.te Collection
source Center
3
~ 19107
United States
Environmental Protection
Agency
OffIce of
Emergency and
Remedial Response
EPAIROD/R08-87/017
September 1987
8EPA
Superfund
Record of Decision: .
!fB 88 -172 ( 5t3
Denver Radium III, CO
U.S. Environmantal Protection AgencJ
Re!1ioil III Information Resour~
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- . TECHNICAL REPORT OAT~
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EPA/ROD/R08-87/0l7
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SUPERFUND RECORD OF DECISION September 29, 1987
Denver Radium III, CO .. ~11II'OIlll-"I"'a 0Illla.""Z"'10... <:001
Fifth Remedial Action
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U.S. Environmental Protection Agency Final ROD Report
401 M Street, S.W. 1.. I~O"'IOIIIINa Aal...cy C:OOI
Washington, D.C. 20460 800/00
,to IY""'I"I"'T"III" NOTI.
,.. -- ~-- located in Denver, Colorado, consists of more than 40
The Denver Radium site,
contaminated properties that have been grouped into operable units. This is the fifth
operable unit of the Denver Radium site for which EPA has selected a remedy and is.. --
comprised of the 3.4-acre 1000 West Louisiana vacant lot and the 0.46-acre Creative
Illumination property, as well as two contiguous properties, the Packaging Corporation
of America and the Colorado Southern Railroad ( CSR) . A property adjacent to the
railroad, Titian Labels, Inc., is included in all discussions of the CSR property. The
properties cover approximately 11 acres in an area zoned for industrial use. The DenveI
Radium site beginnings mirror the Unites States radium producing industry of the early
1900s. Prior to 1914, radium-bearing ore was shipped from the U.S. to Europe where it
was defined. The United States Bureau of Mines entered into a cooperative agreement
with a private corporation establishing the National Radium Institute in Denver, which
successfully developed and operated a radium processing plant in the Unites States. Th4
Denver radium, vanadium and uranium industry remained strong until the early 1920s when
rich ore deposits were discovered in what was then the Belgian Congo. The Denver
producers were unable to remain economically competitive and the industry in Denver
collapsed. 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
(See Attached Sheet)
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Record of Decision
Denver Radium III, CO
Fifth Remedial Action
Contaminated Media: soil, debris, air
Key contaminants: radium, radioactive mater als
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EPA/ROD/R08-87/017
Denver Radium III, CO
Fifth Remedial Action
16.
ABSTRACT (continued)
of 31 "radioactive sites in the Denver metropolitan area, two of which are now included
with the 1000 West Louisiana properties.
Immediately after identifying these properties, the Radiation Control Division of the
Colorado Department of Health 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 contacting the division. An
estimated 16,000 yd3 of soil and debris are contaminated with radium and its
associated decay products.
EPA's preferred remedial action for this site is permanent offsite disposal.
However, until a facility suitable for permanent disposal of the 1000 West Louisiana
properties material is designated and, if necessary, acquired and developed, this
alternative cannot be implemented. The State of Colorado estimates facility selection
to take up to five years to complete. The selected interim remedy is temporary building
storage on the Card Corporation property which includes: cleanup of the Creative
Illumination property with storage of approximately 200 yd3 of contaminated material:
excavation of the contaminated soi1 remaining on the 1000 West Louisiana properties with
consolidation and capping on the vacant lot at 1000 West Louisiana Avenue: cap and
storage facility maintenance until a suitable permanent offsite facility becomes.
available: and final removal of the contaminated material from both properties to th~
~ermanent disposal facility. The estimated capital cost for this remedial action is
$2,172,800 with 5-year present worth O&M of ,305,800.
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DECLARATION
FOR THE
RECORD OF DECISION
Si~e Name
lOCO ~est Louisia~a
Cperabl~ Uni~ II:
Denver Radium Site
P==;e=~:~s
Site Location
1000 West Louisiana Avenue
Denver, Colorado
Statement of PurDose
This decision document presents the selected remedial action
for this operable unit of the Denver Radium Site developed in
accordance 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).
The State of Colorado has concurred on the selected remedy.
(See attached letter.)
Statement of Basis
This decision is based upon the administrative record for
the 1000 West Louisiana properties,' Operable Unit III 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.
Descriptio~.of the Selected Remedv
This Record of Decision addresses the contamination present
on what is known as the 1000 West Louisiana properties, Operable
Unit III of the Denver Radium Site. This is the fifth 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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2
Radium and its associated decay products are the hazardous
ubstances of primary concern that have been released and
ontinue to be released into the environment at the 1000 West
ouisiana properties. Long-term exposure to radium and its dec.
roducts has been shown conclusively to increase the risk of
~ntracting lung cancer.
EPA's preferred remedial action alternative for the 1000
3St Louisiana properties is Offsite Permanent Disposal.
)wever, until a facility suitable for permanent disposal of the
JOO West Louisiana properties material is designated and, if
=cessary, acquired and developed, this alternative cannot be
lplemented. ,Pursuant to CERCLA Section 104(c)(3)(C)(ii), it is
1e responsibility of the State of Colorado to assure the
' "ailability of a facility for offsite disposal of the 1000 West
. JUisiana properties material. Although both EPA and State of
lorado are continuing to seek a permanent disposal site, the
~ ate estimates that this process could take up to five years.
( ven the length of time which may pass before the State assures
t e availability of an offsite ~~rmanent disposal facility, and
i order to prevent or minimize the threat to public health and
t e environment, EPA has determined that a remedial action
a ternative which includes temporary response actions should be,
i plemented at the 1000 West Louisiana properties.
The selected remedy for the 1000 West Louisiana properties
i Temporary BUilding Storage on the Card Corporation property
( ~erable Unit X), Offsite Permanent Disposal. This remedial
ar :ion alternative will attain a degree of cleanup of the
h. ~ardous substances which will assure both short-term and long-
t, ~m protection of human health and the environment. The
p: =sent-worth cost of this alternative is $3,406,100 based upon a
t! I-percent interest rate, a five-year discount period, and a
Pf :petual monitoring period. This alternative entails:
cleanup of the Creative Illumination property and
storage of the approximately 200 cubic yards of
contaminated material in a temporary storage facility
on the Card Corporation property, Operable Unit X of
the Denver Radium Site;
excavating the contaminated 50i1 remaining on the 1000
".t Louisiana properties and consolidating and capping
this material on the vacant lot at 1000 West Louisiana
Avenue;
maintaining the cap at 1000 West Louisiana and the
temporary storage facility at the Card Corporation
property until a facility suitable for the permanent
'disposal of Denver Radium Site wastes becomes
available; and
final removal of the contaminated material from both
properties to the permanent disposal facility.
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3
Remedial Design for this operable unit will include the
selected remedy described above and EPA's preferred remedial
action alternative, Off site 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 1000
West Louisiana properties, EPA may implement its preferred
alternative, Offsite Permanent Disposal.
Operation and maintenance activities will be 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 on the
1000 West Louisiana properties or the temporary storage faCility
on the Card Corporation property. Also included as an operation
and maintenance activity for cost estimating purposes 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 $305,800. 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 1000 West Louisiana
properties, Operable Unit III 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
technologi.. to the maximum extent practicable. Even though the
remedy doe. not satisfy the statutory preference for treatment
which reduC88 the toxicity, mObility, or volume of hazardous
substances aa its principal element, the principal threat at the
properties will be addressed. Treatment was determined to be
impracticable based upon effectiveness, technical feasibility,
implementability, and cost factors. .
