-------
can be found on page 5 of this document.
This summary also provides a distinction
between the fundamental changes and the
sirniiicant changes to the remedy which
are being proposed;
3.
Identifies key information about the Site
which provides the basis for modifying
the remedy. This information can be
found in the administrative record (AR)
for the Site; .
4.
EvaluateS the two remedies to explain
why UDEQ and EP A prefer the modified
remedy; and
5.
Encourages the public to provide input on
the remedies being considered and
provides information on how to do so.
UDEQ is the lead agency for developing cleanup
options and conducting cleanup work at the Site.
EP A is the support agency at the Site. Both
agencies coorriin::lfed development of this
Proposed Plan.
This' Proposed Plan was prepared in fulfillment of
the public participation requirements specified
FIGURE 1 \\ I
:::::.:::::::..::... \\
"':::::"'..11
~
-------
CKD is exempted from being a hazardous waste
under the Resource Conservation and Recovery
Act (RCRA), but it is a hazardolD substance
under CERCLA definitions. For this site, this
distinction is imponam because it means, among
other things, that the cm may be disposed in a
- less-expensive RCRA Subtitle D industrial
landfill as opposed to a more-expensive RCRA
Subtitle C luImrdous wilste landfill.
Between 1963 and 1983, CKD was collected from
the Portland Cement Plant in Salt Lake City, and
deposited as fill material at the Site. A few
hundred tons of chromium-bearing bricks from the
plant kiln were. also disposed at the Site along
with the em (the kiln bricks are a htzzDrdous
waste).
EP A placed the Ponland Cement Site on the
National Priorities List (NPL) in June 1986. In
order to more efficiently manage cleanup at the
Site, it was divided into operable units (OUs).
OU-l was the CKD. OU-2 was the connmm:lrNi
soils underlying the CKD and chromium-bearing .
bricks. The CODf:lmin:lred ground water, which
will be addressed in the fumre, was to be
deSignated as OU-3.
Lone Star Industries, Inc. conducted the remedial
investigation/feasibility study (RIIFS) for OU-l
under an agreement with the State. The Site was
characterized in several RI Reports. For aU-I,
the Phase I RI was submitted in July 1986. The
Phase n OU-l RI was submitted in July 1989 to
address data gaps in Phase 1. The OU-2 remedial
investigation/focused feasibility stUdy reports were
completed by UDEQ and EP A in
November 1991.
Together, the RIlFS studies determined the
approximate extent of em .CODf:lminMion at the
Site. The R1/FS studies also included assessmentS
of the risks posed by the Site cont:imin:lntS. One
of the conclusions of the risk assessmems was that
people are at risk to being exposed to alkaline
materials at the Site. For more information on the
Site risks, the AR should be consulted. The OU-l
risk assessment is published in ~e Phase n RI,
Volume 1, dated July 21, 1989, and the Record
of Decision (ROD) dated July 1990. The OU-2
risk assessment is published in the RI Repon for
OU-2 dated November 1991 and the ROD dated
March 1992. These documents are in the AR.
EPA and UDEQ selected clean-up. remedies for
aus 1 and 2 in RODs issued in 1990 and 1992,
respectiveiy. These remedies were designed to
mitigate or reduce Site risks. The OU-l and
aU-2 remedies are described in detail later in this
document. In 1992, after signing the OU-2 ROD,
EPA and UDEQ combined 9U-l and OU-2 for
remedial design and remedial action (RDIRA).
The OU-1 and OU-2 remedies are hereafter
collectively referred to as the combined remedy.
If necessary, ground-water connminMion will be
addressed by a future ROD. This determiDaEion
will be made following removal of the CKD and
connmin:lred soils.
This plan proposes to modify the combined
remedy.
ORIGINAL COMBINED REMEDY:
The original combined remedy is as follows:
v
Removal and off-sire disposal of CKD and
non-hazllrdous debris in a landfill buill
specijically for the Site CKD;
v
Removal. trearment, and off-site disposal
of contaminared soils and chromiIIm-
bearing bricJa;
Ground-wazer monitoring before and after
removal of CKD and contaminaled soil;
and
v
v
Implementation of institutiDlUIi contrrJu,
as required, to rem-ia jurure Jand-use at
the Sire. .
