhlished let:hnology. None required.
.......
COST
Capilal $215,UOO $2,960,mO $168,.t68,6()1) $~9 ,560,1100
Firsl Year AlUlllal OperulilNI and $85,000 $2I.t,OOO $1,000,000 $211.000
Maintenance
Presenl Wonh Cosl $1,5S0,(KIO $6,160,000 $22.t,!KJU,OIKI $53.9:16,(JOO
Alternative 0
Fixation
Difficuh 10 assure complele
fixalion by in silu process.
Groundwah'r Irealllleni syslem
easily monilored.
Moderale coordinalio'l rellul/ell
including groundwater dist:harg~
approval.
None re'juired.
Availahl~ nn a regllll1all...sis.
Established lechnology.
$2,256,960.0IMI
$I,113,OO(J
-------
Criterion 2: Compliance with Applicable or Relevant and Appropriate Reauirements
(ARARs)
This criterion addresses whether a remedy will meet all Federal and State environmental laws
and/or whether there is a basis for a waiver from any of these laws. Applicable requirementS
must be met to the full extent required by the law. However. pursuant to Section 121 (e) of
CERCLA. no permits are required for remedial actions which are to occur completely within.
the Sharon Steel site boundaries.. On the other hand, only the relevant and appropriate.
portions of non-applicable requirementS must be achieved and only to the degree that they are
substantive, rather than procedural in nature. The ARARs are divided into chemical specific.
action specific and location specific groups.
Chemical specific ARARs are those based on health or risk based values that establish an
acceptable amount or concentration of a chemical that may be found in. or discharged to. the
ambient environment. Alternatives I and 2 do not meet all the chemical specific ARARs
ident;ified. Alternatives 3, 4, and 6 will comply with all ~e chemical specific ARARs.
Action specific ARARs are technology or activity based requirementS or limitations on
actions taken with respect to hazardous substances. Alternatives 2. 3. 4, and 6 will comply
with all action specific ARARs during implementation of the remedial action. As no
remedial activity is undertaken by Alternative 1. there are no action specific ARARs for this
alternative.
Location specific ARARs are limitations on the use of specific locations. Alternatives 2. 3, 4,
and 6 will comply with all location specific ARARs. As no remedial activity is undertaken
by Alternative 1 that would affect protected locations. there are no location specific ARARs
for this alternative.
LR SHNS OOl\ROD\ROD-2.FNL\120993
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EPA has thus determined that Alternatives 3. 4. and 6 will comply with all ARARs. Table 16
identifies which ARAR,s are action specific, chemical specific, and location specific.
In addition to ARARs, there may be other types of information useful for designing the
remedial action, or necessary for determining what is protective of public health or the
environment. These may be non-promulgated. non-enforceable guidelines or criteria that
provide useful information and are termed criteria "to be considered" (TBC). Best
professional judgment is used to evaluate TBCs.
Utah has promulgated Groundwater Protection Rules (R317-6) using the authority of the Utah
Water Pollution Control Act. This regulation governs pollutantS that will or are likely to
enter into groundwater. and establishes protection levels that discharges into groundwater can
not exceed. Since the regulation states, however, that the protection levels in the regulation
are not to be considered ARARs for CERCLA cleanups (R317-6-6.15), EPA considered the
Groundwater Pr~tection Rules as a TBC. ElementS of Alternative 4 such as the cap,
stormwater diversion measures and. the interceptor trench will enable this alternative to meet
the intent of the Groundwater Protection Rules of minimizing the discharge of contaminants
to groundwater. Alternatives 3 and 6 will also comply with the intent of this TBe. Since
Alternative 1 contains no measures, and Alternative 2 contains only minimal measures that
will reduce discharges of contaminantS to groundwater, these alternatives will not meet the
intent of the Groundwater Protection Rules.
Criterion 3: Lone-term Effectiveness and Permanence
This criterion refers to expected residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time once clean up goals have been
met. The reduction and management of residual risk at the site is most effective in
Alternative 3 because it removes the risk from the QUI site and transfers it to a controlled
facility (the risk must be managed at the new facility). Fixation provides moderate
effectiveness at reducing and controlling residual risk through treatment. It is less effective
loR SHNS OOl\ROINWD-2.FNL\l20993
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TABLE 16
FINAL FEDERAL AND STATE ARARsI FOR OUI ALTERNATIVES
Federal and State ARARs NatUre of ARAR
1. SAFE DRINKING WATER ACT
A. National Primary Drinking Water Chemical-specific and action-specific
Standards
B. National Secondary Drinking Chemical-specific and action-specific
Water Standards
C. Maximum Contaminant Level TBC
Goals
IT. UTAH SAFE DRINKING WATER ACT Chemical-specific and action-specific
ill. UTAH GROUND WATER TBC
PROTECTION RULES
IV. CLEAN WATER ACT
A.
Dredge or fill
V.
B. Ore mining and dressing
UTAH WATER POLLUTION
CONTROL ACT .
A.
B.
Water Quality Standards
Utah Pollution Discharge
Elimination System
VI.
CLEAN AIR ACT
VII.
VIII.
National Primary and Secondary
Ambient Air Quality Standards
UTAH AIR CONSERVATION ACT
A.
SOLID WASTE DISPOSAL ACT
A.
Criteria for Oassification of Solid
Waste Disposal Facilities and
Practices
B.
Standards applicable to
transponers of hazardous waste.
LR SHNS OOlfTBL-16.TBUl20993
54
Action-specific
Chemical-specific and action-specific
Chemical-specific and action-specific
Action-specific
Chemical-specific and action-specific
Chemical-specific and action-specific
Action-specific
-------
TABLE 16
FINAL FEDERAL AND STATE ARARs FOR OUI ALTERNATIVES(continued)
Federal and State ARARs
Nature of ARAR
IX.
x.
XI.
XII.
XllI.
XIV.
xv.
C.
Standards for owners and operators
of Hazardous Waste Treannent,
Storage. and Disposal Facilities
Action-specific
1.
2.
Oosure and post closure
Waste Piles
Action-specific
Action-specific
3.
Landfill
Action-specific
Action-specific
Guidelines for Land Disposal of
Solid Wastes
TOXIC SUBSTANCE CONTROL ACT
D.
A.
Asbestos
Action-specific
UTAH SOLID AND HAZARDOUS
WASTE ACT
A.
B.
Solid Waste Rules
Hazardous Waste Rules
Action-specific
Action-specific
1. Closure and Post closure
2. Waste piles
3. Landfills
4. Ground water protection
Action-specific
Action- specific
Action-specific
Action-specific
C. Corrective Action Clean Up Policy
SURFACE MINING CONTROL AND
REC~AMA TION ACT'
UTAH RECLAMATION OF LAND
MINES FOR MINERALS ACT
Action-specific
Action-specific
Action-specific
OCCUPATIONAL HEALTH AND
SAFETY ACT
UTAH OCCUPATIONAL HEALTIi
AND SAFETY ACT'
DOT HAZARDOUS MATERIALS
TRANSPORTATION ACT
Action-specific
Action-specific
Action-specific
LR SHNS OOlfTBL-16.TBUlZ0993
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TABLE 16
FINAL FEDERAL A~'D STATE ARARs FOR OUI ALTERNATIVES(continued)
Federal and State ARARs Nature of ARAR
XVI. RSH AND WILDLIFE Action-specific
COORDINATION ACT
XVll. ENDANGERED SPECIES ACT Action-specific
XVill. EXECUTIVE ORDER ON Location-specific
FLOODPLAIN AND WETLANDS
XIX. EXECUTIVE ORDER ON THE Location-specific
PROTECTION OF WETLANDS
XX. UTAH WATER REGULATIONS Location-specific
XXI. UTAH WELL DRILLING STANDARDS Action-specific
XXII. AGENCY FOR TOXIC SUBSTANCE TBC
AND DISEASE REGISTRY.
TOXICOLOGICAL PROFll..ES FOR
CADMIUM AND ARSENIC
Notes:
TBC = To Be Considered
1)
ARAR as used in this table indicate that the requirement is either applicable or
relevant and appropriate
LR SHNS OOIfI'BL-16.TI!Ul209Y3
56
-------
than ExcavationlTransport/Containment because there are concerns about its long-term
stability. It is more effective than Alternative 4 because of the residual risk of cap breaches.
however. Alternative 2 does not reduce the residual risk at the sire: however. it does manage
the risk. Groundwater exposure risks in Alternative 2 are addressed through institutional
control mechanisms, whereas Alternatives 3, 4, and 6 utilize monitoring and. if necessary a
pump and treat system. Alternative 2, therefore. has the lowest long-term effectiveness of the
alternatives.
Criterion 4: Reduction of Toxicitv. Mobilitv. or Volume throu~h Treatment
Of the five alternatives. only Alternative 6utilizes treatment as a remedial response action for
tailings and soil It provides reductions in toxicity and mobility, but may result in an increase
in volume of contaminared material. Although Alternatives 2. 3, and 4 reduce the mobility of
contamination. they are not treatment processes. Therefore. they are rated lower than
Fixation. Capping provides reductions in contaminant mobility to the air. surface water. and
. groundwater and. therefore, is rated higher than lilstitutional/Site Controls.
Alternatives 3, 4, and 6 utilize the same groundwater treatment system and provide equal
reductions in toxicity, mobility and volume of that media. Alternative 2 does not provide
groundwater treatment and is therefore rated lowest.
Criterion 5: Shon-tenn Effectiveness
This criterion addresses the period of time needed to achieve protection and any adverse
effects on human health and the environment that may be posed during the construction and
implementation period, until cleanup goals are achieved.
Alternative 2 - Institutional/Site Controls is the most effective alternative at protecting human
health and the environment during implementation. It has the potential for dust generation
during regrading and surface water runoff from contaminated areas. but has no impact on
LR SHNS OOl\ROINWD-2.FNL\l20993
-------
groundwater quality. It may be implemented in the shonesf time period. also. so that
potential risks are minimized. Alternative 4 is the next most effective at shan term
pr.otection. It holds the same potential for risk as Institutional/Site Cona-ols. but takes tWo
years to implement. The Fixation alternative is rated moderate for shan term effectiveness.
because it utilizes chemicals and has the potential for groundwater impactS during
implementation. Excavationffransport/Containment provides low effectiveness during
implementation due to the long time period required and the risks associated with excavation,
a-ansponation, and redisposal of the contaminated material.
Criterion 6: Implementabilitv
Implementability addresses the technical and administtative feasibility of the remedy,
including availability of materials and services needed to implement a panicular option.
Altem3:tive 4 - Capping has the highest implementability. It utilizes locally available
equipment and personnel and requires little regulatory agency coordination. Alternative 2
also utilizes locally available equipment and personnel. however, the maintenance required for
this alternative is high. Dust suppressant application must be repeated every year in order to
remain effective. Additional remediation under this alternative is easily implemented.
Alternative 3 has a moderate implementability because it utilizes locally available equipment
and personnel. but may place a high demand on their availability and may require specialized
equipment. Fixation (Alternative 6) has low implementability compared to the other
alternatives. The equipment and personnel required are available on a regional basis. but
operation of the process may be difficult given the variable characteristics of the waste.
Criterion 7: Costs
Cost factors include estimated capital and operation and maintenance (O&M) costS. as well as
present worth costS. .
LR SHNS 001\ROD'ROD-2.FNL\120993
-------
The present wonh costS for implementing the five alternatives evaluated for remediation of
OUI range from $1.580.000 for Alternative I to $2.271.860.000 for Alternative 6. The
.Institutional/Site Cona-ols. Capping. and Excavationffranspon/Containment alternatives costS
lie within this range and are $6.160.000. $53.936,000. and $224.000.000 respectively.
Criterion 8: State Acceptance
This criterion indicates the State's preferences regarding the various alternatives. The State of
Utah has issued Senate Concurrent Resolution 12 which indicates that the State would prefer
an alternative other than Alternative 4 as the selected remedy. The State has' expressed a
preference for Alternative 3.
Criterion 9: CommunitY Acceptance
This criterion addresses the public's general response to the alternatives described in the
Proposed Plan. The commUnity has not fully endorsed Alternative 4 and would prefer
. Alternative 3.
Of the various alternatives proposed. Alternatives 3 and 4 were the best overall in satisfying
the nine remedy selection criteria of the NCP.
10.
THE SELECTED REMEDY
EP A has chosen Alternative 4. Capping as the selected remedy and Alternative 3.
Excavationffranspon/Containment as the contingency alternative for the Sharon Steel OUI
site. The alternatives are discussed in detail in the OUI FS: A summary of each of these
alternatives follows.
LR SHNS OOI\ROrAAOD-2.FNL\12D993
-------
The Selected Remedv: Alternative 4 - Capping
IR summary, this alternative has the following componentS:
.
The tailings within 150 feet of the center line of the Jordan River will be
excavated and placed on the tailings pile. This excavation will prevent furore
surface water contamination and eliminate exposure of orgamsms to
contaminated sedimentS which could result if these tailings are left in their
current unconcrolled state.
.
Soil contaminated above action levels will be excavated to a depth of tWo feet
(approximately 132.000 cubic yards. based on soil action levels) in the former
mill area and placed on the tailings pile. The excavated soil will be replaced
with clean fill. and the excavated area revegetated. This excavation will
eliminate any physical contact with contaminated soils in the mill area.
.
The contaminated wetlands sedimentS will be dredged and this soil will be
placed on the pile (approximately 43.600 cubic yards as determined iJ:1 the FS).
The wetlands area will be reconsttUcted to itS natural state. This excavation
will also prevent surface water contamination and exposure of organisms to
contaminated sedimentS which could result if these sediments are left in their
current unconcrolled state. .
.
The tailings stored on the west side of the Jordan River will be 'excavated and
placed on the pile. This excavation will eliminate exposure to contaminated
tailings. '
.
The residential soil and debris removed during the OU2 remedial action
(approximately 323.300 cubic yards) will also be added to the tailings pile
before the final cap of the tailings is completed.
.
A five-foot. multi-layer vegetated soil cap (or design-based equivalent) is to be
consttllcted over the entire tailings pile. The cap will be designed to allow
access to pedestrian craffic. Only those strUcrores specified during remedial
design will be permitted on the cap in order to ensure the cap's integrity. The
cap will be designed to eliminate direct exposure to. and dispersion of, ,the
tailings. It will also be designed to reduce percolation of water through the
tailings and reduce the potential for leaching of metals to groundwater.
.
Measures will be taken to divert stormwater runon. to protect against erosion
during flood events. and to concrol subsurface recharge to the site. An
interceptor cre,nch will be constructed along the eastern boundary of the tailings
LR SHNS OOI\ROINWD-2.FNL\120993
60
-------
to intercept groundwater flow into the tailings from the perched terrace aquifer.
intercepted groundwater will be drained to the Jordan River if monitoring data
confirms that this groundwater meetS surface water discharge standards. Net
tailings inflow will be reduced by 20 percent. which will in tUrn reduce
seepage of contaminated water out of the tailings.
.
Both the cap and interceptor trench will serve to isolate the tailings by
significantly reducing inflow of water to the tailings, in tUrn reducing seepage
of contaminated water out of the tailings. This reduction in seepage from the
tailings combined with dilution will result in a decrease in groundwater'
contaminant concentrations in the upper sand and gravel aquifer below the
tailings.
.
The use of groundwater on the site will be prohibited through deed restrictions,
thereby eliminating potential onsite exposure.
.
A shallow groundwater monitoring system is to be installed along the nonhern
and western peripheries of the tailings. These wells will function as pointS of
compliance for the shallow groundwater migrating westWard. to the Jordan ,
River, and potentially northward. offsite in the upper sand and gravel aquifer.
These wells will be designed to also function as extraction wells should
ARARs be exceeded in them, necessitating pumping and treatment of
, groundwater. For groundwater discharg41g to the river, the action level is the
A WQC for arsenic. .For groundwater potentially migrating to the nonh. the
action level is the MCL for arsenic. If these levels are exceeded at the pointS
of compliance (based on evaluations by the State and EPA), a pump and treat
system will be' activated. Treated groundwater will be discharged to the Jordan
River.
.
This monitoring and possible treatment of the unconfined upper sand and
gravel groundwater will serve to contain contaminated groundwater and prevent
offsite migration in the upper sand and gravel beneath the OU1 tailings.
.
Additional monitoring will be conducted of water levels and metals
concentrations in the deep principal aquifer. water levels and metals
concenttations at locations other than the compliance point wells in the shallow
aquifer. and metals concentrations in the Jordan River. Site conditions will be
reevaluated by EP A and the State if any of the following are observed:
.
A statistically significant decrease in water levels in the deep principal
aquifer.
.
A statisticdly significant increase in shallow water levels beneath ,the
tailings.
LR SHNS OOI\ROD\ROD-2.FNL\l20993
-------
.
A statistically significant increase in river arsenic levels.
.
Statistically significant increases in arsenic levels in the deep principal
aquifer or in the upper sand and gravel aquifer at locations other than
the compliance point wells.
.
This additional monitoring will serve to contain contaminated
groundwater and prevent migration of contaminated groundwater outSide
the QUI site boundaries or into the deep principal aquifer.
The hydraulic characteristics of the selected remedy are basically twofold. First. the amount
of water coming into the tailings will be significantly reduced. Water presently within the
tailings will drain out until an equilibrium is reached betWeen the volume of water entering
the tailings and the volume draining from the tailings. Due to the cap and interceptor trench,
this volume will be minimized. The second characteristic is containment of contaminated
groundwater beneath the site. This will be achieved by the monitoring/extraction well system
and treattnent. if necessary. If migration of contaminated groundwater is prevented, aquatic
life in the river and groundwater users outSide the QUI site boundaries will be protected.
Estimated costs for the selected remedy are provided in Table 17. Figure 3 shows an
approximate site layout for this alternative. The actUal areal extent of the cap. location of the
trench, number of monitoring wells, and frequency of monitoring will be determined during
remedial design.
The Continl!encv Alternative: Alternative 3 - ExcavationffransportiContainment
Based upon the engineering cost estimates that it has received. EP A anticipates that the cost
to implement the offsite option favored by the State for remediation of the Sharon Steel
tailings QUI site will be substantially greater than that of the selected capping remedy. The
State has questioned EPA's position based upon their own studies. EPA and the State have
agreed to jointly conduct the following process to resolve their difference of information on
this issue.
LR SHNS OOl\ROIJIROD-2.FNL\J20993
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TABLE 17
Page I
COST ESTIMATES FOR THE OUI SELECTED REMEDY
PROJECT: SHARON STEELlMIDVALE TAILINGS SITE (OUI)
ALTERNATIVE ,I: CAPPING (Revised 4/92)
DESCRIPTION: Conslruction ala mulli-Iayered soil cap,
groundwater control with extraction. Ireatmenl and Jordan River disposal.
ENR Average Construction Cost Index
4890.83
DIRECT CAPITAL COSTS
(Includes Labor, Equipmenl & Materials, Unless Olherwise Noted)
COST
COMPONENT
UNIT
I. Excavation
a. Mill Facility Area
(Excav & Spread)
b. Wetlands Rumuve/Restore
c. Tailings West 01 Jordan
(Excav & Spread)
d. Settlement Analysis
CY
CY
CY
LS
0\
W
2. Sur lace Waler Control
a. Regrading (includes
Ib, OU2 soils)
b. Regrading Jordan River
c. Galena Canal Rehab
d. Slope Siabilizalion (Soil Cemenl)
3. Capping (incl milliacility area)
a. 24" Low Permeability Layer (clay)
b. 12" Sand Drainage Layer
c. Geotextile Filler Fabric
d. 24" Vegelalion Layer
e. Revegetation
CY
CY
SY
CY
AC
CY
CY
LF
LF
4. Groundwater
a. Groundwator Exlraction Wells
b. On-site Treatmenl
c. Pumpin!}'Diacharge 10 Jordan River
d. Inlerceplor Trench
EA
LS
LS
LF
TOTAL DIRECT CAPITAL COSTS
QUANTITY
132000
43600
22300
648100
1400000
5600
8600
567900
284000
851900
871200
270
11
1
1
5500
UNIT CAPITAL
COST COST
$9 $1,226,000
$11 $472,000
$9 $207,000
$35,000 $35,000
$1 $765,000
$1 $2,002,000
$81 $454,000
$702 $6,038,000
$9 $5,009,000
$11 $3,062,000
$2 $1.721.000
$9 $7,928,000
$721 $195.000
$18,000 $198,000
$885,000 $885,000
$397.400 $397,000
$69 $377,000
-------
PROJECT: SHARON STEELJMIDVALE TAILINGS SITE (OUI)
ALTERNATIVE~: CAPPING
INDIRECT CAPITAL COSTS (% 01 Direct Capital Costs)
I. Engineering & Design (15%)
2. Contingency Allowance (25%)
3. Other Indirect Costs
A.Legal (5%)
B. Regulatory (5%)
C. Mobilization/Demobilization (10%)
TOT ALINDIRECT CAPITAL COSTS
TOTAL CAPITAL COSTS (DIRECT + INDIRECT)
0\
.J;:.
TABLE 17 (CONTINUED)
COST ESTIMATES FOR THE OUI SELECTED REMEDY
Page 2
$4,646,000
$7,743,000
$1.550,000
$1,550,000
$3,097,000
$18,590,000
-------
TABLE 17 (CONTINUED)
COST ESTIMATES FOR THE OUI SELECTED REMEDY
Page 3
PROJECT: SHARON STEEllMlDVALE TAILINGS SITE (OUI)
ALTERNATIVE 4: CAPPING
PRESENT WORTH Discount Aale = 9.0%
DIRECT ANNUAIJPERIODIC COSTS DIRECT LIFE OF
QUANTITY UNIT ANNUAL ITEM ANNUAL PERIODIC
COST COMPONENT UNIT FREQUENCY (PER YEAR) COST COST (YEARS) COSTS COSTS
DIRECT ANNUAUPERIODIC COSTS
1.Cap
a. Inspection EA ANNUAL $2,000 $2.000 30 $21,000 nla
b Mowing & Ruvegelation EA ANNUAL $63,500 $63.500 30 $652,000 nla
c. Cap Repair & Maintenance EA ANNUAL $10,000 $10,000 30 $103,000 nla
2. Groundwater
a. Replace Groundwater ONE EVERY
Extraction Wells EA YEAR 1 $18,000 $18.000 30 $185,000 nla
b. Well O&M LS ANNUAL 1 $40.000 $40,000 30 $411,000 nla
c. Treatmenl Plant 0 & M LS ANNUAL 1 $88,500 $88,500 30 $909,000 nla
d Replace Treatment Plant EA EVERY nla $885,000 nla 10 nla $532,000
10 YEARS
e. PumpinglDischarge to Jordan O&M LS ANNUAL $55,100 $55.100 30 $566.000 nla
TOTAL DIRECT ANNUAL COSTS: $271,000
0\ TOT AL PRESENT WORTH OF DIRECT COSTS: $2,847,000
VI TOTAL PRESENT WORTH OF DIRECT PERIODIC COSTS: $532,000
TOTAL PRESENT WORTH OF DIRECT ANNUAUPERIODIC COSTS: $3.379,000
INDIRECT ANNUAUPERIODIC COSTS (Percentage 01 Total Direct Annual Cosls):
Administralion (10%) LS ANNUAL $27.700 30 $285,000 nla
Maintenance Reserve &
Contingency Costs (25%) LS ANNUAL $69,300 30 $712,000 nla
TOTAL PRESENT WORTH OF INDIRECT ANNUAUPERIODIC COSTS: $997,000
TOTAL PRESENT WORTH (Capital & AnnuaVPeriodic) COSTS: $53.936.000
-------
I.(JOO [ ~_._---_._.._- r~'"
'~~I-= 1----= --~ t , - WEST UONITORING
--',-. ..-./.,.., -- ~ .~ ~ONE ~
" ~~~ . . .,:,., OPERABLE UNIT' /-: .