~. - j~.
J' s';. S:herer
Regional Administrator
EPA Region VIII
/
,~.~"t'
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RECORD OF DECISION
SUMMARY
Site Name
1000 West Louisiana P~ope~ties
Operable Unit rII
Denver Radium Site
Site History
The Denver Radium Site has its beginnings with the United
States radium producing industry of the early 1900s. Radium was
first discovered in the late 1800s and was highly valued for
medicinal purposes. Prior to 1914, radium-bearing ore was
shipped from the United States to Europe where it was refined.
The possibility of.war in Europe threatened to disrupt the United
States' importation of radium and prompted the development of a
domestic refinement process. The United States Bureau of Mines
entered into a cooperative agreement with a private corporation
establishing the National Radium Institute which successfully
developed and operated a radium processing plant in the United
States.
Denver was chosen as the location of the National Radium
Institute facility due to its proximity to the Colorado Plateau,
which contained rich deposits of radium-bearing ore. Soon
numerous other radium, vanadium, and uranium processing
operations opened in Denver. The Chemical Products Company
operated a milling at what is currently 1000 West Louisiana
Avenue. Vanadium and radium was reportedly produced at the plant
from 1918 to 1921.
The Denver radium, vanadium, and uranium industry remained
strong until the early 1920s when extremely rich deposits of ore
were discovered in what was then the Belgian Congo. The Denver
producers were unable to remain economically competitive and the.
industry in Denver collapsed.
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, two of which
are now included with the 1000 West Louisiana properties
(Figure 1).
~
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Denver Radium 5ite
, ,
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3
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 contacting 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 the 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) of the Denver Radium Site to determine the
nature and extent of the contamination present on those
properties which the State did not previously study plus several
contiguous properties where additional contamination was
suspected. EPA also directed its contractor to conduct a
Feasibility Study (FS) of each operable unit to evaluate proposed
remedies tor the contamination present on all of the Denver
Radium Site properties which, with the addition of the contiguous
properties, totaled over 40 properties.
Because of the enormity and complexity of the Denver 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 original
Denver Radium Site properties plus the 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 Open Space properties being
Operable Units VI, IX, and XI. The properties were divided based
primarily upon site conditions and proximity to other Denver
Radium Site properties.
In Ap*11, 1986, the Denver Radium Site Remedial
Investigation Report, which addresses all eleven operable units,
was released to the public. The draft Operable Unit III 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 III FS is comprised of the
draft Operable Unit III FS incorporating the changes described in
the errata.
Pursuant to SARA Section 104(i), the draft Operable Unit III
FS was submitted for review by the Agency for Toxic Substances
and Disease Registry (ATSDR). At the signing of this Record of
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4
Decision, ATSDR had not formally responded. However, prelimlnary
discussions with ATSDR indicated that ATSDR had no major
criticisms of the report.
Site Location and Description
The Denver Radium Site, located in Denver, Colorado,
(population 509,000) consists of more than 40 contaminated
properties. These prOperties have been grouped into Operable
units. Operable Unit III is comprised of the 1000 West Lcuisiana
vacant lot and the Creative Illumination property, as well as two
contiguous properties which are the Packaging Corporation of
America (PCA) and the Colorado Southern Railroad (CSRR)
properties. A property adjacent to the railroad, Titan Labels,
Inc., is included in all discussions of the CSRR property. These
P~Operties are known collectively as the 1000 West Louisiana
properties. The 1000 West Louisiana properties are bounded on
the east by Jason Street, on the north by Mississippi Avenue, on
the west by Lipan Street, and on the south by Platte River Drive
(Figure 2). The properties COVer approximately 11 acres in an
area zoned for indUstrial use. There are several buried
municipal utilities within the property boundaries.
The 1000 West Louisiana properties are located outside the
SOO-year floodplain. The properties are underlain by alluvium
and the Denver formation sandstone. The approximate'depth to
ground water is 1S feet. A small drainage ditch, which runs
through an uncontaminated area, drains east to the South Platte
River. The climate of the area is typified by low annual'
precipitation, averaging about 14 inches per year.
The vacant lot at 1000 West Louisiana covers 3.4 acres and
is currently owned by Tenneco Corporation. The lot is nearly
flat with a slight slope toward Jason Street. Access to the
property is restricted by a wire fence. Radiation warning signs
are posted on this fence. The property is covered with grasses,
scrub growth, and a few small trees. A City of Denver ordinance
concerning weed growth cannot be enforced because the
contaminated soils should not be disturbed. Historical aerial
photographs show that a factory was once located in the area of
the vacant lot. This factory was reported to have been destroyed
by fire aDf the remains bulldozed into the basement cavity.
Creative Illumination is a small commercial facility at 1298
South Kalamath Street. The property Covers approximately
0.46 acre and contains a single permanent structure. The
structure consists of a three-story brick bUilding which was
constructed in 1896 and currently serves as offices and storage
space. A. concrete block addition serves as a workshop and sales
showroom, and an aluminum structure serves as a workshop. The
three-story brick building is occupied by 12 people for
approximately 30 hours per week. Most of the area surrounding
the building is paved. A portion of the grounds are used for
equipment storage.
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6
Packaging Corporation of America (PCA), W:.ich prints and
folds paperboard boxes, is a subSidiary of Tenneco. The PCA
property is a 5.6 acre site located at 1377 South Jason Street.
EXisting structures include a small chemical storage shed and a
main bUilding that houses an office as well as production and
storage areas. The factory portion of the PCA bUilding is
Occupied by 94 employees for 40 hours per week, and the office
portion of the PCA.building is oCcupied by 25 to 30 employees for
40 hours per week. The northern and eastern portions of the
property are paved with asphalt and serve as a parking and drive
area. A CSRR track spur runs along the West side of the PCA
bUilding. Some undeveloped land within the property boundaries
is located south of the plant. Historical aerial Photographs
reveal that a pond was at one time located on the PCA property.
The CSRR property is 1.43 acres of active railroad tracks
now owned by Burlington Northern Railroad and located adjacent
(west) to the vacant lot and the PCA plant. Titan Labels, Inc.,
owns property adjacent to the CSRR property. .
Current Site Status
. Radium and its associated decay products are the primary
contaminants of concern at the 1000 West Louisiana 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 1000 West Louisiana properties (Shaded areas of Figure 2).
Gamma radiation readings in excess of background were found OVer
203,915 square feet of the properties, including the area in one
bUilding. Average gamma radiation measurements ranged from
background to 154 microroentgens per hour (~R/hr) above
background. The maximum gamma radiation measurement was
2,189 ~R/hr above background. (A general discussion of radiation
and its associated units of measurement is presented in
Appendix A of the Operable Unit III FS and in the Public Health
and Environmental Assessment, Appendix C of the Operable Unit III
FS.)
The pre..nce of radium in the soi1 was verified by
radiochemical analysis of subsurface soil samples. The volume-
weighted a98raqe radium concentration in the contaminated soils
on the 100a-w..~ Louisiana properties was determined to be
114 picocuries per gram (PCi/g). The maximum radium
concentration found on the properties was 2,120 PCi/g. The
maximum depth of radium contamination found on the properties was
96 inches. The estimated total volume of radium contaminated
soil and debris on the 1000 West LOUisiana properties is
16,000 cubic yards. Table 1 summarizes the gamma radiation and
radium concentration data collected on the 1000 West Louisiana
properties.
