'.
:ollection
:e Center
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPAIROO/R08.87/013
September 1987
107
.\,---~
6EPA
Superfund
Rec'ord of Decision:
rE8S-(12/'35
t
!
Denver Radium/12th.& Quivas,C'O

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EPA/ROD/R08-87/0l3
.. TITL.I A,.. 0 5UITITL.1
TECHNICAL REPORT DATA
'Pltfll~ "lflcJ /lIttlUCI/OffS 011 Iht '/Iv,", tHIeN, CO~"I/llllIfJ

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5 "'1'01'11 l' OA 1'1
SUPERFUND RECORD OF DECISION
Denver Radium/12th and Quivas, CO
Fourth Remedial Action
7 AUTMOI'II'SI
C::O,"," ?q 1 q87
e. ~E"'~O~""/\IC Ol'lCA/\I1 lA 1'10/\1 COOE
-
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19. '1I'II'Ol'll..'HQ O"'CAHIZATION I\IA"'I ANO AOO"'ISS
'0. ''''OCAA'' I~U"IN.1' "0
12. S'OHSOI'II'NC ACINCY NA"" AI\IO AOOl'll15S
I" <;;ONTI'IIAc;T/Cil'llANT NO

. i .
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
Agency
13. TY'! 0' ""'O"'T 4NO '1""00 CO\lE~EO

!<';n~l p()n QO,",l"}rt-
,.. S'ONSOI'II'NC ACINCY COOl
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800/00
15. 5U"L.E"INTAlilY NOTIS
. .
'.. AUT"'ACT
The Denver Radium site, located in Denver, Colorado, consists of more than 40
contaminated properties. These properties have been grouped into eleven operable
units. This operable unit consists of five Denver Radium site properties which are
known collectively as the 12th and Quivas properties., The 12th and QUlvas property SitE
consists of approximately 8.1 acres in an industria~ use area. In 1979 EPA noted a
reference to the National Radium Institute (NRI) in a 1916 U.S. Bureau of Mines report.
This reference revealed the presence of 31 radioactive sites in the. Denver Metropolitan
area. In 1913 the NRI was established in Denver as a domestic source of radium which
was in high demand as a wonder drug for the treatment of cancer. SUbsequently the
Denver radium, vanadium and uranium industry thrived until the early 1920s, when rich
deposits of ore were discovered in Africa. The Pittsburgh Radium Company (PRC), a
division of the National Vanadium Products Company, refined ore on Quivas Street until
1924 and is considered the source of contamination on the five 12th and Quivas
properties. There is no serious public health risk at present from radium and its
associated decay products. However, since radium has a half-life of 1,600 years, there
is a long-term potential for increased public health risk if the contaminated media and
debris were to be misused or inadvertently spread. The primary contaminants of concern
affecting approximately 11,000 yd3 of soil is radium and its associated. decay products.
(See Attachpd c::hool-\
17.
..
OIlC".'TOIII,
1(1 Y WOIII08 AHO OOC"'W'HT AHAL. .,.".
b.IOIHTI"II'III/O'IN 11\1010 TE"'''''
C. CO'A TI F.eldJCiroup
Record of Decision
Denver Radium/12th and Quivas, CO
Fourth Remedial Action
Contaminated Media: soil, air, debris
Key contaminants: radium and associated
products
II. 015TI'IIIIUTION STATIMINT
deccy
,.. 51Culll' TY CL....SS I nU4 Ihpor"
2' /\10. o~ PACIS
40
I
20. SICUI'IIITY CL.ASS InUlplI~1
22 IOI'IIIC!
I'. ,- 2nO-1 (I... '-711
"".""0"" .0.1"0" '. Q.'O~.1'.
-'.'.-.-

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EPA/ROD/R08-87/0l3
Denver Radium/12th and Quivas, CO
Fourth Remedial Action
16.
ABSTRACT (continued)
The selected remedial action for this site includes: capping open areas of soil
contamination (7,600 yd3); excavation of contaminated soil lying under structures on
the properties (3,400 yd3) and placing this material into an onsite temporary storage
facility; maintenance of the cap and temporary storage facility until a facility
suitable for the permanent disposal of Denver Radium site waste becomes available; and
final offsite disposal of the contaminated material to a permanent disposal facility.
The estimated present worth cost for this remedial action is $3,702,800 with 5-year O&M
of $290,000.

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DECLARATION
FOR THE
RECORD OF DECISION
Site Name
12th and Quivas. Properties
Operable Unit I
Denver Radium Site
Site Location
West 12th Avenue and Quivas Street
Denver, Colorado
Statement of Purpose
This decision document presents the .s~lected remedial action'
for this operable unit of the Denver Radium'Site developed in
accordance with the Comprehensive Environm~ntal Response,
Compensation, and ~iability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and the National Contingency Plan (40 CFR fart ~OO).
, .
The State of Colorado has concurred on the selected remedy
for this operable unit. (See attached letter.)
Statement of Basis
This decision is based upon the administrative record for
the 12th and Quivas properties, Operable Unit I of 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 the Selected Remedy
This Record of Decision addresses the contamination present
on what is known as .the 12th and Quivas properties, Operable
Unit I of the Denver Radium Site. This is the fourth operable
unit of the Denver Radium Site for which EPA has selected a
remedy. The EPA is una~rtaking additional feasibility: studies to
evaluate remedial action alternat~ves at the other Denver Radium
. .

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Site operable units and will complete a Reco~d of Decision or 'an
Action Memorandum for each of the op~rable units for which a
remedy has not already been selected.

Radium and its associated decay products are the hazardous
substances of primary ccncern that have been released and .
continue to be released into the environment at the 12th and
Quivas properties. Lonq-term exposure to radium and its decay
products has been shown conclusively to increase the risk of
contractinq lunq cancer.
~
EPA's preferred remedial action alternative for the 12th and
Quivas properties is Offsite Permanent Disposal. . However, until
a facility suitable for permanent disposal of the 12th and Quivas
properties material is desiqnated and, if necessary, acquired and'
developed, this alternative cannot be implemented. Pursuan~ to
CERCLA Section 104(c)(3)(C)(~i), it is the responsibility of the.
State of Colorado to assure the availability o~ a facility for
offsite disposal of the Denver Radium Site material. Althouqh
both the EPA and State of Colorado are continuinq to seek a
permanent disposal site, the State estimates that this process.
co~ld take up to five years. Given the lenqth of time which may
pass before the State a~sures the availability of an offsite
permanent disposal facility, and in order to prevent or minimize
the threat to public health and the environment, the EPA has
determined that a remedial action alternative which includes-
temporary response actions should be implemented at the 12th and
Quivas properties. .
The selected remedy for the 12th and Quivas properties is
Onsite Temporary Containment (Capping), Offsite Permanent
Disposal. This remedial action alternative will attain a degree
of cleanup of the hazardous substances which will assure both
short-term and long-term protection of human health and the
environment. The present-worth cost of this alternative is
$3,702,800 based upon a ten~percent interest rate, a five-year
discount period, and a perpetual monitoring period. This remedy
entails: '.
placing a cap over the identified open areas of soil
contamination;
excavating the contaminated .soil lying under several
structures on the properties and placing this material
. into a temporary storage facility onsite; .
maintaining the cap and temporary storage facility
until a facility suitable for the permanent disposal of
Denv~r Radium Site wastes becomes available; and
final removal of the contaminated material to the
permanent disposal facility.
Remedial DeSign for the..12th and Quivas properties will
include tbe selected remedy described above and EPA's preferred
,
\

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3
remedial action alternati~e, Offsite Permanent Disposal. Should
the State of Colorado fulfill its obligation to assure the
availability of a suitable disposal facility for material from
the Denver Radium Site by the time EPA has concluded Remedial
. 'Design for the 12th.and Quivas properties, the EPA may
immediately implement its preferred alternative, Offsite "
Permanent Disposal. -

Operation and maintenance activities will be required to
ensure the effectiveness of the temporary response actions.
These activities include site inspections, ongoing radiological
monitoring, and possible minor repairs to the cap or temporary
storage facility. Also included as an operation and maint~~nance
activity is a review of the properties which, pursuant to SARA
Section 121(c), must be conducted no less than every five years
if a remedial action is selected that results in any hazardous
substances remaining onsite. Since EPA does not anticipate that
any hazardous substances will remain onsite longer than five
years, the cost of this ,review is considered a contingency. .The
maximum total of the discounted annual operation and maintenance
costs of these activities using a five-year discount period and a
ten-percent discount rate is $290,000; This operation and
maintenance cost is included with the present-worth total'
alternative cost mentioned above.
Declarations
Consistent with the Comprehensive Environmental Response,
Compensation, and Liability 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), I have
determined that the selected remedy for the 12th and Quivas
properties, Operable Unit I of the Denver Radium Site, is
protective of human health and the environment, attains Federal
and State public health and environmental requirements that are
applicable or relevant and appropriate, and is cost-effective.
The remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable. Even though the
selected remedy does not satisfy the statutory preference for
treatment which reduces the toxicity, mobility, and volume of
hazardous substances as its principal element, the remedy will
address the principal threat at the properties. Treatment was
determined to be impracticable based upon effectiveness,
technical feasibility, im~lementability, and cost.
~Qu..
/
Ja es J. Scherer
Regional Administrator
EPA Region VIII.
Jy.~f
I (

Date
O'r?

