United States
Environmental Protection
Agency
Office 01
Emergency and
Remedial Response
EPAIROD/R08-87/012
June 1987
~
3 EPA,'
Superfund
Record 01 Decision:
?B 8~- IUlib I
DENVER RADIUM/ .
CARD PROPERTY, CO
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TECHNICAL REPORT DATA .,
tPftfIU fHd 'lfllItlCtlOllI 011 th. ffV,,,, /Hlon co",,,I,,i,,,) I
1. ""O"T NO. r2. 3. "ICI'tINT'S ACCI$SION NO. 1
EPA/ROD/R08-87/0l2
.. TITLI ANO SY8TITLI 5. "I'O..T DATI
SUPERFUND RECORD OF DECISION ,Tlln~ 30. 1987
Denver Radium/Card Property, Co. 8. 'E"IIO"~'''NO O"OANIZATION COOl
Third Remedial Action
1. AUTHO"ISI .. 'I""O"MING O"OANIZATION Ae'OAT NO.
.. '.""O..M.NO O"OANI%ATION NAME AND AOO".SS 10. '''OO''AM ELEMINT NO.
". CONT..ACT/OllrANT No.
12. S'ONIO..INO AOENCv NAM. ANO AOO"ESI 13. TV'E 011 "I'O..T AND '1"'00 COI/EAEO
U.S. Environmental Protection Agency !;Ii".:>' ROD ~...nnrt
401 M Street, S.W. 1.. S'ONSO"'NO AGINCV COOl
Washington, D.C. 20460' 800/00
15. SU"LEMINTA..V NOTIS
1.. A8ST"ACT
The Denver Radium/Card Corporation property is a l7.2-acre site located in Denver,
Colorado. In 1979, the EPA discovered a reference to the National Radium Institute in a
1916 U.S. Bureau of Mines report. SUbsequent field research revealed the presence of
thirty-one radioactive sites in t~e Denver Metropolitan area; one of these being- Card
property, the location of the original Pittsburgh Radium Company processing facility.
The site consists of five bUildings and an oil and waste water pond at the eastern
boundary. There is no serious pUblic health risk at present from radium or its decay
products, most notable radion gas. However, there is the potential for increased public
health risk if the radium contaminated materials are misused or inadvertently spread.
Currently, radium has been detected in the soil, sediment and underneath the True Truss
bUilding.
EPA's preferred remedial action for the Card property is permanent offsite disposal.
However, this alternative can not be implemented until a suitable offsite facility is
designated. In the interim, the selected remedy is temporary onsite building storage.
This includes: excavation of approximately 4,000 cubic yards of radium-contaminated
soil and sediment; storage of the contaminated material within reinforced synthetic bags
placed within the True Truss building and within possible additions to the building;
optional staging or storage of contaminated material from selected other Denver Radium
(See Attached Sheet)
11. IeIV WO"OS ANO OOCUMINT ANAI.VS'S
.. O'SC"'''TO''S b.IOINTI"'I..SlO'IN ENOIO Te"MS c. COSATI FieldiGtoup
Record of Decision
Denver Radium/Card Property, Co.
Contaminated Media: sediment, soil, debris,
(building)
Key contaminants: radium
None 34
11. O'ST"'IUTION STATIMINT 11. SICU...TV CI.AS8 / TI,i$ R,po", 21. NO. OF PAOIS
.
None
20. SICU...TV CI.ASS IT1,i, PtI,., 22. ''''CI
I~A ,- 2220-1 (I... .-77)
"".YIOUI I:OITION.I O.IO"'.T.'
-------
EPA/ROD/R08-87/0l2.
Denver Radium/Card Property, Co.
Third Remedial Action
16.
ABSTRACT (continued)
site properties on the Card property; final offsite disposal of all
contaminated material to a facility suitable for the permanent waste disposal;
and decontamination and dismantling of True Truss building and any additions
with disposal of the material in a sanitary landfill. The present worth cost
for the selected remedy is '1,148,000 with present worth O&M costs of '89,500.
-------
Declarati on
for the
Record of Decision
Si te Name
. Card Corpora ti on Property
Operable Unit X
Denver Radium Site
Si te Location
1314 West Evans Avenue
Denver, Colorado
Statement of Purpose
This decision document presents the selected remedial action for this
operable unit of the Denver Radium Site developed in accordance w;th the
Comprehensive Environmental Response, Compensation, and Liabili~ Act of 1980
(CERCLA) as amended by the Superfund Amendments and Reauthorization Act of. .
1986 (SARA) and the National Contingency Plan (40 CFR Part 300).
The State of Colorado has concurred on the selected reme~.
Statement of Basis
This decision is based upon the administrative record for the Denver
Radium Site. The attached index identifies the items which comprise the
administrative record upon which the selection of the remedial action was
based.
Description of Selected Reme~
This operable unit of the Denver Radium Site addresses the contamination
present on the Card Corporation proper't;y ("Card property"). The hazardous
. substances of prima~ concern that have been released and continue to pose a
significant threat of being released into the environment are radium and its
associated decay products.
EPA's preferred remedial action alternative for the Card property is
Permanent Offsite Disposal. However, until a facility suitable for permanent
disposal of the Card property material is designated and, if necessary,
acquired and developed, this alternative cannot be implemented. Pursuant to
CERCLA Section 104(c)(3)(C)(ii), it is the responsibility of the State of
Colorado to assure the availability of the disposal facilities for offsite
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3
The EPA is undertaking additional feasibility studies to evaluate
remedial action alternatives at the other Denver Radium Site Operable Units
and will complete a Record of Decision or an Action Memorandum for each of the
Operable Units for which a remedy has not already been selected.
Decl ara ti ons
'Consistent with the Comprehensive Environmental Response, Compensation,
and L1abfli'tY Act of 1980 (CERCLA), the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and the National Contingency Plan (40 CFR
Part 300), I have determined that the selected reme
-------
~
Summary of Remedial Alternative Selection
Si te Name
Card Corporation
Operable Unit X
Oenver Radium Site
Si te Hi story
What is known today as the Denver Radium Site has its roots in the robust
U. S. radium producing industry of the early 1900' s. At that time', radium was
consioered to be a woncer drug, a cure-all for every ailment from the common
cold to cancer. A mere gram of the radioactive element sold for $325,000.
Prior to 1914, there was no U.S. production of radium. Rather,
radium-bearing ore was shipped from the U.S. to Europe where it was refined.
Fearing that a European war might stymie U.S. importation of radium. the U!S. .
Bureau of Mines entered into a ~ooperative agreement with a private
corporation, the National Radium Institute, to develop and operate a radium
processing plant in the United States.
Denver was the chosen location for the Institute due to its proximity to
carnoti te, a radium-bearing ore of the Colorado Pl ateau. Soon there were at
least eight other radium processing operations in Denver. One of those radium
producers was Pittsburgh Radium Company. Using equipment purchased from the
Institute, Pittsburgh Radium Company began operations in 1920 in What had been
the Overland Cotton Mill building.
.
The Denver radium industry remained strong until around 1920 when
extremely rich deposits of the radium-bearing ore, pitchblende, began to be
developed in the Belgian Congo. Most Denver radium producers were not able to
compete with their African counterparts and were forced out of business. The
Pittsburgh Radium Company was one producer which was able to continue
operations because, unlike the other radium producers who processed carnotite
for"radium, Pittsburgh Radium Company processed roscoe1ite for vanadium.
However, Pittsburgh Radium Company, too, was eventually forced to close.
Records show that the company sold the Overland Cotton Mill building in 1924.
Since 1924, the property has had various industrial uses including World
War II and Korean War muni tions manufacturing, hardware manufacturing, and
fabrication of heavy mining equipment. The property became known as the Card
property because Card Corporation owned the property in 1979, when the
radiological contamination was discovered there. The property will be
referred to throughout the remainder of this summary as the Card property.
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.,
2
Response Hi story
In 1979. the EPA discovered a reference to the National Radium Institute
in a 1916 U.S. Bureau of Mines report. Subsequent field research revealea the
presence of thirty-o~~ radioactive sites in the Denver metropolitan area. one
of these being the Card property. the location of the original Pittsburgh
Radium Company processing facilitv (Figure 1). Immediately following these
discoveries. the Radiation Control Division of the Colorado Department of
Health officially notified the affected property owners of the presence of
contamination on their properties. The letters requested that no excavation
or soil movement be undertaken without first contacting the Division.
The Denver Radium Site was placed on the Interim Priorities List in
October. 1981. and final promulgation of the National Priorities List oCcurred
on September 8. 1983. )he Colorado Department of Health, under a cooperative
agreement with the EPA. assumed lead activities and initiated engineerin\:l
assessments of the various properties in August, 1981. However, Mentor
Corporation. owner of the Card property, denied the State access to the site.
The EPA resumed funa-lead activities in June, 1983, because the Colorado
State Legislature failed to appropriate the state cost share for remec.iial
planning required by EPA policy at the time. In December, 1983, the EPA
directed its contractor, CH2M Hill, to conduct a Renedial Investigation (RI)
of the Denver Radium Site to determine the nature and extent of the threat
presented by the contamination and a Feasibility Study (FS) to evaluate
proposed remedies. During the RI. Mentor Corporation allowed EPA access to
the Card property so that the extent of the contamination present on the .
propertv could be determined. ,'„
Due to the enormity and complexity of the Denver Radium Site, the EPA
determined that response actions could be undertaken as operable units in a
cost-effective manner, consistent with a permanent remedy for the entire
Denver Radium Site, and would decrease the release, threat of release, and
pathways of exposure. Thus,the original Denver Radium Site properties plus
several contiguous properties where contamination was discovered subsequent to
the intial listing of the site on the Interim Priorities List were dividec:
into eleven operable units. the Card property being Operable Unit X.