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, "
Ta.ble 1
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Are~ A. 60 1,JS3 . 73 779 ,. .,.., , 81"'\.
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Area a 4 100 :3 23 36 to 48 .- . 41.7
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AreA P 44 600 II 20 H 98.a 227.1
Area Q 37 1,000 8 20 12 5..5 8
Ar.. a 44 600 14 19 .J.! 2:.7 28
Total lS,760 ;:06,~67 Max:'::t::II
(lS ,659 ;011, Oe~t::: 96
101 <1-==:.s)
, ~epth 1:cticates ~e est:.~at:.ed d.~~ ol c=:tami:u~=c.
~nevat:.ed qammA ra~4t:.~on levels 1: t.::ese a:eu lIIa1 or1qi:14te
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~ax1.:lNm ;eIIIIII. :a<11at1oa U KX~ q:'~<1 scan r;amu.
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GammA :'ad~At~Qn val~.s are
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8
The Creative Illumination and PCA bUildings on the 1000 West
Louisiana properties were tested for radon. Levels exceeding
standards were not detected in the PCA bUilding, but the Creat:
Illumination.building was found to contain elevated radon decay
product concentrations. During a 1985 EPA investigation, a
maximum radon decay product concentration of 0.17 Working level
(WLJ was detected in the basement of this bUilding. The average
value for the bUilding was 0.04 WL. Although this level exceeds
the limit allowed by the EPA standard for radon, an emergency
response action was not taken because the patterns of OCCUpancy
and the concentrations of radon decay products present during
periods of occupancy reduce the likelihood of significant long-
term exposure. The complete set of radon decay product
concentration data collected for the Creative Illumination
bUilding is presented in Table 2-2 in the Operable Unit III FS.
. The Creative Illumination bUilding also contains elevated
levels of alpha radioactivity. The maximum fixed alpha
radioactivity measurement, 116~000 decays per minute per 100
square centimeters (dpm/100 em ), was found on the floor of the
main level. The maximum removable alpha radioactivity
measurement, 364 dpm/100 cm2, was found in the attic of the
bUilding. The complete set of alpha radioactivity data collected
for the Creative Illumination bUilding is presented in Appendix B
of the Operable Unit III FS.
The radium concentration in the soils on the 1000 West
Louisiana properties and the radon decay product concentrations
and gamma radiation levels found in the Creative Illumination
bUilding exceed the "EPA Standards for Remedial Actions at
Inactive Uranium Processing Sites," 40 CFR Part 192, which EPA
has determined are relevant and appropriate Federal requirements
for the 1000 West Louisiana properties. The alpha radioactivity
levels in the Creative Illumination bUilding exceed the State of
Colorado gUidelines for fixed and removable alpha radioactivity,
which are discusSed along with the 40 CFR Part 192 standards
later in this SUmmary in the section entitled "Statutory
Determinations".
The 1000 West Louisiana properties were investiqated for
nonradiolog1cal contamination because of information from
historical aerial photos and known industrial uses of the site.
A small nu8b8t of POlynuclear aromatic hYdrocarbons (PARs! and
volatile organic compounds were found in site sOils. Figure 2-5
of the Operable Unit III FS shows sampling locations and Table 2-
5 of the Operable Unit III FS presents the results. There are no
standards for PARs and volatile organic compounds in soil to
which these levels can be compared.
The elevated concentration of radium and the uncontrolled
state of the soils at the 1000 West Louisiana properties pose a
health hazard due to three principal potential expOsure pathways.
In order of decreasing significance, they are: (1) inhalation of
radon gas, the immediate decay product of radium, and radon's own
short-lived decay products, (2) direct gamma radiation exposure
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9
from the decay of radium and its progeny, and (3) ingestion 8r
inhalation of radium-contaminated materials. Since radium is in
a form that is relatively insoluble, and since migration of
radiological .contaminants into the ground water or surface wate~
has not been noted, ingestion or contact with contaminated gr8und
water or surface water are not among the principal potential
exposure pathways. Each of the three principal exposure routes
resulting from the radium contamination on the 1000 West
Louisiana properties will be discussed briefly in terms of the
potential health risks associated with that exposure route. In
addition, the health risks associated with ingestion of the
nonradiologically contaminated soil present on the properties
will be discussed.
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
highly ionizing 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 increase the occurrence of lung cancer in uranium miners.
Dispersion quickly dilutes radon emanating from radium-
contaminated ground. This mechanism will minimize the radon
concentration in the air above the open areas of the 1000 West
Louisiana properties to such an extent that no one living near
the properties is presently at risk from exposure to radon and
its associated decay products from this source. Radon decay
products can concentrate to unacceptable levels in buildings
built over contaminated ground if those buildings are energy
efficient, that is, have little exchange of indoor air with
outdoor air. The Creative Illumination building on the 1000 West
Louisiana properties exhibits 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 fu~ur. risks for the following reasons. First, the
building i.not energy efficient. Second, the duration of
exposure i. limited due to the fact that people work there rather
than live there. Finally, during the times that people are
working there, radon levels, and consequently exposures to radon,
are reduced because the air exchange rate with the outdoors
increases when people are entering and leaving the building.
Although the present public health risk from radon decay
product exposure at the 1000 West Louisiana 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 is spread closer to potential receptors, especially if
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1 0
it is used as fill or construction material, or (2) if any of the
bUildings on the 1000 West Louisiana properties are sealed to
make them mOre airtight, or (3) if the properties are eVer
redeveloped for any USe that involves OCCupancy in enclosed,
well-sealed structures. The Public Health and Environmental
Assessment for the 1000 West Louisiana properties, summarized
below and contained in Appendix C of the Operable Unit III 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 G, the largest
contaminated area on the 1000 West Louisiana properties
representing about 97% 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
0:66 WL with an estimated maximum concentration of 6.54 WL. The
radon decay product concentration in a typical United States home
is 0.005 WL and the relevant and appropriate EPA standard, 40 CFR
Part 192, is Or02 WL. The average project~ cancer risk
(exCluding background) to individuals Working in such a bUilding
ranges from 700 to 2,300 cancer deaths per 10,000 persons
exposed. The average prOjected cancer risk to individuals living
in such a bUilding ranges from 3,100 to 6,700 cancer deaths per
10,000 persons exposed.
These risk values can be compared to the average projected
cancer risk if the radon decay product concentration in the
bUilding was 0.02 WL, EPA standard. In this case, the average
projected cancer risk to individuals working in such a bUilding
ranges from 23 to 91 cancer deaths per 10,000 persons exposed.
