f'
"
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United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EP A/RODIR08-90/034
August 1990
(9
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~ '11,..1 '2.14.9 '2..
&EPA
Superfund
Record of Decision:
Monticello Mill Tailings (DOE),
UT
-------
502\12-101
REPORT DOCUMENTATION II. REPORT NO.
PAGE EPA/ROD/R08-90/034
I 2.
3. Recipient'a Accea,.;on No.
4. l1U. and SubdUe
SUPERFUND RECORD OF DECISION
Monticello Mill Tailings (DOE), UT
First Remedial Action
7. Author(a)
5. Reporl Date
08/22/90
6.
8. Perlorming Organlzadon Rept No.
g. PerformIng Orgalnlzallon Name and Addreu
10. ProjectlTaaklWork Unit No.
II. Contrsct(C) or Grant(G) No.
(C)
(G)
12. Sponeoring Organization Neme and Addreaa
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type 01 Report & Period Covered
Agency
800/000
14.
15. Supplemenlary Notea
18. Abatracl (LImit: 200 worda)
The 300-acre Monticello Mill Tailings site is comprised of a 78-acre inactive uranium
and vanadium milling operation and affected peripheral properties in Monticello, San
Juan County, Utah. Surrounding land use is rural residential and agricultural. The
site overlies a shallow alluvial aquifer, and part of the site lies within the
floodplain of Montezuma Creek. Approximately 18-acres of wetlands adjacent to Montezuma
;reek also have been contaminated by tailings. In 1940, the site was operated as a
vanadium ore-buying station. Milling of ore began in 1942, and a vanadium/uranium
sludge product was produced onsite from 1943 to 1944. Onsite uranium milling processes
began in the mid-forties and continued until 1959. Mill tailings from these operations
were disposed of in four onsite tailings piles that are within the floodplain of the
Montezuma Creek. The mill was permanently closed in 1960, and the tailings piles were
covered and vegetated. From 1964 to 1965, the entire plant was dismantled and
foundations were partially buried onsite along with contaminated material. Onsite and
offsite soil contamination is the result of wind and surface water erosion of the
contaminated tailings piles with subsequent deposition elsewhere. In 1972, 15,000 cubic
yards of contaminated soil were excavated and disposed of on the onsite tailings piles.
(See Attached Page)
17. Documenl Analyala L Deacrlplors
Record of Decision - Monticello Mill Tailings (DOE), UT
First Remedial Action
Contaminated Media: soil, debris
Key Contaminants: metals (arsenic, chromium, lead), radioactive
materials (radium-226)
b. Idenllflera/Open.Ended Terma
c. COSA 11 Reid/Group
18. AvaUabllity Slatemeni
19. Security Clua (Thie Report)
None
21. No. 01 Pagea
72
~
20. Security Clue (Thie Pege)
None
22. Price
(See ANSI.Z39.18)
See Ins/rucaone on Reverse
1272 (4.77)
(Formerly NTIS-35)
Department 01 Commerce
-------
:
EPA/ROD/R08-90/034
Monticello Mill Tailings (DOE), UT
7irst Remedial Action
Abstract (Continued)
Site investigations from 1989 to 1990 identified the presence of onsite and offsite
radioactively-contaminated soil and ground water, and elevated concentrations of metals
within the tailings piles. This Record of Decision (ROD) addresses remediation of two
Operable Units (OUs): the 78-acre Millsite area (OU1), and the 240-acres of peripheral
properties (OU2). A subsequent ROD will address remediation of ground water and surface
water once the source areas have been removed. The primary contaminants of concern
affecting the soil and debris are metals including arsenic, chromium, and lead; and
radioactive materials including radium-226and radon.
The selected remedial action for this site includes dewatering and excavating 1.5 million
cubic yards of tailings, contaminated soil, and process-related material from the
contaminated tailings piles; consolidating these materials in an onsite repository that
will be built one mile south of the existing millsite; diverting Montezuma Creek to allow
for the relocation of mill tailings and contaminated floodplain soil, excavating 300,000
cubic yards of contaminated soil from the peripheral properties, followed by eventual
consolidation of the soil within the repository; backfilling excavated areas with clean
fill; treating surface runoff and construction/dewatering water collected during
construction using evaporation ponds, reverse osmosis, or another technology and
discharging the treated water to Montezuma Creek; disposing of any treatment residuals
within the repository or at an offsite facility; covering the repository with a clay and
multi-media cap; revegetating the millsite and repository site; monitoring air, ground
water and surface water; and implementing institutional controls and site access
:estrictions. The estimated capital cost for this remedial action ranges from
$64,787,500 to $70,600,000 (based on the cost of engineering controls), which includes an
annual O&M cost of $40,846 for 24 years.
PERFORMANCE STANDARDS OR GOALS: Federal standards for radium-226are 5 pCi/g above
background in the surface 15 centimeters of soil, and 15 pCi/g above background level for
radium-226in the deeper 15 centimeters - thick layer. Because the background level at
the site is radium-2261.0 + 0.4 pCi/g, excavation levels were set at 6 pCi/g for
surficial soil, and 16 pCi/g for soil greater than 15 centimeters deep. The Federal
standard of 20 pCi/m2/sec for radon emissions will also be met.
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DECLARAT:ON FOR THE RECORD CF DECIS:ON
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MONTICELLO MILL TAILINGS SITE
DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Monticello Mill Tailings Site
San Juan County. Utah
Statement of Basis and Purpose
This decision document presents the selected remedial action for the
Monticello Mill Tailings Site (Operable Units I and II) in San Juan Coun~y.
Utah. The selected remedial action was chosen in accordance with the
requirements of the Comprehensive Environmental Response. Compensation. and
Liability Act of 1980. as amended by the Superfund Amendments and
Reauthorization Act of 1986 and the National Oil and Hazardous Substances
Pollution Contingency Plan. This decision document explains the factual and
legal basis for selecting the remedy for this site.
The State of Utah and the Environmental Protecti)n Agency concur with the
selected remedy. This remedial action decision ~s based on the administrative
record for this site.
Assessment of the Site
Actual or threatened releases of hazardous substances from this site. if
addressed by implementing the response action selected in this Record of
Decision. may present an imminent and subs"antial endangerment to public
health. welfare. or the environment.
not
DescriPtion of the Selected Remedv
The selected remedies for Operable Units I and II are described in this Record
of Decision. Final remediation of Operable Unit I. Mill Tailings and Millsite
Property. requires completion of the selected remedy for Operable Unit II.
Peripheral Properties. Remediation of Operable Unit III. Ground Water and
Surface water. will be addressed in a separate Record of Decision as it
requires implementation of the selected remedy for Operable Units I and II. A
summary of the extent of contamination in Operable Unit III has been included
in this Record of Decision to assist in defining the extent of contamination
from the millsite.
Operable Unit I - Mill Tailings and Millsite Property
Remediation of this operable unit is the first of three final actions that are
planned for the site. Operable Unit I addresse~ the source of contamination
by excavation of uranium mill tailings and other by-product materials (as
defined in Section 11(e)(2) of the Atomic Energy Act of 1954 as amended. and
in 40 CFR Part 192 as "tailings or waste produced by the extraction or
concentration of uranium from any ore processed primarily for its source
material content"). contaminated buildings and equipment material. ore. and
contaminated soils on the millsite that p~esent a source of ground-water
contamination or threat of direct exposure. After excavation. the
contaminated material will be contained in a repository that will be built
approximately one mile south of the present millsite. The remedy addresses
the principal threats at the site. which are associated with radon emmisions
and direct exposure to gamma radiation from the existing mill tailings piles.
1
-------
The major components of the selected remedy for Operable Unit I include:
Removal of approximately 1.5 million cubic yards of tailings. ore. a~d
process-related material (by-product material. cOntaminated building
materials. and mill equipment) from their present location where they
are within the floodplain of Montezuma Creek or are in contact with the
ground water to a repository one mile south of the present mill tailings
Site. The repository would be designed to meet requirements of the
Uranium Mill Tailings Radiation Control Act of 1978 and the Uranium Hi:l
Tailings Remedial Action Program technical standards. These standards
require the repository be effective for up to 1.000 years to the extent
reasonably achievable. and that the escape of radon gas be controlled tJ
within acceptable limits. This remedy has been determ~ned to be an on-
site remedy pursuant to the National Contingency Plan.
Capping the repository to protect the ground water. isolate the waste
from the environment. and to control the escape of radon gas:
Construction of surface-water controls necessary during remedial action
construction activities and for the repository:
Treatment of contaminated runoff water and conStrUction/dewatering water
collected during construction activities in accordance w~th applicable
standards prior to release to the environment. with disposal of
residuals in the repository or another licensed repository. Treatment
may be performed by evaporation. reverse osmosis. or another appropriate
technology and will be determined during the design stage;
Revegetation of the millsite and repository site:
Long-term surveillance and environmental monitoring to ensure the
effectiveness of the remedial action and compliance with ground-water
and surface-water standards;
Land acquiSition and access control as necessary.
Operable Unit II - Peripheral Properties
Remediation of this operable unit is the second of the three final actions
planned for the site. Remedial action at Operable Unit II addresses the
removal of radioactively contaminated soils and processing by-product
materials located on peripheral properties. The remedy would reduce radiation
expOsure to the public by either removing contaminated materials by
conventional construction techniques or environmentally sensitive construction
techniques. or by proposing the use of supplemental standards. As allowed
under the principal relevant and appropriate requirement. supplemental
standards allows leaving some or all of the contamination in place where
removal would cause undue environmental damage. Materials removed from the
properties would be placed on the existing tailings pile for final disposal
with tailings from Operable Unit I. In areas where supplemental clean up
standards under Title 40 Code of Federal Regulations. Part 192.22 could apply
(the cemetery and densely vegetated hillsides south of Montezuma Creek).
institutional controls may be used to restrict access and control the use of
the land to prevent future exposure.
2
-------
The major components of the selected remedy include:
Removal of an estimated 300.000 cubic yards of tailings from peripheral
properties and eventual disposal in the same repository as described fo~
Operable Unit I;
Vegetation after removal of tailings;
The use of institutional controls. if necessary.
Operable Units I and II are scheduled to be completed over a S-year period.
Reviews of the selected remedy are scheduled under the Comprehensive
Environmental Response. Compensation. and Liability Act at five-year
intervals. commencing with the initiation of remedial action.
Operable Unit III - Ground Water and Surface Water
Remedial action of Operable Unit III addresses clean up of ground-water and
surface-water contamination. The Upper and Lower Montezuma Creek peripheral
properties will also be remediated in this operable unit. During the remedial
action of Operable Units I and II. the characteristics of the ground water in
the alluvial aquifer and the surface water in Montezuma Creek (Operable Unit
III) will be altered. Remedial action construction activities will cause the
following changes:
1.
Surface water. a principal source of ground water. will be diverted.
around the site. This will cause unknown effects in the attenuation
and chemical properties of soils below the site.
The soils in the alluvial aquifer contaminated by mill tailings or
leachate will be excavated to the standards in 40 CFR 192 during the
remedial activities proposed for Operable Unit I. The contaminated
pore water retained in the excavated soils will be removed with the
soils. .
2.
3.
During construction. portions of the site must be dewatered to
facilitate removal activities thus removing a large amount of water
from the alluvial aquifer. All water from dewatering of tailings and
soil and from construction activities will be treated and released to
the environment in compliance with the applicable requirements.
The results of these changes will have an unknown effect on the
characteristics of the aquifer.
Throughout remediation of Operable Units I and II. a ground-water and surface-
water monitoring program of the alluvial and Burro Canyon aquifers will be
conducted upgradient from. downgradient from. and on the millsite. This
monitoring program will continue for three years after removal of the
contaminated material. As monitoring continues during the three year period.
the U.S. Department of Energy. the U.S. Environmental Protection Agency. and
the State of Utah will periodically review the results of the monitoring
program and determine what additional steps. if any. will be required to
complete aquifer restoration. When sufficient data have been gathered through
a focused remedial investigation/feasibility study to warrant a final decision
for ground-water and surface-water restoration. a Record of Decision will be
produced for Operable Unit III.
Institutional controls. including buying or leasing of land and water rights.
will be implemented for Montezuma Creek and the alluvial aquifer prior to
remedial action construction on Operable Units I and II. These controls will
be maintained until such time as a decision is made regarding surface-water
and ground-water remediation.
3
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Declaration of Statutory Determinations
The selected remedy is protective of human health and the ~nvironmen~.
complies with Federal and State of Utah requiremen~s that are l~gally
applicable or relevant and appropria~e to the remedial ac~~on. and is ccst-
effect~ve. This remedy utilizes permanent solutions and alterna~ive trea~men~
(or resource recovery) ~echnologies ~o the maximum extent prac~~cable for ~his
site. This remedy does not sa~isfy ~he statutory preference for treatment as
a principal element for several reasons. Due to the large volume of
contaminated materials. t=eatment is not practicable. Further. none of the
proven treatment technologies available for radiological contaminants reduces
the total volume or toxicity of these contaminants. nor do they irreversibly
reduce contaminant mobility. Technologies that could reduce the total volume
of contaminated soil produce residuals that would present a threat to human
heal~h and the environment.
Because this remedy will result in hazardous substances remaining on site
above health-based levels. a review will be conducted within five years after
commencement of remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
or (Region VIII)
Protection Agency
J>~;2 J- -7d
Date
/) J;F.
. .' {...-
U.S. Departme~ l~ Ene~gy
Idaho Operations Office Manager
.-
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Concurring in this determination:
State of Utah. v
Department of Health
Date
4
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7.0
8.0
9.0
1.0
2.0
3.0
4.0
5.0
6.0
MONTICELLO MILL TAILINGS S~TE
DECISION SUMMARY FOR THE RECORD OF D=:CISrO~1
TABLE OF CONTENTS
Site Name. Location. and Description. . . .
. . . . .
Site History and Enforcement Activities
. . . . . .
. . . .
2.1
2.2
Site History. . . . .
Enforcement Activities
. . . . . .
. . . . . . .
. . . . . .
. . . . . . .
. . . . .
. . . .
Highlights of Community Participation
. . . . . .
. . . . . . . .
Scope of Role of Operable Units Within Site Strategy. .
. . . . .
Summary of Site Characteristics
. . . .
. . . . . .
. . . .
5.1
5.2
5.3
5.4
5.5
Mill Tailings. . . . . . . . . . . . . . . . . . . . .
Soil. . . . . . . . . . . . . . . . . . . . . . . . . . . .
Air. . . . . . . . . . . . . . . . . . . . . . .
Montezuma Creek. . . . . . . . . . . . . .
Ground Water. . . . . . . . . . . . . . .
Summary of Site Risks
. . . . .
. . . . . . . .
Human Health Risks
Environmental Risks
. . . . .
. . . . .
. . . . .
6.1
6.2
. . . . .
. . . . . .
. . . .
Description of Alternatives
. . . . . .
. . . . .
7 . 1
7.2
. . . . .
Operable Unit I -- Mill Tailings and Millsite Property
Operable Unit II -- Peripheral Properties. . . . . . .
Comparative Analysis of Alternatives. . . . .
8.1
8.2
. . . .
. . . . . .
Operable Unit I -. Mill Tailings and Millsite Property
Operable Unit II -- Peripheral Properties. . . . . . .
Selected Remedy
9.1
9.2
. . . . . . . .
. . . . . . . . . . . . . . . . .
Selected Alternatives. . . . . . . . . . . . . . . . . . . .
Significant Differences from the Proposed Plan. . . . . . .
10.0 Statuxory Determinations. .
. . . . . . . . .
. . . .
. . . . . .
10.1 Protection of Human Health and the Environment. . . . . . .
10.2 Compliance with Applicable or Relevant and
Appropriate Requirements. . . . . . . . . . . . . . . . . .
10.3 Cost-Effectiveness. . . . . . . . . . . . . . . . . . . . .
10.4 Utilitization of Permanent Solutions and
Alternative Treatment Technologies to the
Maximum Extent Practicable and Preference
for Treatment as a Principal Element. . . . . . . . . . . .
APPENDICES
Appendix A
Monticello Mill Tailings Site Responsiveness
Summary. . . . . . . . . . . . . . . . . . . . .
Federal and State of Utah Applicable or Relevant
and Appropriate Requirements. . . . . . . . . .
. . . . .
Appendix 8
. . . . .
i
1
4
4
5
5
6
7
7
7
9
:'0
11
12.
12
16
17
17
19
21
21
27
29
29
37
37
37
38
44
44
A - 1
8 - 1
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Figure 1-1.
Figure 1-2.
Figure 7-1.
Figure 9-1.
Table 5 - 1.
Table 8-1.
Table 8-2.
Table 9 - 1.
Table 9-2.
FI GURE S
Monticello. Utah. Regional Location Map
. . . . . .
Monticello Millsite Site Plan
. . . . .
. . . . . .
Peripheral Properties
. . . .
. . . . . . .
. . . . . . .
On-Site Stabilization South of the Present Site
Operable Unit I - Alterna't:ive 1 . . . . .
. . . . .
TABLES
Average Radium-226 Concentrations in Tailings
Piles and Millsite Soil. as Compared to
Clean-up S't:andards . . . . . . . . . . . . .
. . . . . . .
Summary of Comparative Analysis of Alternatives
for Operable Unit I. Mill Tailings. . . . . .
. . . . . .
Summary of Comparative Analysis of Alternatives
for Operable Unit II. Peripheral Properties. .
Estimated Costs of the Selected Remedy for
Operable Unit I . . . . . . . . . . . . . .
. . . . . .
. . . . . . . .
Estimated Costs of the Selected Remedy for
Operable Unit II . . . . . . . . . . . . .
. . . . . . . .
Table A3-1. Present Worth Calculations for the Monticello
Millsite Project. . . . . . . . . . . . . .
Table B-1.
Table B-2.
. . . .
Applicable or Relevant and Appropriate Requirements:
Federal Standards. Criteria. and Limitations. . . .
Applicable or Relevant and Appropriate Requirements:
State of Utah Standards. Criteria. and Limitations
. . . .
ii
2
3
20
30
8
22
24
33
35
A - 12
B-;!
B-6
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MONTICELLO MILL TAILINGS SITE
DECISION SUMMARY FOR THE RECORD OF DECISION
1.0
SITE NAME. LOCATION. AND DESCRIPTION
The Monticello Mill Tailings Site (the site) is located in San Juan County.
Utah. near the City of Monticello (Figure 1-1). in the southeastern corner :f
Utah. Mill tailings and associated contaminated material remain on the
millsite as a result of milling for uranium and vanadium. The tailings piles
are within the floodplain of Montezuma Creek and are partially in contact ~~th
an alluvial aquifer. Tailings particulate material has been windblo~n and
transported by surface water to properties peripheral to the millsite. The
site is bordered by land owned by the U.S. Department of the Interior's Burea~
of Land Management. the City of Monticello. and private owners. No residences
are located within the millsite boundary. but residences are adjacent to the
north and east edges of the site. The City has a population of approximately
1.900.
The site includes the millsite. where radioactive tailings and associated
contaminated material are located. and peripheral properties. The millsite. a
78-acre tract within the City of Monticello. is owned by the U.S. Department
of Energy. During the period of mill operation. private land to the north and
south of the existing site was leased for the stockpiling of ore. The former
ore-stockpile areas and areas contaminated by airborne-tailings particulate.
matter or surface-water transport cover approximately 300 acres around the
site and contain most of the estimated 300.000 cubic yards of peripheral
property material to be remediated. Peripheral properties also include the
bed and banks of a 3.3-mile reach of Montezuma Creek between the City of
Monticello and Vega Creek.
The millsite consists of the former mill area and the tailings-impoundment
area. An estimated 100.000 cubic yards of contaminated material have been
identified in the mill area: and approximately 1.4 million cubic yards (2
million tons) of tailings. contaminated soil. by-product material. and
contaminated building material are located in the tailings-impoundment area.
Figure 1-2 depicts the millsite property. associated buildings. and tailings
piles.
The tailings are contained in four piles. These piles are located within the
floodplain of Montezuma Creek. They are also partially in contact with a
shallow alluvial aquifer underlying the site. This alluvial aquifer is not
presently used as a private or public drinking water source. However. it does
have a potential for agricultural use. A deeper aquifer. Burro Canyon. is
used as a drinking water supply and monitoring has shown no evidence of
contamination. Two aquitards. the Mancos Shale and part of the Dakota
Sandstone. separate the Burro Canyon aquifer from the overlying alluvial
aquifer under most of the millsite.
Montezuma Creek. which flows through the millsite'. is a small perennial stream
with headwaters in the Abajo Mountains immediately west of Monticello.
Low-flow conditions prevail in the late summer. fall. and winter months.
Within the project area. base flow in Montezuma Creek is maintained year-round
by ground-water discharge from the alluvial aquifer and by releases from
Monticello Reservoir (located on South Creek. one mile west of Highway 191).
1
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Figure 1-1.
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-------
Domestic surface-water resources for the Monticello area are located
topographically upgradient from the site. The source of domestic Hater i~r
those people living outside the City of Monticello is predominantly grcu~d
water. drawn chiefly from wells drilled into the Burro Canyon aquifer.
The total annual average precipitation for the Monticello area during the
period of 1982 through 1986 was 18.3 i~ches. The annual average potential
evapotranspiration is 24 to 26.9 inches.
The prevailing winds are generally from the south. west-southwest. ar.~
northwest. The strongest winds. ranging from 7 to 13 miles per hour. are
those from the south and northwest.
Wildlife inhabitants of the millsite are few due to the sparse vegetation on
the tailings piles and in the mill area. The only "residents" appear to be
rodents. three species of rabbits. and several species of birds. None of the
wildlife inhabitants or vegetative species are cor.sidered to be threatened or
endangered. Occasionally. transient big game animals. such as mule deer. or
predators. such as coyotes. have been found on the site. The entire length of
Montezuma Creek through the site (17.8 acres) has been designated as wetlands
by the U.S. Army Corps of Engineers. Archaeological finds are scattered over
several peripheral properties. Several significant finds exist in Montezuma
Creek canyon.
