Collection
Jrce Center
Uni18d States
EnvlronmenlBJ Protection
Agency
Ot'IIce of
EmergEJnCy and
Remedial Respon..
E PAlRODfR08-861OO4
March 1986
19107
"- ----------~
AEPA
Superfund"
Record of Decision:
~u- 12l.f 210
Denver Radium Site Streets, CO
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TECHNICAL REPORT DATA
(I'tHM mid /"""""ion$ 011 tht nllmt btfon co,""ltti",)
,. "EftO"T NO. 12. 3. REClft'ENT'S ACCESSION NO.
~PA/ROD/R08-86/004
&. TITLE AND aU.TITLE a. R.ftORT DATE
~PERFUND RECORD OF DECISION March 24, 1986
enver Radium Site Streets, CO .. ftER"ORMING ORGANIZATION CODE
7, AUTHO"'I' e. I'ER"ORMING ORGANIZATION REI'ORT NO.
,. I'I""O""INO O"OANIZATION NAME ANO ADDRESS 10. ""DGRAM .LEMIN Ne.
1'. ceNTRACT/gRANT NO.
12. S"ON'O"INO AGENCY NAME AND ADDRESS 13. TYI'. 0" R."O"T AND 1'."'00 COV.ReD
J.S. Environmental Protection Agency Final ROD Report
101 M Street, S.W. ' 1.. SI'ON50RING AGENCY COD.
qashington, D.C. 20460 800/00
11. SUft"LEMINTA"Y NOTIS
'e. ,,- ,... This operable unit is
Denver Radium Site Streets is located in Denver, Colorado.
~omprised of eight street segments in the Cheesman Park area and one segment in the
~pper downtown area. The nine contaminated street segments are owned by the City and
:Ounty of Denver and extend approximately 4.5 miles through largely residential areas.
rhe Denver Radium Site Streets contain a 4- to 6-inch layer of radium contaminated
sphalt. The contaminated layer is underlain by compacted gravel road base and is
~sually overlain by 4 to 12 inches of uncontaminated asphalt pavement. There is an
estimated 38,500 cubic yards of contaminated material covering approximately 832,000
square feet. Radioactive contamination does not extend beyond the paved right-of-way of
.~he streets and generally does not appear to have migrated into the soils below the
oontaminated asphalt. Radium concentrations at representative locations on the streets
range from 4 to 79 picocuries per gram. Surface gamma radiation readings generally fall
below 20 microroentgens per hour above background.
The selected remedial action for this site includes: leaving the contaminated
~terial in place~ improving institutional controls~ and removing any contaminated
naterial excavated during routine maintenance, repair, or construction activities in.the
sffected streets to a facility approved for storage or disposal of contaminated
naterial. The estimated initial cost of the remedy is $30,000. This includes the cost
)f studying and (See Attached Sheet)
7. KIV WO"DS ANO OOCU..INT ANALYSIS
t. 011C" ,,.,.0 "S b.IDENTIFI.RS/OI'EN ENDED TE AMS C. COSATI Field/Group
~cord of Decision
Denver Radium Site Streets, CO
Contaminated Media: asphalt
ey contaminants: radium
,.. DIST"IIUTION STATEMENT 1t. SECU"'TY CLASS (Tllu R,po"J 2'. NO. OF I'AGES
None 66
20. SECU"ITY CLASS (Tllil POP) 22.1'''IC.
~ None
f
I'A ,- 2220-' (I... .-71)
""."IOUI .OITION II O.IOLETE
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."
INSTRUCTIONS
1.
REPORT NUM8.R
Inserllht LPA rt,on number u it Ippall on tbe cower of tile publil:alion.
LEAVIILANK
2-
1
RICIPIENTS ACClatON NUI8IR
Rnand for u. by ea~h ~porl m;ipirftl,
TITLE AND IUITITLE
Title should Indicllt dearly Ind britny Ihe subjKl .:ovcra~ 1.11' IIw report.- and be lIi'I'lay~" ",umin,'nlly, s.", 'Uhlilk, If U!I4,''', m ~nlilliL',
type or otherws. subordInate II to maul utle, When I report IJ prcparfll In !110ft' lhoan Uft\: VL)jU~. rL'",'al Ih,' rnnl;lry 'ilk, alill v,1I:aIl1\.'
number and iDcbl4lsubtitle for the specifk title, .
..
I.
REPORT DATI
Each report IhaII carry 1 elate iDdicatiDa It least month and yeu, Indi..-att tilt h...", un ",hil:h II .;1' ",,'k.~Icli (qt., JII,,' "1 iuuc', "'c' "I"
qproNl, ." 01 PHptI18tio11, "C.),
..R'OR.NG ORGANIZAnON CODI
Lave blank.
I.
7.
AUTHOR III
Give nametll in ~->nventional ordCr (Joh" R, 0«, J. Robe'" OM, C"C'.J. Li~1 authur'J afliliatlun if il dine~ "'Llm Ih,' rc,furmi", ."pni-
zation.
I.
..R'OMIING ORGANIZATION REPORT NUM8ER
l...n if performln. orpnization W1shn to alSip thl~ number.
"R~NG ORGANIZATION NAME AND ADORID
Give... street. city,ltlte, and ZIP e:ode, List no more than two levels of an u'pnilaliunal hin:ald,y.
..
,0. PROGRAM ILlMINT NUM8IR
U. the propam .tement number under whi.:h the repon WilS prepared, Suborllinah: numbe" m;l)' be indu.l,'.J In Jt;IrL'nlh,''''''"
.
11. CONTRACT/GRANT NU_IR
In_t contnct or IfInt number under whie:h report was prc:pen:d.
12. SPONIORING AGINCY NAME AND AooR..
Ine:lude ZIP code.
11 TY" 0' REPORT AND "RIOD COVERID
Indicate interim fmal. etr.. and if applie:able. clat.. covend.
1.. SPONIOR'NG AGkNCY CODE
Insert appropriate code.
11. ~IMaNTARVNOTII
Enter information nol included elsewhere but u.ful, sue:h as:
To be pubUshed in. Supersedes. Supplements. ete:.
,1. A81TRACT
Include a brief (200 worth or ItlsJ fae:tualsummary of the mo,t ,ilnllkanllnfurmillinn L.untilln,'.! III Ih,' 1"I.nrl. II "'" «'1""1 n1/l1;lUl' a
sipiflClnt bibliOlflphy or literature survey. mention II hen:.
Prepared in .:oopcriltiun wnh, hoan-.l;allull III, I"~""'"I,-.J ;II n,"IL''''IH' ..I.,
17. KEY WORDS AND DOCUMENT ANAL YIII
(a) DESCRIPTORS. Select from the TheuUlU. 01 I::n.ineerir.. ;and Sc.:M:ntllk "fenn, the: prupt:r ilu'l...rll~1I krill' th;at Iwnll"y tiw ma,ur
conc.pt 01 the researe:h and are sufficiently ipec:llic: and pnciM: to be UM:d ii' Inwx entrlC' "ur \;atillut:lftt:.
(b) IDENTIFIERS AND OPEN.ENDED TERMS. U. identiflen for projcL:1 nilm~" \;ude nam.:s. e'fulpment .Je'lt:n~lurs, et.:. U..c: l-ren.
ended terms wriuen in descriptor form for those subjects lor which no de~nptur e""ts.
(c) COSATII'ILLD GROUP. neld and poup auipments.ue to be taken !'rom the t 965 ('OS,\ 11 Suhl\'\;1 ('al~'I!"'Y U~I. .Sin,"'V the ma.
jority 01 documents an multidisciplinary in nature, the Primary Held/Group ils~ianrm:ntf 'I will be sPL'~ II". II",I"hn~. art'a "I' human
encleayor. or type of physical object. 11ae applicationCs) wW be CfOIIo-rclc:re:n,"-cd with ..c:,'unchary Ild,I/C iruul' "ssll!lIIlIenls Ihat wllIl...lh..
the primary postinatS),
,1. DIIT"'IUTION ITATIMINT
Denote relnsabilit)' to the public or limuation for realOnli other than \4:\;unty fur uilm"le "1te:1!:;I'" 1:111111111,',.." (lie: ;lIIJI ;I~ilil;al"hl)' I..
the public. wllh address ;and pnce:. .
1'..20. IECURITY CLASSifiCATION
DO NOT submit C:lauitied re:ports to the: National Tc.:hnicillinforlftiitiun S4:rvi\;c.
21. NUM8IR OF 'AGIS
Insert the tolll number of paps, inc:ludinl this onc and unnumbend palC'. but udud.: distnbutiun 11,1. II ;any,
22. "UCI
Insen the price set by the Nltional rechnicallnformation S.:rvice ur tl,,: Government Pnnting om\;C, II knuwn.
I" ,- 2220-1 (.n. 4-77) (.._..)
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EPA/ROD/R08-86/004
Denver Radium Site Streets, CO
16.
ABSTRACT (continued)
then establishing the institutional controls which would monitor all
construction and utility work for the affected streets. The annual
operation and maintenance cost will vary depending upon the amount of
material excavated during any particular year.
f
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Record of Decision
Remedial Alternative Selection
Site Name:
Denver Radium Site Streets
Operable Unit 7
Site Location:
Denver, Colorado
Documents Reviewed
I have reviewed the following documents describing the analysis of
the remedial alt~rnatives for the Denver Radium Site Streets Operable Unit:
- Denver Radium Streets Feasibility Study, prepared for the EPA
Region VIII by CH2M Hill, July 26, 1985.
;
- City and County of Denver recommendations/comments on FS.
- Colorado Department of Health recommendations/comments on FS.
- DOE recommendations/comments on FS prepared by Bendix Field
Engineering Corp, August 29, 1985.
Endangerment Assessment (Appendix A of FS).
- EPA Region VIII Staff recommendations/comments on FS.
- General public recommendations/comments on FS.
- Denver Radium Sites Disposal Method Study, prepared for the
Colorado Department of Health by Dames & Moore, March, 1983.
- Engineering Assessment and Remedial Action Plan for Radium
Processing Residues at Nine Streets and One Alley in the
City and County :of Denver, Colorado, unpublished Report
prepared for the Colorado Department of Health by Arix, Inc.,
1982. '
- Letter from Colorado Department of Health dated February 18, 1986
containing commjnts on the draft Streets ROD.
Memorandum dated March 3, 1986 from Philip Nyberg to John Brink
pertaining to Radiation Protection Standards.
I
- National Oil and H~zardous Waste Pollution Contingency Plan,
40 CFR Part 300~
- Responsiveness Summary, prepared for EPA Region VIII by CH2M Hill,
January 13, 1986, (attached).
- Standards for Remedial Actions at Inactive Uranium Processing
Sites, 40 CFR Part 192.
- Summary of Remedial Alternative Selection, EPA Region VIII,
January 9, 1986, (attached).
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2
Description of Selected Remedy
The EPA selected remedy combines features of excavation and disposal
with tne Modified No Action Alternative. This remedy entails:
leaving the contaminated material in place,
- improving institutional controls so that all routine maintenance,
repair, or construction activities in the affected streets by
government agencies, utility companies, contracting companies,
and private individuals will be monitored, and
- removing any contaminated material excavated during routine main-
tenance, repair, or construction activities in the affected
street~ to a facility approved for storage or disposal of con-
taminated material.
The EPA may share in the capital costs of designing improved insti-
tutional controls to be implemented by the City and County of Denver.
Consistent with CERCLA Section 104(c)(3), the State of Colorado or the City
and County of Denver will be responsible for assuring the payment of all
future costs of maintaining and operating the institutional controls, in-
cluding proper disposal of any contaminated material excavated during routine
maintenance, repair, or construction activities in the affected streets.
.
Declarations
Consistent with the Comprehensive Environmental Response, Compensation
tion, and Liability Act of 1980 (CERCLA), and the National Contingency Plan
(40 CFR Part 300), I have determined that the selected remedy described in
the preceding section at the Denver Radium Site Streets Operable Unit is a
cost-effective remedy that effectively mitigates and minimizes threats to
and provides adequate protection of public health, welfare, and the environ-
ment. The action will require future operation and maintenance activities
by the State of Colorado or the City and County of Denver to ensure the
continued effectiveness of the remedy. These activities will be considered
part of the approved action and will be funded by the State of Colorado or
subdivision thereof. The selected remedy is the alternative which the State
of Colorado recommended in its August 12, 1985 comments on the Feasibility
Study. The State has reviewed and commented on the Record of Decision.
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3
I have also determined that the action being taken is appropriate
when balanced against the availability of Trust Fund monies for use at
other sites. In addition, the limited off-site transport and secure
disposition of the contaminated material recommended in the institutional
controls is more cost-effective than any other remedial action and is
necessary to protect public health, welfare, or the environment from the
misuse of contaminated material excavated from the Denver Radium Site
Streets Operable Unit in the course of any routine maintenance, repair,
or construction activities in the affected streets.
~--
Jo . Well es
Regional Administrator
Region VIII
U.S. Environmental Protection
.3 /2.Y /3t
,
Date
.;
Agency
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Summary of Remedial Alternative Selection
Site Name:
Denver Radiu~ Site Streets
Operable Unit 7
Site Location
Denver Radium Site Streets Operable Unit is located in Denver,
Colorado. The Qperable Unit is comprised of eight street segments in
the Cheesman Park area and one segment in the upper downtown area (See
Figure 1):
- 9th Avenue from Ogden Street to Cheesman Park
- 11th Avenue from Josephine Street to Cheesman Park
.
- 23rd Street from California Street to Lawrence Street
- Corona Street from 7th Avenue to 10th Avenue
- Downing Street from 7th Avenue to 10th Avenue
- Humboldt Street from 7th Avenue to 9th Avenue
- Lafayette Street from 1st Avenue to 9th Avenue
- Marion Street from 6th Avenue to 9th Avenue
- York Street from 6th Avenue to 13th Avenue.
The nine contaminated street segments are owned by the City and
County of Denver and extend approximately 4.5 miles through largely
residential areas. An estimated 800 households border the contaminated
streets. The streets are adjacent to various parks and public-use areas
and properties. Except for minimal controls on excavation imposed by the
Denver Public Health Engineering and the Denver Public Works Departments,
use of the streets has not been restricted.
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2
Site History
In 1979, EPA discovered a reference to Denver's National Radium
Institute in a 1916 U.S. Bureau of Mines report. Subsequent research
identified the presence of several long-forgotten radium processing
operations which were active in the 'Denver area from about 1914 through
the mid-1920's. Production of the refined radium, primarily for cancer
therapy and research, generated large quantities of radioactive residues.
Radium contaminated tailings and other wastes were discarded or left on
site when the facilities were closed. Changes in ownership and use of
the properties resulted in the residues being used as cover, fill, and
foundation material and as aggregate in concrete and asphalt mixtures.