.
In April. 1986. the Denver Radi um Si te Remedi a 1 Inves ti 9a ti on Report.
Which addresses all eleven operable units. was released to the public. A
draft Card Corporation Operable Unit X Feasibility Study was released for
pUblic review on October 1,1986. A second draft Card Corporation Operable
Unit X Feasibilitv Study was released for public comment on April 24, 1987.
'1M second draft report reflected pUblic conments received on the first draft
report and incorporated new requirements mandated by the passage of the
Superfund Amendments and Reauthorization Act (SARA) in October. 1986. The
final Card Corporation Operable Unit X Feasibility Stuay which incorporates
responses to comments received during the both public conment periodS will be
released along with the Record of Decision (ROD) for the Card property.
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3
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-------
4
Site Location and Description
The Card properfy is a 17.2-acre site located at 1314 West Evans Avenu~.
The site is in an area of Denver zoned 1-2 for industrial use. Its ownership
is currently divided between Mentor Corporation, which owns 13.7 acres, and
Consolidated Freightways, which owns the rest. Mentor rents its portion of
the site to various light manufacturing and warehousing companies.
Consolidated Freightways operates a trucking terminal on the SOUthern end of
the property. There are currently five buildings on the Card property - the
Brick Commercial bUilding, the Office building, the UPL building, the True
Truss building, and the Consolidated Freightw~s facility. There is a small
oil and waste water pond on the eastern side of the property. The property is
crossed by several currently unused rail spurs.
The site is bounded on the north and east by commercial offices and some
light manufacturing and storage buildings. To the west is the Colorado and
Southern Railroad property, and to the south is West Wesley Avenue and the
Arapahoe generating station of the Public Service Company of Colorado. The
nearest residences are two blocks east of the site.
The Card property is located within the Platte River Valley but is not
within the designated 100-year flood plain. The site is underlain by fill
material, alluvium, and the Denver formation sandstone. Deptn to bedrock is
approximately 10 feet and depth~to ground water is approximately 20 feet.. The'
topography of the site is pred~minantly flat although surface runoff tends
eastward toward a storm sewer near the intersection of West Iliff Avenue and
South Navajo Street. There is no surface water on the site other than the
small oil and waste water pond mentioned earlier.
'!!'
.
Current Si te Status
Radium is the primary contaminant of concern at the Card property. Since
gamma radiation readings in excess of background may indicate the presence of
radium, a gamma radiation survey was used to outline tile extent of possible
radium contamination on the Card property (Figure 2). Gamma radiation
reading~ in excess of background were found over 67,000 square feet of the
site including in the Brick Commercial and UPL buildings. lhe presence of
radium in the soil and underneath the buildings was verified by radiochemical
~nalysis of subsurface soil samples. Average radium concentrations range~
frQm 4.4 to 472 picocuries per gram. The maximum radium concentration, 960
picocuries per gram, was found in area H2. The radium contamination extended
to a maximum depth of 108 inches in Areas F2 and G. The estimated total
volume of radium contaminated soil is 3,900 cubic yards of which 475 cubic
yards lie underneath buildings. There is an additional estimated 200 cubic
yards of radioactively contaminated sediment around and on the bottom of the
oil and waste water pond. Table 1 summarizes the data presented above. (A
general discussion of radiation and its associated units of measurement is
presented in Appendix A of the FS and in the Public Health Assessment,
Appendix 8 of the FS.)
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FIGURE 2 CONTAMINATION
EXTENT OF
E UNIT X
OPERABl AOIUM SITE
DENVER R
'..J ..
--- ~
c-~
II
o
.
lOa
<'00 fT
.d
SOIJTH NAVAJO STREET
II
X
II
II
TIIUE TRUSS
8U1LDING
,..0
)""'1
V
,-'
)(
Jt
CONSOLIDATED
FREIGHTWAYS
8UllDING
I
'-
.
L
l BUILDING
COMMERCIA
BRICK OHICE AREA SPACE
"~SEMENT ANO CRAWl
"
II
i
)(
,J
)(
I
-------
Location
Area A
~rea B
Area C
Area D
Area E
Area 1'1
Area F2
Area C
Area H
Area I
Area J
Area K
Area L
Area Hl
Area M:!
Area r>
Area 0
Area P
Area Q
Area R
Area S
Area I
Area U
Area V
Area I.'
Area X
Area Y
Area Z b
Area ~
Area BB
Area CC
Area DD
Area EE
Area FF
Area CG
Area HH
Area !I
Area JJ
Area KK
Area LL
Area 11M
IOTAL
VOl~e
(vd )
--
30
1
4
41
10
300
183
200
5
11
67
3
2
2,500
33
5
18
6
8
1
1
3
7
9
1
6
2
2
(32 )
( :1)
145
62
53
."
..~
15
99
.:.
(1oia11)
24
4
NA
3
SURFACE
1,100
25
100
1,100
550
8,100
5S0
600
125
580
1,815
79
79
33,720
230
60
300
110
95
1,733
65
7,800
480
1,430
570
800
2,660
240
430
110
10
70
67,036
Are,
(ft )
180
130
110
150
420
40
30
180
80
6
Table 1
OPERABLE UT\IT X
DENVEP RADIUM SITE
AND SUBSURFACE CONTJ._"UNATION
Camma (uR /h r)
Average Maxlmum
4
15
8
6
5
7
54
12
6
7
7
1
5
13
12
5
8
6
7
4
8
7
1
.
12
i
5
7
3
2
2
4
38
5(11)
8
9
9
10
8
NA
10
7
24
13
10
14
5
3
5
6
69
1l( 12)
23
16
54
17
16
NA
1/.
Deptha
(in. )
5
15
8
9
6
21
89
26
11
17
34
1
5
95
6 at 12-18
12
12
12
6
12
108
108
12
6
12
12
6
Range from
0-30
Avg: 18
60
12
at 12-66
12
6
6
6
6
12 and
18 at 5':'-72
12
6
6
6
6
6
12
6
Radium Concentration
(PCi/g)
AVera~e Maximum
10.4
NA
NA
15.6
5.8
8
96.9
99
NA
6.4
119.2
18
7.8
99.8
236.9
8.4
47.5
202
NA
NA
NA
10
26.2
24.9
53.7
19
7.9
5.6
4.4
7.1
14.9
NA
56.2
12.1
5.5
60.5
120
18
7.4
, ...,
..,..
(,
12
31
NA
~A
30
5.8
34
287.4
99
NA
6.4
224
18
7.8
660
960
8.4
182.5
685
NA
NA
NA
10
41
37
89
19
12
5.6
6.;
11
34
NA
270
28
6.~
282.:'
2BS
.
3,889
12
5
8 54
34
8
4
8
7
1
42
12
12
6 at 12-11:
1:
6
18
12
i
NA
12
. <:
.I.~
16
90C
6
12
~pth indicates the estimated depth of contamination. A range from x to y indicates a
variation in the depth of contamination. x at y to z indicates a lens of contamination
of thickness x under y inches of clean overburden.
bIhese contaminated locations are no longer identifiable after construction of the
Consolidated Freightways facility.
cAreas AA and BB are not included in this total.
NOTE:
Maximum
Depth:
108
Maximum gamma exposure rate is maximum surface grid scan gamma exposure rate.
Gamma radiation readings are net readings above background, which in Denver
is 15 lJR/hr.
Data not available or not recorded for this area.
NA:
DE/TEN/053
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7
The radium concentrations found on the Card property and the gamma
radiation levels in places within the Brick Commercial and UPL buildings
exceed the IIEPA Standards for Remedial Actions at Inactive Uranium Processing
Sites, II 40 CFR Part 192, which the EPA has determined are relevant and
appropriate Federal pUblic health requirements for the Card property. These
standards are discussed in detail later in this summary in the section
en ti tl ed IIDegree of Cl eanu pll .
Radon decay product contamination resulting from the radium contamination
on the site is not a concern on the Card proper~ under present use of the
property and existing site conditions. Slightly elevated radon decay product
concentrations were detected in the Brick Commercial, UPL, and Office
buildings; however, all measurements with one exception were well below the
relevant and appropriate 40 CFR Part 192 standard of 0.02 working levels. The
one measurement which exceeded the EPA standard was taken in a relatively
small, unventilated location of the UPL building (a storage closet) and is not
considered representative of the entire building.
Alpha particle radioactivity also resultin~ from the radium contamination
on the site was not found in any significant degree in the Brick Commercial, .
Office, and UPL buildings. Of the 108 samples taken, only 14 had measurable
levels of removeable alpha activiJy and all of the levels were well below th~
release limits specified by the Colorado Department of Healtn standards.
Minor amounts of non-radiological contamination. mainly pOlyaromatic
hydrocarbons, were detected in the soils and in the pond sediments at the Card
property. There is nothing to suggest that either dispersion or migration of
these substances nas occurred. No known sources of these compounds are
present on the property at this time. and thus. there is no reason to suspect
any additional releases. lhe Public Health Assessment of the Card property.
indicated that the non-radiological contamination represents a minimal concern
relative to the radiological contamination present at the site. In addition.
any remedy that reduces or eliminates the radiological hazard at the Card
property will eliminate the known non-radiological hazards as well.