2.0
SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1
SITE HISTORY
In late 1940. the Vanadium Corporation of America opened a vanadium ore-buying
station at Monticello to stimulate vanadium mining in the region. Within a
year. ore production in the area had increased sufficiently to justify
construction of a vanadium mill. The mill was constructed by the Vanadium
Corporation of America in 1942 with funds from the Defense Plant Corporation.
Initially. only vanadium was produced. but from 1943 to 1944 a uranium-
vanadium sludge was produced by the Vanadium Corporation of America for the
Manhattan Engineer District. The Atomic Energy Commission bought the site in
1948. Uranium milling commenced 15 September 1949 and continued until January
1960. when the mill was permanently closed. Part of the land was transferred
to the Bureau of Land Management: the remaining parts of the site have
remained under the control of the Atomic Energy Commission and its successor
agencies. the U.S. Energy Research and Development Administration and the U.S.
Department of Energy.
Numerous milling processes were used at the Monticello millsite during its
tenure of operation. These processes included raw ore carbonate leach.
low-temperature roast/hot carbonate leach. and salt roast/hot carbonate leach
up to 1955: acid leach resin-in-pulp and raw ore carbonate leach from 1955 to
1958: and a carbonate pressure leach resin-in-pulp process from August 1958 to
mill closure in 1960.
In the summer of 1961. the Atomic Energy Commission began to regrade.
stabilize. and vegetate the piles. This work was initiated on the East
Tailings Pile. Tailings sand was hauled from the other three piles and spread
o:er the surface. After the grading was completed. fill dirt and rock were
spread over the tops and sides of the piles. The plant was dismantled and
excessed by the end of 1964. During the summer of 1965. 6 to 12 inches of
topsoil were removed from the ore-storage areas. Photographs suggest that the
contaminated soil was used as fill material to partially bury the mill
foundations.
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In 1972. the Atomic Energy Commission requested additional radiation survevs
of the south stockpile area and the ore-buYing station. Recommendations ~ere
made to remove nearly 15.000 cubic yards of contaminated soil from these
areas. Ore-contaminated soil scraped frem the ore-storage areas was dumped or.
the previously stabilized surface of the East Tailings Pile.
The Department of Energy. under the authority of the Atomic Energy Act.
initiated the Surplus Facilities Management Program in 1978 to ensure safe
caretaking and decommissioning of government facilities that had been retired
from service but still contained radioactive contamination. In 1980. the
millsite was accepted into the Surplus Facilities Management Program and the
Monticello Remedial Action Project was established. The intent of the project
is to remediate the government-owned millsite. to dispose of or contain the
tailings in an environmentally safe manner. and to perform remedial actions 00
off-site (vicinity) properties that had been contaminated by radioactive
material from the mill operations.
In 1983. remedial activities for vicinity properties were separated from the
Monticello Remedial Action Project with the establishment of the Monticello
Vicinity Properties Project. The Monticello Vicinity Properties Project was
listed on the National Priorities List in 1986 and is being remediated
pursuant to a Record of Decision dated 29 September 1989. Both the Monticello
Remedial Action Project (Monticello Mill Tailings Site) and the Monticello
Vicinity Properties Project are currently administered by the Grand Junction
Projects Office of the U.S. Department of Energy.
2.2
ENFORCEMENT ACTIVITIES
A Federal Facility Section 120 Agreement with the U.S. Environmental
Protection Agency and the State of Utah. pursuant to the Superfund Amendments
and Reauthorization Act of 1986. became effective on 24 February 1989. A
Hazard Ranking System score for the millsite was developed that led to the
inclusion of the Monticello Mill Tailings Site on the Environmental Protection
Agency's National Priorities List on 16 November 1989.
The Department of Energy. the U.S. Environmental Protection Agency. and the
State of Utah have agreed to perform the response action(s) at the millsite in
accordance with the 1989 Federal Facility Agreement. As stated in the
Agreement. the Department of Energy is a responsible party with respect to
present and past releases at the millsite. Responsibility for oversight of
activities performed under the Federal Facility Agreement will be shared by
the Environmental Protection Agency and the State. with the former being the
lead agency having ultimate responsibility and authority. The State of Utah
will participate in planning. selection. and implementation of the remedial
action.
In February 1990. the Department of Energy completed the Remedial
Investigation/Feasibility Study-Environmental Assessment (DOE/EA-0424) for the
millsite. The remedial investigation/feasibility study was supplemented to
include analyses sufficient to enable the Department of Energy to assess the
impacts of the remedial action alternatives considered in terms of the
requirements of the National Environmental Policy Act.
3.0
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The remedial investigation/feasibility study and the proposed plan for the
Monticello Mill Tailings Site were made available to the public for comment 00
27 October 1989. A public comment period on the documents was held from 27
October 1989 to 2S November 1989. This comment period was extended through 19
December 1989 to accommodate additional comments. A public meeting was held
on 16 November 1989. Responses to comments received are included in the
Responsiveness Summary (Appendix A).
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This decision document presents the selected remedial action for t~O of the
three operable units at the Monticello Mill Tailings Site in Monticello. Utah.
chosen in accordance ~ith the Comprehensive Environmental Response.
Compensation. and Liability Act. as amended by the Superfund Amendments and
Reauthorization Act. and the National Contingency Plan. The decision for
remediation of this site is based on the administrative record. This document
addresses the millsite (Operable Unit I) and the peripheral properties
(Operable Unit II).
4.0
SCOPE AND ROLE OF OPERABLE UNITS WITHIN SITE STRATEGY
The Department of Energy. ~ith concurrence from the Environmental Protection
Agency and the State of Utah. organized the remedial ~ork into three operable
units. These are:
Operable Unit I:
Operable Unit II:
Operable Unit III:
Mill Tailings and Millsite Property
Peripheral Properties
Ground Water and Surface Water
The remedial actions planned for these operable units are interdependent.
This Record of Decision addresses the remedial actions for Operable Units
I and II. Follo~ing the initiation of remedial action ~or Operable Units
I and II and collection of additional surface- and ground-~ater monitoring
data. a Record of Decision ~ill be prepared for Operable Unit III.
Operable Unit I addresses the tailings. ore. and milling by.product materials.
This Operable Unit also includes contaminated buildings and equipment. and
contaminated soils at the millsite. The principal threats to public health
from the tailings and associated materials are exposure to radon gas and gamma
radiation. Nonradiological risks have been shown to be minor in comparison tQ
the radiologic risk. Additional environmental threats include surface.~ater
contamination of Montezuma Creek and radiological contamination found in the
alluvial aquifer due to tailings in contact ~ith that aquifer. The
remediation of Operable Unit I ~ill reduce health threats from tailings and
associated material to acceptable levels. and ~ill reduce the potential for
further contamination by removing and containing the contamination source.
,
Operable Unit II addresses the properties peripheral to the millsite
contaminated by ~ind.blown tailings particulate matter. tailings migration via
surface ~ater. and residual radioactive material at ore-buying stations. Nine
separate land types have been identified. including the Monticello Cemetery.
pasture land. hillsides. creek-bottom areas. and Montezuma Creek. Remedial
action activities may show that the areal extent of peripheral properties
differs from the current estimated acreage. The principal threats to the
public from peripheral properties are exposure to gamma radiation and radon
gas. The contaminated soil of peripheral properties generally exhibits lo~er
levels of contamination ~hen compared to the mill tailings. The remedial
response to Operable Unit II would remove and/or control the source of these
health threats.
During the remedial action of Operable Units I and II. the characteristics of
Operable Unit III (ground water and surface water) will necessarily be
altered. Source removal will cause three changes to the alluvial aquifer:
(1) The diversion of surface water ~ill cause unkno~n effects in the
geochemical attenuation of soils below the site: (2) De~atering of tailings
during excavation activities and relocation to the repository may result in
removing a large amount of water from the alluvial aquifer. This ~ater ~ill
be treated in accordance ~ith the Clean Water Act. Utah Pollution Discharge
Elimination System. and other applicable regulations: and (3) Contaminated
pore-water retained in the contaminated soils will also be removed. treated tQ
acceptable standards. and released. Removal of contaminated sediments in
Montezuma Creek will affect the contamination levels in the creek. Since the
6
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results of these changes will have an unknown effect. a monitoring program f~r
the alluvial and Burro Canyon aquifers and Montezuma Creek will be conducted
during remediation of Operable Units I and II. This mOnitoring program will
continue for three years following removal of the contaminated material. Upon
collection of adequate data to support selection of a remedial action and the
completion of a Remedial Investigation/Feasibility Study. a Record of Decision
will then be prepared for Operable U~~t III.
5.0
SUMMARY OF SITE CHARACTE~ISTICS
5.1
MILL TAILINGS
The uranium mill tailings characterization included sampling for radium-226
and uranium to descr~be the uranium-238 decay series. A number of
elements are generally present in uranium mill tailings in concentrations
above background. This characteristic is due to their elevated levels in
uranium ores as well as being concentrated as a consequence of milling
operations. Nonradioactive elements sampled for in the tailings
characterization were antimony. arsenic. beryllium. cadmium. chromium. copper.
lead. mercury. molybdenum. nickel. selenium. silver. thallium. vanadium. and
zinc.
The tailings generated by the millsite operations are contained in four piles
referred to. in order of their construction. as the Carbonate Pile. Vanadium Pile.
Acid Pile. and the East Pile. The Carbonate and Vanadium Piles were constructed
when the mill was recovering vanadium as a by' product using a salt roast/carbonate
leach flow sheet. The Acid Pile received tailings from the acid leach Resin-in-
Pulp process and a carbonate leach circuit. The East Pile received tailings from
the acid leach circuit and the high-temperature. carbonate leach Resin-in-Pulp
circuit.
Results of the mill tailings characterization indicate that arsenic. cadmium.
chromium. copper. lead. molybdenum. radium-225. uranium. vanadium. and zinc
are enriched in the tailings due to the milling process. The Carbonate and
Vanadium Piles are distinctly high in vanadium and contrast sharply in this
respect with the East and Acid Piles. Beryllium. copper. molybdenum. nickel.
and selenium are found in higher concentrations in the East and Acid Piles.
5.2
SOIL
Surface soil on the millsite and the peripheral properties has been
contaminated by tailings and ore residue from mill operations through the
storage of ore in open stockpiles. the emissions from the roaster stack. the
overflow of tailings ponds. and the erosion of tailings piles by wind and
water. The dispersal of tailings and ore residues has contaminated soil with
both radioactive and nonradioactive elements. Areas are considered
contaminated if the radium-226 concentration in soils exceeds the
Environmental Protection Agency standard (40 CFR 192.12) of 5 pCi/g above
background in the top 15 cm of soil or 15 pCi/g above background in any 15 cm
layer below the top 15 cm. A summary of millsite contamination as compared to
the standards is presented in Table 5-1.
The contamination of surface soil by these radioactive and nonradioactive
elements was portrayed by mapping the distribution of radium-226. The use of
radium as a proxy for other metals contained in the ore and tailings is
justified because the other elements. excluding uranium and vanadium. passed
through the mill circuit with radium to the tailings piles where they reside
in concentrations approximating those found in ore. Further. no transport
mechanism has been identified that would account for the segregation and
dispersal of one of the non-ore elements independently of others.
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Details of the radium mapping and sampling activities are found in the
remedial investigation report. Analytical results on soil samples. together
with results of in-situ spectrometer measurements. indicate an average
background radium-226 concentration of 1.0 ~ 0.4 picocuries per gram (pCi/g)
for surface and subsurface soils.
Table 5-1. Average Radium-226 Concentrations in Tailings Piles
and Millsite Soil. as Compared to Clean-Up Standards
Location
Average Radium-226 Concentration
Standard1 (DCi/g)
Carbonate Pile Approximately 870
Vanadium Pile Approximately 460
Acid Pile Approximately 750
East Pile. Approximately 590
Surface Soil (Millsite) 20 ~Ci/g
Subsurface (Millsite) N/A
Background 1.0 = 0.4 pCi/g
1~0 CFR 192.12. land clean-up standards are given as pCi/g above background.
"5" indicates 5 pCi/g averaged over the first 15 cm of soil below the
surface~ "15" indicates 15 pCi/g averaged over 15 cm thick layers of soil
more than 15 cm below the surface.
pCi/g
pCi/g
pCi/g
pCi/g
5/15
5/15
5/15
5/15
5
15
2An average radium-226 concentration for all subsurface soil areas on the
millsite was not calculated. Radium-226 concentrations in subsurface soil
for off-pile areas generally do not exceed the standard below 6.5 ft. Soil
and alluvium beneath the tailings piles may exceed the standard as deep as
18 ft.. generally.
5.2.1
Millsite
Most of the surface-soil layer on the millsite contains concentrations of
radium-226 exceeding Environmental Protection Agency standards. Contaminaticn
of the cover-soil material on the piles is believed to be due largely to the
redistribution of tailings by burrowing animals. Some surface-soil
contamination on the East Pile was caused by the disposal of contaminated soil
during the 1974 to 1975 peripheral properties clean-up activities.
The average concentration of radium-226 in the surface-soil layer is 20 pCi/g
for the millsite. The total radium-226 activity of the surface layer
(0-15 cm) is estimated to be 4 to 5 curies.
Radiometric logs of borings drilled on the millsite indicate apparent
radium-226 contamination of subsurface materials. In off-pile areas.
contaminated soil exceeding the Environmental Protection Agency subsurface
criterion of 15 pCi/g above background extends no deeper than about 4 to 6.5
feet and some areas show no subsurface radium contamination. Environmental
Protection Agency standards may be exceeded as deep as 15 to 18 feet in the
soil and alluvium beneath the tailings piles. In areas where contaminated
building material and by-product material may be buried. standards are also
expected to be exceeded.
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5.2.2
Peripheral Properties
Radiologically contaminated areas adjacent to the millsite include t~o former
ore-storage areas. the ~eigh station. the buying station. mill buildings.
three residences. and farming properties. totaling approximately 300 acres.
Approximately 200 acres are affected by radium-226 levels that exceed
Environmental Protection Agency standards at 40 CFR 192.12. It is probable
that former ore storage areas and other properties have buried by-product
material or contaminated building and equipment ~aterial that may cause
elevated concentrations of radioactive constituents. Windblo~n and ~aterborne
radium-226 contamination extends to the north and east into residential and
farming properties.
The ~eighted average depth of radium-226 contamination is 0.9 feet: the range
is from 0.5 foot to greater than 6 feet. Radium-226 at a concentration
greater than 500 pCi/g ~as found in an ore-stockpile area south of Montezuma
Creek and ~est of the Acid Pile. Radium concentrations above the
Environmental Protection Agency standards range from 6 pCi/g to 7185 pCl/g.
5.3
AIR
T~o types of substances ~ith the potential to adversely affect ai~ quality
have been identified at the site: radon-222. a radioactive gas produced by
the natural decay of radium-226. and airborne radioactive and nonradioactive
particles associated ~ith the tailings. Environmental monitoring programs
~ere established both on and off the millsite in 1983 to evaluate the radon
levels and to measure select elements in the total suspended particulate
burden. The following subsections summarize the contaminant concentrations
found and identify the applicable regulatory standards associated ~ith each
contaminant. Details of the sampling methodology and results appear in the
remedial investigation report.
5.3.1
Atmospheric Radon
The Environmental Protection Agency standard (40 CFR Part 192) for atmospheric
radon gas concentration at the edge of an inactive uranium mill tailings pile
is 0.50 picocurie per liter (pCi/L) above background. Therefore. the site-
specific standard is calculated to be 0.91 pCi/L. using 0.41 pCi/L as the
average annual background for Monticello (inferred by examining results from
and at every edge-of-pile location). The only off-site location where
contamination exceeds the standard is a single sampling station located
approximately 1.700 feet east of the millsite boundary. The contamination
results from the wind-blown materials. Radon gas concentrations were found to
be the same as background at a sample site located 1100 feet northwest of the
Department of Energy property boundary.
An atmospheric transport model ~as used to estimate the atmospheric dispersion
of radon gas attributable to the millsite. The predicted concentration in
excess of background for the entire Monticello area is 0.06 pCi/L.
5.3.2
Radon Gas Emissions
On-site measurements indicate that the Environmental Protection Agency
standard (40 CFR 192) for radon emissions at inacti~z ura~tum mill processing
sites (20 picocuries per square meter-second [pCiom osee ]) is exceeded at
each of the four tailings piles. The w~;ghte~iaverage radon emission at the
Carbonate Pile was highest at 765 pCiom ~osec .
9
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Off-site measurements show elevated radon gas concentrations in an area
extending southeast from the millsite property boundary to within 150 feet of
the sampling station located approximately 1.700 feet east of the property
boundary. It is suspected that tailings were physically transported from the
millsite and deposited on a narrow alluvial floodplain in this area. This
source is estimated to cove~229.7~~ square meters. The maximum radon emission
in the area is 65 ! 3 pCiom osee.
5.3.3
Air-Particulate Levels
Continual air particulate monitoring was initiated at the Monticello site in
August 1983. Sampling stations at the site were located along the paths of
the prevailing wind directions. to the north and to the east (as determined by
windrose data). In addition. a background station was established west of the
site.
No Department of Energy limits for radioactive particu!ates (the limits above
backgr~und as stated in DOE Order 5480.1 are 3.0 ~Ci/m for radium-226 and
9 ~g/m for uranium-238) were exceeded. according to measurements taken both
on and off site. The results of sampling were also compared to background
measurements taken at other rural areas in the western United States. The
levels found at the Monticello millsite were several orders of magnitude lower
than those at other locations. The average air particulate 3adium-226 and
uranium-238 5oncentrations at the millsite were 0.0006 pCi/m radium-226 and
<0.0012 ~g/m uranium. respectively.
5.4
5.4.1
MONTEZUMA CREEK
Stream Sediments
Several studies were performed following mill closure to assess the levels
radium-226 in sediments of Montezuma Creek downstream from the Monticello
millsite. Data from these early studies revealed that high concentrations
radium-226 persisted in the sediments of Montezuma Creek. These high
concentrations were probably attributable to bedload transport of sandy
tailings material eroded from the piles during mill operations.
Data from a 1987 survey provide a more detailed portrayal of the radium
distribution along the creek because samples were collected from stream banks
and floodplain soil near the creek as well as from the channel itself.
Substantial radium contamination exists in and adjacent to Montezuma Creek to
a point about 1.600 feet east of the millsite. Downstream from this point.
concentrations of 1 to 60 pCi/g are typical. although concentrations of 100
pCi/g and higher occur sporadically. Sediments are considered contaminated
when the concentration of radium-226 exceeds the 40 eFR 192.12 standard of 5
pCi/g above background in the top 15 cm of sediment or 15 pCi/g above
background in any 15 cm layer below the top 15 cm.
of
of
5.4.2
Surface Water
A summary of the current surface water contamination is presented here so that
the extent of contamination due to the millsite may be better understood. The
existing surface water characterization also provides a baseline for further
characterization to be performed following millsite remediation. under
Operable Unit III.
Background surface-water quality has been monitored for some years at a point
on Montezuma Creek east of the culvert under Highway 191. upstream from the
millsite. The water has been characterized as having low or nondetectable
levels of heavy metals or mill-tailings-related material.
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Montezuma Creek flows through the middle of the millsite. Flow is perennial.
although it can be quite low during the late summer. Data obtained frem a
September 1981 intensive sampling of the creek indicate that uranium
concentrations in the creek begin to increase (0.29 mg/l uranium) upstream
from the point at which the creek traverses the actual tailings piles.
Uranium levels in the creek increase by an additional 40 to 50 percent toward
the downstream boundary of the millsite. Concentrations of arsenic.
molybdenum. vanadium. and uranium increase downstream from the entrance of a
seep (located between the Carbonate and Vanadium Piles) into the creek. On
the downstream side of the Vanadium Pile. concentrations of uranium.
molybdenum. selenium. vanadium. and radium continue to increase.
Seeps issuing from an alluvial aquifer increase the concentration of uranium
in the creek by as much as an order of magnitude in the first 160 to 330 feet
downstream from the millsite. Samples collected 1/2 mile downstream from the
millsite show an average concentration of 0.183 mg/l uranium. In addition.
four miles downstream from the millsite. the Salt Wash Member of the Morrison
Formation contributes measurable amounts of uranium to Montezuma Creek. This
contribution is responsible. in part. for maintaining the high uranium
concentrations (as high as 0.22 mg/l) observed at the Montezuma Canyon
sampling location. 6 miles below the millsite.
Other mill tailings constituents have been sampled for in Montezuma Creek and
compared with Federal water-quality standards and State of Utah water-quality
standards. Samples were collected east of the tailing site downstream from
the aquifer recharge area. The comparison of the surface-water sampling data
to State and Federal water-quality standards indicates that gross alpha-
particle activity. arsenic. molybdenum. manganese. selenium. zinc and pH
exceed recommended concentration levels. The potential for exposure to these
elements suggests that this water should not be used for drinking by humans or
cattle and that remedial action should be taken to improve surface-water
quali ty.
5.5
GROUND WATER
A summary of the alluvial aquifer contamination is presented here so that the
extent of contamination from the millsite is better understood. The existing
ground-water characterization also provides a baseline for further
characterization of the ground water. which will occur during and following
remediation of the millsite and peripheral properties. A Record of Decision
will be prepared when sufficient data have been gathered to warrant a final
decision for restoration of the alluvial aquifer.
Analytical data from samples obtained from seven on-site wells drilled into
the alluvial aquifer and sampled for nonradioactive elements associated with
mill tailings (these elements are identified in Section 5.1). and for uranium.
radium. and vanadium. show considerably elevated concentrations in comparison
with the upgradient wells. In general. the highest concentrations are
associated directly with the tailings area. Many of the highest
concentrations of nonradioactive and radioactive elements are from wells
drilled in the vicinity of the Carbonate and Vanadium Piles and from a well
located near the east edge of the millsi te propert'y.