Estinuued Capiml Cosrr:
Estimated A1I1UItll O&M CoStS:
Estim/lled Present-WorTh Costs:
Estimated Tzme to implement:
W.517,{)()(J
$5,0fXJ
$19,329,{)()(J
5yetlTS
The original combined remedy involves removal
and off-site disposal of CKD . in a landfill
constructed specifically for the Site waste. Co-
disposed chromium-bearing bricks would be
separated from the CKD and temporarily StOred
on site. Co-disposed. non-hazardous mareria1s at
the Site, such as coDStIUction debris, would also
be removed and disposed in the landfill along with
the CKD. The landfill would be located in the
general vicinity of the Salt Lake Valley I .:Indfi11 in
: Itemized co. ---.....- ior the Original and Modi&d Combined p.......dn are publiahcd in a memorandum from Michac1
McCcncy (EPA) to tho Portland Ccmcat Site File dated Octobct 25. 1993. The lubjc:ct of the memorandum is "Cost E""".--
for the Portlaad Ccmc:at Proposed MocWicd CombiDcd R.a=dy.. Tbia II1CIDIIfIDdum is in the AR.
-3-
-------
Salt Lake County. It would be constrUcted as an
industrial waste. double-lined landfill.
Site soils conrnmin~ted above the action levels
would be excavated and treated on site. The
stored chrOmium-bearing bricks at the Site would
also be treated Q!l site. Treated materials woUld
be disposed off site at an appropriate facility. The
soil action levels would be. for lead. 500 parts per
million (ppm) and. for arsenic. 70 ppm.
Following removal activities. the entire Site would
be covered with at least 18" of clean backfill.
Ground water at the Site would be monitOred both
before and after removal of the em and
COJ1Dmin~ted soils. The purpose of this
monitOring would be to assess the need for
ground-water remerlimon in the fumre. .
If necessary, institutional controls in the form or
deed restrictions would be imposed. These
controls would be designed to control. as
necessary, future ground water and land use at the
Site. The need for instiunionai controls would be
assessed during re~ial design.
NEW. INFORMATION:
Since signing the Site RODs, EP A and UDEQ
have received new information which has
prompted consideration or a modified remedy.
This information is as follows:
a. Unsolicited Prouosais from Commercial
Landfills: Several existing commercial landfills
have contaeted UDEQ with offers to accept the
Ponland Cement CKD. Some of these offers
indicate that disposal in commercial landfills may
be as or more cost effective than constrUcting a
new landfill.
b. Public Conc.ems Renrdinl! Landfill
Location: Members and leaders of the Salt Lake
City and County comrmlUities have expressed
concerns over the possibility of locating a new
landfill in Salt Lake County.
Co Summitville Emel'2enev ResDOnse: In
December 1992, EPA began an emergency.
cleanup at the abandoned Summitville Mine in
soUthern Colorado. EP A has proposed the
Summitville site for listing on the. NFL. As part
of the cleanup activities at the Summitville site.
EP A may need to apply acid neutralizing agems at
the mine. EP A is considering the use of lime or
CKD for this purpose. If the Ponland Cemem
em is determined to be chemically acceptable
and can be transported to the ~e safely and
economically, EP A proposes to use it at the mine.
Use of the CKD for this purpose would not only
neutralize acidity of the mine waste but also
reduce the pH of the CKD. m~lrin~ the CKD less
hazardous. More information on this proposal can.
be found in AR documentS inciuding:
Snmmmrille Disoosal Dorton Cost Analvsis,
July 2, 1993, prepared by URS Consulams.1nc.
d. EPA Reevaluation of RCRA ADDlicabilim
Since signing the OU-2 ROD. EP A has concluded
that soils COrmlmin~teci with cm are exempt
from regulation under the RCRA Subtitle Claw
(as is CKD).' Previously, EPA took the position
that soils conrnminMM with CKD were considered
a iwzardous wasre and subject to RCRA Subtitle
C requiremems. One such RCRA Subtitle C
requiremem is that the waste be treated prior to
disposal. Under EPA's new RCRA interpld4tion.