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RECORD OF DECISION
SUMMARY
Site Name
12th and Quivas Properties
Operable Unit I
Denver Radium Site
o
Site History
When radium was discovered in 1898, it was considered to be
a wonder drug and was used especially in the treatment of cancer. "
.This caused the demand for r~dium to escalate, setting in motion
the radium boom of the early 1900s. Radium was first found in
pitchblende, a rare mineral found in Bohemia, Saxony, Cornwall,
and Colorado." Soon after these discoveri~s, another radium-
bearing mineral, carnotite, was discovered in Colorado.
Prior to 1914, radium was not produced in the United States.
Rather, radium-bearing ore was shipped from the States to Europe
where it was refined. The onset of World War' I in "Europe caused
concern in the United States that radium importation might be
blocked. This concern led to the establishment of the National
Radium Institute in Denver in 1913. The National Radium
Institute successfully demonstrated that radium could be
extracted from carnotite. Soon several radium, vanadium, and
uranium processors were operating in Denver. The Denver r~dium,
vanadium, and ura~ium industry thrived until the early 1920s,
when extremely rich deposits of ore were discovered in Africa.
Most Denver producers could not keep up with their African
competitors and were forced out of business.
The Pittsburgh Radium Company, a division of the National
Vanadium Products Company, refined ore at 1201 Quivas Street
until 1924. This property is currently part of the 12~h and
Quivas properties, Operable Unit I of the Denver Radium Site.
The source of the contamination on the 12th and Quivas properties
is believed to be the result of Pittsburgh Radium Company.
operations. .
Response History
In 1979, EPA noted a reference to the National Radium
Institute in a 1916 United States Bureau of Mines report.
Subsequent field research revealed the presence of thirty-one
radioactive sites in the Denver metropolitan area, of which four
are now included with the 12th and Quivas properties (Figure 1).

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Immediately after identifying these properties, the
Radiation Control 'Division of the Colorado Department of Health
officially notified the affected property owners of the presence
of radiological contamination on their properties. The letters.
requested that no excavation or soil movement be undertaken
without first contac~in9 the Division. '

In August, 1981, the Colorado Department of Health, under a
cooperative agreement with EPA, assumed lead activities and'
initiated engineering assessments of the majority of tha original
31 properties. In October, 1981, shortly 'after the cooperative
agreement was awarded to' the State, the Denver Radium Site was
placed on the Interim Priorities List. The Site was included on
the Final National Priorities List promulgated on September 8,
1983.
EPA resumed Fund-lead activities in June, 1983, because the
Colorado State Legislature failed to appropriate the state cost
share for remedial planning required by EPA at the time. In
December, 1983, EPA directed its contractor to conduct a Remedial
Investigation (RI) to determine the, nature and extent of the
contamination present on those properties which the State did not
Pr.eviously study plus several contiguous properties where
additional contamination was suspected. EPA also directed its
contractor to conduct a Feasibility Study (FS) to evaluate
proposed remedies for the contamination present on all of the
Denver Radium Site properties which now, with the addition of the
contiguous properties, totaled over 40 properties.
Because of the enormity and complexity of the Denve~ Radium
Site, EPA determined that response actions undertaken in operable
units would be cost-effective and consistent with a permanent
. remedy for the entire Denver Radium Site. Thus, the origin~l
Denver Radium Site properties plus the several contiguous
properties where contamination was discovered subsequent to the
initial listing of the Site on the Interim Priorities List were
divided into eleven operable units, the 12th and Quivas "
properties being Operable Unit I. The'properties were divided
based primarily upon site conditions and proximity to other
Denver Radium Site properties.
, In April, 1986, the Denver'Radium Site Remedial
Investigation Report, which addresses all eleven operable units,
was finalized. The draft Operable Unit I FS was released for
public review on August 3, 1987. Responses.to comments received
during the public comment period are contained in" the
Responsiveness Summary attached to this Record of Decision. The
final Operable Unit I FS is comprised of the draft Operable Unit
' I FS incorporating the changes described in the errata. Pursuant
to SARA Section 104(i), the draft Operable. Unit I FS was
submitted for review by the Agency for Toxic Substances and
Disease Registry (ATSDR). At the signing of this ROD, ATSDR had
not formally responded. However, preliminary discussions with
ATSDR indicated that ,ATSDR ,had no'major criticisms of the report.

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4
Site Location and Description
The -Denver Radium Site, located in Denver, Colorado
(population 509,000), consists of more than 40 contaminated
properties. T~ese properties' have been grouped into ope~able
units. Operable Unit. I consists of the following Denver Radium
Site properties, also known collectively as the 12th and Quivas
properties:
B&C Metal Products
- Erickson Monuments
- Materials Handling Equipment Company
Rudd Investments
- Denver and Rio Grande Western ~ailroad
(DRGRR)
. The 12th and QUivas properties are located in the Platte
River Valley but are not within the designated 100-year flood
p+ain. The properties are. underlain by fill material, alluvium,
and the Denver formation sandstone. Depth to ground water is
14 feet and depth to bedrock is 16 feet. The topography of the
of the site is predominately flat, however, a north-south ridge
of approximately ten feet in height runs along the eastern
portion of the site. There is no surface water on the 12th and.
Quivas properties; however, Occupants of some of the properties
report that storm water drainage in the area can be a problem at
times. The climate of the area is typified by low annual
precipitation, averaging about 14 inches per year.
The 12th and Quivas properties are located in an area of
Denver currently zoned I-1 for industrial use. The properties
. cover approximately 8.1 acres and are bounded on the east by
Qu~vas Street, on the north by West 13th Avenue, on the west by
Shoshone Street, and on the south by West 12th Avenue (Figure 2).
There are buried municipal utilities with~n these boundaries.
B&C Metal Products is located at 1623 West 12th Avenue. The
property is sparsely vegetated with weeds and trees. The only
structures on the property are a two-story stone and brick
building with a basement and a storage shed. The building is
Occupied by 12 people approximately 40 hours per week. The
building covers 20,700 square feet of the 33,100-square-foot lot
owned by B&C Metal Products.
. .
The Erickson Monuments property, located at 1241 Quivas
Street, covers approximately 29,800 square feet. A railroad spur
cuts diagonally across the property. Sandblasting grit and waste
granite, mixed with fill material, has been regraded to create an
area on the northern end of the property which is three to five
feet higher in elevation than the surrounding property. Spent
silicon carbide sandblasting grit has been scattered over the
entire property. B6th finished and unfinished monuments have
ceen placed over a large portion of the property. There are two
connecting, single-story buildings on the property. One is made
of frame and steel and the other is a small brick building. Six
people work at the property approximately 40 hours per week. .

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6
The Materials Handling property is the largest of the 12th
and Quivas properties, occupying 5.4 acres at 1740 West 13th
Avenue. The company employs 65 people 40 .hours per week. These
people work in a single brick and concrete building on the.
property. .

The Rudd Investments property is located at 1229 Quivas
Street. A brick building on the property is occupied by 16 to 18
people between 40. and 50 hours per week. The west part of the
property is an asphalt-paved, fenced; storage area which contains
one sheet-metal storage shed.
The DRGRR property is a road easement that was once used for
railroad access. With time and disuse, the tracks have become
covered with dirt and are only visible in certain areas.
Current Site Status
Radium and its associated decay products are the primary
contaminants of concern at the 12th and Quivas properties. Since
gamma radiation readings in excess of background may indicate the
presence of radium, a gamma radiation survey was used to outline
the extent of possible radium contamination on the 12th and
Quivas properties (Shaded areas of Figure 2). Gamma radiation
readings in excess of background were found over 95,50~ square
feet of the properties including areas inside several buildings.
Average gamma radiation measurements ranged from 2 microroentgen
per hour (~R/hr) to 50 ~R/hr above background. The maximum gamma
radiation. measurement was 510 pR/hr above background. (A general
discussion of radiation and its associated units of measurement
is presented "in Appendix A of the Operable Unit I FS and in the
Puplic Health and Environmental Assessment, Appendix B of the
Operable Unit I FS.)
. The presence of radium in the soil and underneath the
buildings was verified by radiochemical analysis ~f subsurface
soil samples. The volume-weighted average radium concentration
in the contaminated soils on the 12th and Quivas properties was
determined to be 108 picocuries per gram (pCi/g). The maximum
radium concentration found on the properties was 1,920 pCi/g.
Radium contamination was found to a maximum depth of 132 inches
from the surface. The estimated total volume of radium-
contaminated soil on the 12th and QUivas properties is 11,000
cubic yards of which over 3,000 cubic yards lie under structures.
Table 1 summarizes the gamma radiation and radium concentration
data collected on the 12th arid Quivas properties~
The B&C Metal Products, the Materials Handling, and the Rudd
. Investments buildings on the 12th and Quivas properties contained
elevated radon decay product concentrations resulting from the
radium contamination on the properties. During a 1984 EPA
investigation, a radon decay product concentration of
.0.135 working level (WL) -was detected in the east end of the B&C
. Metal Products bui.lding basement. In .response, EPA installed a

-------
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-------
8
.
vented-plenum wall in the basement. After installation of this
wall, the radon decay product concentration in the B&C Metal
Products bui~ding dropped to 0.058 WL. The maximum radon decay
product concentration measured in the Materials Handling building
was 0.0512 WL and the maximum concentration measured in the Rudd
Investments building was 0.180 WL. Although these levels'exceed
the limits allowed by EPA standards for radon, further emergency
response actions were not taken at the 12th and Quivas properties
because the patterns of occupancy and the concentrations of radon
'decay products present during periods of occupancy reduced the
likelihood of significant long-term exposure. The complete set
of radon decay product concentration data collected for the 12th
and Quivas properties is presented in Table 2-2 in the Operable
Unit I FS.
The radium concentrations, the gamma radiation levels~ and
the radon decay product concentrations found on the 12th and
Quivas properties exceed the "EPA Standards for Remedial Act~ons
at Inactive Uranium Processing Sites," 40 CFR Part 192, which EPA
has determined are relevant and appropriate Federal requirements
for the 12th and Quivas properties. These standards are
discussed later in this summary in the section entitled
"Statu~ory Determinations".
The elevated concentration of radium at the 12th and Quivas
properties poses a health hazard due to three principal 'PQtential
exposure pathways. In order of decreasing significance, they
are,: . (1) inhalation of radon gas, which is 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 ihat i~
relatively insoluble, and since migration of radiological
contaminants into the ground water has not been noted, ingestion
or contact with contaminated ground water is not one of the
principal potential ex~osure pathways. Each of the three
principal exposure routes will be discussed briefly in terms of
the potential health rjsks associated with each exposure route.
Inhalation of Radon Decay Products:

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 typically electrostatically
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 the
high~y ioniz~ng sub-atomic particles which the ,radon decay
products emit. Prolonged inhalation of air with a high
concentration of radon decay products has been conclusively shown
to cause increased ,occurrence of IUE9_cancer in uranium miners.
Dispersion quickly dilutes radon emanating from radium-
contaminated ground. ~his mechanism will minimize the radon
concentration in the air above the open areas of the 12th and