Wells located downgradient from the millsite typically have nonradioactive and
radioactive element concentrations that are elevated in comparison with
upgradient wells. For example. the maximum arsenic concentration found in
upgradient wells is 0.01 mg/L and the maximum downgradient is 0.02 mg/L for
the period 1984-1986. For uranium. the maximum upgradient well concentration
for the same period is 0.019 mg/L and the maximum downgradient is 0.8 mg/L.
The southward extent of offsite alluvial aquifer contamination is limited by
Montezuma Creek. where the creek enters Montezuma Canyon.
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Ground-water samples collected from wells located downgradient from the
millsite and completed in the Burro Canyon Formation are similar to those
observed in the up gradient well in the alluvial aquifer. suggesting that the
Burro Canyon aquifer is not affected by the contaminated alluvial aquifer.
Elevated levels of nonradioactive and radioactive elements found downgradient
in the alluvial aquifer are not found in the Burro Canyon aquifer. Current
data show the average uranium c~ncentration for three downgradient wells in
the alluvial aquifer is 0.41 mg/L. ~hereas the average u=anium content of
downgradient wells in the Burro Canyon aquifer is approximately 0.002 mg/L.
6.0
SUMMARY OF SITE RISKS
A baseline risk assessment was conducted to evaluate the public health and
environmental risks resulting from the existing contamination at the millsite.
The risk resulting from ground-water and surface-water contamination will be
addressed in detail after remediation of the millsite and peripheral
properties begins. Actual or threatened releases of hazardous substances from
this site. if not addressed by the preferred alternative or one of the other
active measures considered. may present an imminent and substantial
endangerment to public health. welfare. or the environment. The following
risk summary explains why this endangerment exists. Information included in
this summary has been excerpted from Chapter 8 of the remedial investigation
report where details of the assessment can be found.
The radiologic health threat is attributed predominantly to uranium and
radium-226. Uranium is a health concern as well due to its toxicity. Of the
nonradiologic elements. arsenic is a proven carcinogen. The other elements
are potential health concerns depending upon the concentration and type of
exposure.
Dispersion of uranium mill tailings from the millsite occurs through natural
and man-caused actions. Wind- and surface-water dispersion have caused the
spread of tailings to peripheral properties. while use of the tailings as
construction material has distributed the tailings to local residential and
commercial properties. Dispersion to numerous residences and businesses in
the City of Monticello has resulted in the identification and remediation of
the Monticello Vicinity Properties. This site was included on the National
Priorities List in 1986.
6.1
HUMAN HEALTH RISKS
6.1.1 Radioactive Contaminants
The two major contaminants of concern for the radiological public health
assessment are radon gas and gamma radiation. both of which are attributable
to the tailings piles and the contaminated soils and materials on the millsite
and peripheral properties. Radon gas migrates through the tailings into the
atmosphere. Gamma radiation is emitted from the tailings. The adverse health
effects of radon emanation arise from inhalation of the short-lived radon
daughter products which can expose the lungs to their full radiation dose.
Gamma radiation delivers its dose to the entire body.
Five potential exposure pathways were identified:
ingestion of contaminated food produced in areas contaminated by the
tailings:
.
inhalation and ingestion of airborne radioactive particulates:
ingestion of surface water contaminated by the tailings:
12
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inhalation of radon and radon daughters; and
direct exposure to gamma radiation emitted from the tailings.
The first two pathways. which include ingestion of plant material "dusted"
with windblown tailings. ingestion of animal food products from animals
ingesting such plant material. inhalation and ingestion of airborne
particulates. and ingestion of household dust. are considered insignificant
because concentrations of uranium and radium associated with airborne
particulates are below background levels. The third pathway is not considered
to be a probable pathway because elevated radium concentrations have not been
detected in Montezuma Creek. Elevated uranium levels have been detected in
off-site wells and Montezuma Creek. however. uranium is being considered under
nonradiological risks for the following reasons. First. the radiological
eXDosure dose rate from uranium is low because of its low concentration in the
water. Secondly. uranium is a strong nephrotoxin and because it has a very
long half-life will persist in the environment. Therefore. two pathways
remained for consideration: inhalation of radon and radon daughters. and
direct exposure to gamma radiation.
For each of these two pathways. the excess cancer incidence to the Monticello
population was determined by multiplying the population dose commitment ty a
factor representing the estimated cancer risk per rem of exposure. Rem
(Roentgen Equivalent Man) is a unit used to measure exposure to radiation
which applies qualitative and other modifying factors to account for the
particular character of the radiation exposure. Population dose commitment.
was determined by multiplying the average annual individual rate of exposure
by the total population: it is expressed in units of person-rems per year
(person:5em/yr). For radon. an individual lung cancer risk factor ~f
20 x 10 per rem. or 20 excess cancer deaths per year per 1 m;~lion person-
rem. was used. For gamma radiation. a risk factor of 120 x 10 per rem was
used. This factor is equivalent to 120 excess cancer deaths in an exposed
population for each 1 million person-rem of collective dose equivalent.
For the scenario representing inhalation of radon from the millsite and
peripheral properties. the excess annual_~ancer incidences to the Monticello
population are estimated to be 0.38 x 10 (or. 0.0038 excess cancer
incidences for the Monticello population). Whole body exposure to gamm~
radiation resulted in an estimated excess cancer incidence of 2.0 x 10- per
year. or 0.02 excess cancer incidences for the entire Monticello population
annually. The radiological risk assessment was performed on a population
basis prior to recent EPA guidance on performing radiological risk assessments
on an individual basis.
As an indicator of potential individual risk due to baseline radiological
conditions. a gross estimate of the l;setime excess cancer incidence to the
individual was estimated to be 1 x 10 . Although this rough estimate is
within th~6Environmental Protection Agency's acceptable risk range (1 x 10-4
to 1 x 10 ) the millsite will still be remediated to comply with the
pertinent health-based applicable or relevant and appropriate requirements in
40 CFR 192 which requires remediation of uranium mill tailings to specific
levels regardless of risk. .
6.1.2
Nonradioactive Contaminants
A preliminary screening was conducted to identify the "highest risk". or
indicator. elements found on the site. Excluded from consideration as
indicator elements were those elements found in upgradient surface-water at
equal or higher concentrations than those appearing on the site. Those
elements found in soil and air particulates at concentrations not exceeding
background levels were also excluded. The following elements were selected as
13
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nonradiologic "indicator" elements: arsenic. copper. lead. molybdenum.
selenium. uranium. vanadium. and zinc. With the exception of molybdenum. all
Jf the elements characterized in the tailings piles are listed as
Comprehensive Environmental Response. Compensation. and Liability Act
hazardous substances at 40 CFR 302.4.
Under existing conditions. the major sources of nonradiologic elements are the
tailings piles and mill process-related by-product material at the millsite.
Nonradiological constituents in the tailings piles can be leached from the
tailings and released into other environmental media. Contaminants mav be
transported or released from the tailings pile into the ground water. surface
water. and air. Toxic elements are leached from th~ tailings into the shallo~
alluvial aquifer.
Potential exposure pathways were developed based on the populations and
activity patterns in the vicinity of the uranium mill tailings site. These
pathways are:
inhalation of resuspended dust:
ingestion of contaminated soil:
ingestion of contaminated vegetables: and
ingestion of contaminated beef.
The first pathway. inhalation of resuspended dust. was excluded from further
consideration because monitored particulate concentrations indicated that the
levels were not elevated above background. Further. several nonradiologic
elements were analyzed for in the particulate samples obtained. Lead is the
only nonradioactive airborne particulate measured at the millsite that is
regulated by a specific standard. Acceptable airborne levels of this element
are defined by the Environmental Protection Agency under the NatiJnal Ambient
Air Quality Standards. The standard specifies 3hat a 3-month average
concentration of lead is not to exc3ed 1.5 ~g/m. The maximum concentration
measured at the site is 0.0490 ~g/m . well below the compliance standard.
The second pathway. ingestion of contaminated soil. was also excluded from the
assessment because although limited entry may occur at the millsite. the
frequency is very low due to existing fences. The chance that a trespasser
would ingest contaminated soil is low because ingestion is associated
predominantly with very small children. Further. the existing soil cover
serves as an additional barrier to ingestion of the tailings material. which
contains the greatest concentration of nonradiological constituents.
The potential future risk for the soil ingestion pathway has been
qualitatively estimated. although the potential for the access controls
currently used by the Department of Energy to be removed in the future is
extremely low. The Department of Energy has strict requirements for
controlling radioactively contaminated sites. which do not allow sites to ~e
released for unrestricted use unless radiation levels are within acceptable
limits. It is highly unlikely that the Department of Energy. or other
successor Federal agency. would loosen this policy for a contaminated site.
However. under a future risk scenario. it is anticipated that risks to the
exposed population will be minimal because of a low exposure frequency due to
the area's sparse population. Also. the exposure dose will be low (under 60
mg/day) because only older. unsupervised children are likely to enter this
area. Therefore. assuming it is possible to enter the site under a future
scenario, risks associated with nonradioactive contaminants through the soil
ingestion pathway should be negligible.
14
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Pathways (3) and (4) were retained for consideration. They are considered to
be indirect exposure routes resulting from contaminated surface water in the
area. used to irrigate fields and water livestock. Contaminants in the water
can enter the food chain through the ingestion of contaminated vegetables and
beef. .
Noncarcinogenic health effects can arise from acute and chronic exposures to
all eight elements. Reference doses have been developed by the Environmental
Protection Agency to indicate the potential for adverse health effects from
exposure to chemicals exhibiting noncarcinogenic effects (e.g.. persistent
neurological effects. neurotoxicity. respiratory problems. skin rashes). A
reference dose is an estimate of a lifetime daily exposure level (specific to
a particular exposure route) for humans. including sensitive individuals.
which is unlikely to result in an appreciable risk of deleterious (adverse)
effects during a lifetime. a Estimated intakes of chemicals from environmental
media (e.g. the amount of a chemical ingested from contaminated drinking
water) can be compared to the reference dose (or acceptable intake for chronic
exposure). Both parameters are expressed in units of milligram per kilogram-
day (mg/kg.day).
Intake estimates of each indicator element were computed for the potential
exposure pathways for both children and adults. Maximum and average soil
concentrations were used in exposure dose calculations. Total oral intake for
the contaminated vegetable and contaminated beef pathways were then compared
with the acceptable intakes for chronic exposure.
Exposures were then calculated for the two exposure scenarios retained for
consideration. Comparison of existing contaminant concentrations with the
acceptable intakes for chronic exposure resulted in no apparent health risk.
When average concentrations of contaminants in soil were used. none of the
dose levels were exceeded. Copper. uranium (including the vegetable pathway)
and zinc (including or excluding the vegetable pathway) exceeded recommended
levels for children when maximum soil concentrations were used. However.
because the millsite is uninhabited. and considering historical land use
patterns in the area. it is unlikely that individuals would receive chronic
exposure to these maximum concentrations. Because average exposure doses do
not exceed the acceptable intakes for chronic exposure. use of surface water
to irrigate pasture or alfalfa. on which cattle graze. appears to be
acceptable.
Arsenic is the only indicator chemical that is considered to be a human
carcinogen. According to the Environmental Protection Agency weight-of-
evidence classification system for carcinogenicity. arsenic is included in
Group A. meaning it is a confirmed human carcinogen. The slope factors
(analogous to cancer risk factors for radiologic contaminants) fO~larsenic for
the inhalat;~n and ingestion exposure pathways are 50 (mg/kg.day) and 1.5
(mg/kg.day) . respectively. .
-....----.......----------
aThe original risk assessment used "acceptable intakes for chronic exposure"
instead of reference doses. Acceptable intakes for chronic exposure and
reference doses are similar in concept. but reference doses are derived using
a more strictly defined methodology. Acceptable intakes for chronic exposure
were recommended by the Environmental Protection Agency when the original risk
assessment was prepared. but the Environmental Protection Agency now
recommends the use of reference doses. Therefore. this terminology has been
used in this discussion.
15
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Excess lifetime cancer risks due to exposure from arsenic levels at the
millsite. for pathways 3 and 4. were determined by multiplying the intake
level. by. the slope factor. Calculated can~~r risks fr~m arsenic contamination
are w~th~n the health goal range of 1 x 10 ~g 1 x 10 0 lifetime cancer risk.
This range has g point of departure at 1 x 10 . An excess lifetime cancer
risk of 1 x 10" indicates that. as a plausible upper bound. an individual has
a one in one million chance of developing cancer as a result of site"related
exposure to a carcinogen over a 70.year lifetime under the attributable to the'
mill~~te for an individual due to ingestion of contaminated vegetables is 2.7
x 10 . or 2.7 cancers in 100.000 people exposed: using maximum soil
concentrations: and 7.0 x 10.0 (or 7 cancers in 1.000.000 people exposed) for
average soil concentrations above background. Cancer risks for arsenic
attributable to the millsite fgr an individual due to ingestion of
contaminated beef is 2.0 x 10" (or 2 cancers P5r 100,000 people exposed)
using maximum soil concentrations and 2.0 x 10 (or 2 cancers per 1.000.000
people exposed) using average soil concentrations above background. On the
basis of this information, arsenic may pose a public health impact under the
existing conditions at the millsite.
6.2
ENVIRONMENTAL RISKS
Risks to the natural environment that were considered in the remedial
investigation/feasibility study are also addressed in this Record of Decision.
Specific environmental concerns at the millsite and on peripheral properties
include impacts to archaeology, vegetation. wildlife. fisheries. and
floodplain/wetlands.
An inventory of the lower Montezuma Creek drainage identified one historic
site on the floodplain and numerous prehistoric sites along the walls of the
canyon. The historic site was field-evaluated as nonsignificant. Several of
the prehistoric sites were field-evaluated as significant because they are
likely to possess undisturbed stratified cultural deposits: determinations of
these sites' eligibility for the National Register of Historic Places must be
made prior to their disturbance. and will be dealt with under Operable Unit III.
Threatened or endangered plant species were not encountered during the
remedial investigation. although the area is within the potential range of two
species of cacti. one of which is listed as threatened and one of which is
listed as endangered by the U.S. Fish and Wildlife Service. No plants of
State concern were found in the area.
According to the U.S. Fish and Wildlife Service. no threatened or endangered
avian species occur at or near the Monticello millsite. although the
endangered American peregrine falcon and the threatened bald eagle could occur
in the area. Use of the millsite by either species is considered remote
because of the lack of arboreal vegetation.
Fishery species of concern which occur in the San Juan River approximately 30
miles south of the millsite include the Colorado squawfish. the razorback
sucker. and the roundtail chub. In the upper reaches of Montezuma Creek where
sampling occurred. no fish were found. The principal reason for this is
thought to be the seasonal dewatering of the creek. especially prior to 1986.
Present stream conditions in the lower creek indicate deep pools with cover
that could support a fishery.
The U.S. Army Corps of Engineers performed a wetlands assessment in August
1989. It was determined that Montezuma Creek and adjacent wetlands areas
constitute 18.63 acres of wetlands, beginning at Highway 191 and ending at the
creek's confluence with Vega Creek.
16
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7.0
DESCRIPTION OF ALTERNATIVES
Remedial action alternatives in the feasibility study report were evaluated in
accordance with the Comprehensive Environmental Response. Compensation. and
Liability Act. as amended by the Superfund Amendments and Reauthorization Act.
and the National Contingency Plan. Prior to evaluating remedial action
alternatives. several preliminary evaluations Qccurred. Remedial actio~
objectives were identified on the basis of th mil:site characterization
results. Response actions and associated te~r:nologies were considered and
screened for each operable unit. The tech~o~ogy screening activities were
based on relative effectiveness. implementability. and cost.
Preliminary remedial action alternatives were then developed from the
remaining technology process options. The concept af operable units was
utilized to differentiate contaminated media and to provide a mechanism for
developing and evaluating alternatives for each media. Alternatives were
developed ranging from those eliminating the need for long-term management. to
alternatives involving treatment that would permanently reduce the mobility.
toxicity. or volume of the hazardous substances as their principal element.
Containment options were also developed.
During the preliminary remedial action alternatives analysis. several
potential options were dropped. Chemical/physical treatment of the tailings
was eliminated due to high cost (i.e.. lime stabilization) for treatmert of
all constituents. and poor implementability because of unproven technologies
(i.e.. in-situ vitrification). Disposing of the tailings in a repository
built at the tailings piles' current location was eliminated due to the
inability to meet relevant and appropriate requirements. specifically 40
eFR 192. which places severe limits on disposal sites placed in contact with
ground water. The tailings would have to be removed. a liner installed. and
the tailings replaced. Cost. decontamination difficulties. and questions on
longevity and liner effectiveness made this option ineffective. less
protective of human health and the environment. and difficult to implement.
Seven potential off-site repository locations within 12 to 45 miles of the
site were also evaluated during the preliminary screening process for
effectiveness. implementability. and cost. Siting criteria were established
based on 40 eFR 192 and each potential site was evaluated against these
criteria.
Based on the screening process. the Highway 9S site was selected as the most
suitable of these sites and was kept for further evaluation in the feasibility
study. This location was ultimately eliminated during the detailed analysis
of alternatives because of implementability and cost. The site was v~ry
similar in most respects to the "existing off-site repository" alternative
(which was retained as a remedial action alternative) except that the Highway
9S site consisted of undisturbed land. The potential for impact to
environmental and historical resources. and other pertinent requirements would
make this alternative more difficult to implement than removal to an existing
off-site repository. The lack of existing improvements on the Highway 9S site
also led to increased costs. The other six sites exhibited substantially
higher potentials for wind and water erosion. flooding. and landslides than
did the sites retained for detailed analysis. Other problems exhibited by the
eliminated sites include ground-water concerns. endangered species
considerations. and the ability to meet design longevity standards for the
repository.
7.1
OPERABLE UNIT I -- MILL TAILINGS AND MILLSITE PROPERTY
Operable Unit I includes approximately 1.5 million cubic yards of uranium mill
tailings. ore. by-product material. contaminated building materials. and mill
equipment existing on the millsite.
17
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Three remedial action alternatives were retained for detailed development
analysis for this operable unit. ~hey are no action. removal of tailings
transport to a licensed repositor . and removal of tailings with disposal
repository on site. south of the present location. A discussion of each
alternative follows:
and
and
in a
7.1.1
Alternative 1:
No Action
The no-action alternative provides a baseline with which to compare other
alternatives and involves performing no remedial action. while continuing
monitoring activities. Institutional controls are likely to be in place due
to their current existence and the Department of Energy's philosophy of
restricted access for contaminated areas. This alternative would result in
continued contamination of the alluvial aquifer and Montezuma Creek. ~eaving
the tailings in their present condition would subject them to dispersal by
water and wind and would continue to prevent beneficial use of contaminated
areas. Exposure levels (and therefore. health risks) could increase
significantly if land use were to change. or if uncontrolled removal of the
wastes were to occur.
7.1.2
Alternative 2:
Repository
This alternative involves excavation and removal of contaminated materials to
an off-site licensed repository. The disposal cell would meet the current
design and operation requirements of the Nuclear Regulatory Commission or
relevant State agency. Since remediation of the Monticello site is a
Comprehensive Environmental Response. Compensation. and Liability Act action.
Environmental Protection Agency design criteria at 40 CFR Part 192 would be
relevant and appropriate requirements for the repository.
Removal of Tailin~s and Transport to a Licensed
All tailings. milling process by-product material. and contaminated building
and equipment material from the millsite would be relocated to the site by
truck transportation on highways.
7.1.3
Alternative 3: Removal of Tailin~s and Disposal in a Repository On
Site. South of the Present Location
This alternative involves excavation and removal of contaminated materials to
an on-site repository site located south of the existing millsite. Removal of
the tailings. by-product material. and contaminated building and equipment
material would prevent future contamination of air. surface soil. and ground
water as presented in the previous alternative. Removal would be by
conventional earthmoving equipment. Transport of tailings and other materials
would be entirely on site. Dust-control measures and access restrictions
would be used to protect public health during remedial action activities. To
control runoff. diversion structures would be built with collected water
treated by evaporation ponds. reverse osmosis. or other appropriate
technologies to be determined during the design process. Treated water would
be discharged to Montezuma Creek in accordance with the applicable regulations
(Clean Water Act. Utah Pollution Discharge Elimination System. and other
regulatory requirements). or used for compaction or dust control purposes.
Contaminated residuals from either of the treatment systems would be disposed
of in the new repository or at a licensed repository. Tailings disposal would
occur on land contiguous to the existing millsite in a repository covered with
a clay and multimedia cap. This repository would be designed to comply with
40 CFR 192 performance standards. The land is not currently owned by the
Department of Energy and would have to be acquired. The Environmental
Protection Agency. in accordance with the National Contingency Plan. has
determined that the proposed location of the repository meets the criteria for
being considered "on site".
18
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7.2
OPERABLE UNIT II -- PERIPHERAL PROPERTIES
Operable Unit II includes approximately 300.000 cubic yards of radioactively
contaminated soils carried by wind or water from the millsite. and mill
processing by-product material located on peripheral properties.
Two remedial action alternatives. retained for detailed development and
analysis for this operable unit. are described in the following subsections:
no action. and clean up to 40 CFR 192.12 standards. which includes placement
of contaminated material in a repository with the millsite ~ailings. This
alternative also allows the opportunity for the Department of Energy to apply
for supplemental standards under 40 CFR 192 at specific properties.
7.2.1
Alternative 1:
No Action
This alternative would leave contaminated peripheral properties alone. with no
remedLation being performed. In contrast with the no-action alternative for
Oper.' - Unit I. institutional controls are not currently in place because
prope. s are not under the Department of Energy's control. The no-action
alterna_~ve provides a baseline with which to compare the other remedial
action alternatives.
7.2.2
Alternative 2:
Clean Up to 40 CFR 192.12 Standards
Peripheral properties will be cleaned up to the principal relevant and
appropriate standard. 40 CFR 192. Contaminated materials will be transported
to the existing millsite and will be relocated with the millsite materials to
the repository location chosen for Operable Unit I.