soils that are conrnminM~ with CKD do mn need
to be treated prior to disposal.
e. Value Ensrineennl!: During value
engineering sessions, EP A and UDEQ made two
00St saving determinations:
1) Since soils dQ not need to be treated prior to
disposal. chromium-bearing bricks can be treated
less expensively off site than on site. The cost
savings would be due primarily to the reduced
amount of materials requiring treaIment. If only
the chromium-bearing bricks require tre'"""ent. it
becomes more expensive to design, mobilize, and
Operate a tr~tmeQt facility on the Site than to
send the materials to an existing treaID1em facility
off site.
2) Non-hazardous debris which has been disposed
along with the CKD at the Site can be safely re-
used at the Site as fill mareria1 following removal
of the CKD. Studies indicate that there are
approximateiy 300,000 cubic yards of constrUCtion
debris mixed with soil fill at the Site, mostly
concentrated in the west portion. Value
engineering indicates that ttiis soil and debris may
provide a safe and cost-effective fill material for
the Site.
, This cie=miDaIiaD was 8Ct forth in a memorandum from EPA Hc:adquancrsoifu:ca to EPA RcPm vm datcdJuac30. 1993.
The lubject of tbia mcmarudum is . C1ari1ic:al:ion of RCRA AppW:ation to SoU- Con""IIt;"".M by CcmaIt Kiln DUlL. 'This
~ is in &he AR. -4-
-------
v
v
MODIFIED COMBINED REMEDY:
Based on analysis oi the new information outlined
above. EP A and UDEQ propose the following
modified combined remedy:
Removal and off-sile disposal of CKD.
Disposal couid occur in various MJes of
facilities:
Off-sile disposal 01 coTl1a1llinawi soils
withoUt prior rrearmenr:
v
Qjfsire rreatmenr and disposal 01
chrmnium-bearing bricks:
v
&JJg of non-hozardous'debris as Sire fill
material:
v
Ground-warer monitoring before and after
removal of CKD anti coTl1a1llinawi soil:
and
v
ImplementDlion of insrinJrioruzi conrrois.
cis required. ro resmer furure land-use. Ql
rhe sire.
EstimtJzed CApimi Com:
EstimtJzed Annuai O&M CoSIS:
EstimtJzed Presenr- Worm Com:
Estimated Tune 10 Implement:
$21. 781.{x)()
$5.{X)()
$18.641,{X)()
3-5 yean
SUMMARY OF CHANGES TO COMBINED REMEDY
.~:f:;:~!r(:.,:""""",',.di:::Orij;nSal:':.COiDbiJie.[Remedy""',
i)mftAlftllfttJd ChaDges:
o
Treat conhl.........M soils to meet 13Dd-ban
resuicUODS (apply RCRA Subtitle C to soils);
ami
The differences betWeen the original and proposed modified combined remedies are summarized
below. This summary also indicates which changes to the remedy EP A and UDEQ consider
fundamental changes rather than silrnificam changes:
o
Non-hazardous debris at the Site is to be
removed and disposed off site.
SigDifiamt Chauges:
o
Removal and off-site disposal of CKD.
ConstrUCt landfill near Salt Lake Valley l.aDdfiII
for off-site disposal of CKD;
o
Use double liner for landfill interior and cap
with vegeuted layer; and
o Trest cluomium-bearing briCks on site.
" n:.:,';::'
-5-
"Midii_"combiDe.hReiDedy~':':
....
. ..
o
Do Dot treat ccmhl.........M soils prior to
disposal: auQ
o
Non-hazardous debris would either be used as
Site backfill or disposed off site.
o
Remova.t and off-site disposPl of CKD.
CnDsider the following options for off-site
disposal:
a. Dispose of in a permitted commercial
iaDdfill:
b. Use as a resource at SummitVille Mine or
other indusaial operation:
c. Construct a landfill off site:
o
Type of liners used would depend on
reguhuiODS governing the land.fill chosen for
disposal: auQ
a Trest chromium-bearing bricks off site.