The average project~ 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 that of a typical United States home, 0.005 WL, then
the aVerage project~ cancer risk to individuals living in the
bUilding wOUld range from 33 to 130 cancer deaths per 10,000
persons expos~. It should be noted that these average projected
cancer risk numbers do not include the EPA-estimat~ spontaneous
risk of lung cancer, that is, the risk not attributable to either
smoking or radon. Table 2 presents the information stat~ 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
contaminat~ area a reasonably uniform irradiation OVer the whole
bOdy. The greater the duration or intensity of this exposure,
the larger the dose, and hence the greater the risk of adverse
health effects. In the case of the 1000 West LOUisiana
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Scenario
RadOn Decay Products:
Building constructed
over Area G
EPA Standard*
Typical U.S. Home
Gamma Radiation:
Building construct~d
over Area G
EPA Standard*
Back ground
11
Table 2
PROJECTED CANCER RISKS
OPE~A8LE UNIT III
DENVE~ RADIUM SITE
Excosure
Average Cancer Deaths
Per 10,000 Persons Excosed
0.56 WL Workplace 700 to 2300
Residential 3100 to 6700
0.02 WL Workplace 23 to 91
Res i dent ia 1 130 to 500
0.005 WL Residential 33 to 1 30
29 ..uR/hr Work place 40**
Residential 100**
20 J.lR/hr Workplace 31**
Res i dent i a 1 53**
15 ,uR/hr Res i den t i a 1 27
,
* 40 CFR Part 192
** In addition to risk from exposure to background gamma radiation levels.
'"
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1 2
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 1000 West Louisiana properties
was disturbed and misused or if the area was redeveloped. If a
bUilding was constructed OVer Area G, the largest area of
contamination on the 1000 West Louisiana properties, the
estimated annual dose to a person working in the bUilding
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1 3
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 1000 West Louisiana properties and dust control
measures ordinarily employed during excavation have been shown to
provide sufficient control of exposure from this source.
Interior surfaces of the Creative Illumination building have
excessive levels of long-lived, alpha-emitting radionuClides.
There is a possibility that persons working in this building may
inhale or ingest some of the radioactivity. It is not Possible,
however, to derive a quantitative current health risk from these
excessive surface contamination levels without making highly
speculative and subjective assumptions. For these reasons and
the ones stated above, EPA acknowledges the human exposure
pathway resulting from inhalation and ingestion of radionuclides,
b~t no quantitative risk numbers were developed in the Public
Health and Environmental Assessment for the 1000 West Louisiana
properties.
Ingestion of Nonradiologically Contaminated Soil:
The Public Health and Environmental Assessment quantifies
risk to human health from ingesting soil containing low-levels of
certain nonradiological carcinogenic contaminants which were
found in discrete locations on the 1000 West Louisiana
properties. The average projected cancer risks from this type of
exposure range from 0.051 to 0.093 cancer deaths per 10,000
persons exposed. These risks are several orders of magnitude
lower than the estimated risks. resulting fro~ exposure to the
radiological contamination on the property. Nonetheless, the
presence of nonradiological contaminants on the site will be
explicitly considered in all health and safety provisions of the
cleanup.
It is clear that a release or substantial threat of release
of a hazardous substan~e or pollutant or. contaminant into the
environment has occurred at the 1000 West Louisiana 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 1000 West
Louisiana properties is justified.
Enforcement
A detailed responsible party search for the entire Denver
Radium Site has been initiated. Regarding the 1000 West.
Louisiana properties, records indicate that the Chemical Products
Company, which may have been a division of the Ludlum Steel
Company, operated a processing facility at this location from
1918 to 1921, the time of apparent disposal of ore processing
wastes containing, among other contaminants, radium, the
hazardous substance of concern. Sources also indicate that the
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Chemical Products Company may have been associated with the are
Products Company. EPA is attempting through the responsible
party search to trace the Chemical Products Company or any
associated Companies to a viable, preSent-day entity. At thLS
time, the responsible party search has not revealed that the
present owners of the 1000 West Louisiana properties have any
record of having been connected with the activities that caused
the site to be radiologically contaminated.
14
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 1000 West
Louisiana 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 and remedial
action and Will attempt to recover EPA's response costs from the
responsible parties.
Community Relations Histor~
On August 1, 1987, and again on August 2, 1987, the Proposed
Plan for the 1000 West Louisiana properties was Published in both
the Rocky Mountain News and the Denver Post. The disPlay ads
announced the August 3 through 21, 1987 public comment period and
the August 17 public meeting, gave a brief description of the
remedial action alterna~ives, 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 III FS, was mailed to the approximately 300 names on the
EPA-compiled Denver Radium Site mailing list.
On JUly 24, 1987, EPA met with the owners and tenants of the
1000 West Louisiana properties. The owners and tenants who
attended the ...tinq expressed concern about adverse publicity
which they 81ght receive resulting from any press coverage of
EPA's Propo88d 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 17, 1987, EPA
held a pUblic meeting conCerning the 1000 West Louisiana
properties. Attendance was poor. Major concerns raised were
from neighboring homeowners who questioned whether their homes
were contaminated with material from the 1000 West Louisiana
properties and who were concerned about the poor condition of the
fence surrounding the vacant lot. Another major concern raised
during the public meeting was a question of why remedial action
at the Site would be so costly.
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1 5
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 1000 West
Louisiana properties. The community has reservations about any
temporary response action which EPA may take at the 1000 West
Louisiana properties because of concerns that the State of
Colorado will not make available a permanent disposal site far
this material and, therefore, no permanent measures will ever be
implemented at the 1000 West Louisiana properties. The portion
of the community in the vicinity of the Card Corporation property
(See Figure 1) strongly opposes temporary storage at the Card
Corporation property, Operable Unit 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 became
p~rmanent, resulting in a decrease in property values in the
area.
The Responsiveness Summary attached to the Record of
Decision 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 III FS.
Alternatives Evaluation
EPA evaluated potential remedial action alternatives for the
1000 West Louisiana 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 on 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 121 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 applicable or
relevant and appropriate, and that utilizes permanent solutions
and alternative treatment technologies or resource recovery
technoloqi.. to the maximum extent practicable. Additionally,
SARA Sect1~ 121 and the guidance documents referenced above
require EPA to give.preference to remedies which employ treatment
which permanently and significantly reduces the toxicity,
mobility, or volume of hazardous substances as their principal
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
properties. 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 1000 West Louisiana properties.
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1 6
(See Table 5-1 of the Operable Unit III FS.) Rased uoon 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
1000 West Louisiana properties. An example of this SCoping
process was the elimination of onsite biological treatment from
further consideration because biological processes capable of
detoxifYing radioactive contaminants do not exist. Appendix E of
the Operable Unit III FS illustrates the SCoping process and
Table 5-2 of the Operable Unit III FS details the results.
Section 121(b)( 1) of SARA requires that an assessment of
permanent solutions and alternative treatment technologies or
resource recovery technologies that, in whole or in part, will.
result in a permanent and significant decrease in the tOXiCity,
mobility, or volume of the hazardous substance, POllutant, or
contaminant be conducted. As part of this process, EPA evaluated
permanent solutions to the problems associated with the specific
hazardous substances present on the 1000 West Louisiana
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 prescreened based on
their suitability to abate the threat at the 1000 West Louisiana
properties. Source control measures are intended to contain the
hazardous substances onsite or eliminate the potential for
contamination altogether by transporting the hazardous substances
to a safer location. Management-of-migration actions are taken
to minimize and mitigate the migration of hazardous substances.
The result of the prescreening of both source control ~nd
management-of-migration measures based on their suitability to
abate the threat at the 1000 West Louisiana properties is
presented in Table 5-3 of the Operable Unit III 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
(includinq 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.
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1 7
Remedial action alternatives de' ~loped in the Operable
FS for the 1000 West Louisiana f :operties Were:
9.
10.
Unit :::
1 .
No Action
2 .
Deferred Removal, OffE te Permanent Disposal
3 .
Onsite Reprocessing/Tr atment, Offsite
Permanent Disposal
4 .
In-Situ Vit~ification
5 .
Onsite Permanent Dispo 11
6 .
Offsite Permanent Disp ;al
7 .
Onsite Temporary Land: :orage, Offsite
Permanent Disposal
8 .