. ,.".".' "~LIT"'-INGS 7J
.~, --.. ----"X~-=-- o~-lf-= .=~~u---
z z z Z L Z
g 8 g -g 8 g
~ ~ i d ci ~
~1=-;. -~-y\ '~nl~_';~I[n~r:~: C-~J J L J L:~=j I~_~~~ .
:C" ,J I.r-----' DO 1 [ . ----
.~~JL___H - - ...- .-~
(~~l:=- J_~_J
11.01111 I
10,000 l
----'-------- --
g,OOO l
-'1--....,
---~.-
"-
'.--
ESTIUATE AREAl
EXTENT CAP
0\
0\
8.001J Ł -=-:':~~:-~'_::' ---- --.-
/J'
z
o
o
o
5i
J
-,..- 3-9
--3'
400 0
~.__..
400 800
-.. .-. ---.,
~~~
~~~~I
COM rmERAi.'PROGRAiiS'CORPOr~ATlOtJ
Q subsQ.U'i' ul c'lJmp Oft:S~OI .. Uc;Kee Inc.
SHARON STEEL/MIDVALE
TAILINGS SITE
COMPONENTS or SELECTED REMEDY
FICUR[ J
-------
In order to gain better insight into these coStS. EPA and the State of Utah will joindy fund the
,following process. EPA. working in pannership with the State of Utah. will lead a Request
for Proposal (RFP) process to resolve the issue of whether a protective. cost-effective offsite
disposal alternative existS. TIris process will also determine if the offsite alternative meetS the
nine criteria for remedy selection set forth in the National Contingency Plan (NCP). and is
irnplementable in a timeframe and cost similar to the selected capping option.
In order for the contingency alternative process to proceed. the following schedule of
activities must occur. EP A will use four of the following dates (indicated by an asterisk) as
"triggers" for activities which follow. EP A will use the other dates as milestones to ensure
that this evaluation process is proceeding expeditiously toward completion. If a milestone
date is missed due to EP A's inability to meet that date. or if a trigger date is missed for
reasons beyond the control of the State. the milestone and trigger date will be revised by
EPA. if EPA agrees after a review with the State. of the reasons(s) the date was missed.
*By January 1. 1994. the Governor of Utah will provide a letter to EPA stating his
concurrence and support of this parmership approach betWeen EPA and UDEQ that
will be used to arrive at consensus on the market costS for the offsite and onsite
alternatives. The Governor will also commit to working with the Legislature of the
State of Utah during itS 1994 legislative session to make preliminary inquiries
regarding the funds the State is willing to provide to implement either the offsite or
onsite remedy.
Upon receipt of this letter to EPA's Region VIII Regional Administrator. the evaluation
process. as follows. will begin:
EP A will lead in the development of a dual track. Request for Proposals (RFP) for both a
capping alternative and an offsite disposal alternative. This process will provide for the full
involvemerit of the State of Utah in a manner similar to the State's involvement in the
LR SHNS OOI\ROD\ROD-2.FNL\l20993
-------
decision process for remedy selection. EP A will work with the State of Utah to ensure that
the State is provided with opportunity to fully participate in the conduct of this evaluation
process.
*By March 31. 1994, the Governor will provide a letter to Ef A stating, on behalf of
the State of Utah. his conunitment to seek funding as appropriate to remediate the
tailings. In the letter the Governor will provide his firm conunitment to seek
legislative approval for the amount of funds that the State is willing to provide in
order to implement an onsite or offiste remedy.
If these forgoing triggers are met. the following milestone dates and accomplishmentS are
expected to occur:
By September 30. 1994, EPA. in consultation with UDEQ, will complete the
development of performance specifications for both a cap and the offsite option.
These performance specifications will be used to request accurate information from
potential vendors regarding the final cost. .technology, and schedule of implementation
of the capping and offsite options.
By December 31. 1994, EPA will place the performance sp~cifications into the
marketplace for bid. .
Prior to the March 31, 1995 trigger date. all activities related to the receipt of bids. bid
evaluation. negotiation and cost verification are to be complete.
*By March 31, 1995, EPA, in consultation with UDEQ, will complete evaluation of
the bids and issue a decision on which technology to award. Pursuant to CERCLA
Section 121, EP A's authority to determine the final remedy selection is preserved. In
the event that the cost of offsite disposal is determined to be greater than that of
capping and the State of Utah desirrs offsite disposal be the remedy which is
implemented, the State of Utah will be required to enter into a contract (Agreement)
with EPA. pursuant to CERCLA Section 104(c)(3), ~2 U.S.c. g 9604(c)(3).
*By June 30, 1995, the State of Utah will sign the Agreement. This Agreement will
require Utah to provide 1C?., of funding requested from the Superfund. as required by
CERCLA Section 104 (C) (3), 42 U.S.C. g 9604 (c) (3) (Ten Percent Fund), or other
amountS consistent with the Governor's March 31, 1994 letter and to identify all
additional funding that will be used. If however, the amount of funding to be
LR SHNS OOI\ROC\ROD-2.FNl.\l20993
-------
provided by the State and the additional funding identified is less than the sum of the
remedy cost difference and the Ten Percent Funds. EP A may proceed. after
consultation with the State. to implement the selected capping remedy.
By September 30. 1995, EPA will proceed to award the contract for Remedial Design
of the selected technology in consultation with UDEQ.
By September 30, 1996. it is anticipated that the final design will have been completed
and a contract for Remedial Action for the lowest cost qualified bid on the selected
technology shall be awarded by EP A in consultation with UDEQ.
EP A considers each of the dates with an asterisk to be "triggers" for the activities which
follow. If these trigger dates are not met, then pursuant to itS decision authority in CERCLA
Section 121. EPA may proceed to implement the capping alternative as detailed in this ROD.
If a milestone date is missed due to EP A' s inability to meet that date. or if a .trigger date is
missed for reasons beyond the. control of the State. the milestone and trigger will be revised
by EPA if, after review with the State. EPA agrees with the reason(s) that the date was
missed. All other dates are to be used as milestones of performance toward the expeditious
finalization of this evaluation process. If however. EP A determines at any point during the
above schedule of-activities that the. proces's is not leading to an expeditious cleanup of the
site. EP A, after notification to and consultation with the State, may exercise itS authority
under CERCLA Section 121 to begin the capping alternative.
The outcome of this evaluation is intended to provide both EPA and the State of Utah with a
"market analysis" of the actUal costS to implement either the selected cap remedy or the
contingen6:Y offsite alternative. EP A will award the fmal contractS for Remedial Design and
Remedial Action based on contract requirementS detailed in the Federal Acquisition
RequirementS (FAR).
In summary. the contingency alternative has the following componentS:
.
Soil contaminated above action levels will be removed to a depth of two feet in
the former mill area (approximately 132.000 cubic yards), with placement of
this soil on the tailings pile. replacement of the excavated soil with clean fill.
LR SHNS OOl\RODIROD.2.FNL\l20993
-------
and revegetation of the excavated area. This will eliminate any physical
contact with contaminated soils in the former mill area.
.
The wetlands will be dredged to remove sediments (approximately 43,600
cubic yards) and the sediment will be placed on the existing pile. The
wetlands area will be restored to its natural state. This will prevent surface
water contamination and exposure of organisms to contaminated sediments.
.
The tailings on the west side of the Jordan River will be excavated and
stockpiled on the existing pile. This excavation will eliminate exposure to the
. contaminated tailirtgs.
.
Excavation with subsequent transpon of the existing tailings (9,022.300 cubic
yards), soils (1,266,000 cubic yards), and sediments from the site, and soils and
debris from OU2 (323,300 cubic yards) deposited on the site. Removal of the
contaminated soils and tailings will eliminate the threat of exposure to these
materials.
.
A groundwater monitoring system will be installed as described for the
preferred alternative. Action levels will also be the same as those described for
the preferred alternative.
.
The tailings and soils will be transponed to a State and EPA approved disposal
cell complying with EPA's offsite Disposal Rule and State landfIll
requirementS.
.
The materials will be deposited in the offsite disposal cell.
.
Once removal of tailings and contaminated soils is complete. clean fIll will be
brought in to replace the materials removed during excavation and the site will
be revegetated.
.
The new disposal cell will be covered and vegetated. The cell will be
maintained and the groundwater monitored as necessary, to ensure that
contaminants do not migrate and adversely impact the area surrounding the
cell.
.
Groundwater use resmctions will be implemented to prevent the installation of
groundwater wells onsite (other than those associated with this alternative).
These resmctions will prevent ingestion of possibly contaminated groundwater.
Estimated costs for the contingency alternative are provided in Table 18.
LR SHNS OOI\ROD'ROD-2.FNL\120993
70
. . -.-...-.--'-"- "..-...--. .. . .
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l'ABlE 16
Page 1
COST ESTIMATES FOR THE OUI CONTINGENCY ALTERNATIVE
PROJECT: SIIARON STEElIMlDVAlE TAILINGS SITE (OUI)
ALTERNATIVE 3: EXCAVATION (Revised 6/92)
ENR Averdge Construcllon Cosllndex
4890.83
DESCRIPTION: Excavallon 01 aU on-she contamlnaled malerlal & disposal al State
deslgneled cell within a 30 mile rddlu8 01 Sharon Sleel.
Groundwater conlrol wbh extracllon, use, and trealmen\.
DIRECT CAPITAL COSTS
(Indudes labor, Equipment & Materials, Unless Olhe/Wlse Noted)
UNIT TOTAL CAPITAL
COST COMPONENT UNIT QUANTITY COST COST
1. Cell Development
a. Cell Construction LS 1 $23,245,000 $23,246,000
b. 24" Vegetallon Layer CY 323000 $9 $2,942.630
c. Vegelallon AC 100 $664 $68.437
2. Weiland RemovelAeslore CY 43600 $11 $471,752
3. Groundwater
a. Groundwaler Exlracllon Wells EA 4 $18,000 $72.000
b. On-slle Treatment lS 1 $885.000 $885.000
...... c. PumpsIDlscharge 10 Jordan River lS 1 $397,400 $397,000
4. Slurry Mixing & Dewatering Facilities LS $27,700.000 $27,700.000
5. Slurry Pipeline Construcllon LF 158400 $291 $46,079,000
6. SlurrylWater Pumping Stallons EA 3 $776,100 $2.328.300
7. Revegelale She
a. 24. Vegetallon Layer CY 871200 $9 $7.927,920
b. Revegetation AC 270 $721 $194.670
-.-....--.......
TOTAL DIRECT CAPITAL COSTS $112,311.609
INDIRECT CAPITAL COSTS (% 01 direct capllal coslS)
1. Engineering & Design (15%) $16,847,000
2. Conllnglncy Allowance (15%) $16.847,000
3. Olher Indirect Cosls
A. Legal (5%) $5.616,000
B. Regulalory (5%) . $5,616.000
C. MoblllzallonlDemoblllzalion (10%) $11.231,000
....o............"
TOTAL INDIRECT CAPIT Al COSTS $56.157.000
TOTAL CAPITAL COSTS (DIRECT t INDIRECT) $168,468,809
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TABLE 18 (CONTINUED)
COST ESTIMATES FOR THE OUI CONTINGENCY ALTERNATIVE
Page 2
PROJECT: SHARON STEEUMIDVAlE TAILINGS SITE (OUI)
Al TERNATIVE 3 : EXCAVATION
DESCRIPTION: EKcavation 01 aU on-sne contaminated malerlal & disposal al Slate
deslgniJted cell wUhln a 30 mHe rddlus 01 Sharon Steel.
Groundwaler conlrol wnh eKlracllon, use, and treatment.
PRESENT WORTH
DIRECT ANNUAUPERIODIC COSTS DIRECT LIFE OF n-'''''''''''' ..................-....
QUANTITY UNIT ANNUAL ITEM ANNUAL PERIODIC
COST COMPONENT UNIT FREQUENCY (PER YEAR) COST COST YEARS COST COST Discount Rale ,,9"10 9.00"10
DIRECT ANNUAUPERIODIC COSTS
,. Dusl Conlrol during EKcavation lS ANNUAL $267,000 $267,000 8.6 $1,300,000 nla
2. Air Monnorlng
a. Air Sampling/Analysis EA QTlY 4 $2,580 $10,000 30 $100,000 nla
b. Air Monnor Slation
O&M EA WEEKLY 62 $420 $22,000 30 $200,000 nla
c. Replace Air Monnorlng EVERY
Equlpmenl EA 5 YEARS nla $81,600 nla 6 nla $101,000
--J 3. EKcavationlTransportlPlace CY ANNUAL 1630770 $3 $5,185,849 8.5 $24,700,000 nla
N
4. Siuny Pipeline O&M lS ANNUAL $1,843,160 $1,843,160 8.5 $8,800,000 nla
6. Groundwater
a. Replace Groundwater EA ONE EVERY $16,500 $16,500 30 $200,000 nla
EJdracilon Wells YEAR
b. Well O&M lS ANNUAL $40.000 $40,000 30 $411,000 nla
c. Treatment Planl O&M lS ANNUAL $88,500 $88,500 30 $900,000 nla
d. Replace Trealmenl Planl EVERY
EA 10 YEARS nla $885,000 nla 10 nla $532,000
.................. ................-... -.................
TOTAL DIRECT ANNUAL COSTS: $7,000,000
TOTAL PRESENT WORTH OF DIRECT ANNUAL COSTS: $37,000,000
TOTAL PRESENT WORTH OF DIRECT PERIODIC COSTS: $1,000,000
..............-......- .....................
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TABLE 16 (CONTINUED)
COST ESTIMATES FOR THE OUI CONTINGENCY ALTERNATIVE
PROJECT: SHARON STEEUMIDVAlE TAILINGS SITE (OUI)
ALTERNATIVE 3: EXCAVATION
DESCRIPTION: Excavation '01 all on-slle contaminated malerlal & disposal al State
designated cell within a 30 mila radius 01 Sharon Sleet
Groundwater control wllh exlractlon, use, and trealmenl.
COST COMPONENT'
QUANTITY
FREQUENCY (PER YEAR)
UNIT
COST
UNIT
tNDIRECT ANNUALIPERIODIC COSTS (% 01 Tolal Dlrecl Annual Costs):
Administration (10%)
a. Flrsl'6.4 Vears LS ANNUAL $733,000
b. lesl 23.6 Years LS ANNUAL $186,000
Maintenance Reserve &
Contingency Costs (25%)
B. Flrsl 6.6 Years LS ANNUAL 1 $1,632,000
b. Last 23.5 Years LS ANNUAL 1 . $465,000
TOTAL PRESENT WORTH OF INDIRECT ANNUALIPERIODIC COSTS:
--!
I..U
TOTAL PRESENT WORTH (Capllal t AnnuatlPerlodlc) COSTS:
TOTAL PRESENT WORTH COSTS PER ACRE (BASED UPON 270 ACRES)
DIRECT
ANNUAL
COST
$733,000
$186,000
$1,832,000
$465,000
LIFE OF ---_m""""
ITEM ANNUAL
YEARS COST
6.4
23.6
6.5
23.5
$3,453,000
$1,796,000
$6,730,000
$4,485,000
.....-............
Page 3
...............
PERIODIC
COST
Dlscounl Rale = 9%
900%
nla
nla
...............
$18,000,000
$224,000,000
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11.
PERFORMANCE STANDARDS
1"!1e Performance Standards presented below for the selected remedy have- been developed for
the various components of the remedy. These standards were developed to ensure attainment
of the remedial action objectives. More detailed standards addressing specific consttUction
and operating requirements will be developed during remedial design.
Excavation
Soils and tailings excavations will be guided by:
.
Volume identifications made in the FS.
.
Visual observations made during excavation. and
.
Verification sampling conducted during/following excavations to ensure that all
soils/tailings exhibiting contaminant concentrations above action levels have been
removed.
Verification sampling and analysis will be conducted according to an EPA-approved Sampling
and Analysis Plan.
Cappin~
If the selected remedy is implemented. cap design and consttUction must be approved by .
EP A. The cap will be designed to isolate the tailings; i.e.. to be a physical and hydraulic
barrier. The final cap must be designed in a manner which permits pedestrian access.
Potential land use options will be evaluated during design. Design. consttUction. maintenance
and monitoring of the cap will be conducted according to strict engineering standards
established during remedial design. Version 3.0 of ~l1e HELP model will be used during
detailed cap design to predict leachate generation and provide comparisons with estimates.
made in ~e FS. Regular inspections and maintenance will ensure the cap's integrity.
LR SHNS 001\ROOlROD-2.FNL\l20993
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Interceotor Trench
'Ihe interceptor trench is part of the selected remedy and will be designed to further
hydraulically isolate the tailings, thereby further reducing seepage out of the tailings into the
unconfmed upper sand and gavel aquifer. Design, construction, maintenance and monitoring
of the trench will be conducted according to strict engineering standards established during
remedial design, and must be approved by EP A.
Groundwater Monitorine: Svstem
The groundwater monitoring system is identical for both the selected remedy and contingency
alternatives. The purpose of the shallow groundwater monitoring system will be to ensure
that ARARs are not exceeded at the pointS of compliance in the upper sand and gravel
aquifer. This will in turn ensure that migration of contaminated groundwater is prevented
beyond the QUI boundary. If necessary, as triggered by exceedance of ARARs. extraction
and treatment of gro"undwater will be conducted. The goal of treatme~t will be to contain the
groundwater beneath the site and prevent migration beyond the OUI boundary.
The compliance point for the site will be defmed by shallow monitoring wells located along
the western and northern boundaries of the tailings. The wells will be designed to also
function as extraction wells should groundwater arsenic levels in the wells exceed ARARs.
necessitating pumping and treatment of groundwater.
Specific performance standards are as follows:
.
Based on monitoring at the western compliance point wells, groundwater in the
unconfined upper sand and gravel aquifer exhibiting arsenic levels greater than
the A WQC of 190 J.lg/L must not discharge to the Jordan River.
.
Based on monitoring at the northern compliance point wells groundwater in the
unconfined upper sand and gravel aquifer exhibiting arsenic concentrations
LR SHNS OOl\ROD'IROD-2.FNL\l20993
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greater than the MCL of 50 pg/L must not migrate beyond the OU 1
boundaries.
.
If these levels are exceeded (based on statistical evaluations and evaluations
conducted by EP A) a groundwater pump and treaunent system will be activated
to threat groundwater in the upper sand and gravel aquifer.
.
If extraction and treattnent are initiated, the goal is only to contain groundwater
and meet ARARs in the compliance point wells. The system will operate as
long as required .to contain contaminated groundwater in the unconfined upper
sand and gravel aquifer.
In the case of non-compliance with performance standards, EP A or the State may require the
implementation of more aggressive remedial measures.
Additional monitoring will be conducted of water levels and metals concentrations in the deep
principal aquifer, and in the unconfined upper sand and gravel aquifer at locations other than
the compliance point wells. Metals concentrations in the Jordan River will also be monitored.
Additional performance standards relative to this additional monitoring are as follows:
.
Based on water level monitoring in the deep principal aquifer, water levels
must not show a statistically significant decrease or a decrease in the average
water level of greater than 20 feet (a baseline level will be established during
design).
.
Based on water level monitoring in the unconfined upper sand and gravel
aquifer. water levels must not show a statistically significant increase beneath
the tailings on OU 1.
.
Based on water quality sampling, arsenic concentrations in the Jordan River
down gradient of the QUI site must not show a statistically significant increase
above levels up gradient oi the site.'
.
Based on groundwater monitoring and sampling in the unconfined upper sand
and gravel and deep principal aquifers (at locations other than the compliance
point wells), arsenic concentrations must not show a statistically significant
increase or an increase of more than 10 pg/L.
LR SHNS OOI\ROD'ROD-2.FNL\l20993
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.
If any of the above conditions are observed during monitoring af the site. a
reevaluation of site conditions will be conducted by EP A.
The details of the monitoring system will be developed during remedial design and will
include. at a minimum, the following: locations of compliance point and other monitoring
wells; frequency of monitoring of compliance point and other wells. analytical parameters.
sampling field .methods, water level measurement frequency, analytical methods for chemical
analysis, locations and methods for water level measurements, locations and methods for
surface water sampling, and statistical methods for evaluating the analytical data. All
monitoring will be conducted according to EPA-approved methods and procedures.
The 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:
.
Concentrations of arsenic in compliance point wells;
.
Distribution of contaminants in the unconfined upper sand and gravel aquifer and deep
principle aquifer and surface water,
.
Rate and direction of contaminant migration in the unconfined upper sand and gravel
aquifer.
.
Changes in contaminant concentrations or distribution within the aquifer sysrem over
time;
.
Changes in hydraulic gradients between the unconrmed upper sand and gravel and
deep principle aquifer over time;
.
Effects of any modifications to the original remedial action.
The groundwater at the compliance point wells will be monitored for contaminants throughout
the implementation of the remedy and until there is no longer a threat of offsite migration of
arsemc.
LR SHNS OOI\ROD'ROD-2.FNL\l20993
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DiSDOsal Cell
If- the contingency alternative is implemented. offsite disposal must comply with all local.
state, and federal regulations required as pan of CERCLA response action. The landfill site
must incorporate surface water run on/runoff control. leachate collection. impermeable liners
and dust control to prevent contaminant migration as needed to meet design specifications.
Details regarding the design. construction. maintenance. and monitoring of the cell will be
established during remedial design.
Institutional Controls
.
If the selected remedy is implemented. only structures determined to be suitable for
placement on the cap will. be permitted in order to prevent breaches in the integrity of
the cap and to ensure that erosion is prevented. The determination of the type and
number of structures will be finalized by EP A during design.
.
No domestic wells will be permitted onsite through deed restrictions to prevent any
ingestion of contaminated groundwater. This is a restriction which is regulated by the
Stare of Utah. Utah will retain final authority to 'restrict or appropriate groundwater
use at this site. .
12.
STATUTORY DETERMINATIONS
Under its legal authorities. EPA's primary responsibility at Superfund sites is to undenake
remedial actions that achieve protection of human health and the environment. In addition.