Removal of contaminated materials will be either by conventional construction
techniques or by environmentally sensitive removal techniques. Conventional
construction utilizes large earthmoving equipment to remediate the properties
by removing the contaminated soil and materials. Soil removed would be
replaced with clean material and the site would be revegetated. Although all
means would be attempted to revegetate the area to its present condition. it
will take several years to re-establish the native bushes and decades to
re-establish the native tree species.
In areas with mature dense vegetation. environmentally sensitive construction
techniques. such as hand excavation. could be used successfully to remove the
contaminated soils. yet minimize environmental damage to areas that are
important wildlife habitats. An option to hand excavation would be the use of
high-suction vacuum equipment specifically designed for remediating hazardous
waste spills. This equipment has costs similar to hand excavation. but would
tend to clean up more precisely the actual areas of contamination. Other
environmentally sensitive construction techniques would be considered.
Figure 7-1 shows the peripheral properties currently ident~:ied. with the
exception of Upper and Lower Montezuma Canyon (designated E SS and I-SS).
which are located further downstream on Montezuma Creek. Remediation of these
two properties will be addressed in the Record of Decision for Operable Unit
III following remediation of Operable Units I and 'II. The Environmental
Protection Agency and State of Utah have agreed that supplemental standards
applications under 40 CFR 192 will be considered for these two properties.
Use of supplemental standards may allow no clean up or clean up to a lesser
standard than 40 CFR 192.12 if full remediation would cause undue direct
environmental damage in comparison to the derived health benefits.
19
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----.. /'"
-.--..
- -.- --- -----
--
Perlpheral Propertle
20
J
o
- -
~
.~ -... C.,-:i
~-'~ ~
r ~
. -
-------
The Department of Energy. the Environmental Protection Agency. and the State
of Utah have agreed that the densely vegetated hillside properties. designated
B-SS. located on the north side of Montezuma Creek will be remediated to the
40 CFR 192.12 standards using conventional or environmentally sensitive
construction techniques. These six properties had previously been proposed
for supplemental standards application under 40 CFR 192. The Environmental
Protection Agency and the State of Utah have agreed to consider applications
for the use of supplemental standards on densely vegetated hillside prcpert~es
on the south side of Montezuma C:~ek. designated B-SS. and the Monticello
cemetery (F-SS). Application submittal and evaluation will occur during
remedial design.
8.0
COMPARATIVE ANALYSIS OF ALTERNATIVSS
The following discussion summarizes the alternatives evaluation identified in
the feasibility study. The alternatives were evaluated on the basis of nine
key criteria that directly relate to the factors that the Comprehensive
Environmental Response. Compensation. and Liability Act mandates for
assessment when selecting a remedy. These criteria are:
(1)
( 2 )
(3)
Overall protection of human health and the environment.
Compliance with applicable or relevant and appropriate requirements
(detailed in Section 10.0).
Use of treatment to achieve a reduction in the toxicity. mobility.
or volume of the contaminants.
Long-term effectiveness and permanence in protecting human health
and the environment.
Short-term effectiveness in protecting human health and the
environment.
Implementability.
COSt.
State acceptance. and
Community acceptance.
(4 )
( 5 )
(6 )
(7)
(8 )
(9)
Criteria 1 and 2 are threshold criteria. relating directly to statutory
findings that must ultimately be made in this Record of Decision. These
criteria must be met by the chosen remedial action alternatives. Criteria 3.
4. S. 6. and 7 are considered primary balancing criteria that represent
technical. cost. institutional. and risk concerns. The final two criteria are
modifying criteria and are used within an alternative to alter activities
based on State and local concerns. The comparative analysis of alternatives
for Operable Units I and II are summarized in Tables 8-1 and 8-2.
respectively.
8.1
8.1.1
OPERABLE UNIT I -. MILL TAILINGS AND MILLSITE PROPERTY
Protection of Human Health and the Environment
Alternative 1. no-action. fails to protect human health and the environment
because it does not control exposure pathways. C~ntamination of the alluvial
aquifer and Montezuma Creek would continue. and tailings left in their present
configuration would remain subject to dispersal by water and wind. Human
exposure to radioactive constituents would continue at present levels.
21
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TABLE II-\. SUMMARY OF COMPARA'IlVE ANALYSIS OF ALTERNATIVES
FOR OPERABLE UNIT I, MILL TAIIJNGS AND MILLSITE PROPEHTY
\. Overall 2, Compliance 3. Reduclion of 4. l.ong,Tenn
Prollx:tioo With Tuxicily, Effectiveness
OfIlWTIan ApGlieable MubililY, ur and Pennanence
lIealth or elevant Volume uf
and the and Appropriale Contaminants
Envirorvnent Requirements by Trealmem
AI.TERNA llVE
1.
No Action
Does IlOl meet
criterioo,
Fails 10
control
exposure
pathways,
Meets
criterion.
Cootaminalion
ICUn:eU
removed.
Reduces
contaminant
mobility by
cmtainment
in . rcposi-
101}' comply-
ing with
40 CHI 192.
Does not meet
criterion.
Fails 10
meet 40 CFR
192 and others.
Dues not meet
crilerion.
No trealment
is invulved,
Docs nul meel
crilenon.
Fails 10
COllllol
exposure
pathways.
2.
Tailings Removal
and Transpon to
a licensed
ReposilOl}'
Meets criterion.
Complies with
aU require.
ments, includina
40CFR 192.\2
clean-up standards;
40 CHI 61, Subpan
Q radOll emission
standards; Utah
Water Quality
Control Standards;
the Utah Occupa.
tional Safety and
Health Act; State
and Federal historic
preservation laws;
floodplain/wetland
policy; and the
hnnland Proteclioo
Policy Act.
Does 1101 meet
criterion,
Meels '-Titerion.
Overall
reductiun of
radiulogic
risk to
public is
41% whc:n
compared tu
exi sting
cundiuollS.
3.
Tailings Removal
and OisJ?Osal in
a ReposllOI}'
On Site, Soulh uf
Present Locauon
Meets criterion.
Removcs
contamination
source. Redoces
cmtamin.nt
mobility by
containment in a
repOSitory
cOOJplymg with
40 CHI 192.
Meets criterion.
Complies with
aU requirements,
including 40 CFR
192.12 clean-up'
stambrds; 40 CrR
61, Subpart Q
radon emission
standards; Utah
Water Quality
Control Standards;
the Utah Occupational
Safety and Health
Act; State and Federal
historic preservauon
laws; floodplain!
weiland policy; and
the Fannland Protection
Pohcy Act.
Docs not meet
critenon.
Meets crilerion.
Overall radiulugic
risk reduction
is 40% lu the public
when cum(\i1red 10
e"isting cundluuns,
-------
I' ANALYSIS OF ALTERNATIVES
TABLE 8-1 (CON'IlNUED). SUMMARY Of COMPAR
5.
Shon-Term
Effectiveness
FOR OPERABLE UNIT I, MiLl, TAIUNGS ANI) MILLSITE I'I
-------
TABLE 8-2. SUMMA/(Y Of COMPARAllVE ANALYSIS 01' ALTERNA1lVES
fOR OI)ERAHLE UNIT II, PERIPHERAL PROPER'IlES
I.
Overall
ProtecUoo
Of Human
lIuhh
andlhe
Envirorunent
2.
Compliance
With
Applicable
or Relevant
and Appropriate
Requirements
J.
/(cducuu" of
Toxicity,
Mobility, or
Volume of
COnlaminams
by T reatmclll
4.
I.ong-Term
Eff&uveness
and Permanence
ALTERNA TIVE
I.
No Action
Does not meet
criterioo.
Fails to
coouoJ
exposure
pathways.
Does nOl meet
criterioo.
Fails to
meet 40 CfR
192 and othen
(including Clean
Water Act, aem
Air Act, etc.).
Does not meet
crilenoo.
No treatmenl
is involved.
Does not meel
criterion-
Fails 10
conlrol
exposure
pathways-
2.
aCln Up to
40CFR 192.12
Saandards
Meeta criterion.
Control. exposure
pathways by
rernovin, the
soun:e 0 contami.
nllioo. Environ-
mentally IC:ftsitive
coosuuclion and
supplemental
IIIndards awlica-
tioo assure
enviroomental
protection while
protecting human
health. COOlain-
ment in the reposi-
tory reduces
cootaminant
mobility.
Meets criterion.
aem up will
meet 40 CFR 192.12
or 40 CFR 192.22
standards, and
will meet aU
requirements
detailed in
Appendix B
(including specifics
of the aCln Air
Act, <"1ean W.ter
ACI, Ocwpauooal
Safety and Health
Act, etc.).
Remediation of
propenies does
nOl meet the
criterion.
Removal of
cootaminalcd
materials is
effective in
eliminating the
source of
cootaminatioo-
Ultimate disposal
in a reposilory
meeling the
40CFR 192
performance
re'luiremems is
a more permanenl
Solulion than the
no-action ahemative-
S. Shon-Term 6. Im~emenl- 7. Cost 8- State 9. Communily
Effectiveness abi'ty Acceptance Acceptance
ALTERNA1lVE
I. No Action Does not meet Implementable. Neglible. No Suppon- Low
criterion. communilY
Fails to control acceptance.
exposure pathways.
2. aCln up to Engineering con- Implementable. Esumated 111e Slale of Overall
40 CFR 192.12 trois will be in Technologies for minimum cost is Utah suppons communilY
Standards place during remedillion are $12,648,000. dean up to accep...nce.
remedillion proven and Estimated 40 Cfl< 192
acuvies 10 rudLly available. maximwn COSI is standards.
assure that this $ 1II,460,CXJO.
criterion is met
-------
Alternatives 2 and 3 are equally protective of human health and the
environment. Both alternatives would eliminate the source of ground-water and
surface-water con~amination by removing the tailings from their present
location. During tailings removal activities. controls would be in place to
limit dust generation and to prevent ground-water contamination. The tailings
repositories for both alternatives would be designed to meet the repository
performance requirements of 40 CFR 192. including cap design to minimize radon
emanation. Alternatives 2 and 3 both reduce the mobility or contaminants by
placing the tailings and associated materials in repositories conforming to
the requirements of 40 CFR 192.
Current Environmental Protection Agency guidance requires an evaluation to be
conducted every five years for alternatives in which contaminants remain on
site (as with Alternative 3). These five year evaluations would allow
assessment of whether future action or remediation would be required. Any
problems with protectiveness identified in the five-year reviews will be
addressed at that time.
8.1.2
Compliance with Applicable or Relevant and Appropriate Requirements
Alternative 1. no action. would violate the Uranium Mill Tailings Radiation
Control Act and implementing regulations at 40 CFR 192. The tailings piles
would not meet disposal site design requirements nor would they meet the
ground-water standards proposed to be added to 40 CFR 192. Continued
contamination of Montezuma Creek and the alluvial aquifer would violate the
Utah Water Pollution Control Act and Utah's Ground-Water Protection Act.
Alternative 2. removal of tailings and transport to an off-site licensed
repository. would meet the applicable or relevant and appropriate requirements
identified in Section 10 and detailed in Appendix B. For example. mill
tailings removal and repository operations will comply with the applicable
requirements under the Clean Air Act (40 CFR 61. Subpart Q). and State of Utah
requirements for the control of fugitive dust emissions. All activities will
comply with the Occupational Safety and Health Act requirements. Flood-
plain/wetlands requirements will be followed during the temporary diversion or
Montezuma Creek and any impacts to wetlands will be mitigated. The State or
Utah's Water Pollution Control Act will be adhered to if any discharges are
made to Montezuma Creek. The existing repository would possibly need a
license amendment to meet the requirements of 40 CFR 192. Also. to meet the
pertinent requirements at the repository. it may be necessary to obtain
Federal. State. or local permits.
Alternative 3. tailings removal and disposal on site. would meet all
applicable or relevant and appropriate requirements identified in Section 10
and detailed in Appendix B. Mill tailings removal and repository operations
will comply with applicable requirements under the Clean Air Act (40 CFR 61.
Subpart Q). and State of Utah requirements for the control of fugitive dust
emissions. All activities will comply with Occupational Safety and Health Act
requirements. Floodplain/wetlands requirements of Executive Orders 11988 and
11990 will be followed when temporarily diverting Montezuma Creek and any
impacts to 'wetlands will be mitigated. The State of Utah's Water Pollution
Control Act will be adhered to if any discharges are made to Montezuma Creek.
The repository would be designed to meet the requirements of 40 CFR 192. No
Federal. State. or local permits would be required since the remedial action
is performed on site: however. substantive permit requirements would be met.
8.1.3
Reduction of Toxicitv. Mobility. or Volume of Contaminants by Treatment
The no-action alternative does not reduce toxicity.
because all contaminated materials would be left in
3 do not include treatment of the mill tailings and
toxicity. mobility. or volume by treatment.
mobility. or volume
place. Alternative 2 and
therefore do not reduce
25
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8.1. 4
Lon2-Term Effectiveness and Permanence
The no-action alternative would result in the continuation of excessive long-
term risk to the P~2lic: the total radiologic risk to Monticello residents
would be 2.38 x 10 excess cancer mortalities (0.0238 additional cancers for
the entire population) per year. This alternative would be neither effective
nor permanent.
Alternative 2 achieves the greatest reduction in overall risk to th~ local
population from radiological contamination. with a risk reducti~n c: 41% fr~m
current conditions. This alternative achieves long-term e:fective,ess because
the contaminant source is removed. Operation of the licenzea repo~itorv in
conformance with licenses and permits will help to assure that the alte;~ativ~
is also a more permanent solution than Alternative 1. and is as permaner.t as
Alternative 3.
Alternative 3 achieves a 40% reduction in risk to the local population from
radiological contamination when compared to current conditions. This risk
reduction is slightly lower than the risk reduction achieved by Alternative 2
because the repository is located closer to the local community. The
nonradiologic risk index for Monticello residents after remediation is 0.09.
which means that the cumulative exposure to nonradiologic constituents is less
than the cumulative acceptable intake. and is therefore an indicator of no
adverse health effects. A nonradiologic risk of 1.0 or greater indicates
potential adverse health effects. This alternative achieves long-term
effectiveness because the contamination source is removed. The tailings
repository would be designed and maintained in accordance with the regulations
identified in Section 10 of this document: the alternative is more permanent
than Alternative 1. and is as permanent as Alternative 2.
8.1.5
Short-Term Effectiveness in Protectin2 Human Health and the Environment
The no-action alternative does not entail short-term effectiveness
considerations: therefore. it does not meet this criterion. as the criterion
is not applicable.
Alternatives 2 and 3 would involve identical short-term impacts during the
removal of contaminated materials from the millsite. Radiological impacts to
workers and the public will be minimized by engineering controls during
remediation activities. A controlled work site will be main':ained to limit
access to the millsite and areas of construction. Dust suppressants will be
utilized and air monitoring will be performed. The State or Utah's
Occupational Safety and Health Act will be followed.
Alternative 2 includes additional impacts due to haulage of contaminated
materials on public roads. The number of expected transportation injuries and
fatalities will increase due to the number of vehicles hauling on roadways.
with 13.16 additional highway injuries and 0.12 fatalities occurring. The
rate of highway deterioration will also increase. Alternative 3
transportation impacts are due only to worker transportation to and from the
work site on public roads. All haulage of contaminated material will be done
on site. An additional 1.09 transportation injuries and 0.010 fatalities can
be expected for on-site disposal of the mill tailings.
8.1. 6
Imclementabilitv
The no-action alternative is relatively easy to implement because
environmental monitoring currently exists and is the only activity involved.
Alternatives 2 and 3 would be equally implementable during removal of
contaminated materials. Conventional excavation technology is effective and
proven in removing source material such as tailings. Alternative 2 is more
difficult to implement with regard to the repository because an existing
licensed repository would have to amend its license prior to accepting
26
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millsite materials. Since disposal activities are off site. Federal. State.
and local permits may be required. Disposal in an on-site repository.
Alternative 3. has neither of these c,ncerns.
8.1.7
Cost
The no-action alternative is the least expensive to implement. Capital costs
are zero. Annual operation and maintenance costs for the environmental
monitoring to be performed under this alternative are $250.000. The present
worth of Alternative 1 using a 5% discount rate (i.e.. an interest rate of 5%
after inflation) is $1.700.000.
Removal of tailings and transport to a licensed repository (Alternative 2) has
capital costs of $86.400.000 (in 1989 constant dollars) to achieve a cell tha:
complies with 40 CFR 192 requirements. and annual operations and maintenance
costs of $41.000. The present worth of the entire remedial action using a 5~~
discount rate (using a real interest rate of 5%: or. an interest rate that is
5% higher than the inflation rate) is $69.874.000.
Capital costs for tailings removal and disposal in a repository on site
(Alternative 3) are $52.100.000. in 1989 constant dollars. Annual operations
and maintenance costs are $41.000. The present worth using a 5% discount
rate. as defined previously. is $42.346.000. The remedial investigation/
feasibility study report provides details for all costs.
8.1. 8
State Acceptance
The no-action alternative does not have State of Utah support. as evidenced by
the State's signing of the Federal Facility Agreement. The State currently
has a policy excluding certain wastes from disposal at licensed repositories
and has not accepted Alternative 2. Alternative 3 is acceptable to the State
of Utah.
8.1. 9
Community Acceptance
Although some local residents are not convinced that the mill tailings pose a
problem. community acceptance of the no-action alternative is low. Local
mining interests are favorable to Alternative 2 as is the local public in
general. The local public is also supportive of Alternative 3.
8.2
OPERABLE UNIT II -- PERIPHERAL PROPERTIES
8.2.1
Protection of Human Health and the Environment
The no-action alternative fails to protect human health and the environment
because it does not control the major exposure pathways of radon emissions and
exposure to gamma radiation. Alternative 2. peripheral property remediation.
is protective of human health and the environment because the contamination
source is removed and would ultimately be disposed of in a repository meeting
the requirements of 40 CFR 192. Contaminant mobility is also reduced by
containment in the repository. The potential of using environmentally
sensitive construction techniques and supplemental standards application on
properties where environmental harm is excessive further assures protection of
both human health and the environment. Prior to using supplemental standards
at peripheral properties where environmental damage is grossly
disproportionate to health benefits. the selected remedial action must come as
close to meeting the otherwise applicable standards as is reasonably possible
under the circumstances and must not pose a clear present or future hazard.
8.2.2
Compliance with Applicable or Relevant and Appropriate Requirements
The no-action alternative fails to meet the clean-up standards of 40 CFR 192.
Remediation of the peripheral properties to 40 CFR 192.12 standards assures
compliance with this requirement. Clean up will allow the State of Utah Water
27
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Pollution regulations to be met for discharges to Montezuma Creek. All
remediation activities will be performed in compliance with the Occupational
Safety and Health Act and Utah's rules for control of fugitive dust emissions.
This alternative will meet all other applicable or relevant and appropriate
requirements detailed in Appendix B.
8.2.3
Use of Treatment to Achieve a Reduction in Toxicitv, Mobili~v.
or Volume of Contaminants
No treatment is involved with the no-action alte=na~iv~. ~o this cr-.:erion is
not met. Remediation of the peripheral properties does nJt meet the criterion
because no treatment is involved.
8.2.4
Lon~-Term Effectiveness and Permanence
The no-action alternative does not meet this criterion beca~se the source of
contamination is left in place. Under Alternative 2. the ccntaminated
materials will ultimately be placed in a repository meeting the ?erformance
requirements of 40 CFR 192; this is an effective solution and is more
permanent than the no-action alternative.
8.2.5
Short-Term Effectiveness
The no-action alternative does not involve short-term effectiveness
considerations: therefore. the criterion is not applicable and is not met.
Alternative 2. remediation of the peripheral properties. meets the criterion.
through engineering controls during remediation activities. For example.
suppressants would be applied to control fugitive dust emissions. air-
monitoring would be performed to determine when respiratory protection is
needed. and the radiation dose to workers would be monitored by film badges.
8.2.6
Implementabflity
The no-action alternative is implementable because no activity is required.
Alternative 2 is also implementable because the technology. services. and
materials to perform either conventional or environmentally sensitive
construction are proven and readily available.
8.2.7
Cost
The cost of the no-action alternative is negligible. The estimated minimum
cost for remediation of the properties. Alternative 2. is $12.6~a.OOO using
conventional construction on all properties except the cemetery and densely-
vegetated hillsides south of Montezuma Creek (where supplemental standards
could be applied), The estimated maximum cost. assuming environmentally
sensitive construction is used on all heavily vegetated hillsides and
conventional construction is used elsewhere. is $18.460.000.
8.2.8
State Ac~eotance
The State of Utah is not supportive of the no-action alternative. as evidenced
by its signing of the Federal Facility Agreement. The State supports
remediation of the peripheral properties to the standards of 40 CFR 192. The
State of Utah also concurs with the possible use of Supplemental Standards on
hillside dense vegetation south of the millsite.
8.2.9
Community Acceptance
Community support for the no-action alternative is low. although some
residents doubt that a real risk is posed by the mill tailings-related
contamination. Overall. the community is supportive of the remediation
alternative (see Appendix A for details).
28
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9.0
The selected remedy for the Monticello Mill Tailings Site involves removal of
tailings. by"product material (as defined in Section 11 (e) (2) of the Atomic
Energy Act of 1954 as amended. and in 40 CFR Part 192 to mean ":ailings or
waste produced by the extraction or concentration of uranium from any ore
processed primarily for its Source material content"). and COntaminated
bUildings and equipment material. with disposal of these materials on site for
Operable Unit I: and remediation to 40 CFR 192 standards for Operable Unit II.
peripheral properties. by either conventional or environmentally sensitive
conStruction. or in limited cases. the USe of supplemental standards. Ground-
water and surface"water reStoration will be addressed in a separate Record of
Decision following initiation of remediation for Operable Units I and II.
SELECTED REMEDY
Detailed descriptions of the selected alternatives follow. The remediation
goals. corresponding risk levels to be attained. and points of compliance for
each medium addressed by the remedy. are discussed. Finally. a detailed
discuSsion of the costs of each component of the remedy is presented.