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-
" 9
Quivas properties to such an extent that no one working on or
living.near the properties is presently at risk from exposure to
radon and its associated decay products from this source. Radon
decay products can concentrat. to unacceptable-~evels in
buildings built over contaminated ground if those buildings are
energy efficient, tbat is, they have little exchange of indoor
air with outdoor air. 'Three bUildings on the 12th and Quivas
properties' exhibit concentrations of radon decay products'
exceeding the relevant and appropriate EPA standard. The current
risks associated with these elevated radon decay product
concentrations are believed to be small compared with possible
future risks for the following reasons. First, the duration of
exposure is limited due to the fact that people work there rather
than live there. Second, d~ring the times that people are
working there, radon levels, and consequently exposures to radon,
ar~ reduced because the air exchange rate with the outdoo~s
increases when people are entering and leaving the building,
loading bays are standing open, etc.
Although the present public health risk from radon decay
product exposure at the 12th and Quivas properties is
comparatively minor for the reasons stated above, EPA has
determined that a significant increase in public health risk
would occur if (1) any of the contaminated material on the
properties ~s spread closer to potential receptors, especially if
it is used as fill or construction material, or (2) if any of the
buildings on the 12th and Quivas properties are sealed to make
them more airtight, or (3) if the properties are_ever ,redeveloped
for any use that involves occupancy in enclosed, energy efficient
structures. The Public Health arid Environmental Assessment for
the 12th and QUivas properties summarized below and contained in
Appendix B of the Operable Unit I FS presents projected cancer'
risks if EPA were to take no action at the properties and the
properties were redeveloped in any of these ways.
, If a building were constructed over Area I (See Figure 2),
the most contaminated area on the 12th and Quivas properties,
iepresenting about 19% of the estimated total volume of
contamination on the properties, and several conservative
assumptions are made (such as lifetime exposure), the estimated
radon decay product concentration in the building would average
1.54 WL with an estimated maximum concentration of 11.5 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 average projected cancer risk
(excluding background) to individuals working in such a building
range~ from 1,500 to, 4,300 cancer deaths per. 10,000 persons
exposed. The.. average projected cancer risk to individuals living
in such a building ranges from 4,800 to 7,800 cancer deaths per
10,000 persons exposed. "
These risk values can be compared to the average projected
cancer risk if tne radon de~ay product concentration in the
building was 0.02 WL, the EPA standard. In'this case, the
projected cancer r~sk to' ~ndividuals working 'in such a building
,
\

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1 °
ranges from 23 to 91 cancer deaths per 1.0,000 persons exposed.
The average projected cancer risk to individuals living in such a
building ranges from 130 to 500 cancer deaths per 10,000 persons
exposed. If the radon decay product concentration in the
building was .t.hat of a typical U.S'. home, 0.005 WL, then the
projected cancer risk. to individual~ living in the building would
range from 33 to 130 cancer deaths per 10,000 persons exposed.
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 information stated above.
Gamma Radiation Exposure:
The radioactive decay of radium and its decay products
results in the emission of highly penetrating gamma radiation.
Gamma radiation is of concern because it can easily penetrate a
few centimeters of soil to give. anyone standing over a
contaminated area a reasonably unitorm 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. In the case of the 12th and Quivas properties,
the gamma radiation- emission is limited to the area immediately
above the contamination.
As discussed previously, EPA has determined that a
significant increase in public health risk would result if any of
the contaminated material on the 12th and Quivas properties was
disturbed and misused or if the area was redeveloped. If a
building was constructed over Area 0 (See Figure 2), the largest
area of contamination on the 12th and Quivas properties
representing about 19% of the estimated total area of
contamination on the properties, the estimated annual dose to a
person working in the building would average 58 millirem per year
(mrem/yr) with an estimated maximum annual dose of 543 mrem/yr.
The estimated annual dose to a person living in a building built
over Area 0 would average 191 mrem/yr with an estimated maximum
annual dose of 1770 mrem/yr. These doses are in addition to the
background dose of 130 mrem/yr incurred by those living in the
Denver area and resulting from cosmic, terrestrial, and internal
sources. The National Council on Radiation Protection and
Measurements (NCRP) and the International Commission on .
Radiological Protection (ICRP) recommend a maximum allowable
whole-body gamma radiation dose of 100 mrem/yr for members Qf the
public in addition to natural background ~adiation and medical
exposures they receive.

The projected cancer risk from gamma radiation (including
background) to individuals working in a building built over
Area 0 would average 29 cancer deaths per 10,000 persons exposed.
The projected cancer risk to individuals living in the building
would average 39 cancer deaths per 10,000 persons exposed. If
individuals in 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

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Scenario
Radon Decay Product5:
Bui1ding"COn5tructed
over Area I
EPA Standard*
Typical U.S. Home
Gamma Rad i at i on:
Building con5tructed
over Area 0
EPA Standard*
Background
11
Table 2
PROJECTED CANCER RISKS
OPERABLE UN IT I
DENVER RADIUM SITE
Exp05ure
Average Cancer Deaths
Per 10,000 Persons Exposed
1. 54 WL Workp1 ace 1500 to 4300
 Residential 4800 to 7800
0.02 WL Workplace 23 to 91
 Residential 130 to SOp
0.005 WL Residential 33 to 130
29 )JR/hr Work place 29**
 Residential 39**
20 )JR/hr Workplace 31** .
 Residential 53**
15 .uR/hr Res-i dent i a 1 27
* 40 CFR Part 192
** In addition to risk fr"om exposure to background gaIJ1ma radiation levels.

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12
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 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
. inhala~ion of radon decay products. Table 2 presents the
information stated above.
Inhalation or Ingestion of Radium-Contaminated Material:
Inhalation ~f the long~lived radionuclides like uranium,
thorium, and radium is possible for persons living or working on
or near the 12th and Qui~as properties. Airborne particulate
matter may contain small concentration~ of these radionuclides
. resulting in a potential human exposure pathway. Direct
ingestion of long-lived radionuclides is another potential human'
exposure pathway which can result in significant doses to various
internal organs of the body. However, studies by the United
States Department of Energy have shown that the projected.
radiation do~es from these sources are many times smaller than
those estimated for either radon decay product inhalation or
direct gamma radiation exposure using even the most conservative
assumptions. Also, it is unlikely that a person would ingest
large amounts of the radium-contaminated material on the 12th and
Quivas properties and dust control measures ordinarily employed
during excavation have been shown to provide sufficient control
of. exposure from inhalation of radium-contaminated material. For
these reasons, EPA acknowledges these human exposure pathways,
but no quantitative risk numbers were developed in the Public
Health and Environmental Assessment for the 12th and Quivas
properties.
It is clear that a release or substa~tial threat of release
of a hazardous substance or pollutant or cont~minant into the
environment has occurred at the 12th and Quivas properties and
the release or threat of release may present an imminent and
substantial endangerment to public health. It is also clear from
the calculated risks that remedial action at the 12th and Quivas
properties is justified.
. Enforcement
A detailed responsible party search for the entire Denver
Radium Site has been initiated. Regarding the 12th and Quivas
properties, records show that Pittsburgh Radium Company operated
a processing facility at this location at the time of apparent
disposal of ore processing wastes containing, among other
contaminants, radium, the hazardous substance of concern.
Although extensive investigation has been conducted, the
responsible party search has yet to trace th~ Pittsburgh Radium

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~
13
Company to a viable, present-day company. At this point, the
responsible party search has not revealed that the present owners
of the 12th and Quivas properties have any record of having been
connected with the activities that caused the site to be
radiologically contaminated.
. EPA does not feel that response actions should be delayed
pending. finalization of the responsible party search. Upon
finalization of. the search, the status of responsible parties
will be determined and evaluated and, if appropriate, EPA will
formally notify them of the selected remedy for the 12th and
Quivas properties and initiate negotiations for the
-implementation of the remedy. If the .responsible parties do not
formally commit to performing the remedy in a timely manner, EPA
will proceed with a Fund-financed remedial design ~nd remedial
action and will attempt to recover EPA's response costs from the
responsible parties.
. .
Community Relations History

On August 1, 1987, and again on August 2, 1987, the Proposed
Plan for the 12th" and Quivas properties was published in both the
Rocky Mountain News and the Denver Post. The ~isplay ads
announced the August 3 through 21, 1987 public comment period and
the August 12 public meeting, gave a brief description of the
'remedial action alternatives, and stated the rationale for the
Proposed Plan. The display ads also included a statement
asserting the State of Colorado's support of the Proposed Plan.
In addition to publishing the Proposed Plan, EPA issued a
press release announcing the public comment period. The press
release, along with the Executive Summary of the Operable Unit I
FS, was mailed to the approximately 300 names on the EPA-
compiled Denver Radium Site mailing list.
On July 10, 1987, EPA met with the owners and tenants of the
12th and Quivas properties. The owners and tenants who attended
the meeting expressed concern about adverse publicity which they
might receive resulting from any press coverage of EPA's Proposed
Plan. They also were interested in the details of the remedial
action phase, in particular, how remedial action would affect
their business operations. On August 12, 1987, EPA held a public
meeting concerning the 12th and Quivas properties. Major
concerns raised by those who attended the meeting were how' the
remedial action at the properties would affect the business
operations of the owners and tenants and the liability of the
owners and tenants.
In general, the public supports the complete excavation and
permanent offsite disposal of all Denver Radium Site material
including the contaminated material present on the 12th and
Quivas properties. The community has reservations about any
temporary response action .which EPA may take because of concerns
that the State of Colorado will not make available a permanent