Onsite Temporary Buildi .g Storage, Offsite
Permanent Disposal
Onsite Temporary Contai ment (Capping),
Offsite Permanent Dispo al
Temporary BUilding Stor ~e at the Card
Corporation Property (0 X), Offsite
Permanent Disposal
Alternat~ves 2, 3, 6, 7, 8, ~
the permanent offsite disposal of
eliminate the need for long-term n
monitoring) at the 1000 West Loui~
3 and 4 involve treatment as their
necessarily reduce the mobility, t
waste. Alternatives 4 and 5 requi
and hence, long-term management an
Louisiana properties. Alternative
containment options - Alternative
containment and Alternatives 7, 8,
on site containment. Finally, No A<
Alternative 1.
. and 10, since they require
:ontaminated material, would
.nagement (including
ana properties. Alternatives
principal element, but do not
xicity, or volume of the
~ permanent onsite remedies,
monitoring at the 1000 West
5, 7, 8, and 9 are
requiring permanent onsite
lnd 9 requiring temporary
:ion was included as
Alternative 6, Offsite Permane .t Disposal, is not
immediately implementable because teState of Colorado has not
at this time designated a facility or the disposal of the Denver
Radium Site wastes. Pursuant to CE CLA Section 104(c)(3)(C)(ii),
it is the responsibility of the Sta ~ to assure the availability
of a disposal site. Also, in order to comply with SARA Section
104(k), and in order to assure that :emedial actions within
Colorado continue, the State must p )vide adequate assurance of
the availability of a hazardous was' 3 treatment or disp6sal
facility within three years from th! effective date of SARA,
October 17, 1986. Although progres~ is being made to this end,
the State does not expect to have a :ully operational disposal
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J8
faCility prior to implementation of any remedial action and
possibly for up to five years. In the meantime, in its present"
uncontrolled state, the radium-contaminated material at the
1000 West Louisiana properties could be misused or inadvertently
spread, possibly increasing the risk to present cr future pUblic
health or the environment. In addition, the cost of final
remedial action is expected to increase due to inflation; the
1000 West Louisiana 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 these 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 at the 1000 West Louisiana properties, develoPing
remedial action alternatives which include temporary resPonse
actions was appropriate. Thus, Alternatives 7, 8, 9, and 10 ~ere
developed to reduce eXisting risks by including temporary
response measures followed by permanent offsite disposal of the
contaminated material when a facility for such disposal becomes
available.
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 HCP and
the OSWER Directive No. 9355.0-19, the remedial action
alternatives develoPed for the 1000 West Louisiana properties
were initially screened using the criteria of cost,
implementability (acceptable engineering practices), and
effectiveness. Table 7-1 in the Operable Unit III 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 screened
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 or exceeds
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, the volume would not be
significantly affected. This remedial action alternative would
provide no Additional benefit to public health or the environment
over other remedial action alternatives to be considered.
Alternative 4, In-Situ Vitrification, 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
1000 West Louisiana properties. The extreme temperature
requirements of this process could cause unknown damage to onsite
structures and buried utilities. Once vitrified, a cap over the
area would be necessary to limit the escape of radon gas; thus,
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19
this alternative does not affect toxicity or persistence of the
contaminated material. Furthermore, the property would have to
be permanently dedicated as a disposal site and measures would
have to be taken to prevent human contact with or disturbance of
the vitrified material. Finally, this 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 regulations on siting permanent disposal facilities,
(6 CCR 1007-1, Part III, 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 environmental conditions be
conducive to continued immobilization and isolation of
contaminants from usable ground water Sources. These criteria
are clearly not met at the 1000 West Louisiana properties which
are located within a metropolitan area, and where the depth to
ground water is only 10 to 15 feet.
With the 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, or offers the potential for better
treatment performance or implementability, lesser adverse
impacts, or lower costs than demonstrated remedial action
alternatives.
Alternative S, Onsite Permanent Disposal, was eliminated
from further consideration because of implementability and
effectiveness factors. The property would have 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 high potential for human disturbance and in an area
where the ground water is fairly close to the surface as it is on
the 1000 West Louisiana 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 regulations
on siting permanent disposal facilities (6 CCR 1007-1, 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. This alternative was therefore eliminated during initial
screening.
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20
The follo~lng 15 a description of the remedial action
alternatives surviVing the initial screening:
1 .
NO'Action
If this remedial action alternati'le were selected, no
action would be taken at the contaminated 1000 ;vest
Louisiana properties. This alternative serves as a
baseline and ~as retained for further analysis and
consideration as required by Section JOO.68(f)( 1 )I'll ~f
the NCP.
2 .
Deferred Removal, Offsite Permanent Disposal
If this remedial action alternative were selected,
removal of the contaminated material at the" 1000 West
Louisiana properties would be deferred until an
approved offsite permanent disposal facility is
identified and made available by the State of Colorado.
Once this facility becomes available, the entire
estimated 16,000 cubic yards of contaminated material
on the 1000 West Louisiana properties including the
estimated 200 cubic yards of contaminated material
present in and around the Creative Illumination
bUilding would be excavated and transported by either
truck or rail for final disposal at this facility. The
1000 West Louisiana 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 16,000 cubic yards of contaminated
material on the 1000 West Louisiana properties would be
excavated and temporarily stored on the site. An
asphalt pad would be constructed on the vacant lot at
1000 West Louisiana Avenue. 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
facility. The 1000 West Louisiana 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 16,000 cubic yards of contaminated
material on the 1000 West Louisiana properties would be
excavated and placed in containers. The containers
would be temporarily stored in a newly constructed
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2 1
bUilding on the 1000 West Louisiana ~roperties.
Security precautions, inspections, and radiation
monitoring of the storage facility 'N'ould be insti':u':ed.
Once a suitable offsite permanent disposal facility
becomes available, the contaminated ~aterial ~ould be
transported by either rail or truck to the faci~it1.
Upon removal of the containers, the building ~ould be
decontaminated and either dismantled or left in place.
The 1000 West Louisiana properties ~ould then be
available for unrestricted use.
9.
Onsite Temporary Containment (Capping),
Permanent Disposal
Offsite
If this remedial action alternative were selected, the
small areas of contamination south of the PCA bUilding
and north of Titan Labels, Inc., would be excavated and
placed on the large area of contamination present on
the northern portion of the 1000 West Louisiana
properties. The area of contamination would then be
capped. Contamination in and around the Creative
Illumination building would be removed and placed in a
temporary building or land storage facility. Access
restrictions would be required to limit disturbance of
the cap. Security precautions, inspections, and
radiation monitoring of the storage facility and the
cap would be instituted. Once a suitable offsite
permanent disposal tacility becomes available, the
contaminated material would be transported by either
rail or truck to the facility. The 1000 West Louisiana
properties would then be available for unrestricted
use.
1 o.