9.1
SELECTED ALTERNATIVES
9.1.1
o erable Unit I -- Removal of Tailin sand DisDosal in a Re ositorv
On Site. South of the Present Locat~
The selec
-------
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-------
Radiologically contaminated building materials and mill equipment will be. tJ
the extent practical and in accordance with prevailing standards.
decontaminated and either released for unrestricted use as defined by
Department of Energy Orders. released for restricted use as defined by
Department of Energy Orders. or disposed of in a sanitarv landfill. The-
repository will be used for disposal of some of this radiologically
contaminated material. but the quantity will be kept to a minimum and
materials will be disposed of in strict accordance with the repository design
specifications.
An additional remediation goal is to eliminate the potential for leaching or
contaminants in the mill tailings to ground water and surrace water. These
goals will be achieved by diverting Montezuma Creek away from its current
channel where it is in contact with mill tailings piles. removing the tailings
and relocating them to the secure repository. replacing the tailings piles
with clean fill. grading and revegetating the site to provide proper surface
drainage. and reconstructing the channel of Montezuma Creek to its pre-
millsite historic location. In addition. any dewatering of tailings or water
removed from contaminated soils will be treated and released to the
environment. If discharged to Montezuma Creek. the waste water would be
treated to meet Utah's requirements for discharge to surface waters (U.C.A.
Title 26. Chapter 11; R-448-8 U.A.C.).
The remediation of the mill tailings and associated materials will ccmply with
the principal relevant and appropriate requirement. 40 CFR Part 192.12. which
specifies the maximum permissible concentration of radium-226 above background
levels. Soils with radium-226 concentration above 6 pCi/g in the O-to 6-inch
(15 cm) layer. and 16 pCi/g in any subsequent 6-inch (15 cm) layer below 6
inches (15 cm) are considered to be contaminated and will be removed (using an
average background level of 1.0 ! 0.4 pCi/g).
The tailings repository would be designed to contain approximately 2.5 million
cubic yards of tailings and contaminated materials and would cover
approximately 40 acres of disposal area. It is estimated that about 1.9
million cubic yards of contaminated material will be removed and transported
to the repository. Materials removed from peripheral properties will be
temporarily stored at the mill tailings site. and then transported to the
repository. Included in the contaminated material to be received at the
repository is approximately 100.000 cubic yards of contaminated soil and
building materials from the Monticello Vicinity Properties National Priorities
List site (this material.was the subject of the Monticello Vicinity Properties
Record of Decision).
Design components of the tailings repository will be based on the Department
of Energy's Uranium Mill Tailings Remedial Action Program research and
practice standards (including the latest revision of the Technical Approach
Document. Revision 2. December 1989. DOE/AL-050425.0002). During design.
engineering considerations will take into account such factors as radon gas
minimization. erosion control. dust control. water infiltration control. and
site security. The State of Utah and the Environmental Protection Agency will
have review authority on remedial design activities to ensure that the most
appropriate technology is used in the final design. The repository will be
designed to comply with the requirements of 40 CFR Part 192. which requires
that the repository be designed to:
Be effective for at least 200 years and to the extent reasonably
achievable. to be effective for up to 1.000 years:
Provide reasonable assurance that releases of radon-222 from residual
radioactive material will not exceed an avera~e release rate of 20
picocuries per square meter per second (pCi/m /s): and
31
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Provide reasonable assurance that releases of radon-222 from residual
radioactive material will not increase the average concentration of radon-
222 in air at or above any location outside the disposal site by more than
0.5 pCi/L.
The compliance point for the standards applying to radon-222 emissions is the
entire surface of the repository. In addition. proposed additional standards
to 40 CFR Part 192.32 (Subpart D). require that uranium mill tailings be
managed to conform to the ground-water protection standards and with
monitoring requirements of 40 CFR Part 264.92 (Subpart F). The point of
compliance for monitoring is defined in 40 CFR Part 264.95 as being the
vertical surface located at the hydraulically downgradient limit of the waste
management area that extends down into the uppermost aquifer underlying the
regulated units.
The costs of remediation of Operable Unit I are presented in Table 9-1. The
total capital cost of the project. in 1989 dollars. is estimated to be $52.1
million. in~luding contingency costs of $8.69 million. Annual operation and
maintenance costs in 1989 dollars are estimated to be $40.800 per year for the
period 1996 to 2020. including contingency costs of $6.800 per year. The
total project cost in 1989 dollars calculated using a discount rate of 5
percent is estimated to be $42.346 million.
Some changes may be made to the selected remedy as a result of the remedial
design and construction process. In general. such changes will reflect
relatively minor modifications resulting from the engineering design process.-
9.1.2
Operable Unit II -- Peripheral Properties Clean Up to 40 CFR 192.12
Standards
The proposed action consists of removal of contaminated materials and
relocation to the millsite tailings pile. with ultimate disposal in the
repository described for Operable Unit I. Removal will be achieved by
environmentally sensitive construction practices. and/or conventional
construction techniques to meet the standards of 40 CFR 192.12. Techniques
will vary depending on the degree of contamination and the environmental
consequences of remediating specific land types.
The occurrence of chemically hazardous substances not associated with tailings
or process'waste exposure has been pursued. but has yielded no substantive
evidence of contamination by these substances. Therefore. no public health
evaluation was performed for these substances. If during remedial action.
hazardous substances or materials not excluded from the Resources Conservation
and Recovery Act [e.g.. 40 CFR 261.4(a)(ii) (4) source. spent nuclear. or by.
product material as defined by the Atomic Energy Act of 1954. as amended.
U.S.C. 2011. et seq.] are found on site. they shall be remediated and/or
disposed of in accordance with applicable regulations. including Resource
Conservation and Recovery Act requirements. if determined to be applicable or
relevant and appropriate. Any by-product material associated with mill
processing and found on peripheral properties. will be disposed of in the
repository.
32
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Table 9-1.
Estimated Costs of the Selected Remedv for Operable Unit I
(Removal of Tailings and Disposal On Site. South of
Present Location)
Capital Costs
Total
Millsite Site Preparation
$
740.000
Repository Site Preparation
Millsite Remediation (removal)
7.160.000
7.350.000
Construction of Repository
7.480.000
Millsite restoration
2.125.000
Repository restoration
Mobilization/demobilization
2.360.000
815.000
Subtotal
15.420.000
$43.450.000
Indirect Costs
Contingency (at 20%)
8.690.000
Total Project Costs
(1989 dollars)
$52.140.000
Operation and Maintenance Annual Costs
Annual Cost
Contingency (at 20%)
Total annual O&M costs (1989 dollars)
$34.038
6.808
Groundwater monitoring and surveillance (1996-2020)
$40.846
1989 TOTAL PRESENT WORTH
(present worth calculated using a 5% discount rate)
$42.346.40Q
33
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Soils with radium concentrations above 6 pCi/g in the 0 to 6 inch layer of
soil and concentrations above 16 pCi/g in each subsequent 6 inch increment
below the top layer are considered to be contaminated (using a background
concentration of 1.0 = 0.4 pCi/g) and will be removed. The peripheral
properties include irrigated mesa pasture lands. areas of dense hillside
vegetation. low hillside vegetation. hilltop dryland pasture. creek-bottom
pasture. the U.S. Bureau of Land Management compound. creek banks along upper
Montezuma Creek and the Monticello Cemetery. The properties constituting
upper and lower Montezuma Creek will be remediated with Operable Unit III.
following initiation of remediation for Operable Units I and II.
In areas with mature dense vegetation. hand excavation could be used
successfully to remove the contaminated soils and to minimize environmental
damage to those areas that have important wildlife habitat. An option to hand
excavation would be the use of high-suction vacuum equipment specifically
designed for cleaning up hazardous waste spills. This equipmerit has costs
similar to hand excavation yet would tend to clean up more precisely the
actual areas of contamination.
Where acceptable. conventional construction techniques will be used to remove
contaminated soils from specific areas. including those previously disturbed.
such as farm land. This involves the use of large earthmoving equipment to
remove the contaminated soil. The removed soil would be replaced with clean
material and the site would be revegetated. On several properties. a
combination of conventional and environmentally sensitive construction
techniques will be used. As a result of meeting the contaminant-specific
applicable or relevant and appropriate requirements. it is expected that
exposure of inhabitants in the Monticello area to health risks from radiation
in excess of background levels will be reduced to acceptable levels.
Radiation risks are primarily associated with inhalation of radon-222 and
exposure to gamma radiation. Where conventional or environmentally sensitive
construction techniques are used to remove contaminated materials. radiologic
risks will be reduced to background levels. Nonradiologic long-term risk to
individuals after peripheral property remediation was included in the
comparative analysis of Operable Unit I. and is considered insignificant.
The Environmental Protection Agency and the State of Utah will evaluate
proposals for the use of supplemental standards on densely vegetated hillsides
south of Montezuma Creek and at the Monticello Cemetery during remedial
design. Supplemental standards. which allow leaving contamination in place.
are standards included within the principal relevant and appropriate
requirement. 40 CFR 192. These standards are typically applied to areas where
physical removal of materials would cause undue environmental damage in
comparison with the derived environmental and health benefits. In areas where
supplemental standards may be applied. radiation dose is currently estimated
to be within 1 percent of health-based standards.
Operable Unit II consists of an estimated 311.600 cubic yards of contaminated
material (including 8.000 cubic yards of material to which supplemental
standards may apply). The capital costs of remediation of this operable unit
are presented in Table 9-2. Unit costs have been ~resented for each land type
and each construction alternative where more than one construction alternative
is available. Therefore. a range of total costs is presented. The costs
range from $12.648 million (assuming conventional construction techniques are
used on all properties except that supplemental standards are applied to the
cemetery and south hillside) to $18.460 million (assuming that supplemental
standards are not used. environmentally sensitive construction techniques are
used to the maximum extent possible. and conventional techniques are used
elsewhere). The total costs are provided in 1989 dollars. and calculated
using a discount rate of 5 percent. The costs include transporting the
contaminated material to the millsite. Costs of subsequent transport and
disposal of the material at the repository south of the millsite are included
in the cost of remediation of Operable Unit I.
34
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Table 9-2.
Land Type
A (Mesa irrigated
Pasture)
B (Hillside dense
vegetation)
B (Hillside dense
vegetation)
BSS (Hillside dense
vegetation
including BSS')
BSS' (Properties
South of
Montezuma
Creek)
C (Hillside low
vegetation)
o (Hilltop dryland
pasture)
E (Creek bottom)
Estimated Costs of the Selected Remedy for Operable Unit II
(Peripheral Properties Clean Up to 40 CFR 192 Standards)
Constructio~
Alternative
Conventional
Conventional
Environmentally
Sensitive
Conventional
Environmentally
Sensitive
Supplemental
Standards
Conventional
Conventional
Conventional
Cubic Yards
Cost Per
Cubic Yard
16.360
$24.33
33.120
38.53
33.120
117.81
24.800
47.34
24.800
120.32
6.000
o
(120.32)*
55.550
37.59
70.800
95.230
32.34
31.52
Direct and Indirect Capital Costs of
Site Preparation. Removal. & Restoration
Contingencies Total
@ 20% 1989 Dollars
Subtotal
$ 398.000
1.276.000
3.902.000
1.174.000
2.984.000
o
( 722.000)
2.088.000
2.290.000
3.002.000
$ 79.600
$
480.000
255.200
1.530.000
780.400
4.680.000
234.800
1.410.000
596.800
3.580.000
o
(144.000 )
o
866.000)
417.600
2.510.000
458.000
2.750.000
600.400
3.600.000
.Should Supplemental Standards not be approved. incremental costs would be as shown.
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Table 9-2 (continued).
Estimated Costs of the Selected Remedy for Operable Unit II
(Peripheral Properties Clean Up to 40 CFR 192 Standards)
Land Type
Direct and Indirect Capital Costs of
Site Preparation. Removal. & Restoration
ConstructioJf Cost Per Contingencies Total
Alternative Cubic Yards Cubic Yard Subtotal @ 20% 1'189 Dollars
Conventional 2.000 59.50 119.000 23.800 140.000
Supplemental
Standards 2.000 0 0 0 0
Conventional 7.070 59.12 418.000 83.600 500.000
Conventional 6.670 27.29 182.000 36.400 220.000
FSS (Monticello
Cemetery)
G (BLM Compound)
H (Upper Montezuma
Creek Bank)
Minimum Tota12
Project Costs
Conventional and
supplemental
standards
303.600
10.534.500
2.106.900
12.647.500
Maximum Total3
Project Costs
Conventional and
Environmentally
Sensitive
311.600
15.383.000
3.076.600
18.460.000
lSupplemental standards may be applied to land types BSS' and FSS.
2Minimum total project cost assumes that conventional construction techniques will be used in all areas.
except BSS' and FSS where supplemental standards will apply. Cost per cubic yard applies to conventional
construction only.
3Maximum total projecl cost assumes that environmentally sensitive cOllstruction techniques will be us~d for
land types B. BSS. and BSS'. and conventional techniques elsewhere.
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9.2
SIGNIFICANT DIFFERENCES FROM THE PROPO~ED PLAN
The Proposed Plan was released for public comment in October 1989. The plan
identified three operable units to be remediated at the Monticello Mill
Tailings Site. The decision made for remediation of Operable Unit I remains
as identified in the Proposed Plan. Operable Unit II will be remediated with
Operable Unit I except that the Upper and Lower Montezuma Creek properties
will be remediated with Operable Unit III. Selection of a preferred
alternative for Operable Unit III. Ground Water and Surface Water. has been
delayed until remediation of the other two operable units is underway. A
decision for restoration of this operable unit is postponed because surface
water and aquifer characteristics will necessarily change during remediation
activities for Operable Units I and II. Following data collection and
analysis during and following Operable Units I and II remediation. the
Department of Energy. the Environmental Protection Agency. and State or Utah
will determine the additional steps needed to restore the alluvial aquifer.
The aforementioned parties will work together under the existing Federal
Facilities Agreement to develop a Record of Decision pursuant to the
Comprehensive Environmental Response. Compensation. and Liability Act. as
amended. and in accordance with the requirements of the National Contingency
Plan.
This approach differs from that in the Proposed Plan for Operable Units II and
III. While it is considered a significant change. a new public comment period
is not required at this time. but will be included in the development of a
surface- and ground-water Record of Decision at a later date.
10.0
STATUTORY DETERMINATIONS
The selected remedy meets the statutory requirements of Section 121 of the
Comprehensive Environmental Response. Compensation. and Liability Act. The
statutory determinations for the preferred surface- and ground-water remedy
(Operable Unit III) will be discussed in a separate Record of Decision that
will be prepared following the initiation of remediation of Operable Units I
and II and the collection and analysis of additional monitoring data.
10.1
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy for Operable Unit I (mill tailings and millsite property)
and Operable Unit II (peripheral properties) protects human health and the
environment through the following engineering controls:
Excavation of all materials at the millsite contaminated at levels above
health-based standards specified under the Uranium Mill Tailings Radiation
Control Act in 40 CFR 192.12;
Relocation of the contaminated materials to a repository constructed to
meet design standards and monitoring standards of the Uranium Mill
Tailings Radiation Control Act.
The selected remedy for Operable Unit I will eliminate the source of ground-
water and surface-water contamination. The selected remedy will result in a
40 percent reduction in radiologic risk to the Monticello population. After
tailings removal. the annual cancer risk to-zhe Monticello population from
radioactive conSti~~ents would be 1.43 x 10 as compared to the existing
level of 2.38 x 10 (or. 0.0143 additional cancers per year for the entire
population compared to the existing estimate of 0.0238 cancers). Although the
millsite remediation will follow health-based remediation standards for the
radioactively contaminated materials (40 eFR 192.12) to achieve acceptable
risk. a gross estimate was made for the excess lifetime c~gcer incidence to an
individual following remediation. The estimate is 6 x 10 excess cancer
"incidences due to radiologic constituents for an individual. following
remediation. Because the Environmental Protection Agency's acceptable risk
37
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range is from 1 x 10-4 to 1 x 10-6 excess lifetime cancers, this rough
estimate could be low by nearly two orders of magni~ude and s~ill be below the
upper bound of the acceptable risk range. The selec~ed remedy will not pose
unacceptable short-term risks and will decrease cross-media imDacts. The
nonradiological risk index for Monticello residents afte= compietion of the
selected remedy for Operable Unit I is "0.09", which is an indication of no
adverse health effects. (The Environmental Protection Agency considers a risk
index greater ~han 1.0 to be indicative of adverse health effects.)
The remedy selected for Operable Uni~ I minimizes adverse impacts to
floodplain/we~lands and waters of the U.S. ~hrough the avoidance of
unnecessary impacts to these areas. f~ere adverse impacts are unavoidable.
there is a determination of meeting the subs~an~ive requirements of the Clean
Water Act. Executive Order 11988 and 11990. Mi~igat~on of unavoidable impac~s
to these areas will be accomplished through floodplain/wetland restoration and
creation projects. and channel reconstruction.
The selected remedy for Operable Unit II (Peripheral Properties) will protect
human health and the environment through the following engineering controls:
Excavation of contaminated materials using either conventional or
environmentally sensitive construc~ion techniques in areas where removal
is required to mee~ health-based s~andards of 40 CFR 192.12;
Relocation of the excavated material to a repository as described for
Operable Uni~ I.
The selected remedy for Operable Unit II will reduce radiologic risks to ~he
exposed segmen~ of the populations of Monticello primarily by removal of soils
contaminated with gamma radiation-emitting contaminants such as radium-226.
The long-term radiologic risk to Monticello residents after peripheral
proper~y remediation (except for areas where supplemental standards are
applied) is estimated to be background. As for Operable Unit I. the selected
remedy will not pose unacceptable short-term risks and will decrease cross-
media impacts.
10.2
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
Under Section 121(d) (1) of the Comprehensive Environmental Response.
Compensation. and Liability Act. (42 U.S.C. ~ (d)(1)). remedial actions must
attain a degree of clean up which assures protection of human health and t~e
environment. Additionally. remedial actions that leave any hazardous
substance. pollutant. or contaminant on site must meet a level or standard of
control that at least attains standards. requirements. limitations. or
criteria that are "applicable or relevant and appropriate" under the
circumstances of the release.
"Applicable" requirements are those clean-up standards. standards of control
and other substantive environmental protection requirements. criteria. or
limitations promulgated under Federal or State law that specifically 3ddress a
hazardous substance. pollutant or contaminant. rem~dial action. location. or
other circumstance at a remedial action site. "Relevant and appropriate"
requiremen~s are clean-up standards. standards of control and other
substantive environmental protection requirements. criteria. or limitations
promulgated under Federal or State law tha~. while not "applicable" to a
hazardous substance. pollutant. contaminant. remedial action. location. or
other circ~mstance at a remedial action site. address problems or situations
sufficiently similar to those encountered at the site that their use is well-
suited to the particular site. See the National Contingency Plan
(40 CFR Section 300.6) for further information.
There are three types of requirements governing remedial actions. The first
type includes "contaminant-specific" requirements which set limits on
concentrations of specific hazardous substances. pollutants. and contaminants
38
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in the environment. An appropriate example of this type of requirement for
the Monticello Mill Tailings Site is the 40 eFR Part 192 clean up standard fo:
residual radioactive materials. The second type of requirement includes
location-specific requirements that set restrictions on certain types of
activities based on site characteristics. These include restrictions on
activities in wetlands. floodplains. and historic sites. The third type of
requirement includes action-specific requirements. These are technology-based
restrictions which are triggered by the type of action under consideration.
Occupational Safety and Health Act standards which regulate worker health and
safety are action-specific requirements.
In determining whether requirements are "relevant and appropriate". the
Environmental Protection Agency and the State of Utah have looked at the
remedial actions proposed. the hazardous substances present. the waste
characteristics. the physical characteristics of the site. the population at
risk. and other appropriate factors. The Environmental Protection Agency and
the State of Utah reviewed Federal and State laws. standards. requirements.
criteria and limitations for possible application to the Monticello Mill
Tailings Site. Tables 1.3 and 1.7 in the feasibility study identify the
potential requirements screened by the Environmental Protection Agency and the
State. Table B-1 in Appendix B identifies those which have been determined to
be "applicable" or "relevant and appropriate". The Environmental Protection
Agency has determined that there are no applicable or relevant and appropriate
public health and environmental requirements of Federal or State laws that the
selected remedies for Operable Unit I and II (millsite and tailings. and
peripheral properties. respectively) will not meet. and therefore no Superfund
Amendments and Reauthorization Act Section 121(d) (4) waivers would be
involved.
A brief discussion of the principal applicable or relevant and appropriate
requirements for Operable Units I and II and how the remedies will satisfy the
requirements follows:
10.2.1
Contaminant-Specific Requirements
The Environmental Protection Agency Standards for Remedial Action at Inactive
Uranium Processing Sites. 40 CFR Part 192. is the principal contaminant-
specific requirement identified for the Monticello Mill Tailings Site.
Operable Units I and II.
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. However. they are not directly
applicable to the Monticello Mill Tailings Site because the standards apply
only to certain specifically designated sites where uranium was processed.
The standards are relevant and appropriate to the millsite and peripheral
properties for the following reasons:
The Monticello site is an inactive uranium mill tailings site which is
owned by the Federal government.
The regulations were promulgated to control tailings which were dispersed
into the environment and pose a threat to human health and the environment.
The inactive Monticello uranium mill tailings site is characterized by
large above-surface and subsurface uranium process residue/tailings piles
which pose a danger to the public. Dispersion of contaminants into the
environment through air. ground water. and surface water pathways has
occurred.
39
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The numeric standards for health and environmental clean up would be
relevant and appropriate for corrective action. Uranium and vanadium were
processed at the site. and it is the gross alpha. radium-226. radium-228.
and metals content of uranium processing wastes that are regulated by these
standards.
The regulations allow for situations where numerical standards may be
inappropriate and allow other standards (supplemental standards) to be used
for remedial actions where the action would produce environmental harm in
excess of the derived health benefits. The supplemental standards could
pertain to the proposed remedial action involving the clean-up portion or
steep slopes. and the Monticello Cemetery.