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14
disposal site for this material and, therefore, no permanent
measures will ever be implemented at the properties. The portion
of the community in the vicinity of the Card Corporation property
(See Figure 1) ~trongly opposes temporary storage at the Card.
.Corporation property, Operable U~it X of the Denver Radium Site,
again because of concerns that the State of Colorado will.not
make available a permanent disposal site and that the temporary
storage facility on the Card Corporation property will become
permanent, resulting in a decrease in property values in the
area.
The Responsiveness Summary attached to the ROD contains the
official transcript of the public meeting, describes in more.
detail the nature 'and level of the community's concern, and
includes EPA's responses to all comments received during the
public review of the Operable Unit I FS.
Alternatives Evaluation
EPA evaluated potential remedial action alternatives for the
12th and Quivas properties primarily by progressing through the
series of analyses which are, outlined in the National Contingency
Plan (NCP), in particular, 40 CFR Section 300.68; the Interim
Guidance o~ Superfund Selection of Remedy, December 24, 1986,
(OSWER Directive No. 9355.0-19); and the Additional Interim
Guidance for FY '87 Records of Decision, July 24, 1987, (OSWER
Directive No. 9355.0-21). This process, in part, enables EPA to
address the SARA Section 12,1 requirements of selecting a remedial
action that is protective of human health and the environment,
that is cost-effective, that attains Federal and State public
health and environmental requirements that are ~pplicable or
relevant and appropriate, and that utilizes permanent solutions
and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Additionally,
SARA Section 121 and the guidance documents referenced above
require EPA to give preference ~o remedies which employ treatment
which permanently and significantly reduces the toxicity,
mobility, or volume of hazardous substances as their p~incipal
-element.
The selection of remedy process begins by identifying
certain site-specific information to be assessed in determining
the types of response actions that will be considered for the
site. A general list of site-specific information to be
considered in this process is contained in Section 300.68(e)(2)
of the NCP. This list was used to identify specific site and
waste characteristics of the 12th and Quivas properties. (See
Table 5-1 of the Operable Unit I FS.) Based upon these site and
waste characteristics" EPA was able to scope, from the universe
of all possible. response actions, a set of response actions and
associated technologies to be considered for the 12th and Quivas
properties. An example of this scoping process was the
eLiminatipn of the use of sedimentation basins from further
considerat~on because surface water contamination is not a

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15
characteristic of the 12th and Quivas properties. Appendix D of
the Operable Unit I FS illustrates the scoping process and
Table 5-2 of the Operable Unit I FS details the results.

Section 121{b){1) of SARA requires that an assessment of
permanent solutions ~nd 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 be conducted. As part of this process, EPA evalu~ted
permanent solut~ons to the problems associated with "the specific
hazardous substances present on the 12t~ and Quivas .properties.
The alternative treatment and resource recovery technologies
considered included, among others, in-situ vitrification and
reprocessing.
. Before the technologies were assembled into remedial action
alternatives, they were categorized as either source control or
management-of-migration measures and then pre screened based on
their suitability to abate the threat at the 12th and Quivas
properties. Source control measures are intended to contain the
hazardous substances onsite or eliminate the potentia) for
contamination altogether by transporting the hazardous substances
to a safer location. Management-of-migration actions are taken
to minimize or mitigate the migration of hazardous substances.
The result of the prescreening of bo~h source control and
management-of-migration measures based on their suitability to
abate the threat at the 12th and Quivas properties is presented
in Table 5-3 of the' Operable Unit I FS.
The next step of the selection of remedy process is
assembling the remaining technologies and/or disposal options
into remedial action alternatives. Pursuant to OSWER Directive
No. 9355.0-19, "Interim Guidance on Superfund Selection of
Remedy", remedial action alternatives are to be developed 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. Remedial action alternatives developed
in this way will vary mainly in the degree to which they rely on
long-term management of treatment residuals or low-concentration
wastes. further, a containment option involving little or no
treatment and a no-action alternative are to be developed'.
Remedial action alternatives developed in the Oper~ble Unit I FS
for the 12th and Quivas properties were:
1 .
No Action
2.
Deferreq Removal, Offsite Permanent Disposal

Onsite Reprocessing/Treatment,' Offsite
Permanent Disposal
3 .
4.
In-Situ Vitrification
-'.-._.-

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1 0 .
16
5.
6.
Onsite Permanent Disposal
Offsite Permanent Disposal
7.
Onsite Temporary Land Storage, Offsite
Permanent Disposal
8.
Onsite Temporary Building Storage, Offsite
Permanent Disposal

Onsite Temporary Containment (Cappingt,
Offsite Permanent Disposal
9.
Temporary Building Storage at the Card
Corporation Property (OU X), Offsite
Permanent Disposal
Alternatives 2, 3, 6, .7, 8, 9, and 10, since they require
the permanent offsite disposal of contaminated material, would
eliminate the need for long-term management (including
monitoring) at the 12th and Quivas properties. Alternatives 3
and 4 involve treatment as their principal element, but do not
necessarily reduce the mobility, toxicity, or volume of the
waste. Alternatives 4 and 5 require permanent onsite remedies,
. and hence, long-term management and monitoring at the 12th and
Quivas properties. Alternatives 5, 7, 8, and 9 are containment
options - Alternative 5 requiring permanent onsite containment
and Alternatives 7, 8, and 9 requiring temporary onsite
containment. Finally, No Action was included as Alternative 1.
Alternative 6, Offsite ~ermanent Disposal, is not
immediately implementable because the State of Co~orado has not
at this time designated a facility for the disposal of the Denver
Radium Site wastes. Pursuant to CERCLA Section 104(c)(3)(C)(ii),
it is the responsibility of the State to assure the availability
of a disposal site. Also, in order to comply with SARA Section -
104(k), and in. order to assure that remedial actions within
Colorado continue, the State must provide adequate assurance of
the availability of a hazardous waste treatment or disposal
facility within three years from the effective date of SARA,
October 17, 1986. Although progress is being made to this end,
the St~te does not expect to have a fully operational d~sposal
facility prior to implementation of any remedial action and
possibly for up to five years. In the meantime, in its presently
uncontrolled state, the radium-contaminated material at the 12th
and Quivas properties could be misused or inadvertently spread,
possibly increasing the risk to present or future public health.
or the environment. In addition, the cost of final remedial
action is expected to increase due to. inflation; the 12th and
Quivas property owners and tenants face economic losses
associated with restricted use of their properties; and EPA may
incur further cost by.updating site studies in face of changing
site conditions. For the~e reasons, EPA determined that in order
/'
to effectively mitigate or minimize short-term threats to and
provide adequate protection of public health and the environment

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17
at ~he 12th and Quivas properties developing remedial action
alternatives which incl~de temporary response actions was
appropriate. Thus, Alternatives 7, 8, 9, and 10 were developed
to reduce existing ,risks by including temporary response measures
followed by permanent offsite disposal of the contaminated
material when afac~lity for such disposal becomes availa~le.
Initial screening, which is the next step in the selection
of remedy process, narrows the list of potential remedial action
alternatives. Consistent with Section 300.68(g) of the NCP and
the OSWER Directive 9355.0-19, the remedial action alternatives
developed for the 12th and Quivas properties were ini t-ially
screened using the criteria of cost, implementability (acceptable
engineering practices), and effectiveness. Table 7-1 in the
Operable Unit I FS summarizes the initial screening process.
Alternatives 1, 2, 7, 8, 9, and 10 passed the initial screening
and were carried forward for detailed analysis, while
Alternatives 3, 4, 5, and 6 were .creened"out primarily for the-
reasons set forth below. -
Alternative 3, Onsite Reprocessing, was eliminated from.
further consideration based on its lack of effectiveness. The
residuals from this process, 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. These residuals would retain
many of the toxicity and mobility characteristics of the
untreated material and, in addition, th~ volume would not be
significantly affected. This remedial action alternative would
provide no additional benef~t to public health or the environment
over othe-r remedial action al terna~i ves ,to be .conside'red.

Alternative 4, In-Situ Vitrificatioh, was eliminated during
the initial screening because its implementability and
effectiveness 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 12th
and Quivas properties. The extreme temperature require~ents of
this process could cause unknown damage to onsite structures and
buried utilities and tanks. Once vitrified, a cap over the area
would be necessary to limit the escape of radon gas; thus, this
alternative does not affect toxicity or persistence of the
contaminated material. Furthermore, the property would have to
be permanentl~ 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 remedial action
alternative would require long~term government ownership,
licensing, management, and monitoring to protect the integrity of
the cap and the vitrified mass. These requisites would conflict
with current and proposed land uses for the area, as well as
State policies on siting permanent disposal facilities,
(6'CCR 1007-1, Part-I~~, Schedule 'E, Criterion 1). The State
siting objectives specify, among other things~ that permanent
disposal facilities must be located away from populated areas and
that hydrogeologic and other en~ironmental conditions be
" .

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J8
conducive to continued immobilization and isolation of
contaminants from usable ground water sources. These criteria
are clearly not met at the 12th and Quivas properties which are
located within a metropolitan area, and where the' depth to ground
water is only 10 to 15 feet.

With th. elimination of ,these two remedial action
alternatives, no remedial action alternative which involves
treatment as a principal element survives the initial screening.
However, EPA has no reasonable belief that either of these
remedial action alternatives is equally protective as other
remedial action alternatives being considered, or offers the
potential for better treatment performance or implementability,
lesser adverse impacts, or lower costs than demonstrated remedial
action alternatives.
Alternative 5, Onsite Permanent Disposal, was eliminated
from further consider~tion Qecause 'of implementability and
effectiveness factors. The property would h~ve to be permanently
dedicated as a disposal site and measures would have to be taken
to isolate the contaminated material from man and the environment
for a thousand years without ongoing active maintenance. This
objective would be difficult to attain in an urban area where
there is a hig~ potential for human disturbance and in an area
where the ground water is fairly close to the surface as it is on
the 12th and Quivas properties. This remedial action alternative
would require long-term government ownership, licensing, and
management and monitoring to protect the integrity of the
facility. These requisites would conflict with current and
proposed land uses for the area, as well as State policies on
siting permanent disposal facilities (6 CCR 1a07-1, Part III,
Schedule E, Criterion 1) discussed above.
Alternative 6, Offsite Permanent Disposal, is not
implementable at this time because the State of Colorado has yet
to designate a facility for the disposal of Denver Radium'Site
wastes and was therefore eliminated during initial screening.
Following is a description of the' remedial action.
alternatives surviving the initial screening.
1 .
No Action
If this remedial action alternative were selected, no
action would be taken at the contaminated 12th and
Qu~vas properties. This alternative serves as a
baseline and was retained for -further analysis and
consideration as required by Section 300.68(f)(1 )(v) of'
the NCP. ' " , '
2.
Deferred Removal, Offsite Permanent Dispo~a}_-