Section 121 of CERCLA establishes several other statutory requirementS and preferences.
These'specify that when complete. the selected remedial action for this site must comply with
applicable or relevant and appropriate environmental standards established under Federal and
State environmental laws unless a statutory waiver is justified. The selected remedy also
must be cost-effective and utilize permanent solutions and alternative treatment technologies
or resource recovery tecL;,')logies to the maximum extent practicable. Finally, the statute
includes a preference for remedies that employ treatment that permanently' and significantly
reduce the volume. toxicity, or mobility of hazardous wastes as their principal element. The
LR SllNS OOI\R0J:)'80D-2.FNL\l20993
78
-------
following sections discuss how the preferred and contingency alternatives meet these statutory
requirementS.
Protection of Human Health and the Environment
The selected remedy provides protection of human health and the environment by providing a
barrier between the tailings and contaminated soil, and the environment. Migration of tailings
particles to the air and the risk of inhalation of tailings dust by humans is therefore
minimized. Because the cap also reduces infiltration through the tailings, the leaching of
arsenic to the underlying groundwater aquifers will be limited. By containing and treating, if
necessary, contaminated groundwater, offsite risk to humans and the environment will be
minimized.
By removing the contaminated tailings and soils from the site to a State and EPA approved
disposal cell, and monitoring and, if necessary, treating the groundwater, the contingency
alternative provides protection of human health and the. environment. Direct.contact,
inhci.1ation. and groundwater ingestion risks at QU I will be eliminated by this remedial action.
In addition, the environmental migration routes of air, surface water, and groundwater would
be removed at QUI (the risks will need to managed at the new location).
Compliance with ARARs
The chemical-specific ARARs related to air, surface water and groundwater quality are
satisfied by the selected remedy because it minimizes dust generation, contact of surface and
subsurface infiltration and inflow with contaminated material. and leaching of arsenic to
groundwater and it contains contaminated groundwater and preventS offsite migration. As a
result, the health-based standards for exposure will be satisfied. Leaching of arsenic to
groundwater will be minimized by the cap construction by minimizing infiltration of
precipitation and rerouting of storrnwater runon. Action specific ARARs which will be
incorporated into the remedial design prevent discharge of contaminated materials and surface
LR SHNS OOI\ROD'&OD-2.FNL\120993
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water to the Jordan River. dust generation during site grading and cap construction. and will
meet standards for surface impoundment, groundwater protection. site cleanup and OSHA
r;quirementS. . The location and action specific ARARs will be addressed in the remedial
design for the selected remedy. Location specific requirementS include the evaluation of
impactS on floodplains and preservation of wetlands.
Appendix A provides a list of the ARARs and TBCs for the selected remedy. The
determination of whether State requirementS are more stringent than Federal requirementS has
not yet been made.
The chemical specific ARARs related to air and water quality will all be satisfied by the
contingency alternative because the contaminantS are removed from the site (some residual
contamination may remain in the groundwater beneath the excavated tailings). The health and
regulatory standards at the site also will be met. The landfill site selected by the State must
incorporate surface water ronon/runoff control. leachate collection. impermeable liners and
dust control. Disposal of the waste must comply with all local; State and Federal procedural
and substantive requirementS. regulations, and statutes required for disposal of mining waste
as a part of a CERCLA response action. The tailings are exempted by the Bevill Amendment
and thus do not require treatment before removal as specified in the Land Ban regulations.
Action specific ARARs will also be incorporated into the remedial design of the contingency
alternative. These include control of tailings and surface water discharge to the Jordan River.
dust generation from the tailings during excavation. and national and Utah standards for
.landfills. groundwater protection, site cleanup and OSHA requirementS. Location specific
ARARs will be satisfied during the remedial design of this alternative. Preservation of the
floodplain and wetlands will be incorporated into the excavation plans. and original contours
and wetlands acreage will be restored.
LR SHNS OOl\ROD'ROD-2.FNL\l2099'3
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Cost Effectiveness
~ased on analysis of costs, EP A has determined that the selected remedy would be the most
cost-effective, with the contingency alternative somewhat less cost-effective, but within an
order of magnitude of the cost of the selected remedy.
Utilization of Permanent Solutions and Alternative Treatment Technolo!!ies (or Resource
Recoverv TechnolOlries)
EP A has determined that the selected remedy represents the maximum extent to which
permanent solutions and tteatment technologies can be utilized in a cost-effective manner for
OUI at the Sharon Steel/Midvale Tailings site. Of those alternatives that are protective of
human health and the environment and comply with ARARs, EPA has detennined that this
remedy (Alternative 4 as selected remedy and Alternative 3 as contingency alternative)
provides the best balance in terms of long-term effectiveness and permanence; reduction in
toxicity, mobility or volume. achieved through tteatment; shon-term effectiveness:
irnplementability; and cost while also considering the statutory preference for tteatment as a
principal element and considering State and community acceptance.
The selected remedy (Alternative 4) would be designed to be a permanent solution. Regular
cap inspections, and groundwater monitoring and, if necessary, tteatment would ensure the
continued safety of the surrounding populations and the environment.
The contingency alternative (Alternative 3) would be a permanent measure as well since the
contaminated materials would be removed from the site. The approved disposal site will
satisfy all Federal, State, and local requirements, regulations, and statutes, and will be
considered a permanent disposal site.
LR SHNS OOt\ROD'ROD-2.FNL\120993
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Preference for Treatment as a Principal Element
Both the selected remedy and contingency alternative will include the treatment of
groundwater, if necessary, but not of contaminated soils or tailings which are the principal
threat.
Of the alternatives which were evaluated for the site, only Alternative 6 meets this
requirement. However, fixation would be difficult to implement due to the variable
characteristics of the waste. It is also cost-prohibitive.
Because treatment of the contaminated soils and tailings was not found to be practicable. the
selected remedy does not satisfy the statutory preference for treatment.
13.
DOCUMENT A TION OF SIGNIFICANT CHANGES
CERCLA Section 117(b) requires an explanation of any significant changes to the preferred
alternative as presented in the Proposed Plan which was availabl~ for public comment. There
were no significant changes.
LR SHNS 00 1\ROINWD-2.FNL\l20993
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GLOSSARY
Action Levels - Levels of contaminantS in soil, air. or water at which EP A believes a remedy
is necessary. Action levels vary from site to site and even within sires. based on potential
exposure.
Arsenic - A metal-like substance used in the manufacture of glass, metal alloys, and wood
preservatives. Arsenic also is used in insecticides and weed killers because it is highly toxic
to insectS and plantS. Arsenic occurs natura.lly, and has been found in sea water, spring
water. and in. association with mineral depositS of silver and antimony. Ingestion of arsenic at
high levels over an extended period of time may cause skin cancer.
Capital Costs - The labor, material. and equipment costS of construction associated with a
remedial alternative.
Capping - Covering contaminated soil with layers of barrier materials.
Carcinogen - A substance that increases the incidence of cancer.
Chronic Dailv Intake (CDI) - The average amount of a chemical in contact with an
individual on a daily basis over a substantial portion of a lifetime.
Chronic Exposure. - A persistent, recurring, or long-term exposure. Chronic exposure may
result in health effectS (such as cancer) that are delayed in onset, occurring long after
exposure ceased.
Contamination - Pollution of the natural environment.
Contingency Alternative - As used in this document. the contigency alternative is the
alternative to excavate, transport. and contain the tailings at an offsite location.
Dust Suppressant - A non-toxic chemical, such as a polymer coating, applied to a surface to
prevent the blowing of dust. .
Endangerment Assessment CEA) - A study conducted as pan of a Remedial Investigation
that describes the risks posed to public health and the environment at a Superfund site.
Exposure - The opportunity to receive a dose through direct contact with a chemical or
medium containing a chemical.
Exposure Assessment - The process of describing, for a population at risk. the amountS of
chemicals to which individuals are exposed. or the distribution of exposures within a
population. or the average exposure of an entire population.
LR SHNS OOI/GLOSSARY.TXT/I2D993IKV:sdb
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Exposure Pathway - The main route through which contamination may enter the body.
Inhalation. ingestion. and direct contact are three exposure pathways.
Fixation - A process of mixing the soil and a chemical agent together to immobilize the
spread of contamination.
Hazard Index (HU - An EP A method used to assess the potential noncarcinogenic risk. The
chronic daily intake (CD!. see defmition above) divided by the chronic reference dose (RID.
see defmition below) or other suitable toxicity value for noncarcinogens yields the hazard
mdex (HI). If this value is less than one. then the exposure represented by the CDI is judged
unlikely to produce an adverse noncarcinogenic effect. A cumulative. endpoint-specific HI
can also be calculated to evaluate the risks posed by exposure to more than one chemical by
summing the CDURfD ratios for all the chemicals of interest exen a similar effect on a
particular organ.
Institutional Controls - Rules. regulations. laws. or convenantS that may be necessary to
ensure the effectiveness of a cleanup alternative.
Groundwater - Water contained in sand, soil. rock. or gravel panicles beneath the earth's
surface. Rain that does not evaporate or immediately flow to rivers. streams, and lakes.
slowly seeps into the ground forming a groundwater reservoir. Typically, groundwater flows
more slowly than surface water, often along routes that lead to streams. rivers. and lakes.
Leach - The removal of soluble minerals caused by the percolation of water through soil and
tailings.
Lead - A metal used as a gasoline additive. in batteries. foil. solder. .and constrUction
equipment. In humans. lead is stored primarily in bones and teeth. Inhalation or ingestion of
lead may damage the central nervous system and affect a. child's ability to learn.
National Priorities List (NPL) - EPA's list of top priority hazardous substance sites that are
eligible for an investigation and cleanup under the Federal Superfund program.
Operable Unit (OU) - A term used to describe a specific portion of a Superfund site. An
operable unit may be established based on a panicular type of contamination. contaminated
media (e.g.. soils. warer). source of contamination. and/or geographical location.
Operation and Maintenance Costs - The annual costS of ensuring that a remedial alternative
is protective.
Present Worth - The amount of money required in taday's dollars to pay for the entire
remediation. through the life of the proje~t. Inflation is not included in the figure.
LR SHNS OOIiGLOSSARY.TXr/120993IKV:sdb
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Reference Dose (RID) - The EPA's preferred tOxicity value for evaluating noncarcinogenic
effects. The RID is the dose which an individual may be exposed to for a lifetime without
significant adverse health effects.
Remedial Action - Long-term cleanup of a Superfund site.
Remedhil Alternative - An option for addressing site contamination.
Remedial Desi2n - Development of detailed plans for cleaning up a hazardous waste site;
Remedial Design comes after a remedy has been selected and includes all details necessary to
construction of the remedy.
Remed~vesti2ationIF~tv Study (RI/FS) - Long-term study and identification of
cleanup alternatives at a Superfund site. The Remedial Investigation identifies the types.
locations, and quantities of hazardous wastes, and the Feasibility Study develops and
evaluates alternatives to clean the wastes up.
Residential Soils - Yards and other unpaved open areas within residential, business, and
, public properties in Midvale that were sampled during the Sharon Steel soils stUdy.
Risk - The nature and probability of occurrence of an unwanted, adverse effect on human life
or health, or on the environment
Risk Assessment (RA) - A baseline risk assessment provides an evaluation of the potential
threat to human health and the environment in the absence of any remedial action. It also
provides a point of reference for detennining whether or not remedial action is necessary and
the justification for performing remedial actions.
Sediment - Rock. sand. soil and decomposing animals and plants that settle to the bottom of
a wetland. stream. river, pond. or lake.
SUDerfund - A common name for the Fec;ieral program established by the Comprehensive
Environmental Response. Compensation, and Liability Act (CERCLA) of 1980. as amended
in 1986. EPA administers the Superfund program to study and clean up actual or potential
releases of hazardous substances from uncontrolled hazardous waste sites.
Surface Water - Standing or flowing water located on the ground surface. such as streams.
rivers. ponds, or lakes.
Tailin2S - A fine, sandy byproduct of ore milling operations. Tailings on the Sharon Steel
site contain high concentrations of finely ground metals such as lead and arsenic.
LR SHNS OOIlGLOSSARY,TXTIl20993IKV:sclb
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Ve2etated Soil Cap - A covering for contaminated tailings and soil with layers of barrier
materials that prevent water from reaching the contaminated materials. In the case of a
vegetative cap, the upper surface of the cap is planted with vegetation to stabilize the surface.
Wetlands - An area of land that is continually wet. such as a swamp or marsh. Wetlands are
very important habitats to many animals.
LR SHNS OOIIGLOSSARY.TXT/I20993IKV:sdb
86
-------
APPENDIX A
ARARs FOR THE
-------
APPENDIX A
ARARs FOR THE SELECTED REMEDY
~::::::::.:::: :
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National Primary Drinking Water Standards
National Secondary Drinking Water Standards
National Maximum Contaminant Level Goals
Utah Safe Drinking Water Act
Utah GroWldwater Protection Rules
National Clean Water Act Dredge and Fill Requirements
National Clean Water Act Ore Mining and Dressing Requirements
Utah Standards for Water Quality
Utah Pollution Discharge Elimination System
National Primary and Secondary Ambient Air Quality Standards
National Criteria for Classification of Solid Waste Disposal Facilities
National Standards for Transportation of Hazardous Waste
National Closure and Post Closure Standards for Hazardous Waste
National Waste Piles Standards
National Landfill Standards
National Guidelines for Land Disposal of Solid Waste
National Toxic Substances Control Act - AsbestOs
Utah Closure and Post Closure Standards for Hazardous Waste
Utah Waste Pile Standards
Utah Landfill Standards
Utah GroWldwater Protection Standards
Utah Corrective Action Cleanup Policy
National Occupational Safety and Health Act
Utah OSHA - Toxic and Hazardous Substances
Utah OSHA - Excavations. Trenching and Shoring
Utah OSHA - General
DOT Hazardous Material Transponation Act
National Fish and Wildlife Coordination Act
LR SHNS 00 1 lAP X-A. TBL/120993
"..'''..,',".
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R&A
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R&A
R&A
R&A
R&A
R&A
Applicable
R&A
R&A
R&A
R&A
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Applicable
Applicable
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Applicable
R&A
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APPENDIX A
ARARs FOR THE SELECTED REMEDY (continued)
I: . .. . , :.):;I:,~:~i\TU~;:::1
. .... ... ... ... ..
..... .. ..... . . .
.... ....... .... .
... .... . ,'..... '::::DESCRIPTION: ... ..
..'P.- ...,
..
Executive Order on Floodplains Management Applicable
Executive Order on Protection of Wetlands Applicable
Utah Well Drilling Regularions Applicable
Toxicological Profiles for Arsenic and Cadmium TBC
National Surface Mining and Reclamation Act R & A
Endangered Species Act Applicable
Notes:
R & A = Relevant & Applicable
TBC = To Be Considered
Specific citarions for these ARARs can be found in the Feasibility Study.
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EP A RESPONSE TO COMMENTS DOCUMENT
FOR
OPERABLE UNIT 1 (OUl)
OF THE
SHARON STEEL MIDV ALE T All..INGS
SUPERFUND SITE
MIDV ALE, UTAH
December 1993
Prepared for:
U.S. Environmental Protection Agency
Prepared by:
CDM Federal Programs Corporation
1626 Cole Blvd., Suite 100
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EP A RESPONSE TO COMMENTS DOCUMENT
FOR OPERABLE UNIT 1 (OU1) OF THE SHARON STEEL MIDYALE TAILINGS
SUPERFUND SITE
IN MillY ALE. UTAH
December 1993
TABLE OF CONTENTS
Section
1. Introduction
Pa!!e
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1
II.
Background on Recent Community Involvement. . . . . . . . . . . . . . . . . . . . . . . .
2
ill.
Background on Historical Community Involvement
.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ..
3
IV.
Community Concerns. . . . . '.' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5
Y.
Summary of CommentS Received During the Public Comment Periods. . . . . . . .. 9
A.
Local Community Concerns and Agency Responses. . . . . . . . . . . . . . . .. 9
1. Remedial Alternative Preferences. . . . . . . . . . . . . . . . . . . . . . . . . . .. 9
2. Cleanup Objectives. Permanence. and Protection. . . . . . . . . . . . . . .. 18
3. Cost Issues. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 21
4. Risk Assessment/Health Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 24
5. Remedial Design. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 26
6. Feasibility StudylProposed Plan. . . . . . . . . . . . . . . . . . . . . . . . . . ., 27
7. Land Use. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., 29
8. Public Participation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., 29
9. Reprocessing......................................... 30
10. Alternate PrGposals .................................... 31
B.
Legal and Technical Questions and Agency Responses. . . . . . . . . . . . .. 32
1. Long-Term Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 32
2. Cost Issues. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 35
3. LegalJRegulatOry/Compliance Issues. . . . . . . . . . . . . . . . . . . . . . . .. 39
4. Groundwater Issues. . . . . . . . . . . . . . . . . . . . . . . . . .' . . . . . . . . .. 44
5. Remedial InvestigationslFeasibility Studies. . . . . . . . . . . . . . . . . . .. 48
6. Remedial Design. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 54
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7. Alternative 4 -- Capping Issues. . . . . . . . . . . . . . . . . '.' . . .. . . . .. 56
8. Alternative 3 -- Excavationffransponation/Containment Technologies.. 63
8a General CommentS. . . . . . . . . . . . . . . . . . . . . . . . . . .. 63
8b Excavation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 68
8c Transponation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 70
8d Containment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 77
9. Fixation/Chemical Treatment and Vitrification. . . . . . . . . . . . . . . . .. 78
10. Reprocessing. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . ., 81
11. Alternate Proposals. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85
VI.
Remaining Concerns. . . . . . . . . .'. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 87
LR SHNS OOl\RESPONSE.FNL\120893
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I.
Introduction
'Phis Responsiveness Summary has been prepared as part of EPA's Record of Decision (ROD)
describing how contaminantS at the Sharon Steel (Midvale Tailings) Superfund site (Sharon
Steel site) will be remediated. This Responsiveness Summary serves several functions. It
provides the public and the d~cision-mak:ers with infonnation about what the community
thinks about EP A' s propos~d remedial action and other alternatives that were evaluated. In
addition. it documentS how EP A considered public commentS during the decision-making
process and describes how EP A has responded to major issues that have been raised at the
Sharon Steel site.
This Responsiveness Summary and the associated Record of Decision culminate eleven years
of study at the Sharon Steel site. which includes an abandoned milling operation and nearby
residential and business properties in Midvale. Utah. In 1989 the study was divided into tWO
separate "operable unitS" (QUs. or study areas) to facilitate site cleanup.
The focus of this document is QUI. QUI includes tWO componentS. the fonner mill site and
tailings; and soils from OD2 that will be excavated during the QU2 cleanup. OU2 consistS of
business and residential properties in areas that have been contaminated by materials from the
mill site. The cleanup phase of OU2 is being managed by the State of Utah and is
proceeding on a separate schedule from OU 1.
QUI has been the subject of three analyses by EPA to remediate the site. All three of these
analyses have resulted in an EP A recommendation to cap the tailings. In general. the
community and the State of Utah have opposed capping, With each successive analysis. EPA
has sought to work with the State and the community to develop a viable alternative that
would meet local needs and complies with the National Contingency Plan's nine criteria for
selecting a remedial action.
LR SHNS OOl\RESPONSE.FNL\l20893
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EP A believes that the cap meetS those criteria and has chosen the cap as the selected remedy.
In order to provide the State and community the opportUnity to enhance the remedy, a
contingency alternative consisting of removal and offsite disposal has also been designated.
This document describes community concerns about EPA's proposal and EPA's response to
those concerns. This document includes the following sections:
.
Background on Recent Community Involvement
.
Background on Historical Community Involvement
.
Community Concerns
.
Summary of CommentS Received During the Public Comment Period and Agency
Responses
Part A: Summary and Response to Local Community Concerns
Part B: Comprehensive Response to Specific Legal and Technical Questions
.
Remaining Concerns
.
Attachmeilt: Community Relations Activities
n.
Background on Recent Community Involvement
The most recent of the three OU 1 analyses conducted by EP A concluded in 1992 when EP A
published a Proposed Plan that described both EPA's and the State's preferred alternatives to
clean up to the mill site. Subsequently, EPA held a comment period and encouraged
interested parties to comment.
The OUI Proposed Plan published in June 1992 describes tWo protective approaches to
solving the tailings problem on OUI. One approach was proposed by EPA and the other by
the State.
EP A . s ProDosal: EP A proposed capping the tailings and treating the groundwater to prevent
migration of contamination from OUI. This cap is markedly different from caps previously
LR SHNS 001\RESPONSE.FNL\120893
2
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proposed by EPA for the following reasons. The newly proposed cap would consist of a 5-
foot soil cap (or design-based equivalent), thicker than previously proposed. that would cover
the tailings. Once constructed, native plantS would be grown over the cap. Pedestrian access
to the site would not be restricted; however, some land use restrictions would apply. Storm
water run-off would be divened from the site through a drainage system. Arsenic
concentrations in the groundwater would be monitored and treated, if necessary, to prevent
migration of contaminantS. In addItion, contaminated sedimentS from wetlands near the river
would be excavated and incorporated into the tailings prior to capping. Tailings would be
moved 150 feet back from the centerline of the Jordan River to create a buffer zone from the
nver. Construction of this cap could be completed in two years.
State of Utah's Proposal: As an alternative, the State proposed to evaluate whether it could
find a location outSide of Midvale to which the tailings could be moved. EP A and the State
agreed that if an alternative site were found it would need to meet stringent environmental
and other regulatory criteria. It would also need to be acceptable to the citizens of affected
communities, both Midvale and any communities near, or enroute, between the new location
and Midvale. If an alternative location were found, the cleanup would consist of removing
the contaminated materials from the Sharon Steel OUI mill site and transporting them to an
approved landfill that would be constructed at the new location.
Public p-eaction to EPA's and the State's June 1992 Proposals: During the 1992 comment
period, the community generally expressed suppon for having the State investigate the
possibility of moving the tailings to a new location.
Ill.
Background on Historical Community Involvement
The Sharon Steel site is located in Midvale, Utah, approximately 12 miles south of Salt Lake
City. The 270-acre mill site was used by an ore refining company from 1906 to 1971. The
OUI are:: is gene:ally borcered by 7800 South Street on the nonh. by Main Street (750) West
on the east, and the Jordan River on the west and the south. During milling activities. metals
LR SHNS OOl\RE.SPONSE.FNL\120893
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such as lead. copper. and zinc were removed from crushed ore. EP A estimates that
approximately 9 million cubic yards of sand-like tailings remain on the mill site as a result of
ote processing activities.