The selected remedy will meet 40 CFR 192. Subpart A requirements by proper
design of the repository cell. Design parameters of the repository will
follow the latest Uranium Mill Tailings Remedial Action Program guidance.
developed to assure compliance with 40 CFR 192 performance criteria.
Repository components finalized during the design phase will be chosen to meet
the minimum of 200-year effectiveness and the desired 1.000-year effectiveness
requirements. including a radon cap placed on the pile to minimize radon gas
emanation. Water infiltration through the pile and erosion of the pile will
be minimized by top cover and side slope design. The 40 CFR 192. Subpart A
standards follow:
"Subpart A - Standards for the control of Residual Radioactive Materials from
Inactive Processing Sites
192.02
Standards
Control shall be designed to:
(a)
Be effective for up to one thousand years. to the extent
reasonably achievable. and. in any case. for at least 200
years. and.
(b)
Provide reasonable assurance that releases of radon-222 from
residual radioactive material to the atmosphere will not:
(1)
Exceed an average release rate of 20 picocuries per
square meter per second. or
(2 )
Increase the annual average concentration of radon-222
in air at or above any location outside the disposal
site by more than one-half picocurie per liter."
The requirements of 40 eFR 192. Subpart B will be followed as clean-up
standards for peripheral properties and for the millsite itself. Subpart C
requirements will be followed by the Department of Energy when proposing the
use of supplemental standards at the Monticello Cemetery and densely vegetated
hillsides on the south side of Montezuma Creek. The subparts follow:
"Subpart B - Standards for Cleanup of Land and Buildings Contaminated with
Residual Radioactive Materials from Inactive Uranium Processing Sites
192.12
Standards
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 not exceed the background
level by more than -
40
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(1)
5 pCi/g. averaged over the first 15 cm of soil below
the surface. and
( 2 )
15 pCi/g. averaged over 15 cm thick layers of soil more
than 15 cm below the surfac~.
(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) that shall ~~t
exceed 0.03 WL. and
( 2 )
The level of gamma radiation shall not exce~d the
background level by more than 20 microroent~ens per
hour."
Subpart C - Implementation (summarized)
192.21
Criteria for ApDlvin~ Supplemental Standards
The implementing agencies may apply standards in lieu of the
standards of Subparts A or B if certain circumstances exist. as
defined in 192.21.
192.22
Supplemental Standards
"Federal agencies implementing Subparts A and
proceed pursuant to this section with respect
individual situations meeting the eligibility
192.21."
B may in lieu thereof
to generic or
requirements of
(a)
".. .the implementing agencies shall select and perform remedial
actions that come as close to meeting the otherwise applicable
standards as is reasonable under the circumstances."
(b)
".. . remedial actions shall. in addition to satisfying the
standards of Subparts A and B. reduce other residual
radioactivity to levels that are as low as is reasonably
achievable."
(c)
"The implementing agencies may make general determinations
concerning remedial actions under this Section that will apply
to all locations with specified characteristics. or they may
make a determination for a specific location: the Department of
Energy shall inform any private owners and occupants of the
affected location and solicit their comments. The Department of
Energy shall provide any such comments to the other implementing
agencies (and) shall also periodically inform the Envircnmental
Protection Agency of both general and individual determinations
under the provisions of this section."
Protection of ground water is also provided for in 40 eFR Part 192 (a) (2) and
(3). The Department of Energy has agreed to comply with the "Proposed
Standards for Remedial Action at Inactive Uranium Mill Processing Sites with
Ground-Water Contamination" (52 FR 36000. September 24. 1987). Although
neither applicable or relevant and appropriate. these standards are "to be
considered" and are further discussed in Section 10.2.5.
41
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A second contaminant-specific requirement for the Monticello Mill Tailings
Site is the Clean Air Act. National Emission Standard for Hazardous Air
Pollutants (40 CFR Part 61. Subpart Q. Section 61.192) which sets standards
for emissions of Radon-222 into the air from storage and disposal facilities
for radium-containing materia2' No source at a Department of Energy facilitv
shall emit more than 20 pCi/m -s (per unit of time) of radon-222 as an average
for the entire source. This is an applicable requirement for the Monticello
Mill Tailings Site. at the existing millsite tailings piles and at the new
tailings repository. The radon barrier for the repository will be designed to
meet the radon emanation requirements. A compliance agreement between the
Environmental Protection Agency. the State of Utah. and the Department of
Energy will be negotiated during remedial design to meet the requirements of
this regulation.
The State of Utah's Standards for Quality for Waters of the State (Title 26.
Chapter 11. U.C.A. R448-2 UAC) and the Utah Pollution Discharge Elimination
System (Title 26 Chapter 11. UCA. R448-8 U.A.C.) are applicable to any surface
waters discharged from the site. For Operable Unit I. this will include
surface water discharges resulting from the dewatering of tailings. pore water
from contaminated soils. water collected in the repository (disposal cell)
during construction or placement of the tailings and/or other surface waters
collected on site. Any of these waste waters entering Montezuma Creek shall
be treated to comply with the discharge requirements and to meet the water
quality standards.
The Utah Occupational Safety and Health Standards (Title 35. Chapter 9.
U.C.A.. R 500. U.A.C.) establish. implement. and enforce occupational health
and safety standards similar to the Federal regulations. The State
requirements incorporate the radiation exposure limits promulgated in 10 CFR
Part 20. These standards are applicable to all work activities involved in
the remediation of Operable Units I and II.
10.2.2
Location-Specific Requirements
Physical characteristics of the Monticello Mill Tailings Site influence the
type and location of remedial responses considered for Operable Units I and
II. The location-specific requirements identified for the site (see
Appendix B) establish consultation procedures with Federal and State agencies
and may impose constraints on the location of remedial measures or may require
mitigation measures. Location-specific requirements for Operable Units I and
II relate to historic preservation. fish and wildlife. wetlands/floodplains.
farmlands. and work in navigable waters.
Both Federal and State laws provide for protection of historical resources.
There may be sites eligible for Federal or State historical registers. All
regulations relating to historic preservation will be followed. Prior to
disturbing peripheral properties. the State will be notified. and the results
of archaeological surveys performed by the Department of Energy will be
discussed to determine any mitigation necessary.
Wetlands and floodplain requirements will be applicable for both Operable Unit
I and Operable Unit II. The tailings piles and the former millsite are in the
floodplain of Montezuma Creek and the Corps of Engineers has identified
wetlands along Montezuma Creek. Agency policy and guidance for carrying out
the provisions of Executive Order 11988 "Floodplain Management" and 11990
"Protection of Wetlands" have been promulgated in 40 CFR Part 6 "Appendix A".
The Department of Energy has performed a floodplain/wetlands assessment. in
accordance with 10 CFR 1022. "Compliance with Floodplain/Wetlands
Environmental Review Requirements." the results of which are included in the
Feasibility Study. Appendix B. Mitigation for floodplain/wetlands areas where
impact is unavoidable include revegetation and replacement of soil where
removed. Following diversion of Montezuma Creek during millsite remediation.
42
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the creek will be returned to its pre-millsite historic channel. the channel
will be vegetated with wetland species. revetments will be added to prevent
bank erosion. and the stream bottom will be modified with rock riffle/pool
structures to enhance aquatic habitat.
The Farmland Protection Policy Act (7 CFR Part 658) identifies standards a~d
criteria for identifying and taking into account adverse impacts on
significant/important agricultural lands. The U.S. Soil Conservation Service
has stated in a letter dated 4. June 1990. that the proposed repository
location does not meet the requirements of prime. unique or important
farmland. Peripheral properties will also be evaluated to determine if
significant/important agricultural lands exist. The Act's requirements will
be followed t~ mitigate any adverse impacts to these areas. Other loca~ion-
specific standards are identified in Appendix B.
10.2.3
Action-Soecific Requirements
Action-specific requirements are 'technology-based restrictions triggered by
specific types of remedial measures under consideration. Once the remedial
action alternatives were developed for Operable Units I and II in the
feasibility study. the Environmental Protection Agency and the State of Utah
identified action-specific requirements which were applicable or relevant and
appropriate to the remedies considered. The Uranium Mill Tailings Radiation
Control Act and implementing regulations at 40 CFR 192. and the Occupational
Safety and Health Act and implementing regulations at 29 CFR 1910.96 and
1926.58. double as action-specific requirements for the millsite and
peripheral properties. Compliance with these regulations was discussed
Section 10.2.1. Appendix B identifies all action-specific requirements
have been identified for the selected remedies for Operable Units I and
in
which
II.
10.2.4
"To Be Considered" Requirements
In addition to the requirements mentioned above. ~he Environmental Protection
Agency considered other Federal and State criteria. advisories. and guidance
in determining the appropriate degree of clean up for the Monticello Mill
Tailings Site. The following requirements are not "applicable" or "relevant
and appropriate". but have been agreed to by the Department of Energy.
Environmental Protection Agency. and the State of Utah as "to be considered"
when determined to be pertinent to the clean up at the Monticello Mill
Tailings Site. Operable Units I and II.
Guidance on designing the repository (Uranium Mill Tailings Remedial Action
Program research and practice). including the latest revision of the
Technical Approach Document:
As discussed above. guidance developed by the Department of Energy and the
Nuclear Regulatory Commission to assist in meeting the requirements of 40
CFR 192. Subpart A. will be followed during repository design activities.
Guidance establishing standards and requirements for the Department of
Energy and its contractors with respect to protection of the public health
and environment against radiation (Department of Energy Order 5480.1):
As with occupational health and safety standards.
requirements for protection of the public and the
radiation will be enforced during all remediation
will be monitored appropriately.
Radiologic protection guidelines (hot-spot criteria) for clean up of
residual radioactive material and management of the resultant wastes and
residues (U.S. Department of Energy Guidelines for Residual Radioacrive
Material at Formerly Utilized Sites Remedial Acrion Program and Remore
Surplus Facilities Management Program [Revision 2. March 1987])":
Department of Energy
environment against
activities. Compliance
43
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The Department of Energy's hot-spot criteria will be used for both Operable
Units I and II when surface or subsurface soil concentrations in a
specified area exceed the 40 CFR 192.12 standards by a certain factor. The
approach for determining the site-specific hot-spot criteria. referred to
above. will be followed.
"Proposed Standards for Remedial Action at Inactive Uranium Processing
Sites with Ground-Water Contamination" (52 FR 36000. September 24. 1987)
will replace existing -ground-water protection standards at 40 CFR 192.20
(a) (2) and (3). It requires clean up of contamination that occurred before
the tailings are stabilized and also requires that tailings be stabilized
and controlled in a manner that eliminates or minimizes the contamination
of ground water. The proposed standards specify that remedial actions at
processing sites will comply with 40 CFR Part 264. Sections 264.93.
hazardous constituents. and 264.94. concentration limits. Table 1 in
Section 264.93 identifies the constituents and the maximum concentration
limits allowable. In addition to those constituents listed in 264.93. the
proposed rule includes concentration limits for molybdenum. nitrate.
combined radium-226 and radium-228. and combined uranium-234 and uranium-
238. The limits for other constituents are set at their background level
in ground water at the regulated unit.
During the remedial design phase for Operable Unit I. a monitoring program
will be developed to evaluate background concentrations for ground-water
compliance purposes and to monitor repository performance with respect to
ground-water contamination. The program will assess cell integrity by .
monitoring compliance with specific ground-water constituents. determined
in accordance with the proposed regulations. In accordance with the
proposed rule. corrective action would be invoked if noncompliance with the.
ground-water standards occurs.
10.3
COST EFFECTIVENESS
The selected remedy is cost-effective because it has been determined to
provide overall effectiveness proportional to its costs. The selected remedy
for each operable unit represents the most cost-effective alternative of the
alternatives evaluated in the feasibility study. where cost-effectiveness is
defined as the reduction in threat to public health and the environment per
dollars expended.
The estimated cost of the selected alternative for Operable Unit I ($42.3
million) is approximately 60 percent of the cost of the off-site disposal
alternative. but provides the same level of long-term protection and involves
fewer short-term risks. The selected alternatives for Operable Unit II may
range in cost from $12.648 million and $18.460 million. depending upon the
remedial method employed for specific land types.
10.4
UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE AND PREFERENCE FOR
TREATMENT AS A PRINCIPAL ELEMENT
The selected remedy does not employ treatment or resource recovery
technologies. Although several treatment technologies were evaluated during
the process of developing alternatives for the site. most of them were found
to be either technically unfeasible or inadequately tested for use with
radiologic contaminants under conditions in existence at the site. None of
the available treatment technologies would permanently reduce the toxicity of
radiologic contaminants by reducing their mass. Treatment technologies that
would result in a reduction in volume require handling and disposal of
residuals that could present additional health risks to workers or the
environment. and were not as cost-effective as the selected alternatives.
Treatment technologies that could result in a reduction in mobility were
either untested or were not cost-effective.
44
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The selected remedy will reduce human health risks to the maximum extent
practicable for the Monticello Mill Tailings Site. with maximum short-term
effectiveness. The selected remedy employs well-accepted and easily
implementable techniques and would achieve maximum cost-effectiveness.
45
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APPENDIX A
MONTICELLO MILL TAILINGS SITE
RESPONSIVENESS SUMMARY
-------
APPENDIX A
MONTICELLO MILL TAILINGS SITE
(Monticello. Utah)
RESPONSIVENESS SUMMARY
1.0
OVERVIEW
This Responsiveness Summary responds to comments received during the public
comment period on the Remedial Investigation/Feasibility Study (RI/FS) and
Proposed Plan for the U.S. Department of Energy's Monticello (Utah) Mill
Tailings Superfund Site remedial action project. It should be noted that
reference is often made to this project as the Monticello Remedial Action
Project. or MRAP. as it is titled under DOE's Surplus Facilities Management
Program. The Monticello Millsite RIfFS and Proposed Plan were available to
the public for comment from October 27 through November 25. 1989. The comment
period was extended until December 19. 1989 to accommodate additional
comments.
At the time of the public comment period. the U.S. Department of Energy (DOE)
had proposed preferred alternatives for the three Operable Units (OUs) of the
Monticello Remedial Action Project. The proposed preferred remedial action
alternative for Operable Unit I (Tailings) would be to remove the
approximately 2 million cubic yards of tailings from the millsite. the
peripheral properties. and the vicinity properties and relocate them to a
designed disposal cell at a site south of their present location.
Based upon the verbal comments received during the public meeting. the
residents and City of Monticello have no objections to the proposed preferred
alternative for OU I. Written comments received during the public comment
period indicate the Umetco Minerals Corporation. Boulden Contracting Company.
Rio Algom Mining Corporation. and Ecology and Environment. Inc. prefer the
second alternative for OU I. removal of tailings to a licensed repository.
However. the State of Utah Bureau of Radiation Control has indicated that
current state policy does not allow the disposal of Comprehensive
Environmental Response. Compensation. and Liability Act (CERCLA) materials at
Nuclear Regulatory Commission (NRC) disposal sites. Two local ranchers
suggested that land currently owned by the government be used instead of
purchasing additional private land for the south site location. Written
comments from Rio Algom Mining Corporation questioned the cost differences
between alternatives 1 and 2 and requested a clarification of those
calculations. In addition. the U.S. Environmental Protection Agency Region
VIII (EPA) and the State of Utah (State) have submitted written questions
regarding engineering design of the preferred alternative for OU I.
The proposed preferred alternative for Operable Unit II (Peripheral
Properties) is to use a combination of conventional construction and
environmentally sensitive construction methods for clean up to the 40 CFR
192.12 standards depending on the nature of the contamination and the type of
land. Supplemental standards (leaving some or all of the contamination in
place) could potentially be applied in specific areas where the clean up would
cause excessive environmental damage in comparison to the derived
environmental and health benefits.
A-1
-------
No written concerns were expressed relative to the proposed remedial aCcion
for the peripheral properties. One comment expressed at the public mee~ing by
an employee of the City of Monticello requested clarification of the proposed
use of supplemental standards at the cemetery.
The Department of Energy's proposed preferred alternative at the time of the
public comment period for Operable' Unit III (Ground Water) was to remove the
source of the contamination (mill tailings) and to allow passive restoration
of the ground water. Passive restoration would entail natural flushing ~f the
Alluvial aquifer over a 60-year time period with institutional controls t~
limit access to ground-water use. The State and EPA submitted written
comments regarding the technical aspects of passive restoration.
Written comments from Boulden Contracting Company. the Rio Algom Mining
Corporation and Ecology and Environment. Inc. supported more active ground-
water treatment methods and a reduction of the time-span for ground-water
clean up. The Southeastern Utah District Health Department expressed concern
that present and future downstream uses of Montezuma Creek water hai not been
fully taken into consideration and proposed that the final clean-up plan
incorporate a suitable measure of health protection for all present and
potential users.
Since this time. EPA. the State of Utah. and DOE. have agreed to evaluate
remedial action alternatives for ground water and surface water following
completion of remedial action for Operable Units I and II. This approach is
presented in the Record of Decision.
More detailed responses to verbal and written comments received during the
public comment period appear in Section 3.0. Summary of Comments Received
During the Public Comment Period and Agency Responses.
These sections follow:
Background on Community Involvement.
Summary of Comments Received During the Public Comment Period and
Agency Responses.
Remaining Concerns. and
.
Attachment: Community Relations Activities for the Monticello
Millsite Superfund Site.
2.0
BACKGROUND ON COMMUNITY IW10LVEMENT
Community relations activities by the U.S. Department of Energy's Grand
Junction Projects Office have been ongoing since 1980. A list o£ community
relations activities is included as an attachmen~ to this R~sponsiveness
Summary. Contact has been predominantly through periodic tiefings of city
and county officials. State of Utah representatives. local iedia. and
individual peripheral property owners. Periodic press releases and fact
sheets have been issued and several public meetings have been conducted on
Monticello clean-up activities. Community interest in the clean up of the
Monticello millsite has been very low with few community concerns expressed.
A-2
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The low public concern can be accounted for by several factors:
Local citizens have lived and worked with the uranium mining and
milling industry since the early 1940's. Many made their liveiihood
from those industries.
Most citizens do not view the mill tailings as a serious
hazard. and the majority of the community is unconcerned
presence of contamination.
health
about the
Interim site stabilization has been in place since
millsite tailings piles blend into the surrounding
not been perceived as a hazard or eyesore by local
Routine monitoring and maintenance of the millsite
in place since stabilization.
1964. The
terrain and have
residents.
tailings has been
Work has been in progress at the Monticello
several years and local residents are aware
process of cleaning up the mill tailings in
Vicinity Properties far
that DOE is in the
the area.
General community concerns expressed in the past have centered on the
following issues:
Safety
Community concerns relating to any type of prolonged mill tailings
remedial action construction activity include increased potential fa=
car/truck accidents. and concern that spills could occur that may
affect the community and environment along the transportation route.
City officials have expressed concern about road damage from truck
traffic and the need to provide funding for road upgrading and
routine repair.
The proposed preferred alternative for au I is relocation of the
tailings pile out of the Montezuma Creek floodplain to an on-site
location south of the present site. Worker commuter traffic to and from
the site will increase as will equipment haulage by truck when compared
to the normal traffic patterns. These effects would not be expected to
present serious inconveniences to the general public. Heaviest movement
of equipment during pile relocation would be restricted to the site. An
on-site road would be constructed and used during the tailings
relocation process. thus eliminating heavy truck traffic on public
roadways.
Recently. the
Monticello in
tailings from
disposal.
Department of Energy agreed to share with the City of
the repair costs of those roads used by DOE to move
the Vicinity Properties to the millsite for ultimate
Noise/Dust Control
Some concern has been expressed about noise and dust impacts on
properties close to the millsite during remediation.
A- 3
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Noise impacts would most affect on-site workers. Hearing protection
will be provided and impacts on neighboring properties should be
negligible. Dust control will be exercised during remediation using
established methods and procedures.
Tourism
Monticello derives some income from tourist traffic. Potential l~ss
of tourist trade during remedial action is a local concern.
Any economic loss due to decreases in the tourist industry should be
minimal and should be at least partially offset by increased income to
the community through contractor payrolls. lodging and purchases of
goods. etc. DOE estimates that during the multi-year construction
period. about 43 jobs will be filled by local residents. with another
estimated 83 indirect jobs being created by the project. Furthermore.
implementation of the proposed alternative minimizes highway impacts.
3.0
SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
AND AGENCY RESPONSES
Comments raised during the Monticello Millsite public comment period on the'
RIfFS and Proposed Plan are summarized briefly below and agency responses are
provided.
3.1
SUMMARY OF QUESTIONS RECEIVED AT THE PUBLIC MEETING ON THE MRAP
RIfFS AND PROPOSED PLAN ON NOVEMBER 16. 1989.
The following is a summary of comments received and responses made at the
public meeting held in Monticello. Utah. on November 16, 1989. The transcript
from the public meeting is located in the Administrative Record in the San
Juan County Library and contains all questions asked and full responses made
during the meeting.
3.1. 1
General Comments
1)
Several questions asked for clarification of the differences between
the Monticello site and Uranium Mill Tailings Remedial Action (UHTRA)
sites.
DOE RESPONSE: Unlike UMTRA sites. the Monticello millsite was owned
and operated by DOE. Therefore. it cannot be remediated under DOE's
UMTRA Program. Unlike UMTRA projects. the State does not share costs
on the millsite project. DOE is the principal responsible party and
bears clean-up costs.
2 )
The local public and local contractors were interested in whether the
project can be broken down into smaller units so that local
contractors may bid on remediation activities.
A-4
-------
3.1.2
DOE RESPONSE: Certain phases of the clean-up activities can be
broken down into smaller units. such as peripheral properties
remediation and site preparation activities. There will be many
instances where local contractors will be in a good poSition to
provide contracting services.
3 )
At the public meeting a request was made by the Rio Algom Mining
Corporation to extend the public comment period to January 5. 1990.
DOE RESPONSE: DOE was unable to respond to this question during
public meeting because the decision was EPA's responsibility.