-------
The modified combined remedy involves removal
and off-site d~osal or CKD. Disposal couid
occur in the following types of .facilities: a) a
. landfill construCted off site specifically for the Site
CKD (as in the original remedy); b) a commercial
landfill: or c) an indusnial operation for re-use or
the material (such as the proposed Summitville
SupenUnd Site). One or a combination of these
options would be selected during remeciial design.
ConstrUction or a new landfill (option (a) above)
would be considered only if options (b) and (c)
are found to be not viable nor cost effective.
Final selection of the optionis) will be based upon
an evaluation of which options best meet EP A' s
nine criteria. (EP A' s nine evaluation criteria are
described later in this documem.) The laodfill(s)
chosen would be lined and/or capped according to
applicable laWs. Co-disposed non-hazardous
materials at the Site would either be disposed off
site or used at the Site as backfill. (This decision
would also be made during remedial design and
will be based on whether it is possible [0
economically separate CKD from non-hazardous
debris.)
CKD-conr.nninMM soils would be removed and
disposed off site. Conr.amin:lred soils would nm .
be treated prior to disposal. Chromium-bearing
bricks would be separated from the CKD and be
treated and disposed off site. Following removal
activities. the entire Site would be backfilled with
a minimum of 18" of clean backfill.
Ground water at the Site would be monitored both
before and after removal of the CKD and
CODr.aminMOO soils. The purpose of this
monitOririg would be to assess the need for
ground-water remediation in the futUre.
If necessary, institutional controls in the form of
deed restrictions would be imposed. These
controls would be designed to control, as
necessary, future land and ground water use at the
Site. The need for institutional controls would be
assessed during remedial design.
EVALUATION OF THE ALTERNATIVES
AND THE PREFERRED ALTERNATIVE:
The preferred alternative is the Modified
Combined Remedy, as described above. Although
UDEQ is currently designing the combined
remedy in itS simificamly modified form. a
decision on m:llrin~ the fundamental and
silmincarn changes to the original remedv will not
become tinal until interested parties ha~e had a
chance to review and comment on the proposed
cl1anges. Based on new information or public
commentS received during the public comment
period. EPA and UDEQ may further modify the
Modified Combined Remedy. including reverting
back to the Origiiztzi Combined Remedy. UDEQ
and EP A, thereiore. encourage the public to
review and comment on the. alternatives provided
in this proposed plan. The RIlFS dor.nmP.m$ and
the original RODs should be consulted for more
information on these alternatives. These
documentS are in the AR.
. The two alternatives (the Orif!inai Combined
RDnedy and the Modified OJmbined Renu!dy) were
evaluated using EP A' s nine criteria. which are
summarized as follows:
1.
Overall Protection of Human HP.II.th
and the Environment addresses whether
or not a remedy provides adequate
protection and describes how risks posed
through each patb.way are eJi...;nJIT-q,
reduced. or comrolled.
2.
Compliance with Applicable or ReIenDt
and Appropriate Requirements
(ARARs) addresses whether or not a
remedy will meet all Federal aDd State
environmental laws and/or provide
grounds for a waiver.
oJ.
Reduenon of Toxicity, Mobility or
Volume through Treatment refea to the
preference for a remedy that reduces
health hazards. the movemem of
COnr.lmin:nl1'~. or the quantity of
COnr.lmin~ntS at the Site.
4.
Long-term Effectiveness and
Permanence refers to the ability of a
remedy to mainrnin reliable protection of
human health and the environmem over
time.
5.
Short-term Effectiveness refers to the
period of time needed to complete the
remedy, and any. adverse impaas on
human health and the environment that
may be posed during the constrnaion and
implementation of the remedy.
-6-
-------
6.
Implemeatability refers to the technical
and administrative feasibility of a remedy,
including the availability of materials and .
services needed to implement the chosen
solution. It also includes coordination of
federal, State and local governments to
clean up the Site.
7.