Interest in the Sharon Steel site dates to 1982 when health officials learned that some Midvale
residents were using windblown tailings from the site in sandboxes and gardens. Samples of
the material were analyzed and found to contain elevated levels of lead. arsenic. cadmium.
and other metals. Funher study showed that these materials had contaminated the soil. air.
and ground water in the Midvale area. EP A prepared a Risk Assessment in which population
statistics and lifestyles of individuals living in the area were analyzed to evaluate potential
risks to human health. EPA and the State concluded that the site should be cleaned up to
reduce risks to human health and the environment from these contaminants. In 1984 EP A
proposed that the Sharon Steel (Midvale Tailings) site be added to the National Priorities List
(NFL) of sites to be cleaned up.
Since 1985, EPA and the State have followed State and Federal environmental requirements
and have analyzed the environmental conditions on and surrounding the site: Their findings
have been presented to local officials and members of the community on a regular basis. In
1990. EP A officially listed the entire site. including neighboring properties. on the NFL.
Since 1990 EPA has proposed cleanup alternatives for OUI to the State and the community
on three separate occasions. Each time. EP A has received substantial feedback that has
caused the Agency to change its course of action in response to suggestions from the
community. After responding to requests from citizens to conduct more extensive evaluations
of OUI site conditions and other alternatives. EPA believes that the currently proposed five-
foot cap would be protective of human he:lith and the environment and meet local needs in a
cost-effective manner. EPA also believes that it is important to get the. cap built so that
migration of contaminants from OUI is curtailed as soon as possible.
LR SHNS OOl\RESPONSE.FNL\l20893
4
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IV.
Community Concerns
Elected officials representing the S tate of Utah and the City of Midvale. in addition to
Midvale citizens, the Utah Department of Environmental Quality (UDEQ), and other
organizations. have repeatedly expressed opposition to the placement of a cap over the mill
tailings at the Sharon Steel site.
The most frequently mentioned reasons include concerns about risks the tailings pose to
human health and the environment; the ability of a cap to protect both surface water and
groundwater. interest in reprocessing the tailings as a remediation method; concern about
eventual cap deterioration; confusion and doubt over ~hether the tailings actually pose risks;
and a concern about curtailing future land use options and thus. negatively impacting property
values and the tax base.
In addition. there also appears to be a high degree of frustration that in the eleven years since
the State first investigated health concerns associated with OUl, a solution to the tailings
. problem has not been identified and visibly acted upon. Nearby residents want to know
whether their health, and the health of their children, is in jeopardy and if so. what protective
measures should be taken, for how long, and when they will begin.
These concerns and EP A's response to them are described below.
(1)
The citizens of Midvale have expressed concern that the tailings present a risk to
human health and the environment.
EP A Response
Like the citizens of Midvale. EP A is concerned with protecting human health and the
environment in and around Midvale from risks associated with the Sharon Steel OUI
$ite. Based on the results of both State and EP A studies. EP A believes there are
legitimate scientific concerns about the potential risks the tailings pose to human
LR SHNS OOl\RESPONSE.FNL\120893
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health and the environment. Consequently, EP A listed the site on the NFL. and has
selected a cleanup method it believes will be protective of both human health and the
environment. In selecting the cap, EP A believes that potential migration of
contaminantS from the tailings will be sufficiently restricted so that futUI'e risks to
human health arid the environment will be alleviated. In addition, EPA and the State
have agreed in principle to a contingency plan which would allow ~e S~te to enhance
the remedy and select a remedial action consisting of removal and offsite disposal, if
appropriate.
(2)
The citizens of Midvale and the State have expressed concern about the ability of a
cap to protect both surface water and groundwater.
EP A Response
In 1989, in response to State and community concern over EPA's preferred alternative,
a low permeability cap, EPA divided the Sharon Steel Superfund site into tWO
operable unitS. This decision allowed EP A to study groundwater and surface water in
the vicinity of QUI in greater detail while it proceeded with study and cleanup of
residential and business properties. At that time, EP A also revised the Community
Relations Plan, set up a technical review committee, initiated periodic public forums to
keep citizens informed, and prepared and distributed a fact sheet on lead and arsenic.
These actions were taken to enable EP A to funher explore and respond to the
community's concerns about the level of protection a cap could provide.
(3)
Area residentS have expressed the desire to see the ~gs reprocessed. both to reduce
the volume and toxicity, and to produce additional income generating opportunities for
local entrepreneurs.
EP A Response
In late 1989. EP A issued a request for proposals (RFP) for the reprocessing of tailings
at the Sharon Steel site. Nine interested parties responded with proposals. EP A and
LR SHNS OOI\RE.SPONSE.FNL\1:OS93
6
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the U.S. Bureau of Mines (BOM) evaluated these proposals. but none met the criteria
requested by EP A in the RFP.
(4)
Area residentS questioned whether the reprocessing proposals were evaluated fully and
fairly.
EP A Response
In March of 1990, EPA issued a Project Starns Repon that briefly discussed the starns
of the reprocessing proposals submitted to EPA in February. In May, EPA held a
public forum during which it provided a brief update on the reprocessing proposals.
At that forum. EPA indicated that it had asked BOM to assist in the evaluation. EPA
selected BOM to conduct the evaluation because of itS extensive mining expertise, and
in recognition of the imponance of having a third party evaluate the reprocessing
proposals. After determining that none of the proposals adequately responded to the
criteria that had been laid out in the request for proposals.. and in response to
continuing public interest in the feasibility. of reprocessing as a potential cleanup
method, EP A contracted with BOM in f991 to conduct a beneficiation study to
determine whether beneficiation could refme the tailings sufficiently to be reprocessed
and meet environmental requirementS. In May 1992, EP A held a public forum in
Midvale at which BOM presented itS conclusion that beneficiation is not advisable
from an environmental compliance and regulatory perspective. A copy of the BOM
srndy and itS conclusions is available for public review in each Sharon Steel
information repository.
(5)
Citizens have expressed the concern that a cap may eventually deteriorate and would
therefore not be a permanent solution.
LR SHNS OOl\RESPONSE.FNL\120893
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EP A Response
The cap will require the state of Utah to provide and assure maintenance. This
assurance is statutorily required of each remedy which uses Superfund Trust Fund
dollars to implement the remedy.
(6)
Because no remedy has been put in place yet. and citizens have been told there may
be a risk. some citizens have expressed confusion over whether human health is still at
risk. They have asked what protective measures should be taken and for how long.
EP A Response
There is still risk posed by the uncontrolled tailings. Following remediation these
risks will be largely removed.
(7)
Midvale citizens have expressed an interest in bringing the cleanup to a final
resolution and in getting the job over and done with so the community will no longer
have to experience the economic stigma associated with having an NPL site in itS back
yard.
EP A Response
EP A, by selecting this remedy and implementing it, will be able to remove the NPL
"stigma" because the site can proceed to be delisted from the NPL once the remedy is
completed.
(8)
Midvale citizens have expressed concern that the use of a cap will limit future land
use options and will also limit the community's tax base.
EP A Response
EP A believes that the cap will provide ~.!bstantial. though not unrestricted land use.
The ta."( base is :::1 issue outside of EPA's direct involvement at the Sharon Steel site.
LR SHNS OOI\RESPONSE.?IL\J20893
8
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The selected remedy will provide appropriate land use. There has been some interest
in use of the site as a park.
v.
Summary of Comments Received During the Public Comment Periods
This Responsiveness Summary was prepared in the summer of 1993 and contains comments
received during three comment periods that have been conducted on OU 1. Comment. periods
were held on the Proposed Plans that were published in July 1989, October 1990 and June
1992. During each of the three comment periods, members of the public and public officials
raised issues that EP A considered before selecting the five-foot cap. Comments received
during the comment periods are summarized below. Part A. Local Community Concerns
and Agency Responses, addresses community concerns and comments that are non-technical
in nature. Part B. Legal and Technical Questions and Agency Responses, provides
responses to specific legal and technical comments. Comments in each pan are categorized
by topic.
Part A.
Local Community Concerns and Agency Responses
1. Remedial Alternative Preferences
Comment 1
UDEQ, a number of Midvale residents, the Mayor and City Council. a representative
from the Salt Lake Community Action Program, former Congressman Owens,
engineers with a remediation company, and the Midvale Citizens' Group all expressed
opposition to capping. The most frequently mentioned reasons were: lack of long-
term solutions and permanence: concern about surface water protection: concern about
groundwater quality and protection of drinking water for 450,000 valley residents:
concern about strong seismic potential in the area: concern about eventUal cap
deterioration: futt!re land use options: and concern about overall protection of public
LR SHNS 001\RE.SPONSE.FNL\l20893
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health and the environment. Mayor Dahl reaffIrmed the Midvale City Council's
decision of June 1992, to reject a cap in any form. [June 92. August 92]
EP A Respanse
EP A believes that the selected capping alternative addresses the concerns raised. A
properly maintained cap will permanently prevent migration of the tailings and provide
overall protection of public health and the environment. Surface water will be
diverted and controlled to prevent erosion of the cap, and contaminated groundwater.
if found to be migrating in the future, will be prevented from migrating off-site
through the use of a pump and treat system. The cap will be engineered to withstand
seismic disturbances to the extent possible and several future land use options will be
possible.
Comment 2
In written comment. Mayor Dahl summarized some of his concerns by saying that if
the materials on the site are contaminated. then they must be removed or rendered
harmless to humans or the environment. The Mayor stated his belief that capping
would not accomplish this objective and thus should be discarded as a viable
alternative. [August 92]
EP A Response
In the June 1992 QUI Proposed Plan, EPA recommended the construction of a fIve
foot thick multi-layer cap over the tailings. This cap would eliminate the potential for
dispersion of contaminated tailings caused by blowing dust, as well as contact with the
tailings by people. plants and animals. The selected remedy would monitor arsenic
concentrations in the groundwater and prevent migration of contaminated groundwater
outside of QU I boundaries through the use of a pump and treat system. if needed.
In
addition, institUtional controls would limit construction of drinkin~ water wells on the
OUI site. It is EPA's opinion that the selected capping alternative would protect
public health and groundwater that is used for drinking water, would pennit
LR SHNS OOI\RESPONSE.FNL\l20893
10
. ~ 4 ..
-------
appropriate. land use on and around the QUI site. and would be designed to be a
permanent solution. EP A is confident that the selected remedy complies with
CERCLA and the regulations.
Comment 3
UDEQ expressed disagreement with EPA's characterization of groundwater
contamination in the FS and stated that because of differing characterizations of
groundwater, the State could not agree that capping would protect the groundwater.
[June 90]
EP A Response
The purpose of capping is to limit additional recharge to the tailings and subsequent
leakage to the upper sand and gravel aquifer. The upper sand and gravel aquifer
would be monitored, and a groundwater pump and treat system would be
implemented, if needed. to prevent migration of contaminantS in groundwater outSide
the QUI boundaries.
Comment 4
The General Manager of the Salt Lake County Water Conservancy District expressed
his opinion that capping sufficiently addresses the problem of airborne contaminantS
but indicated that more could be done to reduce groundwater contamination. He stated
that groundwater should be treated for lead. arsenic. and other contaminantS leaching
from the tailings. [November 90]
EP A Response
The proposed capping alternative includes a provision for pumping and treating the
groundwater to :prevent migration of contaminantS in groundwater outSide the QUI
boundaries if monitOring shows that contaminantS will migrate offsite above cleanup
standards.
LR SHNS 001\RESPONSE.FNL\12D893
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Comment 5
A remediation company stated' its opinion that capping is not a cure because it would
not prevent metals or other contaminants from migrating to other places. [August 92]
EP A Response
One objective of the cap is to minimize additional recharge to the tailings. A
groundwater pump and treat system will be used to prevent migration of contaminants
above the cleanup standards away from the OUI boundaries.
Commeiu 6
A remediation company stateq its opinion that capping would work only if: 1) no
eanhquakes would ever occur that would cause a 10ss of the cap integrity; 2)
groundwater could be prevented from moving under and through the capped material: '
3) the environment under the cap would remain constant throughout eternity: 4) no
further needs or changes would occur for the inundated lands: 5) the river would never
undercut the tailings pile during flood stages; 6) the soil was uniform in stratigraphy
assuring uniformity for capping; 7) no chemicals such as lawn or garden fertilizers
could migrate with the groundwater through the site soils; and 8) EP A could assure
that none of the above situations would ever occur.
EP A Response
While it is true that capping of the site will only be effective if none of the above
sitUations occur, the same can be said for all but the most extreme alternatives. such as
in-situ vitrification, which still could be affected by a severe seismic event. The
capping alternative will be designed to withstand seismic activity. The capping design
is predicated upon reducing the infiltration of surface water into the area of
contamination. The soils used in the constrUction of the cap would be controlled for
uniformity.
LR SHNS OOl\Rf.SPO:-ISE.FNL\1;:0893
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It is true that the capping alternative is based upon the assumptions that the
environment under the cap will remain constant These assumptions are made for all
of the alternatives. The design of a cap would include bank stabilization. flood control
along the Jordan River. and regrading of the river banks. The groundwater will be
constantly monitored and contaminated groundwater would be prevented from
migrating away from QUI site boundaries through the use of a pump and treat system.
if necessary.
Comment 7
A remediation company stated its opinion that simply closing the site. imposing
institUtional controls. and/or performing monitoring are not viable solutions. especially
when other solutions are available. [August 92]
EP A Response
EPA agrees with this conunent That is why the No Further Action (Alternative #1)
- and institUtional/Site Controls (Alternative #2) were rejected. In addition to
institutional controls and monitoring, EPA's selected remedy is to- cap the site and
control migration of contaminated groundwater. if necessary. This combination of
actions would most successfully fulf'ill the nine criteria established by CERCLA. when
evaluated against the other proposed alternatives.
Comment 8
Former Congressman Owens urged EP A not to select capping, limited site control
measures. or no funher action as the remedy for the site. citing lack of protection of
human health and the environment Mr. Owens stated his preference for excavation.
transpo~ and containment as an alternative more protective of human health and the
environment Former Congressman Owens questioned EP A as to why chemical
treatment of the tailings was not considered as a fmal alternative. especially since in
his opinion. this process could provide a cost-effective and permanent remedy. [July
92]
LR .:."HNS OOI\RESPONSE.FNL\l20893
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EP A Response
Limited site control and no funher action were not selected as remedies for the site.
The proposed capping alternative. which includes possible groundwater treatment and
other measures. was chosen as the selected remedy. EP A selected this alternative
because. in its opinion. it provides the most effective achievement of all nine
CERCLA criteria for remedy selection. The only chemical treatment of the tailings
that is remotely feasible is beneficiation and subsequent reprocessing. A 1991
beneficiation study performed by the U.S. Bureau of Mines on the Sharon Steel
tailings detennined that this method would still leave a significant quantity of highly
contaminated waste which would then require disposal.
Comment 9
After studying the FS, UDEQ commented that in its opinion the excavation.
transportation. and containment alternative would be the most protective of human
health and the environment and provide the highest long-term effectiveness and
permanence by eliminating direct contact and migration routes of surface water to
groundwater. [August 92]
EP A Response
The construction of a five foot multi-layer cap (or design-based equivalent) would
effectively prevent surface water from migrating through the tailings and leaching
contaminants into the groundwater. Other modifications will divert stonnwater from
reaching the tailings pile. Excavation, transportation. and containment is not a risk
free alternative. There is a potential that an uncontrolled spill of significant magnitude
could occur during transport of the tailings. Also, a repository that is reasonably
located and acceptable to the public has to be found if the tailings are to be moved. If
an alternate site is located, a landfill will need to be constructed before the tailings are
moved to protect against contaminant .nigration. A cap would also be necessary.
Such a landfill would require maintenance and monitoring throughout its life.
LR SHl'iS 001\RESPONSE.FNL\120893
14
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Conunent 10
A remediation company stated its opinion that the work done in preparing the latest
feasibility study for Alternative 3 appeared to be entirely generic. and made
assumptions of methods. machinery, and costs based upon non-site-specific criteria.
This company indicates that it conducted its own FS and researched and developed
cost estimates for specific machinery, methods, sizes. project duration. rights-of-way,
and locations. The company indicates that it employed and retained experts with local
knowledge and understanding to conduct studies and research. to complete engineering.
feasibility investigations. to make assessments of human health and environmental
impacts, to arrange for specific transportation corridors, to reserve an appropriate
repository site. and to prepare detailed, item-by-item cost estimates. The company
believes this higher degree of detail provides a more accurate indication of the true
cost of an excavation. transportation, and placement alternative. [August 92]
EP A Response
The purpose of EP A's FS was to .fIrst identify all possible methods to remediate the
contamination. The identified methods were screened and those not meeting the
applicable criteria were eliminated from further consideration. The remaining methods
were combined into alternatives which were then analyzed. The purpose of the.
analysis was to compare the ability of the alternatives to meet the nine CERCLA
criteria. EP A follows federally prescribed guidelines for preparation of an FS. These
guidelines do not provide for the level of detail described by the conunenter. Many of
the details suggested by the cornrnenter will not be finalized until the Remedial Design
stage.
Conunent 11
A Midvale citizen stated that while the excavation and disposal alternative was
proposed to cost $224 million .and capping was proposed to cost $54 million, the
health hazard posed by the tailings justifIed spending available money for excavation
and transport. [June 92]
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EP A Response
Based on the results of the FS. EP A has determined that the proposed capping
alternative provides protection of human health and the environment.
Comment 12
A Murray resident and candidate for the State legislature representing the nonh side of
Midvale stated his familiarity with moving tailings by rail at the Vitro site. He noted
the time and cost effectiveness of such a process and requested that EP A reconsider a
transpon proposal like the Peterson/Fitzgerald alternate proposal. He stated that the
3D-mile transportation and relocation limit seemed arbitrary and shon-sighted. and
further expressed his disapproval of capping as an alternative that would provide long-
term solutions. [June 92]
EP A Response
To date, EPA has not received the Peterson/Fitzgerald alternate proposal and therefore
cannot make any judgement as to its validity. Transportation of the tailings by rail
may be economical if a rail line eXists from the existing site to the alternate disposal
site. The tailings could be loaded directly onto the existing rail line at OU 1.
However, costs for construction of a rail line to a new site would be very high. An
alternative would be to truck the tailings from the closest point of the existing rail line
to the alternate site. The cost of unloading the tailings from rail cars and loading
.
trucks would also be significant. Because of cost and technology constraints. EP A has
recommended that the S tate identify an alternate site within a 30 mile radius of
Midvale. At this distance all three transportation options are technologically feasible
and thus their costs and other variables can be compared on a relative basis. The 30
mile radius also makes sense considering the geography of the area, the Great Salt
Lake to the nonh and mountains east and west.
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Comment 13
A West Jordan resident stated that the tailings should be removed and that IRC. a
remediation company. should perform the excavation and cleanup. [August 92]
EP A Response
EP A evaluated removal and disposal of the tailings at a different location and found.
that this remedy is not the best based on the National Contingency Plan (NCP) nine
criteria. Also, it is not the purpose of the FS to select the remediation conn-actor.
Comment 14
Mayor Dahl noted EPA's progress in its cap design from what he described as the
original "moonscape", to the cap that was proposed in June 1992 that would have
more land use options such as a park or golf course. He proceeded. however. to
reaffirm the Midvale City Council's decision of June 16, 1992~ to reject a cap in any
form; citing concerns about permanence, groundwater protection during an earthquake,
and potential drinking water contamination. The Mayor was joined in this opinion by
UDEQ, former Congressman Owens. the Midvale Citizens' Group, a number of
Midvale residents. and a Salt Lake Community Action Program representative. Lack
of provision of appropriate land use was also cited by these parties as an additional
failure of the capping proposal. [June 92]
EP A Response
The capping alternative. as proposed in the FS, addresses all risks posed by OU 1. The
cap prevents migration of contaminants due to wind and water caused attrition of
tailings from the site. thereby mitigating human health risks from ingestion and
inhalation. and environmental risks to air quality, surface water, and
groundwater/drinking water supplies. The installation of the cap and associated
surface and subsurface water inflow conn-ols funher reduce the inf1ltration of water
into the tailings and consequent leaching into the groundwater. If necessary, a
groundwater pump and n-eat system would prevent contamination from migrating
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outSide the OU1 boundaries. Slope stabilization of the tailings along the Jordan River
preventS the migration of tailings into surface water.
Land use is not one of the nine criteria the EPA must use by law, to select a remedy;
however, the Agency has considered land use desires in selecting a remedy.
2.
Cleanup Objectives, Permanence, and Protection
Comment 15
UDEQ reiterated the cleanup objectives stated by Governor Bangener three years ago:
permanence. appropriate land use. protection of public health. and protection of the
environment (which includes groundwater issues). The Salt Lake County Board of
Commissioners stated these same concerns, adding that the capping proposal did not
meet these criteria. UDEQ funher stressed that any solution selected must be
permanent. no matter what the cost, and must be acceptable to the people of Midvale
and to the State of Utah. [June 92]
EP A Response
The capping proposal does meet all three of the Governor's objectives. The cap will
be designed for a 30 year life. The life of the cap can be extended by proper
maintenance and repair. Within the 30 years. it is quite possible that new, more
effective technology will emerge. As stated in the response to Comment 14. it is not
the mandate of EP A to consider land use in the CERCLA process other than for risk
assessment purposes. EP A has agreed to design a cap such that the remediated area
can be used as a park or golf course and provide space for the Jordan River Parkway.
The capping alternative provides protection of human health and the environment.
The tailings will be isolated such that risk of contact will not be a concern. The
groundwater will be protected ay reduction of infiltration. and pumping and treating of
contaminated groundwater, if necessary, to prevent migration of contaminated
groundwater beyond the OU1 boundaries.
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Comment 16
Former Congressman Owens submitted a statement at the public meeting expressing
appreciation of EPA's willingness to listen and respond to concerns about the Sharon
Steel site, but further expressing total dissatisfaction with EPA's selection of capping
as the proposed alternative. Citing cost bias, earthquake hazards. groundwater quality.
the already-contaminated Jordan River, cap deterioration, and what he believes to be
an overall lack of protection of public health and the environment. Mr. Owens' stated
his opinion that EPA had shirked its duties and had flagrantly ignored Congress's
Superfund directive to find a permanent solution for OU1. [June 92]
Comment 17
Via written comment, former Congressman Owens reaffmned his opposition to
capping by stating that he would introduce legislation that would prevent EP A from
selecting capping as a remedy for a Superfund site unless cenain soil and groundwater
cleanup levels had been reached. He urged Midvale residents to make their views
known. [June 92]
Comment 18
A representative of the Midvale Citizens' Group stated the group's desire to be part of
a cooperative solution and reiterated the Mayor's and Governor's positions in seeking
a permanent solution. He stated disagreement, however. with the protective quality
comparisons made betWeen the capping and excavation and transpon alternatives as
noted on page 7 of the Proposed Plan. [June 92]
EPA Response to Comments 16. 17. 18
The proposed plan rates both the capping and the excavation and disposal alternatives
as equally protective of human health and the environment. Overall protecTIon of
human health and the environment addresses whether or not a remedy is protective
and describes how risks posed through each pathway are eliminated, reduced, or
controlled through treatment engineering controls or institutional controls. Neither
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alternative tteatS the tailings or alters them in any way such that the potential risk is
eliminated. They both however. adequately reduce the risk through use of engineering
conttols such as capping and groundwater monitoring.