The elevated concentration of radium at the Card property poses a health
hazard due to three principal potential exposure pathways. In order of
decreasing significance. they are: (1) inhalation of radon gas. the immediate
decay product of radium, and radon's own short-lived decay products. (2)
direct gamma radiation exposure from the decay of radium and its progeny. and
(3) ingestion or inhalation of radium-contaminated materials. Since radium is
in a form that is relatively insoluble. and since migration of contaminants
into the ground water or from the pond sediments into the pond water has not
been noted, ingestion or contact with contaminated surface water or ground
water is not one of the principal potential exposure pathways. Each of the
three principal exposure routes will be discussed briefly in order to describe
the potential heal th risks.
/
.
-------
8
Inhal a ti on of Radon Decay Produc ts:
Radon gas and its decay products present the greatest health risk from
long-term exposure. Radon gas decays to a series of short-lived particulates
which are t;ypically &1ectrostatically charged at their formation and often
attach themselves to airborne particles. If these contaminated particles are
inhaled, then the lungs and other internal organs are exposed to th~ highly
ionizing sub-atomic particles Which the radon decay products emit. Prolonged
inhalation of air Which has a high concentration of radon decay products has
been conclusively shown to cause lung cancer in uranium miners.
Dispersion qUickly dilutes radon emanating from raQium-contaminate~
ground. lnis mechanism will minimize the radon concentration in the air above
the open areas of the Card property to such an extent that no one working on
or living near the site.is presently at risk from exposure to radon and its
associated decay products. Radon decay products can concentrate to
unacceptable levels in buildings built over contaminated ground if those
bUildings are energy efficient and well-sealed, that is, have littl£ exchange
of indoor air with outdoor air. However, this is not presently the case for
the buildings on the contaminated portions of the Card property because the
buildings have enough ventilation to keep the radon decay product
concentration at low levels.
The analysis summarized above shows that th~re is no serious pUblic
health risk at present from the radon gas exposure pathway at the Card
property. However, the EPA has detennined that a significant increase in. -
pUblic hea.lth risk would OCcur iJ- any of the contaminated material at the site
is spread closer to potential receptors, especially if it is used as fill or
construction material, or if any of the buildings on the site are sealed to
make them more airtight, or if the site is ever redeveloped for any use that
i nvol ves occupancy in enclosed, well -sealed structures. lne Publ i cheal th
Assessment summarized below presents projected cancer risks if the EPA were to
take no action at the site an~ the Card property were redeveloped in any of
thes e ways.
.
If a building were constructed over Area Ml, the largest contaminated
area on the Card property, and several conservative assumptions are made such
as lifetime exposure, the estimated radon decay product concentration in the
building would average 0.18 working level (~1) with an estimated maximum
concentration of 1.2 WL. The radon decay product concentration in a typical
U.S. home is 0.005 WL and the relevant and appropriate EPA standard, 40 CFR
Part 192, is 0.02 WL. The projected cancer risk (excluding backgrounG) to
iAdividuals working in the building ranges from 190 to 790 cancer deaths per
10,000 persons exposed with a maximum projected cancer risk of 1,200 to 3,700
cancer deaths per 10,000 persons exposed. lne projected cancer risk to
inaividuals living in the building ranges from 1,100 to 5,600 cancer deaths
per 10,000 persons exposed with a maximum projected cancer risk of 4,400 to
7,900 cancer deaths per 10,000 persons exposed.
These risk values can be compared to the projected cancer risk if the
radon decay product concentration in the building was 0.02 WL, the EPA
standard. In this case, the projected cancer risk to individuals wor-king in
-------
9
the building ranges from 23 to 91 cancer deaths per 10,000 persons exposed.
The projected cancer ~isk to individuals living in the building ranges from
130 to 500 cancer deaths per 10,000 persons exposed. If the radon decay
product concentration in the building was that of a typical U.S. home, 0.005
Wl. then the projected cancer risk to individuals living in the building would
range" from 33 to 130 cancer deaths per 10.000 persons exposed. Areas M1 and"
M2 combined represent about 65% of the estimated total volume of contamination
present at the site. It should be noted that these projected cancer risk
numbers do not include the EPA-estimated spontaneous risk of lung cancer. that
is. the risk not attributable to either smoking or radon. Table 2 presents
the above stated information.
Gamma Radiation Exposure:
The radioactive decay of radium and its decay products results in the
emission of highly penetrating gamma rays. Gamma r~s are of concern because
they can easily penetrate a few centimeters of s011 to give anyone standing
over a contaminated area a reasonably uniform irradiation over the whole
bOdy. The greater the duration or intensity of this exposure. the larger the
dose. and hence the greater the risk of adverse health effects. The gamma
radiation enmission is limited to the area immediately above the contamination. .
As discuSsed previouSly. tn~ EPA has determined that a significant
increase in public health risk would result if any of the contaminated
material on the Card property was disturbed and misused or if the area was
redeveloped. If a building was constructed over the area with the highest
gamma radiation readings, Area F2. the estimated annual dose to a person
working in the building would average 109 mi11irem per year with an estimatec
maximum annual dose of 179 mi11irem per year. These doses are in addition to
the background dose of 130 mi11irem per year incurred by those living in the
Denver area and resulting from cosmic. terrestrial, and internal Sources. The
maximum allowable whole-body gamma radiation dose derived from the relevant
and appropriate EPA standard, 40 CFR Part 192, and the National Council on
Radiation Protection and Measurements (NCRP) and International Commission on
Radiological Protection (ICRP) recommendation for a person in the workplace
are 180 and 100 mi11irem per year, respectively, in addition to natural
background and medical exposure. The estimated annual dose to a person living
in a building built over Area F2 would average 355 mi11irem per year with an
estimated maximum annual dose of 585 mi11irem per year. The Whole-body gamma
radiation dose derived from the relevant and appropriate EPA standard, 40 CFR
Part 192, and the NCRP and ICRP recommendation for a residential occupant are
130 and 100 mi11irem per year, respectively, in addition to natural background
and medical exposure.
The projected cancer risk from gamma radiation (including background) to
individuals working in a building built over Area F2 would averag~ 40 cancer
deaths per 10,000 persons exposed with a maximum projected cancer risk of 47
cancer deaths per 10,000 persons exposed. The projected cancer risk to
individuals living in the building would average 98 cancer deaths per 10,000
persons exposed wi th a maximum projected cancer risk of 1,200 cancer deaths
per 100 persons exposed". Area F2 represents about 5% of the estimated volume
of con tami na ti on on the site.
-------
10
If individuals }fl any building were to receive a lifetime gamma radiation
dose equivalent to that of the relevant and appropriate EPA standard, 40 CFR
Part 192, then the projected cancer risk to those working in the building
would average 31 cancer deaths per 10,000 persons exposed and the projected
cancer risk to those living in the building would average 53 cancer deaths per
10,000 persons exposed. The projected cancer risk to individuals receiving a
lifetime dose of 9.5 rem resulting from the Denver area background would be 27
cancer deaths per 10,000 persons exposed. It should be noted that cancer
risks resulting from gamma radiation exposure are in addition to those
resulting from inhalation of radon decay products. Table 2 presents the above
state information.
Inhalation or Ingesti9n of Radium-Contaminated Material:
Inhalation of the long-lived radionuclides like uranium, thorium, and
radium is possible for persons living or working on or near the Card
property. Surface material suspended by the wind may contain small
concentrations of these elements and the resulting airborne contamination is a
potential human exposure pathway. Direct ingestion of long-lived
radionuclides can result in significant doses to various internal organs of
the bOdy. However, s tudi es by the U. S. De partmen t of Energy have shown tha t
the projected radiation dose from this source are many times smaller than
U10se estimated for either rad~ decay product inhalation or direct gamma'
radiation exposure using even ~1e most conservative assumptions. Also, it is
unlikely that a person would ingest large amounts of the radium-contaminated
material on the Card property and dust control measures ordinarily employed
during excavation have been shown to provide sufficient control of exposure
from this source. For these reasons, the EPA acknowledges this human exposure
pathway, but no quantitative risk numbers were developed in the Public Health
Asses smen t.
.
Low-levels of certain non-radiological carcinogenic contaminants were
found in discrete locations on the Card property. The Public Health
Assessment quantifies risks to human health from ingesting soil containing
, these contaminants. The projected cancer risks from this type of exposure
range from .038 cancer deaths per 10,000 persons exposed to 1.2 cancer deatns
per 10,000 persons exposed. lhese risk estimates are several orders of
magnitude lower than the estimiated risks resulting from exposure to the
radiological contamination on the proper~. Nonetheless, the presence of
non-radiological contaminants on the site will be explicitly considered in all
health and safety provisions of the cleanup.
The foregoing discussion demonstrates that a release or substantial
threat of release of a hazardous substance or pollutant or contaminant into
the environment has occurred at the Card property and that the release or
threat of release may present an imminent and substantial endangerment to
public health or welfare. It is also clear from the calculated risks that
remedial, action at the Card, property is justified. The short- and long-term
potential for adverse health effects from human exposure associated with the
various remedial action alternatives evaluatea for the Card property are
discussed later in this summary.