If this remedial action alternative were selected,
removal of the contaminated material at the 12th and
Qu~vas properties would be deferred until an approved

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.,
9.
19
. offsite permanent disposal fa~ility is identified and
made available by the State of Colorado. Once this
facility becomes available, the entire estimated 11~QOu
cubic yards of contaminated material. on the 12th and'
Quivas. properties including the contaminated material.
under the- B&C Metal Products, Materials Handling, and
Rudd Investment~ buildings would be excavated and
transported by either truck or rail for final disposal
at this facility. The 12th and Quivas properties would
then be available for unrestricted use.
7.
Onsite Temporary Land Storage, Offsite Permanent
Disposal
If this remedial action alternative were selected, the
approximately 11,000 cubic yards of contaminated
material on the 12th and Quivas properties would be
excavated and temporarily stored on the site. An
asphalt pad would be constructed in an open area of the
eastern portion of the Materials Handling property.
Contaminated material would be placed on the pad and
covered with a suitable material. Security.
precautions, inspections, and radiation monitoring of
the storage facility would be instituted. Once a
suitable offsite permanent disposal facility becomes
available, the contaminated material would be
transported by either rail or truck to the faci1ity~
The 12th and Quivas properties would then be available
for unrestricted use. .
8.
Onsite Temporary Building Storage, Offsite Permanent
Disposal
If this remedial action alternative were selected, the
approximately 11,000 cubic yards of contaminated
material on the 12th and Quivas properties would be
excavat€d and placed in containers. The con~ainers
would be temporarily stored in a newly constructed
building on the 12th and Qui vas properties. . Security
precautions, inspections, and radiation monitoring of
the storage facility would be instituted. Once a
suitable offsite permanent disposal facility becomes
available, then the contaminated material would be
transported by either rail or truck to the facility.
Upon removal of the containers, ~he building would be
decontaminated and either dismantled or left in place.
The 12th and-Qui vas properties would then be available
for unrestricted use. .
. .
Onsite Temporary Containment (Capping), Offsite
Permanent Disposal .
If this remedial action alternative were selected,' the
identified open. areas of contamination cin the 12th and
Quivas properties would be capped. Contaminated soil
,
\

-------
20
under the B&C Metal Products, Materials Handling, and
Rudd Investments buildings would be excavated and
consolidated on the eastern portion of the Materials
Handling property in a temporary storage facility.
Access restrictions 'would be required to 'limit
disturbance of the cap. Security precauti-ons,'
inspections, and radiation monitoring of the storage
facility and the cap would be instituted. Once a
suitable offsite permanent disposal facility becomes
available, the contaminated material would be
transported by either rail or truck to the facility.
The 12th and Quivas properties would then be available
for unrestricted use.
1 O.
Temporary BUilding Storage at the Card CorporatiQn
Property (OU X), Offsite Permanent Disposal
If this remedial action alternative were selected, a
portion of the contaminated material on the 12th and
Quivas properties would be excavated, placed in
containers, and the containers transported to the Card
Corporation Property (OU X) for temporary storage. The
remaining material on the 12th and Quivas properties
would be excavated and consolidated on the eastern
portion of the Materials Handling property in a
temporary storage facility. Security precautions,
inspections, and radiation monitoring of the storage
facilities on both operable units would be instituted.
. Once a suitable offsite permanent disposal facility
becomes available, the contaminated material from both
operable units would be transported by either rail or
truck to the facility. The 12th and Quivas properties,
as well as the Card Corporation property, would then be
available for unrestricted use.
Consistent with Section 300.68(h) of the NCP, the OSWER
Directive No. 9355.0-19, and the OSWER Directive No. 9355.0-21,
the remedial action alternatives remaining after initial'
~creening were further refined and then subjected to detailed
analysis. Detailed analysis of each remedial action alternative
entailed evaluation based on the three broad criteria of
implementability, effectiveness,. and cost. For each of these
broad criteria, EPA identified appropriate and more specific
"component measures" so that the remedial action alternativ~s
could be compared to each other using a full array of eval~ation
factors. The component 'measures derived for implementability,
effectiveness, and cost were based upon specific requirements and
criteria contained in Section 300.68(h)(2) of the NCP, SARA
Sections 121(b)(1 )(A through G), SARA Section 121(c), the
discussion on detailed analysis contained in the OSWER Directive
No. 9355.0-19, and the OSWER Directive No. 9355.0-21.
The component measures of implementability are: technical
feasibility, constructability, reliability, administrative

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21
concerns, availability of the technology, and operation and
maintenance. The component measures of effectiveness are
attainment of applicable or relevant and appropriate requirements
(ARARs); effectiveness in significantly and permanently reducing
mobility, toxicity, and volume; persistence, toxicity, mobility,
and propensity to bioaccumulate of the hazardous substances and.
their constituents; protectiveness/health effects; environmental
protectiveness/potential for adverse environmental impacts; and
compliance with the Solid Waste Disposal Act. The component
measures of cost are: capital cost, operation and maintenance
costs, and potential future remediation costs if the alternative
fails. Section 8 of the Operable Unit I FS provides a
comparative review of the remedial action alternatives based upon
~ach of the component measures listed above. .
Implementability Analysis:

All of the alternatives which were analyzed in detail are
technically feasible and constructable as they rely on common
earth moving and construction technologies - technologies which
are both operationally reliable and read~ly available. Although
technically feasible, Alternative 7, Onsite Temporary Land
Storage, Offsite Permanent Disposal,.and Alternative 8, Onsite
Temporary Building Storage, Offsite Permanent Disposal, are the
most difficult remedial action alternatives to implement bec~Use
of the limited space on the 12th and Quivas properties where
either a land-storage or building-storage facility could be
constructed with enough capacity to contain the entire volume of
material from the properties. The necessary equipment and.
specialists for implementation of any of the remedial action
alternatives are readily available. Remedial action work similar
to that envisioned in any of the remedial action alternatives is
already being safely conducted in Grand Junction, Colorado, under
the auspices of the United States D~partment of Energy Uranium
Mill Tailings Remedial Action Project.
No Action and Alternative 2, Deferred Removal, Offsite
Permanent Disposal, are -adm~nistratively the easiest alternatives
to implement. The need to coordinate and obtain access
agreements with the 12th and Quivas property owners and the need
to obtain necessary approvals and non-environmental construction
permits from other offices and agencies are administrative
implementation constraints common to all of the remedial action
alternatives with the exception of No Action. Alternative 10,
Temporary Building Storage at Card Corporation Property (OU X),
Offsite Permanent .Disposal, has an additional implementation
constraint, that is, an agreement with the Mentor Corporation,
current owner Of the Card Corporation property, to allow for
storage of other Denver Radium Site wastes on the Card
Corporation property must be finalized..
. All remedial action alternatives except No Action and
Alternative 2 require a limited degree of operation and
maintenance activities. .The final response action associated
with the remedial action alternatives, permanent offsite

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22
disposal, cannot be
provides a faci~ity
This implementation
action alternatives
implemented until the State of Colorado
suitable for the disposal of this material.
constraint is common to all of the remedi~l
~xcept No Action.
Effectiveness Analysis:

'Alternatives 7, a, and 10 will meet contaminant-specific
ARARs for radium levels in site soils once the temporary response
actions are completed. Alternative 10 is more protective, and
thus more effective, than either Alternative 7 or a because a
portion of the contaminated material, instead of being stored on
the 12th and Quivas properties, would be removed from the
properties entirely. Alternatives 2 and 9 are both less.
effective than either Alternative 7, a, and 10 because.
Alternatives 2 and 9 will meet contamin~nt-specific ARARs only.
after the contaminated materia~ from the properties is removed to
the offsite permanent disposal facility. Alternative 9, is in
turn more protective, and thus more effective, than Alternative 2
because the cap will provide interim protection to public health
and the environment, whereas Alternative 2, will provide
absolutely no short~term protection to the public health and the
environment until the material can be removed to the offsite
permanent disposal facility. In addition, Alternative 9 ,will
reduce the chance of dispersal of contaminated material until the
material can is removed. No Action will not meet the
contaminant-specific ARARs for radium levels in soils on the 12th
and Quivas properties and, therefore, will provide neither short-
term or long-term protection of public health and the ,
environment. The possible resulting exposure could result in
4nacceptable risks to public health and the environment.
Alternatives 7, 8, 9, and 10 will meet contaminant-specific
ARARs for gamma radiation levels and radon decay product
concentrations in the buildings once the temporary response
actions are completed. Alternative 2 will meet these levels only
after the contaminated material under the buildings is removed to
the permanent disposal facility. No Action will not meet these
contaminant-specific ARARs and the possible resulting exposure
would result in unacceptable risks to public health.
No Action and, in the interim, Alternative 2 will not reduce
the mobility, toxicity, or volume of the contaminated material on
the properties. Although Alternatives 7, 8, 9, and 10 will not
reduce the toxicity or volume of the radioactive waste, they
transfer the contaminants from an uncontrolled status to a
controlled faciiity, thereby reducing mobility. In addition, an
increase in volume is often the result of the contaminated
material being disturbed. Thus, Alternatives 7, 8, 9,' and 10,
since they reduce the chances of the material being disturbed,
also may prevent the volume of contamination from increasing.
EPA conducted a ~ublic ~ealth Evaluation of Remedial.
Alternatives to determine short-term potenttal for adverse health
effects from human exposure associated with the various remedial

-------
~
23
action alternatives. This analysis, summarized in Appendix F of
the Operable Unit I FS, revealed that all of the alternatives
considered except ~!o Action would result in nearly equivalent
exposure~ during implementation of the remedy. In addition, al~
estimated exposures would be well below target levels established
in ARARs. EPA also ~onducted a Public Health and Environmental
. Assessment to determine. the long-term potential for adverse
. health effects associated with the contaminant levels present on
the 12th and Quivas properties. . This analysis, summarized
earlier in this summary and contained in Appendix B of the
Operable Unit I FS, showed that there would be a significant
increase in public health risk if the No Action alternative was
implemented at the 12th and 'Qui vas propert~es.