Comment 19
An OU2 commenter and a PRP stated that the approach used for setting cleanup goals
for OUI must be more clearly developed. In addition. they thought that EPA should
state more clearly what significant differences distinguish off-site disposal at the
Sharon Steel site from the Vitto site. [September 90]
EP A Response
Cleanup goals for OUI were developed following EPA guidelines. A number of
differences exist between. the Vitto site and the Sharon Steel site. First. the Vitto
tailings were radioactive and thus posed a different health risk. The on-site capping
alternative for the Vitto tailings would have included the placement of a liner under
the tailings. This was needed due to the radioactive narure of the tailings. Also. the
integrity of the disposal cell was questionable due to the potential for differential
settling below the tailings. All these factors conttibuted to the selection of removal as
the preferred alternative at the Vitro site.
Comment 20
A commenter quoted a recent U.S. Science Advisory Board report stating that EPA
should give more emphasis to permanent remediation technologies that desttoy.
detoxify, or recover contaminantS. The commenter added that the repon also sttessed
that once interim remedial measures were taken to mitigate immediate risks. final
action should be withheld until permanent solutions were available at reasonable costS.
[January 91]
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EP A Response
While it is true that a CERCLNSARA statutory emphasis towards treattnent or "truly
permanent remediation technologies" existS. all alternatives. whether they involve
treattnent. off-site disposal. containment (such as the cap proposed for this site). or any
other technology, must be evaluated using the same nine NCP criteria. All of the
alternatives were evaluated in this manner, and the capping alternative was selected
based on itS performance against these criteria. The capping alternative allows for
future recovery of the waste should a permanent solution at a reasonable cost become
available.
Comment 21
One individual at the 1991 public meeting maintained that the tailings issue had been
around since 1986 and asked why it was taking so long to address. [September 90]
EP A Response
EP A has taken. the additional time to research, study and determine that the capping
proposal is a protective remedy, as requested by the public, elected officials and
UDEQ. This has also provided UDEQ time to conduct itS own stUdy on offsite
dispoSal.
3.
Cost Issues
Comment 22
Noting 38-52% fluctUations in cleanup cost estimates from January ~.991 to June 1992
on what the commenter believes to be basically the same proposal. a representative of
a Midvale Citizens' Group expressed deep concern about the assumptions upon which
EP A based itS cost estimates; especially since cost was a determining factor in the
selection of the final remedy. A similar concern was expressed by a remediation
company which stGted that in itS opinion, the $168 million estimated by EPA for
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excavation. transpon. and containment was overstated by at least $80 million.
[June 92]
EP A Response
It is true that the reponed estimated costs for the proposed remediation alternatives
differ betWeen the 1990 and 1992 feasibility studies. New information was made
available and changes were made that significantly affected the cost estimates. First.
the U.S. Bureau of Mines completed its repon on beneficiation which included a
detailed analysis of the quantity of tailings stOred on OU1. This new volume was
significantly lower than previous estimates. Also, the demolition of the mill buildings
was removed as part of the alternatives and has been performed as a separate function.
A factor that caused the cost to increase was higher labor wage rates and workmen' s
compensation rates. Specific changes were made to the June 1992 Alternative #3
Excavationffransponation/ Containment. They included different methods of
excavation and transportation and a shoner haul distance.
Comment 23
UDEQ noted the nmowing gap betWeen the changing price estimates for capping and
excavation/removal over the last three years. UDEQ expressed the opinion that as the
proposed costs become more realistic. it would probably end up being less expensive
to move the tailings than to cap them. [June 92]
EP A Response
UDEQ now agrees with EP A that the cost for excavation of the tailings will never be
lower than the cost for capping. Both alternatives will require some form of capping.
The removal alternative will have the additional expense of excavation and transpon
of the contaminated soils and tailings.
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Comment 24
Given the $62 million collected from the PRPs that is earning interest. Mayor Dahl
commented that slurry cranspon of tailings (plus the slag from another Superfund site.
the Midvale slag site) to Cedar Valley. for the proposed $33 million, or to the
causeway in Great Salt Lake, for $68 million. should be possible without tapping into
taxpayer monies. [June 92]
EP A Response
The costS quoted by the Mayor are based on proposals submitted by private groups.
These are significantly below estimates prepared by EP A. Major factors that resulted
in these low estimates include the fact that the cost cited by the private groups did not
consider all cost items. All, funds from the PRP settlement will be exhausted prior to
using other monies to fund the proposed remedy.
Comment 25
The Mayor stated that since Midvale was not privy to the negotiations that allowed for
a settlement ~hereby the PRPs only partially paid for proper remediatiqn of the OUI
area. and did not have to remove the contaminated materials. then the parties that
accepted the PRP settlement should bear the cost of total removal or of rendering the
materials inen. [August 92]
EP A Response
EP A will commit the funds remaining in the PRP settlement account toward the
Remedial Action. If these funds are insufficient. EP A will request funds from the
Superfund Trust Fund to bring the combined total funding up to the cost estimated to
implement the remedy selected in the ROD (capping) as long as Utah provides the 10
percent match of trust monies as required by CERCLA 104 (c) (3).
Comment 26
Mayor Dahl stated his opinion that studies on alternatives which EP A seemed
interested in supporting or deleting outright are conveniently funded by EP A, but
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.studies that may prove to be more beneficial to the interestS of the citizens of Midvale
must be funded by the State. the City of Midvale. or .private individuals. [August 92]
EP A Response on Comments 25. 26
EP A has equally funded all studies which would appear to have the ability to provide
a remedy which is protective of human health and the environment.
4. Risk AssessmentiHealth Risks
Comment 27
A Midvale mother of five children, one of whom was in the lead study, expressed
concern over health risks to and safety of her children and asked how to obtain
additional information on protective measures. [June 92]
EP A Response
EP A has published numerous fact sheetS on protective. measures. in lead contaminated
areas. These are available from EPA's Office of External Affairs in Denver.
Comment 28
A 13-year resident of Midvale expressed concern about the lead in the tailings and the
tailings dust and attributed Midvale cancer deaths to the tailings pile. However. a 49-
year old lifetime Midvale resident acknowledged playing in the tailings pile as a youth
with his friends and questioned the actual health risks posed by the tailings, since he
and his friends were still healthy. [June 92]
EP A Response
It is difficult to draw any conclusions about health risks to the general population
based on the experience of a h. N individuals. The purpose of EP A's risk assessment
is to characterize both carcinogenic and noncarcinogenic risks related to OU 1.
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Comment 29
The Midvale District Representative from the Utah House of Representatives asked if
EP A had performed lead and arsenic blood tests on Midvale children and adults and
where the results of the tests could be obtained. [June 92]
EP A Response
EP A has not conducted any tests on children or adults in Midvale. On other sites,
EP A has participated in such studies by helping with sampling of soil. dust and other
media. but is not able itself to conduct human exposure studies. A number of Midvale
children did participate in a blood lead study conducted by consultants to ARCO.
ARCO may be contacted for the results of this study.
Comment 30
A PRP assened that the risk of injury or death associaied with the industrial activiry
and traffic that accompany remediation far exceeds the risks from the lead and arsenic
in the tailings or soil. [November 90]
EP A Response
EPA does not wish to infer that by allowing the State to enhance ~e remedy by
developing an excavation disposal alternative, it is ignoring the materials handling
difficulties of the tailings. EP A agrees that any handling of the tailings would be
difficult, however EP A has stated that the construction activities proposed in the
excavation alternative are technically feasible, would adequately handle the tailings
material, and could be done protectively.
EP A concurs that the potential for dust emissions during construction activities is high,
however, EP A has stated that the emissions could be controlled with an extensive dust
abatement program and have included the cost for such a program (Appendix C. May
1992 FS). In addition. it was assumed that a significant portion of the tailings would
be moist or wet and would not be susceptible to migration by wind. Additionally, the
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use of a slurry pipeline, if one were used. decreases the risk of injury or death
associated with truck traffic.
It is not possible to absolutely eliminate all risk. The risk of injury or death is
considered low for implementing the remedial action. . All actions will be taken to
minimize any risk associated with any construction work and risks will be mitigated
by following OSHA guidelines and safe construction practices. Construction is a
shott-term process, whereas the risk from the lead and arsenic is long-term.
S. Remedial Design
Comment 31
A Midvale resident expressed concern about wind dispersion of the tailings, especially
after OU2 materials had been added to the tailings pile, and asked what the risk was in
leaving the dust free to be blown around while final OU1 decisions were deliberated.
Another resident asked that more .dust.suppressant cover be applied while decisions
were being made. [June 92]
EP A Response
EP A considers limiting wind dispersion of contaminants imponant during deliberations
on the remedy for OU 1. A dust suppressant has been applied to the surface of the
tailings to limit blowing dust. EP A intends to keep this surfactant in place until a
final decision on OU1 is made, and remedial action begins.
Comment 32
UDEQ commented that Utah was not sure that any cap design could meet the State's
concerns, but that the State was willing to work w~th EP A to determine if additional
design of EPA's preferred alternative could be accom;:ished in a way that would
meet the State's requirements for remediation of the tailings. UDEQ noted this would
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involve significant design changes and possibly treatment prior to disposal.
[August 92]
6. Feasibility StudylProposed Plan
Comment 33
UDEQ submitted comments on an advance draft of the Proposed Plan requesting a
number of wording/grammatical changes and suggesting the rewording of statements
that clarified conceptS such as: 1) the BOM study prompted both EPA 'and UDEQ to
agree that beneficiation/reprocessing should be eliminated as a potential remediation
alternative; 2) UDEQ has a desire to evaluate Alternative 3 equally against Alternative
4; and 3) UDEQ recognizes that while Alternatives 3 and 4 reduce mobility of
contaminants in the air and the groundwater, they do so through containment rather
than treatment. [June 92]
Comment 34
UDEQ also provided comments on the Draft Feasibility Study requestin~ a number of
wording and grammatical changes that UDEQ felt would improve the clarity of the
document and further address technical concerns. UDEQ subsequently requested
further wording and grammatical changes on the Final FS. Additionally, UDEQ
requested correction, clarification, and/or elaboration on textual content of the FS. For
full review of the UDEQ comments on the FS, please see UDEQ letters dated June 5.
1992 and August 14. 1992, which are included in the Administrative Record at the
Sharon Steel site Information Repositories. [August 92]
EPA Response on Comments 32,33,34
Many of the changes requested by UDEQ on the Draft FS were addressed during the
Writing of the Final FS. CommentS about material in the Final FS appear as official
comments under their related subject heads throughout this Responsiveness Summary.
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The Final FS was published in May, 1992. UDEQ was aware of the schedule and was
given sufficient lead time to provide its comments prior to publication. The comments
from UDEQ were received by EP A after the document was published and are
addressed in this Responsiveness Summary.
7.
Land Use
Comment 35
The Midvale Chamber of Commerce stated that in its opinion, Alternative 3
(excavation and removal) serves the best interests of Midvale City by enhancing
economic development potential and protecting the environment and health of those
living and working in Midvale. The Chamber stated that restricted land use under the
capping proposal would have a definite adverse economic impact on the community
and that neither the potential sale nor the development of the land was addressed
under the capping proposal. The Chamber funher noted that while health and
environmental concerns are EP A priorities, issues of economic development should be
included as cleanup selection criteria. These views were also shared by a West Jordan
resident. UDEQ commented that land use limitations should be further addressed for
appropriateness by the community of Midvale. A PRP, however, stated opposition to
the suggestion in the FS that future land use would be considered as a criterion for
remedy selection. The PRP said that under any guise, future land use was an
inappropriate criterion for remedy selection. [November 90. October 90. June 92]
EP A Response
EP A agrees that "unrestricted" land use is not a criterion for remedy selection, nor is it
the remedial goal of CERCLNSARA, thus EP A is not selecting the remedy based on
land use planning. Rather, the primary criterion for remedy selection is protection of
public health and ...le environment. However, State and Community Acceptanc..: are
:uso important modifying criteria (see the National Contingency Plan. 40 CFR
300.430) to be considered in remedy selection, and were used to clarify the narore of
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the remedy, as intended by EPA. in tenns of future uses of the land. State and local
governments may enhance the remedy to funher benefit the community in terms of
future land uses and development.
Comment 36
Mayor Dahl expressed opposition to capping because in his opinion~ capping would
prevent the State of Utah from constructing the Jordan River Parkway, a plan for
uninterrupted pathways and trails along the Jordan River. [January 91]
EP A Response
The proposed capping alternative does not have to prevent the construction of the
Jordan River Parkway. The capping alternative proposed a soil cement embankment
along the Jordan River to' stabilize the tailings and prevent migration of the tailings
into the river. During the Remedial Design phase. appropriate featUres could be
included in the design of the embankment to account for futUre development of the
parkway.
The conceptual design of the cap, as included in the revised FS (May 1992). includes
the removal of the tailings along the river to allow for the construction of the
Parkway. A 150 foot buffer measured from the toe of the cap to the centerline of the
river will be established. The embankment of the tailings pile along the river will be
terraced and stabilized to prevent slippage of the pile.
8. Public Participation
Comment 37
The State and the Midvale Citizens' Group stated that a 30-day comment period on
the Proposed Plan was inadequate. and formally requested an extension of the public
comment period by at least 30 days. [June 92]
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EP A Response
EPA extended the comment period an additional 30 days.
Comment 38
Several commenters noted the number of non-English-speaking people affected by
OU 1 and requested that EP A budget for translations of material into the "language of
the people." Commenters asked if the material could be translated into Spanish and if
this could be done before the end of the Proposed Plan comment period. [June 92]
EP A Response
EP A held bi-lingual meetings with interested Spanish speaking residentS and provided
written material in Spanish.
9. Reprocessing
Comment 39
During a 1989 public meeting, the opinion of the audience was that the reprocessing
industry should be given a chance to test various reprocessing technologies on the
tailings so that a reprocessor could remove the contaminantS, sell the metals/minerals
of value, employ Midvale residentS. and allow Midvale to reclaim the OU1 site for
future land use. The audience's sentiment at the time appeared to be that EP A and
the State should fund such reprocessing. [1989]
EP A Response
In response to this sentiment, EPA asked the U.S. Bureau of Mines to perform testing
to determine if the tailings could be reprocessed. The BOM study indicated that
beneficiation does not meet the nine criteria.
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10. Alternate Proposals
Comment 40
A remediation company stated it utilized a process to extract metals from tailings
whereby the hazards could be treated by the toxicity characteristics leaching procedure
(TCLP) to less than RCRA limits for lead. arsenic. and cadmium. A company
representative stated that a Feasibility Study on this process at the Sharon Steel
tailings had been prepared by them. that such a project could be performed within the
budget set aside for the project (as projected in the FS). that such a process would
benefit the community and protect the dedicated wetlands. and that the FeaSibility
Study had been favorably received by members of the Midvale City CounciL an action
committee. and certain Congressional aides. [August 92]
EP A Response
Upon review of this proposal. EP A determined that insufficient technical information
was presented to confirm the remedial claims made.
Comment 41
A Midvale resident commented that he had presented his alternate excavation and
removal proposal to the Utah County Commissioners. the City of Lehi. the town of
Cedar Fort, and the town of Fairfield. and that these area councils would discuss the
proposal further. His proposal includes moving the tailings by rail to an old mine site
located within the 30-mile radius. [August 92]
EP A Response
Upon review of this proposal. EP A determined that insufficient technical information
was presented to fully evaluate the alternative.
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Comment 42
A Salt Lake City resident expressed concerns about reponed plans to dump or store
the Sharon Steel tailings in the Great Salt Lake or to build a causeway constructed of
cement-encased tailings. She noted the potential harm to recreationalistS. wildlife. lake
dwellers. the brine and magnesium industries. etc.. from lead and arsenic
contamination. and funher noted the area's unpredictable weather and tidal
fluctuations. [July 92]
EP A Response
It is not the intent of EPA to place the tailings from the Sharon Steel site in the Great
Salt Lake. This was a proposal by a private company. EPA studied the general
alternative of excavation/removal/containment.
B.
Legal and Technical Questions and Agency Responses
The purpose of this section is to respond to specific legal and technical questions
raised by the COIJUTIunity. If necessary, this part elaborates on responses with a greater
level of technical detail than presented in Part A.
1. Long-Term Effectiveness
Comment 43
Fonner Congressman Owens stated that under the capping, no action. and site controls
alternatives, approximately 10 million tons of contaminated tailings would be allowed
to remain at a location that is only 1/4 mile from the residences of 1.400 people and
only 1 mile from the residences of 8.000 people. He expressed his opinion that
capping does not adequately address the potential for seepage of lead, arsenic. and
other metal contaminantS down into the deep principal aquifer that se: les as a drinking
water source for Midvale and Salt Lake City. He stated his opinion that the capping
proposal did not require remediation (0 reduce levels of contaminantS in groundwater
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. _...~ -. "--.'
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underlying OUl, nor did this proposed alternative require measures to prevent
. migration of existing contamination into the drinking water aquifer. Former
Congressman Owens compared capping's limited long-term effectiveness to the
fIXation process proposed as Alternative- 6 where contaminants would be immobilized
and thus rendered incapable of migrating to surface waters or groundwater. [July 92.
August 92]
EP A Response
The capping alternative includes a provision for a groundwater pump and treat system.
if necessary, to prevent migration of contaminants beyond the OU1 boundaries. The
cap will effectively reduce seepage of contaminants into underlying aquifers.
Comment 44
Mayor Dahl stressed that one of the items listed in the cleanup criteria was long-term
effectiveness and permanence. He noted that the 30-year time period referenced in the
- -
proposed remedy is more like a Band-Aid than a permanent solution. [January 91]
EP A Response
EP A's interpretation of the word permanence differs from an interpretation that the
word permanence means "forever." The Long-Term Effectiveness and Permanence
criteria, as defined in the NCP, involve the "magnitude of residual risk. . . from
untreated waste remaining at the conclusion of the remedial systems." In particular.
the criterion assesses the "potential need to replace technical components of the
alternative, such as a cap." (NCP, Section 300.430 e9ii(C)). The comparison rated
capping as meeting the criteria. This was true for excavation and disposal. and
fIXation. Fixation is the most effective at long-term effectiveness. Both excavation
and disposal and capping utilize containment and capping of the tailings without
treatment as the primary technology. Both alternatives also include long term
maintenance of the cap. With pro?er maintenance and repairs when needed, the
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integrity of the cap should not be compromised. Therefore. on a comparative basis.
they too meet the criteria for long term effectiveness.
With the operation and maintenance (O&M) resources included in this alternative. this
is a permanent solution under the NCP. The alternative was costed for a period of
thiny years, and the NCP presumes that O&M would continue as needed beyond the
thiny-year time frame by the responsible public agencies.
Comment 45
A representative from the Salt Lake Community Action Program raised general
. concerns about covering up the Sharon Steel contamination by capping and presenred
additional concerns about the added effects that Kennecott's contaminant migration
would pose to the Jordan River. She urged that the tailings be removed and suggested
USPCI as a personal choice for a site. She also recommended that alternate proposals
be reviewed again with diligence. [June 92]
Comment 46
Mayor Dahl said that in his opinion. the cost for slurrying the tailings to another
mining district in Cedar Valley was about the same as the cost for capping, and it
provided a more permanent solution by removing the tailings from the site. [January
92]
EPA Response to Comments 45,46
The remedy selected by EP A must be protective of human health and the environment.
. . .
and must comply with the applicable or relevant and appropriate requirements
(ARARs) under Federal and State laws and regulations. Slunying the tailings to
another mining district may create human health and environmental risks from the
transportation activL::.=S and in another location. If the tailings were transported to a
new mining district. the contamination and the risks they pose would still need to be
LR SHNS OOI\RE.SPONSE.FNL\120893
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.-_._- .
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addressed. No overall cost savings. when compared to the capping alternative. are
realized by this proposal.
EP A does not believe that the cost for moving the tailings as compared to capping in
place is approximately equal. EP A has not received the cost estimate for the Cedar
Valley proposal. However. other cost estimates that were submitted to EPA for
similar proposals failed to take into consideration all necessary requirements to
perform the alternative proposed. EP A estimates show capping to be more cost
effective than excavation and disposal.
2.
Cost Issues
Corrunent 47
UDEQ commented that EPA's estimate of costS for the excavation. transportation. and
containment alternative could be approximately $60 million high, lowering the
estimated cost from $224 million to $164 million. UDEQ noted that EPA's estimates
were based on the premises that a.RCRA Subtitle C landfill be constructed as the
required disposal "cell," that transportation of the tailings to the cell be via slurry line.
and that the operational life of the slurry system wo.uld be 6.5 years. UDEQ
suggested that the following premises are in error: 1) RCRA Subtitle C is not
applicable to Bevill amended waste and thus is not applicable to a disposal site for the
Sharon S~eel tailings; therefore, the estimated costs for the disposal cell may be
significantly high (as presented: $26 million); 2) EPA's estimated itemized costs for
constructing the slurry line, including pumps and dewatering systems. is approximately
$75 million; this figure is three to four times the estimates from the two slurry
proposals reviewed by the State; 3) EP A proposes that the slurry line operate 8
hours/day (operational life = 6.5 years); but tWo slurry proposals examined by the
State operate for 24 hours/day, 9 months/year (operational life = 3 years); and 4) as a
consequence of lower direct costS (construction of slurry line. pumps. etc.) indirect'
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costS that are estimated as a percentage of the presented direct costS would be reduced
appropriately. [August 92]
EP A Response
It is true that the tailings would be covered by the Bevill Amendment and therefore
not classified as a RCRA C waste. It is EP A's intent that wastes from the extraction
and beneficiation of ores and minerals are to be regulated under Subtitle D of RCRA.
or where appropriate and relevant. under specific sections of Subtitle C.
Disposal of the mining waste must comply with all local. State. and Federal procedural
and substantive requirementS, regulations and statues. required as part of a CERCLA
response action.
At this time. the most prudent and conservative course for costing purposes is to
assume that a new disposal cell may need to meet all the requirementS of Subtitle C
even though the tai1i.ngs themselves are classified under Subtitle D. The exact
requirementS cannot be determined until the exact location for the cell has been
. .
finalized.
EPA's estimate for construction of the slurry line. pumping, and dewatering was
developed at a -30% to +50% level of accuracy. Funhennore. all cost saving
assumptions cannot be substantiated at this time. The cost estimates were based on
applicable regulations and standard design practices for the handling of hazardous
wastes. This approach was true for all alternatives and therefore all alternatives were
compared using a consistent cost basis and are .subject to the same level of accuracy.