Contaminated asphalt pavement was placed in the streets either when the
streets were orjginally built or when streetcar lines were removed. No
conclusive proof which identifies the source of this material has been
found.
The Denver Radium Site was placed on the Interim Priorities List in
October 1981. Final promulgation to the National Priorities List (NPL)
occurred on September 8, 1983. After initial site discovery, the Colorado
Department of Health undertook engineering assessment work using RCRA grant
funds. The nine street segments were identified by the State contractor,
the Arix Corporation, as being contaminated with radioactive materials.
As a result of the Arix study, the Denver Public Health Engineering Depart-
ment began monitoring gamma radiation levels during any excavation carried
out in the streets.
.
State studies were discontinued when RCRA grant funds ran out. The
EPA resumed fund-lead RIfFS activities in 1983 because the Colorado State
Legislature failed to approve the cost share required for RI/FS funding
under EPA's policy at the time. In July 1985, the EPA completed a study
further defining the contamination of the streets. On July 26, 1985, the
Draft Feasibility Study was released.
Site Description
The Denver Radium Site Streets contain a 4- to 6-inch layer of radium-
contaminated asphalt. The contaminated layer is underlain by compacted
gravel road base and is usually overlain by 4 to 12 inches of uncontaminated
asphalt pavement. There is an estimated 38,500 cubic yards of contaminated
material covering approximately 832,000 square feet. Radioactive contamin-
ation does not extend beyond the paved right-of-way of the streets and gener-
ally does not appear to have migrated into the soils below the contaminated
asphalt. '
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3
Radium concentrations at representative locations on the streets range
from 4 to 79 picocuries per gram (Table 1). (Units of measurement are de-
scribed in Section 1.4 of the Feasibility Study and in the En9angerment
Assessment.) These levels exceed the standards for IIRemedial Actions at In-
active Uranium Processing Sites,1I 40 CFR Part 192, which serve both as the
initiator and the goal of the remedial actions at the Denver Radium Site.
Surface gamma radiation readings generally fall below 20 microroentgens per
hour above background (Table 2 and Fi'gure 2). The peak gamma level reported
to date is 57 microroentgens per hour. Gamma exposure rates in outdoor con-
taminated areas are not directly addressed in 40 CFR Part 192. However,
the gamma exposure levels found in the streets are well below the guide-
lines set by Federal agencies such as the Nuclear Regulatory Commission
(NRC) and by n~tional and international advisory groups such as the National
Committee on Radiation Protection and Measurements (NCRP) and the Interna-
tional Commission on Radiological Protection (ICRP).
Current Site Status
.
The Denver Radium Site Streets Operable Unit poses a minimal threat
to public health. There is every indication that the material is bound
in the asphalt and is not free to move in any direction. As long as the
material remains in its present location, the potential routes of human
exposure to the radioactivity are limited because the contaminated material
is well contained. None of the streets are near surface water or ground-
water resources and the material has little potential for erosion or leach-
ing due to the pavement capping. For these reasons, contamination of the
surface water or groundwater is not considered a potential exposure pathway.
The most significant routes of exposure to the radiation associated
with the Denver Radium Site Streets material are, in order of decreasing
significance: (1) inhalation of radon gas and its decay products, which
are the immediate decay products of the radium, (2) direct gamma radiation
exposure from the decay of radium and its progeny, and (3) ingestion or
inhalation of radium-contaminated material. In general, the greater the
exposure rate and the longer the exposure to radiation, the greater the
associated health risks. ; Each of the three exposure routes will be ex-
amined briefly in order tb describe the potential health risks.
Inhalation of Radon Decay Products:
Radon gas and its d~cay products, called daughters, present the great-
est health hazard of long-term exposure. Radon daughters may attach to
airborne particulates and be inhaled. The lungs and internal organs are
then exposed to the highly ionizing particles which the radon daughters
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Table 1
RADIUi.1 CONCENTRATION
DEN'.ER RAD IUi" STREETS
t"ax; r.1l"T.t
Contill!1;na~ioI11 Pa vernclI"': RaJi um
Depth Thic~ncss Concentration
Bur~:1g :~o. Lo = a t ion 2 (inches', (;i1c~e:;) ( pC ~ / 1iT.1 )
-
1 Yor" St. near 7th ;\ve. 1~ 1: 5..
., Yorl-. c' 4. IIcai i 1 th Avr.:. 1U 1u " ,-
... ~"'.. ",oJ
3 11 th Ave. near R
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'ra~"1 e ;:
lE','ELS OF' CAr.:;.1r, RADIA7!Q~.t
DEN\ER RADIUM STREETS
P~rce!l t~lje Cif Co I\"~am; ilil'~eJ J...reuu
- ~U Grea tel"
Les:;; 'to h i,m to than L!; ghe s~
~U uR/hr QO ui:/h r 40 J,;P. /11 rLJ Rt:i!d;ng
Street ( aoo ve l)ac!~ ground) (above bad ground) (<:.bovc uilCI~ ground) uR/hr
9th Avenu~ r::." 4G ., 57
-.. t..
(5-1 /~ tJ1;)c~s,
~a,ouo i':l.:)
1 i 'tli iW\:II"'~ 'Si '''' :.;U
"'''''
(4-112 blocks,
5u,OOO foe 2) ,
~ 3"0 Street 93 7 0 23
(6 D1oc~s,
12U,OOO ft2)
;;
Corolla Street 73 :'7 0 29
(3 l>locksJ,
~O, 000 foe'-)
Do\mi\l9 Stre~t u4 lG 0 34
(3 b1oc..s,,>
~O,OOU ft..)
lIumooldt Stra~t 56 44 0 ~o
(2 b 1 oc:~ s ~
!,j~, OUO ft..)
Lafilyc'.:te S'i:r~(:t 50 40 1 51
(!) b 1 oci~ ~ .
1':0, 000 f.~2)
Had on S'~rcct 30 67 ... 1.:-
;.; .. I
(4 clockS,
...
lul},OC~ fJ~",)
YO'I'.~ S~I'eet i'O :::) 1 5i
(7 ~10c~:iJ,
:0,000 f;;''-)
aiicscd on ua~i: fl'or.1 Arix, 1~:2.
LJThc t-dgtlt::;t g\:orJr.1il rac;at;o:1 1ev~1 repor~ed;:; !J7 ~P./houl' !UOVC baci.:groulH1.
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-------
4
emit. Prolonged inhalation of radon decay products which are concentrated
in the air has been shown conclusively to cause lung cancer ~ uranium min-
ers. However. no effects have been observed at the lower concentrations to
which the general public is exposed.
Radon daughters are not a problem in the out-of-doors where vertical
dispersion quickly dilutes the radon emanating from the ground. This mech-
anism will minimize the concentration' of radon in the air above the affected
streets. However. radon decay products can concentrate to unacceptable
levels in confined spaces such as in buildings built on contaminated ground.
This is not a problem in this case because no buildings will be constructed
in the streets.
The potential exists for diffusion of radon from the contaminated as-
phalt into the ~omes located along the affected streets. However. EPA has
calculated that the relatively small amount of contamination in the streets
is insufficient to cause elevated levels in any of the homes. given that
there is typically 20 to 30 feet of compacted soil between any street and
house and possible avenues for gas migration such as loosely filled pipe
trenches are isolated from the contaminated asphalt layer. Solid material
such as soil will sufficiently retard the diffusion of radon so that the
gas will decay into a stable solid product before reaching the homes. This
barrier should represent an attenuation factor of over one million times
for radon moving from the streets to the homes. The resulting concentration
from this source to the houses is negligible.
Gamma Radiation Exposure:
The radioactive decay of radium and its daughter products results in.
among other things. the emission of highly penetrating gamma rays. Simi-
lar to x-rays. gamma rays are of concern because they can easily penetrate
a few centimeters of soil to expose anyone walking above the contaminated
area. The gamma ray emission. however. is limited to that area immediately
above the contamination and is essentially not measurable beyond the paved
rights-ot-way of the streets. Furthermore. the gamma radiation exposure
rates measured at even the areas of highest contamination in the streets
represent a negligible h~alth threat to the casual passerby. For example.
if a person were to stand on the location ot the highest measured exposure
rate (57 microroentgens per hour at York Street) tor 16 hours each day.
365 days a year. the resulting dose would be only 330 millirems per year.
This may be compared to the guidelines ot the Federal Radiation Council
(FRC) and others which suggest a maximum annual exposure of no more than
500 millirems per year to any non-occupationally exposed individual member
of the-general population.
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5
A more realistic case might be the exposure of children playing in
the street for two hours each day, five days per week. If t~e average
exposure rate above the contaminated streets is assumed in this case to
be 40 microroentgens per hour, the resultant dose would be only about 20
millirems per year - well below the recommended exposure guideline of the
National Committee on Radiation Protection and Measurements (NCRP), 100
millirems per year above background; and a small fraction.of the approx-
imately 150 millirems that anyone in. Denver receives each year from natural
natural background radiation (cosmic, terrestrial, and internal).
Inhalation or Ingestion of Radium-Contaminated Material:
While direct ingestion or inhalation of radium-contaminated materials
can result in significant doses to various internal organs of the body,
the confined location of the material in the streets makes this the least
significant of the major exposure routes. For exposure by this route to
occur, the material would have to be moved from its current location and
made available to the population. Also, it is unlikely that a person will
intentionally eat or breathe significant amounts of contaminated material.
From the forgoing discussion it is clear that the radium-contaminated'
material in the streets represents only a minimal hazard in its present
state. This situation will change, however, if the material is disturbed
by activities such as utility excavations, trenching, or repaving. Uncon-
trolled excavation presents the possibility of release and dispersion of
the radioactivity, potentially increasing the exposure from all three routes.
For this reason, it is important to maintain proper controls over any activ-
ities which disturb the status quo so that the risks of population exposure
are not unduly increased beyond the presently minimal level. Through proper
administrative and technical controls, any disruption of the streets, up to
and including complete reconstruction, can be conducted with little addition-
al risk to the workers or the general public.
.
Enforcement
Responsible party search work presently underway has identified the
paving contractors who are thought to have used asphalt containing the
contaminated material. ~ince financially viable, present day successors
of the original contractbrs have not been identified, the Region views the
Denver Radium Site Streets as a fund-lead site. There is a potential
for cost recovery if a responsible party is identified in the future.
Since the streets were owned by the City and County. of Denver at the
time of disposal, a minimum of 50% cost-share responsibilities, imposed'
by CERCLA Section 104(c)(3)(C)(ii), will also apply to the Denver Radium'
Site Streets. Also, the City and County of Denver could be ~onsidered a
responsible party under CERCLA Section 107(a)(1) by virtue of its current
ownership of th~ streets.
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6
Alternatives Evaluation
The remedial objectives for the Denver Radium Site Streets Operable
Unit are to take actions which protect public health by (1) minimizing
the spread of the radium-bearing material to locations where it could
pose a hazard and (2) preventing contamination, especially the radium
decay progeny, from entering pathways that could result in greater risks
of exposure. These objectives are consistent with the National Contingency
Plan, 40 CFR Part 300, and the cleanup standards set by the EPA for "Reme-
dial Actions at Inactive Uranium Processing Sites," 40 CFR Part 192. These
cleanup standards have been adopted as remedial action objectives for the
Denver Radium Site. These standards are relevant and appropriate Federal
requi rements as- defi ned by the newl y revi sed NCP because it is. the radi um
content of uran~um mill tailings which is regulated for the mill tailings
cleanup actions. Other Federal criteria. advisories, guidances and State
standards which were considered when developing the alternatives are dis-
cussed later in this document in the section entitled, "Consistency With
Other Environmental Laws."
Initial screening of alternative actions resulted in the elimination
of several remedial options because they are technically ill-suited to the
site conditions or contrary to the remedial objectives. Among the options
rejected are reprocessing/treatment; lead, concrete. or soil shielding for
radiation attenuation; area exclusion; and dilution of contaminated mater-
ial with clean soil.
Complete excavation and disposal of all the contaminated material was
also considered. However, the cost of implementing this as a remedy (ap-
proximately $8,600,000) far exceeds the cost of the remaining alternatives
described below without providing substantially greater public health or
environmental protection.: Although complete excavation and disposal might
be considered the most reliable alternative because all of the contaminated
material would be excavated over a short time, other alternatives, including
the selected remedy, meet the relevant and appropriate standards at a much
lower cost with much less impact on traffic and neighborhoods.
The selected remedY~;was developed from the remaining alternatives des-
cribed below: .
(1) Limited Excavation and Disposal: Approximately 194 cubic yards of
material found within 4. 00 square feet of the most contaminated street
segments could be excava~ed and disposed at an EPA-approved facility. This
alternative entirely removes the contamination in the areas where there is
the greatest public health risk - where gamma radiation levels are greater
than 40 microroentgens per hour above background. No action would be ta~en
on the remaining areas.
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7
(2) Asphalt Shielding: Approximately 36% of the total street area
could be paved. The areas which show a gamma radiation level over 40
microroentgens per hour above background, approximately 4,600 square feet,
would receive 5 inches of asphalt and areas which show a gamma radiation
level between 20 and 40 microroentgens per hour above background, approxi-
mately 295,000 square feet, would receive 3 inches of asphalt. This al-
ternative would reduce the exposure level by 50% to 70% in the areas of
the greatest gamma radiation exposure (more than 20 microroentgens per
hour above background).
(3) Limited Asphalt Shielding: Approximately 1% of the most contam-
inated portion 'of the streets could be paved. Those areas with gamma level
readings greate~ than 40 microroentgens per hour above background (approxi-
mately 4,600 square feet) could be overlain by a 2-inch layer of asphalt.
The asphalt "patches" would be tapered on all sides to provide a smooth road
surface. This tapering would bring the total area of covered street surface
to 8025 square feet. This alternative would reduce the exposure level by
approximately 35% in the areas of peak gamma radiation exposure (more than
40 microroentgens per hour above background).
.
(4) Modified No Action: The contaminated material could be left in
place and institutional controls could be established to monitor all routine"
maintenance, repair, or construction activities in the affected streets.
This alternative limits the public health risk by preventing the spread
of the contamination to areas where it could potentially enter pathways
of exposure that could increase public health risks.
(5) No Action: The contaminated material could be left in place.
This alternative does not reduce the public health risk from contamination
being spread to areas where it could potentially enter pathways of exposure.
The factors used to evaluate the effectiveness of the remaining
alternatives are cost, reliability, feasibility, technology, administraive
and other concerns, and their relevant effects on public health, welfare
and the envir~nment. Results of the evaluation are summarized below:
(1) Limited Excavation and Disposal: High cost ($148,050); eliminates
public health risks of long-term exposure in excavated areas only; high
reliability due to the penmanent removal and safe disposal of the contam-
inated material; moderate to high feasibility. Complete excavation and
disposal would eliminate public health risks entirely but would cost
approximately $8,600,000 - an expense that cannot be justified in light"
of the minimal health threat posed by the material as long as it remains
in place.