-------
Table 2
PROJECTED CA~CER RISKS
OPERABLE UNIT X
DENVER RADIUM ~ITE
Average Cancer Deaths Maximum Cancer Deaths
Scenario Exposure Per 10,000 Persons Exposed Per 10,000 Persons Exposed
Radon Decay Produc ts:
Building constructed O. 18 Wl Workp1 ace 190 to 790 Workplace 1 200 to 3700
over Area Ml Resi dentia1 1100 to 5600 Resi rlenti a 1 4400 to 7900
;
EPA Standard 0.02 WL Workplace 23 to 91 ......
Resi denti al 1 30 to 5UO ......
Typical U.S. Home 0.005 UL Residential 33 to 1 30
Gamma Radiation:
Building constructed 54 .tIR/hr Workp1 ace 40* Workplace 47*
over Area F2 Resi dentia1 98* Residential 1 ,200*
EPA Standard 20 .tIR/hr Workp1 ace 31*
Resi dential 53*
Background 15 AJR/hr Resi dentia1 27
* In addition to risk from exposure to background gamma radiation levels.
.
-------
,
12
Enforcemen t
A detailed responsible party search for the entire Denver Radium Site has
been initiated. Thus far. the search has not identified any parties
responsible for the G~ntamination on the Card property. Records show that
Pittsburgh Radium Company owned and operated the radium processing facility at
the time of disposal (circa 1920-1924) of radium. the hazardous substance of
concern. Although extensive investigation has been conducted. the responsible
party. search has yet to trace the corporate history of Pittsburgh Radium
Company to a viable. present-day company.
Mentor Corporation is a current owner of a large portion of the site.
1he responsible party search indicates that Mentor Corporation acquired the
property in 1977 without knowledge of the contamination on the site. Further.
it does not appear that.(1} Mentor Corporation conducted or permitted the
generation. transportation, storage. treatment, or disposal of any hazardous
substance at the Card property or that (Z) Mentor Corporation. since becomin9
aware of the contamination on its property, contributed to the release or
threat of release of a hazardous substance at the facility through any action
or omission.
Based upon these initial findings, EPA has begun negotiations with ~~ntor
Corporation concerning a covenant not to sue for potential liability to the
United States, including future liability, resulting froD. the release or
threatened release of the hazardous substance to be addressed by remedial
action at the Card property. The terms of this convenant not to sue are
embodied in a draft administratiYe order on consent which is attacned to the .
ROD. Upon selection of the remedy and finalization of the responsible party
search for the Card property, EPA will revise the draft administrative order
to comport with the ROD and current laws. In exchange for this covenant not
to sue, Mentor Corporation would agree to provide access to its property to
enable EPA to undertake remedial action at the Card pro~erty ana, at EP,~'S
discretion, permit EPA to deliver for storage at the Mentor property
radium-contaminated materials from other properties included in the Denver
Radium Site.
.
Consolidated Freightways is a current owner of a portion of the Card
proper~. Consolidated Freightways bought its portion of the property in
March, 1985, nearly two years after the formal listing of the Denver Raaium
Site on the National Priorities List. During the summer of 1985, the company
proceeded to construct a trucking terminal on the property and as a result two
areas of contamination on the site can no longer be identified.
The EPA does not feel that remedial action should be delayed pending
finalization of the responsible party search. EPA anticipates discussions and
negotiations with both Mentor Corporation and Consolidated Freightways.
Further. if upon finalization of the search. the EPA identifies
additional responsible parties, the EPA will formally notify them of the
remedy selected in the ROD and ini tiate negotiations for the implementation of
the remedy. Negotiations will not exceed sixty days. Thereafter, if the
..
-------
Regulatory Agency
FEDERAL
II.~. F.rA-40 eFR rart 191,
Suhp:Jrt B-St:Jndard!l
~~lrRr Rr~ulatory
Commission (NRC)
1 II eFR r:Jrt 70
Type of Cont:JmlO
a]1 contaMinated ares would be remedl;'lted.
Relevant and appropriate to Indoor gamma radiation.
Point of compliance Is Inside any site building.
Re]evant and appropriate to Indoor radon.
1'1 lance Is InsIde any site building.
Po Int of cnm-
......
1../1
Point of compliance Is any location withIn sltr.
Point of co.pllance Is any location withIn sltr.
Point of compliance Is any locatIon withIn site.
Point of compliance Is any location within site; sl!r
would be unrestricted for relledlatlon workrrs.
;JRf'lev:Jnt and approprlat.e st.:Jnd;'lrd hut not ;'15 prot.ectlve as Other Guidance; see Table 4-3.
h
An unrest.rlct.ed are:l 15 rr":lrdrd ;'IS :my phcE' around :J W;'Ist.E' consolld:Jtlon/storage area facility whpre access Is not controlll'd.
c" rl'strlct.ed arr:J h rrg:Jrded ;'IS ;'Iny pl"ce "round :J W;'Istf> consolld:Jtlon/stor:lge :Jrea where access Is controlled.
I1E/l I-:N7/0 17
.
.
-------
13
responsible parties do not formally commit to performing the remedy in a
timely manner, the EPA will proceed with a fund-financed remedial ~esign ana
remedial action and will attempt to recover EPAls response costs from the
responsible parties.-'
Degree of Cleanup
Pursuant to SARA Section 121(d), remedial actions shall attain a degree
of cleanup of hazardous substances, pOllutants, and contaminants released into
the environment and control of further release which at a miniumum assures
protection of human health and the environment. In addition, remedial actions
shall, upon their completion, reach a level or standard of control for such
hazardous substances, pollutants, or contaminants which at least attains
legally applicable or relevant and appropriate Federal standards,
requirements, criteria, or limitations, or any promulgated standards,
requirements, criteria, or limitations under a State environmental or facility
siting law that is more stringent than any Federal standard (ARA~s).
On November 20, 1986, the EPA requested that the State of Colorado
identify potentially applicable or relevant and appropriate state requirements
for the Card property. On January 21, 1987, the State responded to this
request and provided a list of Colorado requirements which the State believed
pertained to the Denver Radium Site. Concurrently with this State activity,
the EPA developed potentially applicable or relevant and appropriate Federal'
requirements. The EPA classified all app1 icab1e or relevant and appropriate
requirements identified into four categories: contaminant-specific ARARs,
action-specific ARARs, location-specific ARARs, and other Federal and State
criteria, advisories, and guidance to be considered. A description of each of
these categories is provided in both Chapter 4 and Appendix C of the FS.
Tables C-1 through C-4 in Appendix C of the FS contain a brief description of
each potential Federal and State requirement identified and EPA's analysis of
each requirement's applicability or relevance and appropriateness to the Care
property. The result of this analysis is summarized below.
Contaminant-specific ARARs:
.
The EPA Standards for Remedial Action at Inactive Uranium Processing
Sites, 40 CFR Part 192, are one of two contaminant-specific ARARs identified
for the Card property. For properties contaminated with uranium processing
residues, these standards establish limits for the gamma radiation level and
an~ual average radon decay product concentration in any occupied or habitable
building and for the radium concentration in soil on open lands. Although not
app1 icab1e to the Card property since the standards apply only to certain
specifically designated sites where uranium was processed, the standards are
relevant and appropriate to the Card property because (1) it is the radium
content of the uranium mill tailings which is regula tea; (2) the waste
products resu1 ting from uranium ore processing are very simi lar to those from
both radium and vanadium ore processing; (3) the residues from both processes
enter the environment through the same exposure pathways; and (4) the adverse
health concerns resulting from exposure to the residues from both processes
a re the same.
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14
The portion of the standard relevant and appropriate to the contaminated
soil on the Card property is 40 CFR Section 192.12 ~ich states:
"Remedial acti ons shall be cOnQJcted so as to provi de reasonabl e
assurance that. as a result of residual radioactive materials from any
designated processing site:
(a)
the concentration of radium-226 in land averaged over any area
of 100 square meters shall not exceed the background level by
more than -
(1) 5 pCi19. averaged over the first 15 cm of soil below the
surface. and
(2) 15 pCi/g. averaged over 15 cm thick l~ers of soil more
than 15 cm below the su rface. II
(40 CFR Section 192.12.)
The portion of the standard relevant and appropriate to the buildings on
the Card property is 40 CFR Section 192.12(b) ~ich states:
(b) In any occupied or habitable building -
.
(40 CFR Section 192.12(b).)
..
(1) The objective'of remedial action shall be. and reasonable
effort shall be made to aChieve. an annual average (or
equivalent) radon decay product concentration (including
background) not to exceea 0.02 WL. In any case. the radon
decay product concentration (including background) shall
not exceed 0.03 WL. ana
, (2) The 1 evel of galTlTla radi ation shall not exceed the
background level by more than 20 microroentgens per hour.
Even though the radon decay product concentration in the buildings is
well below the 0.02 working level standard. some galTlTla radiation measurements
in the Brick Commercial building exceed 20 microroentgens per hour.
. The second contaminant-specific ARAR identified for the Card property is
the Nuclear Regulatory Commission Standards for Protection Against Radiation.
10 trR Part 20. lhese regulations establish standards for protection against
radiation hazards arising out of activities under licenses issued by the
Nuclear Regulatory Commission (NRC). Because these standards apply to
licensed NRC facilities. they are not appl icable to the Card property.