It may be impractical to assume that a slurry line could be operated continuously 24
hours a day for ni,ne months out of the year. :. ;le transponation process includes
exc:lvating the tailings. conveying them to the facility for making the slurry, making
the slurry, pumping to the disposal site. storing the slurry. dewatering, and fInal
LR SHNS OOl\RESPONSE.FNL\l20893
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'...--.'--'.
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disposal in the cell. By assuming a 24 hour operation. it is also assumed that each
one of these separate stages will work in perfect synchronization. If anyone of the
parts fail then the whole system will have to shut down. Further a continuous
operation assumes that there will not be any bottlenecks in the system. That is all
material is moved to the next stage at the exact time and in the exact quantity needed.
This scenario is highly unlikely.
Lowering the direct costS would subsequently lower indirect costS. EP A is confident
of their original cost estimates with the specified range of accuracy and therefore are
also confident of the indirect costS based on a percentage of direct costS.
Comment 48
In the opinion of a site remediation company, the cost estimate for Alternative 3
reflectS a lack of knowledge and understanding of local conditions, state-of-the-art
excavation methodologies, and slurry-line technology. The company stated that the
use or conceptual-phase cost-estimating techniques is inappropriate at this stage of the
investigation. The company questioned not only the validity of the published costS for
Alternative 3, but also other alternatives. The commenter believes that Direct Capital
CostS Items No.4 and No.5 for Alternative 3 are overstated by nearly $50.000,000
(see Appendix C of FS). In addition, the commenter believes the following costS are
also overstated: 1) the engineering costS of approximately 15 percent are unrealistic
and unwarranted for a project of this size by at least $10.000,000: 2) mobilization!
demobilization for this type of project should run no more than 6 percent. so this is
overstated by another $10,000,000: 3) paying almost $8 million for an imponed 24-
inch vegetation layer in Utah is unreasonable: and 4) the inclusion of $8.7 million in
contingency costS on the indirect annual/periodic costS is without merit and reflects a
cavalier attitude toward what should be responsible cost estimating. [August 92]
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EP A Response
EP A believes that the use of conceptUal-phase cost estimating is appropriate at this
stage. Without specific design criteria. a more detailed cost estimate is not justifiable.
All percentages used in the estimates adhere strictly to EP A costing guidelines for this
level of stUdy. EPA guidance for performing a Feasibility Study clearly states that the
level of accuracy should be in the range of -30% to + 50%. Costs were based on
standard pricing guides which are accepted nationally by the construction industry.
These costs were appropriately modified to Salt Lake City standards when necessary.
Comment 49
A comrnenter expressed difficulty in determining EPA's estimated costs for excavation
because the costs are commingled with transponation and placement costs.
[August 92]
EP A Response
The cost sheets included in Appendix C of the FS are summary sheets. Detailed
costing with specific unit costs are available as part of the Administrative Record.
Comment 50
Mayor Dahl stated that ~o properly evaluate the cost of the capping alternative. the
cost of loss of water supply and wetlands must also be included. The Mayor noted
that such a water supply and wetlands concern is presently being adjudicated by the
Utah courts in a similar case involving the contamination of a potable water supply.
[August 92]
EP A Response
There will be no loss of water supply or wetlands with any of the alternatives
proposed: :. the FS. The capping alternative includes cost for remediaL.' , 'n and
reconstruction of the existing wetland. Drilling and sampling operations during the
LR SHNS OOl\RESPOSSE.FNL'J20893
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Remedial Investigation showed that the contamination has not reached the drinking
water supply and that it is highly unlikely that it ever wilL
Comment 51
A representative of the Utah Chemical Corporation posed questions about cost
estimates for capping and slurrying. He noted that EP A's $168 million slurry estimate
is about five times the cost of another bid and also noted that EP A's annual operation
and maintenance costs for capping are $277,000, while maintenance costs for relocated
material are $7 million. The speaker funher added that slurry costs are estimated at
three times higher than capping costs, when, in his opinion, they should be 30% less;
An explanation of the estimates was requested, as was information on who prepared
the estimates and where copies were available. Similar sentiment about estimates was
expressed by UDEQ. [June 92]
EP A Response
It is true that the maintenance cost for the relocation alternative is inappropriately
high. "The reason is that construction costs for the pipeline and cell past the first year
were included as operation and maintenance costs. They should have been included as
part of capital costs. This actually lowers the total cost of the alternative since these
costs were amortized over a 30 year period. The basis for the estimate has been
further described in the responses to Comment 47.
3. Legal/Regulatory/Compliance Issues
Comment 52
Former Congressman Owens voiced ~oncern over permanence provided by the
proposed alternative. He stated that lack of treatment to destroy or permanently
reduce the toxicity or volume of contaminants in QUI media constituted non-
adherence to CERCLA, because CERCLA requires the use of permanent solutions [0
the maximum extent possible. [July 92]
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EP A Response
CERCLA does state a preference for solutions that permanently treat or destroy
contamination. Pursuant to CERCLA. however. EP A must compare alternatives using
the nine NCP criteria. At present EPA is not aware of any technology which can treat
these materials at a cost equal to or lower than the capping cost. Based upon this
comparison. capping best meets all the criteria EP A considers in selecting a remedy.
Comment 53
The FS stated that one of the disposal location options is a S tate-designed cell
constructed according to RCRA Subtitle C requirements. UDEQ pointed out that
RCRA Subtitle C was not applicable based on the Bevill Amendment. All ARARs
must be considered when disposing of waste: therefore. UDEQ requested that "RCRA
Subtitle C requirements" be referenced as "ARARs." Representative Jorgensen also
asked for clarification as to how the Bevill Amendment affected procedures at Sharon
Steel. [June 92. August 92]
EP A Response
Please see response to Comments 47 and 55.
Comment 54
A PRP noted that the FS failed to respond to PRP comments on Federal ARARs. The
earlier FS did not explain why EPA applied RCRA Subtitle C or 0 or reclamation
standards to this mining waste site. [November 90]
EP A Response
Refer.to response to Comment 47.
Comment 55
In commenting on the FS, UDEQ suggested that if a RCRA Subtitle C disposal cell
were required for off-site containment of the tailings. then the same requirements
LR SHNS OOl\RESPONSERiL\l20893
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- - - ..~_. ---- -. .
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would need to be applied to the proposed on-site cap. These on-site requirements
would substantially increase the cost of the capping alternative. [August 92]
EP A Response
As noted earlier, the Bevill Amendment does cover the tailings. See response to
Comment 47. It is important to note that Bevill does not exclude RCRA Subtitle C
requirements. It simply states that they are not applicable; however. they can still be
appropriate and relevant.
Comment 56
Former Congressman Owens stated his opinion that neither the no funher action
alternative nor the site control alternative would comply with the protective statutory
requirements of CERCLA and should thus both be rejected by EPA when selecting a
final remedy. [July 92]
EP A Response
EP A agrees with former Representative Owens and dropped these tWo alternatives
from funher consideration after detailed analysis. Evaluation of what is called a "No
Further Action" alternative is a required component of the evaluation process and
serves as a baseline against which to compare other alternatives.
Comment 57
Former Congressman Owens noted that while CERCLA mandates a preference for
treatment of contaminants, in his opinion, EP A has stated that capping does not fully
comply with this statutory preference. Congressman Owens does not accept EPA's
justification of this deficiency that the contingency alternative also does not satisfy
CERCLA's preference for treatment. [July 92]
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EPA Response
CERCLA mandates a "preference" for treatment. The FS studied the ability to treat
the wastes. This included an in-depth bench scale study by the U.S. Bureau of Mines
on beneficiation. It was determined that there is no presently available means to
technically and economically treat the wastes such that they no longer would be
considered hazardous.
Comment 58
After commending the diligent team efforts of all involved, the Midvale District
Representative for the Utah House of Representatives asked for clarification of
federally-required distances between hazardous materials and underlying aquifers.
[June 92]
EP A Response
The tailings are not classified as hazardous waste as they are exempted by the Bevill
Amendment.
Comment 59
A representative of a private technical company pointed out that although EPA stated
at the August 17, 1989 public hearing that there would continue to be liability on
behalf of the PRPs for future contingencies. the Consent Decree indicated that all
liabilities were settled. [January 91]
EP A Response
All liabilities which were settled between EP A and PRPs are subject to standard
reopeners, if site conditions change or new information becomes available.
Comment 60
A PRP contended that EPA attempted to rewrite CERCLA regarding State ARARs by
ignoring CERCLA's requirement that State ARARs be more stringent than Federal
LR SHNS OOl\RESPONSE.FNL\120893
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standards. The PRP insisted that absent a showing that Utah environmental standards
were more sningent. all State requirementS identified as ARARs in the earlier FS were
incorrect: those references should be deleted and State standards should not be used in
selecting or designing a remedy. [November 90]
EP A Response
EP A agrees that some of the State regulations identified in the FS are not ARARs (see
response to the next comment). In general CERCLA limitS the scope of State ARARs
to standards. requirementS. criteria. or limitations under environmental or facility siting
laws that are promulgated and more stringent than Federal requirementS.
Comment 61
A PRP maintained that Volume II. pages 2-22 to 2-23 of the earlier FS. properly
stated that neither the Utah Groundwater Protection Rules nor the Corrective Action
Cleanup Standards Policy for MCLs at Hazardous Waste Sites are ARARs. However,
according to Table 2.2-1. both requirementS were applicable (pages 2-5 and 2-10).
The PRP funher stated that Table 2.2-1 should be corrected to reflect that these
requirementS were not ARARs for the Midvale Tailings Site. [November 90]
EP A Response
EPA agrees that neither the Utah Groundwater Protection Rules nor the Corrective
Action Standards are ARARs.
Comment 62
A commenter expressed his opinion that capping was legally and technically wrong
and that capping would be likely to pollute the waters of Midvale. He supported his
position by referencing Federal Water Law 33 U.S. Code 1311 - ". . . the discharge of
any pollutant by any person shall be unlawfu1." [January 91]
LR SHNS OOI\RESPONSE.FNL\l20893
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EP A Response.
EP A disagrees that capping is legally or technically wrong. Capping has been selected
at a number of Superfund sites and does not violate any Federal laws or standards.
This remedy will comply with requirementS of the cited statute. At this time no point
discharges are anticipated.
4. Groundwater Issues
Comment 63
Mayor Dahl expressed numerous concerns about groundwater protection under the .
capping alternative. He reiterated that the FS acknowledged that both the upper sand
and gravel aquifer and the deep principal aquifer are contaminated. Mayor Dahl
stressed his opinion that with capping, some pumping and cleanup of the groundwater
would be necessary for the projected 30-year period. The Mayor asked what would
happen to this flow of water through the tailings after 30 years. [January 91]
EP A Response
The remedial investigation does not identify any contamination present in the deep
principal aquifer. Treatment of groundwater could continue for an indefinite time into.
the future. if necessary. It should be noted that Superfund evaluations of the
effectiveness of remedies where waste is left onsite are limited to an examination of a
30-year time frame and include 5-year reviews.
Comment 64
A commenter indicated that in his opinion capping poses a potential for contamination
. of the deep principal aquifer. especially under drought conditions. In the event of a
drough~ he believes the artesian effect. (that is, the upward pressure and flow of water
from the lower aquifer to 'the upper aquifer caused by underground cross flow down
from the mountains) would stop. The artesian effect is now keeping waters of the
upper aquifer from migrating down to the lower aquifer. When stopped by reducing
LR SHNS 001\RESPONSE.FNl.\l20893
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the level of the water in the lower aquifer. contaminated water from the upper aquifer
would flow into the lower aquifer. [January 91]
EP A Response
This hypothesized movement from the upper portion of the upper sand and gravel
aquifer was examined during the remedial investigation. The time period for
contaminants to travel vertically through the system (when the sorptive properties of
the aquifer and confining zone separating the deep principal aquifer from the upper
sand and gravel aquifer are considered) are extremely long. and it is EPA's opinion
that. even if these conditions were to continue for a lengthy period. it is unlikely that
any measurable degradation of the deep principal aquifer would be detected.
Comment 65
A resident. Mayor Dahl, the Salt Lake County Board of Commissioners. and a PRP
noted their opinion that due to the number of wells and drill holes at au l, and the
areas where no confining clay layer exists between aquifers underlying OUI, heavy
metals could migrate directly into the deep principal aqUifer. The Commissioners
noted that the preliminary draft repon addressing the groundwater investigation
suggested that the upper sand and gravel aquifer had been contaminated with heavy
metals beneath the tailings. The Commissioners, Mayor Dahl. and the State of Utah
expressed concern that future increased pumping for drinking water supplies may lead
to a more widespread gradient reversal and increased contamination. Joined by an
earlier commenter on OU2, they charged that the protection of the deep principal
aquifer is a must regardless of cost because it is an imponant drinking water source
for Salt Lake County residents. [October 90, November 90, September 90, January 91]
EP A Response
See response to Comment 64.
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Comment 66
UDEQ asked for an explanation on the statement in the FS that the direction of
groundwater flow beneath au 1 is different than the direction of regional groundwater
flow. Mayor Dahl voiced the opinion that increased groundwater pumping could alter
groundwater flow from a westerly to a northeasterly direction. [January 91, August 92]
EP A Response
The selected remedy includes a provision for pumping contaminated groundwater to
prevent migration of contaminated groundwater outside the aUI boundaries or
downward into the deep principal aquifer in the event that groundwater conditions
change significantly and/or contamination is detected in the deep principal aquifer.
Comment 67
The FS stated that lead concentrations greater than MCLs were found in groundwater
from the northwest corner of the site. UDEQasked from what depth (aquifer) was ~e
sample collected? Was the extent of lead contamination defined and additional
confirmation sampling conducted during the 1989 Rl? . Why or why not? Does data .
indicate the source to be from Sharon Steel or Midvale Slag? Similar concern was
shared by the Midvale Distric;t Representative from the Utah House of Representatives.
[June 92, August 92]
EP A Response
The upper sand and gravel aquifer was sampled during the supplemental RI
investigations and no exceedances of MCLs for lead were identified.
Comment 68
The Salt Lake County Board of Commissioners commented that capping the tailings
may reduce the infiltration of watel from precipitation, but does not address the lateral
new of groundwater into the wlings. which could gene:ate the subsequent leaching of
heavy metals and migration of the leachate into the upper sand and gravel aquifer.
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The Commissioners noted that this groundwater flow could be reduced if intercepted
by a slurry wall or French drain. but that neither remedy would be permanent or free
of costly maintenance and monitoring to insure permanent effectiveness. [August 92]
EP A Response
Without the leaching forces of inf1ltration. the addition of metals to the underflow
would be greatly reduced. Migration and a small amount of leaching could occur
from lateral flow. Lateral groundwater inflow control is included in EPA's June 1992
preferred alternative. Costs for capital and operation and maintenance for 30 years
have been included in that alternative.
EP A's June 1992 proposed alternative includes a provision for pumping of
contaminated groundwater from below the tailings. if necessary. The quantity of
lateral inflow was esrimated to be a small portion of the total inflow to the system.
Comment 69
A PRP reponed its opinion that the data in the Rl Addendum do not suppon EP A's
conclusion that the "upper sand and gravel aquifer responds as a non-leaky system and
does not show recharge boundary effects from the Jordan River." The PRP stated itS
opinion that the RI Addendum also does not support EPA's conclusion that the
"aquifer haS a hydraulic conductivity of 135 to 208 feet/day." [November 90]
EP A Response
The repon addresses the question of leaky versus non-leaky response adequately for
remedial investigation purposes. If pumping of contaminated groundwater becomes
necessary, the hydraulic characteristics of the upper sand and gravel aquifer will be
better defined during design of the system.
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Comment 70
A commenter expressed concern about the slow migration of the Jordan River water
through the tailings along the old river bed which could result in carrying leached
contaminantS downstream and contaminating downstream aquifers. [January 91]
EP A Response
The selected alternative includes a provision for preventing the migration of
contaminated groundwater from below the site to areas outSide au 1 boundaries, if
ongoing monitoring provides infonnation that suggestS this is necessary.
5. Remedial Investigations/Feasibility Studies
Comment 71
UDEQ noted that the aquifer "in the Midvale area" has not been fonnally "classified"
as a Class II groundwater and requested that the FS state that the referenced aquifer
meetS the criteria for classification as a Class II groundwater. [August 92]
EP A Response
EP A believes the existing water quality is adequately characterized in the RI repon.
See response to Comment 34.
Comment 72
. A statement that only arsenic has migrated to groundwater is presented in the FS.
UDEQ asked for an explanation about the lead concentration above MCLs encountered
at the northwest comer of the site. [August 92]
EP A Response
See response to Comment 67.
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. Comment 73
UDEQ commented that the FS was not clear in the development of the alternatives
that the treatment of groundwater would be accomplished prior to on-site discharge.
UDEQ also commented that it was not clear that both on-site discharge options
(injection and irrigation) were carried through to remedial action development. UDEQ
further commented that the FS stated that on-site discharge (apparently reinjection
only) was carried through to remedial action alternative development. though it was
not listed on Table 2.8-1 of the May 1992 FS. UDEQ asked for clarification. [August
92]
EP A Response
Both on-site and off-site discharge alternatives were considered for use in the
development of the alternatives. Only on-site treatment with discharge to the Jordan
River was actually used as pan of Alternatives 3 and 4. The selection of this
groundwater treatment and discharge alternative was shown on Figure 8-1 in the May
1992 FS.
Comment 74
The FS stated that the water rights for the deep principal aquifer far exceed aquifer
recharge. UDEQ asked what State agency provided this infonnation. [August 92]
EP A Response
This statement is based on regional hydrologic reportS cited in the RI report.
Comment 75
A PRP stated that the RI Addendum (RIlFS Octobet 1990) should recognize the
presence of an unsaturated or vadose zone within the tailings pile. and acknowledged
that the vadose zone was a potential source of acid generation and subsequent leaching
of metals. [November 90]
LR SHNS OOl\Rf.SPONSE.FNL\l20893
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EP A Response
The comment is accurate. No evaluation of the vadose zone geochemistry was
conducted. since it was not necessary for alternative evaluation. An assumption was
made that the currently observed water quality in the saturated portion of the tailings
would be representative of future quality that would result if recharge is allowed to
continue. The capping alternative will address this during remedial design.
Comment 76
UDEQ noted that the Proposed National Maximum Contaminant Level Goals (MCLG)
appeared to be incorrect as stated in the FS. Arsenic should be changed to 2.0. copper
to 1.3. and lead to O. [August 92]
EP A Response
The MCLG's for copper and lead were reponed incorrectly in the FS. Copper should
be 1.3 and lead O. Arsenic currently does not have a MCLG. The MCL for arsenic is
50 micrograms per liter.
Comment 77
UDEQ. noted that page 1-4 of the FS stated that the tailings are as deep as 56 feet. but
that page 1-35 stated that tailings have been encountered at 61.6 feet below grade.
UDEQ requested a consistent statement. [August 92]
EPA Response
The depth of 56 feet as noted on page 1-4 of the May 1992 FS .is correct. The
statement on page 1-35 is incorrect.
Comment 78
A statement was provided in the FS that no underground storage tanks (USTs) had
been noted on the former mill portion or OU 1 to date. In the text. however. there
were statements that indicated that USTs were present on OU1. UDEQ asked for
LR SHNS 001\RESPONSE.FNL\l20893
50
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. clarification about the likelihood that USTs exist at OU 1 and also noted that a
dispenser and vent piping had been identified at OU1. UDEQ funher noted that while
the FS stated that the Mining Reme~ial Recovery Company (MRRC) was responsible
for USTs that may be located OU1, MRRC claims that the USTs are EPA's
responsibility and that MRRC has no further environmental liability for Sharon Steel.
[August 92]
EP A Response
A dispenser was located at bUI on the north side of the mill building. It was
removed by an EP A Emergency Response Contractor. The remains of a large above-
ground storage tank were inunediately next to the dispenser. This tank could have
been pan of the fuel dispensing system. This tank was also removed as pan of the
demolition of site sttUctures. No USTs are known to exist at OU1. EP A recognizes
that MRRC would not be responsible for any USTs at OU 1.
Comment 79
The FS stated that an asbestos cement pipe would need to be considered for disposal
during demolition of the mill building facility. UDEQ commented that according to
MRRC. there are no intentions to remove the asbestos pipe from the facility. [August
92]
EP A Response
The asbestos cement pipe that is currently at OU 1 was re.moved by an EP A
Emergency Response contractor, or their subcontractor. who performed the demolition
of the mill buildings.
Comment 80
The FS stated that eight buildings were being dismantled by MRRC, but UDEQ
commemed that only six of the eight buildings located on OUI are being dismantled.
[August 92]
LR SHNS OOl\RESPONSE.Fr.1.\l20893
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EP A Response
All existing above ground structures on the pilll site have been demolished by EP A's
Emergency Response contractor.
Comment 81
The FS stated that 10,000 gallons of liquid were said to be present in the thickener
building on QUI. UDEQ asked if this was true, and if so, what kind of liquid was
present? Why was further investigation as to the type of liquid present not conducted?
[August 92]
EP A Response
The statement concerning the existence of liquid in the thickener building was true at
the time of the original writing of the F:S. This statement should have been removed
from the May 1992 FS. There are no free liquids in any visible tank at QUl.
Comment 82
UDEQ noted that an incorrect statement was made in the FS stating that the work plan
provided in Appendix K of the FS was approved by EP A and was in full compliance
with all requirementS to protect human health and the environment. The work plan
that was approved by EPA is the June 5, 1992 version, not the draft work plan dated
April 13, 1992 that is presently in Appendix K. [August 92]
EP A Response
This is correct, however, the FS was published in May 1992 prior to the approval of
the fmal work plan. There were no substantive changes in the draft Work Plan which
was included in Appendix K.
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Comment 83
The FS stated that remedial action was scheduled to begin at OU2 in the summer of
1992, but UDEQ commented that remedial action is scheduled to begin in the spring
of 1993. [August 92] ,
EP A Response
At the time that the FS was written. the OU2 schedule still called for work to begin in
the summer of 1992. It began in June 1993.
Comment 84
The Midvale District Representative from the Utah House of Representatives asked for
clarification about the Toxic Characteristics of Leaching Procedure (TCLP). He
further asked if the .TCLP had been done at the OU1 tailings site and what the results
were. [June 92]
EP A Response
The Toxicity Characteristics Leaching Procedure (TCLP) has been performed at the
OU1 tailings site. The results of the TCLP are included in table F-5 in Appendix F of
the May 1992 Feasibility Study. Paragraph 3.3 of Appendix F states:
"None of the leachates from the EP toxicity test or the TCLP test of treated tailing
samples exceeded the concentration criteria of 40 CFR 261.24 and therefore the treated
tailings materials do not meet the definition of RCRA hazardous waste. This is not
true of the untreated or reprocessed samples. The EP Tax leachate results from the
untreated samples for the regulated metals are summarized on Table F-1." This
section goes on to discuss treatment with fIxation agents to reduce the amounts of
metals in 1eachates.