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8
(2) Asphalt Shielding: Very high cost ($1,233,410); adequate
protection of public health attributable mainly to the long-term controls
required for any alternative that includes leaving some or all of the
material in place; moderate to high reliability with long-term controls
on excavation and maintenance activities; high feasibility.
(3) Limited Asphalt Shielding: ,Moderate cost ($87,418); adequate
protection of public health; moderate reliability with long-term controls
on excavation and maintenance activities; high feasibility.
(4) Modified No Action: Low initial cost ($30,000); adequate protec-
tion of public health; moderate reliability with long term controls on ~x-
cavation and maintenance activities; moderate to high feasibility.
(5) No Action: No cost; slight risk to public health except if con-
tamination is spread during excavation and maintenance activities poten-
tially increasing public health risk; moderate to low reliability due to
lack of controls on excavation/maintenance activities; high feasibility.
The selected remedy combines features of excavation and disposal and
the Modified No Action Alternative. Initially the Modified No Action
Alternative was the EPA preferred alternative. However, in response to
concerns raised during the public comment period, the EPA amended the Mod-
ified No Action Alternative to recommend that the institutional controls
also provide for the safe disposal of contaminated material removed during
routine maintenance, repair, or construction activities in the affected
streets.
Community Relations
The public comment period for the Denver Radium Site Streets was
August 1, 1985 to August 22, 1985. The Feasibility Study and fact sheets
were placed in several convenient repositories. The public was notified
of the availability of these documents two weeks prior to the beginning
of the public comment period through a display ad in both the Denver Post
and the Rocky Mountain News. Press releases sent to community newspapers
and newsletters resulted in news reports about the solicitation of public
comments in the two major newspapers and on at least two TV and two radio
stations.
No public meetings were held during the comment period because prior
pUblic meetings held by the Colorado Department of Health were sparsley ,
attended and current citizen concern remains low. The EPA has met with
some concerned citizens and has expressed willingness to meet with neigh-
borhood groups or hold public meetings if the level of interest warrants
it.
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9
Most residents and property owners on the affected streets who com-
mented during and after the comment period expressed the preference that
the material be excavated and disposed at an approved facility. Some
government agencies voiced concerns about possible risks associated with
street and utility repairs and the need for more vigorous institutional
controls, in particular, provisions for the notification and monitoring
of street and utility work and for the disposal of contamlnated material
as it is encountered during routine maintenance, repair, or construction
activities in the streets. In response to the public comments, the EPA
developed the selected remedy which recommends that institutional controls
provide for the safe disposal of contaminated material removed during
routine excavation and maintenance activities in the affected streets.
Consistency With Other Environmental Laws
The standards for "Remedial Action at Inactive Uranium Processing
Sites," 40 CFR Part 192, serve as both the initiator and the goal of the
remedial actions at the Denver Radium Site. For properties contaminated
with uranium or radium processing residues, these standards establish
limits for the gamma radiation level and the annual average radon decay
product concentration in any occupied or habitable building and for the
concentration of radium in soil on open lands. Since the standards in
40 CFR Part 192 do not directly address the gamma exposure rate in out-
door, contaminated areas, the relevant and appropriate standard is 40 CFR
Section 192.12(a) which specifies the maximum allowable radium concentra-
tion in the near-surface soil. In order to comply with 40 CFR Section
192.12(a). remedial actions shall be conducted when the concentration of
radium in land averaged over any area of 100 square meters exceeds the
background level by more than 5 picocuries of radium per gram soil in the
upper 15 centimeters of the surface.
.
Only total excavation would satisfy this standard. However, the
Total Excavation Alternative was eliminated in the initial screening
because the cost of implementing this alternative far exceeds the cost of
other alternatives without providing substantially greater public health
or environmental protection. In certain circumstances, 40 CFR Part 192
provides that supplemental standards may be invoked. See 40 CFR Sections
192.21 and 192.22. Supplemental standards are appropriate when:
liThe estimated cost of remedial action to satisfy 40 CFR Section
192.12(a) at a ...site...is unreasonably high relative to the 10ng-
term benefits, and the residual radioactive materials do not pose a
clear present or future hazard. The likelihood that buildings will
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10
be erected or that people will spend long periods of time at suCh a
vicinity site should be considered in evaluating this hazard. Remedial
action will generally not be necessary where residual radioactive mat-
erials have been placed semi-permanently in a location where site-spec-
ific factors limit their hazard and from which they are costly or dif-
ficult to remove, or where only minor quantities of residual radioactive
materials are involved. Examples are residual radioactive materials
under hard surface public roads and sidewalks, around public sewer lines,
or in fence post foundations."
40 CFR Section 192.21(c).
If a supplemental standard is applied, the implementing agency must
select and perform remedial actions that come as close to the otherwise
pertinent standard as is reasonable under the circumstances. 40 CFR Sec-
tion 192.22(a). All of the alternatives remaining after initial screening,
including No Action, fully comply with these supplemental standards.
The following are other Federal criteria, advisories, guidances and
State standards which were considered when developing the selected remedy:
(1) Colorado Department of Health, Rules and Regulations Pertaining to
Radiati?n Control. CRS 25-11-101 et ~. and implementing
regulatlons.
(2) FRC, ICRP, and NCRP Guidelines.
The radioactive material is not, at present, licensed by the Nuclear Regu-
latory Commission (NRC) or the State of Colorado. However, if the.material
is used in a way that presents a hazard to human health, it becomes subject
to the control of the Colorado Department of Health. The EPA Region VIII
will take steps to ensure that disposal of any contaminated material removed
during routine maintenance, repair, or construction activities is consistent
with the EPA's off-site disposal policy.
Selected Remedy
The EPA selected remedy combines features of excavation and disposal
with the Modified No Action Alternative. The selected remedy meets the
supplemental standards for "Remedial Action at Inactive Uranium Processing
Sites" which were chosen as the goal of remedial actions at the Denver Rad-
ium Site. The selected remedy is a cost-effective remedial alternative
that effectively mitigates and minimizes threats to and provides adequate
protection of public health, welfare and the environment. .The costs of the
other alternatives are not justified in light of the marginal reduction in
risk they wou1d provide.
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11
The estimated initial cost of the remedy is $30,000. This includes
the cost of studying and then establishing the institutional controls
which would monitor all construction and utility work in the affected
streets. Since the streets were owned by a subdivision of the State of
Colorado at the time of disposal, the State is responsible for 50% of the
capital cost. A possible funding mechanism for the State .is its Solid
Waste Tax Fund or the cost share credit claimed by the State for its site-
related activities between January 1, 1978 and December 11, 1980.
Operation and Maintenance
The operation and maintenance activities required to ensure the
effectiveness ~f the remedy are (1) excavation controls and (2) recommended
provisions for disposal of contaminated material removed during routine
maintenance, repair, or construction activities in the streets. These ac-
tivities will continue for an indefinite time. The EPA has determined that
the State of Colorado or subdivision thereof such as the City and County
of Denver should be responsible for all operation and maintenance costs
including the costs of the ongoing program to dispose of contaminated mater-
ial removed during street excavations. The annual operation and maintenance
cost (non-EPA funded) will vary depending upon the amount of material exca-
vated during any particular year.
~
Schedule
Project implementation dates cannot be scheduled at this time due
to the CERCLA program slowdown. Once the slowdown is lifted, the following
key milestones will be scheduled:
- Start the design of institutional controls
- Complete the Design of institutional controls
- Selection of either a temporary storage or permanent disposal site
- Implementation of improved institutional controls
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Future Actions
The future remedial activities that are required to compiete site
response are:
(1) Design of institutional controls: A detailed analysis of the
required activities to establish improved institutional controls must be
completed.
(2) Selection of a disposal facility: A facility must be selected
for the proper disposal of any contaminated material removed during normal
maintenance and repair activities in the streets. The State of Colorado
is responsible for selecting a site for the permanent disposal of the Denver
Radium material. Until this decision is made, the State may opt to use a
temporary storage/staging area. EPA may, pursuant to CERCLA Section 111(a).
help the State fulfill its CERCLA obligation to assure the availability of
a disposal site (CERCLA Section 104(c)(3)(C)(ii)) by sharing in the State's
capital expenditures for a disposal site for the Denver Radium material.
.
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COMMUNITY ~ELATIONS RESPONSIVENESS SUMMARY
DENVE~ RADIUM SITE--OPERABLE UNIT 7 (STREETS)
January 13, 1986
U.S. EPA ~egion VIII
INTRODUCTION
This Responsiveness Summary was prepared to ~ccompany the
Record of Decision announci~g EPA's selection of remedial
action for the Denver ~adium Streets, Operable Unit 7 of the
Denver Radium Site. The Denver Radium Site consists of
11 property groups, each considered as a separate operable
unit for the purpose of investigation and remedial action
under Superfund. EPA conducted a Remedial Investigation of
the Denver Radium Streets and prepared a draft Feasibility
Study and ,Endangerment Assessment for Operable Unit 7, which
was released July 25, 1985.
BAC~GROUND
The Denver Radium Streets (Operable Unit 7) consist of nine
street seqments, totalling approximately 45 blocks in the
Denver Metropolitan area. One seqment is located in the
northern part of the central business district, while the
remaining eight seqments are located in the vicinity of
Cheesman Park, an urban residential area with some commercial
and institutional establishments.
f
The Remedial Investigation for Operable Unit 7 consisted of
field surveys to determine the level of radioactivity at
street level, and borings to determine the location and ver-
tical extent of contamination. The results showed that the
radioactive contamination is contained in a layer of material
at a depth of about 6 inches under the roadbed, and is en-
tirely confined to the paved street area.
The Feasibility Study (FS) identified a range of possible
remedial actions, and evaluated them based on technical fea-
sibility, cost, and extent of environmental or health pro-
tection each would provide. An Endangerment Asse.sment
evaluated the 'risks aasociated with the existing exposure
levels and the long-term effects from taking no action. It
was concluded that the radioactivity present in the .treets
does not exceed the recommended limits for general public
expo.ure, and that standing at the "hottest" location for
16 hours a day for an entire year would result in only two-
thirds the maximum recommended exposure for general public
health. Most of the street areas showed much lower levels.
Since the asphalt pavement offers a degree of 8hielding,
there is little risk if the material is left in place. A
greater risk may result from excavation and removal of the
material, resulting in exposure through other pathways.
1
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Three categories of potential remedial actions were considered:
removal and disposal of contaminated material: radiation
shielding with appropriate materials: and other alternative~
including no action, area exclusion, and institutional con-
trols. Based on these categories, five remedial alternativ~~
were developed and evaluated in detail in the Feasibility
Study. The alternatives were:
(1)
(2)
(3)
(4)
(5)
Limited Excavation and. Disposal:
Excavation of 194 cubic yards of contaminated material
found within 4,600 square feet of the most contaminated
street seqments, with removal and disposal of the mate-
rial at an EPA-approved facility for radioactive waste.
Total cost of this alternative was estimated at $148,050.
~sphalt Shielding:
Shielding to reduce gamma radiation by placing aspha~t
pavement over portions of the streets that are most
contaminated, based on readings of gamma radiation.
Approximately 36 percent of the total street area would
be paved, with about 295,000 square feet receiving
3 inches of asphalt, and 6,000 square feet receiving
5 inches. Total cost estimate: $1,233,410.
Limited Asphalt S~ielding:
Limited shielding of 8,025 square feet of the streets
by overlaying with a layer of 2 inches of asphalt.
Total cost estimate: $87,418.
Modified No Action:
Leave material in place7 establish institutional controls
and perform monitoring of all construction and utility
work in the streets. Total cost estimate: $30,000.
No Action:
Leave material in place7 maintain at present level the
monitorinq of all construction and utility work in the
8treets.
A8 lonq as contamination exposed durinq street excavation is
properly handled, any of the five alternatives would satisfy
th~ applicable or relevant and appropriate environmental.
requlations and health standards and would maintain .the gamma
exposure below the maximum recommended levels for the qeneral
public.
The Asphalt Shielding Alternative is the most costly, but
reduces the gamma exposure to the lowest level of the five
alternatives. The contaminated material would remain in
, .
, .
2
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t
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.
place, however, with a possibility of exposure due to future
excavations or utility work. .
The Limited Excavation and Dispo.sal Alternative would mini-
mize future exposure to residents, users, and street workers.
However, it requires the availability of a disposal site for
the material that is removed, and might temporarily increase
the hazards to residents and workers associated with removing
and disposing of the contaminated material.
The Limited Asphalt Shielding Alternative
level of gamma exposure to about the same
ited Excavation and Disposal Alternative,
the material in place.
would reduce the
degree as the Lim-
but ~ould leave
The Modified No Action Alternative would leave the streets
intact with no shielding and would not reduce current levels
of radioactive exposure, but protection from unnecessary
exposure would be provided by the enforcement of strict in-
stitutional controls. .
The No Action Alternative would leave the streets intact
with no shielding and would not reduce the current levels of
radioactive exposure. The Denver Public Health Engineering
Department would continue monitoring gamma radiation levels
. during any excavation in the streets.
f
As described in the Endangerment Assessment contained in the
Feasibility Study, the existing level of gamma radiation
does not exceed the maximum recommended exposure for the
general public. Since all five alternatives maintain expo-
sure levels below recommended limits and satisfy legal and
environmental requirements, EPA considered the Modified No
Action Alternative to be the most cost-effective remedy for
Operable Unit 7. .
The selected remedy is a combination of the Limited Excavation
and Disposal and the Modified No Action Alternatives. Ini-
tially, the Modified No Action Alternative was the EPA-
preferred alternat~ve. However, in response to concerns
raised during the ~ublic comment period, the EPA amended the
Modified No Action I Alternative to provide for the safe dis-
posal of constructfon activities in the affected streets.
I
ACTIVITIES CONDUCTED BY EPA TO INFORM THE PUBLIC OF THE
REMEDIAL ALTERNATIVES
The public comment period for the Operable Unit 7 Feasibility
Study (FS) was held from August 1 through August 22, 1985..
It was announced in a display ad placed in the'Denver Post
and the Rocky Mountain News two weeks prior to August 1.
EPA also'prepared a press release announcing the public com-
ment period, identifying the Denver Radium Streets, and
announcing the availability of the FS report and fact sheets.
3
"
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The press release was sent to the Denver Post, the Rocky
Mountain News, Westword, Life on Capitol Hill, and the
Washington Park Profile. The latter two are local community
publications. In addItion,. 650 copies of the press release.
were included as inserts in the Urban Dweller, ~ newsletter
mailed to members of the Capitol Hill United Ne;qhborhoods
Aasociation.