Therefore. a response is now provided.
the
The public comment period started with the release of the RIfFS and
Proposed Plan on October 27. 1989. On that date. the RIfFS and the
Proposed Plan were placed in the Administrative Record at the
Information Repository locations. Additional copies were sent to ke::
contacts. Two Notices of Opportunity to Comment were published in
the San Juan Record. On November 16. 1989. DOE. EPA. and the State
held a public meeting in Monticello to receive any comments on the
two documents. The comment period initially allowed four weeks for.
comment and was scheduled to end on November 25. 1989. but was
extended to accommodate additional comments. With the extension.
which was agreed to by EPA and the State. the comment period ended on
December 19. 1989. Rio Algom Mining was also informed by EPA that
any written comments by the company would be accepted following the
close of the public comment period. Rio Algom submitted comments on
December 1. 1989.
4)
Several questions related to the overall cost of the millsite project
and to the length of time that the project has been "studied".
DOE RESPONSE: Currently. under oOE's five-year plan which
prioritized clean-up activities and associated funding. the
Monticello Mill Tailings Site is a "priority one" site. The current
cost estimate of approximately $65 million for clean up of the
millsite includes Federal Facility Agreement development. RIfFS. NEPA
documentation. etc.. as well as remedial design and remedial action.
Operable Unit I - Monticello Millsite
1 )
A local resident asked whether DOE would retain ownership of the
millsite area following remediation.
DOE RESPONSE: The site will have to be verified as being clean and
must be de-listed from the National Priority List prior to being
released by the Federal government for private use or ownership.
A- 5
-------
3.1.3
2)
Many questions were asked regarding the proposed South Site remedial
action alternative. including cap design. physical location ot the
repository. slope considerations. physical security. etc.
DOE RESPONSE: General details regarding repository design have been
identified in the Montic~llo millsite RI/FS and were reviewed at the
public meeting. Specific cetails of repositcry design. physical
location. security measures. etc.. will be determined during remedial
design. Community relations activities to be performed during
remedial design include issuing fact sheets and providing a public
briefing following final design.
3 )
The mayor asked what ramifications would occur if the City expanded.
Related questions involved how close development could come to the
final repository and whether the proposed repository site is wit~in
current City limits.
DOE RESPONSE: The proposed repository site is not within City
limits. Repository design will include concern for aesthetics to tte
surrounding community. The acceptable distance (or buffer zone)
needed between the repository and the local community will vary
according to land use. Commercial or industrial use could be allowed
to take place closer to the repository than residential dwellings.
Specific answers will be developed during remedial design.
4)
The representative of an engineering firm asked whether the same
disposal standards would apply to the tailings if hauled to a
currently licensed facility.
DOE/STATE OF UTAH RESPONSE: The State responded that current policy
allows no CERCLA waste to be disposed of with wastes at NRC-licensed
facilities. Barring State policy. the same disposal standards would
apply. The State of Utah Bureau of Radiation Protection would take
the lead on issues regarding disposal standards.
Operable Unit II - Peripheral Properties
1)
A representative from the Southeastern Utah District Health
Department asked for examples of supplemental standards usage.
DOE RESPONSE: One area where supplemental standards have been used
traditionally is for utility lines under pavement and sidewalk. They
have also been proposed for cemeteries.
2 )
Several questions were raised regarding the proposed use of
supplemental standards at the cemetery in Monticello.
DOE RESPONSE: The use of supplemental standards. as described in
40 CFR 192. may be proposed for the cemetery. Prior to a decision
being made to leave the tailings in place under the supplemental
standards provision. DOE will prepare a detailed docume~t for State
and EPA review and concurrence which evaluates any impact to human
health and the environment.
A- 6
-------
3)
A Monticello resident asked whether the golf course in Monticello is
contaminated.
DOE RESPONSE: The answer given at the public meeting was that the
golf course is not contaminated. This is in error. The golf course
is contaminated with mill tailings and will be remediated under the
Monticello Vicinity Properties project.
3.1.4
Operable Unit III - Ground Water
A summary of questions from the meeting and agency responses follows. It
should be noted. however. that DOE has agreed with EPA/and the State to
postpone evaluation of the ground water and surface water until after
remediation 'of the millsite and peripheral properties. Therefore. answers to
questions regarding potential ground-water remedial action alternatives are
provided. but a focused Remedial Investigation/Feasibility Study and Record of
Decision will follow at a later date to determine the appropriate remedial
action.
1)
A local resident asked about the duration of passive restoration and
how clean the ground water will be at that point in time.
DOE RESPONSE: Modeling done for the millsite indicates that if
passive restoration of the ground water is chosen as an alternative
for ground-water remediation. approximately 60 years would be needed
to reduce the contaminants in the alluvial aquifer to acceptable
levels. based on current levels of contamination.
2 )
Several questions were asked regarding how far the ground-water plume
has traveled and how far it will travel in sixty years.
DOE RESPONSE: Since several
the issue. DOE's response is
on page A-15.
written comments were also received on
found in Section 3.3 of this Appendix.
3.2
WRITTEN COMMENTS RECEIVED ON THE CERCLA PROCESS
1)
EPA requested additional information regarding why all but one of the
off-site alternatives was eliminated during the preliminary screening
process.
DOE RESPONSE: The preliminary screening process involved evaluating
each potential repository location with respect to effectiveness.
implementability. and cost. The evaluation also included an
evaluation of compliance with the major action-specific ARAR. 40 CFR
192. "Standards for Remedial Actions at Inactive Uranium Processing
Sites". Based on this ARAR. 25 siting criteria were established and
each potential site was evaluated against the criteria.
Seven potential off-site repository locations within 12 to 45 miles
of the site were evaluated during the preliminary screening process.
Based on the screening process. the Highway 9S site was selected as
the most suitable of these sites and was kept for further study in
the FS. This location was ultimately eliminated during the detailed
A-7
-------
analysis of alternatives because of relatively high cost and concerns
with implementability. The other six sites exhibited substantially
higher potentials for wind and water erosion. flooding. and
landslides. Design longevity questions. ground-water concerns. and
endangered species considerations also were reasons for dropping the
other six sites. All potential off-site locations required transport
of contaminated materials for various distances on public roads.
2) The State requested that a site-specific health and safety plan be
developed.
DOE RESPONSE: This activity is scheduled to be performed during the
design phase of the project and will be completed prior to performing
field work.
3) The State and EPA made numerous editorial comments and technically-
oriented substantive comments on the draft final MRAP RIfFS and
Proposed Plan.
DOE RESPONSE: Editorial and grammatical comments on the RIfFS are
incorporated in the final MRAP RIfFS by the addition of errata
sheets. Neither editorial nor grammatical comments on the Proposed'
Plan were incorporated since the Proposed Plan served its one-time
purpose during the public review and comment period.
Substantive technical comments made on the RIfFS and Proposed Plan
are responded to in this Responsiveness Summary and in addition. have
been incorporated into the Record of Decision.
4) The EPA and State had several comments regarding Applicable or
Relevant and Appropriate Requirements (ARARs). EPA clarified the
appropriateness of RCRA as an ARAR by stating that 40 CFR 192. (the
predominant relevant and appropriate regulation for the Monticello
millsite cleanup) and proposed amendments "... provide sufficient
protective conditions to make the determination that additional RCRA
Subtitle C regulations are neither relevant or appropriate.. .". The
State noted several additions to the list of ARARs currently defined
for the project.
DOE RESPONSE: Under CERCLA. ARARs identification is termed an
iterative process. Based on the promulgation and identification of
several new State laws. and resolution of. the RCRA issue. it is
appropriate that a final list of ARARs be included in the Record of
Decision. No ARARs discussions were modified in the draft MRAP RIfFS
in response to these comments. However. an errata was added that
refers to the ARARs table in the Record of Decision. Appendix B.
5) The EPA commented that several MRAP FS appendices make reference to
two preliminary remedial action alternatives. one involving slurry
walls within the aquifer. and one consisting of stabilization in
place for the mill tailings.
A-a
-------
DOE RESPONSE: The FS appendices were prepared prior to the knowledge
of proposed changes to 40 CFR 192. which address ground-water quality
at mill tailings sites. The two preliminary alternatives discussed
in the appendices were dropped from consideration as remedial action
alternatives in the FS for this reason. However. these appendices
still contain relevant information for the remedial action
alternatives identified in the FS and remain as originally written.
3.3
WRITTEN TECHNICAL QUESTIONS/CONCERNS RECEIVED REGARDING REMEDIAL
ALTERNATIVES
1 )
EPA and the State have made several comments on the design f~r the
preferred alternative (removal and disposal on-site. south of the present
site). These include location of the repository and repository design.
DOE RESPONSE: DOE is in agreement with both the State and EPA that the
entire south area. comprising the near South Site and far South Site.
should be identified as the repository area (see Figure 9-1). This
clarification has been incorporated into the ROD and will allow
flexibility in the design process to site the repository in an ideal
position based on further investigation of the site. As recommended by .
EPA. DOE has expanded its current geotechnical investigation to identify
the design constraints posed by topography. geology. and ground-water
conditions. The existing drilling investigations will include a ground-
water study and analysis which will provide sufficient data to identify
the piezometric surface both in the alluvium (pediment gravels) and in the
underlying Mancos Shale. Based on these findings. a determination will be
made as to whether the near South Site is an acceptable repository site
that provides protection of human health and the environment. If the near
South Site is determined to be unacceptable to the State and EPA. the
repository will be located on the far South Site. Both the State and EPA
consider this design approach for on-site remedial action as appropriate.
DOE is in agreement with EPA and the State on the principle that the
repository must be designed and constructed to comply with 40 CFR Part
192. Title I design criteria. This design must be based on comprehensive
studies of the tailings and repository site characteristics. These
studies are either currently in progress or are scheduled during the
design phase. The primary design guidance is the UMTRA Technical Approach
Document (TAD) which includes the latest acceptable repository design
approach. The preliminary design presented in the FS is based on the TAD.
other UMTRA research. and DOE/NRC research for long-term repositories with
up to a l.OOO-year life. A mutual~y acceptable design will be agreed to.
once the design review process is initiated. It is also recognized that
new information will be forthcoming in revised TAOs that will also change
the design concept of the repository. The final repository design will be
based on the latest research and experience available. and will be
approved by the State and EPA.
A-9
-------
2)
EPA and the State made several comments regarding the selection and
effectiveness of passive restoration of the ground water.
DOE RESPONSE: DOE agrees with EPA and the State that the Proposed Plan
provides for the ground-water contamination to be cleaned up in accordance
with 40 CFR Part 192. Some active ground-water treatment measures would
initially be employed during the tailings (source) removal activities to
de-water tailings. Activities to be implemented prior to mill tailings
remediation involve implementing institutional controls (consisting of
buying or leasing water rights. for example) to restrict any potential
public use of the ground water and implementation of a monitoring program
to evaluate changes in ground-water contamination as a result of tailings
removal.
Throughout construction of Operable Units I/II. a ground-water monitoring
program of the Alluvial and Burro Canyon aquifers will be conducted. This
monitoring program will continue for three years after removal of the
contaminated material. As monitoring continues during the three year
period. DOE. EPA. and the State will periodically review the results of
the monitoring data and determine what additional steps. if any. will be
required to complete aquifer restoration. When sufficient data has been
gathered to warrant a final decision for ground-water restoration. a
Record of Decision will be produced for Operable Unit III.
3)
Various comments were received from EPA. the State of Utah. two nearby NRC-
licensed millsites. and construction and consulting firms pertaining to
the cost comparisons and design requirements for the various alternatives.
DOE RESPONSE: The cost estimates and design requirements presented in
RIIFS were developed utilizing consistent criteria for regulatory
considerations. technical design. DOE subcontracting. and procurement
practices. Some of the specific questions raised include:
the
3a) Why the cost savings associated with placing the tailings into existing
NRC-licensed disposal sites was not utilized for the off-site disposal
alternative.
There are several significant problems with disposing of these CERCLA
materials in an NRC-licensed millsite.
. State of Utah policy prohibits the disposal of CERCLA material at an
NRC-licensed millsite.
The MRAP repository design must comply with UMTRCA Title I requirements
for inactive millsites. Title II requirements for licensed millsites do
not necessarily fulfill all Title I requirements for the 200- to 1.000-
year repository design life.
. DOE would be unwilling. given the perpetual legal liabilities for
CERCLA materials. to co-dispose the Monticello tailings with any other
millsite materials that may have pre-existing site releases or design
inadequacies. The only feasible off-site alternative from a liability
standpoint would be to construct a separate repository cell complying
with Title I requirements for the CERCLA materials.
A-lO
-------
3b)
DOE was asked why the COSt estimates seemed to be much higher than
commercial practice for uranium millsite remediation.
These estimates are based upon R.S. Means data. incorporating the requirements
for CERCLA and DOE quality assurance and environmental. health. and safety
standards. In addition. DOE requires all subcontracted activities to comply
with Davis-Bacon wage rates. Specific questions and responses are detailed
below.
3c)
According to the Superfund guidance as stated on page 4-8 of the
Feasibility Study. inflation must be taken into account before present
worth analysis can be performed. In the cost estimates. the costs are
expressed in 1989 dollars and are allocated to the year in which they
occur without taking into account inflation. It appears that the costs
are then discounted. If inflation has not been incorporated in the
analysis. please make the appropriate changes to include inflation or
justify why inflation was neglected.
According to the March 1988 Superfund guidance. a discount rate of 5 percent
before taxes and after inflation should be assumed. This discount rate takes
into account inflation. If all costs were inflated. a higher discount rate
would have been used. Regardless of which approach is used. the net result 'of
the ranking of alternatives by cost would not change.
3d)
In the cost estimates. some years appear to have two operating costs.
For example on page F-23 of the FS report. the year 1996 has a cost of
$250.000 and $42.000. Please explain this apparent inconsistency.
Environmental monitoring at an operating cost of $250.000 per year begins in
1990 and is completed by the end of 1995 (beginning of 1996). Ground-water
monitoring at an operating cost of $42.000 per year begins in 19?6 and is
completed by the end of 2019 (start of 2020). The year 1996 has only one
operating cost of $42.000.'
3e)
Some of the present worth calculations cannot be reproduced.
example. the operating and maintenance costs on page F-23 of
report. Please make any necessary corrections.
For
the FS
The present worth calculations have been recalculated. While the capital
costs are the same. there are some minor changes in the operating and
maintenance costs. None of the changes i~ cost change the overall ranking
alternatives. Table A3-1 shows correct calculations of present worth.
3f)
of
Please explain why the specified percentages were chosen for the
indirect costs and the contingencies.
The percentages for indirect costs are based on currently utilized cost data
for other construction projects administered for the Department of Energy.
The percentage for contingencies is typical for alternatives in a preliminary
or conceptual phase.
3g)
Please explain
subcontracting
percentage.
why labor. materials. equipment. and potential
items should all be allocated the same overhead
A-11
-------
Table A3.1.
P~esent Worth Calculations
for the Monticello Millsice
Proj ec c
THIS TABLE WILL CALCULATE PRESE~T WORTH VALUES WHEN GIVE~;
DISCOUNT RATE (%), CAPITAL COSTS AND O&~ COSTS IN THE YEAR
OF EXPE:-1DITURE
PROJECT: OPERABLE UNIT I, Alternative 3
PRESE~T WORTH CALCULATION TABLE
DOLLARS IN $1000
i= 5 % START DATE 1989
t= 31 years END DATE 2019
PRESENT WORTH = S42,346,398
A B C D E F
YEAR CAPITAL O&~ ANNUAL DISCOUNT PRESENT
COST COST COSTS EXPENDITURES FACTORS* wORTH
I OCCURS I B+C : (1/1+U"t: D*E
I I
---------------------------------------------------------------------
---------------------------------------------------------------------
" I I I I I I
I I I I I I I I
, 0 I 1989 I I I 0 I 1.000 I $0 I
I I I " I I I
, 1 I 1990 I I I 0 I 0.952 I SO I
I I I I I I I I
I 2 I 1991 I I I 0 I 0.907 I SO I
I I I I I I I I
, 3 I 1992 :13035000 ' I 13035000 I 0.864 :$11,260,123 I
I I I I I I
I 4 I 1993 :13035000 ' I 13035000 I 0.823 :SlO,i23,927 '
I I I I I ,
I 5 I 1994 :13035000 I I 13035000 I 0.i84 :$10,213,264 I
I I ' I I I
I 6 I 1995 :13035000 I I 13035000 I 0.H6 I S9,i26,918 I
I I I I I I I
, 7 I 1996 I I 41000 I 41000 I 0.711 I $29.138 I
I I I I I I I I
I 8 I 1997 I I 41000 I ~1000 I 0.617 I $21,750 I
I I I I I I I I
I 9 I 1998 I I 41000 I 41000 I 0.645 I $26,429 I
I I I , I I I ,
I 10 I 1999 I I 41000 I 41000 I 0.614 I S25,1iO '
I I I I I I I I
I 11 I 2000 I I 41000 ' 41000 I 0.585 I 523,972 I
I I I I I I I I
I 12 I 2001 I I 41000 I 41000 I 0.557 I $22,830 I
I I I I I I I I
I 13 I 2002 I I 41000 I 41000 I 0.530 I S21, H3 I
I I I I I I I I
I 14 I 2003 I I 41000 I 41000 ' 0.505 I S20,708 I
I I I I I I I I
I 15 I 2004 I , 41000 I 41000 I 0.481 I $19, i22 '
I I I I I I I I
I 16 I 2005 I I 41000 I 41000 I 0.-'58 I $18, 783 I
I I I I I I I I
I 17 I 2006 I I 41000 I 41000 I 0.436 I $17,888 I
I I I I I I I I
I 18 I 2007 t I 41000 I 41000 I 0.-416 I $1; , 036 I
I I I t I I t I
I 19 I 2008 I , 41000 t 41000 I 0.396 I $16,225 I
" , " I I I
I 20 I 2009 I I 41000 I 41000 I 0.377 I U5, 452 I
I I , I I I I I
I 21 I 2010 I I 41000 I .nOOO I 0.359 I $14,717 I
I I I I I I I I
I 22 I 2011 ' I 41000 I 41000 I 0.342 I SH,016 I
I I I ' I I I I
I 23 I 2012 I I 41000 I 41000 I 0.326 I $13,348 I
I I I I I I I I
I 24 I 2013 I I 41000 I 41000 I 0.310 I $12,713 I
I I I I I I I I
I 25 I 2014 I I 41000 I oBOOO I 0.295 I $12,107 I
I I I I I I I I
I 26 I 2015 I I 41000 I 41000 I 0.281 I $11,531 I
I I I I I I I I
I 27 I 2016 I I 41000 I 41000 I 0.268 I S10,982 I
I ' I I I , I I
I 28 I 2017 I I 41000 I 41000 I 0.255 I S10,459 I
I I I I ' I , I
I 29 I 2018 I I 41000 I -41000 I 0.243 I S9,961 I
I I I I I I I I
I 30 ' 2019 I I 41000 I 41000 I 0.231 I $9,486 I
I I I I I I I I
=====================================================================
S42,346,398
A-12
-------
Table AJ. 1.
cor:tinued
THiS TABLE ~iLL CALClL~7E ?RES~XT ~ORTH VAL~ES
DISCQL'~T ;tHe: (:;J, c..:.PIT":'L CaSTS .:"~:D 0&:,1 caSTS
q F' EX ?=:~:D ITeR S
?~OjSCT: O?£RA3LE eXIT I, Alt~~n~li~e 2
~';': E:\ G; rEX;
I~: TilE Y:::.~il
?RES~~T ~ORTH CALCULATION TARLe:
~=
5 :
21 years
Si.';~T DAT£
E~D DA7E:
! =89
2019
t=
?R:::S£~;T h'ORTH =
S59,a:J3,850
A
Y:::A~
3
CAPiTAL
C;JST
C
0&:01
C;JSiS
D
A~SVAl ~ISCOU~T
SA rE:~D J TURE:S F":'CTORS:8:
3+C : (1/1+: )~t:
t'
..
.
CCS1'
?~:::s::~;~
OC':C:1S :
""nRTH
Dz:;:
=====================================================================
I I I I
I I I I
0 ' :9ag 0 I 1.000 I ::J '
I I , I
. I 1990 ' 0 I 0.952 ' 50 I
L I I " I
'" ; s:! I 0 I 0.90; sa I
I I I I
.. I ~=92 ::!5JOOCO I 21600000 ' 0.36'; :S!8.552.S;Z '
~ I ,
. I 13g3 :Z:500000 :~SOOOOO I 0 ....~ I~. - ~-,,,,, ~":"""
r I .~..;~ I.' J. ( 1 j I .. ! '-II ..j ,
5 I 199-4 :2:500000 I I 21500000 I 0.i8-t I ~ , ," r; ':" .....:
' I , I I"".:')'__~'.~"""
0 I .. :~o - :::500000 I I ::: 1600eJOO I O.~~5 :S:5~1~31:.~~ I
I j':_~ I I I I
; I :995 I I ';:000 I ~1000 I O. i 11 ":' 1'\ -: ~ ~.... I
I , I , I ~ -.... , . ""'~ ,
a I -.........- I r ~~aoo I ~~CoO I 0.57;" 5:7,7:0 '
I .:..:., I I I I I I
3 I 1993 I I ';1000 I ';1000 I 0.645 I <::""""Q '
I I I I , I ..;.:)....:.. I
~O I 1999 I I ';10CO I ';1~00 I 0.61'; I S25t~7J '
I , I I I r
11 ' 2000 I , 41 000 I ';1000 I 0.333 I ~.,.. ~-... ,
' " I I ~-..;.,_:.;.