However. EPA has determined that portions of the regulations are relevant and
appropriate to individuals ~o would be conducting the remedial action on the
Card property. In particular. Appendix B of 10 CFR Part 20 provides limits
for airborne concentrations of natural uranium. thorium-230. and radium-226.
Gamma radiation dose standards for individuals in restricted and unrestricted
areas are cited in 10 CFR Sections 20.101 and 20.105. respectively. These
10 CFR Part 20.standards along with the 40 CFR Part 192 standards are
summarized in Table 3.
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1 5
Location-specific ARARs:
The Colorado Hi~torical Society has made a preliminary detennjnation tnat
the Card property is eligible for inclusion in the National Register of
Historic Places. This finding was based on the property's earlier industrial
importance as a radium processing facilitY. The EPA has determined that both
the National Historic Preservation Act and the Archeological and Historic
Preservation Act are location-specific ARARs. Remedial action at the Card
property will not adversely affect the historic character of the site.
Nonetheless, the EPA will continue to cooperate with the Colorado Historical
Society by providing documentation lending historical significance to the
property and will adhere to the requirements of the afonnentioned Acts.
Action-specific ARARs:
The EPA has identified several action-specific ARARs. Since these ARARs
are techno10gy-based restrictions triggered by specific types of remedial
measures under consideration they were considered along with the development
of remedial action alternatives and will be discussed in the next section
entitled "Alternatives Evaluation".
Other Criteria to be Considered:
In the category of other Federal and State criteria, advisories, and,
guidances the EPA determined t~~t when selecting the remedy it would consider
the National Committee on Radiation Protection and Measurements (NCRP) and
International Commission on Radiological Protection (ICRP) guidelines. The
NCRP and ICRP recommend a maximum gamma radiation dose to the whole body of
100 mi11irem per year for all sources except medical and natural background
for chronic exposure situations.
.
Pursuant to the NCP, '40 CFR Section 300.6B(a)(3) and SARA Section 121,
Federal, State, and local permits are not required for on-site fund-financed
remedial actions. However, the EPA expects that non-environmental and
construction permits will be required in carrying out CERCLA Sections 104 and
106 onsite response actions. The EPA will also take steps to ensure that
offsite disposal of any contaminated material removed from Card property is
consistent with the EPA's offsite disposal policy, that is, final disposal
will be at a facility suitable for the disposal of the Denver Radium Site
was tes. .
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1 7
Alternatives Evaluation
The EPA evaluated potential remedial action alternatlves for the Card
property by progressing through the series of analyses which are outlined in
the National Contingency Plan (NCP), in particular, 40 CFR Section 300.68, and
the Interim Guidance on Superfund Selection of Remedy, December 24, 1986,
(OSWER Directive No. 9355.0-19). This process in part enables the EPA to
address the SARA Section 121 requirements of selecting a remedial action that
is protective of human health and the environment, that is cost-effective, anC;
that utilizes permanent solutions and al ternative treatment technologies or
resource recove~ technologies to the maximum extent practicable.
lhe selection of remedy process begins by identifying certain
site-specific information to be assessed in determininy the types of res~onse
actions that will be considered for the site. A general list of site-specific
information is contained in Section 300.68(e)(2) of the NCP. This list was
used to identify specific site and waste characteristics of the Card
property. (See Table 5-1 of the FS.) Based upon these si te and was te
characteristics, the EPA was able to scope, from the universe of all possible
response actions, a set of response actions and associatea technologies to be
considered for the Card proper~. An example of this scoping process was the
elimination of ground water barriers from further consideration because groun~
water contamination is not a characteristic of the Card propert;y. Appendix D
of the FS illustrates the scoping process and Table 5-2 of the FS details the
res u 1 ts.
.
Section l21(b)(l) of SARA-.states that, "The President shall conduct-an -
assessment of permanent solutions and alternative treatment technologies or
resource recovery technologies that, in whole or in part, will result in a
permanent and significant decrease in the toxicity, mObility, or volume of thE
hazardous substance, pollutant, or contaminant.1I As part of this process, the
EPA evaluated permanent solutions to the problems associated with the specific
hazardous substances present on the Card property. The necessity to fina a
treatment technology which successfully reduces the mobility, toxicity, and
volume of a hazardous substance presents a problem since the hazardous
substance associated with the Card property is a radioactive element. The
characteristic of spontaneously emitting energy and subatomic particles is a
property inherent to each atom of a radioactive element and which cannnot be
altered or destroyed by any chemical or physical treatment known today. Most
treatment and resource recovery technologies concentrate the radioactive
elements present in the waste, increasing toxicity without significantly
reducing volume or mobili~. lhese treatment and reSOurce recovery
. technologies often also leave a waste product which is still radioactive.
~Onetheless, EPA considered several treatment and resource recove~
technologies along with more conventional response actions such as capping or
excavation. lhese alternative treatment technologies include sand sifting, in
situ vitrification, and reprocessing. .
-------
18
Before the techn010gies were assembled into remedial action alternatives,
they were categorized as either source control or management of migration
measures and then prescreened based on their sUitabilitY to abate the threat
at the Card property. Source control measures are intended to contain the
hazardous substances onsite or eliminate the potential for contamination
altogether by transporting the hazardous substances to a safer location.
Management of migration actions are taken to minimize and mitigate the
migration of hazardous substances. Management of migraton measures have
particular importance at the Card propertY since radon gas, alpha particles,
and gamma r~s are continuously being released from the source, radium. The
results of the prescreenlng of both Source control and management of migration
measures based on their sUitabilitY to abate the threat at the Card property
are presented in Table.5-3 of the FS.
The next step of the selection of remedy process is assembling the
remaining technologies and/or disposal options into remedial action
alternatives. Section 300.68(f)(2) of the NCP requires EPA to develop
remedial action alternatives in a range of categories which are based in part
upon ARAR attainment. The OSWER Directive No. 9355.0-19, hInterim Guidance on
Superfund Sel ection Remedy" requires EPA to develop remedial action
alternatives ranging from those that would eliminate the need for long-term
management (including monitoring) at the site to alternatives involving
treatment that would reduce toxicity, mobilitY, or volume as their principal
element. Alternatives developed in this way will va~ mainly in the degree to
which they rely on long-term management of treatment residuals or
low-concentratea wastes. lhe OSWER Directive also instructs EPA to develop a
containment option involving little or no treatment and a no action
al ternative.
.
Alternatives developed in the FS for the Card property were:
1. No Action
2. Deferred Rer.oval, Offsite Permanent Disposal
3. Onsite Reprocessin&/Treatment, Offsite Permanent Disposal
4. In Si tu Vi tri ff ca ti on
5. Onsi te Permanent Disposal
6. Offsite Permanent Disposal
7. Onsite Temporary Land Storage, Offsite Permanent Dispo~al
8. Onsite Temporary Building Storage, Offsite Permanent Disposal
9. Onsite Temporary Containment (Capping), Offsite Permanent Disposal
Table 4 provides a comparison of each of the alternatives listed above
with the alternative categories specified in Section 3oo.68(f)(2) of the NCP.
-------
NCP Category
]. Complete removal and subse-
quent treatment or disposal
at an offsite facility.
2. Attain applicable or rel-
evant and appropriate
Federal and State public
health and environmental
requirements
3. Exceed applicable or rel-
eVont and appropriate
Federal and State public
health and environmental
requirements
4. Does IIOt attain Federal
and State requirements but
reduces present or future
threat and provides signi-
ficant protection to pub-
lic health and the
environment
0:-,. No action
I JJ-:/TI':U 2/0]0
Common
Elements
x
Table 4
NCP ALTERNATIVE CATEGORIES
OPERARLE UNIT X
DENVER IU\DIUH SITE
I
Alternative Number
~34 5678
X
X
X
~
X
X
X
X
x
.
X
9
Comments
X
X
Complet~ removal of oily layer ilnd
decontamination of wall material; cum;-
plete removal of soils and sediments..
Vitrification and capping might attain
ARAR's.
\0
Onsite and offsite disposal
designed and implemented to
ARAR's.
could bp
exceed
X
Reprocessing may not provide a non-
radioactive soil after treatment;
significant reduction could Occur.
Temporary measures will probably not.
meet ARAR's until the contaminated
materials are removed from the sitp.
and placed in an off site disposal
facility. Alternatives 7 and 8 could
temporar ily reduce exposure to r ad J' ,-
active materials. Alternative <.' ("lJuJd
reduce exposures, depending upon
thickness of the cap.
Also serves as a basf'line for
comparison.
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20
Alternatives 2, ~; 6, 7, 8, and 9, since they require the permanent
offsi te disposal of contaminated material, woul d eliminate the need for
long-term management (including monitoring) at the Card proper~.
Alternatives 3 and 4 involve treatment as their principal element, but do not
necessarily reduce the mobility, toxicity, or volume of the waste.
Alternative 3 necessarily includes a provision for the permanent disposal of
the treatment residues. Alternatives 4 and 5 require peMminent onsite
remedies, and hence, long-term management and monitoring at the Card
proper~. Finally, No Action was included as Alternative 1.