The study documents were placed in public repositories es-
tablished at the EPA Library, the Denver Publ'ic Library, the
Colorado Department of Health, and the Capitol Hill Community
Center. A qeneral fact sheet discussinq the Denver Radium
Site and a supplemental fact sheet summarizinq. the remedial
alternatives for Operable Unit 7 were prepared. Copies of
the documents were distributed to the repositories and the
fact shee~s were mailed to individuals and qroup~ on the
Denver Radium mailinq list. As a. result of EPA's activities,
media interest led to news reports on two local TV stations
(RCNC Channel 4 and KWGN Channel 2) and local radio stations
(KIMN and KOA) at the start of the public comment period.
Channel 2 and the Denver Post also did followup stories on
the closing day of the comment period.
~
CONCERNS RAISED DURING REMEDIAL PLANNING PHASE
Durinq the remedial investiqation of Operable Unit 7, resi-
. dents and property owners on the affected streets voiced few
specific concerns. However, some qovernment aqencies raised
concerns about possible risks associated with street
construction or utility repairs. Followinq incidents in
which street work was undertaken on Denver Radium Streets
without workers beinq aware of the contamination, officials
realized the need for better control measures. Provisions
for notification and monitorinq of street work were
subsequently established by the City and County of Denver,
but City, State, and EPA officials have continued to voice
the need for establishinq more riqorous institutional
controls, which is reflected in EPA's choice of a remedy.
CONCERNS RAISED DURING THE FEASIBILITY STUDY COMMENT PERIOD
Fifteen written clmments were received durinq the Feasibility
Study public comm.nt period. Nine letters were sent by af-
fected residents ,nd other concerned citizens, and a petition
was siqned by 12 residents of one of the Denver Radium Street
blocks. One letter was sent by an environmental qroup, and
a local enerqy firm sent a letter solicitinq radon monitorinq
8ervices. The City and County of Denver, the Colorado Depart-
ment of Health, and the Department of Enerqy also 8ubmitted
comments. Copies of all the written comments sent to EPA
are attached to this Responsiveness Summary, and the letters
are referenced by number in the followinq discussion.
, '
4
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The alternatives preferred by the commentors are as follows:
Excavation and Disposal
Shieldinq/Repavinq
Leave Intact/Institutional Controls
7
3
4
One letter (No. 10) did not express a preference, but raised
questions concerninq the development and evaluation of the
alternatives, and other related issues.
The issues raised, the level .of concern expressed, the number
of commentors mentioninq each issue, and EPA's'responses are
summarized below. The followinq discussion r~presents EPA's
response to the individuals and qroups that submitted com-
ments. Also attached is an errata sheet with corrections to
the Feasibility Study report. 'EPA's responses to the detailed
technical comments submitted by the other aqencies are not
contained in this responsiveness summary; rather, they are
addressed as corrections shown on the errata sheet or they
will be addressed in the Feasibility Study process for other
Denver Radium Operable Units.
General Concern About Radioactive and Hazardous Waste
E
Comment:
Response:
One letter (No.1) expressed qeneral outraqe about.
the presence of radioactive materials at the Denver
Radium Site as well as at the Rocky Flats nuclear
weapons plant and in uranium mill tailinqs. The
writer also questioned the possible presence of
radioactivity in streets in Boulder, Colorado
Sprinqs, or Denver suburban areas.
EPA indicated that the Rocky Flats Plant is on the
National Priorities List and is beinq studied as a
separate Superfund site. The uranium mill tailinqs
are beinq dealt with by the Department of Enerqy
under the Uranium Mill Tailinqs Remedial Action
Program. Other municipal streets in Denver and
Boulder have been investigated with no radioac-
tivity found. The Colorado Sprinqs area has not
been investiqated because there is no evidence
that radioactive materials were processed in that
area.
Public Notification and provision of Information
Comment:
One letter (No. 10) expressed concern about EPA's
provisions for notifyinq affected residents about
the public comment period and providing information
about the remedial alternatives. The commentor
felt that each resident should have been directly
notified and that an open forum (meetinq) should
have been provided. The same commentor also felt
5
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, .~
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Response:
Comment:
Response:
that the fact sheet did not provide sufficient
information about the technical aspects of the
remedies.
As described above, EPA pursued several avenues to
notify the qeneral public, as well as residents of
the affected area about the Operable Unit 7 public
comment period and the availability of information
about the remedial alternatives. EPA felt that it
was not necessary to send notices to every addressee,
and that the 650 notices mailed with the Capitol
Bill United Neiqhborhoods newsletter would ade-
quately notify area residents.
EPA has met with concerned individuals and upon
request would be willinq to meet with neiqhborhood
'qroups or hold public meetinqs if the level of
interest or concern warrants it. Prior meetinqs
held by the Department of Health were sparsely
attended, and minimal interest has been expressed
in site activities.
The fact sheets prepared by EPA'are intended to
provide qeneral information about site activities,
nontechnical summaries of the results, and the
remedial alternatives. They also announce the
availability of the technical study documents in
the public repositories~
t
Technical study documents contain executive sum-
maries, as well as detailed discussion of the tech-
nical information. EPA will continue to assure
that the public has access to them in the reposi-
tories. In addition, EPA will provide copies of
the executive summaries of future Denver Radium
RI/FS documents directly to anyone requestinq them.
The Colorado Department of Health (CDB) (No.5)
expressed concern about the amount of time for
their review of the Feasibility Study document
prior to public release.
An earlier draft of the document was submitted to
CDB for review and EPA considered these comments
when revisinq the FS. Under the Manaqement Assis-
tance Cooperative Aqreement between CDH and EPA,
all Feasibility Studies and other major Denver
Radium documents that have not already been pro~
vided for State review will be furnished to the '
State in advance of release.
6
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Degree of Risk Associated with the Denver Radium Streets
Comment:
Response:
Comment:
Response:
One letter (No.3) was received from a long-time
resident on one of the streets who felt that there
is no threat to human health and that EPA should
leave the streets alone. However, six other com-
mentors (Nos. 1, 2, 8, 9, 11 and 13) expressed
considerable concern about exposure to radioactivity
if no action was taken or if excavation or street
repairs are done. These individuals felt that any
amount of radioactive contamination warrants exca-
vation and removal to prevent exposure.
~o letters (No.2, 10) questioned the level or
dose of radioactivity and the standards that are
a~plied. Two writers (Nos. 9, 10) expressed con-
cern about the cumulative effects of continued
exposure to any amount of radioactivity and one
(No.9), who also spoke directly with an EPA rep-
resentative, questioned the risk compared to other
types or sources of radioactive exposure.
These questions are addressed in EPA's Endangerment
Assessment, as part of the Feasibility Study for
Operable Unit 7. The levels of radioactivity mea-
sured on the streets during the field work was
assessed and ~ompared to the quidelines that esta-
blish maximum recommended limits to the general
public for lifetime exposure. Information was
provided about the level of risk associated with
long-term exposure in the area where the highest
readings occurred, and showed that levels were
within the guidelines. Commentors are referred to
the Endangerment Assessment for a detailed discus-
sion. The results of the Streets investigation
showed that the contamination and exposure levels
do not JustifV complete excavation and disposal.
A related issue was raised concerning the detection
of the radioactivity (No. 13). The writer felt
that if the levels were high enough to be detected
even though the streets have probably been repaved
several times, then there must be a risk that would
not be eliminated by covering the streets.
~
This is explained by the 8ensitivity of the instru-
ments used in EPA's investigations. The instruments
can detect even small changes in natural background
radioactivity and can detect levels of radioactivity
significantly below levels thought to pose a signi-
ficant health risk.
7
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Comment:
Another writer (No.6) expressed "moderate" concern
about the radioactivity unless diqqinq or street
work takes place. This letter reported that when
aome work was done on a Denver Radium street last
year, the authorities were not notified and no
precautions were taken. The commentor raised ques-
tions about risk to the street workers, and about
potential exposure due to potholes in the contam-
inated streets.
EPA encouraqes anyone observinq such conditions to
immediately notify the City and County of Denver,
Department of Health and Hospitals (893-6241),
which has responsibility for monitorinq street
work. The City has already established a permit/ '
~otification requirement for utility and street
work involvinq excavation on the affected streets.
EPA's recommended remedial action will auqment the
current requirements and establish more riqorous
control and monitorinq systems.
Availability of Disposal Site
Response:
Comment:
Response:
Comment:
Response:
Three commentors (Nos. 5, 6, and 13) referred to
the availability of a suitable disposal site if
material is removed from the streets. One commentor
(No.2) referred to the EPA requirement to dispose
of radioactive hospital wastes, and questioned why
other radioactive material, such as that found in
streets, could be left in place.
EPA responds that hospital wastes come under more
strinqent requirements because they are often much
more radioactive than the material in the streets
and are usually in forms that offer a much qreater
chance for human exposure.
Two commentors (Nos. 6 and 13) were in favor of
removal, but were concerned about the availability
of a disposal site. One questioned the cost of .
disposal and who would bear it, while the other
(No. 13) encouraqed the State and EPA to work to-
qether to establish a disposal site.
EPA acknowledqes the need for a disposal site,
which is the leqal obliqation of the State. Since
Colorado does not currently have a disposal facil-
ity for radioactive waste, EPA is studyinq dispolal
options for any material that may be removed'from
the Denver Radium Sites. The Disposal Site Study
is intended to assist the State in fulfillinq its
'Obliqation to provide a disposal site for Super-
fund wastes. EPA will announce the availability
8
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Comment:
of the study for public review. The preliminary
conclusions that may be drawn from the study are
that the options for immediate disposal are ex-
tremely costly, and other options will probably
not be available for at least 3 years. For these
and other reasons, EPA feels that the excavation
and disposal alternative is not a cost-effective
solution for the Denver Radium Streets at the pre-
sent time.
Comments received from the Colorado Department of
Health (No.5) suqqest qradual excavation and re-
moval of the material as future street work is
carried out. The State further suqqests estab-
.lishinq a fund to provide for the cost of such
activities.
EPA believes that such a remedy is appropriate,
but would have to be implemented by the State and I
or City/County of Denver since fundinq for onqoinq
or future maintenance activities falls outside the
Superfund proqram.
In arrivinq at its final selection of a remedy,
EPA has also considered the costs of immediate
versus qradual excavation/disposal as they may
affect other aqencies or individuals. Immediate
excavation/disposal (Limited Excavation Disposal
Alternative) would cost approximate~y $150,000 and
provide no material health and safety advantaqes
over "no action." Since the streets are City prop-
erty, the costs of remedial action would be allo-
cated 50 percent to Superfund and 50 percent to
the State, as provided by CERCLA. The State in
turn may pass the cost on to the City and event-
ually some cost burden may be borne by property
owners. However, the health and safety benefits
of better controls on excavation could be improved
by prov1dinq a safe method to dispose of contam-
inated ~aterial found durinq excavations. There-
fore, EPA has added a provision for this in its
selection of a remedy.
I
I
Effectiveness of Institutional Controls and Monitoring
Response:
Comment:
Concern about controllinq excavations and monitor-
inq street work was expressed by two private citi-
zens (Nos. 2, 6), by the City and County of Denver
(No.4), and by the Colorado Department of Health
(No.5). One commentor (No.2) felt that control
of private contractors would be difficult, and
future street administrators would need to prevent
9
f
-------
digging up the streets for repaving. Another writer
(No.6) felt that covering the streets would do
little good if excavations were often taking place,
and questioned how this could be controlled. The
Department of Health (No.5) cited the -difficulty
of maintaining institutional control"-and empha-
sized the need for a formal mechanism within the
City and County of Denver to ensure control.
Response:
EPA recognizes the need to establish strong insti-
tutional controls for notification and monitoring
of work on the Denver Radium streets. This was
the focal point of EPA's preferred alternative.
EPA is aware that the present system has not always
worked well in the past. Furthermore, the Agency
recognizes that effective controls on excavation
,would be necessary even if shielding or partial
excavation were implemented.
EPA believes that institutional controls are neces-
sary to prevent inadvertent exposure and to ensure
that any contaminated material that may be removed
in the course of future street work is identified.
With joint participation of all the involved agen-
cies, EPA believes that an effective system can be.
established. EPA assistance will be made available
to the City/County in devising appropriate systems
for this purpose.
.
CONCLUSION
The foregoing summary indicates the nature of the comments
received during the August 1-22 public comment period and
the issues raised regarding the remedial alternatives con-
sidered for Operable Unit 7 (Streets) of the Denver Radium
Site. EPA has taken the comments and recommendations into
consideration, and its responses are summarized here. Based
on the comments received during the public comment period,
EPA amended the recommended remedy to include provisions for
safe disposal of contaminated material exposed during street
excavation and repair. Bowever, because the type of excava-
tion and disposalilprogram recommended is largely a street
maintenance activ~ty, implementation of this remedy is pri-
marily the respon~ibility of the City and County of Denver
and the State of qolorado. On balance, this remedy is in-
tended to satisfY'lthe concerns of proponents of excavation
and disposal without the adverse impacts of the costs and
disruption that would accompany a major short-term program
of excavation and disposal. Since the contamination present
in the streets poses no significant health threat as long' as
it remains in place or is properly disposed of once excavated,
the remedy will be fully protective of public health and the
10
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environment as well as being cost-effective. Further details
on EPA's decision and the justification for its choice of
remedial action are provided in the accompanying Record of
Decision.
DE/DENRDS/046
i
11
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ERRATA
DRAFT FEASIBILITY STUDY
STREETS, DENVER RADIUM SITE
JUL Y 2 6, 1 9 8 5
Paqe Paraqraph and
No. Line Nuznber(s)
ii 3, 3
Hi 1, 4
iii 1, 5
iv 2, 1
iv 3, 1
ix Table
ix Table
1-1 2, 1 & 2
1-6 Fiqure 1-1
1-7 Table 1-2
1-8 3, 1
1-10 Fiqure 1-2
Alterations
Should read "9th Avenue from Ogden Street to
Cheesman Park"
Should read "Lafayette Street from 1st Avenue
to 9th Avenue"
Should read "Marion Street from 6th Avenue to
9th Avenue"
Should read "...potential remedial actions..."
Should read "These remedial action alterna-
tives..."
Table 2-1 should be labeled "Denver Radium
Streets, possible Remedial Actions"
f
Table 3-4 should be labeled "Rejected Alterna-
tives, Denver Radium Streets"
Should read "...remedial action alterna-
tives..."
Identification of street seqments should be
made consistent with those on paqes ii, iii,
and on Fiqure 1-2.
Title of table should read "Site Groupinq,
Denver Radium Sites"
Paraqraph headinq should read "Denver Radium
Streets." Replace "...Section 1.4" with "1.3."