The potential for adverse environ~ental impacts at the 12th
and Quivas properties is low. However, leaving the materi~l on
the properties in an uncontrolled state provides an opportunity
for potential environmental impacts during a catastrophic event,
such as a flood or water main break, resulting in a substantial
dispersal of the contaminants.
Cost Analysis:
No Action is the least costly remedial action alternative,
followed by Alternative 2. Alternative 10 is the most expensive
alternative followed closely by Alternative 8. Alternatives 7
and 9 have costs'between the extremes, with Alternative 9 being
slightly less expensive. Table 3 presents a breakdown of each
remedial action alternative's cost based upon the component
measures of cost described above. Even more detail is provided
in Appendix G of the Operable Unit I FS. Section 8 of th~
Operable Unit I FS contains a sensitivity analysis of these
costs. '.
In summary, the selected remedy for the 12th and Quivas
properties was. chosen from the detailed analysis of remedial
action. alternatives. The analysis was based upon component
measures of implementability, effectiveness, and cost. Xable 4
outlines the detailed analysis of remedial action alternatives
summarized above. (See also Section 9 of the Operable Unit I FS~)
. .
Selected Remedy
This Record of Decision addresses the contamination present
on the 12th and Quivas properties, Operable Unit I of the Denver
Radium Site. This is the fourth operable unit of the Denver
Radium Site for which EPA has selected a remedy. 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. .

-------
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\
I.pleaentebillt,
[valuallon Criteria
[f feet Ivenen
Table 4
5UH/tARY OF al.TEPIIATlvt EVaUIATION
OP[flAlIl[ UN IT I, OIJIVER RAIIIIIH 51T£
Ulernathe I
No action
Fe4lIbl..
40 CFA 192 conditions for radlue-116
In solis ..ould not be attailled. If
the properties ar. redeveloped, pro-
tectiveness levels for radun ..ould
not be attained.
As 14.. as Peasonabl, allovabl.
(AURAl .prlnclple and NCPP/ICPP quld-
ance (or qam.a radiation aa, not be
.et It land use chanqes or .Isuse
of current sltuatlou occurs.
110 Action doe; not reduce 801I1I1tr,
to.lclty, or volllllO) o( radioactive
.aterlals at OU I.
Radloactlva .aterlals are e.tre.el,
per5lslent. Aadlo.. Is not verr
80bt Ie alld 'lives 0(( radon decar
rroducts to the atmosphere. IIhlle
not 50luble aller revrocesslnq,
radII.. Is subject to dispersal via
h..aan actlvltr. Aa1100.deca, products
can accu.ulate In h",.an IUllqs alld
are carcln0gellS.
Alternatlv. I
De(erred Ae.ovall
OUsite Pernanellt Olsposal

011 I properties could under9Q additional
denlol'..ent In conte.lnated areas. COII-
te.lllaled .aterlals could be dispersed
or diluted such that the, vould no lonqer
b. Identifiable.
[Icavatlon cannot proceed until an off-
site disposal (acllltr II available.
hallahllltr required b, SARA 104 'U.
racilltr Is &Ssuaedpot to b. available
until 1991.
While re.ov.1 I. de (erred, conta.lnant-
apecl(lc aAAA'. aar not be 88t. ARAP'.
vould be .et upon reaoval.
1
of 4 pages
AHerllathe 1
OII.H. 'e.porarr I.and 5tora,.el
O((slt. Per.anent Olsposal

'e.porarr .toraqe can have teehllical
proble.s. .ucb as rlpplnq o( the
'rnt hetlc lInu or crack.s In the
aspha I t pad.
'e.porar, .tora9. ..ould be used until.
o((slte dllpo.al (acillt, Is available.
hallabllltr required br SARA IOUU.
Facilltr Is a.su.ed not to be avall-
abl. until 1992. .
Sit. acce.. re.trlctlons and approval.
..ould be needed to construct the
esphalt ~d stor.ge unit. Storaqe
facillt, voul4 leverel, restrict usaqe
o( the Halerl." lIandllnq property (or
5 rear.. since It ..ould oca'pr . larqe
rereentaqe of open space at the Hate-
rial. Handling propert,.

al~AA principle .nd HeRP/ICAP 9a...a
radiation values ..ould be met. The
.obillt, of the 8aterl.1 viii be
decreased (or erosional aspects. A .,n-
thetlc liner .ar not recluce the .obllltr
o( radon 9.' on a lonq-ter. basis.
N
1ft

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Evaluation Criteria
Effectlveneaa (continued)
Alternat Ive 1
No Action
CoaU
lIot Appllnble
a~ - preaent worth at 8 10 percent dlacount factor.
bOMt ~. Ope.utlona and Helntenance.
Table 4
(continued)
Alternative 2
Deferred Re.oval/
Offalt~ rereanent Dllpolal

DUrlna excavation, re8edlal action
"orl
-------
[valuation Criteria
lepluentabllit,
[If ect heness
I
/
Alternat Ive 8
OneUe Tupour, Oulldlnq Stouqel
Offslte Pel.anellt Disposal

S,nthet Ie baqs could rip and spill ..te-
rial In the bulldln9. lIowever, the bulld-
Inq should contain an, spilled ..terlals.
Teeporar, .toraqe would be used until
oflslte disposal facillt, Is avallabla.
Avallablllt, required b, SARA 10tlkl.
racillt, I. essumed not to ba avallabla
untlt 1992.
Site access restrictions and approval.
would be needed to construct the asphalt
pad storaqe unit at Ihe "oterlals lIalldllnq
propert,. Stora~e facillt, would severel,
restrict usaqe of the propert' for 5 ,ear.,
since It. would occup, a larqe percenlaqa
of oren space at I he "oter 10 Is lIandllnq
proper t,.

Teeporar, .toraqa faclllt, would not.....t
.0 CrR 192 and 10 CrR 20 standards for
9a~a radIation and radon unless ventIla-
tion Is used. lIowner, ndl U8 standards
In ,olh would ba r>et upon InItial rti80val.
The 8Obillt, of the .aterlal would be
decreased unless the contaIner broke, hOll- .
ever, the use of a bulldlnq for .torlnq
the containers IIou Id cOllta In an, Spillaqe.
'he 8Obllit, of radon 'In could ba
decreased, but could slill present a prob-
lea within tha COlJlalner bulldlnq used (or
.to18qe.
Table 4
(con t J nued 1
A Hunattve 9
Onslte fe.pOUI, Contaln..nt (Capplnqll
O(lsll'e Pel.i"'ent Olsposel

Teaporar, contaln.ent Can have technIcal
prohle.s, such as cucks In the a'..halt
pad.
Te.porar, contaln.ent would be used
until offslle disposal tecillt, Is
avaIlable. Avallabillt, required b,
SARA 10tllll. racllll, Is assU8ed not to
be available until 1992.

Site access restriction. and approva'.
vould be noeded to construct the'
teararar, storage unit and cap at
"~Ierlah lIandllnq. StOllge hclUt,
and cap vould severel; restrict usa~e of
overall slle for 5 ,ears, 'Ince It would
occup, a hrqe percentaqe o( open apaca
at tha propert,.
earplnq and storlqe would not ...et
to erR 192 Ind 10 erR 20 atandlrds.
AI~RA prIncIple would be ...t. the
eohlllt, of the ealerhl 11111 be
de~rea'ed (~ eroslonll aspect.. A
s,nlhetlc lIner eo, not reduce the
eoh lilt, of radon 'In, If land .toraqe
Is leple.ented. If blllldlnq .torlqe I.
leple8enled, the 8Oblllt, of rldon 98'
eou 1<1 be decre..sed, but cou Id .tllt
present a prohlee IIlthln the container
building.
3 of 4 pages
Alternathe 10
Onslte te.porar, Bulldlnq Storaqe at
Card Corporation IOU XII
Offslte Per.anent 01'00501
S,nthetlc be9S could rip and spill ~.Ie-
rial In the bulldln9. 110"-"''', the bulld-
In9 should contain an, Spilled 84terlals.

Teerarafy .torage IIould be used"untll off-
sit. disposal facillt, Is evallable.
A.allabillt, required b, SARA 10tlkl.
hell II , Is "...ed not to be a...llabla
until 1992. .
Arprovals for usln9 the "aterla" lIandllnq
Plopert, for radioactive .aterlal storaqe
need to be obtaIned.
Teaporar, atorlge facillt, vould not neet
.0 erR 192 and 10 CrR 20 .tand..rds for
9a..a radiatIon and radon unless ventila-
tion Is used. lIollever, udl.... standards
In soil. IIould be eet upon InItIal reeova'.
The 8Oblllt, of the .ate.lal vould be
decrelsed unlesl the container broke, hov-
e.er, the USI of a bull~ln9 for storln9
fhe containers "ould conlaln an, Spillage.
The 8Obllit, of radon 901 coilld be .
d"~reased, but could stili pre5ent a prob-
I.. vllhln the container bulldln9 used for
storage.
N
'-J
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\
f
I .
Evaluation Criteria
Effectiveness (contlnuedl
Costs
Alternallve 8
On~Ue Teapoury Dulldlnq .Stouqel
Offslte Permanent Disposal
Durlnq excava~lon, remedial action
workers would be exposed to approxl~
.ately 382 .rea/yr (whole body Dose
Equivalent), which Is below the 10 CFR
20 quldellne u1 ~OO areli/yr. Onslte
workers who are not associated with
cleanup would be exposed to approxi-
mately 3.1 .reli/yr, which Is below the
tlCRP/lCRP standard of 100 aremlyr."
Transportation risks would be ldenl1ca"I
to Alternative 2.
a
CapAtai PW --$4,256,900
OUt ~1--518,400
apw .. present war th at a 10 percent d Iscounl factor.
bO'" .. Operallons and "alntenance.
\
I
J
Table 4
(contlnuedl
. Alternat"e 9
Onslte T~.porary Contal~ent (Capplnqll
OtCslte Permanenl Dlsllosd