Alternatives 7, 8, and 9 were developed to include temporary response
measures followed by permanent offsite disposal of the contaminated material
when a facili~ for such a disposal becomes available. Alternative 6, Offsite
Permanent Disposal, is not immediately implementable because the State of
Colorado has not at this time designated a facili~ for the disposal of the
Denver Radium Site wastes. Pursuant to CERClA Section 104(c)(3)(C)(ii), it is
the responsibili~ of the State to assure the availabili~ of a disposal
site. Also, in order to comply with SARA l04(k), and in order to assure that
remedial actions within Colorado continue, the State must provide adequate
assurance of the availabili~ of a hazardous waste treatment or disposal
facility within three years from the effective date of SARA, October 17,
1986. Although progress is beinQ...made to this end, the State does not expect-
to have a fully operational disposal facility for up to five years. In the
meantime, in its presently uncontrolled state, the radium-contaminated
material at the Card property could be misused or inadvertantly spread,
possibly increasing the risk to present or future pUblic health, welfare, or
the environment. In addition, the cost of final remedial action is liable to
increase due to inflation; the Card property owners and tenants face economic
losses associated with restricted use of their properties; ana the EPA may
incur further costs by upaating si te s tudi es in the face of changing si te
conditions. The EPA determined that developing alternatives which include
temporary response actions was not only justified, but necessary in order to
effectively mitigate or minimize threats to and provide adequate protection of
,public health, welfare, or the environment at the Card property.
.
Once the remedial action alternatives were developed, it was possible to
identify action-specific ARARs. lnese ARARs are distinct from the
contaminant-specific and location-specific ARARs identified earlier in this
summ~ry in that action-specific ARARs are technology-based restrictions
triggered by specific action elements associated with the remedial action
alternatives under consideration. lne following action elements are part of
at least one or more remedial action alternative developed for the Card
proper~ :
- remOval of the oily layer of the oil and waste water pond
- removal of soils and sediments
- removal of wall material
- permanent onsite disposal
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21
...
permanent offsite'disposal
- temporary onsite storage or containment
- treatment or reprocessing
Potential action-specific MARs for the action elements listed above were
cons'idered in Appendix C of the FS and are presented in Table 6-3 of the FS.
Initial screening, which is the next step in the selection of remedy
process, narrows the list of potential remedial action alternatives requiring
detailed analysis. Consistent with 40 CFR Section 300.68(9) and the OSWER
Directive 9355.0-19, the remedial action al ternatives developed for the Card
property were initially screened using the criteria of cost, implementability
(acceptable engineering practices), and effectiveness. Table 7-1 in the FS
surnnarizes the initial screening process. Alternatives 1,2,5,7, and 8
passed the initial screening and were carried forward for detailed analYSis
while Alternatives 3, 4, 6, and 9 were screened primarily for the reasons set
forth below.
Alternative 3, Onsite Reprocessing, was eliminated from further
consideration based on its lack of effectiveness. Since both the reprocessed
soil and the concentrated precipitate resulting from the reprocessing of the
soil would require disposal in a facility that meets the requirements of 40
CFR Part 192, this alternative would provide no additional benefit to public,
health or the environment ovel"'~other alternatives to be considered.
Alternative 4, In ~itu Vitrification, was eliminated during the initial
screening because its implementability for this particular application is
unproven. In situ vitrification has not been demonstrated on a large scale or
utilized in a highly-populated urban area like that of the Card property. The
extreme temperature requirements of this process could cause unknown damage to
onsite structures and any buried utilities or pipelines. Once vitrified, a
cap over the area might be necessary to limit the escape of radon gas an~
associated radon decay products. Furthermore, the property would have to be
permanently dedicated as a disposal site and measures would have to be taken
to prevent human contact with or disturbance of the vitrified material.
Finally, this alternative would require long-term government ownership,
licensing, management, and monitoring to protect the integrity of the
vitrified mass. These requisites would conflict with current and proposed
land uses for the area, as well as State policies on siting disposal
facil i ti es.
.
With the elimination of these two alternatives, no alternatives which
involve treatment as a principal element survive the initial screening.
However, EPA has no reasonable belief that either of these alternatives offers
the potential for better treatment performance or implementabili~, lesser
adverse impacts, or lower costs than demonstrated alternatives.
Alternative 6, Permanent Offsite Disposal, was eliminated during initial
screening because it is not imp1ementable at this time. As discussed earlier,
the State of Colorado has not at this time designated a facility for the
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22
disposal of the Denver Radium Site wastes. Alternative 9, Temporary Onsite
capping. Permanent Dffslte Disposal. was eliminated curing Initial screening
because it is neither as effective nor as implementable as similar
alternatives, Alternatives 7 and 8, and would cost almost as much as other
alternatives that achieve the same objectives.
FOllowing is a description of the remedial action alternatives surviving
the initial screening.
7.
1.
No Action
If tnis alternative were selected, no action would be ta~en at the
contaminated Card property. This alternative was retained for
further analYSis and consioeration as required by the NCP (40 CFR
Section 300.68(f)(1)(v)).
2.
Deferred Removal, Permanent Offsite Disposal
This alternative would defer removal of the contaminated material at
the Card property until an approved permanent offsite disposal.
facility is identified and made available by the State of Colorado.
Once this facilit„ becomes available, the entire estimated 4,000.
cubic yards of contaminated soils and sediments on the Card
property, Which includes the estimated 475 cubic yards of
contaminated soils lying under the Brick CofllTlercial and UPL
buildings, would be excavated. The material would then be
transported by either truck or rail for final disposal at this
facility. The Card property would then be available for
unrestricted use.
.
5.
Permanent Onsite Disposal
This al ternative entails the excavation of the approxima t.ely 4,000
cubic yards of contaminated material on the property and disposal
onsite in a facility constructed in accordance with 40 CFR Part 192
SUbparts A and B. The disposal area would require permanent access
restrictions and long-term monitoring. A buffer zone would be
created between the disposal facility and the surrOunding
businesses. In accordance with SARA Section 121(c), a review of the
permanent onsite disposal facility would be required no less than
every fi ve years.
Temporary Onsite Land Storage, Permanent Offsite Disposal
This alternative would provide temporary storage of the estimated
4,000 cubic yards of contaminated material until a permanent offsite
disposal facility becomes available. There are several options for
the land-based storage facility including an asphalt pad with a
suitable cover. The storage facility would require security
precautions, radiation monitoring, and regular inspections. An
option associated with this alternative is the use of the temporary
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23
facility for storage and staging of material from certain other
Denver Radium Site properties. Once a permanent offsite aisposal
facility becomes available, then the contaminated material would be
sent by truck or rai 1 to the faci 1 ity. The Card property woul d then
be ava i 1 ab-1 e for unres tri c ted us e.
8.
Onsite Temporary Building Storage, Offsite Permanent Disposal
This alternative consists of excavating the approximately 4,000
cubic yards of contaminated material, placing the material in
reinforced synthetic bags, and storing the bags in the True Truss
Building until a permanent offsite disposal facility becomes
available. As with Alternative 7, an option associated with this
alternative is to bring material from certain other Denver Radium
Site properties for staging and storage in the True Truss bUilding.
Once a permanent offsite disposal facili~ becomes available, the
contaminated material would be transported by either truck or rail
to the facili~. The True Truss building would be decontaminated,
then demolished and the material sent to a sanitar,y landfill. The
Card property would tnen be available for unrestricted" use.
Conmon to all of the remedial action al ternatives briefly described above.. .
with the exception of Alternative 1, No Action, is the response actions that
would be taken for the decontamination of the contaminated portion of wall
within the Brick Commercial building and the removal of the water and the oily.
layer from the oil and waste water pond. The contaminated portion of wall
within the Brick Colllnercial bU,Uding would be decontaminated by surface'
scrubbing or by possible removal of the brick wall surface. My wall material
requiring removal would be disposed of along with the contaminated soils and
sediments which are present on the Card property.
The oi ly 1 ayer of the oil and was te water pond woul d be tes ted for
radi oactive and nonradi oactive con taminati on. If only radi oactively
contaminated, the oil would be handled with the contaminated site soils and
sediments. If contaminated only with hazardous substances, depending on the
amount and ~pe of nonradiological contaminants, the waste would be
transported to a hazardous waste disposal or treatment facility or an
industrial boiler or furnace for energy recovery.
If testing reveals both radiological and nonradiological contaminants,
the oily layer could be a mixed waste as defined in the OSWER Directive No.
9440.00-1, "Guidance on the Definition and Identification of Radioactive Mixed
.w as tes II (EP A, 1987) and woul d have to be handl ed in accordance wi th
restrictions on such waste. .
The standing water in the oil and waste water pond would also be tested.
If uncontaminated, the water would be either evaporated 01" used for onsite
dust control if removal or excavation measures are implemented. If
contaminated, the water would be evaporated and the remaining sludge would be
handled with contaminated site soils and sediments or, if necessary, as a
mi xed was te .
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24
Conshtent with Section 300.68(h} of the NCP and the OSWER Directive No.
9355.0-19, the remedial action alternatives remaining after initial screenin9
were further refined and then sUbject to detailed analysis. Detailed analysis
of each alternatiave entailed evaluation based on the three broad criteria of
implementabili~, effectiveness, and cost. For each of these broad criteria,
the EPA identified appropriate and mor~ specific ..component measures" so that
the remedial action alternatives could be compared to each other using a full
arr~ of evaluation factors. The component measures derived for
implementabili~, effectiveness, and cost were based upon specific
requirements and criteri, contained in Section 300.68(h}(2} of the NCP, SARA
Sections 121(b}(1}(A through G), SARA Section 121(c}, and the OSWER Directive
No. 9355.0-19 discussion on detailed analysis.