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Comment 85
The FS stated that at pH values of 7.5 to 7.8. metals would remain bound to the
sediments. UDEQ asked if this would be true for all metals of concern at OUI.
[August 92]
EP A Response
The FS stated (page 1-42) that under slightly alkaline conditions. metals would tend to
remain bound to the sediments. . This is an accurate general statement; other factors
may also influence metals solubility. Please refer to the RI for additional infonnation.
6. Remedial Design
Comment 86
A commenter stated that capping. fixing. and vitrification each. has certain merits. but
that in its opinion these procedures were not applicable to the Sharon Steel tailings.
The methods are suitable for small volumes of recalcitiant contaminants not readily
"treated or able to be removed by other technologies or methods. [August 92]
EP A Response
EP A concurs that fixing and vitrification are not technically or economically feasible
at the Sharon Steel site due to the characteristics and volume of the tailings.
However. capping is amenable to this site. One of the advantages of capping is that
it is protective and can cover a large land area at a reasonable cost. EP A believes that
capping is an excellent choice for the tailings which are not readily treated.
Comment 87
The U.S. Fish and Wildlife SeIVice made five points related to migratory bird
protection during the tailings remediation: 1) clean up of buildings. trees. or wetland"
habitat should be designed $0 as to have minimal impact on nesting birds and nest
sites; 2) due to the tendency of heavy metals to bioaccumulate in aquatic invenebrates
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and plants. monitoring of aquatic life should be conducted to protect migratory birds
from contamination via the food chain: 3) clean wetland sediment may need to be
placed into the wetlands to retain a shallow water depth after remediation: 4)
revegetation of the wetlands and upland areas of the site should be accomplished with
native plant species; 5) pockets of contaminated tailings detected in the Jordan River
should be removed due to their migration potential from floods, eanhquakes. and
construction and because of the risk of bioaccumulation in the food chain. [August 92]
EP A Response
The demolition of the Quildings and remediation of the au 1 site will be performed in
a manner sensitive to the fauna which exists on au 1. Once the remediation is
complete. the ability for heavy metals to enter the food chain will be reduced. As part
of the preferred alternative, the existing wetlands will be remediated and reconstructed
to a natural state. Because of this, EP A has no plan to clean any sediments in the
Jordan River as part of EPA's June 1992 preferred remediation alternative.
Comment 88
UDEQ noted that a statement is made in the May 1992 FS that tWo feet of clean fill
would be placed at the IJiill site if excavation of the tailings were the selected
alternative. This appears to imply that only tWo feet of contaminated soil would be
removed during the excavation process. However. as stated on page 1-18 of Volume
II. Section 1 (of the May 1992 FS), contaminated soils extend to ten feet below the
tailings. UDEQ has requested a remedy for mitigation of the additional depth of
contaminated soil below tWo feet deep and has asked for cleanup levels. [August 92]
EP A Response
Two feet of soil would be removed in the former mill area if either the excavation and
disposal or capping alternatives are selected. If the excavation and disposal alternative
is selected. all contaminated tailings would be excavated. and contaminated soils
below the tailings would be excavated to a depth of four feet. The FS indicates that
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soils with contaminant concentrations exceeding action levels do not extend beyond
four feet below the tailings.
7. Alternative 4 -- Capping Issues
Comment 89
A remediation company stated that a cap would create an anaerobic and anoxic
(devoid of air and oxygen) environment in the material below the cap. In the
commenrer's opinion. this situation could cause the generation of acids, or similar
conditions, far more acidic than the EP A TCLP test used to determine the
concentrations of metals reponed in the survey data. The time for leaching to occur
would also be considerably more extensive in duration than for the previously
mentioned test method which would result in more leaching of a greater extent than is
presently observed. Capping would also induce the native anaerobic bacteria to thrive
in what would be an ideal environment and thereby generate biogenic toxins including
organic complexes of the toxic metals. [August 921
EP A Response
The tailings are currently under anaerobic conditions at depth. The addition of a cap
is not expected to significantly impact this condition. The selected alternative includes
a provision for controlling the flow of contaminated groundwater from the site. if
necessary.
Comment 90
In opposition to capping, Mayor Dahl mentioned that drill logs indicate that the top
few feet of tailings are dry, but deeper down, the tailings go from moist to wet to a
"foul-smelling saturated gooey substance," which according to the Mayor is a formula
for liquefaction. Since Miavale is in a high-risk eanhquakezone, what cost and
remediation has EP A planned for in the event or an earthquake that causes the tailings
to move and the ground to become contaminated? Another commenter also expressed
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concerns about the geologic instability of the Salt Lake City Basin and noted that au 1
could be at risk because the tailings were situated on the former geological bed of the
Jordan River. and the river was divened in the 1950s to allow addition of more
tailings. [January 91]
EP A Response
Liquefaction potential of the tailings during a major eanhquake. has been studied by
EP A and the State. Also. geotechnical analysis of tailings has been conducted by
various parties. including EPA and the U.S. Bureau of Reclamation. Horizontal and
vertical contamination of ground and surface water from eanhquake liquefaction
cannot be easily estimated. however. and it follows that no estimate of remedial costS
from such a cataStrophic event has been prepared to date.
Previous studies have concluded that the tailings. as well as the elastic siltS underlying
them, would be subject to liquefaction under strong shaking. As the tailings drain. this
susceptibility would be reduced. but would probably remain as long as some portion of
the tailings or the subtailings remain saturated. The alluvium under the tailings may
also be subject to liquefaction.
Should any of these materials fail. the cap could become cracked or fail as well.
Proper design of the cap, combined with buttressing of side slopes, could reduce this
susceptibility .
EP A Headquarters performed a technical review of the potential for seismic damage at
the OU 1 site. EP A concluded that seismic hazards can be mitigated using standard
geotechnicai engineering measures. . Measures which will be considered during
remedial design include densification of site soils to reduce their susceptibility to
. liquefaction and implementation of slope stability measures along the cut slope at the
edge of the tailings pile.
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Comment 91
A remediation company expressed the opinion that capping would require some sort of
retaining wall to contain the nearly-fluid material presently on the site and that no
deeply-rooted trees could be allowed 'because their rootS could penetrate and
hydraulically crack the cap. [August 92]
EP A Response
The exact design of the cap will be specified during the remedial design phase of the
project. Under the FS, it is conceptualized that the wall of the tailings pile along the
river will be terraced and utilize a retaining wall for support. Trees could be planted
on QUI without compromising the integrity of the cap by using specifically designed
planter boxes that confine the rootS.
Comment 92
A remediation company expressed the opinion that a solid cap or saturated soil cap
over the tailings site would contribute to e~treme surface water runoff wi)ich could
lead to flash flooding potential for the Jordan River during "cloud burst" ,situations. A
scenario was presented outlining the volume of water that would be channeled to
lower-lying areas and the resulting inundation of all strUctures lying in the flood path.
. The company also noted that during such an event, in itS opinion, the cap would also
be irreparably damagec;i. [August 92]
EP A Response
The design of the cap would include provisions to handle a 100- year storm event
without.damage to the cap. Run-on would be eliminated through the design of
diversion channels. Water on the cap would be collected and channelled to cause the
least damage possible.
Under the June 1992 proposed capping al,temative, a 24" vegetation layer would be
installed over the area of the cap. The purpose of this vegetation layer would be
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establish plant growth that would help stabilize the cap and protect the cap from both
wind and water erosion. The plant growth would also slow down run-off from au 1
in the event of a "cloud burst", and thus reduce the flash flood potential. The cap area
would drain much the same as a large park or pasture area.
This alternative also includes regrading of the tailings and the area along the Jordan
River prior to placement of the cap. The river channel in area of the cap edge would.
be stabilized. Both of these precautions would control runoff from au I. and greatly
reduce the chances of a cataStrophic disaster as predicted by the remediation company.
Comment 93
The Salt Lake County Board of Commissioners stated that the requirement of tOtal
isolation between tailings and the aquifer could only be achieved by removing the
tailings from their current location or by rolling back the tailings then replacing them
on a RCRA-type liner with accompanying leak detection systems. The cost estimate
for capping did not include the RCRA liner approach and therefore makes that
alternative invalid. Mr. Jorgensen. Midvale District Representative from the Utah
House of Representatives, asked if the capping proposal also involved sealing
underneath the tailings in order to prevent leaking. [June 92. August 92]
EP A Response
The capping alternative does not include a liner beneath the tailings. This technology
is not required because from a hydrogeologic and engineering standpoint. a lower liner
is not needed.
Comment 94
Mayor Dahl expressed concern about the potential impactS of capping after
implementation has been completed, including:
a) subsequent land use and imposed restrictions;
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b) wetlands and flood plain contamination:
c) zoning considerations:
d) adjacent compatible land uses and zoning;
e) relationship to Jordan River Parkway;
f) access - limited development potential:
g) institutional controls:
h) propeny ownership;
i) infiltration of contaminants into aquifer:
j) injury to health and welfare of valley inhabitants; and
k) monitoring and operation and maintenance costs after 30 years. [August 92]
EP A Response.
Future land use is not a criterion for remedy selection under CERCLA and EP A is not
selecting the remedy based on land use planning (but has considered it in the remedy
selection process). The primary criteria for remedy selection are protection of public
health and the environmenL The selected remedy will achieve these criteria by
preventing any offsite migration of contaminants and eliminating the potential for
exposure.
Comment 95
Former Congressman Owens stated his opinion that capping does not adequately
comply with the CERCLA mandate to protect public health and the environment. He
stated that capping does not address the future hazards of ingestion. inhalation. and
direct skin contact with contaminated soils and dust which could result from erosion
and deterioratior of the cap. Pedestrian access to the site proposed under th.;7
alternative also creates this risk of exposure and could accelerate the deterioration of
the cap. Former Congressman Owens also stated that capping would not reduce the
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toxic contamination already present in the Jordan River. The Jordan River is home to
cold-water game fish and supplies irrigation water in the vicinity of OU1. Capping
does not eliminate pathways by which persons could be exposed to heavy metal
sediment contamination. [July 92. August 92]
EP A Response
. .
The purpose of a Superfund Clean-up is to find a remedy that is protective of human
health and the environment. EP A has carefully analyzed the situation according to the
requirements and guidance provided by CERCLA and the NCP and fumly believes
that the cap will protect the public from the dangers raised by former Congressman
Owens. Specifically. the capping alternative includes continuous maintenance and
repair of the cap ,and a re-evaluation of the protectiveness of the remedy every five
years. This will protect the surrounding population from exposure to the
contaminants. The pedestrian access will be controlled and the cap will be designed
for such use. Included in the alternative is a groundwater collection and treatment
system. to be implemented if necessary. This will adequately protect the Jordan River
from future contamination.
Comment 96
Mayor Dahl commented that in his opinion capping would not reduce the volume of
contaminants at OUI. which was one of the criteria evaluated for remedy selection.
Capping would only reduce air pathways of contamination. [January 91]
EP A Response
Installation of a soil cap does not reduce the toxicity or volume of contaminants within
the tailings body. A soil cap would decrease the recharge to the tailings. however. and
thus decrease the mobility of contaminated fluids leaking into the aquifer. EP A's June
1992 preferred alternative includes a provision controlling groundwater migration from
the upper sand and gravel aquifer below the tailings. if necessary.
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Comment 97
A commenter stated that covering the tailings would halt the beneficial "wicking" or
evaporation of water. and would result in a saturated condition under the cap. The
saturation would magnify the potential for liquefaction during an earthquake. whereby
the semi-fluid soils could not be retained and would flow into the Jordan River.
[January 91]
EP A Response
Evaporation of water does take place at the exposed surface of the tailings; however.
the source of this water is recharge from snowmelt and rain during wetter portions of
the 'year. Capillary tension is not a sufficient force to move significant quantities of
water upward from the saturated zone within the tailings. The depth to the saturated
zone within tailings is at itS- shallowest at well #003 about 20 feet.
Installation of a cover or soil cap on the tailings would !!Q! result in a greater degree
of saturation within the tailings. The quantity of recharge would decrease from the
current condition. resulting in a drop in water level. Seepage from the base of the
tailings is the primary discharge path for water in the tailings.
Comment 98
In commenting on the June 1992 OUI Proposed Plan and the May 1992 OUI Draft
Final FS. UDEQ stated that the capping alternative does not remove or provide a
barrier to separate the source of potential continual groundwater contamination.
UDEQ added that contaminated water in the tailings could not be feasibly removed
due to geochemical characteristics of the tailings, thus suggesting a continual source
for groundwater contamination. UDEQ asked how this potential source of continual
groundwater contamination would be addressed and if it could be remediated when
and if the upper sand and gravel aquifer i.; treated'? [August 92]
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EP A Response
The source of contamination is not removed under the capping alternative. however.
the contribution of contaminantS will decrease over time as recharge to the tailings is
diminished. The selected remedy includes a provision for pumping of contaminated
groundwater from below the tailings, if necessary.
8.
Alternative 3 -. Excavation/Transportation/Containment Technologies
a. General Comments
b. Excavation
c. Transportation
d." Containment
a.
General Comments
Comment 99
A PRP asserted that the FS ignored risks to public health and the environment.
especially through airborne emissions, created by excavation and off-site disposal and
incorrectly concluded that the alternative is implementable. [November 90]
EP A Response
EP A agrees that any handling of the tailings would be difficult, but feels that the
construction activities proposed in the excavation alternative are technically feasible
and would adequately handle the tailings material.
EPA concurs that the potential for dust emissions during construction activities is high.
however, EP A stated that the emissions could be controlled with an extensive dust
abatement program and has included the cost for such a program. In addition, it was
assumed that a significant portion of the tailings would be moist or wet and would not
be susceptible to migration by wind. Additionally, the use of a pipeline would
decrease the risk of injury associated with truck traffic.
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Comment 100
A PRP commented that EP A underestimated costs and the time it would take to
excavate and remove the tailings. The PRP stated that EP A assumed that the tailings
could be excavated and removed in 7.5 years, but that assumption failed to account for
the receiving capacity of the disposal facility. The PRP expressed the opinion that
EP A had significantly underestimated the cost of excavation and off-site disposal. and
that the cost estimate for the removal and disposal option was incorrect. [November
90]
EP A Response
EPA's estimates of cost were developed at a -30% to +50% level of accuracy, and
were based on applicable regulations and standard design practices. See comments
and responses in Section 2, Cost Issues. Final costs for the excavation and off-site
disposal alternative will depend on the location of the off-site disposal cell. as
determined by the State.
Comment 101
A remediation company expressed itS opinion that the environmental impactS for
Alternative 3 in the June 1992 Proposed Plan appeared to be tOtally exaggerated.
[August 92]
EP A Response
EP A believes the environmental impacts ot all the alternatives were determined based
on sound engineering judgement. The impacts were discussed with expens in all areas
of hazardous waste remediation and risk assessment. The environmental impacts
determined for Alternative 3 are consistent with the rest of the alternatives.
Comment 102
A remediation company stated that time requirements estimated for Alternative 3 were
overstated. but these may have resulted from erroneous slurry line operating
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assumptions. With 24-hour slurry line operations. the commenting company's
estimated project completion was within 4.5 years. [August 92]
EP A Response
It is not realistic to assume that a pipeline could operate nonstop for 4.5 years. Time
is needed for maintenance and repair. The material being pumped is very abrasive and
can potentially require a great deal of maintenance. Funher, continuous operation
assumes that all facilities, both at the slurry making end and the receiving end. are
perfectly designed to handle this continuous flow. It is highly unlikely that all these
systems will work in complete harmony.
It maybe possible to decrease the time required for the removal of mine tailings under
Alternative 3 using a 24 hour/day and 7 days per week work schedule. however
because the total number of man and equipment hours would remain the same the
costs for perfonning this work would remain approximately the same.
Comment 103
A remediation company noted that EP A appears to have downsized its estimates of
volumes of tailings and underlying soils from 12.355,000 yards of tailings. 200.000
yards of OU2 soils. and 1.344,000 yards of underlying native soils to a cumulative
total of 10.6 million cubic yards of tailings and soils. The company further noted that
this volume change would also accordingly downsize private bids submitted for
excavation and removal of the tailings. [August 92]
EP A Response
All alternatives were costed using the same volumes' thus they were compared on an
equal basis. The estimates preformed by private bids do not affect the alternative cost
compansons.
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Comment 104
A remediation company considered the costs of treatment of contaminated
groundwater to be significantly overstated. The company thought that if groundwater
was used for slurry water, then discharged at the disposal site to the Class VI waters.
costs of treatment at the Sharon Steel site would be eliminated for the first 4-1/2
years. This would include the 500.000 and 250,000 gallon storage tanks and
operational costs of the activated alumina treatment process. Only the incremental
costs of treatment prior to Oass VI discharge need to be added back during the
excavation phase. The company assened that following excavation, levels of
groundwater contamination could be determined and appropriate treatment could be
designed and built if necessary. [August 92]
EP A Response
The assumptions made by the remediation company can not be substantiated at this
level of study. It can not be assumed that groundwater can be used or is of sufficient
quantity for use in rnaking the slurry. Other water rights would have to be
investigated. It can not be assumed that no treatment of water would be required if it
is discharged to a Class VI water. The discharge would be highly concentrated with
contaminants and would require some treatment. It would be unrealistic not to include
the cost of treatment at this point. This would not provide an equitable comparison of
alternatives since the potential exists for additional future costs.
Cominent 105
Given the 30-mile radius criteria set by EP A, Mayor Dahl claimed that it would be
very difficult to find an appropriate tailings disposal site. He noted that there were
receiving locations outside of the 30-mile radius that should be evaluated, and further
commented that EP A's setting of such tight parameters would make the relocation
potential almost impossible. [August 92]
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EP A Response
EP A is willing to consider other sites outside the 30-mile radius. The distance was
used as a basis to compare the three transportation methods. pipeline. trucks. and rail.
A disposal location outSide the 30-mile radius may not be feasible technically if the
slurry pipeline is used. and would effect the trucking or rail cars transportation
methods.
Comment 106
In summarizing the post-remediation impacts effects of each of the proposed
remediation alternatives on Midvale. Mayor Dahl highlighted the following post-
cleanup issues about the impacts of excavation. transportation. and containment:
a) subsequent land use;
b) wetlands and flood plain issues;
c) present zone I-I:
d) adjacent land uses and zoning;
e) river reverting back to an old course;
f) extension of infrastructUre into area;
g) any potential institUtional controls; and
h) resultant propeny ownership. [August 92]
EP A Response
FutUre land use is not a criterion for remedy selection under CERCLA and EP A is not
selecting the remedy based on land use planning (but has considered it in the remedy
selection process). The primary criteria for remedy selection are protection of public
health and the environment. The selected remedy will achieve these criteria by
preventing any offsite migration vf contaminants and eliminating the potential for
exposure. .
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The cap will be designed to withstand a 100-year storm event without damage.
Suitable engineering controls will maintain the river in itS present course.
8b
Excavation
Comment 107
A PRP stated that the draft FS failed to consider the impactS of dust suppression on
groundwater. surface water. and wetlands by adding significant water to the tailings
during excavation and handling. [November 90]
EP A Response
The amount of water used for dust suppression will be insignificant. The use of water
or other dust suppressant will be a design issue and will have to be controlled.
Comment 108
UDEQ asked for an elaboration on the dragline excavation .process. [August 921
EP A Response
A dragline is basically a large crane with an excavation bucket attached to the end of
the lifting cable and to a second winch on the crane. The excavation bucket is "cast"
out into the area to be excavated and pulled or dragged back to the crane which fills
the bucket with the excavated material. Draglines are used in the mining industry to
remove overburden off of coal seams in strip mining operations. Draglines are
frequently used to dredge materials that are under or saturated with water. In the FS
for au 1. it was assumed that a dragline would be used to excavate tailings. The
specific details of this process would be developed during remedial design.
Comment 109
A 'remediation company claimed that the estimated effectiveness of Alternative 3 as
noted on page 3-23 of t,he May 1992 FS was underestimated due to the assumption
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that a dragline would. be used for excavation. which would produce a dust level greater
than that which. would be produced by specialized excavation machines. The company
continued to state that the type of excavation method used was a key element in both
the protection of human health during removal and the efficiency/costS of the project.
The company assened that the three removal methods evaluated did not include
"Specialized Custom Excavation Equipment" specifically designed and built for such a
project. As detailed in the company's proposal, Specialized Custom Excavation
Equipment minimizes the working face of the excavation and minimizes dust and
noise. While the draglines and heavy equipment evaluated in the FS are readily
available and their capital and operating costS are easy to acquire. custom machinery
built to excavate this specific site is not only safer and more economical. but it would
minimize dust and noise as well. Consequently. the company believes that the risks
associated with dust generation to both the community and the workers would be
minimized. [August 92]
EP A Response
The consideration of specialized excavation equipment is not appropriate at this level
of investigation. To make the comparisons equitable. commonly available equipment
must be used in development of the alternatives.
For cost estimating purposes it was anticipated that a dragline would be used to
excavate the mine tailings. The assumption. was made based upon observations made
during the remedial investigation for OU 1 when several areas were noted to be
. satUrated and normal equipment could not drive over these areas. It was not our intent
to dictate the type of equipment that a remediation conn-actor would have to use on
this site, but we felt that it was hig~ly possible that this equipment would be used.
As for the issue of the generation of dust and subsequent dust conn-ol, EP A has no
information as to how much dust would be generated by the excavation process
proposed by the remediation company. No matter what type of excavation and dust
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suppression methods used. the air will still need to be monitored to assure that the
production of dust does not exceed the TL V s established for this projec;t.
Comment 110
A PRP stated its observation that the bulk of the tailings consists of fine particles that
are wet or saturated and difficult to excavate using ordinary excavation equipment. In
the opinion of the PRP, EP A . ignores problems associated with the stability of the
tailings. The PRP believes that parts of the tailings piles would not suppon heavy
equipment. and excavation may destabilize additional portions of QUI. Additionally,
the PRP stated its belief that the draft FS incorrectly assumed that excavation could be
accomplished with a dragline and conventional equipment and said that the draft FS
ignored the need either to dry the tailings before excavation and transpon or to
pr?vide specialized equipment to remove the tailings from equipment and rail cars.
[November 90]
EP A Response
The issues raised in the above comment are too specific to the design of the
excavation process for consideration in the FS. These are not insunnountable
problems and can be dealt with by use of conventional methods. These issues would
be addressed during detailed desigri.
8e
Transportation
Comment 111
The operating schedule of the slurry line was stated in the FS to be 8 hours per day
for 270 days per year. Other proposals have recommended operation for 24 hours per
day based on ease of stan-up and shut down. UDEQ asked EP A to review the
standa.id operating parameters of slurry transportation to insure that J hours of
operation is standard practice and could be accomplished. Additionally, a site
remediation company stated that the estimated effectiveness of Alternative 3 as
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. -.- .. ...
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outlined in the FS was not as high as it should have been because of an error in
assuming the duration of the project at 6.5 years rather than a 270-day season totalling
3-5 years. This error also results in a serious overstatement of costs throughout the
entire analysis. [August 92]
EP A Response
See response to Comment 102.