Cost evaluates capital, operation, and
m:aintP.n:mr.,e costs of each alternative and
compares COStS among similarly protective
remedies.
8.
State Acceptance indicates whether the
State concurs with.. opposes, or has no
comment on the Preferred Alternative.
9.
Community Acceptance includes
determining which componentS of the
alternatives interested persons in the
community support, have reservations
about, or oppose. This assessment will
not be completed until public comments
on the Proposed Plan are received.
UDEQ and EP A's comparative analysis of the tWo
alternatives (the Orirtinai Combined Remedy and
the Modified Combined Remedy) is as follows:
Both alternatives would be equally Drotective of
human health and the environment in 3frnining
risk reduction at the Site. Moreover, both
alternatives would comolv with all ARARs at the
Site.' Off-site disposal, with both alternatives,
would be conduCted in accordance with EP A's
Final Off-site Rule.
Both alternatives provide significant reduction of
toxicity. mobilitY or volume of Site wastes. The
modified remedy would better reduce toxicity of
CKD if an industrial use is found such as at the
Summitville Mine. Although the original remedy
would better reduce toxicity of cotmlmin:ated soil
because the soil would be treared prior to
disposal, EP A and UDEQ have determined that
disposal of the umreated, cotmlmin:ared soils in an
acceptable off-site facility would sufficiently
address the need for reduction in toxicity.
mobilitv. or volume of the COI1f:llminMM soils.
The original remedy better controls CKD mobilitY
because am would definitely go to a double-
lined landfill. However, EPA and UDEQ have
determined that so long as the em is disposed in
a facility that does not have anyenvironmp.nt:dly
significam releases of hazardous subStanCeS, there
will be a sufficient reduCtion of CKD mobility.
The modified remedy would have CKD disposed
in a facility that meetS this requirement, whether
or not the facility is double-lined. Both
altematives equally reduce toxicitY. mobilitY. or.
volume of chromium-bearing brick through
treatment.
Both alternatives provide for lonsr-term
Drotectiveness. Under both alternatives, all source
cont2minmon would be removed from the Site.
The modified remedy is more effective in the
short-term because it could be implemented by the
end of 1994. The original remedy, on the other
hand, would likely take tWO to three years longer.
However, the modified remedy is less proteetive
in the short-term due to risks associated with
transporting Cotmlmin:at'M materials because
chromium-bearing bricks will be tteated off site
and soils would no longer be tteated at all.
The modified remedy is more imolememable
because there are more options for disposal of
CKD. As described above, several existing
commercial landfills are interested in receiving the
CKD. Moreover, because soils no longer require
treatment, design and development of a treatment
system is no longer necessary. The availability of
an industrial use for the em, however, is
uncertain.
The modified remedy attains the risk reduction
goals established for the Site more cost-effectivelv
than the original remedy. A commercial facility
or industrial application would be used for
disposal of CKD only if it is more cost effective
than constructing a landfil1. The egrimMed present
worth cost of the modified remedy is at . least
$688,000 less than the esrimaTM cost of the
original remedy.
State and CommunitY AcceDtance will be fully
evaluated at the end of. the public commem
period.
. Draft ARARa for the Modified Combined Remedy arc summarized in a memo from Mike McCcncy to the Ponlalld Ccmcm
Site file cIarcd October 29. 1993. The subject of the memo is "Draft ARARs for the Portlaod Ccmcut Mod.iJH:d Combined
Rc:mcdy.. This memo is in Ihc AR.
-7-
-------
UDEQ and EP A believe that the preferred
modified combined remedy meetS the threshold
evaluating criteria of the NationaJ Contingency
Plan (NCP) and provides the best balance of the
. rem~ining NCP evaluating criteria among the two
alternatives. Based on the information available
at this time, UDEQ and EP A believe the modified
remedy would: protect human health and the
environment; comply with ARARs; be cost-
effective; and utilize permanent solution and
alternative treaanent technologies or resource
recovery technologies to the ~imum eXtent
practicable. The Q10dified remedy would, in pan.
satisfy the preference for treatment as a principle
element.
". .......", . .