Temporary Building Storage at the Card Corporation
Property (OU X), Offsite Permanent Disposal
If this remedial action alternative were selected,
approximately 200 cubic yards of contamination in and
around the Creative Illumination building 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
1000 West Louisiana properties would be temporarily
stored or contained on the vacant lot at 1000 West
Louisiana Avenue. Security precautions, inspections,
and radiation monitoring of the storage facilities on
both operable units would be instituted. Once a
suifable 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 1000 West touisiana properties, as
well as the Card Corporation property, would then be
available for unrestricted use;
-------
22
. Consistent with Section 300.68(h) of the NC?, the 0SWER
Directive No. 9355.0-19, and the OSWER Directi~e No. 9355.0-21,
the remedial action alternatives remaining after ini~ial
screening were further refined and then Subjected to detailed
analysis. Detailed analysis of each remedial ac~ion alternati~~
entailed evaluation based on the ~hree broad criteria of
implementability, effectiveness, and cost. For each of :hese
broad criteria, EPA identified appropriate and more speci:ic
~component measures~ 50 that the remedial action alterna~i~e5
could be compared to each other using a full array of e~aluatiQn
factors. The component measures derived for implement~bility,
effectiveness, and cost were based upon specific requirements and
criteria contained in Section 300.68(h)(2) of the NC?, 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
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 III FS provides a
comparative review of the remedial action alternatives based upon
each 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 readily available. Removal
of materials from the Creative Illumination building will be more
difficult than removing material from the open areas on the
properties. The necessary equipment and specialists for
implementa~1on 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 Uranium Mill Tailings Remedial Action Project.
No Action and Alternative 2, Deferred Removal, Offsite
Permanent Disposal, are administratively the easiest alternatives
to implement. Alternative 10, Temporary Building Storage" on the
Card Corporation Property, Offsite Permanent Disposal, is in turn
administratively easier to implement than Alternatives 7, 8,
and 9 because Alternative 10 can be accomplished in phases, that
-------
23
is, remediation of the open areas of contamination and
remediation of the Creative Illumination bUilding can be
conducted and entirely completed independent of each other.
Alternative 10, however, has an additional implementation
constraint, that is, an agreement with the Mentor CorpOration,
current owner of the Card Corporation property, to allo~ fer
storage of other Denver Radium Site ~astes on the prope~t'l rnust
be finalized. The need to coordinate and obtain access
agreements ~ith the 1000 ~vest Louisiana property o~ners and the
need to obtain necessary approvals and non-environmental
construction permits from other offices and agencies are
administrative implementation =onstraints common to all of the
remedial action alternatives with the exception of No Action.
All remedial action alternatives except No Action and
Alternative 2 require a limit~d degree of maintenance activities.
The final response action associated with the remedial action
alternatives, permanent offsite disposal, cannot be implemented-
until the State of Colorado provides a facility suitable for the
disposal of this material. This implementation constraint is
common to all of the remedial action alternatives except No
Action.
Effectiveness Analysis:
Alternatives 7 and a are protective remedial action
alternatives in which contaminant-specific ARARs for radium
levels in site soils will be met once the temporary response
actions are completed. Alternatives 9 and 10 are also protective
alternatives. Contaminant-specific ARARs for radium levels in
soils will be met for all areas of the site except the vacant
lot. These ARARs will be met on the lot once the capped material
is removed to the permanent offsite disposal facility.
Alternative 2 will provide no short-term protection of pUblic
health and the environment and will meet the contaminant-specific
ARARs for radium levels in soils only after the contaminated
material is removed to the permanent offsite disposal facility.
No Action will not meet the contaminant-specific ARARs for radium
levels in soils and, therefore, will provide neither short-term
nor long-term protection of public health and the environment.
The Possible resulting exposure would result in unacceptable
risks to public health.
Alternatives 7, a, 9, and 10 will meet contaminant-
specific ARARs for gamma radiation levels and radon decay product
concentrations in the Creative Illumination building once the
temporary response action in the bUilding is completed. In
addition, once the temporary response action is completed, the
alpha radioactivity levels in the Creative Illumination building
will be below State guidelines. Alternative 2 will not provide
the short-term protection of Alternatives 7, a, 9, and to because
these contaminant-specific ARARs and State gUidelines will not be
met until after the State has provided a per~anent offsite
disposal facility to which the contaminated material within and
under the building can be taken. No Action will not meet these
-------
24
Contaminant-specific ARARs or State gUidelines and, therefare,
will provide neither short-term nor long-term protection. The
current and potential exposures 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 materials
on the properties. Although Alternati'les 7, 8, 9, and :0 will
not reduce the toxicity or volume of the radioactive waste, they
transfer the contaminants from an uncontrolled status to a
controlled facility, thereby reducing mObility. In additian, 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.
Alternative 10 is slightly more effective than
Alternatives 7, 8, and 9 since the remediation can be phased las
described under the implementability analysis! thereby removing
or controlling the source of contamination, hence the exposure,
more qUickly than if the remediation could not be phased.
EPA conducted a Public Health Evaluation of Remedial
Alternatives to determine short-term potential for adverse health
effects from human expOsure assOciated with the various remedial
action alternatives. This analysiS, SUmmarized in Appendix G of
the Operable Unit III FS, revealed that all of the alternatives
considered except No Action would result in nearly equivalent
exposures during implementation of the remedy. All estimated
exposures are well below ARARs. EPA also conducted a Public
Health and Environmental Assessment to determine the long-term
potential for adverse health effects associated with the
contaminant levels present on the 1000 West Louisiana properties.
This analysis, summarized earlier in this summary and contained
in Appendix C of the Operable Unit III FS, showed that there
would be a significant increase in public health risk if the No
Action Alternative was implemented at the properties.
The potential for adverse environmental impacts at the
1000 West Louisiana properties is low. However, leaving the
material onsite in an uncontrolled state provides an opportunity
for potential environmental impacts during a catastrophic event,
such as a flood, resulting in a substantial dispersal of the
contaminants.
Cost Analysis: .
No Action is the least costly remedial action alternative
followed by Alternative 2. Alternative 8 is the most expensive
alternative. Alternatives 7, 9, and 10 have mid-range and
similar costs. Table 3 presents a breakdown of each
alternative's cost based upon the component measures of cost
described above. An even more detailed breakdown of each
alternative's cost is provided in Appendix H of the Operable
-------
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c...... C....
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Table
3
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-------
26
Unit rII FS. Section 8 of the Operable Unit I~! FS
sensitivity analysis of these costs.
contains a
In summary, the selected remedy for the 1000 West Louis:ar.a
properties was chosen from the detailed analysis of remedia~
action alternatives. The analysis was based upon component
measures of implementability, effectiveness, and cost. Table ~
outlines the detailed analysis of remedial action alternati~es.
(See also Section 9 of the Operable Unit III FS.)
Selected Remed~
This Record of Decision addresses the contamination present
on the 1000 West Louisiana properties, Operable Unit III of the
Denver Radium Site. This is the fifth operable unit of the
Denver Radium Site for which EPA has selected a remedy. BPA 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. EPA's preferred remedial action
alternative for the 1000 West Louisiana 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 1000 West
Louisiana properties, this alternative cannot be implemented.
EPA has therefore determined that the appropriate extent of
remedy at the 1000 West Louisiana properties is Alternative 10,
Onsite Temporary BUilding Storage at Card Corporation Property
(OU X), Offsite Permanent Disposal. The State of Colorado has
been consulted and concurs with the selected remedy.
Remedial Design for Operable Unit III will include the
selected remedy, Alternative 10, and BPA'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
Des1qn for the 1000 West Louisiana properties, BFA may implement
its preferied alternative, Offsite Permanent Disposal.
Description o~ the Selected Remedy:
The selected remedy consists of one temporary management-of-
migration response action and two temporary source control
response actions followed by one final and permanent source
control response action.
The temporary management-of-migration response action
consists of excavating the small areas of contamination south of
the PCA building and north of Titan Labels, Inc., and placing
this material on the large area of contamination present on the
-------
Table
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'.""..101 '."''''.U'.. .....( 'I." II.. 'l..foIl. .u.. "'811.