The component measures of implementability are: technical feasibili~,
constructabili~, reliabili~, administrative concerns, availabili~ of
technology, and operation and maintenance. the component measures of
effectiveness are: ARAR attainment; effectiveness in significantly and
permanently reducing mobili~, toxici~, and volume; persistance, toxici~,
mobili~, and propenSity to bioaccumulate of the hazardous substances and
their cons ti tuents; protectiveness/heal th effects; environmental
protectiveness/potential for adverse environmental impacts; and compliance
with the Solid Waste Disposal Act.- the component measures of cost are: .
capital costs, operation and maintenance costs, and potential future
remediation costs if the alternative fails. Chapter 8 of the FS provides a
comparative review of each remedial action alternative based upon each of the
component measures listed above. Table 5 summarizes the detailed analysis of
alternatives. The selected remedy was chosen after the detailed analysis of
alternatives and is discussed in the next section.
.
Sel ec ted Remedy
EPAls preferred remedial action alternative for the Card property is
Alternative 6, Permanent Offsite Disposal. this alternative, however, was
eliminated during the initial screening of alternatives because until the
State of Colorado identifies a permanent disposal site for material from the
Card property, this alternative cannot be implemented. EPA has therefore
determined that the appropriate extent of remedy at the Card property is
Temporary Onsite Building Storage/Permanent Offsite Disposal, Alternative 8.
In the event that a permanent disposal facility becomes available before
Alternative 8 is implemented at the Card property, EPA may immediately
implement Alternative 6, Permanent Offsite Disposal.
Temporary Onsite Building Storage/Permanent Offsite Disposal, Alternative
8, is protective of human health and the environment and attains or exceeds
the relevant and appropriate Federal and State public health and environmental
requirements that have been identified for the Card property. As determined
during the detailed analysis, this alternative is a cost effective remedy that
effectively mitigates and minimizes threats to and provides adequate
protection of'public health, welfare, and the environment.
-------
Evaluation Criteria
o
Imple.entability
o
E (feet Ivenu.
"
a
Altemathe 1
110 Action
o
,..alble
o 100 CFII 192 condltlona for
ndh.-226 In aol" would not
be ntalned. If the property
II redeveloped, protective.....
Ine Ie for radon Wou Id not be
ettalned.
o ~'ICR' auldance for ....a
radIation ..y not be _t If
the property II redeveloped.
o 110 Ac tlon doea not reduce
8Ob1llty, todclty, and "01-
of aite ndloecthe .aterlale.
o Radioactive ..terlala ere
eatr_ly peralltent; ndl-
II not very _bile and .he.
off radon decay producu to
the at_.phere. ""lie not ..ery
aoluble after reproee..ln.,
radon II aubJect to dllperlll
via ht8en activity. Radon
decay proclucu Cln accl8Ulete
In ....... lunla and are car-
clnoaenlc. ee- radiation
could ceUIe cancer or lenetlc
defecu.
Table 5
SUHHARY or ALTEMATI VE EVAlUATJOII
OPERAnLE UNIT x, DENVER RADIUH SITE
o
Alternathe 2
Deferred Ae~val'
'e~nent OHsite Olopoaal
Site could underlo additIonal
deyeto,..nt (I.e. Con.oll-
dated FrellhtwayaJ In cont..-
Inated area. Contaalnated
.ater"" could be dispersed
or diluted auch that they
_Id no longer be
Identl flable.
o
ExUV8t Ion cannot proceed
until an offalte dl.posal
facility I. available.
A..allability required by
SARA 1010 (k). facility II
..._d not to be aval lable
until 1992.
o \/hlle re80vai Is deferred,
100 CrA 192 radon and 10 CrA 20
airborne concentratIon ARAR's
.ay not be eat unless u.e
restrIctIons and control. are
1.,le_nted. Aedl...-226
leyels In 8011 would not be
Nt unt 11 rel8Oval.
Alternative S
Ooslte Olepoul
o Lend dlspo.al facilltle. can
have technical proble.s, such
a. aeepale; 80derate potentIal
for c""ponent faIlure ..leu.
During constructIon of
disposal facility, clean
.aterl.l. could be dlsper.ed
onslte ..'s"ltlng In dllullon
of cunte..tn8led salls.
o Cond..nlnl alte for a 1,000-
year storage lacility plu. the
hlltorlcal aspect. of the .lte
could create proble.s that .ay
delay I.pleeentation. Site
access re.trlctlon. are .anda-
tory; the sire would be dedi-
cated {or use 88 . storage
facility for low-level radio.
actl..e wa.tes for the
Indefinite fUlure.
o 100 CFR 192 and 10 CrR 20 stan-
darda _Id be ..t by a pro-
perly desllned, con.tructed,
and 1"'PI....nted facility. Site
cleanup would re.ult In @...a
radiation and radon level.
that ere below standarda.
o 6 CeA 1001-1 (Colorado Rule.
and Re,ulatlon. 'ertalnlnl to
Radiation Control) sltlnl
obJect lye. would not be eet
because the ,II,posal facility
would be In a populated area.
-,
Alternative 7
Teeporary Onalte Land Storale'
'erunent Off.lte Dlapoaal
o Teeporary atora.. can hav.
technical probl..., such a.
rlppln. of the aynthetlc liner
or cr.ck. In the aaphalt pad.
o Teeporary .tora.a _Id be
ua.d until offalte dl.po.al
facility la avallabla.
Ayallability required by
SARA lOIo(k). Facility I.
aa._d not to be av.ll.ble
until 1992.
o
Site acce.a reatrlctlon. and
approyal. would be needed to
con.truct the a.phalt pld ator-
al. unit. Ston,e facility
would .nerely rutrlct uu,e
of over.11 alte for S year.,
.Inee It would occupy a lar,e
percentale of open .pace at the
alte.
-------
Evaluation erlt~rl.
o
Effectiveness (continued)
o
Costs
Alt~rn.Uv. I"
No Action
Not Appllc.bl~
a,~ = present worth at . 10 perce~t diScount factor.
bnli.M "" n....p...'t"f""n~ Jlntf N.'1intpn,."rll'
Trtr'
(con
'j
d)
A Iterna tI ve 2
D~f~rr~d R~movall
P~rmanent Offslle Disposal
o
Durlnl excavptlon, remedial
action workers would be exposed
to approxlmat~ly 162 mrem/yr
(whole body Dose Equivalent),
which Is below the 10 eFR 20
standard 01 500 mrem/yr for
workers. Onslte workers that
are not assocIated \11th cleanup
would be exposed to approxi-
mately 7.4 mr~m/yr. which Is
b~low th~ Nr.RP/ICRP guldallce
of 100 mremlyr for chronic
exposure to th~ gelleral public.
Transportatlon of J50 mIles to
offslte disposal facility would
involve driver exposure of
6.4 mrem/per trip. Hlnlmal
exposure would occur to general
public during transportation,
unl~ss an accidental spill
occurred, which would result
1" 8 mInor Increase In expo-
sures.
o Cap~tal Pw"--$7Jl.5oo
O&H PW--$22.7oo
Alternative 5
Onsll~ Disposal
AIt~rnatlv~ 7
T~lIporary Onslt~ Stor.g~1
Pel1Dan~nt orrslt~ Disposal
Th~ facility ahould b~ pro-
t~ctiv~ of th~ ~nvlr~nt If
appropr1at~ IIn~rs and caps
ar~ us~d. Pot~ntfel lilpacts
coo ld occur durlns r~80vII
(bnth for plac~_nt In th~
temporary fad II ty and th~
p~rman~nt offalt~ facUlty) If
uncontrollabl~ disp~raal
occurs to the env IrOf'l8ent.
o During excavation, r~mp-dlal
action workers \loulfl he
expos~d to III IDrem/yr
(whole body rJos~ E'luivalent),
which Is below the 10 eFR 20
standard of 500 IIrem/yr. Onslt~
workers who are not associated
with cleanup would be exposed
to approximately 7.6 mr~m/yr
wh Ich Is be low the NCRP IIr.RP
standard of 1n0 IIrem/yr.
o
o
DurinS excavation, r_dial
action workers would b~
~xpoa~d to approd..t~ly
162 .r~./yr (whole body Dos~
EquiV8I~nt), which h below
th~ 10 eFR 20 standard of
500 .r~./yr. Onsite work~rs
who ar~ not .aaociat~d with
cl~anup would b~ e.po.~d to
7.4 .r~.lyr, which h below
t~ NCRP/ICRP suidel1ne of
100 .r../yr and the 40 CFR 190
atandard of 25 .rn/yr at th~
bc 1I Ity boundary. Transporta-
tion ~.posur.. would b~ id~nti-
cal to Alt~rn.tiv~ 2.
I f olh~r Denver Redil8l prop.
erty Wastes are tellpOrarlly
.tor~d onsit~, r~..dlal action
work~rs wou ld b~ expo.~d to
"ppro""'t~ly 214 .rn/yr.