Durlnq excavation, re.edlal aclton workers
would lie exposed to approxlaatelr
370.re./yr (whole body Dose Equlvalentl,
which Is below tl:e 10 CfR 20 standard of
500 .rell/rr. Onslte workers who are not
assoclat,ed with cleanup would be exposed
to approxillately 4.5 .reli/yr, which Is
below the IICRP/lCRP quldellne of
100 .reli/y r. Transportation expoSures
would be Idcntical to Alternative 2.
a
CapAhl 114 --$3,412,800
OUt rw--190,OOO
4 of 4 pages
Alternative 10
Onslt. Te.porarr Bulldlnq Storaqe al
Cerd Corporation (OU XII
OffsUe Per.anent Disposal

Durlnq excavation, remedial action
workers would be exposed to approxl.atel,
382 .re.l,r (whole body Dose ['Iul,alent),
which I. below the 10 CfR 20 ~uldellne of
500 .re./rr. Onslle workers who ere not
associated vllh cleanup would be exposed
to approxl.atelr 3.3 arem/yr, which Is
belov the tlCRP/lCRP standuc! of
100 .re./yr. Transportation rIsks vould
be sllqhtlr tncre~sed "to 6.9 .rell per
trip.
a
CapAtai PW --$4,416,700
0'" PW--~56,5oo
N
00
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29
EPA's preferred remedial action alternative for the 12th and
Quivas properties is Alternative 6, Offsite Permanent Disposal.
This alternative, however, was eliminated during the initial
screening of remedial action alternatives because, until the
State of Colorado provides a permanent disposal site for material
from the 12th and QUivas properti~s, this alternative cannot be
implemented. EPA has therefore determined. that the appropriate
extent of remedy at the 12th and Quivas properties is Alternative
9, Onsite Temporary Containment (Capping), Offsite Permanent
Disposal. The State of Colorado has been consulted and concurs
with the selected remedy.
Remedial Design for Operable Unit I will include the
selected remedy, Alternative 9, and EPA's preferred remedial
action alternative, Alternative 6, Offsite Permanent Disposal.
Should the State of Colorado fulfill its obligation to assure the
availability of a suitable disposal facility for material from
the Denver Radium Site by the time EPA has concluded Remedial
Design for the 12th and Quivas properties, EPA may immediately
implement its preferred alternative, Offsite Permanent Disposal.
Description of the Selected Remedy:
The selected remedy consists of one temporary management-of-
migration respons~ action and one temporary source control
response action followed by one final and permanent source
control response action.
The temporary management-of-migration response action
consists of placing a cap over the identified open areas of
contamination which cover over 72,000 square feet of the 12th and
Quivas properties, portions of which already have a permanent
cap. The identified open areas of contamination account for an
estimated 7,600 cubic yards of contaminated mate=ial. The cap
will temporarily limit the spread of. the contaminated material by
wind and water erosion and human activity. The cap will also
provide temporary protection of numan health by reducing direct
exposure to gamma radiation and by reducing the risk of
inhalation or ingestion of contaminated soil. Placement of the
cap could take one month. Once in place, the cap will be
routinely inspected and restrictions on excavation will be
instituted to maintain the integrity of the cap. The cap will
remain in place until a permanent offsite disposal facility
becomes avaiiable.
The temporary source control response action consists of
excavating the estimated 3,400 cubic yards of contaminated
material from under the B&C Metal Products, Materials Handling,
and Rudd Investments buildings. Depending upon the struct~ral .
details of each building, the contaminated material would be
excavated either by partial demolition of the floor and
excava~ing through the floor or by excavating from the exterior
of the bUildings. Excavation of the contaminated material trom
under the buildings could take. three to six months. Contaminated
material from under the buildings would be temporarily stored
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30
onsite in either a land storage or building storage facility
until a permanent offsite disposal facility becomes available.
The final and permanent source control response action will
occur once a permanent offsite disposal facility becomes
available and consists of removing the cap and excavati~~ the
material which was temporarily placed under the cap. This
material, along with the material whic~ had been temporarily
stored onsite after having been excavated from under the
' buildings and any portion of the cap which is contaminated, would
then be transported by either truck or rail to the permanent
offsite disposal facility. Excavation of the contaminated
material under the cap and transportation of the contaminated
material to the permanent offsite disposal facility could take
' three to six months. A more detailed implementation schedule for
this response action and the ones described above will be'
developed during Remedial Design.
The present-worth cost of the selected remedy is $3,702,800
based upon a ten-percent interest rate, a five-year discount
period, and a perpetual monitoring period. The cost of this
alternative includes placement of the cap over the ~ontaminated
open areas, construction of a temporary storage facility for
material present under buildings, excavation of the material from
under the buildings and placement of this material within the
temporary storage facility, and maintenance and monitoring of the
'12th and Quivas properties for a period of five years. The cost
of this alternative also includes removal and transport of the
contaminated material and the cap to the offsite permanent
disposal facility, decontaminating and, if necessary, dismantling
the temporary storage facility, and transporting the
decontaminated material to a solid waste landfill.
Operation and maintenance activities ,will pe required to
ensure the effectiveness of the temporary response action. These
activities include site inspections, ongoing radiological
monitoring, and possible minor repairs to the cap or temporary
storage facility. Also included as an operation and maintenance
activity is a r~view of the properties which, pursuant. to SARA
Sectio~ 121(c), must be conducted no less than every five years
if a remedial action is selected that results in any hazardous
substances remaining onsite. Since EPA does not anticipate that
any hazardous substances will remain onsite longer than five
years,-the cost of this review is considered a contingency. The
maximum total of the discounted annual operation and maintenance
costs of these activities using a five-year discount period and a
ten-percent discount rate is $290,000. This operation and
maintenance cost is included with the present-worth total
alternative cost mentioned above. .
Statutory Determinations:
Protectiveness: The Public Health and Environmental
Assessment for the 12th and Quivas properties summarized earlier'
in this document clearly shows that there would be a significant
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31
increase in the risk of contracting lung and other cancers if
Alternative 1, No Action, was selected for this operable unit of
the Denver Radium Site and the properties were ever developed in
a way which might reasonably be expected. The only sure ,way to
reduce this risk is _excavation to achieve target residual levels
established in contaminant-specific ARARs and removal of the
contaminated material from the 12th and Quivas properties to an
offsite permanent disposal facility. Further, because the
offsite permanent disposal facility would be designed to isolate
the contaminated material from man and the environment for a
thousand years, the selected remedy would provide long-term
protectiveness. The temporary measures envisioned in the
selected remedy will provide the necessary short-term
protectiveness. '
In addition to preparing the Public Health and Environmental
Assessment mentioned above, EPA conducted a Public Health
Evaluation of -Remedial Alter~atives~ summarized in Appendix F ot
the Operable Unit I FS. For this evaluation, exposures to gamma
radiation', inhalation of contaminated soils, and inhalation of
radon decay products were estimated for persons who might be
exposed to hazards during implementation of each alternative
undergoing detailed analysis. These persons include'onsite
remedial action workers, individuals not associated with remedial
activities but working in an onsite office, residents of a home
, located outside of the property boundary, a transportation,
worker, and an onlooker present during truck transportation of
the contaminated materials. Exposures were calculated for each
remedial action alternative undergoing detailed analysis. The
evaluation revealed that none of the estimated exposures for any
scenario of any remedial action alternative, including the
selected remedy, exceeded exposure limits set by the relevant and-
appropriate standard or guideline. Also, for any given scenario,
there was no appreciable difference among the estimated exposures
for the remedial action ,alternatives. The risks associated with
this type of remedial acti-on work lie not with possible
radiological exposure, but with the inherent dangers associated
with general construction work. Based upon 'statistics from the
construction industry, EPA estima~es that the number of worker
non-fatal injuries would range from 1.16 to 1.20 for the type of
work to be conducted during remedial action at the 12th and
Quivas properties and the number of fatalities would range from
0.120 to 0.138 for the type of work to be conducted during
remedial action. (See report entitled Operable Unit I, Public
Health Assessment, Dose Commitments.> These numbers can be
significantly reduced by hiring competent and properly trained
construction contracto~s and by strict adherence to the site
safety plan.
The OSWER Directive No. 9355.0-19 states, "Remedies must be
protective of human health and the environment. This means that
the remedy meets or exceeds ARARs..." EPA has determined that
the selec~ed remedy will meet all ARARs identified for the 1,2th
and Quivas properties. I~ addition, from the analyses conducted
in the Public Health and Environmental Assessment and the Public
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32
Health ~valuation of Rem~dial Alternatives and because of the
permanence associated with the de?ign of the offsite disposal
facility, EPA has concluded that the selected remedy wculd be
protective of public health and the en~ironment.
Consistency With Other Laws: Pursuant to SARA Section
121(9), 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 minimum.
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
environmen'tal or faciiity siting law that is more stringent than
any Federal standard (ARARs). -
On November 20, 1986, EPA requested that the State of
Colorado identify potentially applicable or relevant and
appropriate State public health and environmental requirements
for the Card Corporation property (OU X). Th~ State responded to
'this request on January 21, 1987, with a list of Colorado
requirements which the State believed pertained to the entire
Denver Radium Site.
EPA classified all Federal and State public health and
environmental requirements applicable or relevant and appropriate
to the 12th and Q~ivas properties into three categories:
contaminant-specific ARARs, action-specific ARARs, and location-
'specific ARARs. A description of each of these categories is
provided in both Chapter 4 and Appendix C of the Operable Unit I
FS. Other Federal and State criteria, advisories, and guidance
were also considered. Tables C-1 through C-4 in Appendix C of
the Operable Unit I FS contain a brief description of each' ,-
potential Federal and State public health and environmental
requirement identified and EPA's analysis of each requirement's
applicability or relevance and appropriateness to the 12th and
Quivas properties. EPA has determined that there are no
applicable or relevant and appropriate public health and
environmental requirements of Federal or State laws that the
$elected remedy will not meet and, therefore, no SARA
Section 121(d)(4) waivers need be invoked. A brief discussion of
ARARs for the 12th and Quivas properties is provided below.

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 12th and Quivas properties.
For properties contaminated with uranium processing residues,
these standards establish limits for the gamma radiation level
and annual average radon decay product concentration in any
occupied or habitable building and for the radium concentration
in soil on open lands. Although not applicable to the 12th.and
Quivas properties since the standards apply only to certain
\
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33
specifically designated sites where uranium was processed, the
standards are relevant a~d appropriate tc the 12th and Quivas-
properties because (1) it is the radium content of the uranium
mill tailings-which is regulated; (2) the waste products
resulting from uranium ore processing are very similar to those
from both radium and vanadium ore processing; (3) the residue~
from both processes enter the environment through the same
exposure pathways; and (4) the adverse nealth concerns resulting
from exposure to the residues from both processe-s are the same.