Street No.2: Chanqe "York" to "Josephine
Street"
Street No.3: Chanqe "7th" to "9th" Avenue
Street No.4: Chanqe "10th" to "9th" Avenue
Street No.5: Map should indicate seqment and key
should read "Humboldt Street from 7th Avenue to
9th Avenue. Street No.6: Chanqe .Downinq" to
.Cheesman Park"
Street No.7: Chanqe .Stout" to .California
Street"
(Alao note: s~e chanqes apply to map on
Group 7: Streets Fact Sheet Supplement,
Auqunt 1985)
-------
Page
No.
Paragoraph and
Line Number(s)
1-16
2, 13
1-17
Table 1-4
2-1 3, 2
2-1 ' 5, 4
3-1 heading
3-1 1, 1
3-7 2, 10
3-12 Table 3-4
4-4 2, 4
4-9 3, 4
4-12 Table 4-4
5-1 Table '5-1
7-2 1, 1
7-3 5, 1
8-1
2, 5
ERRATA
(continued)
Alterations -
Replace "Figure 1-2" with "1-3."
For Boring No.2, Contamination Depth
Pavement Depth is 10". For Boring No.
tamination Depth is -10". For Boring
Contamination Depth is 6".
is 12"~
3, Con-
No. 12,
Should read "...Denver Radium Streets."
Should read
tude) . . . "
"... (e.9.
by an order of magni-
Should read "Chapter 3"
Should read "The remedial action alterna-
tives..."
.
Should read "...asphalt or regular..."
Headinq should read "Rejected Alternatives,
Denver Radium Streets"
Should read "... (Baker, et al., 1984)."
Should read "... maximum gamma. of 57 IJR/hr."
The total cost for Raisinq Manholes should be
$300. Total cost for the limited shielding
alternative is changed to $84,718. (Due to
the relative cost of this chanqe compared to
the other alternative estimates, this total
will not affect the cost evaluation of the
alternatives.)
Chanqe Ltmite4 Shie14 Capital Cost to. $84,718.
Changoe "2 feet" to "3 feet"
Responses to Comments are provided in a
.eparate Responsiveness Summary to be attached
to the Record of Decision.
Should read "...exposure limit of 500
mrems per year for non-occupationally ex-
posed individual members of the general pop-
ulation."
I,
. ~.
-------
Page Paragraph and
No. Line Number(s)
Appendix A
3-3
3, 9
References Section
DE/DENRDS/047
ERRATA
(continued)
Alterations
Should read "...(80,000 and 1,620 years,
respectively) ,..."
Add the following references:
National Regulatory Commission, 1983, Stan-
dards for Protection Against Radiation
(10 CFR 20), 2S FR 10914, September 28, 1983.
EPA, 1982, National Contingency Plan, National
Oil and Hazardous Substances Contingency Plan
(40 CFR 300), [SWH-FRL 2163-41, July 16, 1982.
Baker, E.G., Hartley, J.N., and Freemen, H.D.,
1984, Asphalt Emulsion Radon Barrier Systems
for Uranium Mill Tailings--A Summary of the
Technology, presented at the Sixth Annual Sym-
posium on Uranium Mill Tailings Management, Fort
Collins, Colorado, February 1 through 3, 1984.
f
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. Richard S. Snyder
1~50 Columbine
Denver, CO 80206
Augusc I, 1985
~~
EPA Office of Public Affairs
899 18th St., $Wte 1300
Denver, CO 80202
SIn:
T'his letter concerns Denver Poat article of Wednesday, July 31, 1985, p.4A
which detailed the radioactivity of certain .treetS in Denver. I and my
family live very near aome of these .treetS. Tbe article .also aid the EP A
8OUc1ted comments on the bandling of the matter.
The first question that' comes to mind is the nature of the radioactivity and
the amount. If it II from radium, then quantitatively, in rads, what 11 the
Itrength of the dose?
The second question concerns the law. I work at Porter Memorial Hospital,
am a registered Medical Technologist, and am the Maintenance and Safety
Supervisor for the laboratory. We are required, by the EPA, to dispose of
even the smallest amount of long-lived radioactive substances through an
authorized contractor who scores the material in a safe and approved maMer.
It seems that the streets are hardly a safe and approved disposal site for
radium.
~
I think that controll1ng the excavation of the affected streets is virtually
Impossible. Nature does plenty of her own. Private plumbers carve their
rectangular slabs out for recapping older bomes' water lines into the city's
main. Someone is going to have to keep track of these streets for the Ufe
of their radioactivity.
Raising the street level by paving over them doesn't seem to the the best
IOlution. Again, someone is going to bave to warn aubseqent generation of
road administrators that they can't rip up all the pavement to pour additional
layers of paving, 81 11 done now to prevent the level of the street from
letting out of band. . .. .- ..0.. '.0 --- .
It teems Uke the only looc1 long-term choice II "Digging up, removing and
disposing of the contaminated asphalt," to quote the Peat article. The
Superfund should be able to handle that-It's hardly In the ..me leque wtth
the Rocky Mountain Arsenal.
~
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-------
"
Federico Fe1ia
MAYOR
City and County of Denver
CTY AND COUNTY 1U11.DINC 8 DENVER. COLORADO 880202
. 1ELEPHO~OCW~Z721
COMMENTS OF THE CITY & COUNTY OF DENVER
ON
EPA PROPOSALS FOR DENVER RADIOACTIVE STREETS
AUCUST " 1985
The City' County of Denver and Its Depar~nt of Heal th C Hospitals
are concerned abo'Ut the 8111 tan Ings from radt~ process Ing that have
been mixed with asphalt and utilized In pavrng certaIn parts of Denver's
streets. Continuous monltorrng by the City and EPA show that radiation
1evah have r...rned const8nt Iince 1979. The levels are 'Very low and do
not prelent a health hazard to Denver residents, even those Jiving adjacent
to the cont..rnated streets.
f
We are concerned that an attempt to excavate the radioactive materia's
.yexpose residents to a greater health danger. Any unnecessary release of
radiation should be avorded.
For this reason, and .the hrgh cost Involved In removal and dISposal. It
~uld be our recommendatton that the streets Invotved be overlaid with a new
asphalt coattng which would elimfnate any potentiat hazard from this materIal.
The limited resources available wIll be better spent cleaning up some of the
other radhn sites. Ve look forward to actIon on the remaining radi&a sites.
\ .. . -..-.. .... . .;."'; '... .
Thank you for Inviting comments on this health concern.
..- I "H-7Yl~....
TOny'1lassaro .
DI rector of bvl ronment Affai rs
IJ!:~IEIID
Suoerfund
AlmIClIaJ Branch
. I. .
i / ~U.t.:~
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/'"
,
CCLC~ACC
RiChard O. Lamm
Govemor
tOt ~vt.\
K. -'-' '-~,.. 'tP
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CEt=ARTMENT OF HEALTH
. " l'..r ..IJ"""/ .
.".~. Thomas M. Vernon. M.D
1 8 'Z \) Executive Director
~.!:1
August 12, 1985
John Brink, Remedial Project HaD&ser
Super~unt Branch
U.S. EQv1roumeQtal ~otectiou Agency
One De~ver Place
De~ver, Colorado 80202-2413
8~.
A_.
Denver.Radiu= Streets Feasibility Stud:.- .
Dear ~rr. Brink :
Enclo.ed are our leneral comments to Mr. Duprey, and our detailed comments for
,our ue. It would have been better if we could have reviewed an in-house
draft of this dOCWleut before it vent public 10 that a lot of these II1Qor ~
items and typos could have been cleared up first. We 8UISest that Tom Stauch
at Denver Public Health Enaineer1Qa &lao be afforded that lame opportunity.
With re.pect to comments 3 aud 18, althoulh the eztremely cOl:1servative
approach to e%1)Osure calculation u.ed here I18Y .erve .at1.factorily for
cOllpar1na options, it can live a .,e1'7 .illeadiq apres.ieu if take eu an
ablolute baail.
We look forward to your Ichedu1inl a joint lIeetins with the Cl ty of Denver
officials after the close of the comment period.
Sincerely,
tli+t!J t~ct.r
Radiation CQQtrol Division
AJH/BG / f/JIJ
Ibelolures
cc: T. r.abody
I.. Duprey
T. Looby'
C. Sutton
/'
4'10 F.A~T 11TH AVENUE f"\f:~". i:r-' ~OLCqADO 80220 PHONE (303) 320-8333
-------
. '
. .
,.",~............
~
-
-
I
CCLORACC
Richard O. Lamm
Governor
Thomas M. Vernon. M.D.
Executive Director
~au.t 13, 1985
"obert Duprey, Director ,
Air , Wa. te Man.aaelDen t D1 v1810n
U.S. hv1rCll1Jlmtal Protect1cm Aaency
ODe Daver Place, Suite 1300
999 18th Street
Denver, CO 80202-2413
,'.
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Dcv,u ladium Streeu le.s1bWty Study (7-2S~5)
Dear ~r. J)upny:
this July 2.S, 1985 vers10n of the fe.sibility I tudy 18 nch improved over the
Ka1'Ch 7, 1984 TUI1on. Under .eparate cover ve .n prov1dina John Br1nk viti
detailed COIIDHU ta; 1111 offer here ouly ...,eral pneral C01l8ef1 ta &8 noted belovo
I would lJke to _pbaa1ze apin the need for adequate time for the State tc
rev1ev these documents before their public action. 111is fea.ibW.ty .tudy vi!
azmounced to the' public before we .aw . copy of it.
The princ:.ipal concern with the radioactive ..terials under the Denver Itreet~
18 the potetial for 10.. of control ed aiau.e a. bas happeed with .imila:
..terials in Grmd Junction and el.ewhere. the difficulty of u1nt ''ll
wtitutional ccmtrol over this kind of location baa already bem _de e "41'
in Grmd Junction ed in Denver during the last five year.. Although ve .rt
not aware of any .isule of the Denver .treet _tenal .ince ita discovery iJ
1979 we are acutely aware of lAP. in in.titutioD&l control.
'l'he bazard of tbe CCIDt.uinaticm in ita pnamt location 18 not arut COUlh tc
juatify the co.t of its immediate reIDoval under the proar_. U long .. thl
cCll1t&mwtion is in the .tneta however, than 18 a potctial for it!
1mcontrolled raoval and iZLadwrteut use under or near .tructures. '!his coull
acerate a def~te ,!Ddoor radon hazard.
We 8UlBest theefore two pneral approaches to prevent future problems: Firs'
there needs to~. atabliaheci with1A Denver Clty GoverD8ent a 8Uch 80re foma:
_Cban1t1l for controllina interaction with thue ..tenals on the part 0:
.treet ad uti.1ity womer.. SecODe!, a fuI1d and d!.poaal faciJ.1ty needa to bl
.et ..14e 80 tbat in the fumre conf'..4"8ted ..terial can be properly di.po.e<
of *- it 18 as into or ftaOftd duriDa the cour.e of nomal npair 0:
npavSna actiTitie.. W. would anticipate that during a hUllcired year tiaefralt
caplete nCOI18t:uction of tha road bee! would b. acc:caplished ed thl
coutaa1nation would h8Ye been r_oyc. ' ,
It 18 aur UIlder.t&n&g that the Dcver authorities .h.e thase Tie". and tna~
our three orpnizatiCl1l CAn arrive at a 8Utually acceptable 8Olution.
Smcerely.
/~1~
Thoma. P. LoobY
Remedial Pro(r8mS Director
cc : To. Peabody J DH&H
Euclosures
4210 EAST 11TH AVENUE DENVER.COLORADO 80220 PHONE (303) 320-~~.~-~
-------
Radiation Control Division
"'"'~
INTER-OFFICE COHMt~ICA!ION
. ,
amt :
TO: Denver Radium File
DAII:: :
SUBJECT:
Augus t 2, 1985
EPA Feas ibllity Study -
Denver Streets
1. CameweU
Colr.len t ,
Commen t
1
2
3
4
s
6
7
8
'age
111
1-16
1-16
1-19
2-3
2-6 .
3-1
3-4
'aragraph
Table
'Should make clear ~ether these are
corrected readings.
2
'!be notification system to Denver Public
Health Engineering has falled on occasion
cd needs Itreqthm1ng.
The moultored escavatious are ln Flg. 1-3
DOt 1-2.
2
6
The likelihood of a person lpending 16
hours a day for 365 daya a year on a
Denver 1lad1u.m Itreet il zero.
~
5
If the ccmtam1Daticm vere to let .
red1ltributed alona utllitles during the
course of escavatlon and ccmstruction
activities, the potentlal for a radon
problem could arile.
3
3
Ibid.
Special pavement removal equipment 11
rout1nely uaed by the City of Denver.
%bls might be partlcularly uleful for the
.treets where the ccmtall1Datiou appears to
be in the lover layers of the pavement
1 tlelf .
: 2
The prtncipal concern wlth thl. k1nd of
..tertal 18 the potentlal for uucODtrolled
future relocation and 1nadvertent ule
under buUd1Aas. the c!1ff1culty of
.aintalninl control in the.e locat1ons 15
already evidet in Denver and Grand
.lanct1on.
-------
., c.., c-
t\.ca -........ . ..c
AU8\1st 2, 1985
Page 2
Co=en t I
13
14
15
16
Page
9
3-7
10
3-6
11
~-10
12
4-2
4-4
5-4
Ap A 3-3
Ap A 6-3
P3ragraph
2
last
3
4
7
3-
T&ble 6-1
#5'
ColllZ:len t
,
Adding a layer of pavellmt could
necessitate additional co.ts for raising
lUtter" curb., .1dev&lks and dra1nages.
H01'1l&J. .treet repavul involves pnor
relloval of the top layer to avoid
ezces.ive buildup.
Ezcessive cost is al.o a c~siderat1on.
with h1lh density concrete.
AD alternative which .hould be c~1dered
18 tbe provu1on of . .t&ndby fu:d to -
Cover future removal and d1.posal of
aater1als 8ZC&vated durinl normal street
repair and repav!.nl act1v1t1e.. lout1Z1e
8urfic1al repavu8 (top 4 inches) 18 done
about every 5 to 10 year.. At 2S year or
lo11&e r in tervals, depend1A1 on wear,
deeper repaving 1ncludiDs rebedd1D& ..y be
done. At that po in t in tae tbere needs
to be a repository and fuud1ng to take
care of removed con tam1u t1on.
E
One can't 8elect1vely repave port1~1 of
8treet to different elevations. A block
or lIore !DUS t be d~e completely. Because
of impacts on draina8e p&tterua,
. addit1oU&l non-cOD t&m1nated .treea 81lbt
have to be repaved.
See CO-en t 8.