E.posur~ to workera not
assoclat~d with cl~anup would
incr~..~ to approd.at~ly
10.6 .r.../yr. In-town truck
drh~rs would be ~"poaed to
appro""at~ly 200 .r~./yr.
which ia below th~ 10 CFR 20
standard of 500 .r~./yr.
o Con.oUdatins uncontroll~d
w"st~a frD8 oth~r DenY~r
RediUJI propertlea at thl. sit~
would probably provide In-
creased ov~rall prot~ctlon
of th~ ~nviroD8ent. Dis-
persal rhk at these otber
prop~rt1.. would b~ r~duc~d.
o
o
Capital PII--$I.J54.000
O&H PII--$l,JJJ.400
o Capital PII--$1.501.400
O&H PI/--$244.5oo
-------
u
Evaluation Criteria
o
ImplemenUbi 11 ty
o
Effectiveness
DE/T£N2/04 7.3
27
Table 5
(Continued)
Temporary Onsite Containment/
Permanent Offsite Disposal
A Iterna t1 ve 8
o Synthetic bags could rip and
spill material in the building.
However, the building should
contain any spilled materials.
o Temporary storage would be
used until oifaite disposal
facility i8 available.
Availability required by
SARA l04(k). Facility is .
a..umed not to be available
until 1992.
o Approval. for u.in. True Tru..
Buildin. for radioactive
material stora,e have been
tentatively obtained.
o Temporary stora.e facility
would not .eet 40 CFR 192 and
10 CFR 20 .tandard. for .amma
radiation and radon unle..
ventilation is used. However,
radium standards in soils
would be met upon initial
remova 1.
o Access restrictions durin, the
storage period would limit
public appreciation of
historic value of the site.
o The mobility of the material
would be decreased unless the
container broke; however, the
use of a building for storing
the contdiners would contain
any spillage. The mobility of
radon gas could be decreased,
but could still present a
problem within the container
building used for storage.
If other Denver Radium prop-
erty wastes are consolidated
and stored at the Card Corpo-
ration site, the volume of
material will significantly
increase.
o
Common Elements
(Contaminated Wall and
Oily Layer)
o M1nimal potential for poor
decontamination performance,
since wall could always be
coapletely removed. Oily
layer, as a liquid, could
pre.ent handling problems;
ri.k of failure during removal
La minimal.
o Cleanup of the wall material
would be remediated a. part
of the cleanup for the .ite.
o Colorado Department.of Health
reaulates alpha particle
emi.sion.; these standards
would be met durin. decontami-
nation. Pond water ,",ould be
evaporated.
-------
, '
Evaluat10n Criteria
o
Effectivenes. (continued)
o Cos ts
DE /I'EN2 /O~ 7.4
28
Table 5
(Continued)
Temporary Ons1te Containment/
Permanent Offsite Disposal
Alternative 8
o During excavation, remedial
action workers would be exposed
to approximately 162 mrem/yr
(whole body Dose Equivalent),
which i. below the 10 CFR 20
gUideline of Soo mrem/yr and
the 40 CFR 190 atandard of
2S mrem/yr at the facility
boundary. Onsite workers that
are not aSSOCiated with
cleanup would be exposed to
approximately 7.4 mrem/yr,
which is below the NCRP/ICRP
standard of 100 mrem/yr.
transportation risks would be
identical to Alternative 2.
o Capital PW--S1,028,lOO
o O&H PW--S89,SOO
Common Elements
(Contaminated l.'a11 and
01ly Layer)
Included in Alternative Estimatea
.
I
-------
29
"\
The selected remedy does not satisfy the statuatory preference for
treatment \It'hich reduces toxicity. mobility. and volume of the hazardous
substances as a principal element. EPA evaluated several treatment
technologies. including sand sifting. reprocessing. and 1n situ
vitrification. None were found to be suitable to the site conditions or the
type of contamination present on the Card property.
.As described earlier. Temporary Onsite Building Storage/Permanent Offsite
Disposal would provide safe. temporary storage of the approximately 4.000 .
cubic yards of radiun~contaminated soil from the Card property until a
permanent offsite disposal facili~ is mad~ available by the State of
Colorado. lhe material would be excavated from the property. placed in
reinforced synthetic bags. and the bags placed in the True Truss building
1 oca ted near the southern end of the Card property. If extra capacit;y is
necessary to store the entire volume of material. an addition to the True
Truss bUilding could be constructed. Upon the availability of a permanent
disposal facili ty. all material waul d be removed from the property and
transported by either rail or trucK to the permanent offsite disposal site.
The True Truss building and any additions would be dismantled. decontaminated.
and the material disposed of in a sanitary landfill.
This alternative includes the option of consolidating and storing
radium-contaminated material from a select few other Denver Radium Site
properties. EPA initially considered bringing up to 40.000 cubic yards of
material from other Denver Radium Site properties. but because of concerns
raised by elected officials and..the neighboring cOllll1unity. EPA decided to
limit the maximum amount of material that could be stored at the Card property
to 13.000 cubic yards. Factors that will be considered in determining whether
material from the other properties will be brought to the storage facility
incl ude capacity of the storage faci li ty. timing. and the compara tive heal th
and environmental threats posed by the other Denver Radium Site properties
wt10se cleanup would be facilitated by temporary offsite storage. No material
would be brought from any Denver Radium Site property where EPA determines
during the selection of remedy process for that property that an onsite remedy
could be implemented, e.g.. there is sufficient space for an onsite action,
and where there is direct access at the property to a rail line for
transportation to a permanent offsite disposal facility.
In 'further response to public concerns about temporary storage on the
property. EPA also decided to limit the duration of the temporary storage.
EPA initially considered a duration of storage extending for as much as three
years additional time beyond the initial five year period if no disposal
faeility had been made available by the State. But in response to comments,
EPA has decided to limit the maximum amount of time for temporary storage at
the Card property to five years.
.
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30
The present wortit cost of this alternative is $1,148,000. This includes
excavation of all contaminated material, placement of the material in the
bags, placement of the bags in the True Truss building, and maintenance and
monitoring of the bags and building for 5 years. The cost also includes
removaJ and transportation of the contaminated material to the offsite
disposal facility, as well as dismantling and decontaminating the bUilding,
and transporting the material to a sanitary landfill.
Operation and Maintenance
Operation and maintenance activities will be required to ensure the
effectiveness of the temporary storage facility. The total of discounted
annual operation and maintenance costs, using a time period of five years and
a discount rate of 101, is $89,500. This figure could va~ depending upon the
State's progress towards identifying a permanent disposal site. Operation and
maintenance activities include site inspections and possible minor structural
repairs. EPA will have lead responsiblili~ for all operation and maintenance
activities during tempora~ storage. The costs of operation and maintenance
during temporary storage will be shared between EPA and the State of Colorado
in the same manner as other aspects of remedial action.
.
Communi~ Relations
The Denver Radium Site Community Relations Plan establishes a means for
communicating information and eliciting comments concerning the site from
State and local officials, potentially interested neighborhood associations
and individuals, and the local media. The EPA issued a press release
announcing tne October 6 through November 15, 1986 public comment period on
the first draft card Corporation Operable Unit X FeasibilitY StuQy. The
~::;.~o~~~:9.~.AR~~~t~~~i"~~ ~~fjca~~t~;s~a~z:~v~~.pa~.p~~;i~;c~~;~d.O
numerous letters and several petitions, most of which opposed the use of the
. Card property as a storage faci 11 ty. The Denver Ci tY Council passed a
resolution against the storage of any radioactive waste anywhere in the Denver
metro area.
So great was the public concern, that the EPA extended the pUblic comment
period to November 30 and held a public meeting on November 19, 1986. Major
concerns raised by those who attended the meeting were: impacts of cleanup
and storage on propertY values; justification for tempora~ storage; health
risks from the cleanup; risks from transporting material to the site; and
concerns that the temporary storage facility would become permanent if the
State faiJs to assure the availabilitY of a permanent disposal site.
The comment period on the second draft Card Corporation Operable Unit X
Feasibility Study was from April 27 through ~ 15, 1987. During this comment
period, the EPA held several availability sessions where concerned citizens
could speak one-on-one with EPA representatives. A second public meeting was
held on May 7, 1987. Issues raised during this meeting and the availability
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31
sessions were similar to'those expressed during the first public meeting. The
Community Relations Responsiveness Summary attached to the ROD describes in
more detail the nature and level of the community's concern and includes EPA's
response to all COmMents received during the public review of both the first
and second draft Card Corporation Operable Unit X Feasibility Study.
Future Actions
The future remedial activities that are required to com~lete remedial
action at the Card property are:
(1) Negotiate final administrative order with Mentor Corporation.
(2) Design remedial action and temporary storage facility.
(3) Enter into State Superfund Contract with State of Colorado.
(4) Conduct remedial action for contamination present on Card proper~.
(5) Determine via RODs on remaining Denver Radium Site Operable Units if
material from certain other Denver Radium Site properties will be
.temporarily stored and staged at the Card property.
(6) Select and. if necessary. design and construct permanent disposal
facil ity. (This activity,'is to be conducted by State of Colorado.)
(7) Remove contaminated material from Card property to permanent disposal
facility. .
.
(8) Decontaminate and demolish temporary storage facility and dispose of
material in a sanitary landfill.
Schedul e
Dates for completing key milestones leading to remedial action at the Card
property are highlighted below.
(1) Complete design of remedial action and temporary storage facility by April
1. 1 988
t2) Complete negotiations on administrative order with Mentor Corporation by
Au gu s t 1. 1 987
(3) Finalize State Superfund Contract with State of Colorado by April 1. 1988
(4) Initiate remedial action no later than during third quarter fiscal year
1988
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