..II. ...., "".d. ... '0."11, 01 .01..... II.. .h",
~.II L. "'.. ,.- ..,. 10..814'1" ... . ".,'0"1'
'.lfI." ""III., 8. ..,..... '''.,..... h,U..,.
IJ
(.0
In..,...... .. ... &11."'81'''. ""88'...
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29
vacant lot at 1000 West Louisiana Avenue. A cap would then ~e
placed OVer this .area. The cap will temporarily limit t~e spread
of the contaminated material by wind and water erosion and ""man
activity. The cap will also provide temporary protect:on ~f
human 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 ~ne to three months. Once
in place, the cap will be routinely inspected, and restric~i~ns
on excavation will be instituted to maintain the integrity =f the
cap. The cap will rema~n in place until a permanent offsita
disposal faCility becomes available.
The first temporary source control response action consists
of removing the estimated 200 cubic yards of contaminated
material from under the Creative Illumination building. This
response action involves excavating contaminated soil from the
basement of bUilding and placing this material in containers.
The second temporary source control response action consists of
decontaminating areas of the Creative Illumination bUilding
exhibiting alpha radioactivity. Material generated during the
decontamination will be placed in the containers. Excavation of
the contaminated material from the basement and decontaminating
the surfaces of the bUilding could take three to six months. The
containers of contaminated material would then be transported to
the Card torporation property, Operable Unit X of the Denver
Radium Site, for temporary storage 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 excavating the
material which was temporarily placed under the cap. This
material and any portion of the cap which is contaminated would
then be transported by either truck or rail to the permanent
offsite disposal facility. In addition, all material stored at
the Card Corporation property, including that which came from the
1000 West Louisiana properties, would be transported by either
truck or rail to the permanent offsite disposal facility.
Excavation of the contaminated material under the cap and
transportation of all 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 $3,406,100
based upon a ten-percent interest rate, a five-year discount
period, and a perpetual monitoring period. The cost of this
alternative includes excavation of contaminated soils from
outs~de and in the basement of the Creative Illumination building
and decontamination of this bUilding, placement of the material
into containers, transfer of the containers to the Operable Unit
X property, and placement of the containers within the Operable
Unit X temporary storage facility, and maintenance and monitoring
of" the containers and temporary storage facility for a period of
five years. The cost of this alternative also includes
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30
excavatio~, consolidation, and capping of the material remaining
on the 1000 W. Louisiana property and maintenance and monitorir.;
of the capped area. In addition, the cost of this alternative
includes removal and transport o~ all contaminated material and
the cap to the offsite permanent disposal facility,
decontaminating and, if necessary, dismantling the temporary
storage facility at the Operable Unit X property, and
transporting the decontaminated material to a solid waste
landfill.
Operation and maintenance activities will be required tQ
ensure the effectiveness of the temporary response action. These
activities include site inspections" ongoing radiological
monitoring, and Possible minor repairs to the cap on the
1000 West Louisiana properties or the temporary storage facility
on the Card Corporation property. Also included as an operation
and maintenance activity for cost estimating purposes 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
t~e discounted annual operation and maintenance costs of these
activities using a five-year discount period and a ten-percent
discount rate is $305,800. 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 1000 West Louisiana properties summarized
earlier in this document clearly shows that there would be a
significant increase in the risk of contracting lung and other
cancers if No Action, Alternative 1, 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 effective 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 1000 West
Louisiana properties to an offs1te permanent disposal facility.
Further, because the offs1te permanent disposal facility would be
designed t~ isolate the contaminated material from man and the
environment tor 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 Alternatives, summarized in Appendix G of
the Operable Unit III 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
-
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3 1
exposed to hazards during implementation of each alternati"le
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 heme
located outside of the property boundary, a transportation
worker, and an onlooker present during trlick transportation ef
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 action 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 estimates that the number of non-fatal
injuries to cleanup workers would range from 0.130 to 0.455 for
the type of work to be conducted during remedial action at the
1000 West Louisiana properties and the number of fatalities would
range from 0.014 to 0.138. (See report entitled Operable
Unit III, Public Health and Environmental Assessment, Dose
Commitments.) These numbers can be significantly reduced by
hiring competent and properly trained construction contractors
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 selected remedy will meet all ARARs identified for the
1000 West Louisiana properties. In addition, from the analyses
conducted in the Public Health and Environmental Assessment and
the Public Health Evaluation of Remedial Alternatives and because
of. the permanence associated with the design of the offsite
disposal facility, EPA has concluded that the selected remedy
would be protective of public health and the environment.
Consist~ With Other Laws: Pursuant to SARA Section
121(d), remedial actions shall attain a degree of cleanup of
hazardous substances, POllutants, and contaminants released into
the environment and control of further release which at a 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
environmental or facility 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
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32
for the Card Corporation property (OU X). The State responded ~~
this request on January 21, 1987, with a list of Colorado
requirements which pertained to the entire Denver Radium Site.
EPA classified all Federal and State public health and
environmental requirements applic~ble or relevant and appropria~e
to the 1000 West Louisiana 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 Section 4 and Appendix 0 of the Operable Unit
III FS. Other Federal and State criteria, advisories, and
gUidance were also considered. Tables 0-1 through 0-4 in
Appendix 0 of the Operable Unit III FS contain a brief
description of each potential Federal and State requirement
identified and EPA's analysis of each requirement's applicabi:ity .
or relevance and appropriateness to the 1000 West Louisiana
properties. EPA has determined that the selected remedy will
meet all applicable or relevant and appropriate public health and
environmental requirements of Federal and State laws and,
therefore; no SARA Section 121(d)(4) waivers need be invoked. A
brief discussion of ARARs for the 1000 West Louisiana properties
is provided below.
The EPA Standards for Remedial Action at Inactive Uranium
Processinq Sites, 40 CFR Part 192, are one of two contaminant- .
specific ARARs identified for the 1000 West Louisiana 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 necessarily applicable to
the 1000 West Louisiana properties since the standards apply only
to certain specifically designated sites where uranium was
processed, the standards are relevant and appropriate to the
1000 West Louisiana 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 residues from both processes enter the environment
through the same exposure pathways; and (4) the adverse health
concerns resulting from exposure to the residues from both
processes 'are the same.
The portion of the standards relevant and appropriate to the
contaminated soil on the 1000 West Louisiana properties and the
portion which serves 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
reasonable 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 hot exceed the
background level by more than -
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33
( 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 1000 West Louisiana properties is 40 CFR
Section 192.12(b) which states:
( b)
In any occupied or habitable building -
( 1 )
The objective of remedial action shall be, and
reasonable effort shall be made to achieve, an
annual average (or equivalent) radon decay product
concentration (including background) not to 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 more than 20 microroentqens
per hour.
( 2 )
(40 CFR Section 192.12(b).)
The second contaminant-specific ARAR identified for the
1000 West Louisiana properties is the Nuclear Regulatory
Commission Standards for Protection Against Radiation, 10 CFR
Part 20. These regulations establish standards for protection
against radiation hazards arising out of activities under
licenses issued by the Nuclear Regulatory Commission (NRC).
Because these standards apply to licensed NRC facilities, they
are not applicable to the 1000 West Louisiana properties.