:j.ii:ilj.....'~i:.~:::j:!::::"~:::!!:i.!:
Action Level: An amoUnt of cont:lmin~m in soil,
air, or water at which EP A and the State believe
a response is l1eC-t"5Sary. Action levels vary from
. site to site based on potential exposures.
Administrative Record (AR): The body of
documentS upon which EP A and the State base a
cleanup decision at a Superiund Site. By law, the
AR must be made available at a repository loCated
near the Superfund site. The AR for this Site may
be found at the Information RepositOries listed on
the from of this fact sheet.
Alktzline: A term used to describe substances
which have high pH (greater than 7). Opposite of
an acid.
Cement Kiln Dust (CKD): A powdery by-ProduCt
of the cement. manuiacturing process. It is
alkaline and contains elevated levels of several
heavy metals.
CERCLA: An abbreviation for the Comprehensive
Environmental Response. Compensation, and
Liability ACt or Superfund, 42 U.S.C. 9 9601, ~
~ CERCLA is a law passed in 1980 that
established a program. to identify abandoned
hazardous waste sites, ensure that they are cleaned
up, evaluate damages to natUral resources, and
create claims procedures for parties who cleaned
up the sites.
Fu1ui4mentDl Clumges: Changes to a Superfund
Site remedy are considered fundamental when they
fnnda:rnemaUy alter the way in which wastes are
IDaDaged at the site. Fundamental changes to a
remedy must be made through an amended ROD.
HtI%rI1fiJJus Substtuu:e: Under CERCLA, any
material which when released. or when threatened
to be released to the' environment, is found by
EP A to pose a substantial threat to public health,
welfare or the environment.
l1tJmrdous Wasu: Under RCRA, a solid waste
which is so dangerous it must be managed under
especially strict requirementS. Wastes are
considered to be hazardous if, among other things,
they are highly toxic, ignitable, corrosive, or
contain certain other hazardous characteristics.
Inmnn:iolUll Controls: Controls, either legal or
physical, which prevent individuals from coming
intO contact with CODtamin~Ted portions of a
Superfund site. These controls include fencing,
warning signs, deed restrictions, and other land-
use restriCtions.
NatiDlUIi Contingency PIDn (NCP): A body of
federal regulations governing the implememation
of CERCLA. The NCP can be found at 40 CFR
Part 300. .
NatiDlUIi Priorities List (NPL): The EPA's list of
the moSt serious uncontrolled and/or abandoned
hazardous waste sites. -NPL sites are eligible for
possible long-term cleanup under Superfund.
Off-siU Rule: An amenrhuent to the NCP which
regulates the off-site transfer of CERCLA waste.
The Off-site rule can be found at 40 CPR Part
300.44Q. The Off-site Rule was finalized on
Se{?tember 22, 1993, and became effective on
October 42, 1993.
Opel'llble UniJ (OU): A term used to describe a
certain portion of a Superfund site.
-8-
-------
OpelTlZion and m.ainU1UIlU:t! (O&M) cosu: The
annual costS of ensuring that a remedial alternative
is proteetive.
pH: A measure of the acidity or alkalinity of a
liquid or solid material.
Resource Conservation and Recovery Act
(RCRA): A Federal law found at 42 U.S.C. 9
6901 eta sea .. that established a regulatory system
to track hazardous substances from the time of
generation to disposal. The law requires safe and
secure procedures to be used in treating,
transporting, storing, and disposing of hazardous .
substances. The regulations implementing RCRA
can be found at 40 CFR Parts 260-281.
RCRA Subtitk C lIJruudous Waste LtmdjiJl: A
disposal facility where waste is placed in or on
land. Subtitle C landfills are disposal sites for
RCRA hazardous waste. They are designed to
minimi7.e the chance of release of hazardous
substances into the environment.
RCRA Subtitk D IndustriDl LandftIl: A disposal
facility where waste is placed in or on land.
Subtitle D landfills are disposal sites for non-
hazardous solid wastes.
Record of Decision (ROD): A public document
that explains which cleanup alternarlve(s) will be
used to clean up sites listed on the NPL.