-- 40 en 192 could alao apply to a part1&1
ft8oval. -
°T-1/2 for Th230 18 80,000 year8 Dot 8000.
What 18 tbe appl1cabU1ty of thae
8 tandards to th18 prolral
It 8hould be pointed out that the CDH
p1del1Du refer to the decont&m111at1on of
fac11it1u and equ.1 plent prior to release
for uurestr.1cted use.
f
-------
~
, DcnVt.r
, ' .\u~nS t.
h~e )
!{.,,j lll!:! File
~, 1.1):~ 5
Co~~"It!~ t iI
r.1 :.1:' ~jjP;1
P,\-c
---
\7 Ai) A R-t .,
11~ :i-'! :!
*5
Co..l.~l:~' t
,
'rVpo - shf)uld
r~ms.
r.~ \ 1 ~!:':T'lt')sur~
ttmtt uf 500
'n\~ short..r LI."., SC("l~I,j~I')!oO Ir~ stIll ",,,,",
tl)1J 11m.'. fr)= .1:\:' r~.1!;(Jn.1~l(: e:.cj)Usu=\.: to
wor't..Qen or C~::=-'J:~rs. Ht')\l~'/ert c:on.,'!:-~Ir)~
of t:~~ 5lrl.'~~ VI ~ :n:~ su~:. 115 t~.~ 1.bt'l
-Sc :'e-::t 'Ia ~ 1. C:"':~~ ~ t
-------
/./
.
-.. tym.
1S1S loa 7tt1 Avenue
D.nwr. C.ado 80218
377-$100
.tb
~ ~~../ .-
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~~~- ?~-~'?7~,. .
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...-:
,,'
*6
Jou ¥.
1515 EQIt 7th Awftu.
D.m.r. C:ob-Qdo 80218
377~100
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-------
,
Dill
...
-~
.Jou Iy",.
1515 EQIt 7th Awn..,.
o.nv." Cokwado e0218
377~100
jib
~~~ ~~. ~:.-r-
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~-
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........ .-., ". ~
- ~~ ?
-------
..
I -
-------
Mark W. Tatge
-1044 Downing St.
Apt. 302
Denver, CO 80218
.~
1'6
. .
. ~ :- .
. -,
Aug. 21, 1985
EPA
Off1ce of P~b11c
999 18th St.
Suite 1)00
Denver, CO 80202
Dear Sir,
Affa1rs
This is 1n response to your request of What to do about the
rad1um tailings in my street.
I shouldn't really have to write this letter.
of action should be obvious - dig it all up.
Superfund 1s for.
Please don't tell me that the radium tailings are not harm-
ful. I don't believe it. Nor am I as gullible as the sailors
who watched the early nuclear tests at Bikini Islands with
U.S. government assurance that it wasn't harmful.
The course
Tba t 's w ha t
So clean that mess on rrrr
jail that put 1t tnere.
~Y
street up and throw the people in
P.S. Please 8end me a complete report of what you intend to do
. 80 I know whether I 8hould move or not.
-------
~~
Auqust 22, 1985
Environmental Protection Aqency
Office of Pu~lic Affairs
999 18th Street, Suite 1300
Denver, Colorado 80202
Gentlemen:
With reqard to the Superfund money allotted for cleanup
of the Denver streets in the Capitol Bill "area paved
with asphalt mixed with uranium mine tailinqs:
Please don't pave over them. Please don't pretend that
the pro~lem will qo away. Remove that stuff from our
streets and dispose of it safely.
Most of us are aware that there are -acceptable" amounts
of radiation...amounts we can and do a~sorb before any
harm is done to our ~odies. New technoloqy has entered
our society at a rapid pace throuqh the work place, the
environment and at home, and has brouqht with it an in-
creased exposure to ~all doses of radioactivity. I think
that aqencies responsi~le for protectinq the welfare of
people in our society must do everything possi~le to
eliminate unnecessary radioactive danqers wherever they
occur.
f
Danqer, it seems to me, lies as much in small amounts of
radioactivity absor~ed cumulatively as in larqe, isolated
and well-publicized exposures.
Thank you for allowing me to express my opinions on this
matter. I stronqly urqe you to consider them when a
final decision is made.
Sincerely,
x' ~ r1I~
L. Carol Christopher x
1424 E. "Tenth Avenue, 17 9"",. 'I
Denver, CO 80218 J~~~: ~
~~ ~~ ~~ ~.
~~~
-------
l,oQ
F'Q~Ty.SECQNO F'~QQR
1801 C"'L.I"Q~NIA ST~EET
OEN"E~. CQL.Q~"'OQ 80202
August 22, 1985
Marilyn Null
o.s. EPA'
Office of External Affairs
Suite 1300 .
999 Eighteenth Street
Denver, Colorado 80202
Re:
Denver Radium Group 7-Streets
Dear Ms. Null:
I am a homeowner at 121 Lafayette Street. Baving
reviewed the July 1985 Superfund Program Fact Sheet and
the August 1985 Fact Sheet Supplement, I am disturbed by
a number of aspects of the. Denver Radium Site program.
1. Notification and Public Comment. As there
are only nine limited street seqments involved, why has
there been no attempt made to notify the residents of these
streets as to the situation, the proposed remedies and
the fact that they have the ability to have an input into
the situation? It would seem rather simple to have mailed
the applicable fact sheets to each of the involved property
owners, as they are an easily identified group.
Bow can it be said that a .public comment period"
exits when no attempt is made to communicate the existence
of a probl~ to the limited easily identifiable group of
residents affected and interested in making comments?
Would it not be more appropriate, if public comment'is
truly desired, to notify each resident on the affected
streets and to have an open forum for discussion of the
three proposed alternatives?
2. The Three Remedial Alternatives. Bow can
residents be expected to form any views as to the three
alternatives mentioned in the ract Sheet Supplement when
DO discussion of any type is provided therein with respect
to these alternatives. Will the removal process produce
higher short-term radiation levels? What will be the cost
of removal and disposal and what are the factors that cause
the EPA to determine it is not cost-effective? What factors
were evaluated by the EPA in determining that leaving the
radioactive material where it is, obviously the easiest
-------
L
~/O
Marilyn Null
Auqust 22, 1985
paqe Two
and cheapest alternative, is also the most cost-effective
solution?
On the subject of cost-effectiveness I would
simply raise the issue of how it is determined that the
situation is so safe that cost-effectiveness is the appropriate
test? When a rock climber, who has willinqly and with
full knowledqe assumed the risks of his endeavor, is hanqing
onto a ledqe in Rocky Mountain Park, is an auditor brought
in to determine the cost-effectivness of using an Army
helicopter to.rescue him? Other similar -emerqency" analogies
abound. Should the fact that in such situations a life-threatening
situation is clearly manifest, as opposed to an increased
cancer risk manifesting itself over 20 or 30 years, be
sufficient to allow the -no-cost" alternative of basically
iqnoring the street radium problem to become the -most
cost-effective alternative."
~
3. Bow Much Radioactivity is There? This question
is answered in the Supplemental Fact Sheet by statinq that
16 hour a day exposure for an entire year would result
in only 8two-thirds the maximum exposure under federal
standards.- Are these standards for annual exposure, lifetime
exposure or some other time period? Is there a cumulative
effect of 30 years of exposure and is that factored into
your calculations? Bow hiqh must an increased cancer risk
be before it becomes cost effective to remove radioactive
material?
More importantly, why should unsuspecting residents
bet their lives on being at two-thirds of current federal
standards? Are these the same standards under which above-ground
nuclear tests were permitted in the Western United States .
in the 1950s. The concept of -safe- amounts of radioactivity
are still evolving and I for one am not reassured by being
at the two-thirds level of today's maximum exposure standards.
What is the increased cancer risk at the two-thirds level?
4. Conclusions. I do not believe the comments
of concerned citizens have been adequately solicited as
no at~empt has "been made to contact directly the residents
of the affected streets. No adequate justification is
presented in your written materials as to why leaving the
radioactive materials in place is anything other than the
cheapest solution. No adequate attempt has been made to
explain the health risks to the affected residents. To
simply state that the EPA considers one solution the most
cost-effective and that radiation levels are at most two-thirds
..
-------
,,*10
Marilyn Null
Auqust 22, 1985
paqe Three
.of current maximum federal standards, is not, in my opinion,
an adequate discussion and qive-and-take for a democratic
system. Finally, why has the EPA not sought a public forum
in which the questions raised in this letter and those
of other concerned citizens ~an be answered?
-Ya~ truly yours.
,-- {::.::w it:: ?-
Richard M. Russo
RMR/bmc
~
-------
1f II
F'ORTy.SECONC F'I.OOR
ISO I C"'~I"O"NI'" STR!!T
OENVER. CO~OIlt...CC eozoz
Auqust 22, 1985
Marilyn Null
U.S. EPA
Office of External Affairs
Suite 1300 '
999 Eiqhteentn Street
Denver, Colorado 80202
Re:
Denver Radium Group 7-Streets
f
Dear Ms. Null:
Attached is a petition reqardinq the above-referenced
situation siqned by all of the residents of the 100 block
of. Lafayette Street who could be contacted durinq the last
two days. I am certain similar petitions would be generated
on other blocks, with siqnatures by an equally hiqh percentaqe
of residents, if a qenuine attempt to notify all affected
residents is made by your office.
V~QllL
Richard M. Russo
RMR/bmc
Enclosure
-------
Ma~il..,..n Null
,. :# 11
~~~ lStr-, St.
u.s. EPA Offi~e of Exte~nal
Affilil"'s
Sui tel::0')
Denve~, Colo~~do, 80:0=
Dea~ Ms. Null,
Tne
under5ignEtd
Street.
01..11'"
st~eet h~s been ident1fied by tne EFA as ~ontAining
rAdium
pl"'O~.ssing
l.yers.
We
a~e
residents
of
.the
100 blo~k of Laf.yet~e
waste
in
SubsurfAce
Asphillt
and .ggregil~e
~onsidered,
two
understand
remedial m.asures Are being
materials
in
pla~e. Le~ving any ~ontaminated materials in pla~e
that
.
three
of
whi ~r-I
involve
l.ilving
tr-..
cantaminated
is un.~~eptable to us. As strongly a5 Possible we urge the EPA to
remave
and
dispose
LAfAylttte
of
the ~ontaminated material not only from
Street, but fl"'om All the streets in the eMeltseman Park
.re~ And upper dawntown. .
S~lly Russo
You may ~orre5pond with us through;
121 LAfayette St.
Denv.r, Co. 80=18
Thank you for your Atte~tlon to thIs matter.
w. AWAit your reply.
Sinc:.r.ly
Address
147 ~~ 4fuG~, ~, bttf 1/:0/"-
/G3 '1/~y j~. 3;;;./i' ~~s
-------
. N-me Address
~~7. ~ /H -~. ~ c; PZ/r .
~~~.h.-L- )(7 ~ 11 "P~
.4~ h~-.:- /H ~ -.
~~ IJa~ /%~ t7~~ 7)-~/C
-------
'L ,
~a/¥'~
APACHE ENERGY & MINERALS COMPANY
13131 WEST CEDAR DRIVE. LAKEWOOD. COLORADO 80228. (303) 988-3033
AulU8t 22, 1985
IHVIIONMENTAL PROTECTION AGENCY
Office of Public Affairs
999 18th Street, Suite 1300
Denver, Colorado 80202
IE:
EPA "quest for Comments on
Radioactive Asphalt in Designated Streets
Gentl_n:
Apache !nerlY & Minerals Company is in the business of measuring radon
which 18 a.sumed to be the principle potential health hazard a.aociated
with radioactive a.phalt, a. it impacts on homes and work enviro:ments
adjacent to the effected areas.
f
B..ed on Apache's knowledge and expertise, ve support your preferred
course of action of "leave the stuff where it is" and feel that this
po.ition could further be supported by .elective ..asurements of the
radon in adjacent .tructures. Additionally this approach would provide
an additional .aftey factor in that if there i. an accumulation of radon
in the adjacent .tructure, the situation could be remedied and corrected
a. it applies to that particular building, rather than the gro.. approach
of tearing up the street and replacing it. It..y or may not be the control
factor to the control of the radon. Apache would propo.e to work with your
oraau1zation on e.tablishing a plan, in prec18e location. to accomplish
8Uch lIOuitoring and further. will provide all necessary .upport services to
1D8tall, r8mOve, and report the ..a.ur_nt..
Por plaan1n1 purpo.es, a co.t of $50 per aou1tor i. provided and the.
duration of the mou1toring period 18 thirty day.. The device ve propose
to uae in conjunction with thi. lIDDitorinl i. manufactured by terrades
Corporation and 18 readily available in the Denver relion. Apache 18
the ti.tr1butor for the lIOu1tor1D& clivici. Th1. dlvice IDd tlclmololY has
been uaed previously in conjunction with EPA sponsored project., and is
8Dre fully de.cribed in the enclosed brochure.
ID the evnt you would like to further explore the p088ibility of utilizing
Apache'. kDovledle and experti.e in this field, plea.e contact the undersirned
at 988-3033.
SlDcerely,
S COMPANY
-------
iif'r 1:iI
165 Marion Street
Denver, CO 80218
August 27, 1985
Mar; lyn Null
U.S. EPA, Office of External ~ffairs
999 18th Street, Suite 1300
Denver, CO 80202
Dear Mari,lyn:
I am writing to you regarding the proposed solutions to the radium
problems in Denver th~t are being considered by the EPA.
In response to the EPAls Proposal 13 (No action; controls and
monitoring of excavation activities), since the Denver radium
sites are on the Federal priority list, I feel "no action" to be
a total neglect of responsibility.
Regarding Proposal 12 (Shielding with a layer of asphalt or concrete),
I have to believe that the streets in question have been resurfaced
several times within the period from 1920 to the discovery of the
radium in 1979. If resurfacing is such an effective shield, how did
the EPA discover the hot spots in 179? Also, how does the EPA plan
on handling the other properties, 1 thru 11, on the Denver radium
property location key?
f
Proposal 11 (Excavation, removal, and offsite disposal of contaminated
material), seems to be the safest, most feasible solution to the
problem. Not only for the stree~ but also for the remaining ten sites.
It 1s my understanding that the State of Colorado still does not have
a contaminated materials dump site. I hope this is not the reasons
for ?roposals ~2 and 13. I would encourage the EPA, the Colorado
DepartJnent of Health and the State to work together to inwnediately
establish a dump site so that once and for 111 all of the contaminated
sites Cln be cleaned.
Sincerely,
.r ~ ," ."
~ ~.~~' //
/' . .,.. .. -... ...-
. . . . .-.
,,'
~. James F. Schaefer
---
-------
Department 01 Energy
PoSt OHic. Boa 2567 .