The portion of the standards relevant and appropriate to the
contaminated soil on the 12th and Quivas properties and the
portion which s~rv,=s as EPA's target residual level for cleanup
is 40 CFR Section 192.12 which states: .
"Remedial actions shall be conducted so as to provide'
re,sonable 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 )
( 2 )
5 pCi/g, averaged over the first 15 centimeters of
soil below the surface, and
15 pCi/g, averaged over 15-centimeter thick layers
of soil more than 15 centimeters below the
surface."
(40 CFR Section 192.12)
The portion of the standard relevant and -appropriate to the
buildings on the 12th and Quivas properties is 40 CFR .
Section 192.12(b) which states:
(b) . In any occupied or habitable building -
( 1 )
( 2 )
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 exceed
0.02 WL. In any case, the radon decay product
concentration (including background) shall not
exceed 0.03 WL, and
The level of gamma radiation shall not exceed the
background level by mor~ than 20 microroentgens
per hour.
(40 CFR Section 192.12(b).)
The second contaminant-specific ARAR -identified for the 12th
and Quivas properties is the Nuclear Regulatory Commission
Standards for Protection 'Against Radiation, 10 CFR Part 20.
These regulations establish standards for protection against
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34
~ad1ation hazards arising out of activities under licenses issued
by the Nuclear Regulatory Commission (NRC). Because thes~
standards apply to licensed NRC facilities, they are not
applicable to the 12th and Quivas properties. .However, EPA ha~
determined that portions of the regulations are relevant and
appropriate to individuals who would be conducting the remedial
action on the 12th and Quivas property. In addition, these
regulations are incorporated by reference in the Occupational
Safety and Healtp Administration Standards, 29 CFR Parts 1910 and
1926, which, due to the mandate contained in SARA Section 126,
now apply to employees involved in responses covered by CERCLA.
,
-
Of particular importa~ce is Appendix B of 10 CFR Part 20
which provide~ limits for airborne concefltrationi 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 S.
Currently there are no identified Federal or State location-
specific ARARs for the 12th and QUivas properties.
Action-specific ARARs are technology-based restrictions
trigger~d by. specific types of remedial measures under
consideration. Once the remedial action alternatives were
developed in the Operable Unit I FS, EPA identified specific
action elements which were part of at least one or more of the
alternatives. These action elements are listed in Section ~ of
the Operable Unit I FS. EPA then identified numerous action-
specific ARARs for each of the action elements. These action-
specific ARARs were ~valuated in Appendix C of the 'Operable Unit
I FS and are presented in Table 6-2 of the Operable Unit I FS.
In addition to the ARARs mentioned above, EPA also
considered other Federal and State criteria, advisories, and
guidance in determining the appropriate degree of cleanup for the
12th and Quivas properties. In particular, EPA considered the
National Council on Radiation Protection and Measurements (NCRP)
and the International Commission- on Radiological Protection.
(ICRP) recommendation for maximum gamma radiation dose to the
whole body. This d9se, 100 mrem/yr, is for chronic exposure to
the general public, excluding natural background and medical
radiation. This recommended level is more protective than the
level established by the NRC in its regulations (10 CFR Part 20),
and will be used in evaluating exposures to those working on the
site but who are not associated with remedial cleanup of the 12th
and Quivas properties.
SARA Section 121(d)(3) codifies EPA's offsite disposal
policy, which requires that offsite disposal of ~ny hazardous
substances, pollutants, or contaminants from a Superfund site
take place only at a facility that is in compliance with
applicable Federal law and all applicable .State public health and
environmental requirements. Furthermore, the unit to which these
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Regulatory A&ellcy
!Ipe of Contumillant
FEDERAL
U.S. EPA-ItO CFR ]92,
, Subpart B-5tandards
RadIUl8-:!'6
Concentration.
\
Gamma radlatlona
Radon Decay Product
Concentration
tluclear Itegulatory
Coauu1&s Ion (NRC)
10 efR 20
Uranlull-natura I
Airborne Concentra-
tiona
]1lorlulD-230
Airborne Concentra-
tlon8
'..
bdlum-226 Alrhorne
Concentrations
Gamma radlatl~nd
Table 5
POTENTIAl. OONTAHItlANT-SPECIFIC ARAR'S
OI'ERABLE UNIT 1, VENVJ.:R RAIHUH SITE
Standard, Requlremellt,
Criteria. or I.illlltatJon
5 pCI/a above backgronnd
wHhln 15 CII of the 811r-
tuce ,ea8ured over a
100-m area
15 pCI/g above hackgroulld
within 8ubsequent 15 CDI
layer~ measured over a
100-111 area
20 JJR/hr above background
0.02 WI. annual average
0.03 \lL DlullllUDI

5 pCI/mJ'3unrcstrlcted arcs
100 pCI/II , Restricted area
3
3 pCI/. 3 Unrestricted area
30 pCI/II , Itestrlcted area
, J
3 pCI/II 3 Unre8trlcted area
30 pCI/1II , Restricted urea

5 reDl/yr, (5,000 Dlrem/yr)
Restricted area
500 mrell/yr, Ullrestrlcled
area
Collllenta
Standa.'da for cleanup of open land. or buildings; concen-
tration of radhlll-226 In land, aVt:a'lIged over any area of
1 00 squa~e mctera. Point of. c2"'pllance fa at any contam-
Inated urea greuter than 100 II. lIowever, during cleallup
all contaoslnated ares would be remcdlaled.
Itelevant and al'proprlate to Indoor lalllllls radlatiun.
of cOfUpllanct: is Inside any site building.
Point
Relevant and uPllroprlllte to Indoor radon.
pllancc Is Inside any site building.

Point of compliance Is any location within site.
Point of COII-
W
l.n
Point or cOllpllnnce Is any location within sI tee
Point of compl1ance Is any location within site.
Point of compliance 18 any location within site; site
would be ulU'estrlcted Cor rt:osedlation workers.
a .
Felcvant alld al'llroprlatc Gtundard but not aa protecllve a8 Other Guldancc!; lice I'able 4-2.
b
All unrestricted area fa. regarded 88 any place around a waste conso Ildal1oll/storage arcu facility where access 18 not controlled.
cA'restrlcted area Is regarded a8 an): (.bce around a waste consul1dotlon/storage area where access Is controlled.
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36
wastes are transported must not be releasing any hazardous waste
or constituent to ground water, surface water, or soil~ and any
such releases from other units at the facility must be controlled
by an approved corrective action program. It is incumbent upon
the State of Colorado, as part of its CERCLA requirements, to
assure the availability of a disposal facility which is in
compiiance with EPA's offsite disposal policy.
,.
Cost-effectiveness and Utilization of Permanent Solutions
and Alternative 'Treatment Technoloqies or Resource Recovery
Technoloqies to the Maximum Extent Practicable: A~ternative 9,
Onsite Temporary Con~ainment (Capping), Of:site Permanent
Disposal is a cost-effective remedial action alternative which
effectively mitigates and minimizes threats to and provides
adequate protection of public health and the environment.' The.
results of this alternative cannot be achieved by the methods
envisioned in the two alternatives which were l~ss costly, .
Alternatives 1 and 2. Although the temporary building- or land-
storage facilities envisioned in Alternatives 7, 8, and 10 may be
slightly more protective than Alternative 9, they are not as
implementable and EPA believes a cap over the open areas of
contamination and 'the temporary storage facility for the
contaminated material which is present under the buildings will
provide the necessary short-term protection for the 12th and
Quivas properties.
The selected remedy will address the principal threat at the
12th and Quivas properties. However, the selected remedy does
not satisfy the statutory preference for treatment as a p~incipal
element. As part of the selection of remedy process, EPA
evaluated permanent solutions to the hazards associated with the
specific substances present on the 12th and Quiva~ properties.
However, since the hazardous ~ubstance associated with the 12th
and Quivas properties is a radioactive element, the number of
treatment technologies which may successfully reduce the
mobility, toxicity, and volume of the hazardous substance is
extremely limited. The characteristic of spontaneously emitting
energy and subatomic particles is a property inherent to each
atom of a radioactive element and which cannot be altered or
destroyed by any chemical or physical ~reatment known today.
Most treatment and resource recovery technologies concentrate the
radioactive elements present in the waste, increasing toxicity
without significantly reducing volume or mobility. These"
treatment and reso~rce recovery technologies will also leave a
waste product which is still radioactive. Noneth~less, EPA
considered several treatment and resourc~ reco~ery technologies
in the technology scoping and screening phase and even the
initial alternative screening stage of the Operable Unit I FS.
However, no technology was found which would result in a
permanent and significant decrease in the toxicity, mobility, and
volume of the hazardous substance, radium, which is presen~ on
the 12th and Quivas properties. /
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( 4 )
( 5 )
( 6 )
- 37
Hazardous Waste
Information ResOl
US EPA Region 3
Philadelphia, PA .
Future Actions
. ~..",,~
The future remedial activities that are req~ired to complet&
remedial action at the 12th and Quivas properties are:
( 1 )
( 2 )
Design remedia~ action.
Enter in to State Superfund Contract with State of Colorado.
( 3 )
Conduct temporary remedial action for contamination present
on 12th and QUivasproperties. .
fl.
Select and, if necessary, design and construct permanent
disposal facility. (This activity is to be conducted by
State of Colorado.)
Remove contaminated material from the 12th and Quivas
properties and ~ransport to ~ermanent disposal facility.

Confirm that the 12th and Quivas properties have been
decontaminated to conform with the requirements of ARARs and
can be made available for unrestricted us~.
Schedule
Dates for completing key milestones leading to remedial
action at the 12th and Quivas properties are highlighted below:
( 1 )
( 2 )
( 3 )
"
Complete design of remedial action by September 30, 19B8.

F~nalize State Superfund Contract with State of Colorado by
September 30, 1988.
Initiate remedial action no later than during first quarter
fiscal year 1989.
...
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