,? I 2001 4!000 I ~lQQO I I n ...~ I 522, :~'j r
.. I I I -. ~;) I I I
13 I 2002 I 41000 I ';1000 I 0.530 I S:l, -.~ I
I I I I I I.. J I
.. I ZaOJ I ~l~f.:O I 41000 I 0.::5 I $:0.723 I
~.. I I I I , ,
13 I :CC~ I 41000 I ';1000 I 0.';81 I ..U -"",.. ,
" I I I ;:).i.. t ' ~.. I
16 I 2005 I 41000 I 41000 I 0.';53 I c: ... -.. I
I I I I ' ..10, I ~,J ,
11 I Z006 I 41000 I ';1000 ' 0.'+36 I S1it.~nR r
I I , I I I
1 3 I ~1j0 i I ~]OOO I ';]000 I O. ~ Hi ::17,005 I
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19 I :008 I 41000 ' 41000 I 0.39~ I $16,2:5 I
I I , I I
20 ' :009 I I -tl oeo I ';1000 I O.37i I co ,.: ,:.., I
I I I I I , ......' t ., oJ..
21 ' ZO!O ' I 410CO I 41000 I O. 3.~~ I <- ,!, -. ~ I
I , I I I I -. Of . . . i I
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I I " I ..J.;... I I
2.; I za13 I I 4~OOO I ~1000 I 0.310 I 512,713 I
I I I I I I I
.... I 2a1~ I , 41000 I 41000 I 0.195 I s 12, :0; I
~;) I I I I I I
2~ I 2015 I I ~1000 I 41000 I 0.28] I S11,5J1
I I I I I I
21 I Z016 ' I ';1000 ' 41000 I o.zsa I S10.98: '
I I I I I I I
23 I 201 i I , 410CO I ';1000 I 0.253 I $]0,';53 I
I I I I I I ,
"Q I 2018 ' I HOOO ' 41000 ' 0.2';3 I $~,96i '
.... I I I I , ,
30 I 2019 I , ';1000 I 41000 I 0.231 I S9,48G '
I , " I I I I
---------------------------------------------------------------------
---------------------------------------------------------------------
S59,393!a~o
A-13
-------
R.S. Means. which is a primary data source of construction costs. breaks COSts
into labor. equipment. and material. The unit costs shown in the cost
estimates consist of the total of labor. equipment. and material with ~verhead
percentages determined by R.S. Means data. For our purposes. the cost
estimates are to be in the +50 to -30 percent range. Unit costs are the level
of detail required.
3h) The costs for hauling tailings to an alternate site would most likely
subcontract. and it is not apparent why they should be subject to the
indirect and overhead costs. Similarly. the costs for hauling clean
material for the restoration of Montezuma Creek floodplain do not
recognize the obvious economies of scale resulting from the trucks
returning empty from the receiving repository.
be a
same
For the level of effort required. all construction costs were burdened by the
same indirect and overhead costs. There is no need to break the construction
costs out by subcontracts. The indirect and overhead costs would change by
an insignificant amount. There may be some savings by hauling clean backfill
back to Montezuma Creek. but because of all the unknowns (e.g.. truck
decontamination needs. suitability and location of fill material. etc.) the
conservative approach was taken.
4)
Several comments were received regarding the methods and
for active ground-water treatment and whether downstream
been fully considered.
time required
impacts had
DOE RESPONSE: Throughout construction of Operable Units I/II. a ground-
water monitoring progr~~ of the alluvial and Burro Canyon aquifers and
Montezuma Creek will b. conducted. This monitoring program will continue
for three years after "3moval of the contaminated material. As monitoring
continues during the three year period. DOE. EPA. and the State of Utah
will periodically review the results of the monitoring data and determine
what additional steps. if any. will be required to complete aquifer- and
surface-water restoration. When sufficient data has been gathered to
warrant a final decision for restoration. a Record of Decision will be
prepared for Operable Unit III.
Institutional controls may be implemented prior to
Units I and II. These controls will be maintained
compliance with the prevailing standards.
remediation of Operable
until the aquifer is in
Although there are traces of contamination found downstream in the
Montezuma Canyon area of Montezuma Creek. constituents do not exceed
water-quality standards to the nearest water user downstream of the
canyon.
4.0
REMAINING CONCERNS
All written and oral public concerns were addressed at the public
meetings and/or within this Responsiveness Summary. Written comments
received from the EPA and the State during the public comment period
have been addressed in this Responsiveness Summary and incorporated into
the Record of Decision. or added as errata to the Final MRAP RI/FS.
There are no remaining concerns left unaddressed.
A-14
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ATTACHMENT TO APPENDIX A
COMMUNITY RELATIONS ACTIVITIES
FOR THE MONTICELLO MILL TAILINGS
SUPERFUND SITE
January 1990
Community relations activities conducted on behalf of the Monticello Mill
Tailings Superfund Site to date have included the following:
Site visits and meetings between the DOE. the Remedial Action Contracto=
(RAC). the Monticello City Manager. San Juan County Commissioners. State
of Utah representatives. and individual property owners. (1980)
News releases on the beginning of the vicinity property cleanup program
and the results of generalized radiologic assessments and survey
activities. (1980)
General information briefings by DOE to the local news media. Utah Stat~
Bureau of Radiation and Occupational Health. and the S.E. Utah District
Health Department.
Issued a fact sheet on the Monticello Uranium Mill tailings.
(1982)
Maintained close contact with the State of Utah Governor. State Division
of Environmental Health. and State Department of Natural Resources and
Energy. (1982)
Participated in San Juan County Board of Commissioners meeting to provide
an update on the DOE's Surplus Facilities Management Program (SFMP) plan
for Monticello clean up. (1982)
Maintained ongoing communications with city and county officials.
(1983)
Met with State officials and the San Juan County Board of Commissioners
to discuss continuation of the Monticello Millsite (MRAP) and Vicinity
Properties (MVP) programs and to outline program milestones. (1984)
Worked with the San Juan Record on a major article summarizing clean-up
activities during 1985. including the Superfund clean-up program. (1986)
Conducted community interviews with local officials and affected
residents. (1986)
Prepared a draft community relations plan.
(May 1987)
Maintained ongoing discussions between EPA. DOE. the State. San Juan
County. and. the City of Monticello during the negotiation of the Federal
Facilities Agreement. (1988)
A-1S
-------
Issued a press release announcing a public meeting to discuss the Federal
Facilities Agreement (FFA). A public comment period from February 9
through February 20. 1989 was provided. (January 27. 1989)
Conducted a Health and Safety training workshop for those involved
Monticello Vicinity Properties clean up. Included in the training
representatives from the State of Utah and the City of Monticello.
(March 1989)
in the
were
Established an Information Repository and the Administrative Record at
the San Juan County Library. (June 28. 1989)
Conducted special briefings for the Monticello City Council and the San
Juan County Commissioners on the DOE 5-Year Environmental Restoration and
Waste ~anagement Plan. (October & November 1989)
Provided public review copies of the RI/FS and ?roposed Plan for the
Monticello Millsite to the Administrative Record and Information
Repository locations. (October 27. 1989)
Developed and distributed a S-page information update on the MRAP
Superfund site. (November 1989)
Published two Notices of Opportunity to Comment in the local newspaper.
A public comment period from October 27 through November 25. 1989 was
provided. (October 25 and November 15. 1989)
.
Conducted a public meeting in Monticello on November 16. 1989 to describe
the work plan contents and to respond to questions. Twenty-eight people
attended. including the Monticello~yor. city manager. representatives
from the City Council. a representa:ive for U.S. Senator Jake Garn and
U.S. Representative Howard Nielson. the San Juan County District
sanitarian. representatives from the State of Utah Department of Health.
and members of the public. A transcript of the meeting. including all
questions and answers. is available as part of the Administrative Record
at the San Juan County Library. (November 1989)
.
Issued a press release on the addition of the Monticello site to the
Superfund National Priority List (NPL). (November 1989)
A-16
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APPENDIX B
FEDERAL AND STATE OF UTAH
APPLICABLE OR RELEVANT AND.
APPROPRIATE REQUIREMENTS
~
-------
APPENDIX B
FEDERAL AND STATE OF UTAH APPLICABLE OR
RELEVANT AND APPROPRIATE REQUIREMENTS
The following applicable or relevant and appropriate requirements for Operable
Units I and II have been identified. Applicable or relevant a~d appropriate
requirements for the remediation of Operable Unit III will be defined during
development of the ground-water and surface-water Record of Decision.
The regulations affecting radioactive materials as promulgated in 40 CFR Pa=t
192 and as proposed in the "Standards for Remedial Actions at Inactive Uranium
Processing Sites with Ground-Water Contamination" (52 FR 36000. September 2~.
1987). are appropriate to the specific characteristics of radioactive
materials that exist at the site. Review and analysis of the major provisions
within 40 CFR Part 192 indicate that they are functionally equivalent to and
are more protective than potentially "relevant and appropriate" nonradioactive
hazardous waste requirements of the Resource Conservation and Recovery'Act.
Subtitle C. The technological standards presently incorporated into 40 CFR
Part 192 and the proposed rule. "Standards for Remedial Actions at Inactive
Uranium Processing Sites with Ground-Water Contamination" provide sufficient
protective conditions to make the determination that additional Resource
Conservation and Recovery Act. Subtitle C. regulations are neither "relevant
or appropriate." provided that the Department of Energy continues to
incorporate the provisions of the proposed rule in the remedial action of the
Monticello millsite.
If hazardous wastes are encountered on site. they shall be remediated and
disposed of in accordance with the Resource Conservation and Recovery Act and
any other applicable regulations.
B-1
-------
Table B. I. Applicable or Relevan~ and Appropriate Requl rements (ARARs):
Federal Standards. Criteria. and Limitations
Standard. Requiremen~.
Criteria. or Limita~ion
Cita~ion
Descr1p~ion
Safe Drinking Wa~er Act
42 USC 300g
40 CFR Part 141
Establishes health based
standards for public water
sys~ems (maximum contaminant
leve16) .
National Primary
Drinking Water
Standa rds
National Secondary
Drinking Water
Standards
40 CFR Part 143
Establishes welfare-based
standards for public water
sys~ems (secondary maximum
contaminen~ levels).
Clean Wa~er Ac~
J) USC 12~1.1376
Water Quality Criter1a
40 CFR Part 131
Quality Criteria
for Water. 1986
Sets criteria for sta~es to
set water quality standards
based on ~oxicity to aquatic
organisms and human health.
Dredge or Fill
Requirements
(Section 404)
40 CFR Parts 230.
231: J) CFR Part
323
Requires permits for dis
charge of dredged or f111
material 1nto navigable
waters.
Clean Air Act
42 USC 7401.7462
National Primary and
Secondary Ambient Air
Quality Standards
40 CFR Part ~O
Establishes standards for
ambient air quality to pro.
tect public heahh and wel.
fare (includes standards for
particulate matter and lead).
Status
Comment
Neither appli-
cable nor rele
vant and appro
priate for OU I
and OU 11 -
May be an ARAR for OUlll
ground and surface water.
Neither appll.
cable nor rela.
vant and appro.
priate for OUI
and OUII.
May be an ARAR for OUIII
ground and surface water.
Applicable
(chemical'
specif1c)
See Title 2b. Chapter II.
U.C.A. (State of Utah).
Applicable
(location.
spec i f i c)
for both
OUI and OU11.
Discharge of dredged or
fill material into navi.
gable waters or wetlands may
Occur dur1ng construction and
remedial action on Montezuma
Creek.
Applicable
(contaminant
specific)
federal standards are
applicable. but are Imple
mented through the air
program of the State of
Utah. See Title 2b.
Chapler 13. U.C.A.
-------
Table R-l (continued). Applicable or Relevant and Appropriate Requirements (AltARs):
Federal Standards. Criteria. and Limitations
Standard. Requirement.
Criteria. or Limitation
Ci tation
Description
Comment
National Emission
Standards for Radon
Emissions from
Department of Energy
Facilities
40 CFR Pa rt 61
Subpa rt Q
Standards for the design and
operation of all storage and
disposal facilities for
radium-containing materials.
Resource Conservation and
Recovery Act (RCRA)
RCRA requirements for treat-
ment. storage. or disposal of
hazardous waste apply to a
Superfund site if the site
contains RCRA listed or char
acteristic hazardous waste
that was treated or disposed
of after the effective date of
the RCRA regulations that are
under consideration as potential
ARARs for the site. or if the
CERCLA activity at the site
constitutes current treatment.
storage. or disposal of ReRA
hazardous waste.
42 U.S.C. 6901
40 CFR Part8 260-
280
Uranium Hill Tailings
Radiation Control Act
42 use 2022.
42 USC 7901.1942
40 CFR Part 192
Establishes health-based
standards fur control of
residual radioactive mate-
rials from inactive uranium
processing sites and health-
based standards for clean up
of lands and buildings
having radioactive materials
from inactive uranium pro-
cessing sites.
Status
Applicable
(chemical-
specific) for
QUI. Relevant
and appropriate
(contaminant-
specific) for
QUI I.
Nei ther appli-
cable nor
relevant and
appropriate
for QUI and
QUI 1 -
Relevant and
appropriate
(action-specific
and contaminant-
speci fie) for
QUI and QUI I.
Characterization at the
Monticello mill tailings
site shows that no ReRA
listed or characteristic
hazardous waste was
treated or disposed of at
the site and no treatment.
storage. or disposal of a
RCRA hazard'ous waste Is
taking or has taken place.
Should nonexempt waste
be discovered on site
during remedial actions
RCItA may be an ARAR.
Also establishes
supplemental standards
for performing remedial
actions that come as
close to meeting the
otherwise applicable
standard as is
reasonable under the
circumstances.
-------
Table 5.1 (continued). Applicable or Relevant and Appropriate Requlremenu; (ARARs):
federal Standards. Criteria. and Limitations
Standard. Requirement.
Criteria. or Limitation
Citation
Description
Comment
Occupational Safety and
Health Act
29 USC 6~1-618
29 CFR 1910.96
29 CFR 1926.~8
Regulates worker health and
safety.
National Historic Preser'
vation Act
16 USC 410
40 CFR 6.301!b)
Requires Federal agencies to
take into account the effect
of any Federally-assisted
undertaking or licensing on a
structure or object that is
included on or eligible for the
National Register of Historic
Places.
Archaeological and
Historic Preservation
Act
16 use 469
40 eFR 6.301(c)
Establishes procedures to
provide for preservation of
historical and archaeological
data which might be destroyed
through alteration of terrain
as a result of a Federal con-
struction project or a
federally licensed activity
or program.
fish and Wildlife
Coordination Act
16 use b61-6b6
40 efR 6.302(g)
Requires consultation when a
federal department or agency
proposes or authorizes any
modification of any str'eilm or
other looter body; requires
adequate provisions for protec'
tion of fish and wildlife
resuurces.
Status
Applicable
(action' specific
and contaminant
specific) for
OUI and QUI I.
Applicable
(lociltion-
speet fic) for
QUI I.
Applicahle
(location-
specific) for
OUI.
Relevant and
appropriate
( location-
sl,eciflc) for
OUI.
c.
l)
Under 40 CFR 300.38.
requirements of this Act
apply to all response
ilctlvlties under the
NCP. These requirements
incorporate the radiation
exp,)sure I Jm! ts of 40 CFR
Part 20. The asbestos
health stilndards are also
addressed by this Act.
Implemented by Utah Law.
Title 35. Chapter 9.
U.C.A.; R500. U.A.C.
Applicable for OUll1
ground and surface water.
Applicable for 011111
ground and surface water.
Mudification of Montezumil
Creek channel during
construction may result
in te~porary habitat JOGS
for fish and wildlife spe, Ie"
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Table B-1 (continued). Applicable or Relevanl and Apprupriate Hequirernent:; (AHARs):
Federal Standards, Cr.iteria, and l.imitations
Standard, Requirement,
Criteria, or Limitation
Citation
Description
COmm~(ll
Endangered Species Act
1531-1 ~43
Parts 11,
CFR 6.302
Requires that Federal agen-
cies ensure that any action
authorized, funded, or car-
ried out by such agencies is
not likely to jeopardize the
continued existence of any
threatened or endangered.
species or destroy or adversely
modify critical habitat.
16 USC
50 CFR
402 40
(h)
Farmland Protection
Policy Act
1 usc 4201
1 CFR Part 658
Standards and criteria for
identifying and taking into
account adverse effects of
an agency's actions on
significant and important
agricultural lands.
Standards for Protection
Against Radiation
10 CFR Pact 61
Standards for worker
health and safety with
regard to radiation exposure
levels.
Statement of Procedures
on Floodplain Management
40 Cf'R Part 6
Appendix H
Establishes agency policy
and guidance for carryir.g
out the provisions of
Executive Orders 11988
"Floodplain Management" and
11990 "Protection of Wetlands."
Status
Neither applicaole
or rei evant and
appropriate for
OUI and OUIl.
Applicable
(l ocat ion-
specific) for
OUI and OUII.
Applicable
(action-
specific and
contaminant-
speci f i c) for
both OUI and
OUll .
Applicable
(location-specfic)
for OUI and OUII.
Threatened or endangered
5 pc c i c 5 0 r c [ i t i (; a 1 h d b i 1 oJ t
are not present in OUI or
OUII. Potentiallyapplicdblc
fur OUIIl.
The U.S. Soil Cunservation
Service has determined
that the proposed repository
area is not prime, unique or
important farmland.
Potentially applicable to
OUI II.
The r."qui rerr.ents of the
Federal Occupational Safety
and Health Act are implemented
by Utah Law, Title 3'>,
Ch.lpter 9. U.C.A.; R'>OO. U.A.C.
including the radiation
exposure levels.
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'--
Table B-2- Applicable ur Relevant and Appropriate Nequirement~ (AHAH~):
State of Utah Standal-d~. Criteria. and LimitaljuII~
Standard. Requirement.
Criteria. or Limitation
Citation
Description
Cornmellt
Procedures for licensin~
well drillers and water-
well drilling standards ,-
standards for drilling.
construction. and abandon-
ment of wells.
7)-)-25. U.C.A
R625-4. U.A.C.
Performance standards for
casing joints. requirements
for abandoning water wells.
Relocation of Natural
Streams - - proLedures
and standards governing
rechanneling of stream
beds.
7)-)-29. U.C.A
R625-5. U.A.C.
Regulates activities involving
the State's natural streams.
Protection of Archaeologi~al.
Anthropological.
Paleontological. Historic.
and Cultural Resources
Title 6).
Chapter 18. U.C.A.
R224. U.A.C.
Utah Code Anotated. Section
6)-18-18 declares a le~isla-
tive interest in the preser-
vation of archaeological.
anthropological. and paleon-
tological resources. The
purpose of the Act is to preserve
these resources for the general
welfare of the public. The
statutes and rules require a review
by the Division of State History
prior to disturbing state lands
which may effect archaeological.
anthropological. paleontological.
historic. and cultural sites.
Utah Occupational
Safety and Health Standards
Title )5.
Chapter 9. U.C.A.;
R500. U.A.C.
Utah Code Anotated. Section ))-9- I
is entitled the Utah Occupational
Safety and Health Act. Implements.
establishes. and enforces OCcupa-
tional health and safety standards
similar to the Federal OSHA
regulations. Incorporates radiation
exposure limits promulgated at
10 CFR 20.
Definitions for Water
Pollution Rules and
Ceneral Requirements
Title 26.
Chapter 11. U.C.A.;
R448-1. U.A.C.
Till ~ ~tatute and rules set fOI-th
the definitiuns and general require-
ments for Title 26. Chapter il.
U.C.A.. R44B-2. 6. and B. U.A.r..
Status
Appl icable
(acUon-
specific) to
OUI.
Division of loIater Rights
governs. Applies to
repository monitoring
wells and abandonment
of mJllsite wells.
Applicable
to OUI (act ion-
and location-
specific).
DivJsion of loIater Rights
governs - Appl ies to
diversioll of Montezuma
Creek during millslte
remediation. Relocation of
Natural Streams -- proce-
dures and ~tandard~ govern-
ing rechallneling of stream
beds.
AI-I- " hie
to OU1 "',
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Table B-2 (continued). Applicable or Relevant and Appropriate Requirements (ARARs):
State of Utah Standards. Criteria. and Limitations
Standard. Requirement.
Criteria. or Limitation
Citation
Description
Status
Comment
Division of Environmental
lIealth governs.
Standards for Quality
for Water of the State
Title 26.
Chapter 11. U.C.A.;
R448-2. U.A.C.
Ground Water Protection
Title 26.
Chapter 11. U.C.A.;
R448-6. U.A.C.
Utah Pollution Discharge
Elimination System
Title 26.
Chapter 11. U.C.A.;
R448-8. U.A.C.
Utah Air Conservation
Act and Rules
Title 26.
Chapter 13. U.C.A.;
R446. 1. U. A . C .
These rules are specific to Utah
waters. though they are derived
in part by using Federal
criteria. See particularly the
non-degradation policy R448 2 )-
The Bureau of Water Pollution
Control. in cooperation with
other bureaus in the Division.
has promulgated ground'water
protection standards. There is
no corresponding federal program.
The Bureau of Water Pollution
Control. in cooperation with
other bureaus in the Division.
has promulgated standards for
surface and underground
discharges of water; compatible
with the Federal regulation adopted
pursuant to the Clean Water Act.
These rules are substantively
similar to corresponding
federal regulation. with the
following exceptions; RIo46-1-1.2~.
and R4106- I'). 1.8. which require
application of best available
control technology for any source;
R446-1').ll. which lists criteria
to be considered in establishing
visibility standards; R446.1.4.1.
which sets visible emission standards:
R446- 1-4.). which regulates fugitive
dust emissions; and R446'1-).1. which
allows the State to require temporary
closure of air pollution sources in
the event of an air pollution
emergency episode. These rules are
applicable specifically regarding
fugitive dust emission from remedial
action activities.
Applicable to
QUI and QUI I
(contaminant-
specific) .
Applicable to
QUI (action.
specific) .
Division of Environmental
Health governs.
Applicable to QUI
(action-specific) .
Division of Environmental
Health governs. Applicable
to any discharge to Montezuma
Creek
Applicable to QUI
and QUII (action'
speci fie) .
Division of Environmental
lIealth governs. Applicable
to fugitive dust emissions
from remediation activities.
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