Grand Junction. Colorado 81502-2587
-Jt I~
August 29, 1985
cpuwJg 1,!peW8t:t
pun~ldns
"r. 80b Du p"ey, Dir8Cto,.
Air and Wast. Managem.nt Division
U. S. Envi ro188ntal Pro1:8C'tion Agency ,
1850 Lincoln St,.88t
Denv.r, CO 80295
~,;;;~~
R.f.r.nce:
(l) Technic.' Revi.. of the D,.aft F.asibf1ity Study for
the Denv.r Radiu8 Streets
08. r Mr. Du p"ey : '
TIt. Grand Junction Ar.. Offic. fs p,....d to d.' iv.r ou,. r"8vi.. of the above-
r-ef.,..nced r.pon: pu,.suant to Int.ragency Agr...nt NUllb.,. DW899309-6S-01-0.
If you h.v. any qu.stions on th... r.ports, pl..s. c." Mr. La,.ry 8111 ("$
322-9228) who fa coo,.dinating this wol"k.
f
v.ry tru, y yours,.
~c:' ~c/
Merl. E. Cr..
Manager
Encl0.u,...
As I'tated
CCI ./enclosu,.es:
~ a'ii""lMiik~-m--
eel ./0 enclosure.:
C. R. Nicho'. - ID
L. 8." - GJAO
. Me Madson - BFEC
8-29ltr/Ba111A
-------
. .
. JALLI-EC Bendix
~ Aerospace
, ..ndlz Fi.'d Engln..ring Corporatiol
P. O. BOil 1 569
'Grand JunClIOn. CO 81502- 1 568
Tetlonone(30312'2-8621
Telell: '54-338
. "'cult 29, 1985
Mr. Wn'1 la11
u.s. DepartaeDt of !DerlY
Graad Junction Projectl Office
r.o. Ioz 2567
GreAd Junction,CO 81502
Subject: Technical ...i.. of the Draft rea.ibility Study for the
o DelrYer I8diua Street.
Dear Mr. la11:
Ve are plea.ed to provide the Depareaeat of InerlY and the
lDYiroameatal Protection Alency with a Technical 1..1.. of the Draft
rea.ibility Study, Str.et., DeDYer I8d1ua Sit. 51-8M01.O dated July
26, 1985. leDdiz r..i.. cD88~at. a. .e11 al a ~d-liD.d" copy of
the Itudy ar. attached. Ve .111 be plea.ed to ~aad on tbe.e
comment. Ibould additional iDfor..rion be required.
,
fJ, ;- ~~
~~{!v.-
With ftl.~4.,
Mich.el I. MadIOD, Project KaD8I.~
UKtIA Pr0lr.. DiTi.ion
" i"
(:M~f ~-.
!,,-wi"'f \~~ /
"l- .l-
17""
011,1
...
~ f/I-' IP
-------
. .
,..
tlchnical "'1.. of thl .
DLU"f rusunm rrt1DY lOa tIE DDVU RADIUM STI!ETS
IJTlODt7CTIOR
A ~.1~..ry draft of the r.a.ibi1ity Study for D.v..r ladiu. Str..t. .a.
'G~itt.d to I.ndiz ri.1d lalin..rinl Corporation for t.chDical rwYi.. iD
..,t..b.r 1984. that r-.i.. ',Icifically addr"'ld hlaltb .~ .aflty,
"Ii..erinl' a~ radiololic "'I....nt coaClrD. aDd v.. 8Qb8ittld to IPA
tbroaah DOl os October 5. 1984.
. fte arrat rrri." ".. perfom.d OD tb. !)r.ft rl..ibiUty Study of 311ly 1985
which .....eld '1:011 che,rlUaiury ¥OI'U of 1984. A CI- of I'-.i..el" vithin
.ndiz "a. .....blld to ,ro~idl ,rofl..io88l ezpll'ilnCI lAd judl...at to chi
r..i... the te.. -.ablr., .~ thlil' r"'lcti~. al'.a. of IZ?lrci.I, iacludld:
D. .i1ia - "el'.l1 t.chaical rwYi..; D. Pric. - nlia..rinl aad r..d1&1
actios dllip; J.. 1Iarri - radiololic a......eac j A. t.chaeche - he.lth 8Ad
..f.CYi &Bd K. II&d.oa - "era11 t.clmical rwYie.. .
~
IOMKUY or UVIIV
'articular atc.atin va. paid to daf.a.ibi1ity of the !)r.ft rea.ibility
ltudy f1:Oll the ,.r.pecti~. that thl docuaaat "ill be ..dl ..ailabl. for public
r..i.. ad cOIDeatary b the ..ar fatur.. lI&a,. of tbl leadia r..i...r.
C088.at., qUI.tioa., a~ recOlD.adatio.. ..y .1.0 b. idlntified ., otb.1'
iadi~idual. or al.aci.. ~ol~ed b the public r-.i.. ,roce... leadiz I'..ie.
cOlDenc. addr... thl fol10wiDi to,ic.:
o The.o Actioa Alt'rDati~e
o ladiololic A.......nt aDd AI.ocut.d Data
o !DliDeeriDI Data
o "port OraaDi&atioD aad Pre.eDtatioa
fte We Actio. Alt'rD.ti~.
fte .0 Actin ~lt'rDati~e pr.ferred ., irA b def.D.ibl.; how..er, tb.
rni..er. Jane Untified 1aOt oaly lacoa.iltnci.. b applicatiOD of the
Itaadard. for l_di.1 Actin (40 en 192) bat .110 paucity of uta .hicb
....a'Craee c08pliaac. vith thl .ea"ard..
c:- radiaticna elata re,orted for the .treeu ar. Mt "l'tiDnt to 40 cr. 192
(part 192.12) "cauae I"" rad1&t1oa 1...1. a"ly 0.1,. to occu,ied or
..bitabl. .tractare. - IA tatlrior .ta.dal'd. lat.rior I"" ~d1&tin
.~teria i8pl.nt.d is the UMTIA PrOII''' ar. di.ca...d is the Viciaity
ho,erti.. lI&ul--t ad Iapl..atatioD II&lI1Ial. (lee ftImC pal" A-' ad
£-10.)
..di..-126 data for the .Cr.et. &1" a"licabll; aDd, the data pr...ated b the
Itudy cl.arly d880a.crac. eoac881Dacioa to be b .ze... of tb. Itaadard ia 40
CPJ. 192.
1 .
-------
.'
"
10 data ar. ,r..e~t.d for rad~ deca, ,roduct co~ceDtratioc. in .tructure.
a10~1 tbe .treet.. The Colorado Depart8~t of lealtb. particularly in tb.
coaduct of d.co~t88iD&tio~ of .icinity ,roplrtil. in tbl Gracd JUDcti~ aria.
cORtiaae. to '- COR.er9ati.e in it. approach to tbi. ,robl.. area. ladiua
cORce.tratio.. iD the .treeC' .., lead to iRcrea.ed vorkici l..el. iD
Itracturea ...eral teD' of f..t di.tact fro. tbl ide~tifild cODt..iDaDCI.
nile the U.ua,tioD' in the Itud,. wbicb .ute that radoc .ilrltio~ iDto
.arby .tTUCturl. 11 of 1" probabilit,. .., .. .aU4. there 81" - data to
..,port th. a..,.,tioa.. U CODt88iDa~C. .r. 18ft b ,lace. thn the
r89iever. fore. Ie a defiDit. ~.4 for bterior It ..a.ur..nt. to 8Ub.ta.tiatl
1- ri..k b the ...,iro1lll8Dc. x...ur"IDt. of u..l a..ra,1 VL .hould ..
takeD b a .tati.ticall, .icnificaDt 8a8b.r of .tracturl' accordiD, to currect
....ur.'Dt ,rococ01l. U.. two r.c8088'.'. addi.tin. to.'th. l.flracl'
lectin. )
DC a?O.ur.-rat:1 pid.liM. bne He~ d.oatrat.d to .. i. ac... of th.
~r.t-ca.e. ezpo.ur.-rat. .ceurio. pre"Dtad in th. r.port aad ar.
acc.,table rith 108' rl..rtatiO'A'. Calculacin. b .,,,,Ddis A ar. ..4. of ,
wor.C ca.. aDDUal 40'" to ...",cifi.. i84i.i4ual. who .,.cd .,.cifi" ..ouCtl
of tta. per ,.ar O'A tb. coctaaiute. .tre.t.. The calculate. aBDUal dO'I' arl
thID cGa,ar.. rith th. USIIC ltait for 8BDU&l do... b cODcrolled area. (10
. crI 10.105) acd fOUD. to .. ..low that l~it. ' Th. WlC iD 10 C7I 10.1 (c)
.tat.. .... ,.r.o~' ... .bou14 '". ..kl ...e1:'1 rea.oubl. effort to ..i~taiD
radi.ati~ ~o.ur.. ... a. low u 11 rea.oDa.l, achi..abll". It..,..
aDlikll, that thl IIC woul4 IraDt a licID.I to. or ,.rait o,eratioDi b,. a
licn..e that woul4 re.ult b ~.ure. to th. leDeral pu.lic of 8D1 bat a
...11 fraceio~ of ehl '00 .:.. ,er ,Iar. ~cordin,l,. CGafari.O'A of espo.ure.
at CIa. Streeta .ite with the DC liait .., IIOt be a"ro,riat.. fte nnnt
t.cbDolol1 of ri.k a....waeDt carr i.. calculatioDi of ri.k .810~d ezpo.ure.
oy.r t~e to hypotbetical d.ath. or tDci4..t. of .tocha.tic .ff.ct. ~ch a.
ca~clr. .ccor4in,l,. u a..ua,ti~ .bou14 .. ".1 of the DD8blr of
tDdi.idual. vho ..y .. ~o... to the calculatl. aDDual do.e. Thl aDDual
8a8b.r of ,.r,oD-r..' .hould be calcmlatl4. ThID th. ri.k factor. propo... b,
th. 1111 eo..ittl. iD 1980 ahould .. a"li.d to ..t~t. CIa. auab.r of
.tochaatic .fflcta for a r..~1t alainae which th. riak r..ulta of .ariou. ,
r..e4ial actio. alc.raaci... could be c08Par.4. A 8Or. r.ali.tic calculatio.
of 88DUl1 do... cou14 be ..d. that Uk.. i.to aCCOaDt ...ra,' do..' (8OC
'i,h..t do...>. lbi.14iD& by yabicl.a. aa4 doa.a to atr..t ..i.C888DC.
,er.ou.l. Additiou11,. what could be tM do..' to i..i.i4ua1l vho ... .a,
will dil s, th. .tr..c. IDtir.l, for ra,id aa.ait CODatruccio. or for 108.
other par,o" t
1. a44iti08 to o.a.~aDcI to IIC JUid.l~', th. 8O.t yiable js.tificatin to
th. 10 ~tioa Alclruti.. 11 cntai~d is 40 en 191 <191.11 (cn. 18 thb
i88taac.. .."l"'Dtal .ca.dard. could" a"li.4 if coat. 81" URrea.osably
bil' relati.. to ,th. 10D&-t.~ ..R.fit. aDd the re.idual radioacti.. ..c.rial.
.. _t po.e a clear pr,"Dt or hture baur4. toa...te~ ....fiu of Clae
r...4ial aceioa alt.raati.e. tiacu...d tD the It1IcI, are aot preci.e11
.tdr.a..4. . ,royi.ioa .bou14 be ..d. iD cia. fisa1 fiadiRI' that if .tr..c.
aTe recOD.trUctad or if u.e i. chaDl.d (..,. .tructur.. bDilt ...r the Itr..t
1884) tbat tJa. coac_i1t&Cioa aPt .. deaD.4 ., aDd th. .it. certified for
aar..trict" u.. b.for. fi..1 r.co..tructiOD ia c..,18te..
f
2
-------
ladiolotie A".'''.Dt aDd A..oeiated Data
Tb. taa"ro,riat..... of a"lyiDl aD iadoor .tandard to the .eraec. bat ba.n
..ntioDed ab~e. On ,ala. 5-3 aDd 5-4 of tha ..danlara.nt a..e...eDC cha
~..ult. of the irA borinl prolr.. ara de.crib.d. However. the.a ..a.ur".DC'
a~. at d.fiud. .av ".ra th.y takan. "bat iza.trua.ntl "er. ..ed. bow "ere
the i..traa..t. calibrated. and bow wera radiua conc.ntrationa deri~ed froa
1-- ~ucU.DI' T tabl. 1-4 aDd Ap,.Dd,iz A, rieure 5-% do not a,rae with ralarel
CO coat88ination d.,th..
I.ti.e.riat Daca
fte l'8,etiti~. (i.cullion. of "Dbpo.al Option." throulhout tha .tudy ara
...-ca..ary. ~ ,robl... a..ociatad "ith a,.iabla di.,o.al .ita a,ply to the
atir. De1rlu ladi- Sita. prolr-. 80t ju.t tha Da1rlar ladi- SCTaeU.
.~ailability, or lack of ..ailability, of a .i.po.al .ita .bould ba addra..ad
b tha lucuti.. I---ry aU Introduction only. If a dll,o.al .ite b
..ailabla, th8D the tran.port co.t.
-------
. .
. ..
: Ar. CDI 1981 aDd 1982 ~.,o~t. pabli.h.d?, '1'''''1'
: Sbould rirar. 1-1 b. wmab.~.d? .
: 1.1 bUdiD, .bould Dot CODCUD tIS. .ord .SIn"
Ki..iD, r.ter.DC. OD A1'iz Co~poratioD r.port?
VDit. of ..a.ur".Dt tD S.etioD 1.4 but tb.r. i. 80 1.4
: Ibould rirar. 1-2 b. aaab.r.d'
: 10 pa,. DuUer of ripr. 1-3, "0 Scal." .ut..Dt .hnle! be iD
the lea.Dd - Mt the titll.
: Table. 1-4 nd App.uiz '-2 di.a'1'.I. IIoDitor.cI DcnatioD' are
.hem! b riaur. 1-3 (saot 1-2). It pablic b..ltb 8DDitoriD,
coBfim. thl ab.lul of coataiuDt bllow the a.phalt .hat
about thl 12, 16, ad 18 iuh 4.ptb. ..tiOD.d iD the ust
,ara,ra,h?
pa,. 1-17 : Data do IaDt qr.. ritb A,,.adis A, riprl 5.2
,a'l 1-18 : "cOID.Dd" ar--r, 40 en 300.68 au 40 en 192 ar. Dot b tb.
r.f.rncI'.
: lec_.Dd" ar....r
: '.coma.Dd.d ar....r
: lecOID.Dd.d '1'''''1'
: '.c088.ael.d ar....r, r.c0888adatioUl abo.t 8Di.po.al OptiOD."
'Iction cODtai..eI tD tab1. 1-1.