However, EPA has determined that portions of the regulations are
relevant and appropriate to individuals who would be conducting
the remedial action on the 1000 West Louisiana property. In
addition, these regulations are incorporated by reference in the
Occupational Safety and Health Administration Standards, 29 CFR
Parts 1910 and 1926, which, due to the mandate contained in SARA
Section t2~~ now apply to employees involved in responses covered
by CERCLA.
Of particular importance is Appendix B of 10 CFR Part 20
which provides limits for airborne concentrations of natural
uranium, thorium-230, and radium-226. Gamma radiation dose
standards for individuals in restricted and unrestricted areas
are cited in 10 CFR Sections 20.101 and 20.105, respectively.
These 10 CFR Part 20 standards along with th& 40 CFR Part 192
standards are summarized in Table s.
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Table 5
POTENTIAL CONTAHINANT-SI'ECIFIC ARAR'S
OI'EItADI.E UNIT 111. UENVt:R RADII!" SI'1'£
Standard, Requlrellent,
Crher"'. or U..hLlUon
Regulatory Agency
~ of Contaalnant
Ci'!IIInclit s
FEDERAL
U.S. £PA-40 CFR 192,
Subpart I-Standards
aadl...-226
Concent n Lion
5 pCI/S above background
wHbln ]5 c. of the sur-
face ,easured over a
100-. area
Standards Cor cicalilip ut 0I,clI IIIII
Nuclear Regulatory
C08lll11iliion (NKC)
]0 c.'a 20
) b
5 pCt/- ,)Unrestrfcted areac PoInt of compll&lllce iii allY location wJlhl1i IIIIC.
100 pCl/. , RestrlcLed area
Uran lua-natura 1
AlrLorlle Concelltra-
tJ 01111
1110r huu- 210
AJrborue Concentra-
tJuna
) PCI/II), UnrestrIcted area
)0 pCI/.. . Rcstrlcted Llrea
PoInt of cOlOl,lIulIl:e b iJny liJcUI 1011 wJlldll :olle.
)
) pCt/1I , UnrestrIcted area
)0 pCI/. , Restricted area
5 re8/yr, (5,000 8re8/yr)
Rutrlcted a.-ea
500 ..-e./yr, Unrestricted
a.-ea .
Radlum-226 AI.-borne
ConceULratJonli
Point of COIDI,IJLlncc iii LIllY 10clltJoil wi Udll sl te.
G&I/IIIIIa Radlationa
PoInt of cOlllpllLlllcc Iii UIlY local 1011 with III l;flei :olte
would b~ u.u-c Ii la- h: led tu," rClUcdl"l Ju.. wUlkcr:;.
-a
Relevant and apl,roprlatc litandurd but not aa protective a8 OU,er Guidance, aee Table 4-).
b
An um-elltrlcted area Ia regarded as any place a.-ound a vallte consolidation/storage areu faclilly w'lere accc:.:o 1:0 1101 CUIIII"""cll.
cA .-elltrlcted area Is resarded 88 any place around a vaute consolldatlon/utorage. area w'u:rc UC(:C:.:; l:i cUIII....Ie.I.
Hote;
WL .. Ilo.-U ns I.eve I .
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35
EPA has identified two potential location-specific ARARs for
the 1000 West Louisiana properties, the National Historic
Preservation Act and the Archeological and Historic Preservation
Act. The Colorado Historical Society is considering a
preliminary determination that the Creative Illumination bUilding
is eligible for inclusion in the National Register of Historic
Places. Remediation of the contamination in and around the
Creative Illumination bUilding is not likely to adversely affect
the historic character of the bUilding. Nonetheless, EPA Will
continue to cooperate With the Colorado Historical Society by
providing documentation lending historical Significance to the
bUilding and will adhere to the requirements of the
aforementioned Acts. Currently there are no identified State
location-specific ARARs for the 1000 West Louisiana properties.
Action-specifiC ARARs are technologY-based restrictions
triggered by specific types of remedial measures under
consideration. Once the remedial action alternatives were
developed in the Operable Unit III 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 6 of
the Operable Un~t III FS. EPA then identified numerous action-
specific ~~s for each of the action elements. These action-
specific ~ARs were evaluated in Appendix D ot the Operable Unit
III FS and are presented in Table 6-3 of the Operable Unit III
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
1000 West Louisiana 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 dose, 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 1000 West Louisiana properties. For the
remediation of the alpha radioactivity contamination in the
Creative IllwBination bUilding, EPA considered the Colorado
Department ot Health gUidelines for fixed and removable alpha
radioactivity. The State gUideline for fixed alpha radioactivity
is 300 dpm/IOO cm2 and for removable alpha radioactivity,
20 dpm/100 cm2.
SARA Section 121(d)(3) codifies EPA's off site disposal
pOlicy, which requires that offsite disposal of any hazardous
sUbstances, pollutants, or contaminants trom a Superfund site
take place only at a facility that is in compliance with
applicable Federal law and all applicable State requirements.
Furthermore, the unit to which these wastes are transported must
not be releasing any hazardous waste or constituent to ground
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36
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 Section 104(c)(3) obligations, to
assure the availability of a disposal facility which is in
compliance with EPA's offsite disposal policy.
Cost-effectiveness and Utilization of Permanent Solutions
and Alternative Treatment Technoloqies or Resource Recovery
Technologies to the Maximum Extent Practicable: Alternative 10,
Temporary Building Storage at the Card Corporation Property (au
X), Offsite Permanent Disposal, is a cost-~ffective 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 two of the alternatives
which were less costly, Alternatives t and 2. Alternative 8
would be much more expensive to implement than Alternative 10
without providing a commensurate increase in effectiveness. As
discussed earlier in this summary, Alternatives 7, 8, 9, and 10
provide. nearly equivalent degrees of effectiveness; however,
Alternative 10, since it can be conducted in a phased manner, is
slightly more effective than Alternatives 7, 8, and 9.
The selected remedy will address the principal threat at the
1000 West Louisiana properties. However, the selected remedy
does not satisfy the statutory preference for treatment as a
principal element. As part of the selection of remedy process,
EPA evaluated permanent solutions to the hazards associated with
the specific substances present on the 1000 West Louisiana
properties. However, since the hazardous substance associated
with the 1000 West Louisiana 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
treatment known today. Most treatment and resource recovery
technoloq1.. concentrate the radioactive elements present in the
waste, increasing toxicity without sufficiently reducing volume
or mobility. These treatment and resource recovery technologies
will leave a waste product which is still radioactive.
NonetheleS8, EPA considered several treatment and resource
recovery technOlogies in the technology scoping and screening
phase and even the initial alternative screening stage of the
Operable Unit III 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 present on the 1000 West Louisiana properties.
-------
( 1 )
" ( 2 )
( 3 )
( 4 )
( 5 )
( 6 )
37
Future Actions
The future remedial activities that are required to complete
remedial action at the 1000 West Louisiana properties are:
Design remedial action.
Enter in to State Superfund Contract with State of Colorado.
Conduct temporary response a.ction's for contamination present
.on 1000 West Louisiana properties.
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 1000 West Louisiana.
properties and the Card Corporation property and transport
it to the permanent disposal facility.
Confirm that the 1000 West Louisiana properties have been
decontaminated to conform with the requirements of ARARs and
can be made available for unrestricted use.
Schedule
Dates for completing key milestones leading to remedial
action at the 1000 West Louisia~a properties are highlighted
below:
( 1 )
( 2 )
( 3 )
Complete design of remedial action by September 30, 1988.
Finalize 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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