Comment 112
While commenting on the slurry/transpon of tailings, a remediation company outlined
the following: a) at least 10,850,000 tons of tailings must be transferred: b) the shlITY
volume must be at least twice the bulk volume of the tailings: c} a slurry plant must
be built having a capacity to receive the return water while preparing slurry for output:
and a retention system must equal the volumes of all fluids and the slurry: d) if a 13-
inch line is used, then the static volume is 6.89 gals per linear foot or 36.379 gal per
mile:.a 26-mile long pipeline, not counting pump dead volumes, is 945.859 gals.; e)
only 1/3 to 1/2 the volume is tailings, thus 472,929 gals or 60,631 cubic feet (2.245
yds or 2,919 tons) of tailings would be in the pipe at any instant in time: f) moving
the tailings would require the transfer of 7,430 complete pipeline volumes to move the
estimated tonnage of tailings at 50150 water-to-solids slurry mixture; g) the number of
days to complete this work is at present unknown to this writer: h) 8,246.000 yards of
solids need to be transferred or 16,492,000 yards of slurry would need to be moved: i)
if a flow rate of 10 mph for the solution. could be achieved, 2.6 hours would be
required to move one pipe volume, and 9.2 volumes or 26,855 tons of tailings could
be transferred per 24 hour shift: requiring 404 days of operations at this level.
The company provided similar figures for a 3-inch pipeline scenario and concluded
that while a 13-inch pipeline is riddled with political, technical, and logistical
concerns, the commenter believes a 3-inch pipeline is simply not realistic. [August 92]
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EP A Response
EP A does not concur with all of the above calculations. However. if a slurry pipeline
alternative were to be built. a costlbenefit analysis would be performed during the
detailed design stage to determine the most advantageous pipe size given all input
parameters such as routing, pumping pressures. velocity. etc.
Comment 113
A remediation company stated itS opinion that transferring tailings to another site does
not resolve the problem, but merely relocates the toxins. The company pointed out a
number of technical problems inherent in pipeline/slurry transfer of tailings to a site
such as Cedar Valley: 1) the likelihood of using the railroad corridor is at best
remote: 2) damage by seismic. natural. or human-related efforts would require constant
surveillance and overwhelming security problems: 3) pumps of very large output
requiring tremendous energy consumption would be required to maintain this very
heavy tailings as a slurry and as a mobile fluid; 4) these same pumps or similar types
would be required to prevent settlirig of the "heavies" at geographic depressions and
irregularities: 5) the heterogeneity of the tailings would require a highly sophisticated
separation technology at the origin: 6) slurrying using Jordan River water would
require a volume equal to or greater in weight than the tailings; 7) there must be a
return line from Cedar Valley carrying the decanted water which now must be
considered hazardous: 8) repair and maintenance would likely equal the cost of
constructing the pipeline. (This pipeline. which would also be considered hazardous
would need to be removed after slurry transfer is complete); 9) disposition of the
water after all transfers were complete would result in the establishment of a special
water treatment facility; 10) the logistics of building a paired pipeline system over the
existing topography is almost overwhelming; the lines must be built and pressurized to
lift the slurry from the site which is very nearly at the lowest point in the region over
a range of hills betWeen Utah W1d Cedar Valleys and thence downward to a receiving
site in Cedar Valley; 11) the slurry must be dewatered in Cedar Valley and the water
returned to the point of origin; 12) the slurry is very abrasive which would require
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frequent pipe section replacement and shutdown; 13) a decanting facility would be
required at the point of receipt; 14) water needs and usage would be high. especially
in settling ponds or tanks needing a volume equal to the constant needs to maintain a
full return line; 15) weather conditions which often turn frigid could cause ruptUre and
leakage; 16) due to the near-colloidal natUre of the particles. a system of separating
. the settleable solids from the suspended solids would need to be devised; 17) leakage
detection would be needed; 18) railway leakage near residences is a potential; 19) the
pros and cons of a buried pipeline need to be assessed; 20) a leak in pipeline
paralleling the Jordan River could contaminate the river. downstream irrigation waters.
and railroad property. [August 92]
EP A Response
EPA concurs with many of the concerns stated above however, most if not all could
be successfully overcome during detailed design.
Comment 114
A remediation company noted that the FS costs of slurry transportation were in its
opinion, vastly overstated, possibly due to assumptions which betray an understandable
lack of knowledge of local conditions. The company cited the example of on-site
wells as the source of slurry makeup water. The least expensive source of water is the
Galena Canal, owned by MRRC, followed by surplus canal water which could be
leased and pumped from the adjacent Jordan River. [August 92]
EPA Response
The issue of water rights, both senior and junior, and availability would have to be
addressed during detailed design of the alternative. At the FS level of study, EPA is
required only to be able to state that water exists in sufficient quantity to make the
alternative viable. It was assumed in the development of the slurry transport
. .
alternative that sufficient water would be available at no additional cost. except for
pumpmg.
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Comment 115
A significant mistake occurred in the estimate of sluny line construction costS.
according to a remediation company. The estimated unit cost of $291 per foot is
nearly three times the cost this engineering company arrived at through consultation
with sluny line design and construction expens. These costS were verified by an
experienced local major constrUction firm. using the company's specific alignment.
which has several unique transportation corridor. utility. and waterway crossings.
[August 92]
EP A Resporoe
The cost of the sluny line construction costS include the costS for obtaining right of
way permitS: a transport pipe with a containment pipe around it; a retUrn water pipe
with containment pipe around it: a leak detection system: and the costS for burying the
pipe during installation and digging up of the pipe during removal: it was assumed
that a certain number of city street miles would need to be removed and replaced both
durjrig installation and removal operations. These assumptions were made because the
theoretical location for the new disposal cell is not known. The costS used by the
remediation company assumed that a location in the Great Salt Lake would be used
and approved. EP A felt that this was a premature assumption.
When the alternative and costS were developed. no specific route was considered. The
routing that is proposed by the remediation company has not undergone any legal
scrutiny and EP A does not have sufficient information to know if it would be feasible.
The proposed pipeline would require double wall for containment and have leak
detection equipment along the entire route. This would greatly increase the unit cost
of construction.
Comment 116
A remediation company was perplexed regarding how the FS could suggest a cost of
527.700.000 for sluny mixing and dewatering facilities. The company's estimated
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coSt was at least $20 million less. which cannot be attributed solely to the company's
not requiring return flow of slurry decant and consequent treatment for discharge to
Class IV water. [August 92]
EP A Response
The cost for the slurry mixing and dewatering facilities includes both the construction
and the demolition of the facilities. These costS also include the purchase of the
conveyor belt system. with feed hoppers that will be used in the excavation of the
tailings material.
Comment 117
A remediation company thought that slurry line transportation was appropriately
selected in the May 1992 FS as the most implementable and least costly removal
alternative. However, the company stated that the study erroneously stated that if an
acceptable disposal site was found in proximity to the existing rail line which connectS
with the mill site, the rail option should be evaluated. The company's study of the rail
option showed that: 1) rail transpon was substantially "more expensive than slurry line
transpon (even for a shon-term project), as evidenced by Kennecott's decision to
abandon rail transpon of copper ore/concentrate and tailings, and replace it with a
slurry line; and 2) the operation of mechanical rail car loading facilities needed to
efficiently move the tailings would cause an unacceptable level of noise. dust. and
disruption to the residentS of Midvale living near the existing rail lines. The
remediation company thought that even if a disposal site were found near an existing
line, rail transpon would not be a viable alternative. [August 92]
EP A Response
EP A has not be given a copy of the commenter's study on the cost of a rail line
transpon system and therefore is not able to comment on the specifics of that
document. It is however, premature to state that rail transportation would not be
viable until an exact location of a disposal site is determined. The use of a slurry
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pipeline in the development of Alternative 3 was based on a comparison of pipeline.
. .
rail. and trucking without a specific site in mind.
Comment 118
UDEQ requested further exploration of the possibility of railroad transpon of tailings
to an off-site location. noting that rail transpon could be as cost effective as slurry
transpon based on tWo proposals provided to the State. [August 92]
EP A Response
EP A does not disagree with the possibility that rail transpon could be as cost effective
as a slurry pipeline. However, this can not be evaluated until a defmite disposal
location is determined. There are many factors which could totally eliminate either
method based on available routes to the disposal location.
Comment 119
A remediation company noted the following legal and regulatory problems inherent
with the slurry/pipeline procedure that would transpon tailings to a site such as Cedar
City: 1) liability insurance for such a project would be prohibitive in cost even if a
carrier could be found: 2) permitting at the municipal, State, and federal levels would
take many years. if such permitting could even be granted: 3) the Not In My Back
Yard. (NIMBY) attitude so prevalent today would put the permitting issues in court
for unduly long periods: 4) litigation would consume all private investment funds: 5)
the receiving site must meet all guidelines for a hazardous waste storage site, which is
extremely expensive: 6) environmental impact statements could take several to many
years to develop and must be accepted during the Public Input Phase which could take
even more time: 7) a decade or more could elapse just in litigation. [August 92]
EP A Response
EPA shares many of the concerns stated above. EPA has charged the State of Utah
with the task of locating a disposal site that is acceptable to the surrounding
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community and would be able to meet all permitting requirementS. The State has the
responsibility to demonsttate that the site is acceptable to all those concerned and
would be available to begin consU"Uction of the cell in a timely manner.
8d
Containment
Comment 120
A remediation company observed that the FS costS associated with land acquisition,
excavation, double liners, and leak detection systems (commonly associated with
RCRA landfills) for containment sites were based on certain assumptions. The'
commenter stated that at most potential locations, these costS might be valid: but at
one specific site, these costS appear to be unnecessary and thus could offer a
significant cost-savings potential. Commenter noted that sites at which these items are
not required would provide significant cost savings potential. In a formal proposal to
the State of Utah and EP A, the company identified such a disposal site that existS
within the 30-mile radius. . At this site. the natural soils (clays) have permeabiliues
equal to that required for a hazardous landfill clay liner (3-feet of 1O-7cm/sec clay). In
addition, the local groundwater is brine - not used for consumptive purposes. If a leak
were to occur, the natural chemical precipitation process of the waters would
neuttalize the heavy metals. Land acquisition costS are negligible. and a residential
exposure scenario is nonexistent and prohibited by State regulation. Required
excavation is reduced from 3,000 acre-feet to less than 1,000 acre-feet. [August 92]
EP A Response
No definite site has been approved by EP Aor the State of Utah. The fact that the
surrounding water is brine does not alleviate the reqUirement for a liner and leak
monitoring equipment. It would be in violation of RCRA to design a cell that would
allow leakage no matter what type condition of the immediate surrounding
environment. The proposed site has not gone through the public acceptance process
nor strict engineering analysis.
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Comment 121
A resident of Midvale requested clarification of the 30-mile radius designated for
disposal of excavated materials and stated there were adequate disposal cell sites to the
west that have previously received Vitro deposits. [June 92]
EP A Response
A distance of 30 miles was used in order to retain the greatest variety of transportation
technologies. At distances of greater than 30 miles the slurry line option no longer
appears implementable.
9.
Fixation/Chemical Treatment and Vitrification
Comment 122
Former Congressman Owens commented that EP A did not justify its exclusion of
chemical treatment as a viable remediation alternative, especially when such.
technology had been successfully employed at another site in the area and offers a
cost-effective, permanent remedy. [July 92]
EP A Response
Chemical treatment was fully evaluated in the FS. The apparent site to which former
Congressman Owens is referring was extremely small in volume. The stUdy
performed by EP A concluded that due to the characteristics and gross volume of the
existing tailings pile, chemical treatment would be prohibitively costly. Additionally,
the capability to adequately treat the tailings to a depth of over 50 feet is questionable.
Comment 123 .
A patent attorney/systems engineer with a background in biological systems for
mineral processing, and the ph.sident of a solid waste solidification company raised
the following points about EP A's decision-making process and criteria for the fixation
alternative. Why did the cost of fixation change from $116 million in the original
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EPA eStimate (Proposed Plan July 1989) to $2 billion in recent proposed plans? Was
fixation dropped as a solution because of itS high cost. even though it was the only
alternative defined by EP A that pennanently solved the waste problem? Did the
asn-onomical cost estimate for fixation influence the PRPs to settle on a quick fix
alternative? [December 90, January 91]
EP A Response
A more detailed study on the types of fixation chemicals was performed between
publishing the original Proposed Plan and the CUlTent revised issue. The study found
that the least costly fIXation agentS would cause the volume of the tailings to double.
Given the very large volume of the existing tailings and the limited size of the OUI
site, this was unacceptable. In order to minimize the increase in volume, a more
costly fIXation agent would be required. Further. the process of completely mixing the
agent with the tailings to a depth of over 50 feet is difficult and costly. The
alternative was eliminated from consideration because of the high cost and difficulty to
implement compared to the other alternatives.
Comment 124
A remediation company stated itS opinion that fIXation was not a reliable remediation
option for the following reasons: 1) the cost is many times higher than a metals
exn-action procedure or capping; 2) the final bulk of the material has been calculated
to be 20% greater than the present tailings or roughly equal to seven of the Great
Pyramids: 3) flXing is not as effective as claimed, especially in moist and moderate to
highly-saline soils as could be evidenced by metals leaching from sidewalks in both
Salt Lake and Davis counties: 4) the area would be rendered useless for any future
generations: and 5) the tailings would require extensive handling, which would be put
to better use in a metals exn-action process. [August 92]
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EP A Response
Fixation was studied and it was detemrined that the fixation alternative did not meet
the nine criteria for selecting a remedy set fonh in the NCP, as well as the other
alternatives. Therefore. flXation was eliminated from further consideration.
Comment 125
When commenting on vitrification, a remediation company stated. itS opinion that this
process used tremendously high voltage and would be prohibitively expensive while
inundating the site. Cenain metals. such as arsenic. cadmium, lead. mercury, tin. and
others vaporize at less than vitrification temperatures. TIris could create hazardous
vapors for all residentS downwind of QUI as well as for the people on QU 1. [August
92]
EP A Response
Vitrification was eliminated from consideration as a viable alternativ.e in the screening
process of the FS. It would be very difficult to effectively treat the entire tailings pile
with electric current. EP A agrees with the concerns of the commenter. and eliminated
vitrification from consideration in the FS.
Comment 126
The president of a hazardous waste solidification company stated his opinion that
leaching of contaminantS into the groundwater could be stopped only at the source by
chemical stabilization (fixation) of the soil to render it unleachable. He believes that
capping would not obtain leach resistance. would only be effective in reducing wind-
borne dust movement and would not meet the State's environmental criteria. TIris
commenter pointed out that EP A recognizes fixation as a viable process and that the
process meetS CERCLA statutory requirementS and remediation criteria. In
conclusion, he stated that he believes private sector tedu:Jlogy existS to permanently
remediate the QUI site at a fraction of the cost of EPA's fixation alternative.
[December 90]
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EP A Response
The primary reason that the cost for the fixation alternative was so high was that the
proprietary fIxation agent chosen resulted in little or no increase in volume of the
tailings. Because OUI contains such a large volume of contaminated soil and tailings,
limited volume expansion could be tolerated. Proprietary fixation agentS that result in
little or no volume expansion are also the most costly.
The comrnenter indicated his opinion that the private sector technology is available "at
a fraction of the cost of EP A's fixation estimate." This could be the case if the
following assumptions are correct: 1) its product does meet the environmental criteri~
2) it attains the expected percentage volume increase of only 5 - 30%: 3) the cost per
ton (which was not provided by the comrnenter) is in fact a fraction of the cost of
EP A's fixation agent.
However, even if these assumptions hold, and cost per ton is 50% lower that the cost
used in the FS ($37.50 per ton instead of $75), the cost for fixation alone is still
approximately $642,000,000 for the volume of tailings at the OUI site. When this
cost is added to the costS for related remedial actions of this alternative, including
indirect costS and annual/periodic costS, fIXation remains a very costly alternative.
10.
Reprocessing
Comment 127
UDEQ asked if the BOM study had determined that the quality of metal that could be
recovered by the benefIciation process was not sufficient to be salable? And. does this
mean that any metal recovered by beneficiation could not be sold? [August 92]
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EP A Response
The BOM stUdy only looked at the recovery of specific precious metals such as gold
and silver. It was the conclusion of the BOM that the value of the metals that could
potentially be recovered was far below the cost required to recover them.
Comment 128
Mayor Dahl expressed concern about the potential impacts of reprocessing:
a) subsequent land use;
b) wetlands and flood plain issues;
c) present zone I-I;
d) adjacent land uses and zoning;
e) river reverting back to an old course;
f) extension of infrastructUre into area;
g) any potential institUtional controls;
h) propeny ownership;
i) any resulting contamination to aquifer or wetlands; and
j) continuation of operating and maintenance costs after 30 years. [August 92]
EP A Response
FutUre land use is not a criterion for remedy selection under CERCLA and EP A is. not
selecting the remedy based on land use planning (but has considered it in the remedy
selection process). The primary criteria for remedy selection are protection of public
health and the environment. The selected remedy will achieve these criteria by
preventing any offsite migration of contaminants and eliminating the potential for
exposure.
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Comment 129
Based on review of the Bureau of Mines test data. a Texas mining company
submitted written comment stating itS ability to economically reprocess the mine
tailings and as defined by EPA standards. [July 92]
EP A Response
EP A has not received a detailed description of the process proposed by the commenter
to reprocess the tailings. The BOM is the nation's recognized leading expen in this
type of work with extensive research facilities which are unequaled by any private
company in the mining industry. In 1989. EPA had openly requested proposals from
remediation companies to describe their method of reprocessing the tailings. To date.
no remediation firm has adequately responded to the criteria carefully specified by
EP A. The fact that reprocessing is not viable as a remediation alternative at this site
was clearly demonstrated in the BOM study.
Comment 130
The Midvale resident who proposed rail transpon of the tailings to the Fitzgerald farm
further revealed that his selection of the site was based on itS proximity to both water
and power supplies that would allow private enterprise to have access to the tailings
for reprocessing. He noted the reprocessing successes of the Merker tailings and
stressed the value of keeping the Sharon Steel tailings available for advances in new
technologies. [June 92]
EP A Response
EP A agrees that future technology advances could provi~e for a suitable method to
reprocess the tailings. The tailings would be available for such a process no matter
whether they are capped in place or excavated and placed in a containment cell.
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Comment 131
A remediation company stated itS opinion that only one viable solution to remediation
of the Sharon Steel tailings was currently being offered -- that of extracting the metals
on site. This solution would solve the multitude of problems presented by the other
methods. free the land from environmental distress, and return the land to the
community as a functional and valuable tract of real estate without the "onus of the
toxins." [August 92]
EP A Response
EPA contracted the U.S. Bureau of Mines (BOM) to study the potential for
beneficiation of the existing tailings. Beneficiation is the first step in reprocessing.
The BOM study concluded that some beneficiation could occur, however, the
remaining by-product would still be considered a hazardous waste and the post-
beneficiation tailings volume would still be significant. Therefore, the dilemma of
having a large volume of hazardous waste to contend with would not be solved, even
after incurring. major costS associated with beneficiating the tailings. The minerals that
could be reCovered would be of insufficient quantity and quality to have any
commercial value. For these re.asons, beneficiation and subsequent reprocessing was
eliminated from consideration.
Comment 132
The Salt Lake County Board of Commissioners recognize that while total removal of
the tailings, in their opinion, is the best alternative, it is extremely costly. They
appreciate that other alternatives, such as reprocessing, have merit and are less costly
than the alternative of total removal. In 1990. they strongly urged EP A to further.
study the value of the reprocessing alternative. If reprocessing is the chosen
alternative, the Conunissioners expressed their opinion that it must result in
unrestricted development on the tailings site. [Gctober 90]
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EP A Response
Referencing the response to Comment 132 above. after beneficiation. a large volume
of hazardous material would still be presenL This material would have to be stored
somewhere and the Sharon Steel site would be the least costly since no transportation
costS would be incUITed. Thus at least partS of OUI would remain unavailable for any
developmenL
11.
Alternate Proposals
Comment 133
A commenter at the public meeting questioned why the Sharon Steel tailings could not
be deposited at a Kennecott site. [June 92]
EP A Response
Kennecott has indicated that they will not accept the wastes.
Cominent 134
A remediation company stated that using the tailings to build a causeway from
Antelope Island to the South Shore failed to take into account the corrosiveness of the
water in the lake or the effectS of wave action. According to the commenter. the salt
in the water would defmitely leach out toxic metals at levels that would render the
lake to be regarded as a hazardous waste dump. According to the commenter.
encasing the tailings in a so-called impervious coating merely exemplifies naivete.
Further. the commenter stated that the waters of the lake have proven that no man-
made strUctUre could withstand the physical and chemical impactS for extended
periods, let alone a narrow causeway. [August 92] .
EP A Response
The proposal to utilize the tailings to construct a causeway to Antelope Island was
suggested by a private company and was not initiated, or endorsed. by EP A. Before
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any such proposal could be considered, an in-depth study would be required to
analyze the long term effectS of depositing the tailings in the Salt Lake. Many other
details would need to be considered also. EP A has not included this proposal as a
considered alternative.
Comment 135
The legal representative of a holder of groundwater rightS adjacent to the Great Salt
Lake stated objection to any plans to dump Sharon Steel tailings into the Great Salt
Lake for fear of adverse effectS on water and propeny rightS. [May 92]
EP A Response
The response to Comment 134 above applies to this comment as well.
Comment 136
A new resident to Midvale, who indicated he is experienced in design and ene:ineerine:
,--
of .tailings removals. requested additional review of his proposal to move the Sharon
Steel tailings via the Rio Grande Railroad to old mine sites on the Fitzgerald farm'
west of Utah Lake within the imposed 3D-mile radius. This resident attested to his
ability to successfully perform such a task at a cost closer to the proposed capping
cost. [June 92]
EP A Response
EP A has not received a copy of this proposal.
Comment 137
During the comment period on OU2. several individuals stated that EP A should
consider innovative technologies for site reclamation, such as using a waste water
treatment technology developed at Pennsylvania State University, constrU ~~ng a berm .
to protect the Jordan River, or planning a waste water spray irrigation system that
would operate on a local golf course. In addition, they suggested that the old
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concentrator building would be an ideal site for a science and mining museum.
[September 901
EPA Response
EP A has looked into innovative technologies for site reclamation at Sharon Steel. The
use of water from the site for irrigation would be a component of the capping
alternative. Certain restrictions and precautions would be necessary depending on the
characteristics of the water. The buildings at the QUI site have been demolished.
VI.
Remaining Concerns
Comment 138
A Midvale citizen expressed concern about what would happen to a pioneer cemetery
on Sharon Steel propeny. [June 92]
EP A Response.
The cemetery in question is not located on the QUI site; rather. it is to the north on
the Midvale Slag site.
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