. "'1 1-3 : 40 en. 300.68 (b) i.a DOt b ~lf8rnca., lack of uta to npport
.tat.aat. about~i.t froa ~adoD.
,a,. 1-4 : DlfiDitioa of "1aomal .,." M, Mt ... a"ro,~iat., DO colt uta
pr...atad for 08 .it. 4i.po.al.
pa.a 2-5 : lec088auad ar-.ar, iac:oui.t.ui.. witb coaorntiou1 ... 4....-
wt1l~' co.c~.t..."
pa,a 2-6 : lecO'l8lnel.d po....r tD "'ctilatioD" ..ctioa, pro,o.ael ~..iaion to
let' ,." out of ,laca.
pa,. 2-7 : Probl.. vitb "Dilpo.al" att.ruti.a. ael thl fact that nl..nt
~.platioD' .ou14 H,.ati.fi" accordiD, to tha ISlcuti.1
8~ry.
pal. 3-1 : Cha,tar or S.ction 31, rlc0888Delael 11'--1', wbat 18 .cODtractor
'~lflrncl"?
,.,. 3-1 : Ccnacratl coutu.iOD a'8iD, wbat hap,...d to .cnbiutioa. of th.
a~. actiou" .. tD table 2-1, au a. b 3-4 OD pal. 3-10t
pa.. 3-3 : Dbpo.al eli.cuui08 "108" b lzac1ltb. S~ry, fult two
1NUatt b 3.1.2 ara ft08'. W. co.taiuDt cauot " ~.,".d
..d ,roba~l, .088 .eriticatiOD 8ODitoriD, woulel ... "cI..ary.
Off .it. eli.po.al 8D.t ... a"U88e1.
,.,. 3-4 : kac tWO eli.annca,.. 11'. IaDt .aU.d, 3.1 tit1a .bould 1t.
"I&eliat1o. Sbialdba.. coac~.t8 probl.. a'8ia. 20 uL'1ar ..ar
1tact,~ou.4 i.a n bt.ru1 Ita.ela~d ilL 40 en 192, .. .. op.D
l8Dd .taDelard. "ct,~ ,111' 25 uL'br i. the VMTIA c~it.rioD
for O8tdoor ,-- (a.er8,.d ..er 100 "Iura ..cu.).
"'1 3-51 : rip~. 3-1 aboulel b. "Iaeliatin tatnli.c,". Mt ttzzpoaurl lata".
10 "apo.ura rat. uta a~1 .ban - tbl fipn. "
"'1 3-6 : 20 uL'b1' .abertl bact,ro-.'
"'I 3-7 : hob1.. .itb fi~.t ael thir4 eliu.s.aDta,I', ~ac...d" 11'--1'
,.,. 3-8 : laor81i4 cOD.i4.ratioa.
,.,. 3-9 : lec.,..nd" ar--r
,... 3-10 : hobl. vitb .coabiucioD altaruti..,"
,.,a 3-11': 'rob1.. iD table 3-3. a'8i., ca..all. co.taiutioD " ~."Idt
leall, elu.t probl..,
pal. 1-4
pa,. 1-?
'8'. 1-8
,a,1 I-t
"'1 I-t
"'I 1-16
"'I 1-19
,a,. 1-20
..,. 2-1
"'1 2-2
4 .
!
-------
,... 3-121: frobl.. iD r.bl. 3-4, citl. .laoold r.ad NStr..t.~, rec0.8.ud.d
.r....r iD "r.a,oD for r.j.cciou" portiOD of tabl..
.... 3-13 : lec088.uded Ir--r
.... ...1 : La.c ball.t coDflict. witla .taC...ut. iD S.ctiOD 4.4 (pa.. 4-14),
ar--r
......3 1 Ia 8101" dUfunc CIwa "1'"
f81. 4-4 : .arur'r.func. caut .. f..d, r.coniDI ch. coDtaiuuc to aD
eze..atiou i. ~bl...tic.
......5 ,"'11 "1_1 I..ual tJaoua. tOD' of cODcaiuc.d a.phalt ..,
.. pr.'.DC i Ja... ,OU att.pcri to cOlipac. cia. actual _ouDta?
,.....9 : l.ecioD 4.3 'CaC.. "47 diu" wb.D r.bl. 1-3 .bow. 57 diu cna
York ad 9cla £0..... .
"'1. 4-12 : Qa..CiOD about nhiDI _laol. - 11 th. pric. $60.00 or $600.001
pa.. 4-14 : V01- cODciD.ncy iI 1.,., alUl .boald .. OD ch. ordu of 25%.
'Itac...uc. aboac re.piracory ..ai,..Dc coDflict wicla tJa. laic
1N11.C cna ,... 4-1. .
pa.. 5-4 : fty 18 40 en 192 ba _ithu hltl. 5-3 1IOr £o".Ddb .,
lef.rnc..: I'iz.c pal., ,.cODd fl'08 boCt- (U£o, lelioD nIl) 11 uc
t.cbDicall, a ref8l'8BC. if it i. aDdac.d ad ..,.bli.la.d.
1JmU 'rolr- nMDI .uald .. i=luc1.d b tu r.f.r.=...
two acWitioul refuac.. recOl88Dd.d ar.:
J. C. 'acer au G. B. Lazap.r, Jr., ia pr.paratioD,
Protoeol for the l.t4._tioD of A..rate tDdoor "don Dautbt.r
Coneeatratioa.. GJltKC-09, I...b 1'1.1d IDli...riDI CorporaciOD
m V.S. hparmnt of I88rl1, hc:laar ..r., hoar.',
Di.1Iio. of I_dial kcio.. hoj.ct. .
.
G. B. taB..r, Jr., i. pr.paratioD, Proe.duTe MaDUal fOT I.t;m-ti~-
of A..rate Indoor "don Dautht.r CODeentration V.int the Radon
Proten~ Intetratint S88Dlint Unit (IPISU) Method, GJ/tKC-l1,
India 1'1.1d IDliu..riRl Corporaciou ~ V.S. D.parta.ut of
Jur." hel..r lD.r., ho.r.e, Di...1IioD of a..di.l ktin.
hoj.ct.
Uppn4b £0)
pa.. 5-41
.... 6-3
,... 7-1
: G- n.u'.tia. apo.ar. .tadard froa 40 en 192 11 p iDC.rior
na1ldard.
I '..1 ...ber for riaarl 2-1!
: 'a.. .-b.7: for 1'11'17:. 2-2!
I S-fooe .eae"'De do.. Me all''' ricb li.. 1 n .... 7-2 of
£oppndb A.
I "co.aeDd.d 11'''''1'
I "U-IU. .eac..nel u. .n.I.
: "dOD c01lc.1Ic7:acio1la a7:. ut .,r..." aa VL, 0.1, DC.
.: "0 Ical." etaC..DC ,'oa1d .. i.a lea.Dd, ,a.e aaab.rf
: frobl- ricb "Hffici.DC1, ...11" .taC...Dti aDd, en en.id.r.
dietarb.d acilici.. eo .. fa.07:abl. co1lduic. for radOD
. ai.racio1l.
: Data do DOC aar.. rich rabl. 1-4. 'a.. _b.r1
: rabl. 6-1 .bould a.. 87:88 co be c01l.i.c.ac wicb teat.
s typo. OD "..c..acioa." lad ".ff.cc"
.... 1-1
"'1 2-3!
,... 2-4!
.... Z-6
"I. 3-1
.... 3-3
.... 3-5
.... 5-21
.... 5-3
5.
-------
- f, . i
,... 7-2 : S...r li~., 2 ft d..,1 ,... 2-6 ,.,, 3 ft.
a.ferne.,: Indb, 1984 do.. IIOt .".ar b test.
nuns :DDVD UJ)Im(
t
6 .
-------
~
s-wr,.....,
lAM ~ GIIICI
fNdric P.'" ....d
.... DR8r
...... H. Sihw
Mir:I8I L ... -...A
Julie E. ~...
SeIphIa c. VoIUr
DdIanh S. .....
SIll .....,.
v... ...
~.....,
Elrl M. .....
Ofc-I
am Yift a-
"". ---
J- Co M., JWe;w8
1»rar rJ n. '. '
&044 FiIiIIIIn St.
SID F. . CA MUS
(41 S) S67-'IOO
8OCZ't IlllUffAllf CWICI
H. Aad8r b:bI
18m P. ShIII8I
Lan PactIr
SuI A-.,.
DauP L. HaaaDId
168 .....
s,m. .....
8ao 16ch St.
SuitI S 14
D8nw. CO Ioaaa
(50J) ItMJOI
.~. DoC. C1f11'1C8
I'ndIrick S. t~. H. - .. m
......... L ...
c...aad J. ZIIIU. Jr.
1ItI ~
..... J. W...
Ofc-l
Ene P. .......
l.p ......
1414 E S&.. NW
- SuitI 6ao
W"""" r D.C.-S
Caaa) ..1778
- ..... GIIICI
Lui J. MImI
, "'I"'"
s.- La Pi8n
Philip S. .....
168 .c-
419 6cb ~
SuiDt J~1
J--. AK 99leu
{9G7~ P6-:rU
16
SIERRA CLUB
LEGAL DEFENSE FUND, INC.
L.--=
AI8I AdImI
Symes Building 8~o 16th St.. Suite 514 Dcn.,er. Colando Sol01 (303) 89l-63
Septe8ber 10, 1985
Marilyn Itlll
U.S. &1viro18ental Protection Alency
Office of External Affairs
gg9 11th Street, Suite 1300'
Denver, Colorado 80202
,
Ie: ec-ents on Denver radi\ll sites
near Ms. ftIlI:
PUrsuant to ., conversation with John Brink on qust 20, 1985, I
sublli t these cC8lents for your consideration after the off icial
CC8lent deadline but prior to public aDDOUDCe8ent of a decision on
this utter. '
f
C\oice of the no-action alternative is inconsistent with the
selection of these sites as "cont8llinated si testbat EPA considers
80st 18portant for thorough investilation aDd possible cleanup."
Super ~ PrOR~ Fact Sheet, Denver Radi\ll Site, .1Ily 19, 1985. !,
placina these sites on RitIOnal PrioritY List, EPA US\IIes a respon-
sibilitY to elilli.nate or aitilate the hazardous substance which
caused the 11 st iDg .
Even 1f EPA can I'roe that a no-act10n altemative -y be
proposed consi stently wi tL' ~ provi sions and purposes of CERc.A, EPA
should adopt the alternative which calls for radiation shieldlna by
dense 81x coa:rete or asphalt. 'DIe costs of this 8itilation action
is extre_ly low 1n cGllp&rison with otber Super PuDd c1eump ICtions.
Ilepavina of s~reets 1s reaularly UDderuken as a utter of DOral
_int8D&DCe aDd repair. for exaaple. the portion of 12th Avenue ODe
bloc:k fl'G8' ~ 18edlately' parallel to the deslpated lite OD 11th
AveJl.1e ws ftJ)aved duriDi the -.-r of 1985. 'lberefore, EPA sbould
cboose the shieldiDi alternative.
In .., tbe Denver rad1ua streets were placed an the National
Priori ty IJ. st because they were "cont_nated 81 tes . .. vi th the
hilbest prioritY for cleaJIJP ICtions." Draft Peasibil1 Study,
.J11y Z6, 1985, at pile 1-3. '!berefore, A. s se e
radiation shieldina alternative proposed in the Draft Study.
L(! t~L
, ~.,~~ IJJ,1fS:::::'
Lori Potter
Rocky MOuntain Office
I;/rs
-------
Collection
Jrce Center
Unil8d States
Environmental Prol8c:tion
Agency
0Ifiee 01
Emergency and
Remedial R_pon..
E PAlRODfR08-861OO4
March '986
19107
-_u_--- ~
AEPA
Superfund.
Record of Decision:
~~- 22'-121(,
Denver Radium Site Streets, CO
-------
ADI.ENWM .
RES roNS I VENESS S tMMAA y
IENVER RADI LM S'IREEI'S
01 W9d., JCI'1. 22, Jom 8[':ink, Phil ~ero, ard Mar il yn Null met with
a qroup of citizens livinq on end near the 10? block of Lafa~tte Street.
~ meetirQ was requestej by Sally Russo, resident of 121 Iafa~tte, am
was held ill t'er tone.
The aroup subnitted a ~tition to ER\ during the; p.Jblic cC1!"'~t
iod (Aug. 1-22, 1985) concernirQ the methcd by wtllch EPA ootlflej
~idents alOl'Q streets contaminated with radiun. In early Septem~,
the I:el"llTer Radiun tean met with Richard Russo (Sally's hu~and). to .dlSCUSS
the I:enver Fad iun site and options for deal:ing with contammatlOn 10 the
streets. IrT early January, Sally callej .req\..E!stin;;J a meetinJ.
Citize~s at this meetino were interested in the health effects of
radiation contanination in the streets, particularly Lafayette Street.
'!hey wanted t:D know 'Itlat effect the gaTma raHation fran the streets
might have on the ir children. '!hey were in terestej :in krowi)"Q what EPA' s
recanmerrlej final de::ision w:>uld be and tDw the institutional oontrols
J;ro~sej in that decision w:>uld w:>rk.
Jom &- ink and Fhil Nyberq explained the effects of this kind of
radiation on hunan health, am went into detail about the effects on
children. .:bhn explained the reccmnerrlej final de::ision of a mcdified ro
a:::tion alternative, r:ointirQ out that currently there is ro a::ceptable
disJDsal'site for D:mvES:' Padiun materials, even if they were dlQ up.
The majority of the qroup ttDlQht the concept of the Pt:rlified N:>
Action alternative was acceptable, but were concerned about the ability
of the City arrl Cbunty of I:el"llTer to actually establish and maintain su:h
controls. '!hey identified nunerolS occasions of digging in the streets
which they were sure had rot been permitted, thus nullifyi)"Q CI'1y controls
that are or may be estab1 ished. '!he aeneral co~ens\S of the' qroup,
after sane discussion, was that the cithens haVe to be watchful of
d iQq inq in the streets and oontact the J;ro~r City & Cbunty of I:enver
departments to ensure ~hat the controls are enforced.
']he group fUrther! aqreed to w>rk with ~ in keeping residents info~Ed
by inclldirg an article in a newsletter p\blished monthly by the Cherry
~eek JmJrCNenent Ass~ iation (CCIA). .
In addition, a copy of the Streets FS and a copy of the tenvet' RacHun
Qmnt.nity !elations Plan were left with the Rus9)s for interested citimens
to rev :iew. ..bm told the qroup that EFA will be accepting ocrmtents fran
citi2Jens t.ntil the ROD is signed. He told then that the final deicisiOn
would be signed soon, so CI'1y comnents stould be sent to EFA as soon as
JDssible.
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