Remedi4l DesigniRemediDl Action (RDlRA):
Remedial Design is a phase of site cleanup where
engineers design the technical specifications for .
cleanup remedies and technologies. Remedi:1I
Action is the actual cOllStruction or
implememaIion phase of a Superfund site cleanup,
following the remedial design.
RemediIlllnvestigation/FeosibiIity Stud, (RlIFS):
RemP.di;Jt Investigation is an in-ileptb. smdy
desigJJed to gather the data necessary to dP.tP!rminp-
the namre and exteDt of COntMnin:tti()11 at a
Superfund site, identify the preliminary
alternatives for cleanup actions, and support the
tedmical and cost analyses of the alternatives.
The Feasibility Study is the analysis of the
potential cleanup alternatives for a site.
Signijictull Changes: Changes to a Superfund
site remedy are considered silmificant when they
are incremental changes to a component of a
remedy that do not fundamentally alter the overall
clean-up approach at the Site. EP A and the State
notify the public of silmificant changes by issuing
an Explanation of Significant Differences fact
sheet.
Value Enginee~: An organized approach to
idemifying costS that do not contribute measurably
to a. project's quality, effectiveness or durability.
FOR MORE INFORMATION, YOU MAY CONTACT:
If you have questions or would like more technical
information, please contact:
Raben M. O'Brien, UDEQ Project Manager
1-801-536-4100
-QR-
Michael H. McCeney, EP A Ploject Manager
1-800-227-8917, Ext. 7169
For additional information, you may contact:
Dan Ford, UDEQ Community Relations
1-801-536-4100
-QR-
Hal Dunning, EP A Community Relations
1-800-227-8917, Ext. 1142
-9-
-------
State of Utah Dept. of Environmental Quality
Div. of Environmental Resp. & Remediarion .
1950 West North Temple
Salt Lake City. UT 84114-4840
r-
I.
L
~
-------
.
.'....'.
f~~ \
~
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VIII
999 18th STREET - SUITE 500
DENVER, COLORADO 80202-2466
mlllIl!I~\ I~I
281452.
Robert L. Duprey, Director
Hazardous Waste Management Division
((:(grPl1
ADMINISTRATIVE RECO;
PRIVILEGEf
FILE PLAN
Ref: 8HWM-SR
f16CT 2'f2 11993
MEMORANDUM
FROM: Micbae1 McCeney, Remedial Project Manager ~.
TO:
4. o:;t
SUBJECf:
Concurrence on Final Explanation of Significant Differences (ESD) and Proposed Plail
to Amend the RODdor the Portland Cement Superfund Site ..
This memo is to request that you approve the attached Portland Cement Superfund Site Final
Proposed PlanlExplanation of Significant Differences. Because we plan.to issue this Plan on October
28, I ask that you respond to this request by COB Monday/October 25. ORC, OEA and SR have
concurred on this Plan; attached are the concurrence memos.
This plan is "hybrid" as it serves both as an explanation of sismificant differences to the
Portland RODs as well as a proposed plan to fundamentally alter the remedy. The Plan discerns
between significant and fundamental changes to the remedy for primarily two reasons: first, the
. Portland team believes that there is such a distinction among the modifications, and second~ to avoid
being accused of having pre-selected our modified remedy. EP A and the State could be so accused
because we have been proceeding with design of the sismificantly modified remedy and we intend to
commence our RA contractor procurement process before the ROD amendment is signed by the .
Regional Administrator.
The State concurs on this Plan. The Plan will be issued on joint EP A and State letterhead and
it indicates that the State is the lead-agency.
The Plan will be formatted in accordance with the EP A Model Proposed Plan.
Please indicate your approval or disapproval of this plan by signing one
of the following: .
~~. ~rertL.~p~
Yes, I approve of the No, I do not approve of the attached Proposed
attached Proposed PlanJESD PlanJESD
cc:
Diana Shannon
Laura Clemmens
Bob O'Brien, UDEQ
Nancy Mangone
Hal Dunning
Printed on Recycled Paper
-------